Part A: Shareholders' Rights

Part Concerns Implementation Reference
A.1 Basic Rights of Shareholders
A.1.1 Does the company pay dividends (interim and final/annual) in a fair and timely manner; that is, all shareholders are treated equally and paid within 30 days after (i) declared for interim dividends and (ii) approved by shareholders at the GMS for final dividends. If the company has offered a script dividend, does the company pay the dividend within 60 days? Astragraphia distributes dividends within 30 days after the announcement of the interim dividend and approval of the shareholders at the GMS for the interim dividend.
A.2 Right to Participate in Decisions Regarding Company Fundamental Changes
  Do shareholders have the right to participate in:
A.2.1 Amendment to the Company's Articles of Association? Shareholders have the right to participate in changes to the Company's Articles of Association through the GMS, as stated in Article 26 of Astragraphia's Articles of Association.
A.2.2 Approval of additional shares? Shareholders have the right to participate in the approval of additional shares, as stated in Article 4 of Astragraphia's Articles of Association.
A.2.3 Transfer of all or substantially all assets, impacting the sale of the company? Shareholders have the right to substantially participate in the transfer of assets, as stated in Article 18 of Astragraphia's Articles of Association.
A.3 The Right to Participate Effectively and Vote in the GMS and to Receive Information on the GMS Rules of Conduct, including Voting Procedures
A.3.1 Do shareholders have an opportunity as evidenced in the agenda of the meeting to approve remuneration (salaries, allowances, allowances in kind and others) or increase in remuneration for non-executive Directors/Commissioners? Do shareholders have an opportunity as evidenced in the agenda of the meeting to approve remuneration (salaries, allowances, allowances in kind and others) or increase in remuneration for non-executive Directors/Commissioners? The GMS has the authority to approve the remuneration for the Board of Commissioners and the Board of Directors.
A.3.2 Does the company give rights to minority shareholders to nominate candidates for members of the Board of Directors/Board of Commissioners? Approval of remuneration for Astragraphia's Board of Commissioners and Directors is included in the agenda of the 4th AGMS 2022
A.3.3 Does the company give shareholders the right to choose the Directors/Board of Commissioners individually? Astragraphia grants minority shareholders the right to nominate the Board of Directors or the Board of Commissioners which can be submitted by Shareholders to the Nomination and Remuneration Committee without distinguishing between majority and minority shareholders.
A.3.4 Does the company inform the voting procedure to be used before the meeting starts? Astragraphia discloses the voting procedures at the GMS which are contained in the Meeting Rules published on the same day as the GMS summons.
A.3.5 Do the minutes of the last GMS record that shareholders are given the opportunity to ask questions and questions raised by shareholders and the answers are recorded? The meeting rules and regulations were also read before the GMS was opened.
A.3.6 Does the company disclose the voting results which include votes in favor, disagree, and abstention for each GMS agenda? Shareholders are given the opportunity to ask questions at the GMS and to be recorded in the Minutes of the Meeting.
A.3.7 Does the company disclose the list of members of the Board of Commissioners and Board of Directors who attended the most recent GMS? Astragraphia discloses the voting results for each agenda and is recorded in the Minutes of the Meeting.
A.3.8 Does the company disclose that all members of the Board of Commissioners/Directors including the CEO (if he is not a member of the Board of Commissioners/Directors) to attend the most recent GMS? Astragraphia discloses the Attendance List for the Board of Commissioners and the Board of Directors and is recorded in the Minutes of Meeting.
A.3.9 Does the Company allow voting for those who are not present? In voting, the votes cast by the shareholders apply to all the shares they own, and the shareholders are not entitled to give power of attorney to more than one proxy for a portion of the number of shares they own with different votes. Voting by Shareholders who are not present cannot be carried out unless represented. If the shareholder has cast his vote electronically before the GMS is held, then according to POJK 16/2020, the shareholder is considered valid to attend the GMS.
A.3.10 Does the company use the voting method by voting (as opposed to raising hand) in making decisions at the most recent GMS? In the implementation of voting, each share gives its holder to cast 1 (one) vote and the voting procedure is regulated in the meeting rules.
A.3.11 Does the Company disclose the appointment of an independent party to count and/or validate the Votes? Astragraphia discloses the appointment of independent parties to count and/or validate the votes, namely the Notary and the Securities Administration Bureau and the Notary as stated in the GMS summons and the Minutes of Meeting.
A.3.12 Does the company announce to the public on the next working day the voting results for all meeting decisions at the latest GMS/EGMS? Astragraphia discloses the results of the GMS decision to the public 1 working day after the GMS, through the IDX website, eASY.KSEI, and the Astragraphia website.
A.3.13 Does the company carry out the summons no later than 21 days before the AGMS and EGMS? Astragraphia wil carry out the summons of the GMS 21 days before the GMS is held.
A.3.14 Does the company provide reasons and explanations for every item on the agenda that requires shareholder approval in the GMS notification and/or accompanying statement? Astragraphia provides explanations for each meeting agenda.
A.3.15 Does the company provide an opportunity for shareholders to propose an agenda at the GMS? In the agenda of the Annual GMS, proposals submitted by the Shareholders or more that represent at least 1/20 (one-twentieth) of the total number of shares issued by the Company with valid voting rights may be stated. , provided that the proposal in question must be received by the Board of Directors no later than 7 (seven) days prior to the summons for the Annual GMS and must be made in good faith, taking into account the interests of the Company, including the reasons and materials for the proposed agenda of the meeting, and not contradicting the laws and regulations. invitation.
A.4 The Market Can Monitor Companies Efficiently and Transparently
A.4.1 In the case of a business merger or takeover that requires shareholder approval, does the Board of Directors or the Board of Commissioners appoint an independent party to evaluate the fairness of the transaction? Astragraphia is obliged to comply with the Company Law and applicable capital market regulations regarding business combinations or takeovers.  
A.5 The Implementation of Share Ownership Rights by Shareholders Including Institutional Investors Must be Facilitated
A.5.1 Does the company disclose ways to encourage shareholders to attend the AGM and engage with the Company? Astragraphia is always committed to providing fast and accurate information for shareholders so that it can assist capital market players in the investment decision-making process in the Company. The Company established an Investor Relations work unit and a Corporate Secretary as PIC.

Part B: Equal Treatment to Shareholders

Part Concerns Implementation Reference
B.1 Share and Voting Right
B.1.1 Do the company's common stock have a vote which is one vote per share? In the implementation of voting, each share gives its holder to cast 1 (one) vote, as referred to in Article 16 of Astragraphia’s Articles of Association.
B.1.2 Does the company publish the voting rights attached to the class of stock (for example, via the company website or reports or stock exchanges or regulator websites)? Astragraphia only recognizes a person or 1 legal entity as the owner of 1 share, namely the person or legal entity whose name is registered as the owner of the share concerned in the Company's Shareholders Register.
B.2 GMS Invitation
B.2.1 Is every decision at the most recent GMS only for one thing per decision? For example, there is no one decision for some things. Each meeting agenda decision is not related to other agenda decisions.
B.2.2 Is the last GMS invitation translated into English and published on the same day as the Bahasa (Indonesian) version? The invitation for the Astragraphia GMS is available in Indonesian and English which are published on the same day as stipulated in Article 52 paragraph (1) of POJK 15/2020.
B.2.3 Is there any Director/Commissioner profile information (such as age, educational qualification, date of appointment, experience and position in other public companies) in the appointment/re-appointment? Astragraphia discloses the profiles of the Board of Directors and Board of Commissioners who will be appointed or reappointed in the agenda of the GMS.
B.2.4 Is the auditor to be appointed/re-appointed clearly identified? Astragraphia disclosed information regarding the appointment of a Public Accounting Firm.
B.2.5 Are Power of Attorney documents easily accessible? The Power of Attorney document from the Shareholders can be downloaded on the Astragraphia website and can be obtained at the designated BAE office during business hours.
B.3 Insider trading and non-compliance will be prohibited
B.3.1 Does the company have a Policy and/or stipulate a prohibition for Directors/Commissioners and their employees to use information that is not yet available to the public? Astragraphia employees including Directors and Commissioners who possess confidential information are prohibited from misusing such information for personal gain, family or other third parties.
B.3.2 Are the directors/ commissioners of the company required to report their transactions on company shares within 3 (three) working days? The Board of Directors and/or the Board of Commissioners are required to report their share ownership in the Company to OJK no later than 3 calendar days after the occurrence of ownership or any change of ownership.
B.4 Transactions with Related Parties by the Board of Directors and Senior Management
B.4.1 Does the company have a policy that requires Directors/Commissioners to inform their interests in transactions and other conflicts of interest? Astragraphia has Guidelines regarding Affiliated Transactions and Conflicts of Interest.
B.4.2 Does the company have a policy that requires a Committee of Independent Directors/Commissioners to review material transactions with related parties, to determine whether these transactions are for the benefit of the company and shareholders? The Corporate Secretary & Legal Department will evaluate the information on the Affiliated Transaction plan, if the value is greater than 0.5% of the Company's paid-up capital or exceeds the amount of Rp. 5,000,000,000, it must use an independent appraiser registered with the Financial Services Authority.
B.4.3 Does the company have a policy that requires members of the Board of Directors/Board of Commissioners not to participate in discussions on meeting agendas in which they have an interest? The Board of Directors/Board of Commissioners who have a conflict of interest will not have their votes counted in the meeting.
B.4.4 Does the company have a policy regarding loans to the Board of Directors/Board of Commissioners either prohibiting them or ensuring that they are enforced on a fair and customary basis at market prices? Every affiliate transaction must be carried out in accordance with the provisions of generally accepted business practices and comply with the arms-length principle.
B.5 Protecting Minority Shareholders from Unlawful Actions
B.5.1 Does the company disclose that transactions with related parties are conducted fairly and on an arm's length basis? Every affiliate transaction must be carried out in accordance with the provisions of generally accepted business practices and comply with the arms-length principle.
B.5.2 In the event that there is a transaction with a related party that requires shareholder approval, is the decision taken by a shareholder who has no interest? Conflict of interest transactions that require GMS approval are taken based on deliberation for consensus or the majority vote of approval from shareholders who do not have a conflict of interest.

Part C: Stakeholder Role

Part Concerns Implementation Reference
C.1 The rights of stakeholders that arise based on legislation or based on agreements must be respected
  Does the company disclose its policies and practices regarding:
C.1.1 The existence and scope of the company's efforts to meet customer welfare? Astragraphia is always responsible for products and services and continues to strive to maintain the quality of products and services provided to customers. As a form of responsibility for security, work safety, environmental conditions and customer comfort, in general, Astragraphia always provides responsible services, pre-installation assessments, ensures machine tools meet safety standards on a regular basis, provides continuous education to technicians, and manages waste properly in accordance with applicable regulations.
C.1.2 Supplier/contractor selection procedure?      Astragraphia has a Supplier and/or Vendor Selection Policy which is implemented to ensure that the selection process and evaluation of service procurement at Astragraphia is carried out in an effective, efficient, competitive, fair and reasonable manner, transparent and accountable.
  • Supplier and/or Vendor Selection Policy
C.1.3 The company's efforts to ensure that its value chain is environmentally friendly or consistent with promoting sustainable development? Astragraphia manages the quality of suppliers of goods and services for the company by implementing a supplier management policy that includes the company's operational standard policies in the selection and evaluation process to protect business interests and the rights of business partners by upholding the principle of mutual trust and in harmony with QCDSM (Quality, Cost, Delivery, Safety, Morale) values.
C.1.4 The company's efforts to interact with the communities in which it operates? Astragraphia continues to increase its social contribution towards sustainable development through the implementation of four pillars of social responsibility programs, namely health, education, environment, and entrepreneurship, especially around Astragraphia's business locations.
C.1.5 Company anti-corruption programs and procedures? Astragraphia has policies related to anti-fraud & anti-corruption. Astragraphia regularly organizes Anti-Fraud, Anti-Bribery, and Anti-Corruption training. Training for all management and employees of the company is carried out regularly through a virtual learning system platform.
C.1.6 How are creditors' rights protected?  
C.1.7 Does the company have a separate report/section outlining the company's efforts on environmental/economic and social related issues? Astragraphia has prepared a separate report discussing Astragraphia's contribution in environmental/economic and social management, in the form of a Sustainability Report which can be downloaded on the Astragraphia website.

C.2 Where the interests of stakeholders are protected by law, stakeholders should have the opportunity to obtain effective redress for violations of their rights
C.2.1 Does the company provide contact details through the website or the company's Annual Reports, so that stakeholders (such as customers, suppliers, communities, etc.) can raise concerns and/or complaints about possible violations of their rights? Astragraphia provides contact details through the Astragraphia website and Annual Reports, where stakeholders can submit questions, criticisms and suggestions.
C.3 Mechanisms for employee participation must be developed
C.3.1 Does the company explicitly disclose its policies and practices for the health, safety and welfare of its employees? As a form of Astragraphia's commitment to occupational health and safety, the Directors of Astragraphia formed a team of Health, Safety and Environment Development Committee (P2K3L Team) to ensure that Occupational Health and Safety (K3) is implemented down to the smallest work units. Astragraphia has also implemented ISO 45001 certification which is the standard for implementing occupational health and safety within the Astragraphia company.
C.3.2 Does the company disclose its policies and practices regarding its employee training and development programs? Employee development is carried out both in terms of increasing competence and adjusting employee abilities. Therefore, various activities related to employee development and training are carried out massively and involve employees at all levels and down to the branches. Not only training activities, the company also encourages employee development collectively and individually through various opportunities and media by utilizing various methods and opportunities.
C.3.3 Does the company have a compensation/reward policy based on the company's performance beyond short-term financial measures? For employees who excel and make significant contributions according to their functions, Astragraphia gives appreciation according to the specified criteria. Every year Astragraphia gives the main award for the Peak Achievement Circle to selected outstanding employees.
C.4 Stakeholders, including individual employees and their representatives, must be able to freely communicate concerns about illegal or unethical practices to the Board of Directors and their rights not be compromised by doing so.
C.4.1 Does the company have a whistle blowing policy that contains procedures for complaints by employees and other stakeholders regarding suspected illegal and unethical behavior and provides contact details through the company's website or Annual Reports? Astragraphia maintains a violation reporting mechanism to receive reports of violations of the Company's code of ethics through the units involved in supervision. Any reports of alleged irregularities will be traced and followed up for improvement and prevention of recurrence of similar incidents.
C.4.2 Does the company have policies or procedures in place to protect employees who disclose illegal or unethical behavior from retaliation? Astragraphia provides protection for the whistleblower and will review the report and take the necessary actions. In addition, Astragraphia will take corrective actions that are deemed necessary to prevent the occurrence of similar violations.

Part D: Disclosure and Transparency

Part Concerns Implementation Reference
D.1 Ownership Structure Transparency
D.1.1 Does the shareholding information reveal the identity of the beneficial owners, with 5% or more shareholdings? Astragraphia discloses the identity of beneficial owners, with > 5% shareholding in Annual Reports.
D.1.2 Does the company disclose the direct/indirect ownership of the majority shareholder? Astragraphia discloses the direct/indirect ownership of the majority shareholder in its Annual Reports.
D.1.3 Does the company disclose share ownership by members of the Board of Directors and Board of Commissioners, both directly and indirectly? Astragraphia discloses share ownership by members of the Board of Directors and Board of Commissioners in its Annual Reports.
D.1.4 Does the company disclose share ownership by senior management, either directly/indirectly? Astragraphia discloses share ownership by members of the Board of Directors and Board of Commissioners in its Annual Reports.
D.1.5 Does the company disclose details of holding companies, subsidiaries, associations, joint ventures and special purpose enterprises? Astragraphia discloses details of its parent and subsidiary companies in its Annual Reports.
D.2 Annual Reports’ Quality
  Does the company's Annual Report disclose any of the following:
D.2.1 Company Objectives Astragraphia discloses the Company's vision and mission and future strategies in Annual Reports
D.2.2 Financial Performance Indicators Astragraphia discloses a review of financial performance in the Annual Reports. Quarterly Financial Statements are available on the Astragraphia website.
D.2.3 Non-Financial Performance Indicators Non-financial performance may refer to: ·         Performance review per business segment and subsidiaries·         Human resource review·         Overview of information technology·         Corporate governance·         Social and environmental responsibility
D.2.4 Dividend Policy Astragraphia has a policy to distribute dividends to all shareholders at least once a year, and if financial conditions allowAstragraphia will distribute the interim dividend in the middle of the year. The dividend amount decision takes into account Astragraphia's net profit and financial condition by taking into account the approval of the General Meeting of Shareholders.
D.2.5 Biography (minimum age, educational qualification, date of first appointment, relevant experience and positions in other public companies) of all members of the Board of Directors and Board of Commissioners. Astragraphia discloses the biographies of all members of the Board of Directors and Board of Commissioners in its Annual Reports.
D.2.6 Details of the attendance of each Director/Commissioner in the meetings held. Astragraphia discloses the details of the attendance of each Director and Commissioner in the meetings held in the Annual Reports.
D.2.7 Total remuneration for each member of the Board of Directors and Board of Commissioners. Astragraphia discloses the total remuneration of members of the Board of Directors and Board of Commissioners in its Annual Reports.
  Governance Confirmation Statement
D.2.8 Do the Annual Reports contain statements confirming the company's compliance with corporate governance and if any violations have been identified and the reasons for each issue are explained? Astragraphia discloses a statement regarding the company's compliance with corporate governance in its Annual Reports.
D.3 Disclosure of Transactions with Related Parties
D.3.1 Does the company disclose a policy regarding the review and approval of material related party transactions? Astragraphia has Guidelines related to Affiliated Transactions and Conflicts of Interest which contain a review and approval mechanism for these transactions.
D.3.2 Does the company disclose the name, relationship, nature and value for any material related party transactions? The disclosures referred to are contained in the Company's Financial Statements.
  • Consolidated Financial Statements 2021 (Pg.76-81)
D.4 Directors and Commissioners conduct company share transactions
D.4.1 Does the company disclose trading of company stock by insiders? In accordance with The Board of Directors and the Board of Commissioners' Share Ownership Report Policy, the Board of Directors and/or the Board of Commissioners are required to report their share ownership in the Company to OJK no later than 3 calendar days after ownership or any change in ownership occurs.
D.5 External Auditor and Auditor Report
  If the company appoints the same Public Accounting Firm for audit services and non-audit services
D.5.1 Are audit and non-audit fees disclosed? Information related to audit fees and other services is disclosed in the Annual Reports.
D.5.2 Do Non-Audit fees exceed audit fees? Information related to audit fees and other services is disclosed in the Annual Reports.
D.6 Communication Medium
  Does the company use the following types of communication?
D.6.1 Quarterly Reports Astragraphia uses Quarterly Financial Statements as a medium of communication with shareholders and stakeholders. The quarterly report can be accessed on the Astragraphia website.
D.6.2 The Company website Astragraphia uses the Company website as a communication medium that can be accessed through www.astragraphia.co.id.
D.6.3 Analyst’s briefing       Astragraphia uses Public Exposure as a medium of communication with investors and stakeholders.
D.6.4 Media Meetings/Press Conferences Astragraphia uses press releases as a medium for public and stakeholder communication.
D.7 Publication Schedule of Annual Reports/Financial Statements
D.7.1 Are audited annual Financial Statements issued within 120 days of the end of the financial year? Astragraphia's Annual Consolidated Financial Statements are released less than 120 days after the end of the Company's financial year.
D.7.2 Are Annual Reports issued within 120 days of the end of the financial year? Annual Reports are released less than 120 days after the end of the Company's financial year.
D.7.3 Is the statement that the Annual Financial Statements have been presented correctly and fairly, has been confirmed by the Board of Commissioners or the Board of Directors and/or related officials from the company. Statements from the Board of Commissioners and the Board of Directors regarding the responsibility for the Annual Reports are contained in the Annual Reports.
D.8 Company Website
  Does the company have a website that discloses recent information about:
D.8.1 Financial Statements (Last Quarter) Astragraphia has published Annual Reports on the Astragraphia website.
D.8.2 Materi Analyst and Media Briefing    Astragraphia has published Public Exposure materials on the Astragraphia website.
D.8.3 Annual Reports can be downloaded Astragraphia has published Annual Reports on the Astragraphia website.
D.8.4 Notification/Invitation to AGMS and/or EGMS. Astragraphia has published the Invitation to the AGMS on the Astragraphia website.
D.8.5 The Minutes of the AGMS and/or RUPLSB Astragraphia have published the Minutes of the AGMS on the Astragraphia website.
D.8.6 Companies’ Articles of Association Astragraphia has published the Articles of Association on the Astragraphia website.
D.9 Investor Relations
D.9.1 Does the company disclose the contact details (e.g. telephone, facsimile, and electronic mail/e-mail) of the officer/institution responsible for Investor Relations? Astragraphia has disclosed the contact person responsible for Investor Relations in its Annual Reports and the Astragraphia website.

Part E: Responsibilities of the Board of Directors and the Board of Commissioners

Part Concerns Implementation Reference
E.1 Duties and Responsibilities of the Board of Directors and the Board of Commissioners
  Clear board responsibilities and corporate governance policy
E.1.1 Does the company disclose its Corporate Governance policies or the Board of Directors/Board of Commissioners Charter? Astragraphia discloses the Work Guidelines for the Board of Commissioners and the Board of Directors on the Astragraphia website.
E.1.2 Are the types of decisions that require the approval of the Board of Directors/Board of Commissioners disclosed? Decisions of the Board of Directors that require the approval of the Board of Commissioners are regulated in Article 18 of Astragraphia's Articles of Association.
E.1.3 Are the roles and responsibilities of the Board of Directors/Board of Commissioners clearly stated? The duties, responsibilities, and authorities of the Board of Commissioners and the Board of Directors are described in the Work Guidelines for the Board of Commissioners and the Board of Directors.
  Company Vision / Mission
E.1.4 Does the company have an up-to-date Vision and Mission statement? Astragraphia's Vision and Mission are disclosed in the Astragraphia website and annual report.
E.1.5 Does the Board of Directors play a major role in the company's strategy development and review process on an annual basis? The Board of Directors is responsible for the strategic review process, establishing the strategy and reviewing its implementation through regular Board of Directors meetings.
E.1.6 Does the Board of Directors have a process to review, monitor and oversee the implementation of the company's strategy? The Board of Directors is responsible for the strategic review process, establishing the strategy and reviewing its implementation through regular Board of Directors meetings.
E.2 Structure of the Board of Directors and Board of Commissioners
  Code of Ethics or Code of Conduct
E.2.1 Are details of the code of ethics or conduct disclosed? The Astragraphia Code of Ethics is disclosed in detail on the Astragraphia website.
E.2.2 Are all directors/commissioners, senior management and employees required to comply with the code of conduct? Astragraphia's Code of Ethics must be complied with by Astragraphia's Commissioners, Directors and Employees.
E.2.3 Does the company have a process for implementing and monitoring compliance with a code of ethics or conduct? The Code of Ethics is conveyed to the Commissioners, Directors and Employees of Astragraphia since they joined Astragraphia and is socialized at every opportunity to employees so that they always remember and adhere to it properly.
  Board Structure & Composition
E.2.4 Is the composition of the Board of Directors/Board of Commissioners independent of at least 50% of the total members of the Board of Directors/Board of Commissioners? Astragraphia has one Independent Commissioner from a total of three members of the Board of Commissioners so that it has complied with the provisions of POJK No. 33/POJK.04/2014, which is 30% of the total members of the Board of Commissioners.
E.2.5 Does the company have a term of office of nine years or less or 2 terms of five years each for its independent directors/commissioners? Astragraphia has complied with the provisions of POJK 33/2014, namely that the Independent Commissioner can serve for 2 consecutive terms, and can be reappointed for a further period as long as the member declares his independence at the GMS.
E.2.6 Has the company set a limit of five positions of the Board of Directors and the Board of Commissioners that can be held simultaneously by an independent/non-executive director/commissioner? Details of the concurrent positions of each member of Astragarphia's Board of Directors and Board of Commissioners are disclosed in the profiles of the Board of Directors and Board of Commissioners in the Annual Report. Astragraphia complies with the provisions for concurrent positions as regulated in POJK No. 33/POJK.04/2014.
E.2.7 Does the company have an executive director who has held more than two positions as the Board of Directors and the Board of Commissioners in another public company? Details of the concurrent positions of each member of Astragarphia's Board of Directors and Board of Commissioners are disclosed in the profiles of the Board of Directors and Board of Commissioners in the Annual Report. Astragraphia complies with the provisions for concurrent positions as regulated in POJK No. 33/POJK.04/2014.
  Nomination Committee
E.2.8 Does the company have a Nomination Committee? Astragraphia has a Nomination and Remuneration Committee.
E.2.9 Does the Nomination Committee consist mostly of independent Directors/commissioners? The composition of the members of the Nomination and Remuneration Committee has complied with the provisions of POJK No. 55/POJK.06/2016.
E.2.10 Is the chairman of the Nomination Committee an independent director/commissioner? The Nomination and Remuneration Committee of Astragraphia is an Independent Commissioner.
E.2.11 Does the company disclose the terms of reference/governance structure/charter of the Nomination Committee? The work guidelines of the Astragraphia Nomination and Remuneration Committee are disclosed on the Astragraphia website.
E.2.12 Is the Nomination Committee meeting attendance list disclosed and, if so, does the Nomination Committee meet at least twice during the year? The Nomination and Remuneration Committee of Astragraphia holds a meeting at least once every four months and is disclosed in the annual report.
  Remuneration Committee/Compensation Committee
E.2.13 Does the company have a Remuneration Committee? Astragraphia has a Nomination and Remuneration Committee.
E.2.14 Are the members of the Remuneration Committee mostly independent directors/commissioners? The composition of the members of the Nomination and Remuneration Committee has complied with the provisions of POJK No. 55/POJK.06/2016.
E.2.15 Is the chairman of the Remuneration Committee an independent director/commissioner? The Nomination and Remuneration Committee of Astragraphia is an Independent Commissioner.
E.2.16 Does the company disclose the terms of reference/governance structure/charter of the Remuneration Committee? The work guidelines of the Astragraphia Nomination and Remuneration Committee are disclosed on the Astragraphia website.
E.2.17 Is the attendance list for Remuneration Committee meetings disclosed and, if so, does the Remuneration Committee meet at least twice during the year? The Nomination and Remuneration Committee of Astragraphia holds a meeting at least once every four months and is disclosed in the annual report.
  Audit Committee
E.2.18 Does the company have an Audit Committee? Astragraphia has an Audit Committee.
E.2.19 Does the Audit Committee consist entirely of non-executive directors/commissioners with the majority being independent directors/commissioners? All members of the Astragraphia Audit Committee are independent parties.
E.2.20 Is the chairman of the Audit Committee an independent director/commissioner? The Chairman of the Audit Committee is an Independent Commissioner.
E.2.21 Does the company disclose the terms of reference/governance/charter of the Audit Committee? The work guidelines of the Astragraphia Audit Committee are disclosed on the Astragraphia website.
E.2.22 Does at least one of the committee members of the independent director/commissioner have accounting expertise (accounting qualification or experience)? The qualifications for membership of the Astragraphia Audit Committee have complied with the provisions of POJK No. 55/POJK.04/2015, that is, one of the members of the Astragraphia Audit Committee has a financial/accounting background.
E.2.23 Is the attendance list for Audit Committee meetings disclosed and, if so, does the Audit Committee meet at least four times during the year? The Astragraphia Audit Committee conducts at least once in three months and is disclosed in the annual report.
E.2.24 Does the Audit Committee have primary responsibility for providing recommendations for the appointment and dismissal of external auditors? The Audit Committee provides recommendations for the appointment of a Public Accountant and a Public Accounting Firm to the Board of Commissioners to be submitted to the GMS in accordance with the Audit Committee's Work Guidelines.
E.3 Process of the Board of Directors and the Board of Commissioners
  Meetings and Attendance of the Board of Directors and Board of Commissioners
E.3.1 Are Board of Directors meetings scheduled before the start of the financial year? The monthly meeting of the Astragraphia Board of Directors for the following financial year has been scheduled before the end of the current year.
E.3.2 Do the Board of Directors/Board of Commissioners hold meetings at least six times during the year? The Board of Commissioners of Astragraphia is required to hold a Board of Directors Meeting periodically at least once in 2 months and the Board of Directors of Astragraphia is required to hold a Board of Directors Meeting periodically at least once a month.
E.3.3 Does each director/commissioner attend at least 75% of all board meetings held during the year? Throughout 2021, the Board of Commissioners held 6 meetings with an average attendance rate of 100% and the Board of Directors held 37 meetings with an average attendance of 98.65%.
E.3.4 Does the company require a minimum quorum of 2/3 for the decisions of the Board of Directors/Board of Commissioners? Meeting decisions are taken based on deliberation for consensus. In the event that a consensus decision is not reached, the decision is made based on a majority vote of the total number of members of the Board of Directors who are present or represented at the Meeting, which includes the President Director/Commissioner or Vice President Director/Commissioner.
E.3.5 Does the company's Independent Director/Commissioner hold a separate meeting at least once a year without an executive present? Throughout 2021, the Board of Commissioners held 6 meetings and the Board of Directors held 37 meetings.
  Information Access
E.3.6 Are the Board of Directors and Board of Commissioners meeting materials available at least five working days before the meeting? Materials for the meeting of the Board of Directors and the Board of Commissioners of Astragraphia are submitted no later than 5 days before the meeting is held.
E.3.7 Does the Corporate Secretary play an important role in assisting the implementation of the responsibilities of the Board of Directors and the Board of Commissioners? The Corporate Secretary plays an important role in assisting the implementation of the responsibilities of the Directors and the Board of Commissioners of Astragraphia.
E.3.8 Does the Corporate Secretary have skills in law, accounting or corporate secretarial practice and keep abreast of relevant developments? The Corporate Secretary of Astragrahia has attended various trainings, seminars, workshops and periodic meetings to increase knowledge and understanding as well as follow developments in the capital market, law, and corporate governance.
  Appointment of the Board of Directors and Board of Commissioners and Reappointment
E.3.9 Does the company disclose the criteria for candidates for Director/Board of Commissioners? The criteria for the Board of Directors and Board of Commissioners of Astragraphia meet the criteria as stipulated in POJK No.33/POJK.04/2014 concerning the Board of Directors and Board of Commissioners of Issuers or Public Companies, which are disclosed in Astragraphia's Articles of Association.
E.3.10 Does the company explain the selection process for the Director/Board of Commissioners? The process of Astragraphia's Board of Directors and Board of Commissioners appointment is disclosed in the annual report.
E.3.11 Are members of the Board of Directors/Board of Commissioners reappointing every 3 years or every 5 years for publicly listed companies specifically for countries with a legal system that requires this? Members of the Board of Directors/Board of Commissioners are appointed by their respective GMS for a period from the date of their appointment as decided in the GMS until the closing of the second annual GMS after the date of appointment and may be reappointed.
  Remuneration
E.3.12 Does the company disclose its remuneration policies (salaries, allowances, in-kind benefits and honorariums) for example short-term and long-term incentives and performance measures for members of the Board of Directors and Commissioners? Astragraphia discloses the remuneration policy for the Board of Commissioners and the Board of Directors in the annual report.
E.3.13 Is the salary structure for Directors/Commissioners disclosed? Astragraphia discloses the remuneration structure of the Board of Commissioners and the Board of Directors in the annual report.
E.3.14 Do shareholders or Directors approve the remuneration of Directors and/or executive officers? Shareholders approve the determination of the salaries and allowances of the company's directors as well as the determination of the honorarium and/or allowances of the Board of Commissioners in one of the GMS agendas.
E.3.15 Does the company have a standard measure to harmonize performance-based remuneration for Directors and Senior Executives with the long-term needs of the company, for example a withdrawal of salaries or bonuses that have been given? Astragraphia has procedures and standards for proposing the determination of remuneration for the Board of Commissioners and the Board of Directors which are disclosed in the annual report.
  Internal Audit
E.3.16 Does the company have a separate Internal audit function? Astragraphia has an Internal Audit Unit.
E.3.17 Is the head of Internal Audit disclosed or if it is carried out by an external party, then is the name of the external party disclosed? Astragraphia disclosed information from the head of Internal Audit.
E.3.18 Does the appointment of internal auditors require the approval of the Audit Committee? The Head of Internal Audit of Astragraphia is appointed or dismissed by the President Director after obtaining approval from the Board of Commissioners
  Risk Monitoring
E.3.19 Does the company have adequate internal control or risk management procedures and the effectiveness of their implementation is regularly reviewed? Astragraphia has a Risk Management unit and an Internal Control unit whose implementation and effectiveness are reviewed regularly by the Board of Directors.
E.3.20 Do the company's Annual Reports/CG reports reveal that the Board of Directors/Board of Commissioners have reviewed the control over material matters (including operational, financial, and compliance) as well as the risk management system? The Board of Directors periodically evaluates the implementation and effectiveness of the risk management system and internal control.
E.3.21 Does the company disclose key material risks (for example, financial, operational including IT, environmental, social and economic)? Astragraphia discloses the risks faced by the Company and their mitigation.
E.3.22 Do the company's Annual Reports/CG Reports disclose the statements of the Board of Directors/Board of Commissioners or the Audit Committee regarding the adequacy of the Internal Control System/Risk Management System? The Board of Directors has evaluated the implementation and effectiveness of the risk management system and internal control and the evaluation results state that the risk management and internal control system has complied with the applicable regulations.
E.4 Members of the Board of Directors and Board of Commissioners
  President Director/ Commissioner
E.4.1 Do different people serve as chairman and President Director? The positions of President Director and President Commissioner of Astragraphia are held by different parties.
E.4.2 Is the Board of Directors/Board of Commissioners led by an Independent Director/Commissioner? In 2022, the composition of the Board of Directors and the Board of Commissioners of Astragraphia will not be led by an Independent Director or an Independent Commissioner.
E.4.3 Has any member of the board of directors served as President Director of the company in the last 2 years? In the last 2 (two) years, no member of the Board of Directors has served as President Director.
E.4.4 Are the duties and responsibilities of the President Director/Commissioner disclosed? Astragraphia discloses the division of duties and responsibilities of each Board of Directors in the annual report.
  Chief member Independent Director
E.4.5 If the Board of Commissioners is not led by an Independent Commissioner, does the Board of Commissioners have a Lead Independent Commissioner and is his role disclosed? In 2022, the composition of the Board of Directors and the Board of Commissioners of Astragraphia will not be led by an Independent Director or an Independent Commissioner.
  Competence and Expertise
E.4.6 Does at least one member of the Board of Commissioners have experience working in the same field as the Company's main business activities? Members of the Board of Commissioners have work experience in the same field as Astragraphia's main business activities.
E.5  Performance of the Board of Directors and Board of Commissioners
  Development of the Board of Directors and Board of Commissioners
E.5.1 Does the company have an orientation program for newly elected members of the Board of Directors and Board of Commissioners? Astragraphia has an orientation program for new members of the Board of Commissioners and Directors.
E.5.2 Does the company have a policy that regulates the obligations of the Board of Directors/Board of Commissioners to attend regular professional training? The Board of Commissioners and Directors of Astragraphia every year participate in various training/education programs.
  Appointment and Performance of President Director
E.5.3 Does the company disclose the President Director and Key Management succession process? Astragraphia discloses policies regarding the succession of the Board of Directors in its annual report.
E.5.4 Does the Board of Directors/Board of Commissioners carry out an annual assessment of the President Director's performance? The Board of Commissioners of Astragraphia conducts an annual assessment of the performance of the Board of Directors.
  Assessment of the Board of Commissioners/ Directors
E.5.5 Does the company carry out an annual performance appraisal for the Board of Directors and the Board of Commissioners and disclose the criteria and processes in the assessment? Astragraphia evaluates the performance of members of the Board of Commissioners and members of the Board of Directors conducted by the Nomination and Remuneration Committee.
  Evaluation of the Directors
E.5.6 Does the company carry out an annual performance assessment for the Board of Directors and the Board of Commissioners and disclose the criteria and processes in the assessment? Astragraphia evaluates the performance of members of the Board of Commissioners and members of the Board of Directors conducted by the Nomination and Remuneration Committee.
  Evaluation of the Committee
E.5.7 Does the company carry out an annual assessment of the performance of the committees under the Board of Commissioners/Board of Directors and disclose the criteria and processes in the assessment? Astragraphia evaluates the performance of the committees that support the implementation of the duties of the Board of Commissioners and those carried out by the Nomination and Remuneration Committee.

Part: Bonus Item

Part Concerns Implementation Reference
(B)A. Shareholders Rights
(B)A.1 The right to participate effectively and vote in general shareholder meetings and to be notified of the regulations, including election procedures, governing general shareholder meetings
(B)A.1.1 Does the company practice electronic voting in absentia at general shareholder meetings? Voting in the Astragraphia GMS is carried out physically (by raising hands) and electronically (using the eASY.KSEI facility)
(B)B. Equal Treatment to Shareholders
(B)B.1 GMS Summons
(B)B.1.1 Does the company issue a GMS notification (with detailed agenda and explanation), as announced to the Exchange, at least 28 days before the meeting date? Astragraphia made the first announcement regarding the plan to hold the GMS through the IDX website, eASY.KSEI, and the Astragraphia website more than 28 days before the date of the GMS.
(B)C. Stakeholder Role
(B)C.1 The rights of stakeholders that arise based on legislation or based on agreements must be respected
(B)C.1.1 Is the company adopting an internationally recognized reporting framework for sustainability (for example, GRI, Integrated Reporting, SASB)? Astragraphia's sustainability report uses the POJK No.51/POJK.03/2017 and SEOJK No.16/SEOJK.04/2021 indexes and the GRI “INTI” international standard.
(B)D. Ownership Structure Transparency
(B)D.1 Quality of Annual Reports
(B)D.1.1 Are audited annual Financial Statements released within 60 days of the end of the financial year? Astragraphia's consolidated annual financial statements are released less than 60 days after the end of the financial year.
(B)D.1.2 Does the company disclose details of the President Director's remuneration? Astragraphia discloses the total remuneration of members of the Board of Directors and Board of Commissioners in its annual report.
(B)E. Responsibilities of the Board of Directors/ Board of Commissioners
(B)E.1 Board Competence and Diversity
(B)E.1.1 Does the company have at least one female Independent Director/Commissioner? In 2022, members of the Board of Commissioners and members of the Board of Directors of Astragraphia are male.
(B)E.1.2 Does the company have a policy and disclose measurable goals for implementing a diversity of Board of Directors/Commissioner and reporting progress towards achieving its goals? Astragraphia has a Policy for Diversity in the Composition of the Board of Commissioners and Board of Directors which is disclosed in the annual report.
(B)E.2 Structure of the Board of Directors/ Board of Commissioners
(B)E.2.1 Does the Nomination Committee consist of independent directors/independent commissioners? The Chairman of the Nomination and Remuneration Committee is an Independent Commissioner.
(B)E.2.2 Does the Nomination Committee carry out a process of identifying director qualities that are aligned with the company's strategic direction? The Nomination and Remuneration Committee of Astragraphia reviews and proposes candidates who meet the requirements according to the needs of the Company as members of the Board of Directors and/or members of the Board of Commissioners to the Board of Commissioners to be submitted to the GMS.
(B)E.3 Appointment and Re-appointment of the Board of Directors/Board of Commissioners
(B)E.3.1 Does the company use professional search firms or other external candidate sources (such as director databases established by directors or shareholder bodies) when searching for candidates for Board of directors/commissioners? The Nomination and Remuneration Committee is responsible for planning the succession of the Board of Directors in order to maintain leadership continuity in the future. The implementation of succession is carried out through identification of executive officers who have potential through the Talent Review Program.
(B)E.4 Structure and Composition of the Board of Directors/Board of Commissioners
(B)E.4.1 Do non-executive independent directors/commissioners make up more than 50% of the directors/board of commissioners for companies with independent chairman? Astragraphia has one Independent Commissioner from a total of three members of the Board of Commissioners so that it has complied with the provisions of POJK No. 33/POJK.04/2014, which is 30% of the total members of the Board of Commissioners.
(B)E.5 Risk Monitoring
(B)E.5.1 Does the Board of Directors/Board of Commissioners describe their governance processes related to IT issues such as disruption, cybersecurity, disaster recovery, to ensure that all major risks are identified, managed, and reported to the Board of Directors/Commissioners? Astragraphia discloses and explains strategies for information technology governance, security from interference and cyber security, and disaster recovery.
(B)E.6 Performance of the Board of Directors/Board of Commissioners
(B)E.6.1 Does the company have a separate Risk Committee at the level of the Board of Directors/Commissioners? Astragraphia has a Risk Management unit and an Internal Control unit.