Научная статья на тему 'Financial planning framework of business startup as advisory and service provider of tire industry machine'

Financial planning framework of business startup as advisory and service provider of tire industry machine Текст научной статьи по специальности «Экономика и бизнес»

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Planning / business / finance strategy / industry / machines

Аннотация научной статьи по экономике и бизнесу, автор научной работы — Muhammad Thomas, Yanuar Tantri, Pusaka Semerdanta, Darmansyah

Every company needs a plan, both in business strategies and financial strategies. Planning is very important in a company, its works to drive the business and measure its accomplishments. Empirical studies across different industrial countries have shown a positive correlation between planning intensity and the success of a business. Nevertheless, financial planning is typically regarded as a major obstacle in the process of new venture creation. Financial framework with five financial planning elements can be implements in a new venture or startup company. The framework will defines the process in to the five financial planning elements as planning of revenues, planning of related expenses, planning of investments, planning of capital requirements (all nonrecurring investments and recurring expenses), and planning of financing. Finally, the robustness of the financial plan can be tested by employing sensitivity analysis, scenario analysis, and simulation. Due to all cash flows have to be estimated in advance, appropriate forecasting methods must be employed.

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Текст научной работы на тему «Financial planning framework of business startup as advisory and service provider of tire industry machine»

DOI 10.18551/rjoas.2019-12.28

FINANCIAL PLANNING FRAMEWORK OF BUSINESS STARTUP AS ADVISORY AND SERVICE PROVIDER OF TIRE INDUSTRY MACHINE

Muhammad Thomas*, Yanuar Tantri, Pusaka Semerdanta, Darmansyah

Faculty of Economics and Business, Esa Unggul University, Indonesia *E-mail: tmuhammad7@gmail.com

ABSTRACT

Every company needs a plan, both in business strategies and financial strategies. Planning is very important in a company, its works to drive the business and measure its accomplishments. Empirical studies across different industrial countries have shown a positive correlation between planning intensity and the success of a business. Nevertheless, financial planning is typically regarded as a major obstacle in the process of new venture creation. Financial framework with five financial planning elements can be implements in a new venture or startup company. The framework will defines the process in to the five financial planning elements as planning of revenues, planning of related expenses, planning of investments, planning of capital requirements (all nonrecurring investments and recurring expenses), and planning of financing. Finally, the robustness of the financial plan can be tested by employing sensitivity analysis, scenario analysis, and simulation. Due to all cash flows have to be estimated in advance, appropriate forecasting methods must be employed.

KEY WORDS

Planning, business, finance strategy, industry, machines.

PT. Tire Mandiri as a new company which concentrate on advisory and service provider of tire industry machine installation has several excellent products. One of them is a machine installation service of tire industry with on time completion time and high level of precision to fulfill end user need (specification) effectively and efficiently. This advantage is the competitive advantage of PT Tire Mandiri's products when is compared with the other installation services of tire machinery industry which generally is general contractor.

As a new comer in the area of tire industry installation service, all the competitive advantage and all the opportunity will be useless if not supported with a good strategy. Financial planning or financial strategy is one of the most important but also difficult hurdles to overcome when planning a new venture.

As this perspective reveals, the profitable exploitation of opportunities is related to the task of systematic planning and the calculation of costs and revenues. We define financial planning as the process of systematic and quantitative forecasting of all cash in and outflows relevant for the exploitation of entrepreneurial opportunities, in order to support financial decisions within the future planning period. The essence is based on the notional anticipation of future outcomes and the application of an appropriate decision making mechanism. Financial planning, viewed in this light, serves as a mechanism for dealing with uncertainties. Distinct from the definition of financial planning, the pro forma financial plan, composed of income statement, balance sheet, and cash flow statement, is the numerical result of the financial planning process.

In supporting the company to achieve its goals, the objectives of the financial strategy to be achieved:

a. Short-term goals:

• Record positive net profit above 2 billion after the second year of operation and profit growth target of at least 5% per year;

• Achieve ROI above 30% of each item after year 2;

• Achieve ROI above 30% annually after the 2nd year of operation.

b. Long-term Goals:

• Generate a Net Present Value (NPV) positive value of the investment value of the project (FCFE);

• Achieving the value of Internal Rate of Return (IRR) which is higher than the cost of capital (cost of capital);

• Distributing dividends to shareholders after the company receives a positive cumulative net profit;

• Achieve discounted payback period within a maximum of 2 years.

The financial planning process, regarded as a set of decision making instruments, includes three core components:

• planning of the income statement;

• planning of the balance sheet;

• planning of the cash flow statement.

By definition, the numerical results of the financial planning process are three appropriate pro forma statements. The triad suggested here relies on the internationally accepted accounting principles. A key supplementary instrument, the "footnotes", contains information on principles, assumptions, details, connections, schedules, and methods used to produce the components, elements, and items of the statements. This provides the groundwork for the planning process. The core components require the (monthly or periodically) planning of five elements, defined as financial planning elements:

• planning of revenues;

• planning of related expenses;

• planning of investments (all nonrecurring investments);

• planning of capital requirements (both all nonrecurring investments and recurring expenses);

• planning of financing.

Figure 1 - Financial Framework of Tire Mandiri

Some of the assumptions used in the projected financial statements of PT Tire Mandiri are as follows:

• The company began since January 1, 2018 so that in the first year or 2018, is projected there will be sales starting early second quarter;

• The growth rate of market share of sales corresponds to what is predicted by marketing;

• The company's operating expenses each year increase according to the 3.5% inflation rate;

• The cost of marketing activities of the company each year increased by 5%;

• Salaries, benefits, employee benefits increased by 5% in the second year, 7% in the third year, and 10% for next year;

• Payment to raw material suppliers in the investment year and the next five years using Cash On Delivery system;

• Payments made by customers of PT. Tire Mandiri is divided in to 4 terms.

Planning of Revenues. Estimated income from PT. Tire Mandiri for the first five years is

expected from five medium-to-large manufacturing companies of tire production volume produced, namely (1) PT. Gajah Tunggal, (2) PT. Sumi Rubber Indonesia, (3) PT. Bridgestone Tire Indonesia, (4) PT. Multistrada Arah Sarana, and (5) PT. Hankook Tire Indonesia. Planning revenue from sales for the first five years can be seen in Table 1.

Table 1 - Planning revenue for the first five years

(unit in Rp. 000)

Description Year 1 2018 Year 2 2019 Year 3 2020 Year 4 2021 Ye ar 5 2022

Total Market 218,500,000 234,887,500 252,504,063 271,441,867 291,800,007

Market Share Estimated 10,875,000 16,100,000 21,000,000 24,100,000 29,500,000

Percentage Market Share 5% 7% 8% 9% 10%

Market Share Per Product

Product 1 1,500,000 2,500,000 3,000,000 - 13,500,000

Product 2 - - - - 2,000,000

Product 3 9,375,000 6,000,000 7,000,000 22,000,000 3,000,000

Product 4 - 5,500,000 11,000,000 - -

Product 5 - - - - 11,000,000

Product 6 - - - - -

Product 7 - 2,100,000 - 2,100,000 -

Market Share Per Targeted Company

PT. Gajah Tunggal Tbk 5,500,000 6,000,000 7,000,000 9,500,000 11,000,000

PT. Sumi Rubber Indonesia 3,875,000 5,500,000 5,500,000 7,000,000 11,000,000

PT. Bridgestone Tire Indonesia 1,500,000 2,500,000 5,500,000 4,000,000 3,000,000

PT. Multistrada Arah Sarana Tbk 2,100,000 3,000,000 2,100,000 2,500,000

PT. Hankook Tire Indonesia - 1,500,000 2,000,000

Planning Cost for Expenses. Profit margin of 50% is to cover the trend of sales PT. Tire Mandiri which is not regular or not always there every month. Cost of goods sold using Activity Based Costing method due to variations of products offered by PT. Tire Mandiri. Cost of sales is using the assumption of Variable Cost which consists of four items whose percentages vary according to the character of the product or project as in table 2.

Besides of cost of goods sold calculation, in this stage, company also calculated projected cost of marketing expenses, general and administrative expenses, and investment cost at pre operation and operation.

Working capital required by PT. Tire Mandiri to run its operations is Rp. 3.937.483,-and rounded to Rp. 4.000.000.000,00 for initial establishment of the company consisting of total initial investment in the amount of Rp. 1.603.811,- and working capital requirement in the amount of Rp. 2.333.672.000,-.

Table 2 - Variable Cost of Product

Variabel Cost Item Product 1 Product 2 Product 3 Product 4 Product 5 Product 6 Product 7

Commission Fee for third party 20% 20% 2% 15% 20% 20% 20%

Consumable Materials 10% 5% 20% 15% 15% 5% 10%

Operational and Tools 10% 15% 18% 10% 5% 15% 10%

Employee Fee PT. Tire Mandiri 10% 10% 10% 10% 10% 10% 10%

Total 50% 50% 50% 50% 50% 50% 50%

Remarks :

Product 1 = Machine Maintenance and Overhaul Services

Product 2 = Tire Industry Machine Calibration and Accuration Services

Product 3 = Tire Industry Machine Installation Services

Product 4 = Industry Piping Installation

Product 5 = Tire Industry Machine Upgrading Services

Product 6 = Advisory and Consulting Services

Product 7 = Engineering Accessories Fabrication

Funding at the beginning of the establishment of the company's operations comes from the founder (founder) and assisted loans from the bank (creditor). Founder consists of 4 people with total amount of funding of Rp. 1.000.000.000,- and bank loan of Rp. 3.000.000.000,-. The capital structure consists of 25% of the capital deposit from the founders and 75% comes from bank loans. The selection of the following composition is due to the limited capital possessed by 4 founders.

Bank loans are filed with property guarantees from the founders and submitted to bank loan programs that focus on Working Capital Loans or Investment Credits that do not require the company to have been running for 1 year or more. To that end, the company proposed to the bank Indosurya Finance for Work Solutions program and Griya with a loan of Rp. 3.000.000.000,- and tenor of 36 months, and interest 12,5 per year.

In accordance with the Company's funding strategy, the Company's funding uses a combination of equity and loans. Therefore, the capital cost will be calculated using the weighted average cost of capital (WACC). From the calculation results using WACC method obtained cost of capital or cost of capital PT. Tire Mandiri by 8.79%.

In the income statement of PT. Tire Mandiri format used is the format of income statement direct method. The resulting revenue is derived from the sales of 7 product categories from five companies that are the sales target in the first five years according to the revenue planning described in table no 1. The resulting sales will be reduced by the direct sales expense which is the variable cost described in table no 2. The difference between sales and direct selling expenses is the gross profit earned by the company.

Gross profit will be reduced by operating expenses (expenses) which are expenditures directly incurred daily for the company's operations, such as marketing, marketing costs, employee salaries, employee bonuses, depreciation expense of initial investment costs on fixed assets. The residual value of the gross profit after deducting the operating expenses is profit before interest and taxes which can be used as a measure of the performance of production or operation.

For the first five-year income statement with the most likely or normal planning scenario can be seen in table no 3, Graphic depicting trend of sales growth, gross profit margin, net profit, and net income ratio to sales of PT. Tire Mandiri in the first five years can be seen from figure no 2.

The total current assets of the company are greater than the total liabilities so that the net worth of the company is positive. For 5 years, the company invested fixed assets at the beginning of its business of about 1.2 billion and 2.5 billion by the end of the second year. The following years until the end of the fifth year the company made no additional investments in fixed assets. In the third year, the company began distributing dividends to shareholders until the fifth year. Projection of balance sheet of PT. Tire Mandiri at the end of December in the first five years can be seen in table 4. Company capital structure on the first five year can be seen in figure no 2.

Table 3 - Income Statement for the first five year

(unit in Rp. 000)

Pro Forma Profit and Loss PT. Tire Mandiri

Year 1 31 Desember 2018 Year 2 31 Desember 2019 Year 3 31 Desember 2020

Sales revenue 10,875,000 16,100,000 21,000,000

Direct Cost of Sales Other Direct Cost of Sales Total Direct Cost of Sales 5.587.500 0 5.587.500 8.455.000 0 8.455.000 10.701.500 0 10.701.500

Gross Profit 5,287,500 7,645,000 10,298,500

Gross Proft Margin (%) 48.6% 47.5% 49.0%

Operational Expense

General & Administrative Expense Salary Expense Depreciation Total Operational Expense 1.125.389 1.534.298 521.131 3.180.818 1.107.233 2.099.857 521.131 3.728.221 1.181.823 2.238.615 831.131 4.251.570

Profit Before Interest & Taxes 2,106,682 3,916,779 6,046,930

Interest 597.923 454.659 289.268

Profit before Taxes 1,508,759 3,462,119 5,757,662

Other Reveneu Tax Incurred 0 377.190 0 865.530 71.875 1.453.790

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Net Profit 1,131,569 2,596,590 4,375,746

Net Profit/Sales (%) 10% 16% 21%

(unit in Rp. 000)

Pro Forma Profit and Loss PT. Tire Mandiri

Year 4 31 Desember 2021 Ye ar 5 31 Desember 2022

Sales revenue 24,100,000 29,500,000

Direct Cost of Sales Other Direct Cost of Sales Total Direct Cost of Sales 12.460.000 0 12.460.000 15.521.000 0 15.521.000

Gross Profit 11,640,000 13,979,000

Gross Proft Margin (%) 48.3% 47.4%

Operational Expense

General & Administrative Expense Salary Expense Depreciation Total Operational Expense 1.284.096 2.450.717 831.131 4.565.944 1.350.524 2.684.028 376.313 4.410.865

Profit Before Interest & Taxes 7,074,056 9,568,135

Interest 103.950 0

Profit before Taxes 6,970,106 9,568,135

Other Reveneu Tax Incurred 158.125 1.774.152 431.250 2.478.284

Net Profit 5,354,080 7,521,101

Net Proft/Sales (%) 22% 25%

In the cash flow statement, cash receipts and payments are classified according to three main categories, namely operating activities, investing activities and financing activities. For the report format used, PT. Tire Mandiri uses the Direct Method cash flow statement format. For operational activities, cash inflows occur annually from the sales department with an increasing value each year. Cash outflows or expenditure on operating activities, divided into six categories: (1) direct cost of sales, (2) general operating and admin expenses, (3) the employee bonus, (4) salary expenses, (5) interest and (6) income taxes. Direct cost of

sales is a variable cost of sales as listed in table 2 but without employee fee PT. Tire Mandiri because the employee fee expense is presented separately on the employee bonus item. For general operating and admin expenses are all expenses incurred fixed costs of operations, human resources, marketing, and other departments but does not include the cost of salaries and employee benefits due to salary and benefit costs of items shown separately in item salary expenses. For interest is interest expense arising from bank loan filed by PT. Tire Mandiri in financing the company's operations.

Figure 2 - Capital Structure of PT. Tire Mandiri

There are two cash flow of this activity during the first five years. Cash outflows or expenses occurred at the initial investment stage and the end of second year for operational car investment. As for financing activities or finance, cash inflows occur in the first year of the capital itself and bank loans. Cash outflows occur in the first four years of repayment of principal loan principal with fixed annual value.

Table 4 - Balance Sheet for the first five year

(unit in Rp. 000)

Pro Forma Balance Sheet PT. Tire Mandiri

Year 1 Year 2 Year 3

Item

31 Desember 2018 31 Desember 2019 31 Desember 2020

Assets

Current Assets

Cash Investment 3,192,098 3,875,326 4,702,524

Account Receivable 543,750 805,000 2,150,000

Total Current Assets 3,735,848 4,680,326 6,852,524

Fixed Assets 1,139,775 3,619,775 3,619,775

Depreciation Accumulation 521,131 1,042,263 1,873,394

Total Fixed Assets 618,644 2,577,513 1,746,381

Total Assets 4,354,492 7,257,839 8,598,905

Liabilities and Equity

Account Payable 0 0 0

Bank Loan 2,222,923 2,529,680 495,000

Total Liabilities 2,222,923 2,529,680 495,000

Cash Investment 1,000,000 1,000,000 1,000,000

Retained Earnings 0 1,131,569 3,728,159

Dividen 0 0 1,000,000

Earnings 1,131,569 2,596,590 4,375,746

Total Equity 2,131,569 4,728,159 8,103,905

Total Liabilities and Equity 4,354,492 7,257,839 8,598,905

Net Worth 1,512,925 2,150,646 6,357,524

Table 4 - Balance Sheet for the first five year (continue)

(unit in Rp. 000)

Pro Forma Balance Sheet PT. Tire Mandiri

Item Year 4 31 Desember 2021 Ye ar 5 31 Desember 2022

Assets

Current Assets

Cash Investment 4,962,735 5.690.149

Account Receivable 2,580,000 1.750.000

Total Current Assets 7,542,735 7.440.149

Fixed Assets 3,619,775 3.619.775

Depreciation Accumulation 2,704,525 3.080.838

Total Fixed Assets 915,250 538.938

Total Assets 8,457,985 7,979,086

Liabilities and Equity

Account Payable 0 0

Bank Loan 0 0

Total Liabilities 0 0

Cash Investment 1,000,000 1.000.000

Retained Earnings 7,103,905 7.457.985

Dividen 5,000,000 8.000.000

Earnings 5,354,080 7.521.101

Total Equity 8,457,985 7.979.086

Total Liabilities and Equity 8,457,985 7,979,086

Net Worth 7,542,735 7,440,149

Table 5 - Cash Flow Statement

PT. Tire Mandiri 5-Year Cash Flow

(unit in Rp. 000) 12/31/2020 3.875.326 4.702.524 12/31/2021 4.702.524 4.962.735 12/31/2022 4.962.735 5.690.149

For the Year Ending Cash at Beginning of Year 12/31/2018 12/31/2019 3.192.098

0

Cash at End of Year 3.192.098 3.875.326

Operations 2018 2019 2020 2021 2022

Cash receipts from

Customers 10.331.250 15.838.750 19.655.000 23.670.000 30.330.000

Other operations 0 0 0 0 0

Cash paid for

Direct cost of sales (4.500.000) (6.845.000) (8.601.500) (10.050.000) (12.571.000)

General operating and admin expenses (1.125.389) (1.107.233) (1.181.823) (1.284.096) (1.350.524)

Employee Bonus (1.087.500) (1.610.000) (2.100.000) (2.410.000) (2.950.000)

Salary expenses (1.534.298) (2.099.857) (2.238.615) (2.450.717) (2.684.028)

Interest (597.923) (454.659) (289.268) (103.950) 0

Income taxes (377.190) (865.530) (1.453.790) (1.774.152) (2.478.284)

Net Cash Flow from Operations 1.108.950 2.856.471 3.790.003 5.597.086 8.296.164

Investing Activities

Cash receipts from

Sale of property and equipment Collection of principal on loans Sale of investment securities Cash paid for

Purchase of tools and equipment Making loans to other entities Purchase of investment securities Net Cash Flow from Investing Activities

0 0 0

(1.139.775) 0 0

(1.139.775)

0 0 0

(2.480.000) 0 0

(2.480.000)

0 0

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5.658.125 0 0 0

(2.500.000) 71.875

(5.500.000) (15.000.000) 158.125 431.250

Financing Activities

Cash receipts from Investor Owner

Borrowing from Bank Cash paid for

Repayment of loans Dividen

1.000.000 0 00 3.000.000 1.438.000

(777.077) 0

(1.131.243) (2.034.680) (495.000)

0 (1.000.000) (5.000.000) (8.000.000)

Net Cash Flow from Financing Activities 3.222.923 306.757 (3.034.680) (5.495.000) (8.000.000)

Net Cash Flow 3,192,098 683,228 827,198 260,211 727,414

Table 6 - Company Business Ratio

Year 1 Year 2 Year3 Year 4 Year 5

Item

2018 2019 2020 2021 2022

Sales Growth 0.0% 48.0% 30.4% 14.8% 22.4%

Percent of TotalAssets

Cash 73.3% 53.4% 54.7% 58.7% 71.3%

Account Receivable 12.5% 11.1% 25.0% 30.5% 21.9%

Fixed Assets 14.2% 35.5% 20.3% 10.8% 6.8%

Total Assets 100.0% 100% 100% 100% 100%

Curre nt L iabilitie s 51.0% 35% 6% 0% 0%

Long-term Liabilities 0.0% 0.0% 0.0% 0.0% 0.0%

Total Liabilities 51.0% 34.9% 5.8% 0.0% 0.0%

Net Worth 40.5% 46.0% 92.8% 100.0% 100.0%

Sales 100.0% 100.0% 100.0% 100.0% 100.0%

Gross Margin 48.6% 47.5% 49.0% 48.3% 47.4?/o

General and Administrative Expenses 24.5% 19.9% 16.3% 15.5% 13.7%

Operating Profit Margin 19.4% 24.3% 28.8% 29.4% 32.4?/»

Net Profit Margin 10.4% 16.1% 20.8% 22.2% 25.5%

Main Ratios

Current 1.68 1.85 13.84 0.00 0.00

Cash 1.44 1.53 9.50 0.00 0.00

Debt to Asset Ratio 0.51 0.35 0.06 0.00 0.00

D ebt to Equity Ratio 1.04 0.54 0.06 0.00 0.00

Times Interest Earned Ratio 3.52 8.61 21.15 69.57 0.00

Operating Income to L ¡abilities Ratio 0.95 1.55 12.22 0.00 0.00

Account Receivable Turn Over 20.00 20.00 9.77 9.34 16.86

Working Capital Turn Over 3.03 3.25 2.83 2.31 2.31

Fixed Assets Turn Over 12.37 10.07 9.71 18.11 40.57

Total Assets Turn Over 4.86 4.92 4.38 4.10 4.38

Return on Assets 26.0% 35.8% 50.9% 63.3% 94.3%

Return on Equity 53.1% 54.9% 54.0% 63.3% 94.3%

In performing the financial function, there are some activities that may pose a risk. By mapping out possible risks and finding some appropriate solutions this can minimize the risk / loss that will occur and if the risk is inevitable PT. Tire Mandiri already has the best solution to deal with that risk.

Financial and operational control of PT. Tire Mandiri is organized in stages covering corporate governance organs, as follows:

The Director develops the Company's internal control system in order to function effectively to secure the Company's investment and assets. The internal control system developed includes the following:

• Internal control environment within a disciplined and structured Company;

• Assessment and management of business risks, a process for identifying, analyzing, assessing and managing relevant business risks;

• Control activities are actions taken in a process of control over the Company's activities at each level and unit within the Company's organizational structure, including authority, authorization, verification, reconciliation, performance appraisal, division of tasks and security of the Company's assets;

• Information and communication system is the process of presenting a report on financial activities and compliance with the rules and regulations applicable to the Company;

• Monitoring is the process of assessing the quality of the internal control system including the internal audit function at each level and the organizational structure of the Company;

• Development of Internal Control System which covers the five points above, need to be equipped with Standard Operating Procedure (SOP) from each of these items. SOPs are also intended to develop work plans, work procedures, recording, reporting, personnel guidance and internal reviews from aspects of production, marketing, finance and business development as well as other aspects.

Internal Audit assists the Director in performing the Company's internal audit of corporate finance and operations and assesses control, management and implementation and provides improvement advice;

The Director shall follow up on the Internal Audit report. The Audit Committee assesses the implementation of activities and audit results, conducted by the Internal Audit, provide recommendations for the improvement of the management control system, ensures that there is a satisfactory review procedure for all information issued by the Company and identifies matters that require the Director's attention. In conducting the assessment, the Company uses the criteria established by the Internal Control - Integrated Framework issued by the Committee of Sponsoring Organizations of the Tradeway Commission (COSO).

Implementation of the code of ethics and all Company regulations is the commitment and responsibility of all levels of employees of the company or stakeholders. Stakeholders and external parties of the Company (Subscribers, Business Partners and Communities) may report errors of both the Company's code of conduct and other Company regulations.

The Company is required to follow up reporting that is potentially harmful to the Company and may damage the Company's image, among others, caused by deviation, manipulation and so forth. In the event of any violation or deviation from the code of ethics and any Company regulations may report such violations through:

1. Direct supervisor;

2. Persons specially appointed by the Company;

3. The Complaint Box, e-mail, fax, telephone or other media specified by the Company.

Disclosure must be done in good faith and is not a personal complaint nor is it based

on a bad will / slander. The complainant is required to clearly identify the identity of the report, accompanied by relevant supporting evidence. The recipients of the report shall keep the identity of the informant secret as part of the Company's efforts to protect the complainant. The Company shall follow up any reports received pursuant to applicable procedures and mechanisms. The Company will also provide legal protection in accordance with applicable laws and regulations.

The Company will follow up any reports received pursuant to applicable procedures and mechanisms and apply sanctions for violations as follows:

• Any employee who is proven to have violated the company's code of ethics and regulations will be given sanctions in accordance with applicable laws and regulations;

• Sanctions for employees who commit offenses are stipulated by the Director after receiving reports from the employee's immediate supervisor;

• The Director shall decide the provision of guidance, disciplinary and / or other measures and the prevention to be carried out by the direct supervisor in their respective circles;

• Sanctions for the Director if the offense is decided by the Shareholder;

• If a partner or other stakeholders who committed an offense, will be subject to the provisions as contained in the contract. If related to a criminal offense will be forwarded to the authorities.

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