ASEAN CG Scorecard

Level 1

Part A: Rights of Shareholders

No	Subject	Implementation in 2020	Reference
No	Subject	Implementation in 2020	Website	Integrated Annual Report 2020
A.1	Basic Shareholder Rights
A.1.1	Does the company pay (interim and final/annual) dividends in an equitable and timely manner; that is, all shareholders are treated equally and paid within 30 days after being (i) declared for interim dividends and (ii) approved by shareholders at general meetings for final dividends. In case the company has offered Scrip dividend, did the company paid the dividend within 60 days?	The Company does pay dividend to the shareholders in an equitable and timely manner pursuant to applicable law. On dividend distribution year book 2020, XL Axiata complies with (i) Law No.40/2007 (Company Law); (ii) Indonesian Stock Exchange (IDX) Regulation Number II-A on Securities Trading; (iii) Decree Letter of Directors of IDX No. Kep-00023/BEI/03-2015; (iv) OJK Regulation No. 15/POJK.04/2020, and other related regulation for the dividend distribution procedure. XL Axiata has distributed dividend for year book 2020 on time according to the prevailing laws.	Dividend Information	Page 58
A.2	Right To Participate In Decisions Concerning Fundamental Corporate Changes
	Do shareholders have the right to participate in
A.2.1	Amendments to the Company's constitution?	The shareholders have the rights to participate in amendments of Company’s constitution (AOA). XL Axiata in this matter complies with (i) Article 19 of the Company Law and (ii) Article 12 of the Company's AOA which stipulates that any changes to the Company's AOA must be approved by more than 2/3 (two thirds) of the total XL Axiata’s shares with valid voting right present at the GMS. In 2020 XL Axiata amended its AOA in order to make an adjustment according to OJK Regulation No. 15/POJK.04/2020 on the Plan and Implementation of General Meeting of Shareholders of Public Companies (OJK Regulation. 15/2020) which has been approved in the EGMS dated 27 October 2020 In 2021, XL Axiata amended Article 3 of its AOA on the purpose and objectives of the Company pursuant to OJK Regulation No. 17/POJK04/2020 on the Material Transaction and Change of Business Activities (OJK Regulation 17/2020), which has been approved in AGMS dated 23 April 2021	Summary of EGMS 27 October 2020 Summary of AGMS 23 April 2021	Page 89
A.2.2	The authorisation of additional shares?	The shareholders do involve in authorization of additional shares. In accordance with OJK regulations, additional capital with or without pre-emptive right must obtain shareholder approval through the GMS. In 2020 and 2021, there were additional shares issuance of XL Axiata conducted in relation to the Employee Share Ownership Program which previously has been approved in EGMS dated 10 March 2016 as later the provisions amendment has also been approved in EGMS dated 30 September 2019.	Summary of EGMS 10 March 2016 Summart of EGMS 30 September 2019	Page 89
A.2.3	The transfer of all or substantially all assets, which in effect results in the sale of the company?	In accordance with prevailing regulations and Article 13 of Company’s AOA, any merger, dissolution or acquisition of the Company must be approved by the GMS. In 2020 XL Axiata did not conduct any of these corporate actions.	Articles of Association	Page 84
A.3	Right to Participate Effectively in and Vote in GMS and should be Informed of the Rules, including Voting Procedures that Govern General Shareholder Meetings
A.3.1	Do shareholders have the opportunity, evidenced by an agenda item, to approve remuneration (fees, allowances, benefit-in-kind and other emoluments) or any increases in remuneration for the nonexecutive directors/commissioners?	Based on Article 96 of the Company Law, the GMS has the authority to approve remuneration for the BOC and BOD. In 2020, the approval on remuneration of the BOC and BOD of XL Axiata is included in the Seventh Agenda of the AGMS dated 18 May 2020.	Summary of AGMS 18 May 2020	Page 112
A.3.2	Does the company provide non-controlling shareholders a right to nominate candidates for board of directors/commissioners?	The Company does provide the non-controlling shareholders a right to nominate a BOD and/or BOC under XL Axiata’s Nomination of Senior Executive Policy which regulates that any candidate for The BOD and BOC can be submitted by the Shareholder to the NRC without distinguishing between majority and minority Shareholders. In 2020 there are no minority Shareholders who submit candidate for the Board of Commissioners or Directors.	2020 Integrated Annual Report Nomination Policy	Page 104 Page 130
A.3.3	Does the company allow shareholders to elect directors/commissioners individually?	Based on the Article 14 (3) and Article 17 (3) of Articles of Association, the appointment of the BOC or BOD must obtain GMS approval. At the AGMS dated 18 May 2020 and EGMS dated 27 October 2020, voting regarding the approval of changes in the composition of the BOC and/or BOD were carried out in a closed manner whereby each Shareholder individually or through his proxy submitted his vote to be then calculated by the Notary.	Summary of AGMS 18 May 2020 and EGMS 27 October 2020	Page 88 Page 92
A.3.4	Does the company disclose the voting procedures used before the start of meeting?	XL Axiata has disclosed the voting procedures of GMS in the Meeting Rules of Conduct which has been published on the same day as the GMS invitation date. In AGMS dated 18 May 2020 and EGMS dated 27 October 2020, XL Axiata has published the Rules of Conduct on company’s website on the same day as the meeting invitation. The voting procedures for AGMS was read by the Corporate Secretary.	Meeting Rules of Conduct and Minutes of Meeting AGMS 18 May 2020 and EGMS 27 October 2020	Page 87 Page 90
A.3.5	Do the minutes of the most recent GMS record that the shareholders were given the opportunity to ask questions and the questions raised by shareholders and answers given recorded?	In GMS, the opportunity for Shareholders to raise questions was recorded in: The summary of minutes of meeting; The minutes of the GMS made by Notary 2020 Integrated Annual Report. Both in AGMS dated 18 May 2020 and EGMS dated 27 October 2020, there were no shareholders raising questions.	Summary of Minutes of Meeting AGMS 18 May 2020 and EGMS 27 October 2020	Page 87 Page 90
A.3.6	Does the company disclose the voting results including approving, dissenting, and abstaining votes for all resolutions/each agenda item for the most recent AGM?	The Company discloses the voting results including the agree, against, abstain and the total agree vote which recorded in Summary of Minutes of the Meeting. Notarial Deed on minutes of meeting. Both documents are published in the Company’s website	Summary of Minutes of Meeting AGMS 18 May 2020 and 27 October 2020	Page 86 Page 89
A.3.7	Does the company disclose the list of board members who attended the most recent GMS?	XL Axiata discloses the list attendance of Board members in GMS. Such list is set out in: The summary of minutes of meeting. The minutes of the AGMS made by Notary 2020 Integrated Annual Report.	Summary of Minutes of Meeting AGMS 18 May 2020 and 27 October 2020	Page 87 Page 89
A.3.8	Does the Company disclose that all board members and the CEO (if he is not a board member) attended the most recent AGM?	XL Axiata discloses the attendance information of BOD and BOC in GMS under 2020 Integrated Annual Report. In 2020, AGMS and EGMS were attended by all members of the BOC and BOD.	Summary of Minutes of Meeting AGMS 18 May 2020 and EGMS 27 October 2020	Page 87 Page 89
A.3.9	Does the company allow voting in absentia?	XL Axiata complies with OJK Regulation 15/2020, OJK Regulation 16/2020 and Article 11 of AOA, in voting the votes issued by shareholders apply to all shares held by them and shareholders have no right to give power to more than one proxy for a portion of their shares with a different vote. Voting by Shareholders do not present in the Meeting is not allowed except if represented by proxy. If the shareholders have given their votes electronically before the GMS is convened, therefore pursuant to OJK Regulation No. 16/2020, such shareholders shall be deemed attending the GMS. Voting of the AGMS dated 18 May 2020 and EGMS dated 27 Ocotber 2020 were conducted electronically This matter is also described under meeting rules of conduct	Meeting Rules of Conduct and Minutes of Meeting AGMS 18 May 2020 and EGMS 27 October 2020	Page 86 Page 89
A.3.10	Did the company vote by poll (as opposed to by show of hands) for all resolutions at the most recent AGM?	To comply with Article 11 of AOA and the Meeting Rules of Conduct of GMS, in AGMS dated 18 May 2020 and EGMS dated 27 October 2020 the vote of the Shareholders who participated in voting was collected and calculated by the Bureau of Securities Administration in front of the Notary.	Meeting Rules of Conduct and Minutes of Meeting AGMS 18 May 2020 and EGMS 27 October 2020	Page 86 Page 89
A.3.11.	Does the company disclose that it has appointed an independent party (scrutineers/inspectors) to count and/or validate the votes at the AGM?	Yes, XL Axiata has disclosed the appointment of Share Registrar to the public in 17 April 2020 for the AGMS, and 22 September 2020 for the EGMS . In regards to above information, XL Axiata has appointed 2 (two) independent parties to count and validate the votes in GMS, among others: Notary as a deed official who witnessed and heard directly the GMS; and The Share Registrar Bureau as a party who calculates and validates the vote results, which this information has also been disclosed at the beginning of the GMS and has been listed in the Deed of the Summary of GMS published in the Company’s website.	Minutes of Meeting AGMS 18 May 2020 and EGMS 27 October 2020 Disclosure Information – Appointment of Share Registrar	Page 86 Page 89
A.3.12	Does the company make publicly available by the next working day the result of the votes taken during the most recent AGM/EGM for all resolutions?	The Company complies with the Article 51 (2) and 52 (1) POJK 15/2020 on the announcement of the GMS’ result. The announcement of the results of the GMS includes the results of the voting. In AGMS dated 18 May 2020 and EGMS dated 27 October 2020, the Company announced the result of the voting to the public one (1) working day after the GMS date through: XL Axiata’s website; IDX’s website; and eASY.KSEI	Minutes of Meeting AGMS 18 May 2020 and EGMS 27 October 2020	Page 86 Page 89
A.3.13	Does the company provide at least 21 day’s notice for all GMS?	The Company complies with Article 17 (1) and 52 (1) POJK 15/2020 on the GMS invitation Convocation of AGMS dated 18 May 2020 was distributed on 24 April 2020; Convocation of EGMS dated 27 October 2020 was distributed on 5 October 2020, Both of the convocations were conducted 21 days before the GMS date.	Invitation AGMS 18 May 2020 and EGMS 27 October 2020	Page 86 Page 89
A.3.14	Does the company provide the rationale and explanation for each agenda item which require shareholders’ approval in the notice of AGM/circulars and/or the accompanying statement?	XL Axiata provides the explanation of agenda item for GMS in the invitation. In this matter, the Company complies with Article 17 (2) POJK 15/2020 and Article 10 (7) AOA in which the Company is obliged to mention the agenda of the meeting including an explanation of each agenda item in meeting invitation. Convocation of AGMS dated 18 May 2020 was distributed on 24 April 2020; Convocation of EGMS dated 27 October 2020 was distributed on 5 October 2020,	Invitation AGMS 18 May 2020 and EGMS 27 October 2020	Page 86 Page 89
A.3.15	Does the company give the opportunity for shareholder to place item/s on the agenda of AGM?	XL Axiata complies with Article 16 (1) POJK 15/2020 and Article 10 (6) AOA, whereby the Shareholders can propose a written meeting agenda to the Board of Directors no later than 7 (seven) days prior to the invitation to the GMS. The information pertaining shareholders’ right to propose agenda item is disclosed in: AGMS dated 18 May 2020, announcement on 9 April 2020. EGMS dated 27 October 2020, announcement on 18 September 2020	Announcement AGMS 18 May 2020 and EGMS 27 October 2020	Page 86 Page 89
A.4	Markets for Corporate Control Should Be Allowed to Function in An Efficient and Transparent Manner.
A.4.1	In cases of mergers, acquisitions and/or takeovers requiring shareholders' approval, does the board of directors/commissioners of the company appoint an independent party to evaluate the fairness of the transaction price	The Company complies with Company Law and applicable capital market regulations relating to merger or acquisition. There is no merger or acquisition that occurred in 2020.	Corporate Action	-
A.5	The exercise of ownership rights by all shareholders, including institutional investors, should be facilitated.
A.5.1	Does the company disclose its practices to encourage shareholders to engage with the company beyond AGM?	XL Axiata has a disclosed Integrated Communication Policy which regulates Communication with Shareholders and Investors. In 2020 Integrated Annual Report, the Company also encourages the shareholders to get involve with the Company by giving information access, opportunity to propose or ask question and/or data through Investro Relation or Company Secretary, except for the confidential question or data.	Integrated Communication Policy Contact Us	Page 167

Part B: Equitable Treatment of Shareholders

No	Subject	Implementation in 2020	Reference
No	Subject	Implementation in 2020	Website	Integrated Annual Report 2020
B.1	Shares and Voting Rights
B.1.1	Does the company's ordinary or common shares have one vote for one share?	XL Axiata complies with Article 11 paragraph 18 AOA, which each share has given the right to its owner to cast one vote. Disclosed to the Shareholders through the Meeting Rules of Conduct of GMS.	The Meeting Rules of Conduct	Page 85 Page 171
B.1.2	Where the company has more than one class of shares, does the company publicize the voting rights attached to each class of shares (e.g. through the company website/ reports/the stock exchange/the regulator's website)?	XL Axiata complies with Article 5 AOA, whereas XL Axiata only recognizes 1 (one) type of share concluded of person or legal entity as the owner of 1 (one) share, namely ordinary shares.	Articles of Association	Page 84
B.2	Notice of AGM
B.2.1	Does each resolution in the most recent AGM deal with only one item, i.e., there is no bundling of several items into the same resolution?	XL Axiata applies each resolution in the most recent GMS deal with only one item or only for one meeting’s agenda only.	General Meeting of Shareholders	Page 84
B.2.2	Are the company's notice of the most recent AGM/circulars fully translated into English and published on the same date as the local-language version?	The Company’s GMS notice is available in English and Bahasa Indonesia version, both published on the same day. XL Axiata complies with Article 52 (1) OJK Regulation 15/2020 and Article 10 paragraph 17 AOA, whereas the Invitation of GMS can be accessed through XL Axiata website which is presented in Bahasa Indonesia and English version. Invitation of AGMS dated 18 May 2020 has been published in website in the same day/date: 24 April 2020; Invitation of EGMS dated 27 October 2020 has been published in website in the same day/date: 5 October 2020.	General Meeting of Shareholders	Page 86
B.2.3	Are the profiles of directors/ commissioners (at least age, academic qualification, date of appointment, experience, and directorships in other listed companies) in seeking election/reelection included?	The profile of BOD and BOC whose subject to election or re-elecetion are included in the GMS material. XL Axiata complies with Article 18 paragraph 4 OJK Regulation 15/2020, whereby the CV of the Candidate of BOD and/or BOC which will be appointed are disclosed in the Company’s website at the same time with the Invitation of GMS. Meeting’s material for 6th Agenda of AGMS dated 18 May 2020 has been published in website in the same date with the AGMS’ Invitation: 24 April 2020. Meeting’s material for 1st Agenda of EGMS dated 27 October 2020 has been published in website in the same date with the EGMS’ Invitation: 5 October 2020	6th Agenda of AGMS 1st Agenda of EGMS	Page 86-91
B.2.4	Are the auditors seeking appointment/re-appointment clearly identified?	The appointment or re-appointment of auditors are clearly identified in the GMS Material. XL Axiata complies with Article 13 (1) OJK Regulation 13/2017, whereas the appointed of auditor should be decided in GMS by considering the suggestion from BOC. The auditor's profile (accountant public and public accounting firm) which requested for GMS’ approval has been disclosed through the Company's website at the same date with the Invitation of AGMS dated 18 May 2020.	4th Agenda of AGMS	Page 163
B.2.5	Were the proxy documents made easily available?	XL Axiata complies with Article 23 (1) OJK Regulation 15/2020, in order to accommodate the presence of the shareholders who’s represented, XL Axiata has provided a Meeting Proxy Form on the website on the same day/date as the invitation of GMS. Pursuant to Article 27 OJK Regulation 15/2020, XL Axiata also provided an alternative to the shareholders to give e-proxy through eASY.KSEI. AGMS dated 18 May 2020 Proxy Form has been published in website in the same date with the AGMS’ Invitation: 24 April 2020; EGMS dated 27 October 2020 Proxy Form has been published in website in the same date with the EGMS’ Invitation: 5 October 2020.	Meeting Proxy Form	Page 84 Page 196
B.3	Insider trading and abusive self-dealing should be prohibited
B.3.1	Does the company have policies and/or rules prohibiting directors/commissioners and employees to benefit from knowledge which is not generally available to the market?	XL Axiata does have policy which prohibits any insider trading in the form of prohibition for employees including for BOC and BOD to provide material information to the public in the Blackout period or disseminating any confidential information as well as information on the future conditions of XL Axiata including business prospect or the strategy of XL Axiata. XL Axiata regulated this matter in the Blackout Policy and the Integrated Corporate Communication Policy as disclosed in the website.	Blackout Policy and Integrated Communication Policy	Page 79
B.3.2	Are the directors/commissioners required to report their dealings in company shares within 3 business days?	The BOD and/or BOC are required to report their transaction in company’s shares. The Company complies with Article 3 paragraph 2 OJK Regulation 11/2017, whereas each change in share ownership of members of the Board of Directors and Board of Commissioners must be submitted no later than 3 (three) working days after the ownership / any change in ownership of the Public Company or at most 5 (five) days after the ownership or change of ownership in the shares of the Public Company if the reporting is carried out through a designated Proxy. XL Axiata regulated in the Board of Directors and Board of Commissioners Shares ownership Policy as disclosed in the website. In 2020, there were reports from the company’s Directors regarding to their transaction of Company’s shares which has also been published in Company’s website	BOC and BOD Shares Ownership Policy Information Disclosure for Certain Shareholders	Page 140
B.4	Related party transactions by directors and key executives
B.4.1	Does the company have a policy requiring directors/commissioners to disclose their interest in transactions and any other conflicts of interest?	XL Axiata has a policy in the form of Board Manual, which requires all conflicts of interest from each transaction or Corporate Action must be stated in meeting of BOC, BOD and Joint Meetings of BOD and BOC. The respective members of BOD or BOC cannot participate into the meeting. Such matters are also stipulated under Article 16 (17) and Article 19 (18) AOA.	Board Manual and Code of Ethics Articles of Association	Page 154
B.4.2	Does the company have a policy requiring a committee of independent directors/ commission-ners to review material RPTs to determine whether they are in the best interests of the company and shareholders?	XL Axiata has several policies on Related Party Transactions, among others, stipulated under: Board of Audit Committee Charter; Board Manual; AOA Whereby the Board of Audit Committee having their role and responsibility to supervise and review towards the Related Party Transactions, as well as to report to the BOC And in this case, BOC should review and decide transaction made by the Company based on types and value of transaction as describe in the Company’s AOA.	Board of Audit Committee Charter Board Manual and Code of Ethics Articles of Association	Page 116
B.4.3	Does the company have a policy requiring board members (directors/commissioners) to abstain from participating in the board discussion on a particular agenda when they are conflicted?	The Company does regulate this matter. Such matter can be found in Article 16 (17) and Article 19 (18) of the AOA and also in Board Manual. Under XL Axiata Board Manual, all conflicts of interest from each transaction or Corporate Action must be stated in meeting of Board of Commissioners, Board of Directors and Joint Meetings of Board of Directors and Board of Commissioners. The respective members of the Board of Commissioners and Board of Directors cannot participate in the meeting.	Articles of Association Board Manual and Code of Ethics	Page 154
B.4.4	Does the company have policies on loans to directors and commissioners either forbidding this practice or ensuring that they are being conducted at arm’slength basis and at market rates?	The Company does have a policy regarding to this matter as stipulated under Remuneration Policy for Senior Executive. Referring to the Remuneration Policy for Senior Executive which applicable in XL Axiata, XL Axiata forbids personal loan to members of BOD and BOC.	Summary of Remuneration Policy	Page 140
B.5	Protecting minority shareholders from abusive actions
B.5.1	Does the company disclose that RPTs are conducted in such a way to ensure that they are fair and at arms’ length?	XL Axiata has disclosed the transactions with related parties as defined in PSAK 7 “Related Party Disclosures” in the 2020 Annual Financial Statement. It is stated in the Annual Financial Statement that any transaction with related parties are made under terms and conditions as those made with third parties, which are, among others, conducted fairly and in arm’s length manners.	Annual Financial Statement	Page 59
B.5.2	In case of related party transactions requiring shareholders’ approval, is the decision made by disinterested shareholders?	XL Axiata complies with OJK Regulation 42/2020, wherease affiliated transactions with conflict of interest must first be approved by the Independent Shareholders. There is no related party transaction that contain conflicts of interest during 2020.	2020 Integrated Annual Report	Page 86

Part C: Role of Stakeholders

No	Subject	Implementation in 2020	Reference
No	Subject	Implementation in 2020	Website	Integrated Annual Report 2020
C.1	The rights of stakeholders that are established by law or through mutual agreements are to be respected
	Does the company disclose a policy and practices that address:
C.1.1	The existence and scope of the company’s efforts to address customers’ welfare?	XL Axiata complies with Law No. 8/1999 on Consumer Protection and Law No. 36/1999 on Telecommunications, XL Axiata is committed to protecting consumer rights, including the right to clear, accurate and truthful information, the right for complaints to be heard and disputes settled, and the right to good services delivered fairly and without discrimination. Consumer protection is included under Product Launch Procedure where socialization in particular to customer service and sales is given with adequate information on the product to be forwarded on to the consumer. XL Axiata has established a service quality monitoring Customer Experience & Service Operation Center (CE & SOC) for four lines of operations: Telco Network, IT Infrastructure, IT Apps, and Billing. XL Axiata operates the CE & SOC as the main facility in monitoring the dynamics of services related to expanding data and business services. XL Axiata Providing a Customer Service Center (Call Center) XL Axiata Conducting customer satisfaction surveys XL Axiata Preparing always-available integrated customer service	2020 Integrated Annual Report Sustainability Report	Page 191
C.1.2	Supplier/contractor selection pro-cedures?	XL Axiata has a Procurement Policy that regulates the selection of suppliers or vendors as well as application of vendor management in order to ensure the legality of its suppliers.	Summary of Procurement Policy	Page 176
C.1.3	The company’s efforts to ensure that its value chain is environmentally friendly or is consistent with promoting sustainable development?	XL Axiata has a Sustainability Commitment, whereas the business ecosystem and achievements are impossible to nurture without mutual and positive relationship with the public and policy owners. As a leading telecommunication company, XL Axiata is fully aware of its social responsibility and manifests this through our various sustainability programs. This information has also been disclosed in 2020 Integrated Annual Report.	Sustainability Report	Page 38 Page 180
C.1.4	The company’s efforts to interact with the communities in which they operate?	XL Axiata discloses this information through 2020 Integrated Annual Report. Through XL Axiata’s sustainability strategy on Building Prosperity, Nurturing People, Process Excellence and Planet & Society pillars, XL Axiata has conducted some activities to interact with communities, among others are: XL Future Leaders: XL Axiata contributes on the development of young leaders in Indonesia, and to enhance their internal competition Gerakan Donasi Kuota: XL Axiata contributes to provide internet access facility to students in many regions In order to increase the benefit value of women, XL Axiata has Sisternet to connect to every women communities and organizations as well as social activists in many areas. Environment Management: Enhancing services quality and optimizing local potential with social outreach to manage environmental impact.	Sustainability Report	Page 38 Page 180
C.1.5	The company’s anti-corruption programs and procedures?	XL Axiata has programs and procedures of anti-corruption as stipulated under anti-bribery and anti-corruption policy which has been published in Company’s website	XL Axiata ABAC Policy Statement Anti-Bribery and Anti-Corruption Policy of XL Axiata	Page 82
C.1.6	How creditors’ rights are safe-guarded?	XL Axiata is not engaged in lending and borrowing. However, In order to fulfill every rights of creditors, XL Axiata complies with Company Law and AOA. The policy in regard to the fulfillment of creditor rights in details are also included in the Credit Agreement made between the Bank as Creditors and XL Axiata as a Debtor.	Integrated Annual Report	Page 176
C.1.7	Does the company have a separate report/section that discusses its efforts on environment/economy and social issues?	XL Axiata has designed a roadmap to grow into a sustainable company through four pillars of Sustainability Framework namely Building Prosperity, Nurturing People, Process Excellence and Planet & Society. XL Axiata in this matter also has a separate report providing information on environment/economy and social issues as described in Sustainability Report.	Sustainability Report	Page 38 Page 180
C.2	Where stakeholder interests are protected by law, stakeholders should have the opportunity to obtain effective redress for violation of their rights.
C.2.1	Does the company provide contact details via the company's website or Annual Report which stakeholders (e.g. customers, suppliers, general public etc.) can use to voice their concerns and/or complaints for possible violation of their rights?	Contact details can be found on the website and the annual report of XL Axiata.	In every Landing Page of Company’s website	Page 195
C.3	Mechanisms for employee participation should be permitted to develop.
C.3.1	Does the company explicitly disclose the policies and practices on health, safety and welfare for its employees?	XL Axiata organize the implementation of health, safety and welfare of its employees in the Employee’s Code of Ethics and Occupational Health & Safety Policy of XL Axiata.	Sustainability Report	Page 73 Page 190
C.3.2	Does the company explicitly disclose the policies and practices on training and development programmes for its employees?	During 2020, the Company has invested around IDR5bio for employees training and development. The HC training and development programs are designed to ensure employees have up to date, agile, and digital competencies. These are important competencies that would ensure the Company’s current and future business growth. In 2020, with the COVID-19 pandemic situations. XL Axiata has identified 3 aspects in order to support its emplyees: Mind, Body and Soul. The Company also focuses to support new ways of working which majorly conducted based on Work From Home (WFH) basis To develop professional competencies, the Company also depends on online application learning, such as Linkedin Learning and Coursera, virtual classes, and e-LMS application (electronic Learning Management System) which integrated to other services in human capital, such as Talent Management, Performance Management and Career Program	Work in XL Axiata	Page 70
C.3.3	Does the company have a reward/compensation policy that accounts for the performance of the company beyond short-term financial measures?	The company does have a reward/remuneration policy. One of the policies which regulates reward/compensation for employees is the Remuneration Policy. In addition, XL Axiata has a Long Term Incentive program which is a stock option program for employees/ management.	Remuneration Policy	Page 112 Page 169
C.4	Stakeholders including individual employee and their representative bodies, should be able to freely communicate their concerns about illegal or unethical practices to the board and their rights should not be compromised for doing this.
C.4.1	Does the company have a whistle blowing policy which includes procedures for complaints by employees and other stakeholders concerning alleged illegal and unethical behaviour and provide contact details via the company's website or annual report.	XL Axiata has a Whistleblowing Policy which includes procedures for complaints by employees and other stakeholders concerning alleged illegal and unethical behaviour through SPEAK UP channel.	Whistleblowing Policy	Page 170
C.4.2	Does the company have a policy or procedures to protect an employee/person who reveals alleged illegal/unethical behavior from retaliation?	Protection for Whistleblower is included in the Whistleblowing Policy amongst others Identity of Reporter; Confidentiality of report content; and Threat, intimidation or other threatening behaviour by the reported party.	Whistleblowing Policy	Page 170

Part D: Disclosure and Transparency

No	Subject	Implementation in 2020	Reference
No	Subject	Implementation in 2020	Website	Integrated Annual Report 2020
D.1	Transparent Ownership Structure
D.1.1	Does the information on shareholdings reveal the identity of beneficial owners, holding 5% shareholding or more?	Information on XL Axiata's shareholding discloses the identity of beneficial owners with 5% or more which can be found in the Group Structure & Ownership or in the Shareholders Detail.	Group Structure & Ownership	Page 188
D.1.2	Does the company disclose the direct and indirect (deemed) shareholdings of major and/or substantial shareholders?	XL Axiata has disclosed the direct and indirect (deemed) shareholdings of major and/or substantial shareholders.	Group Structure & Ownership	Page 186
D.1.3	Does the company disclose the direct and indirect (deemed) shareholdings of directors (commissioners)?	Through Monthly Report of Shares Registration, XL Axiata has disclosed the share ownership of member of BOD and BOC (direct/indirect) on the website of Indonesia Stock Exchange. XL Axiata also published such share ownership in the 2020 Integrated Annual Report.	2019 Integrated Annual Report	Page 184
D.1.4	Does the company disclose the direct and indirect (deemed) shareholdings of senior management?	XL Axiata has disclosed the shares ownership of the senior management, directly or indirectly, which is described in 2020 Integrated Annual Report.	2019 Integrated Annual Report	Page 184
D.1.5	Does the company disclose details of the parent/holding company, subsidiaries, associates, joint ventures and special purpose enterprises/ vehicles (SPEs)/ (SPVs)?	XL Axiata disclosed detail of holding company and subsidiary.	Shareholding	Page 186
D.2	Quality of Annual Report
	Does the company's annual report disclose the following items:
D.2.1	Corporate Objectives	XL Axiata has corporate objectives and business activities which disclosed in 2020 Integrated Annual Report.	Vision, Purpose, and Culture	Page 12
D.2.2	Financial Performance Indicator	The financial performance of XL Axiata over a period of 5 (five) years is available on the website. The financial performance of XL Axiata annually is available in annual reports.	5 Years Financial Highlights	Page 46
D.2.3	Non-Financial Performance Indicator	The Non-Financial Indicator shall refer to: Human Capital Development: page 68 of 2020 Integrated Annual Report. Information Technology: page 63 of 2020 Integrated Annual Report. Good Corporate Governance, including the Risk Management: page 77 of 2020 Integrated Annual Report. Corporate Social Responsibility: page 179 of 2020 Integrated Annual Report.	2019 Integrated Annual Report Sustainability Report	Page 60 Page 39 Page 69 Page 157
D.2.4	Dividend Policy	The current XL Axiata Dividend Policy is as approved by the Board of Commissioners through the Board of Commissioners’ Meeting No. 1/11 dated January 28, 2011 and has been informed to the Shareholders at the Annual General Meeting of Shareholders on April 14, 2011.	2019 Integrated Annual Report	Page 58
D.2.5	Biographical details (at least age, academic qualifications, date of first appointment, relevant experience, and any other directorships of listed companies) of all directors/ commissioners.	Biographical of each member of BOD and BOC of XL Axiata can be found in the Website of XL Axiata and the 2020 Integrated Annual Report.	Management	-
D.2.6	Attendance details of each director/commissioner in all directors/commissoners meetings held during the year.	Attendance of each member of Board of Commissioners and Board of Directors in BOC Meeting as well BOD meeting can be found in 2020 Integrated Annual Report.	2019 Integrated Annual Report	Page 93-95 Page 115 - 118
D.2.7	Total remuneration of each member of the board of directors/ commissioners.	Total remuneration of each member of BOD and BOC can be found in 2020 intergated Annual Report.	2019 Integrated Annual Report	Page 98
	Corporate Governance Confirmation Statement
D.2.8	Does the Annual Report contain a statement confirming the company's full compliance with the code of corporate governance and where there is non-compliance, identify and explain reasons for each such issue?	In GCG Section, XL Axiata has set at a higher level in GCG implementation through solid BOD performance under prudent supervision of the BOC and supported by the exceptional performance of all employees. In addition, XL Axiata Digital Transformation strategy has also succeeded in creating efficiency and effectiveness in the implementation of GCG, especially in the process of decision making and operational activities.	2019 Integrated Annual Report	Page 69
D.3	Disclosure of Related Party Transaction (RPT’s)
D.3.1	Does the company disclose its policy covering the review and approval of material RPTs?	The Company complies with OJK Regulation No. 42/2020 and Article 15 (4) AOA which regulate on this matter. The publication of the policy on reviewing and approving related party material transaction is also provided in Audit Committee Charter.	2019 Integrated Annual Report Articles of Association	Page 71
D.3.2	Does the company disclose the name, relationship, nature and value for each material RPTs?	The Company complies with OJK Regulation 42/2020. The publication on Affililated Transaction and Conflict of Interest. The disclosure of this transaction is as stipulated under Company’s financial statement.	2019 Integrated Annual Report Articles of Association	Page 71
D.4	Directors and Commissioners dealings in the shares of the company
D.4.1	Does the company disclose trading in the company's shares by insiders?	XL Axiata has a policy which regulates on company’s shares trading by insiders. This policy is stipulated under Blackout Policy and has been published in company’s website. Based on such policy, Insiders, among others, are Commissioners and Directors. In this case, in the event there is a trading of company’s shares conducted by Directors and/or Commissioners, XL Axiata will disclose such information pursuant to POJK 11/2017 and BOD and BOC Shares Ownership Policy. In 2020, the Company has disclosed trading of company shares conducted by members of Board of Directors. This transactions are conducted in accordance with the prevailing laws.	2019 Integrated Annual Report Board Manual	Page 153
D.5	External Auditor and Auditor Report
	Where the same audit firm is engaged for both audit and non-audit services
D.5.1	Are the audit and non-audit fees disclosed?	Audit fees are disclosed based on a deal between the Company and the appointed Public Accounting Firm. This audit Fees for financial year 2020 are disclosed In 2020 Integrated Annual Report. Non-audit fees were not disclosed because there were no services for this matter.	2019 Integrated Annual Report	Page 137
D.5.2	Does the non-audit fee exceed the audit fees?	There are no non-audit services conducted by the Public Accounting who also perform the audit services for XL Axiata.	2019 Integrated Annual Report	Page 137
D.6	Medium of Communication
	Does the company use the following modes of communication?
D.6.1	Quarterly Reporting	XL Axiata communicated the company’s financial condition through Quarterly Financial Statement, which submitted to regulator as well as published in XL Axiata’s website.	Quarterly Financial Statement	Page 196
D.6.2	Company Website	XL Axiata has official website which in accordance with the Financial Services Authority Regulation No.8 / POJK.04 / 2015 on the Website of the Issuer or Public Company.	Web XL Axiata	Page 196
D.6.3	Analyst’s briefing	XL Axiata hold Analyst’s briefing in quarterly basis at the same time with Financial Statement.	Materi Analyst’s briefing	-
D.6.4	Media briefings/press conferences	The Company proactively provides latest news about its activities in the form of News Release.	Browse News and Press Release	Page 142
D.7	Timely filing/release of annual/financial reports
D.7.1	Are the audited annual financial report / statement released within 120 days from the financial year end?	XL Axiata’s Annual Financial Statement released on 15 February 2021 or less than 120 days after the end of Company’s financial year.	Annual Financial Statement	Page 196
D.7.2	Is the annual report released within 120 days from the financial year end?	XL Axiata’s 2020 Integrated Annual Report released on 1 April 2021 or less than 120 days after the end of Company’s financial year.	Annual Financial Statement	Page 196
D.7.3	Is the true and fairness/fair representation of the annual financial statement/reports affirmed by the board of directors/commissioners and/or the relevant officers of the company?	The Financial Statement of XL Axiata contains a statement from BOD on the responsibility of the Financial Statement including state that the Financial Statement have been presented true and fairness/fair.	Annual Financial Statement	Page 196
D.8	Company’s Website
	Does the company have a website disclosing up-to-date information on the following:
D.8.1	Financial Statement/reports (latest quarterly)	XL Axiata communicated the company’s financial condition through Quarterly Financial Statement, which submitted to regulator as well as published in XL Axiata’s website.	Quarterly Financial Statement	-
D.8.2	Materials provided in briefings to analysts and media	XL Axiata holds Analyst’s briefing in quarterly basis at the same time with Financial Statement publication.	Materi Analyst’s briefing	-
D.8.3	Downloadable Annual Report	XL Axiata’s Annual Report which available in website is downloadable for public.	Annual Report	Page 178
D.8.4	Notice of AGM and/or EGM	XL Axiata has published the Announcement/Invitation of AGMS/EGMS through: 1 daily newspaper circulated nationally the Stock Exchange’s website; the Company’s website; and eASY.KSEI	GMS	Page 74 Page 178
D.8.5	Minutes of AGM and/or EGM	XL Axiata has published the Minutes of AGM/EGM through: on the Stock Exchange’s website; and on the Company’s website	GMS	Page 74 Page 178
D.8.6	Company's constitution (company's by-laws, memorandum and articles of association)	XL Axiata has published the Articles of Association through: on the Stock Exchange’s website; and on the Company’s website	Articles of Association	-
D.9	Investor Relation
D.9.1	Does the company disclose the contact details (e.g. telephone, fax, and email) of the officer responsible for investor relations?	XL Axiata published detail contact of the Investor Relation in Annual Report and Website.	Investor Relation	Page 131

Part E: Responsibility of the Board

No	Subject	Implementation in 2020	Reference
No	Subject	Implementation in 2020	Website	Integrated Annual Report 2020
E.1	Board Duties and Responsibilities
	Clearly defined board responsibilities and corporate governance policy
E.1.1	Does the company disclose its corporate governance policy/ board charter?	The Company does disclose its governance policy and board charter in company’s website. XL Axiata in this matter complies with OJK Regulation 8/2015 which has disclosed its corporate governance policy/ board charter through XL Axiata website.	Good Corporate Governance Board Manual	Page 104 Page 130
E.1.2	Are the types of decisions requiring board of directors/commissioners' approval disclosed?	XL Axiata regulates the decision that requires approval from the BOD or BOC as stipulated in Article 15 paragraph 3 of the Articles of Association and Board Manual in which both documents have been disclosed in company’s website	Articles of Association Board Manual	Page 103-104 Page 129-130
E.1.3	Are the roles and responsibilities of the board of directors/ commissioners clearly stated?	Roles and responsibilities of BOD and BOC are clearly stated and disclosed under as follows: Articles of Association: Article 15 for BOD. Article 18 for BOC. 2020 Integrated Annual Report: Page 129-130 for BOD Page 103-104 for BOC Working Guideline of the BOD and the BOC / Board Manual The Articles of Association, Annual Report and Board Manual are available in the Company’s Website respectively as disclosed in point D.8.6; D.8.3 dan E.1.2	Articles of Association	Page 103-104 Page 129-130
E.1.4	Does the company have an updated vision and mission statement?	XL Axiata’s Vision/Mission is available in website and 2020 Integrated Annual Report.	Vision, Purpose & Core Value	Page 12-13
E.1.5	Does the board of directors play a leading role in the process of developing and reviewing the company's strategy at least annually?	BOD has responsible to establish XL Axiata strategy and review the implementation through monthly review in BOD Meeting. The implementation in 2020 can be found in the agendas of BOD’s meeting which published in 2020 Integrated Annual Report. In yearly basis, BOD is also required to prepare the business plan in which the Company’s strategy is included. The business plan is prepared for the following year and is discussed in BOD meeting. For instance, XL Axiata’s BOD conducted a meeting on 11 February 2020 to discuss on Company monthly performance review. In 2020, BOD discussed the business plan in several BOD meetings, among others, BOD meeting dated 1 September 2020, 6 October 2020 and 15 December 2020	2020 Integrated Annual Report	Page 131-139
E.1.6	Does the board of directors have a process to review, monitor and oversee the implementation of the corporate strategy?	XL Axiata Board Manual stipulates that BOD are authorized to prepare corporate strategies including the implementation. One example as the BOD discusses the corporate strategy at the meeting of BOD dated 7 January 2020.	Board Manual	Page 131-139
E.2	Board Structure
	Code of Ethics or Conduct
E.2.1	Are the details of the code of ethics or conduct disclosed?	the Code of Ethic for the Board of Directors and the Board of Commissioners are regulated in Board Manual which has been disclosed in Company’s website. In addition, the Code of Ethics is included under the Company Regulation.	Board Manual 2020 Integrated Annual Report	Page 168
E.2.2	Are all directors/commissioners, senior management and employees required to comply with the code/s?	The Code of Ethic prevails for all level of Employees as well as the Board of Directors and the Board of Commissioners.	Board Manual 2020 Integrated Annual Report	Page 168
E.2.3	Does the company have a process to implement and monitor compliance with the code/s of ethics or conduct?	The process of monitoring compliance the code of ethic is conducted by Unit of Human Capital XL Axiata in periodically.	Board Manual 2020 Integrated Annual Report	Page 168
E.2.4	Do independent directors/ commissioners make up at least 50% of the board of directors/commissioners?	The total Independent Commissioners of the Company has met the requirement as stipulated in OJK Regulation No. 33/POJK.04/2014 which is 30% of total members of the Board of Commissioners. As per 31 December 2020, the Company has (3) members of Independent Commissioner from total nine (9) members of Board of Commissioners, namely: Muliadi Rahardja Yasmin S. Wirjawan Julianto Sidarto	Our Leaders 2020 Integrated Annual Report	Page 95
E.2.5	Does the company have a term of office of nine years or less or 2 terms of each of five years for its independent director/commissioner?	The Company complies with OJK Regulation 33/2014 on the term of office of the Independent Commissioners. This regulation has also been implemented in the AOA and Board Manual of the Company, whereby an Independent Commissioner may serve the Company for 2 consecutive periods, and can be reappointed for the next period as long as such member declares their independence in GMS.	Board Manual 2020 Integrated Annual Report	Page 95
E.2.6	Has the company set a limit of five board seats that an individual independent/non-executive director/commissioner may hold simultaneously?	The Company complies with the provision of concurrent Board position for Independent Commissioners as stipulated in OJK Regulation No. 33/POJK.04/2014. Conccurrent position of each Independent Commissioner of the Company disclosed in 2020 Integrated Annual Report under the Board of Commissioners profile section.	2020 Integrated Annual Report	Page 96-103
E.2.7	Does the company have any executive directors who serve on more than two boards of listed companies outside of the group?	As per 31 December 2020, The Company does have BOC who also serve as Board of Directos and/or Board of Commissioners in other public listed company, namely: Dr. Muhamad Chatib Basri Tan Sri Jamaludin Ibrahim Vivek Sood Dato’ Mohd Izzaddin Idris Dr. Hans Wijayasuriya David R. Dean Muliadi Rahardja As for the BOD, there are no Directors in XL Axiata who also serve as Board of Directors and/or Board of Commissioners in other public listed company, For the details of concurrent position of each member of the Board of Directors and Board of Commissioners of the Company, XL Axiata discloses this information in 2020 Integrated Annual Report under the Board of Directors and Board of Commissioners profile section. The Company complies with the provision of concurrent Board position as stipulated in OJK Regulation No. 33/POJK.04/2014	2020 Integrated Annual Report	Page 125-129 Page 96-103
	Nomination Committee
E.2.8	Does the company have a Nominating Committee?	The Company has in place the Nominating and Remuneration Committee as required in Financial Services Authority Regulation No. 34/POJK.04/2014 on Nominating and Remuneration Committee of Issuer or Public Company. Disclosure on Nominating and Remuneration Committee is available on: 2020 Integrated Annual Report, and website of the Company	2020 Integrated Annual Report Nominating and Remuneration Committee	Page 119-122
E.2.9	Is the Nominating Committee comprised of a majority of independent directors/ commissioners?	The membership of The Company’s Nominating and Remuneration Committee has fulfilled the requirement in Financial Services Authority Regulation No. 34/POJK.04/2014 on Nominating and Remuneration Committee of Issuer or Public Company. As of 31 December 2020, 2 (two) Independent Commissioners of the Company were included in the membership of the Company's Nominating and Remuneration Committee.	2020 Integrated Annual Report Nominating and Remuneration Committee	Page 104
E.2.10	Is the chairman of the Nominating Committee an independent director/commissioner?	The chairman The Company’s Nominating and Remuneration is an Independent Commissioner as required in Financial Services Authority Regulation No. 34/POJK.04/2014 on Nominating and Remuneration Committee of Issuer or Public Company. As of 31 December 2020, the Chairman of Nominating and Remuneration Committee is Independent Commissioner of the Company, namely Mr. Muliadi Rahardja.	2020 Integrated Annual Report Nominating and Remuneration Committee	Page 119
E.2.11	Does the company disclose the terms of reference/ governance structure/charter of the Nominating Committee?	The Company has a The Nominating and Remuneration Committee Charter which is disclosed in company’s website. The charter was made in accordance with Financial Services Authority Regulation No. 34/POJK.04/2014 on Nominating and Remuneration Committee of Issuer or Public Company.	2020 Integrated Annual Report Nominating and Remuneration Committee	Page 121
E.2.12	Is the meeting attendance of the Nominating Committee disclosed and if so, did the Nominating Committee meet at least twice during the year?	The Nominating and Remuneration Committee Meeting is held per quarterly basis as stipulated in Financial Services Authority Regulation No. 34/POJK.04/2014 on Nominating and Remuneration Committee of Issuer or Public Company. The meeting attendance is disclosed in 2020 Integrated Annual Report.	2020 Integrated Annual Report	Page 121
	Remuneration Committee/ Compensation Committee
E.2.13	Does the company have a Remuneration Committee?	The Company has in place the Nominating and Remuneration Committee as required in Financial Services Authority Regulation No. 34/POJK.04/2014 on Nominating and Remuneration Committee of Issuer or Public Company. Disclosure on Nominating and Remuneration Committee is available on: 2020 Annual Report, and website of the Company	2020 Integrated Annual Report Nominating and Remuneration Committee	Page 119-122
E.2.14	Is the Remuneration Committee comprised of a majority of independent directors/commissioners?	The membership of The Company’s Nominating and Remuneration Committee has fulfilled the requirement in Financial Services Authority Regulation No. 34/POJK.04/2014 on Nominating and Remuneration Committee of Issuer or Public Company. As of 31 December 2020, 2 (two) Independent Commissioners of the Company were included in the membership of the Company's Nominating and Remuneration Committee.	2020 Integrated Annual Report Nominating and Remuneration Committee	Page 119
E.2.15	Is the chairman of the Remuneration Committee an independent director/commissioner?	The chairman The Company’s Nominating and Remuneration is an Independent Commissioner as required in Financial Services Authority Regulation No. 34/POJK.04/2014 on Nominating and Remuneration Committee of Issuer or Public Company. As of 31 December 2020, the Chairman of Nominating and Remuneration Committee is Independent Commissioner of the Company, namely Mr. Muliadi Rahardja.	2020 Integrated Annual Report Nominating and Remuneration Committee	Page 119
E.2.16	Does the company disclose the terms of reference/ governance structure/ charter of the Remuneration Committee?	As Regulated in Financial Services Authority Regulation No. 34/POJK.04/2014 on Nominating and Remuneration Committee of Issuer or Public Company. The Company has a The Nominating and Remuneration Committee Charter.	2020 Integrated Annual Report Nominating and Remuneration Committee	Page 121
E.2.17	Is the meeting attendance of the Remuneration Committee disclosed and, if so, did the Remuneration Committee meet at least twice during the year?	The Nominating and Remuneration Committee Meeting is held per quarterly basis as stipulated in Financial Services Authority Regulation No. 34/POJK.04/2014 on Nominating and Remuneration Committee of Issuer or Public Company.	2020 Integrated Annual Report	Page 121
	Audit Committee
E.2.18	Does the company have an Audit Committee?	The Company has in place the Audit Committee as required in Financial Services Authority Regulation No. 55/POJK.04/2015 on Audit Committee Implementation Guideline.	2020 Integrated Annual Report Audit Committee	Page 115
E.2.19	Is the Audit Committee comprised entirely of non-executive directors/commissioners with a majority of independent directors/commissioners?	The membership of The Company’s Audit Committee has fulfilled the requirement in Financial Services Authority Regulation No. 55/POJK.04/2015 on Audit Committee Implementation Guideline. As of 31 December 2020, there were two Independent Comissioners of the Company are in the Audit Committee membership namely Mr. Julianto Sidarto and Mr. Muliadi Rahardja.	2020 Integrated Annual Report Audit Committee	Page 115
E.2.20	Is the chairman of the Audit Committee an independent director/commissioner?	The chairman The Company’s Audit Committee is an independent Commissioner as required in Financial Services Authority Regulation No. 55/POJK.04/2015 on Audit Committee Implementation Guideline. As of 31 December 2020, the Chairman of Audit Committee is Independent Commissioner of the Company, namely Mr. Julianto Sidarto.	2020 Integrated Annual Report Audit Committee	Page 115
E.2.21	Does the company disclose the terms of reference/governance structure/charter of the Audit Committee?	As Regulated in Financial Services Authority Regulation No. 55/POJK.04/2015 on Audit Committee Implementation Guideline, the Company has a Audit Committee Charter as published in Company’s website	2020 Integrated Annual Report Audit Committee	Page 115
E.2.22	Does at least one of the independent directors/commissioners of the committee have accounting expertise (accounting qualification or experience)?	Membership qualification of the Company’ Audit Committee has met the requirement under Financial Services Authority Regulation No. 55/POJK.04/2015 on Audit Committee Implementation Guideline whereby at least one (1) member shall have educational and competency background in finance and accounting. All members of the Audit Committee have educational background and competencies in the field of Finance and / or accounting.	2020 Integrated Annual Report Audit Committee	Page 115
E.2.23	Is the meeting attendance of the Audit Committee disclosed and, if so, did the Audit Committee meet at least four times during the year?	The Audit Committee Meeting is held at least per quarterly basis as stipulated in Financial Services Authority Regulation No. 55/POJK.04/2015 on Audit Committee Implementation Guideline.	2020 Integrated Annual Report	Page 117
E.2.24	Does the Audit Committee have primary responsibility for recommendation on the appointment, and removal of the external auditor?	Responsibility for providing recommendations on the appointment and removal of external auditor is regulated in the Audit Committee Charter. In the fourth agenda of the 2020 Annual GMS, the Audit Committee has provided such recommendation.	Audit Committee Charter 4th Agenda AGMS	Page 163 Page 104
E.3	Board Processes
	Board Meetings and Attendance
E.3.1	Are the board of directors meeting scheduled before the start of financial year?	The Board of Directors meeting is held in weekly basis and therefore automatically scheduled at minimum once in a week.	2020 Integrated Annual Report	Page 131-139
E.3.2	Does the board of directors/commissioners meet at least six times during the year?	In 2020: The Board of Directors has held 63 meetings, and The Board of Commissioners has held 10 meetings.	2020 Integrated Annual Report	Page 131-139 Page 105-108
E.3.3	Has each of the directors/commissioners attended at least 75% of all the board meetings held during the year?	In 2020, the average attendance of each member of the Board of Directors in the Board of Directors Meeting is 82% - 100% while the average attendance of the Board of Commissioners in Board of Commissioners meetings is 100%.	2020 Integrated Annual Report	Page 131-139 Page 105-108
E.3.4	Does the company require a minimum quorum of at least 2/3 for board decisions?	Any resolutions of the meeting of the BOD or BOC must be adopted on amicable deliberation basis pursuant to the AOA (Article 16 (11) and Article 19 (12)).	Articles of Association	Page 131-139 Page 105-108
E.3.5	Did the non-executive directors/commissioners of the company meet separately at least once during the year without any executives present?	The Independent Commissioner of the Company does not conduct separate official meetings, whereby in carrying out official meetings will always be held simultaneously with other members of the BOC in BOC meeting.	-	-
E.3.6	Are board papers for board of directors/commissioners’ meetings provided to the board at least five business days in advance of the board meeting?	Yes, the Board papers for the Board of Commissioners and/or Joint Board of Commissioner and Board of Directors meetings are distributed together with the Meeting invitation no later than 7 calendar days before the Meeting pursuant to the Company’s Board Manual.	Articles of Association Board Manual	Page 105 Page 131
E.3.7	Does the company secretary play a significant role in supporting the board in discharging its responsibilities?	The responsibilities of the Company’s Corporate Secretary are to assist the BOD and BOC in amongst others the implementation of BOD and BOC Meeting, implementation of GMS, supervise conflict of interest management and compliance with capital market regulation, provide opinion and support in corporate action as well as document management.	Integrated Annual Report 2019	Page 153-155
E.3.8	Is the company secretary trained in legal, accountancy or company secretarial practices and has kept abreast on relevant developments?	The Corporate Secretary of the Company must have knowledge in legal and follow trainings for competency development.	2020 Integrated Annual Report	Page 152
	Board Appointment and Re-Election
E.3.9	Does the company disclose the criteria used in selecting new directors/commissioners?	Criteria of the Board of Directors and the Board of Commissioners are in accordance with Financial Services Authority Regulation No No.33/POJK.04/2014 on the Board of Directors and the Board of Commissioners of Issuer or Public Company.	Board Manual	Page 104 Page 130
E.3.10	Did the company describe the process followed in appointing new directors/commissioners.	The appointment policy of the XL Axiata BOD is regulated in the Senior Executive Nomination Policy. The Directors/Commissioners candidates as proposed by Shareholders and/or Minority Shareholders are conveyed to the XL Nominating and Remuneration Committee through the Corporate Secretary. The Nominating and Remuneration Committee will further review the nomination proposal in the Nominating and Remuneration Committee Meeting to ensure the fulfillment of candidates’ requirements, qualifications as well as background to be submitted to the GMS for approval purpose.	Nomination Policy	Page 104 Page 130
E.3.11	Are all directors/commissioners subject to re-election every 3 years; or 5 years for listed companies in countries whose legislation prescribes a term of 5 years each?	Yes, pursuant to Article 14 (3) and Article 17 (3) AOA, any Directors and/or Commissioners whose 5-year office term is expired, may be re-appointed in GMS as Director and/or Commissioner by referring to the prevailing laws.	Articles of Association Board Manual	Page 104 Page 131
	Remuneration Matters
E.3.12	Does the company disclose its remuneration (fees, allowances, benefit-in-kind and other emoluments) policy/practices (i.e. the use of short term and long-term incentives and performance measures) for its executive directors and CEO?	The procedure of Commissioners and Directors remuneration determination is stipulated in the Policy on the Remuneration for Senior Executive of XL Axiata and in accordance with Law No.40 Year 2007 and Articles of Association, the General Meeting of Shareholders must approve salary, fees, or benefits paid to the Commissioners and Directors Remuneration for the Commissioners and Directors is determined by taking into account on the Company and individual target, comparison with similar industries, nonmonetary benefits as well as individual and Company performance. The amount of each remuneration is evaluated from time to time to ensure that the remuneration remains in accordance with market conditions.	Summary of Remuneration Policy	Page 112
E.3.13	Is there disclosure of the fee structure for non-executive directors/commissioners?	The remuneration structure for the Commissioners and Directors are stipulated in the Remuneration for Senior Executive Policy as follows: Basic Salary. Benefit. Bonus (only for members of the Board of Directors) The remuneration structure of Directors and Commissioners are disclosed in 2020 Integrated Annual Report.	Summary of Remuneration Policy	Page 113-114
E.3.14	Do the shareholders or the Board of Directors approve the remuneration of the executive directors and/or the senior executives?	Remuneration of the Board of Commissioners and the Board of Directors of the Company in 2020 are resolved in the AGMS, 7th Agenda by giving authority to: Nominating and Remuneration Committee of the Company to determine the salary amount, bonus and other benefits for members of the BOC in accordance with the structure, policy and amount of remuneration based on the Company’s remuneration policy for the relevant financial year. BOC of the Company to determine the salary amount, bonus and other benefits for members of the BOD in accordance with the structure, policy and amount of remuneration based on the Company’s remuneration policy for the relevant financial year.	2020 Integrated Annual Report 7th Agenda AGMS	Page 112
E.3.15	Does the company have measurable standards to align the performance-based remuneration of the executive directors and senior executived with long-term interests of the company, such as claw back provision and deferred bonuses?	XL Axiata in this matter has measurable standards in which the performance-based remuneration (variable cash incentives and annual bonus) of Directors shall be measured based on several factors of Company’s interest, such as, achievement for specific targets and Company’s performance.	Summary of Remuneration Policy	Page 112 Page 169
	Internal Audit
E.3.16	Does the company have a separate internal audit function?	The Company has Internal Audit Unit as required by Financial Services Authority Regulation No.56/POJK.04/2015 on Establishment and Guideline of Internal Audit Charter.	2020 Integrated Annual Report	Page 157
E.3.17	Is the head of internal audit identified or, if outsourced, is the name of the external firm disclosed?	The Company has disclosed Head Internal Audit in Integrated Annual Report 2020.	2020 Integrated Annual Report	Page 157
E.3.18	Does the appointment and removal of the internal auditor require the approval of the Audit Committee?	Based on XL Axiata Internal Audit Charter, Group Head of Audit & Risk Management is appointed and dismissed by President Director upon the approval from the Board of Commissioners. The Company's Audit Committee has a function in making decisions and providing recommendations for the best interests of the Board of Commissioners collectively, whereby this provision is stipulated under Audit Committee Charter.	2020 Integrated Annual Report Charter of Committee Audit and Internal Audit	Page 157
E.3.19	Does the company establish a sound internal control procedures/risk management framework and periodically review the effectiveness of that framework?	The Company has Risk Management and Internal Control System which is being periodically review by the Board of Directors and the Board of Commissioners throough the Board of Audit Committee.	2020 Integrated Annual Report Charter of Audit Committee and Internal Audit	Page 161 Page 164
E.3.20	Does the Annual Report/Annual CG Report disclose that the board of directors/commissioners has conducted a review of the company's material controls (including operational, financial and compliance controls) and risk management systems?	The Board of Commissioners of the Company quarterly review the risk management system in quarterly basis as part of the Audit Committee Report. Disclosure on responsibilitiy of the BOC and BOD on a sound Internal Control System covering oversight towards further conducted measures to minimize the risk as part of Audit Committee report is available at the Annual Report.	GC Report	Page 76
E.3.21	Does the company disclose the key risks to which the company is materially exposed to (i.e. financial, operational including IT, environmental, social, economic)?	The Company discloses the key risks related with its business activities in the Annual Report.	2020 Integrated Annual Report	Page 124
E.3.22	Does the Annual Report/Annual CG Report contain a statement from the board of directors/commissioners or Audit Committee commenting on the adequacy of the company's internal controls/risk management systems?	The Board of Audit Committee (“BAC”) acts as oversight function for risk management and review the adequacy and the integrity of the Company in managing risk.	2020 Integrated Annual Report	Page 118
E.4	Member of the Board
	Board Chairman
E.4.1	Do different persons assume the roles of chairman and CEO?	The Company refers to Article 14 of the Company's Articles of Association, where the Company is managed and led by a Board of Directors consisting of at least 2 (two) members of the Board of Directors, 1 (one) member of the Board of Directors appointed as President Director.	Our Leaders Articles of Association	Page 125
E.4.2	Is the chairman an independent director/commissioner?	As of 2020, the composition of the BOD and BOC of the Company are not led by an Independent Director or an Independent Commissioner.	Our Leaders 2020 Integrated Annual Report	Page 96 Page 125
E.4.3	Is any of the directors a former CEO of the company in the past 2 years?	There was no Director has served as President Director in the last two (2) years.	2020 Integrated Annual Report	Page 125
E.4.4	Are the roles and responsibilities of the chairman disclosed?.	The Company disclosed President Director and President Commissioner roles & responsibility in the 2020 Integrated Annual Report.	2020 Integrated Annual Report	Page 104 Page 130
	Lead Independent Director
E.4.5	If the Chairman is not independent, has the Board appointed a Lead/Senior Independent Director and has his/her role been defined?	XL Axiata in this matter complies with the prevailing laws in Indonesia. Although pursuant to prevailing laws in Indonesia it is not required anymore to have an Independent Director as the IDX Regulation No. I-A has been amended, XL Axiata does have a Director who eligible as an Independent Director where he does not have any shares in XL Axiata and is not a nominee from a majority shareholder, namely Budi Pramantika.	Our Leaders 2020 Integrated Annual Report	Page 210
	Skill and Competencies
E.4.6	Does at least one non-executive director/commissioner have prior working experience in the major sector that the company is operating in?	The Nomination Policy stipulates that the NRC review on the proposed BOC and BOD candidate to ensure fulfilment of required qualification and background in accordance with the need and long-term strategy of XL Axiata. Most of BOD and BOC members have working experience in the same field with the Company’s main business as disclosed in each BOD and BOC profile in 2020 Integrated Annual Report and website of XL Axiata.	2020 Integrated Annual Report Nomination Policy	Page 96 Page 125
E.5	Board Performance
E.5.1	Does the company have orientation programmes for new directors/commissioners?	XL Axiata held an Induction Program for each newly appointed member of BOC and BOD of the Company by GMS. The Induction Program is organized by the Corporate Secretary in the form of presentation on the Company’s fundamental matters as follows: The Company’s strategy which includes business plans, branding and technology and networks. Presentation of Governance includes: duties, responsibilities and authorities as members of the Board of Directors and / or the Board of Commissioners. Policies related to governance	2020 Integrated Annual Report	Page 140
E.5.2	Does the company have a policy that encourages directors/ commissioners to attend on-going or continuous professional education programmes?	Each member of the BOD and BOC always develops his/her competency in order to support the implementation of his/her duties and responsibilities. The competency development can be in the form of participation in seminar, training or as a speaker in events related to the Company’s business scope.	2020 Integrated Annual Report	Page 96-103 Page 125-129
	CEO/Executive Management Appointments and Performance
E.5.3	Does the company disclose the process on how the board of directors/commissioners plans for the succession of the CEO/Managing Director/President and key management?	Process of Succession Director as mention in Director Sucession Policy	Director Sucession Plan Policy	Page 139
E.5.4	Does the board of directors/commissioners conduct an annual performance assessment of the CEO/Managing Director/President?	In 2020, XL Axiata held a self assessment by BOD and BOC which included Board Effectiveness, peer-to-peer assessment with fellow members of the BOD and Cross Board Assessments with each member of the BOC. The assessment includes understanding the roles, duties and responsibilities as well as evaluating the Company’s GCG. The assessment results will be used as recommendations for the Company’s GCG improvements and as one of the basic considerations of the respective BOD member to be reappointed.	2020 Integrated Annual Report	Page 109 Page 139
	Board Appraisal
E.5.5	Did the company conduct an annual performance assessment of the board of directors/commissioners and disclose the criteria and process followed for the assessment?	The BOC performance assessment is conducted as collegial performance for respective financial year as reported in the Annual General Meeting of Shareholders. The General Meeting of Shareholders then provides full release and discharge of responsibilities (acquit et decharge) to the XL Axiata BOC for supervisory during the respective Financial Year Performance assessment of each member of the Board of Directors is carried out by the Nominating and Remuneration Committee based on the achievement of the Key Performance Indicator (KPI) with the Company’s achievements and certain targets (if any). Assessment on BOC and BOD performance is also conducted by the Nominating and Remuneration Committee as well as self assessment assessment on Board Effectiveness.	2020 Integrated Annual Report	Page 114 Page 109 Page 139
	Director Appraisal
E.5.6	Did the company conduct an annual performance assessment of the individual directors/commissioners and disclose the criteria and process followed for the assessment?	Company has conducted performance assessment of each member of the Board of Directors which carried out by the Nominating and Remuneration Committee based on the achievement of the Key Performance Indicator (KPI) with the Company’s achievements and certain targets (if any). In addition, performance appraisal is also handled by the Remuneration and Nomination Committee of XL Axiata, as one of their duties, as stated in the committee’s meeting agenda, as well as through self assessment on Board Effectiveness.	2020 Integrated Annual Report	Page 139 Page 121
	Committee Appraisal
E.5.7	Did the company conduct an annual performance assessment of the board committees and disclose the criteria and process followed for the assessment?	Assessment on Committee under the BOC and BOD are disclosed in 2020 Integrated Annual Report.	2020 Integrated Annual Report	Page 110 Page 139

Level 2

Item Bonus

No	Subject	Implementation in 2020	Reference
No	Subject	Implementation in 2020	Website	Integrated Annual Report 2020
(B)A	Rights of Shareholders
(B)A.1	Right to participate effectively in and vote in general shareholders meeting and should be informed of the rules, including voting procedures, that govern general shareholders meeting.
(B)A.1.1	Does the company practice secure electronic voting in absentia at the general meetings of shareholders?	XL Axiata has implemented an electronic voting (e-Voting) at the AGMS dated 18 May 2020 and EGMS dated 27 October 2020.	General meeting of shareholders	Page 86
(B)B	Equitable Treatment of Shareholders
(B)B.1	Notice of AGM
(B)B.1.1	Does the company release its notice of AGM (with detailed agendas and explanatory circulars), as announced to the Exchange, at least 28 days before the date of the meeting?	In 2020: The first notification of AGMS plan was released on 9 April 2020 for AGMS on 18 May 2020 or more than 28 days before the meeting date. Detailed agenda and explanatory of each agenda was published along with the date of the meeting invitation on 24 April 2020. As for the first notification of EGMS plan was released on 18 September 2020 for EGMS 27 October 2020 or more than 28 days before the meeting date. Detailed agenda and explanatory of each agenda was published along with the date of the meeting invitation on 5 October 2020.	General meeting of shareholders	Page 86
(B)C	Roles of Stakeholders
(B)C.1	The rights of stakeholders that are established by law or through mutual agreements are to be respected
(B)C.1.1	Does the company adopt an internationally recognized reporting framework for sustainability (i.e. GRI, Integrated Reporting, SASB)?	For financial year of 2020, XL Axiata has prepared and submitted an 2020 Integrated Annual Report (IAR) which has developed based on the International Integrated Reporting Framework released by the International Integrated Reporting Council (IIRC).	2020 Integrated Annual Report	-
B)D	Disclosure and transparency
(B)D.1	Quality of Annual Report
(B)D.1.1	Are the audited annual financial report/statement released within 60 days from the financial year end?	The audited annual financial statement of XL Axiata was released on 15 February 2020 or 46 days after the financial year end.	Annual Financial Statement	Page 222-223
(B)D.1.2	Does the company disclose details of remuneration of the CEO?	The Company discloses the details remuneration of the CEO in 2020 Integrated Annual Report, which consists of, salary, transport allowance, telecommunication allowance, other regular allowance and holiday allowance, as well as bonus.	2020 Integrated Annual Report	Page 114
(B)E	Responsibilities of the Board
(B)E.1	Board Competencies and Diversity
(B)E.1.1	Does the company have at least one female independent director/ commissioner?	As of 2020, XL Axiata had 1 (one) woman who is an Independent Commissioner, namely: Mrs. Yasmin S. Wirjawan.	2020 Integrated Annual Report Our Leadeer	Page 77
(B)E.1.2	Does the company have a policy and disclose measurable objectives for implementing its board diversity and report on progress in achieving its objectives?	Yes, it does. Requirements and qualifications of member of BOD and BOC of XL Axiata comply with OJK Regulation 33/2014 and the needs of the Company which including diversity of expertise and composition of BOC and BOD. This has been published in 2020 Integrated Annual Report.	2020 Integrated Annual Report	Page 104 Page 130
(B)E.2	Board Structure
(B)E.2.1	Is the Nominating Committee comprise entirely of independent directors/ commissioners?	XL Axiata complies with OJK Regulation 34/2014 where it’s regulated thatthe composition of Nominating and Remuneration Committee shall consist of: 1 chairman concurrent as member, which is an Independent Commissioner; Other member may come from (i) BOC members, (ii) external independent party, and (iii) a person with managerial position in Human Resources under BOD. In accordance with above regulation, as of 2020, 2 (two) Independent Commissioners of the Company and one from external independent party were included in the membership of the Company's Nominating and Remuneration Committee.	2020 Integrated Annual Report Nominating and Remuneration Committee	Page 119
(B)E.2.2	Does the Nominating Committee undertake the process of identifying the quality of directors aligned with the company's strategic directions?	The main duties of Nominationg and Remuneration Commiittee which includes an analysis of the candidates for the Board of Directors or the Board of Commissioners as proposed in Committee meetings or through circular decisions, which are in accordance with the requirements of the candidate’s qualification and background. The proposal will be brought to and approved by the GMS. This also has been disclosed in the appointment of Directors in 2020 whereby such appointment was conducted by considering the quality of the Directors in which the quality is aligned with the needs of the Company, including Company’s strategic direction. For instance, the appointment of David Arcelus Oses in AGMS dated 18 May 2020 is aligned with the Company’s strategic direction as he is replacing the previous commercial Director, as well as the appointment of Budi Pramantika in EGMS 27 October 2020 who is replacing the previous finance Director. Further, on the appointment of I Gede Darmayusa in EGMS 27 October 2020, the Nominating and Remuneration Committee recommended him to be appointed as Director, due to his expertise in technology in which his contribution will support the Company to achieve the Company’s strategic direction.	2020 Integrated Annual Report Nominating and Remuneration Committee GMS	Page 104 Page 130
(B)E.3	Board Appointments and Re-Election
(B)E.3.1	Does the company use professional search firms or other external sources of candidates (such as director databases set up by director or shareholder bodies) when searching for candidates to the board of directors/commissioners?	XL Axiata has an internal Talent Pool for the successor or candidates of senior leadership including the Board of Directors’ candidate. Apart from such internal Talent Pool, XL Axiata is also collaborated with Axiata to integrate the talent pool with the Group. In the event, no specific candidates is available in both XL Axiata and Axiata’ Talent Pool, thus XL Axiata is engaging professional recruiters to find suitable candidate.	2020 Integrated Annual Report	Page 72
(B)E.4	Board Structure & Composition
(B)E.4.1	Do independent non-executive directors/commissioners make up more than 50% of the board of directors/commissioners for a company with independent chairman?	XL Axiata in this matter complies with OJK Regulation No. 33/POJK.04/2014 whereby the composition of Independent Commssioners shall be 30% of total members of the Board of Commissioners. As per 31 December 2020, the Company has (3) members of Independent Commissioner from total nine (9) members of Board of Commissioners, namely: Muliadi Rahardja Yasmin S. Wirjawan Julianto Sidarto	2020 Integrated Annual Report Our Leader	Page 96
(B)E.5	Risk Oversight
(B)E.5.1	Does the board describe its governance process around IT issues including disruption, cyber security, disaster recovery, to ensure that all key risks are identified, managed and reported to the board?	As a company engages in telecommunications, it must be very related to Information Technology (IT). In carrying out the duties of the BOD of XL Axiata is also assisted by the Information Technology Committee, where this committee reports periodically to the BOD as well as to provides any input and recommendations related to IT. Submission of reports related to IT governance exposure at XL Axiata can be found in the Integrated Annual Report.	2020 Integrated Annual Report Network	Page 63 Page 141
(B)E.6	Board Performance
(B)E.6.1	Does the company have a separate board level Risk Committee?	XL Axiata has 2 risk committees: Under the Commissioners, namely Risk and Compliance Committee; and Under the Directors, namely Risk Management and Business Sustainability Committee	2020 Integrated Annual Report Board Risk and Compliance Committee	Page 123 Page 144

Penalty

No	Subject	Implementation in 2020	Reference
No	Subject	Implementation in 2020	Website	Integrated Annual Report 2020
(P)A	Rights of Shareholders
(P)A.1	Basic shareholder rights
(P)A.1.1	Did the company fail or neglect to offer equal treatment for share repurchases to all shareholders?	XL Axiata has treated all shareholders the same and equally, without any exceptions. XL Axiata has completed the buyback shares in 2020 due to the market conditions that fluctuate significantly and has been performed in accordance with the prevailing laws and regulations.	Disclosure Information on the Plan of Buyback Share Result of Share Buyback	Page 199
(P)A.2	Shareholders, including institutional shareholders, should be allowed to consult with each other on issues concerning their basic shareholder rights as defined in the Principles, subject to exceptions to prevent abuse.
(P)A.2.1	Is there evidence of barriers that prevent shareholders from communicating or consulting with other shareholders?	XL Axiata does not have a policy that stipulates the restrictions of the shareholders for communicating or consulting with one the other shareholders. There is no evidence of barriers that prevent shareholders from communicating or consulting with other shareholders.	-	-
(P)A.3	Right to participate effectively in and vote in general shareholders meeting and should be informed of the rules, including voting procedures, that govern general shareholders meeting.
(P)A.3.1	Did the company include any additional and unannounced agenda item into the notice of AGM/EGM?	At the 2020 and 2021 XL Axiata’s AGMS/EGMS, there were no additional agenda items and there were no items that are not announced. XL Axiata always announces all GMS’ agenda items at the time of the invitation, whereby the meeting’s agenda which has been announced is always the same as the agenda of the meeting at the time of the GMS.	-	-
(P)A.3.2	Did the Chairman of the Board, Audit Committee Chairman and CEO attend the most recent AGM?	Chairman of the Board, Audit Committee Chairman and CEO attended the most recent AGM. Evidence of attendance list was stipulated in: The summary of minutes of meeting – Board Attendance; Notarial Deed of minutes of meeting; 2020 Integrated Annual Report.	Summary of AGMS and EGMS	Page 86 Page 89
(P)A.4	Capital structures and arrangements that enable certain shareholders to obtain a degree of control disproportionate to their equity ownership should be disclosed.
	Did the company fail to disclose the existence of:
(P)A.4.1	Shareholders agreement?	XL Axiata does not have shareholders agreement.	-	-
(P)A.4.2	Voting cap?	XL Axiata does not regulate voting cap.	-	-
(P)A.4.3	Multiple voting rights?	XL Axiata does not regulate multiple voting rights.	-	-
(P)A.5	Capital structures and arrangements that enable certain shareholders to obtain a degree of control disproportionate to their equity ownership should be disclosed.
(P)A.5.1	Is a pyramid ownership structure and/or cross holding structure apparent?	XL Axiata does not have pyramid ownership structure and/or cross holding structure.	-	-
(P)B	Equitable treatment of shareholders
(P)B.1	Insider trading and abusive self-dealing should be prohibited.
(P)B.1.1	Has there been any conviction of insider trading involving directors/ commissioners, management and employees in the past three years?	In the past 3 (three) years, there is no evidence of insider trading involving Directors/Commissioners, management and employees of XL Axiata.	-	-
(P)B.2	Protecting minority shareholders from abusive action
(P)B.2.1	Has there been any cases of non-compliance with the laws, rules and regulations pertaining to material related party transactions in the past three years?	The supervision of any XL Axiata’s related party transactions is under the duty and responsibility of the Audit Committee. Therefore, there were no cases of non-compliance with the laws, rules and regulations pertaining to material related party transactions in the past three years.	2020 Integrated Annual Report	Page 118
(P)B.2.2	Were there any RPTs that can be classified as financial assistance (i.e not conducted at arms length) to entities other than wholly-owned subsidiary companies?	XL Axiata does not have any RPTs that can be classified as financial assistance to entities other than wholly-owned subsidiary companies. This item can refer to the Annual Financial Statements of XL Axiata as well as Disclosure Information which XL Axiata always does.	Annual Financial Statement	Page 222-223
(P)C.	Roles of Stakeholders
(P)C.1	The rights of stakeholders that are established by law or through mutual agreements are to be respected
(P)C.1.1	Have there been any violations of any laws pertaining to labour/employment/ consumer/insolvency/commercial/ competition or environmental issues?	In XL Axiata, there is no violations of any laws pertaining to labour/ employment/ consumer/ insolvency/ commercial/ competition or environmental issues.	-	-
(P)C.2	Where stakeholders participate in the corporate governance process, they should have access to relevant, sufficient and reliable information on a timely and regular basis.
((P)C.2.1	Has the company faced any sanctions by regulators for failure to make announcements within the requisite time period for material events?	XL Axiata has never faced any sanctions from regulators for failure to make announcements on material events. This is as described in the XL Axiata’s Integrated Annual Report.	2020 Integrated Annual Report	Page 153
(P)D.	Disclosure and transparency
(P)D.1	Quality of Annual Report
(P)D.1.1	Did the company receive a "qualified opinion" in its external audit report?	In XL Axiata’s Annual Financial Report which audited by the Public Accounting Firm of Tanudiredja, Wibisana, Rintis & Rekan (a member firm of PricewaterhouseCoopers Global in Indonesia), XL Axiata has received an Unqualified Opinion in all material aspects.	Annual Financial Statement	Page 222-223
(P)D.1.2	Did the company receive an "adverse opinion" in its external audit report?
(P)D.1.3	Did the company receive a "disclaimer opinion" in its external audit report?
(P)D.1.4	Has the company in the past year revised its financial statements for reasons other than changes in accounting policies?	In the past year, XL Axiata has never revised its financial statements for reasons other than changes in accounting policies. This is consistent with the submission of XL Axiata through the website of Indonesia Stock Exchange.	-	-
(P)E.	Dewan Komisaris Responsibilities of the Board
(P)E.1	Board Competencies and Diversity
(P)E.1.1	Is there any evidence that the company has not complied with any listing rules and regulations over the past year apart from disclosure rules?	XL Axiata has never failed to comply with listing rules and regulations over the past year apart from disclosure rules, therefore there is no evidence to support this.	-	-
(P)E.1.2	Have there been any instances where non-executive directors/commissioner have resigned and raised any issues of governance-related concerns?	There is no member of BOD and BOC of XL Axiata whom has resigned and raised any issues of governance-related concerns.	-	-
(P)E.2	Board Structure
(P)E.2.1	Does the company have any independent directors/commissioners who have served for more than nine years or two terms of five years each (which ever is higher) in the same capacity?	There is no Independent Commissioners of XL Axiata has served for more than nine years or two terms of five years each (whichever is higher). This is as described in the XL Axiata Integrated Annual Report and website of XL Axiata.	2020 Integrated Annual Report BOC Profile	Page 96
	¹The five years term must be required by legislation which pre-existed before the introduction of the ASEAN Corporate Governance Scorecard in 2011
(P)E.2.2	Did the company fail to identify who are the independent director(s)/ commissioner(s)?	XL Axiata did not fail for identifying who is the Independent Commissioner(s). All Independent Commissioner of XL Axiata who served is described in the XL Axiata Integrated Annual Report and the XL Axiata website.	2020 Integrated Annual Report BOC Profile	Page 96
(P)E.2.3	Does the company have any independent directors/non-executive/commissioners who serve on a total of more than five boards of publicly-listed companies?	XL Axiata does not have independent directors/non-executive/commissioners who serve on a total of more than five boards of publicly-listed companies. The profiles of each member are presented in the XL Axiata Integrated Annual Report and the XL Axiata website.	2020 Integrated Annual Report BOC Profile	Page 96
(P)E.3	External Audit
(P)E.3.1	Is any of the directors or senior management a former employee or partner of the current external auditor (in the past 2 years)?	XL Axiata does not have directors or commissioners who are former employees or partners of the current external auditor (in the last 2 years).
(P)E.4	Board Structure & Composition
(P)E.4.1	Has the chairman been the company CEO in the last three years?	President Commissioner of XL Axiata has never been the CEO of the company in the last three years.	-	-
(P)E.4.2	Do independent non-executive directors/commissioners receive options, performance shares or bonuses?	Independent Commissioners of XL Axiata do not receive options, performance shares or bonuses. This is in accordance with the Summary of AGMS and Minutes Meeting of AGMS of XL Axiata which published on the XL Axiata website, the Integration Annual Report, and the Indonesia Stock Exchange website.	Summary of AGMS 2020 Integrated Annual Report	Page 88 Page 113

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