Compliance as a Foundation, Not a Formality

Guidance for Employees, Management, and Business Partners

Our Commitment to Responsible Business Conduct

How We Operate

It isn’t a checklist we complete. It’s how business gets done, every time.

At SYNA, compliance is not a department or a deadline — it is a standard of conduct that runs through every decision, every relationship, and every company that operates under our name.

Where the Line Is Drawn

The law sets a minimum. We don’t stop there.

We hold ourselves and our portfolio companies to full compliance with applicable laws, regulations, and ethical standards. This is not a minimum requirement. It is our baseline — the starting point from which we build businesses that are trusted, resilient, and built to last.

What Holds Us Together

Three beliefs, applied without exception, by everyone.

Our approach to compliance is rooted in three convictions:

That principled conduct and strong performance are inseparable.
That accountability must be active, not passive.
And that the culture of a company is reflected most clearly in how it behaves when no one is watching.

Legal Notice

As a holding company, SYNA does not interfere in the day-to-day operations of each company within our portfolio. We provide direction through guidelines and policies covering compliance standards and the Code of Conduct — a framework that serves as a reference for each company in conducting its business responsibly and in compliance with applicable laws.

SYNA conducts oversight to ensure that every company within our portfolio understands and implements the established guidelines without exception. Such oversight is not intended to directly control the business activities of each company, as every company is an independent legal entity with its own vision, mission, and way of working, shaped by years of experience in its respective field. The guidelines established by SYNA are intended not to change those ways of working, but to ensure that each company remains on the right path and is protected from legal risk.

If any company within our portfolio violates the established guidelines, whether intentionally or unintentionally, in the course of conducting its business activities, including when entering into business relationships or making internal and external decisions, and such violation gives rise to legal consequences in criminal or civil matters, then full responsibility for such violation shall rest with the company concerned, and not with SYNA.

Zero Tolerance

SYNA maintains an absolute zero-tolerance position on corruption, bribery, and money laundering — without exception, without qualification, and without compromise.

01

Anti-Corruption & AML

These are not policies that exist on paper. They are active commitments embedded in how every company within our portfolio is governed, how decisions are made, and how relationships are conducted.

We comply fully with Indonesian anti-corruption law (UU Tipikor), anti-money laundering law (UU TPPU), and all applicable regulations enforced by the KPK and PPATK.

02

No Exceptions

No business objective, commercial pressure, or relationship — internal or external — justifies any deviation from this position.

Personal interests must remain strictly separate from company interests, and any conflict of interest — even its mere appearance — must be disclosed and resolved without delay.

03

Tax Integrity

We are equally uncompromising in our commitment to full tax compliance. SYNA and all companies within our portfolio meet their statutory tax obligations accurately, transparently, and on time — in full accordance with applicable Indonesian tax law.

We do not engage in tax evasion, abusive tax arrangements, or any practice designed to misrepresent our true tax position.

The SYNA Code of Conduct

The principles that guide our decisions, actions, and business relationships.

Our Code of Conduct establishes the principles and standards that guide every company within the SYNA portfolio. It reflects our commitment to ethical business practices, responsible governance, respect for people, and long-term value creation.

These principles apply across our portfolio companies and serve as the common framework for how we conduct business, make decisions, and build trusted relationships with our stakeholders.

Human Rights & Labor
Environment
Fair Competition
Data Protection

We recognize and uphold the Universal Declaration of Human Rights. We respect the core labor standards of the ILO and comply with Indonesian labor law, embracing diversity and equal treatment regardless of gender, ethnicity, age, religion, or physical and mental ability.

We are committed to the responsible management of natural resources and encourage environmentally sound practices across our operations, in compliance with applicable environmental regulations including AMDAL requirements.

We champion fair and transparent markets. We comply with all applicable competition laws and refrain from any form of anti-competitive conduct, including price-fixing, market allocation, or abuse of dominant position.

We handle personal data with the utmost care, in full compliance with the Indonesian Personal Data Protection Law (UU PDP) and all applicable regulations.

Reporting Concerns

We provide a confidential and independent Whistleblowing System that allows employees, business partners, and other stakeholders to report suspected misconduct in good faith, without fear of retaliation.