Bogor, 17 Juli 2023

REGULATORY COMPLIANCE

In connection with Religious Allowance, as a non-salary income that must be paid by business actors to workers/laborers or their families prior to Religious Holiday. We found a number of things that need to be a concern, this
is important in order to avoid legal problems that can cause losses to the company in the future.

Currently, the rules for Religious Allowance or Tunjangan Hari Raya (“THR”) refer to the Regulation of the Minister of Manpower 6/2016. Meanwhile, regulations in the form of laws such as Law 13/2003 and Perppu
2/2022 which has been passed into law on March 21, 2023, do not specifically regulate Religious Allowance for employees.

Therefore our company should comply to the provisions Regulation of Minister of Manpower 6/2016. Herewith we provide the compliance analysis in the following table that contain provision of the Minister Regulation, our
Company Regulation and actual realization in our company.

No. Content Regulation of the Minister of Manpower Company Regulation Actual Realization
6/2016
1. Calculation Of Holiday Allowance Article 3 Article 18 Paragraph 1 Different
Workers/laborers who have a service term of 12 1 month of fixed salary for the Employee who has
(twelve) months consecutively or more, shall be reach 1 year service period or more.
granted in the amount of 1 (one) monthly salary;

Article 4 Article 18 Paraghraph 2

Workers/laborers who have service term 1 (one) If the lenght of service is 1 month or more but less
month consecutively, but less than 12 (twelve) than 12 months, will receive THR based on the
months, shall be granted proportionally in following calculation:
accordance with the service term by using the
following calculation:

(service term)/12 x 1 (one) monthly salary. Length of Service (Month) / 12 x Fixed Salary

2. Monthly Salary Defenition Article 3 Paragraph 2 Article 1 Paragraph 16 The calculation is only done based on the amount of base
salary.
Salary which is the clean salary; Fixed Salary is Basic Salary plus Fixed Allowances.
Or basic salary, including fixed allowance.

3.

Sanctions for Entrepreneurs If They Do Not Pay Full THR

Permenaker 6/2016 stipulates provisions for sanctions if the entrepreneur does not pay THR 1 time in 1 year and if the THR payment is not in accordance with the provisions. The sanctions in question are administrative
sanctions.

Regarding further administrative sanctions, sanctions that can be imposed include:[6]

- Written warning;
- Restrictions on business activities;
- Temporary suspension of part or all of the means of production; And
- Suspension of business.