Code of Conduct

Code of Conduct is a guideline that covers values and standards of business practice adopted by the Company and is a reference for each individual, and at the same time describe all parties (shareholders) how the Company runs its business. It has become a guideline for employees to work upholding integrity and discipline to prevent any violation and fraud made.

All articles and rules stated in the Code of Conduct are applied to all individual with no exception. The Company will give punishment to all employees including BOC and BOD who break the rules according to the Company's laws and regulations.


Code of Conduct


Article 1 - Background and Purpose of the Code of Conduct
Ciputra Group(organization)’s mission to become a superior, profitable and healthy organization requires a clear and challenging vision, innovative business development strategies, effective and efficient resources management, as well as effective leadership to be realized. Furthermore, Good Corporate Governance including risk management, adequate internal control, and cultural control must be in place for the organization to survive and stay profitable and healthy.

This Code of Conduct is a set of Corporate Governance Rules describing the organization’s values and standard business practice used as a reference for individuals joining the organization, as well as an explanation for stakeholders regarding Ciputra Group’s standard business practice.

This Code was formulated using integrity as its underlying philosophy. The key to its successful implementation is the cooperation and participation of all Managers and Employees of the Organization.

Definition of Integrity, Cooperation and Participation are:
Integrity: upholding honesty, ethics and morals to create a conducive working environment that optimizes the organization’s value for stakeholders in accordance to its vision and mission.
Cooperation: having respect and appreciation for each other in performing duties, as well as being willing to assist and support each other in improving productivity, in accordance to the organization’s goal.
Participation: All managers and employees participate and contribute in fulfilling their duties and responsibilities to the best of their ability in order to achieve organizational goals.

Article 2 - Stakeholders

Stakeholders are parties with an interest in or a connection with the organization's activities. Stakeholders consist of:

  • Management: Board of Directors and Commissioners, the body authorized to manage the Organization in accordance with its purposes and objectives.
  • Employees: Individuals working in the Organization in exchange for salary.
  • Customer: Buyer and user of products and services produced or marketed by the organizations.
  • Shareholders: Individuals or institutions listed in the Register of Shareholders (DPS) of the Organization.
  • Suppliers: Business partners engaged in the business of providing goods or services required for the Organization’s business activities. The term includes vendors, contractors, consultants and suppliers.
  • Public: Third parties directly or indirectly affected by the organization’s activities.

Article 3 - Code of Conduct

  • Organization Performance & Quality

The organization's long-term success is directly affected by management and employees’ performance, individually as well as a part of a team. Therefore, every individual is expected to perform and contribute their best to the organization.

Employees’ performance plays an important role in improving the organization’s performance. Therefore, employees are expected to avoid acts of carelessness or negligence, i.e.:

  • In a purchase assignment, employees are expected to obtain the best quality product(s) with the best price and payment terms;
  • In a marketing assignment, employees are expected to offer the best price, payment terms, and service to customers. Employees may not be deceptive in any parts of the marketing process;
  • In an asset management and safeguarding assignment, employees are required to preserve, protect and manage the asset(s) and avoid unexpected risk of disappearance, damage, improper usage or mismanagement;
  • In a supervision assignment, employees are required to perform the oversight function to meet quality standard,time and cost budgeted;
  • In an authoritative position, employees are discouraged from manipulating and approving decisions needing approval from higher authorities;
  • It is mandatory for all employees to report any infringement of the above regulations resulting in the hindering of the organization’s goal achievement.

Quality products and services can be broadly defined as products and services with added value to its users. It is the shared responsibility of managers and employees to provide such products and services to enhance the organization’s reputation and performance. Therefore, all managers and customers are expected to identify and understand customers’ needs in order to provide such products and services.

  • Diversity , Participation and Respect

The organization is committed to provide a conducive working environment offering equal opportunities for every individual to thrive and succeed. Therefore, each individual in the organization is responsible for creating a workplace where every individual is treated fairly.
The organization respects every employee’s opinions, beliefs and values, and encourages each employee to do the same.

  • Moral Turpitude (Workplace Violence, Alcohol and Drugs)

Every manager and employee is obliged to refrain from disgraceful deeds and actions, such as violating organizational rules, national laws, as well as social norms prevailing in the society, including; sexual misconduct, cheating and all forms of gambling that potentially result in the tainting of the organization, personal and other party’s reputation.

The organization strives to provide a safe working environment for all employees, thus it does not tolerate acts of violence and abusive behavior that can lead to / or cause workplace violence committed by / or against management and employees. Encapsulated under the definition of prohibited behavior are acts such as: threatening, physical abuse, damaging private or the organization’s property and sabotage.

Maintaining a work environment free from the influence of alcohol and drug abuse is the obligation of all manager employees. Alcohol and drug abuse compromises the safety of people involved in the organizations as well as the products and services it provides, therefore it disrupts the organization’s ability to serve its purpose. The organization does not tolerate any use and misuse of alcohol and drugs for someone tied to the Company. All managers and employees are required to participate in any alcohol and drug Inspection conducted regardless of its timing. Should an employee be prescribed medicinal drugs affecting his/her ability to work, he/she are required to disclose such prescription to his/her manager.

  • Smoking in the Workplace

In order to maintain the health and comfort of all individuals in the organization, smoking is prohibited within the Group’s offices, especially in all closed, air-conditioned rooms.

  • Information and Communication
    • Company Information and Public Communication

The organization strives to provide relevant information in an accurate and timely manner to its investors, the media and the public. The organization puts great care in every information publication. External communication is the responsibility of the Department of Corporate Communications, Investor Relations and the Corporate Secretary.

Only authorized members of the organization may make statements and speeches to as well as accept interviews with third parties including the media on behalf of the organization. Employees of certain positions such as the General Manager of a project may provide statements about projects he/she manages. Other employees require the approval from the Board of Directors.

    • Confidential Information (Including Insider Information)

Confidential Information is a valuable asset to the organization. Such information include information regarding: prices and costs, mergers and acquisitions, business processes and procedures, financial data, trade secrets and skills, computer programs, wages and salaries, sales and marketing programs, customers / suppliers / sub contractors , contract documents, internal audit results. Confidential information also includes information given to the organization as part of a business agreement, such as: personal information of employees, customers and contractors or the confidential information of suppliers and business partners.

Information mentioned above may only be used in a safe situation for the organization’s needs, not for personal gain. Confidential information may only be given to authorized parties needing the information for his/her job. Employment information may only be given to an authorized member of a third party, should there be a legitimate business relationship between the organization and the third party and a need to know for the third party as long as the disclosure does not violate confidentiality agreements. Unauthorized disclosure may impact the concerned parties’ businesses, thus unauthorized disclosure is considered a violation of this Code of Conduct, as well as the national law in some cases and may lead to consequences such as: fines, penalties or legal action against the parties involved.

Individuals with access to confidential information must protect it. Every employee has the duty and obligation to protect such confidential information. This obligation holds even after employment is terminated.

    • Insider’s Information in Security Trading

Every manager and employee may hold "insider information" regarding the organization ahead of publication. But security trading based on "insider information" or communicating such information to third parties who uses the information for security trading purposes are considered a violation of the law thus such acts are prohibited by the Company. Insider Information includes; corporate action plan, performance data, legal disputes, and other information that could affect the outlook for stock prices.

  • Conflict of Interest

Every manager and employee must act in the organization’s interest and avoid participation in any activity that causes conflict with the organization’s interest.

Some situations where a conflict of interest may occur are:

  • Side Business and Moonlighting

Employees are not permitted to engage in private business (directly or indirectly) either: supplying for the organization, redistributing its products, of a similar or competing nature to it.

For cases where an employee’s family member has had a business of a nature mentioned above before the commencement of his/her employment, he/she should declare such situations to the HR (human resources) department and request an approval from management, regarding the conflict of interest risk.

Acts such as moonlighting and owning a side business which may cause a conflict of interest with any manager or employee’s work at the organization are prohibited.

Employees are prohibited from engaging in personal activities not relevant to his/her duties and responsibilities during working hours and using office facilities and other facilities provided for the purpose of his/her work, included in this prohibition are activities for social organizations not supported by written consent from management. Should employees engage in activities for a social organization supported by a written consent from management, he/she is required to report such cases to his/her supervisor and the HR department.

Corporate Opportunities
When a Board or Employees come across business opportunities that interest the organization, he/she is prohibited from exploiting such opportunities for personal interest directly or indirectly.

  • Family Relationships

In order to maintain a professional work environment, the organization does not justify:

Two related employees to work for the same company/project.

Family relationships are defined to be one between:

  • Spouses
  • Siblings (biological/adopted/in-law/step)
  • Parent - Child (biological/adopted/in-law)

Exceptions for such cases only permitted when the potential for conflict is minimal, explained in writing and approved by 2 (two) Directors.

  • Use of Corporate Assets

Organization assets are intended for the use and the benefit of the organization. Management and employees are required to maintain and use these assets as appropriate. Employees are not allowed to remove, transfer or lend tools and work equipment owned by the organization or use it for personal purposes without prior approval from HR department and General Manager, or Head of Business Unit.

  • Accepting Gifts, Entertainment and Bribery / Kick Back

Accepting Gifts

  • Managers and employees are prohibited from accepting gifts from third parties associated with the Company as they may affect the organization’s business relationships, for example:
  • Influence the concerned decision making process;
  • Result in the acquisition of a service / benefit to the third party;
  • Received as a reward for a service / benefit provided to a third party, either in the past, present and future;
  • Etc.
  • Should managers and employees be forced to accept a gift (including holiday baskets), in principle, the gift is property of the organization and therefore recipient of such items should be reported to the receiving business unit manager to decide upon its use.


Acceptances of gifts are tolerated when:

  • Refusal or return of the gift is not practical (i.e. when gift is in the form of personal needs goods or food items);
  • Denial of gift is expected to post harm to the organization (e.g. damage good relations between the organization and the giving party).

Exceptions when a particular occasion an employee may receive a gift or promotional item if it fulfills the following requirements:

  • Gifts given complies to the organizational rules;
  • Gifts are given on an occasional basis;
  • Gifts were not requested;
  • Acceptance of gifts is not publicly humiliating for the organization and receiving employee;
  • The value of gifts are the lowest of: 5% of the concerned employee’s monthly salary or Rp. 500,000.

Gifts received for activities undertaken during working hours are considered property of the organization and shall either be surrendered to the organization or returned to the giver.

The organization will actively communicate to parties with whom it has a business relationship not to give gifts to managers and employees.

The company also will minimize gifts given to business partners.

Accepting Entertainment
Employees are allowed to receive occasional invitations to sporting and entertainment occasions if:

  • Activities do not affect business relationships between the organization and giving party;
  • Activities comply with the giving company’s rules;
  • Activities were not requested;
  • Activities are offered on an occasional basis, of a reasonable value and are not excessive;
  • Acceptance of such invitations is not publicly humiliating for the organization and receiving employee;
  • Activities are approved by the employee’s manager

Accepting Bribery and Kickback (Unofficial Commission)
Bribery or Kickback is the receipt of money, fee, mark up on price spread, unofficial commission, credit, gifts, favors or anything of value, directly or indirectly compromising recipient’s professionalism or to enrich themselves; family or a particular third party. Managers and employees are not permitted to accept any form of bribery and Kickback.

Lending and / or borrowing money
Employees are not allowed to use organizational money for personal, private use, i.e. lending and borrowing at an interest to third parties associated with the activities of the organization.

  • Electronics and Computer Technology Usage

The organization’s electronics and computer technology, including e-mail, voice mail, cell phones, computers, network computers, software, and internet access are considered as its property. Occasional use of the phone, e-mail, Internet, and voice mail for private purposes is permitted as long as it is reasonable and does not violate the law. Managers and employees are prohibited from using company computers, networks, and networks connected to external Internet services for non-company activities, such as: working on side jobs, sending chain letters, personal political activities (including incitement, defamation, etc).

Each manager or employee is given a personal account with a secret password to access the organization’s system and networks and are therefore personally responsible for all activities that occur on his/her account. The organization policy is for each account holder to protect his/her password for self-protection. He/she is prohibited from sharing passwords and allowing others to use their accounts.

It is important for every employee to know that an authorized organization representative may monitor the organization's systems and networks at any time, without notice. By using electronic resources owned by Ciputra Group, each person is considered to consent this activity and understand that information produced, received, or distributed through this system is not private.

The organization does not tolerate the use of its system to generate, store or transmit information that is hostile, malicious, prohibited by law, discriminatory, indecent, or offensive. Sites containing forbidden, sexual, and discriminatory contents may not be accessed using organization equipment or network.

Computers are equipped with legitimate softwares with appropriate copyrights, trademarks or patents. Managers and employees are prohibited from installing softwares that are unauthorized and/or unrelated to their job as well as making copies of prohibited electronic data on the organization's system.

The organization provides an internet enabled network and internet services to facilitate its business. Telephone, e-mail and internet may not be used to share confidential organization information that is not for the public, such as: proprietary, copyright, or any information that may cause damage to the organization or its employees. Failure to maintain the security of the organization’s computer resources is considered a severe violation of this Code of Conduct.

Article 4 - Code of Conduct Regarding Customers

Customers are the key for Ciputra Group’s business continuation, therefore, meeting their needs and expectations is the key to the success of the organization.

  • The organization, through its managers and employees strive to:
  • Provide quality products and services (including after-sales service);
  • Meet or exceed customer expectations;
  • Communicate honestly and fairly.


Advertising is a communication tool to customers
Ciputra Group delivers ad



Article 1 - Objectives

The purpose of sanctions for the violation of this Code of Conduct is:

  • To protect and prevent managers and employees from committing disgraceful acts that can harm and damage his/her and/or the organization’s reputation and credibility.
  • To encourage managers and employees to behave and act in accordance to the organization’s policies.
  • To discipline violating managers and employees.

Sanctions will be given based on the organization regulations (particularly article 45 and article 46) and the applicable legislation.

Article 2 - Serious Violations

Some examples of violations of this Code of Conduct categorized as Serious Violations are:

  • Moral turpitude
  • Inflicting physical injuries upon others.
  • Racially, sexually, socially and politically incorrect statements.
  • Immoral acts, adultery and all forms of gambling that will result in harming the good name of the organization and others.
  • Intentionally damaging personal or organization belongings.
  • Sabotage.
  • Alcohol and drugs abuse.
  • Information and Communication
  • Conducting / participating in an interview or making a misleading speech that is misleading or detrimental to the Company on behalf of the Company without authority and without the consent of the Directors of the Company.
  • Not keeping confidentiality of organization data.
  • Abusing organization’s confidential data for personal or other party’s interest.
  • Unauthorized disclosure of confidential data.
  • Misuse of insider information for the benefit of parties other than the organization.
  • Conflict of Interest
  • Conducting personal business that can influences the organization’s decision making process.
  • Acting as a manager, employee, consultant, owner or agent of companies engaging in a business relationship with the organization, thereby affecting the decisions taken for it.
  • Taking the organization’s business opportunity for the benefit of parties other than the organization.
  • Accepting a side job from competitors, suppliers or customers.
  • Accepting bribes and kickbacks.


  • Abuse of Electronics and Computer Technology
  • Use of the organization’s electronic equipments and computer technology for hostile, malicious, prohibited, discriminatory, obscene or offensive activities.
  • Installing unofficial software, illegal copying of electronic data in the system, which may impact on the organization’s reputation and survival.
  • Customer
    Providing misleading and false information to customers.


  • Shareholder
    Not maintaining the trust of shareholders by providing misleading information about the organization’s performance, etc.
  • Suppliers
    Not being neutral / impartial in choosing and negotiating with suppliers, resulting in extra costs for the organization.


  • Employee aspirations related actions
  • Making a false report or complaint.
  • Divulging confidential reports and / or information regarding reporting individuals who made reports of a Code of Conduct violation.
  • Revenger actions to complainant.



All managers and employees of Ciputra Group receives a copy of this Code of Conduct asa guide onstandard behavior expected in acting as part of the organization. This code applies to every individual employed by the organization, including: Directors and Commissioners; permanent, temporary and part time employees;as well as representatives and agents of the organization.

This code may not lay out procedures to every problem may be encountered throughout the organization’s business operations. Should there be any questions or doubts regarding standard business practices, please enquire managers or the HR department.

As mentioned in the background and purpose of this code in the first chapter, the key to successful implementation and compliance of this code requires the 'cooperation and participation' of all managers and employees of the Company.

Managers are expected to set an example for his/her subordinates in the implementation of this code.