Address：

Menara BTPN, 31st Floor
Jl. Dr. Ide Anak Agung Gde Agung Kav. 5.5 - 5.6
Mega Kuningan, Jakarta Selatan 12950 Indonesia

Tel：

62-21-8062-8710

PT SMFL Leasing Indonesia (SMFLI) has a special function for handling customer complaints. Please feel free to send your feedback and complaints about SMFLI to the following dedicated email address: customer.care@smfl.co.id or telephone (021) 8062 8710.

Summary Procedure for Handling Complaints

1. 1. Customers may lodge complaints verbally or in writing.
2. 2. Our Customer Complaints Service will confirm receipt or issue acknowledgement after the customer has provided the information and documentation that we require. The information and documents required from the customer include the following:
   1. a. Identity of the customer and/or party acting on their behalf (full name, address per identity card and other address (if any), and telephone number);
   2. b. Special Power of Attorney (if the complaint is lodged by a party acting on behalf of the customer);
   3. c. Type and date of the financial transaction;
   4. d. The issue of the complaint; and
   5. e. Other documentation as informed at a later date.
3. 3. For written complaints, customers are given a period of 20 working days to prepare the complete required documents. This period may be extended 20 days under certain circumstances as stipulated in POJK 18/POJK.07/2018 and SEOJK No. 17 /SEOJK.07/2018.
4. 4. Verbal complaints will be resolved within 5 working days after confirmation of receipt, while written complaints will be resolved within 20 working days after the customer has provided all required documentation. The period for resolution of written complaints may be extended under the provisions of POJK 18/POJK.07/2018 and SEOKJ No. 17/SEOJK2018.
5. 5. If SMFLI requires certain supporting documents for addressing a verbal complaint, SMFLI may ask the customer to submit a written complaint attaching the required supporting documents.
6. 6. If no agreement is reached on resolution of the complaint, the customer may apply for dispute resolution at the forum specified in the Financing Agreement.
7. 7. Based on the Financing Agreement, one of the dispute resolution forums that can be selected by The Parties is the Alternative Dispute Resolution Institution for Financial Service Sector (LAPS SJK). Further information about LAPS SJK LAPS can be accessed through the website
   https://lapssjk.id/

Handling of Complaints

As of the end of 2021, SMFL had received 1 (one) complaint from customers.

In relation to comply with Financial Service Authority (hereinafter referred as “OJK”) Regulation, specifically OJK Regulation No. 35/POJK.05/2018 regarding Business Conduct of Finance Company Article 61 Letter a, PT. SMFL Leasing Indonesia (hereinafter referred as “SMFLI / The Company”) is obliged to set out policy and mechanism of Whistle Blowing System (WBS).

I. Mechanism of Whistle Blowing Report through WBS

1. 1. Appointed Person In Charge (PIC) to handle / receive Whistle Blowing Report:
   1. a. Vice President Director, and or
   2. b. Anti – Fraud PIC.
2. 2. WBS Methods
   1. a. Email to:
      wbs@smfl.co.id
   2. b. Mail (Post)
      Attn.: Vice President Director
                Anti – Fraud PIC
      PT. SMFL Leasing Indonesia
      Menara BTPN, 31st Floor
      Jl. Dr. Ide Anak Agung Gde Agung, Kav. 5.5-5.6
      Mega Kuningan, Jakarta Selatan – 12950
      Indonesia
   3. c. Telephone
      +62 21 80628710
      Person In Charge:
      1. - Vice President Director
      2. - Anti – Fraud PIC
   4. d. Whistle Blowing Form attached below.
      > PDF (93KB)
      > Word file (28KB)
3. 3. Types of Fraud / violation that may be reported through WBS are as follows:
   1. a. Fraud including Corruption and Collusion;
   2. b. Gratification including Bribery;
   3. c. Violations of Law;
   4. d. Conflict of Interest;
   5. e. Breaches of the Code of Conduct / Ethic Code of the Company;
   6. f. Actions that may cause financial or non-financial loss to the Company or harm the interests of the Company;
   7. g. Violations of the Company Regulation and Employment Agreement including other Company Documents;
   8. h. Actions that endanger the occupational safety and health, or jeopardizes the security of the Company; and
   9. i. Breaches generally accepted business principles and practices.
4. 4. Whistle Blower Report Procedures
   1. a. The Whistle Blower can report any indication of fraud to the Company by using the 3 (three) WBS Methods as stated above.
   2. b. The report made by the Whistle Blower should be directly addressed to the Appointed PIC of managing the Whistle Blowing Report.
   3. c. In order to ease of contact and immediate follow – up action, the Whistle Blower needs to provide sufficient information on his / her identity, such as:
      1. - Whistle Blower’s telephone number / e – mail address.
      2. - Name of the Whistle Blower (permitted to remain anonymous).
   4. d. In order the Whistle Blower Report can be considered accountable, it is recommended to provide preliminary information on the indication of violation / Fraud and to be accompanied by relevant supporting data (if any), including:
      1. - The fraudulent act / misconduct (What).
      2. - The alleged perpetrators (Who).
      3. - The time at which the Fraud / violation was committed (When).
      4. - The location at which the Fraud / violation was committed (Where).
      5. - Description of how it occurred (How).
   5. e. To align the items required to be reported in the Whistle Blower Report, Whistle Blowing Form (enclosed as Attachment 1) could be used to assist the Whistle Blower in preparing such report and later on send the report via e – mail or mail (post).

II. Whistle Blower Protection

1. 1. All Whistle Blowing Reports which submitted through WBS method will be treated as confidential information.
2. 2. The Company is required to keep the secrecy of the Whistle Blower’s identity and protect the Whistle Blower’s from any forms of threat, intimidation, conviction and even objectionable acts from parties reported.
3. 3. The Whistle Blower, who whistle-blows in accordance with this policy and mechanism, shall not be treated unfairly in any way or terminated without any specific and rational reasons.
4. 4. The “unfair treatment” shall include:
   1. (i) Personnel – related measures such as demotion, mutation, rotation and salary reduction;
   2. (ii) Not allowing the Whistle Blower to do his or her work or forcing him or her to do only miscellaneous work.

III. Prohibited Items

The following actions shall be prohibited at any time and any place:

1. 1. Explicitly or implicitly indicate or suggest the Employee that the Employee will be treated disadvantageously if the Employee Whistle Blows.
2. 2. Explicitly or implicitly ask the Employee not to Whistle Blow.
3. 3. Explicitly or implicitly ask the Employee to dispose of documents and information materials related to the Whistle Blow.
4. 4. Explicitly or implicitly ask and/or demand the Employee not to cooperate with the investigation for the Whistle Blow.
5. 5. Directly or indirectly interrogating the Whistle Blower.
6. 6. Disclosing the fact that an allegation has been made or the details of the allegation to any third party without the prior consent of the Appointed PIC (Investigation Team).
7. 7. Perform any of 1 to 6 above or any other actions equivalent or similar to 1 to 6 through a third party.

This WBS Policy and Mechanism prepared as a reference for Directors, Board of Commissioners, Management, all employees and all Related Business Partners / Outside Parties of PT. SMFL Leasing Indonesia related to reporting of Fraud / violations through WBS. This policy will be reviewed on an annual basis and revisions / adjustments will be carried out by the Anti - Fraud PIC if necessary.