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Creating a Better World Through Sustainable Business Partnership - PT SARATOGA INVESTAMA SEDAYA TBK.
Creating a Better World
               Through
 Sustainable Business
            Partnership

       PT SAR ATO G A I N V ESTAMA SED AYA T BK .
                   S U S TA I N A BI L I TY REPO R T 2 0 2 0
Creating a Better World Through Sustainable Business Partnership - PT SARATOGA INVESTAMA SEDAYA TBK.
PT S ARATOGA I NVESTAM A SE D AYA T B K .   | S U S TA I N A B I L I T Y R E P O R T 2 0 2 0                     1

                            Table of Contents

                     Table of Contents                                                                      1

                     Theme Description                                                                      2

                     President Director’s Message                                                          3-6

                     Sustainability Performance Highlights                                                 7-8

                     Investment Milestone                                                                 9-10

                     About the
                     2020 Sustainability Report
                                                                 Company Profile                         12-13
                                                                 Organization Scale                        19

                     Sustainable Economic
                     Performance
                                                                 Saratoga Governance                       28
                                                                 Governance Principles                   32-33
                                                                 Sustainable Economy                       34

                     Social Performance
                                                                 Excellent Human Resources                 38
                                                                 Employee Health, Safety and Wellbeing     43
                                                                 Training and Development                  43
                                                                 Grow Together to Build Communities        48
                                                                 and Preserve the Environment

                     GRI Index                                                                             57

                     Feedback Form                                                                         58
Creating a Better World Through Sustainable Business Partnership - PT SARATOGA INVESTAMA SEDAYA TBK.
PT S ARATOGA I NVESTAM A SE D AYA T B K .   | S U S TA I N A B I L I T Y R E P O R T 2 0 2 0                                                                      2

                                                                                                    Theme
                                                                                                    Description

                                                                                               As      an          active         investment        company,
                                                                                               we believe that our biggest role in contributing
                                                                                               to sustainable development is to ensure that
                                                                                               the sustainability principles are well applied
                                                                                               to our Company and our investee companies.
                                                                                               We    strive    to     always      consider     environmental
                                                                                               and   social        sustainability     in   our     investment
                                                                                               decisions      to     minimize       the    impact    on     the
                                                                                               environment          and     all    relevant      stakeholders.

                                                                                               By building strategic partnerships and engaging
                                                                                               with our investees and partners, we aim to
                                                                                               encourage       them         to    align    sustainability    as
                                                                                               part of the company’s operations and ensure
                                                                                               economic, social and environmental sustainability.
Creating a Better World Through Sustainable Business Partnership - PT SARATOGA INVESTAMA SEDAYA TBK.
PT S ARATOGA I NVESTAM A SE D AYA T B K .   | S U S TA I N A B I L I T Y R E P O R T 2 0 2 0                                                                   3

                        President
                        Director’s
                        Message
                        [G R I 1 02- 14]

                                                                                               Michael William P. Soeryadjaya
                                                                                               President Director

               Dear Stakeholders,                                                                     Our sustainable development framework
                                                                                                      based on four pillars:
               We are proud to present the Saratoga 2020
                                                                                                      1. Partnership for Sustainability
               Sustainability Report, which is our first Sustainability
                                                                                                      2. Long Term View and Sustainability Strategy
               Report. In this report we would like to present
                                                                                                      3. Growing Together with Competent
               Saratoga’s sustainability performance in the social,
                                                                                                         Human Resources
               environmental and corporate governance that
                                                                                                      4. Growing with Community and in Harmony
               are material for our business and stakeholders.
                                                                                                         with Environment

               As an active investment company, our contribution
               in the framework of sustainable development is to
                                                                                                      Partnership for Sustainability
               ensure that investments are carried out responsibly
                                                                                                      Sustainability in business is believed to be the
               and sustainably, not only in economic aspects
                                                                                                      most significant trend shaping the world economy
               but also in social and environmental aspects.
                                                                                                      over the coming decades. We seek to enhance
                                                                                                      our position as a leader in active investment
                                                                                                      company in Indonesia that help put the economy
                                                                                                      on a sustainable track. Our overall focus is to invest
                                                                                                      responsibly to increase the economic value of our
Creating a Better World Through Sustainable Business Partnership - PT SARATOGA INVESTAMA SEDAYA TBK.
PT S ARATOGA I NVESTAM A SE D AYA T B K .   | S U S TA I N A B I L I T Y R E P O R T 2 0 2 0                                                                                  4

               portfolio companies, increase positive social and                                    We believe our responsibility to stakeholders is not
               environmental contributions and support long-term                                    just to generate profits but also to create prosperity
               value creation for a wider range of stakeholders.                                    for the community and protect the environment.
               As an active investor with long-term prospects,                                      Prioritizing benefits over other performance may
               we     consider       sustainability             issues           intuitively        result in better short-term gains, but less socially
               in    investment       decisions            and          engagements.                acceptable in long term wise and can have an
                                                                                                    adverse impact on the environment which will
               In every investment decision making, we use                                          ultimately       affect      the       company’s        sustainability.
               the    Social      and       Environmental                  Performance
               Standards as an assessment standard for social                                       We encourage investee companies to commit
               and environmental performance of prospective                                         more to reduce social and environmental impacts
               investee companies. Social and Environmental                                         of their operations and to actively contribute to
               Performance        Standards           help         us       to      identify        their sustainability initiatives. Increasing awareness
               the     social     and       environmental                     risks        and      of the importance of a balance between economic
               impacts     of    investee        companies                by       focusing         performance and environmental as well as social
               on eight key issues, namely risk management,                                         sustainability,        especially        in     start-up     investee
               employment,                   resources                           efficiency,        companies, is one of the focuses of our support
               communities,        land       resettlement,                 biodiversity,           because we realize that the main orientation of
               indigenous        peoples,         and         cultural            heritage.         start-up companies in general is to prioritize profit.

               We are proactively taking part in our portfolio                                      Growing with Community and in Harmony
               companies’ individual growth journey. Through                                        with Environment
               strategic     engagements             and        partnerships,                  we   in Recognizing our role as part of the community,
               enhance our understanding and support in terms of                                    we carry out various community development
               investee’s strategy, risk, performance and corporate                                 programs which mainly focus on the education
               governance. Together with our investee companies                                     sector         with       the      aim         of      strengthening
               and investment partners, we discuss strategies                                       the      foundation             for      empowerment              and
               and opportunities to face existing risks and                                         improving the life quality of the community.
               challenges to achieve common goals and benefits.
                                                                                                    Throughout 2020, we continued the flagship
               Long Term View and Sustainability Strategy                                           programs implementation that previously have
               As an active investment company, a long-term                                         been      running,        namely,        the        Entrepreneurship
               outlook and approach is the added value we offer                                     Development            for      Youth         (ENVOY)       program
               to our investee companies and investment partners.                                   and      the     “To      be       a    New         Green    Leader”
               Through our long-term strategy approach, we                                          Environmental           Leadership            Training      program.
               focus on sustainability through business plans and
               long-term value creation from investee companies.

               A     long-term     view       ensures           us       to       integrate
               a sustainability factor into our investment process
               which helps lead to more informed investment
               and more sound, risk-adjusted long-term returns.
Creating a Better World Through Sustainable Business Partnership - PT SARATOGA INVESTAMA SEDAYA TBK.
PT S ARATOGA I NVESTAM A SED AYA T B K .    | S U S TA I N A B I L I T Y R E P O R T 2 0 2 0                                                                  5

              The ENVOY program is an entrepreneurship
                                                                                                    Growing Together with Competent
              development program for students that aims
                                                                                                    Human Resources
              to create new young entrepreneurs. More than
                                                                                                    It is important for us to ensure that human resource
              350 young entrepreneurs have been born since
                                                                                                    development is in line with business development.
              the     program       began         in       2009.          Furthermore,
                                                                                                    We believe that the company’s sustainability and
              through the “To be a New Green Leader”
                                                                                                    growth is supported by competent human resources
              Environmental         Leadership               Training            program,
                                                                                                    and a healthy and comfortable work environment.
              we      are     working        to        raise          awareness                of
              the       environment             and             support               agents
                                                                                                    Through various training programs, we always
              of    environmental          change          in      various          regions
                                                                                                    support our employees to have the opportunity to
              of    Indonesia.      By     the        end        of       2020,          more
                                                                                                    learn and develop themselves. A total of 38 training
              than      17,000       people            from           24        provinces
                                                                                                    sessions have been conducted for our employees
              have          benefited          from              this            program.
                                                                                                    in 2020. Each year we also conduct an annual
                                                                                                    evaluation of employee performance to determine
              As a response and concern for the Covid-19
                                                                                                    potential development tailored to each individual.
              pandemic in 2020, Saratoga has carried out various
              joint initiatives with investee companies and
                                                                                                    We recognize that the safety and health of Saratoga
              partners to support the government in dealing with
                                                                                                    employees is of utmost importance. Since the start
              the pandemic and providing assistance to affected
                                                                                                    of the pandemic in March 2020, we have made
              communities. Assistance of 50 ventilators and
                                                                                                    various changes to work patterns, including Work
              more than 2,000,000 units of Personal Protective
                                                                                                    from Home (WFH), to reduce transmission rates and
              Equipment (PPE) such as protective clothing,
                                                                                                    ensure the health of our employees. This change in
              helmets,           masks,           gloves                has              been
                                                                                                    working patterns does not reduce the productivity of
              provided         to        several             hospitals,                clinics
                                                                                                    our employees, on the other hand provides a sense
              and       communities               throughout                   Indonesia.
                                                                                                    of security for them to continue to do their jobs well.
              In     addition,      we     also         handed             over          more
              than 1000 food packages to health workers
                                                                                                    Sustainability Challenges and Opportunities
              in      several        hospitals                around                Jakarta.
                                                                                                    As we know, 2020 is a tough year for business and
                                                                                                    global community because of Covid-19 pandemic.
                                                                                                    An unprecedented situation where the global
                                                                                                    pandemic has changed the world economic order
                                                                                                    causing a global economic and financial crisis. The
                                                                                                    economic contraction that occurred was mainly due
                                                                                                    to the sudden stoppage of various economic activities
                                                                                                    and affected many industrial sectors, including
                                                                                                    Saratoga and some of our investee companies.
Creating a Better World Through Sustainable Business Partnership - PT SARATOGA INVESTAMA SEDAYA TBK.
PT S ARATOGA I NVESTAM A SED AYA T B K .   | S U S TA I N A B I L I T Y R E P O R T 2 0 2 0                                                                  6

              The fluctuation of economic and political conditions
                                                                                                     Appreciation
              as well as the prolonged impact of the pandemic
                                                                                                     All of Saratoga’s achievements in sustainable
              creates uncertainty in the business climate. In
                                                                                                     performance are not separated to the hard work of
              keeping our financial performance consistent and
                                                                                                     our human resources and synergies with investee
              growing in an unfavorable business climate, we
                                                                                                     companies, partners and all stakeholders. On behalf
              implement a cost leadership strategy that focuses
                                                                                                     of the entire Saratoga management, we would like
              on minimizing costs while maintaining quality and
                                                                                                     to express our deepest appreciation and gratitude.
              competitive advantage. We apply this strategy
              internally to us and our investee companies.

              Portfolio      diversification         and         careful          financial
              management have enabled us to survive and thrive
              in times of pandemics. The declining performance
              of several investee companies due to the impact
              of the pandemic was offset by the performance
              of other investee companies which tended to
              be stable and increased during this pandemic.

              We believe there are still many opportunities
              that we can gain from our investee companies
              and      the      development                of        a        diversified
              portfolio      going    forward.           Therefore,              we           will
              explore the potential and opportunities that
              exist for the development of the company.

                                                                                                                            Michael William P. Soeryadjaya
                                                                                                                                        President Director
Creating a Better World Through Sustainable Business Partnership - PT SARATOGA INVESTAMA SEDAYA TBK.
PT S ARATOGA I NVESTAM A SE D AYA T B K .   | S U S TA I N A B I L I T Y R E P O R T 2 0 2 0                                                          7

                        Sustainability
                        Performance Highlights
                        (IDR in Billion)

                                                                                                                        2018

                                                                                                                        15.772
                                                                                                                                               2020
                                                                                                  Generated
                                                                                                  Value                              31.701
                          1.403                                                                   (Net Asset Value)

                                                                       652                                                  2019
                                    2018              2020
                                                                                                                            22.855
                                    2019
                                                         Active
                                                         Investment
                  1.149                                  *on a net basis

                       Discipline
                       in Execution
                                                                                               2018              2019              2020

                                                New Investment                                        1                 0                 0

                                                Term Sheet                                            8                 7                 6

                                                Desktop Dilligence                                    32                18                22

                                                Initial Assessment                                    47                50                30

                                                Opportunities                                         91                172               86
Creating a Better World Through Sustainable Business Partnership - PT SARATOGA INVESTAMA SEDAYA TBK.
PT S ARATOGA I NVESTAM A SE D AYA T B K .   | S U S TA I N A B I L I T Y R E P O R T 2 0 2 0                                                         8

                                                                                                                                              899
                        Dividend
                        Income
                                                                                                                                      482
                                                                                                                               251

                                                                                                                117

                                    2018                                                   40
                                                               0               2                    7      0            0

                                                                                                                                             1.993

                                                                                                                       1.118

                                                                                                                                      593

                                                                                                                               206
                                                                                                          61
                                    2019                                                                         8
                                                               1               1               0    5

                                                                                                                                              750

                                                                                                                               214    215
                                                                                                                       210
                                                                                                                105
                                    2020
                                                               0               2               0    4      0

                                                             AGII       Deltomed BHP               NRCA   TWU   PALM   MPM     TBIG   ADRO   TOTAL

                 17.000                                                                                    Donated

                 in 24 provinces
                 benefited from Saratoga Environmental
                                                                    PEOPLE

                                                                                                           >1.870
                                                                                                           FOOD PACKAGES
                 Leadership Training program
                 “To be a New Green Leader”

                 >350                                STUDENTS
                 from various regions has participated in ENVOY

                 20          STUDENTS
                             HAVE JOINED IN 2020
Creating a Better World Through Sustainable Business Partnership - PT SARATOGA INVESTAMA SEDAYA TBK.
PT S ARATOGA I NVESTAM A SE D AYA T B K .                              | S U S TA I N A B I L I T Y R E P O R T 2 0 2 0                                                                                9

                                         Investment Milestone
                                2002-2006             2007-2009                   2010                             2011                2012                  2013                  2014
NAV per share (IDR)

                                                                                                                                                                                           8.174
                                                                                             7.157                                            7.462
                                                                                                                                                                    6.557
                                                                                                                           6.108

                                                              3.560

                                       539

                                PT Adaro Indonesia    PT Adaro Energy Tbk.          PT Agro Maju Raya               PT Medco           Interra Resources     Finders Resources     PT Gilang Agung
                                Natural Resources     Natural Resources             Natural Resources               Power Indonesia    Limited               Limited               Persada
                                                                                                                    Infrastructure     Natural Resources     Natural Resources     Consumer
                                Coal & Energy         Coal & Energy                 Palm Plantation
                                                                                                                    Power Generation   Oil & Gas             Polymetallic          Lifestyle

                                PT Banyan Mas         PT Tower Bersama              PT Mitra Pinasthika
                                                                                                                    PT Tri Wahana      Seroja Investment     PT Nusa Raya          PT Trimitra Karya
                                Infrastructure        Infrastructure Tbk.           Mustika Tbk.
                                                                                                                    Universal          Limited               Cipta Tbk.            Jaya (holding of
                                Telco Tower           (formerly                     Consumer
                                                                                                                    Infrastructure     Infrastructure        Infrastructure        PT Merdeka Copper
                                                      PT Banyan Mas)                Automotive                                                                                     Gold Tbk.)
                                                                                                                                       Freight Chartering    Construction
 Saratoga Investment Activity

                                                                                                                    Oil Refinery
                                                      Infrastructure
                                                                                                                                                                                   Natural Resources
                                PT Tenaga Listrik     Telco Tower
                                Gorontalo                                           PT Tenaga Listrik                                                                              Gold
                                                                                                                                       Sihayo Gold Limited   PT Mitra Pinasthika
                                Infrastructure                                      Gorontalo
                                                                                                                                       Natural Resources     Mustika Tbk.
                                Power Generation                                    Infrastructure                                                           Consumer
                                                                                                                                       Gold
                                                                                    Power Generation                                                         Automotive

                                PT Lintas Marga                                                                                        Sumatra Copper
                                Sedaya                                                                                                 and Gold PLC
                                Infrastructure                                                                                         Natural Resources
                                Toll Road                                                                                              Polymetallic

                                PT Provident
                                Agro Tbk.
                                Natural Resources
                                Palm Oil Plantation

                                                      PT Adaro Energy Tbk.          PT Tower Bersama                                   PT Provident          PT Mitra Pinasthika
                                                                                    Infrastructure Tbk.                                Agro Tbk.             Mustika Tbk.
 Listing

                                                                                                                                                             PT Saratoga
                                                                                                                                                             Investama Sedaya
                                                                                                                                                             Tbk.

                                                                                                                                       Sold stake in an                            Sold stake in an
                                                                                                                                       investee company                            investee company
 Divestment
PT S ARATOGA I NVESTAM A SE D AYA T B K .    | S U S TA I N A B I L I T Y R E P O R T 2 0 2 0                                                     10

      2015                  2016                        2017                             2018               2019               2020
                                                                                                                                    11.685

                                                                   8.240                                            8.424
                                     7.202
                                                                                                 5.814
           5.007

       PT Agra Energi        PT Mulia Bosco              PT Deltomed                      PT Aneka Gas
       Indonesia             Logistik                    Laboratories                     Industri Tbk.
       Natural Resources     Consumer                    Consumer                         Consumer
       Oil & Gas             Cold-chain logistics        Herbal Medicine                  Industrial Gas

       PT Paiton Energy      PT Famon Awal
       Infrastructure        Bros Sedaya
       Power Generation      Consumer
                             Healthcare

                             PT Merdeka Copper
                             Gold Tbk.

       Issued EB of         Divested                     Divested PT Lintas               Divested          Sold stake in an   Sold stake in an
       USD100 million       PT Pulau Seroja Jaya         Marga Sedaya                     PT Batu Hitam     investee company   investee company
                                                                                          Perkasa (Paiton
                            Divested palm                Divested                         Energy)
                            plantationassets of          PT Medco Power
                            PT Provident Agro Tbk        Indonesia
                            with a market premium
                            price per hectare.           Sold stake in an
                                                         investee company
About the 2020
Sustainability Report
PT S ARATOGA I NVESTAM A SE D AYA T B K .    | S U S TA I N A B I L I T Y R E P O R T 2 0 2 0                                                           12

                                                                                                Company Data

                           Saratoga                                                              Company Name
                                                                                                 PT. Saratoga Investama Sedaya Tbk. [SRTG]

                           at a Glance                                                           Line of Business
                                                                                                 Carry out trading activities and investment business
                                                                                                 in the companies engaging, among others, in
                                                                                                 sector of natural resources and energy, mining,
                                                                                                 agriculture, plantation, forestry, infrastructure,
                                                                                                 manufacture, production, automotive, distribution,
               PT Saratoga Investama Sedaya Tbk.                                                 trading, technology, property, telecommunication,
               is a Jakarta-based company whose                                                  transportation, health, financial services,
               shares are listed on the Indonesia                                                and other services.   [GR I 102-2]

               Stock Exchange (IDX). Established
                                                                                                 Address
               in 1997, PT Saratoga Investama
                                                                                                 Menara Karya 15th Floor
               Sedaya Tbk. (ticker code: SRTG)
                                                                                                 Jl. H.R Rasuna Said Block X-5 Kav 1-2
               is a world-class active investment
                                                                                                 South Jakarta 12950     [GR I 102-3]
               company in Indonesia with a unique
               track record of creating value for                                                Legal Entity

               our stakeholders and the nation.                                                  Limited Liability Company       [GR I 102-5]

               [GR I 10 2 -1]
                                                                                                 Domicile                  Phone
                                                                                                 Jakarta                   +62 21 5794 4355
               Our         investments       provide             the
                                                                                                 Fax                       Website
               public with access not only to
                                                                                                 +62 21 5794 4365          www.saratoga-investama.com
               key strategic growth sectors of
               Indonesia but also to blue chip                                                   Email
               sector leaders and promising early                                                investor.relations@saratoga-investama.com
               stage and developing companies.                                                   corporate.secretary@saratoga-investama.com

                                                                                                    Core Values               Corporate
                                                                                                                              Character
                                                                                                       Work Hard                 Integrity
               Vision                                    Mission
               To        become         world-           To be the
                                                                                                       Work Smart                Passion & Energy
               class active investment                   partner of choice
               company in Indonesia                      for investors
                                                                                                       Work
               that       excels      on    the          to participate                                                          Competence &
                                                                                                       Thoroughly
               back             of      strong           in the dynamic                                                          Capability
               corporate             characters          growth of                                     Work
                                                                                                       Wholeheartedly
               to create value for our                   Indonesia
               stakeholders and
               the nation
PT S ARATOGA I NVESTAM A SED AYA T B K .    | S U S TA I N A B I L I T Y R E P O R T 2 0 2 0                                                                 13

              Saratoga, an Active Investment
              Company in Indonesia

              Our active investment                                                                  Our Investment
              methodology                                                                            Framework

               Platforms,      partnerships            and          value           creation         Our   investment    framework     is   defined     by
               are    three     clear       concepts             that        guide             us.   substantial development opportunities in Natural
                                                                                                     Resources, Infrastructure as well as Consumer
               PLATFORMS                                                                             Products and Services markets – our three key
               We view each investment strategically, as a                                           pillars to support Indonesia’s economic growth.
               platform for organic growth and future bolt
               on acquisitions within the entire value chain.
                                                                                                     Our portfolio is spread across:
               PARTNERSHIPS                                                                          • Early stage companies with significant upside;
               We work closely with existing business owners whose
               role is critical in providing continuity and performance.                             • Growth companies entering their mature,
               Working with global professional investors, our                                        highly cash generative phase; and
               role is defined as a vital local partner, providing
               extensive knowledge of the market and regulatory                                      • Listed blue chip companies with well-established
               environment. We embrace specialist expertise that                                      market positions, offering long term growth and
               can equip our investees with superior knowledge                                        capital appreciation.
               and     technology          for     competitive                advantage.

               VALUE CREATION
               We    offer    capital       support,          operational               input,
               financial advisory and access to significant business
               expertise and commercial acumen, across Saratoga.
               Our    portfolio     provides            shareholders                with        a
               prudent balance of risk management and reward.
PT S ARATOGA I NVESTAM A SED AYA T B K .     | S U S TA I N A B I L I T Y R E P O R T 2 0 2 0                                    14

                       Portfolio
                       Highlights
                       [G R I 1 02- 2] [GRI 102- 4] [GRI 102- 6] [GRI 102- 9] [GR I 102-10]

                                                                 FOCUS ON GROWTH                     ESTABLISHED

                                                                                  MERDEKA                ADARO ENERGY
                                                                                COPPER GOLD                 Coal & Energy
                                                                                  Gold & Copper

                                                                            PROVIDENT AGRO
              Natural                                                             Palm Plantation
              Resources

                                                                        ANEKA GAS INDUSTRI              TOWER BERSAMA
                                                                                   Consumer and         INFRASTUCTURE
                                                                                   Industrial Gas      Telecommunication Tower

                                                                      MULIA BOSCO LOGISTIK
              Infrastructure                                                  Cold-chain Logistics

                                                                            NUSA RAYA CIPTA
                                                                                    Construction

                                                                                FAMON AWAL              MITRA PINASTHIKA
                                                                                BROS SEDAYA                 MUSTIKA
                                                                                      Healthcare             Automotive

                                                                                    DELTOMED
              Consumer                                                           Herbal Medicine

                                                                                PROVIDENT
                                                                               GROWTH FUND
                                                                                     Technology

                                                                            SC TECHNOLOGY
                                                                           INVESTMENT III LP
                                                                                     Technology
PT S ARATOGA I NVESTAM A SED AYA T B K .         | S U S TA I N A B I L I T Y R E P O R T 2 0 2 0                                                           15

                         Line of
                         Business

              As referred to in the Company’s Articles of                                           To support such main business activities, we are able
              Association, our main purposes and objectives                                         to engage in the supporting activities as follows:
              is to carry out trading activities and investment                                     [GR I 102-2] [GR I 102-9] [GR I 102-10]

              businesses in the companies engaging in three
              sectors, namely Natural Resources, Infrastructure,                                    1. To provide funding and/or financing needed
              as well as Consumer Products and Services.                                               by the companies in which the Company
               [G R I 1 0 2 -2] [GRI 102- 4] [GRI 102- 6] [GRI 102- 9] [GRI 1 02-10]
                                                                                                       has subscribed for its shares, either directly
                                                                                                       or indirectly.
              In pursuing its purposes and objectives, we are
              able conduct the main business activities as follows:                                 2. To provide funding and/or financing needed
              [G R I 1 0 2 -2] [GR I 102- 6] [GRI 102- 9] [GRI 102- 10]
                                                                                                       by the other companies within the framework
                                                                                                       of subscription of shares in such companies or
              1. To establish new companies or subscribe shares                                        such companies’ group or within the framework
                  in other companies either directly or indirectly;                                    of investment of other assets in such companies
                                                                                                       or companies’ group; and
              2. To divest or dispose shares upon the companies
                  in which the Company has subscribed, either                                       3. To provide management services needed by
                  directly or indirectly.                                                              the subsidiaries or companies where the
                                                                                                       Company has invested either directly
                                                                                                       or indirectly, in order to carry out
                                                                                                       its business activities.
PT S ARATOGA I NVESTAM A SED AYA T B K .                | S U S TA I N A B I L I T Y R E P O R T 2 0 2 0                                                                        16

 Name and Corresponding
 Address of Our Subsidiaries

  Subsidiary                  PT Bumi               PT Nugraha              PT Saratoga              PT Surya       PT Wahana      PT Wana         PT Lintas      PT Trimitra
  Name                        Hijau Asri            Eka Kencana             Sentra                   Nuansa Ceria   Anugerah       Bhakti Sukses   Indonesia      Karya Jaya*
                                                                            Business                                Sejahtera      Mineral         Sejahtera

  Corresponding Menara Karya                        Menara Karya            Menara Karya             Menara Karya   Menara Karya   Menara Karya    Menara Karya   Menara Karya
  Address       15th Floor                          15th Floor              15th Floor               15th Floor     15th Floor     15th Floor      15th Floor     15th Floor

  Line of                     Investment            Investment              Investment               Investment     Investment     Investment      Investment     Investment
  Business
  Year of                     2007                  2003                    2005                     2015           2005           2007            2018           2012
  Establishment
  Year of                     2010                  2003                    2005                     2015           2009           2011            2018           2014
  Investment
  Effective                   99,99%                99,99%                  99,99%                   99,99%         99,96%         73,68%          99,99%         86,49%
  Ownership
  Operational                 Active                Active                  Active                   Active         Active         Active          Active         Active
  Status
  Total Assets                IDR 219               IDR 786                 IDR 1.334                IDR 233        IDR 12.648     IDR 79          IDR 24         –
  (in IDR Billion)

 *note on full corresponding address:

 Menara Karya 15th Floor | Jl. H. R Rasuna Said Block X - 5 Kav. 1 - 2, South Jakarta 12950
 Phone : +62 21 5794 4355     Fax : +62 21 5794 4365

 *Total assets below IDR 1 Billion
PT S ARATOGA I NVESTAM A SE D AYA T B K .   | S U S TA I N A B I L I T Y R E P O R T 2 0 2 0                                                                      17

               Shareholding and
               Saratoga Structure

                                     Public                                         Edwin Soeryadjaya

                                                                                                    50,00%                            PT Unitras Pertama

                                                                                                                                               32,72%

                                                                                                    33,10%

                                       12,67%*

                           Natural                                                                                       Infrastructure
                          Resources

                                                                                          SHIPPING                             TELECOMMUNICATION

          MINING                        PLANTATION
                                                                                               Seroja Investment                   Tower Bersama

                 ADRO                                                                              23,26%                             34,23%
                                                    AMARA

                15,18%                                25%

                 MDKA                                PALM
                                                                                                               POWERPLANT                          CONSTRUCTION
                19,13%                              44,87%

                 Sihayo
                                                                                                                   TLG                               NRC
                10,27%
                                                                                                               46,25%                                7,12%
                  HEB

                  50%

            Interra Resources

                12,11%
PT S ARATOGA I NVESTAM A SE D AYA T B K .   | S U S TA I N A B I L I T Y R E P O R T 2 0 2 0                                                                                   18

                                                                                               The Company’s effective shareholdings both directly and indirectly.
                                                                                               *) The Company’s treasury stock was 0.7% of total shares due to buyback as of
                                                                                               December 31, 2020.

                                                                                               ADRO:                               PT Adaro Energy Tbk.

                                                                                               AGII:                               PT Aneka Gas Industri Tbk.

                                                                                               AMARA:                              PT Agro Maju Raya

                                                                                               BHA:                                PT Bumi Hijau Asri

                                                                                               DELTOMED:                           PT Deltomed Laboratories
                 Sandiaga S. Uno                                                               FABS:                               PT Famon Awal Bros Sedaya

                                                                                               HEB:                                PT Hijau Energi Bersama

                                                                                               Interra Resources:                  Interra Resources Limited

                                                                                               MBL:                                PT Mulia Bosco Logistik

                                                                                               MDKA:                               PT Merdeka Copper Gold Tbk.

                                                                                               MOMENTA:                            PT Momenta Agrikultura
                                                                                               MPM:                                PT Provident Agro Tbk.

                                                                                               NRC:                                PT Nusa Raya Cipta Tbk.
                          21,51%                                                               PALM:                               PT Provident Agro Tbk.

                                                                                               Seroja:                             Seroja Investment Limited

                                                                                               Sihayo:                             Sihayo Gold Limited

                                                                                               TLG:                                PT Tenaga Listrik Gorontalo

                                                                                               TBIG:                               PT Tower Bersama Infrastructure Tbk.

                                                                                 Consumer

                  CONSUMER                             LOGISTICS                                  PROPERTY & RENT                       HEALTH SERVICES
                  PRODUCTS

                                                                     MBL                                    BHA                                   FABS
                           MPM
                                                                    23,73%                                 100%                                   3,06%
                          52,21%

                           AGII

                          8,39%

                         Deltomed

                          5,83%

                         Momenta

                          27,5%
PT S ARATOGA I NVESTAM A SE D AYA T B K .    | S U S TA I N A B I L I T Y R E P O R T 2 0 2 0                                                                                 19

               Company Scale
               [GR I 10 2 -7]

                                                                       2018                     2019                     2020

                Total Employees                                              57                    58                        59

                Total Revenue                                          (6.105)                   8.241                    9.187
                (in IDR Billion)

                Total Capitalization                                   10.309                    9.821                    9.305
                (in IDR Billion)

                Liability                                                4.151                   3.883                    3.652
                (in IDR Billion)

                Equity                                                 15.655                   22.725                   31.378
                (in IDR Billion)

                Total Assets                                           20.115                   26.657                   35.049
                (in IDR Billion)

                Net Profit (Loss)                                      (6.195)                   7.371                    8.825
                (in IDR Billion)

               Next year, there will be many big challenges in the                                 We continue to actively seek out target companies
               global economy. Public health emergencies such as                                   that are on the growth path of Indonesian economy.
               Covid-19, which is still not ended since it was started                             It is our job to stay at the forefront, identify sector
               from March 2020, uncertainty from the formulation                                   winners and help them to continue growing.
               of trade and investment policies, all of which have
               affected investor confidence, global supply chains                                  We participate in several initiatives related to
               and also performance of the stock market this year.                                 economic,          environmental             and    social    aspects.
                                                                                                   In    addition,         we      also      support    the     initiatives
               We believe, whenever there are challenges, there                                    carried         out       by        our      investee      companies.
               are opportunities. Therefore, we are optimistic                                     We       also      join        an    association,       namely      the
               about            the    long-term        economic                prospects.         Indonesian Listed Companies Association (AEI).
                                                                                                    [GR I 102-11] [GR I 102-12] [GR I 102-13]
               Indonesian             economy      foundation               will       remain
               strong and be able to overcome existing obstacles
               with resilience. We will continue to actively
               invest by assessing the opportunities that exist.
PT S ARATOGA I NVESTAM A SE D AYA T B K .              | S U S TA I N A B I L I T Y R E P O R T 2 0 2 0                                                                   20

                                                                                                               TECHNICAL STANDARD REPORTING
                           Reporting                                                                           Saratoga’s 2020 Sustainability Report is prepared in
                                                                                                               accordance with GRI Standard: “Core Choices”. In this
                           Profile                                                                             report, there is no restatement and to make it easier
                                                                                                               for stakeholders to find the disclosure standards that
                                                                                                               are applied. We present GRI Standard disclosures
                                                                                                               in special color fonts on every relevant page.
                                                                                                               This is expected to make it easier for readers to
                                                                                                               find related information for each disclosure. In this
               The 2020 Sustainability Report is our first Report.                                             report, the GRI Index is included at the end of the
               This is the first time we make Sustainability                                                   discussion page for the relevant topic. Overall
               Report to demonstrate our commitment and                                                        GRI Standard Index can be found on page 56.
                                                                                                               [GR I 102-54] [GR I 102-55]
               responsibility            in       upholding               transparency                and
               accountability              for     all         Saratoga              stakeholders.             We publish this Report in two languages, namely
                                                                                                               Indonesian and English. For financial data, we
               This report is our form of responsibility in                                                    use Rupiah nominations. Financial data disclosed
               strengthening cooperation both to the Government,                                               in this report is data that has been audited by
               public institutions, private sector, and public.                                                Public Accounting Firm for the purposes of the
                                                                                                               Company’s Annual Report. Quantitative data in
               In     the       future,           we       will       consistently              publish        this report is presented using the principle of
               Sustainability Report every year. We will publish                                               comparability, at least for two consecutive years.
               Sustainability            Report             through            the        company’s
               official web portal. In this report, we use the                                                 This report is prepared based on POJK No. 51/
               terms         “Saratoga”,                “Company”                  or       “Us”          to   POJK.03/2017 on the Implementation of Sustainable
               represent PT Saratoga Investama Sedaya Tbk.                                                     Finance for Financial Service Institutions, Issuers
               [G R I 1 0 2 -51 ] [GRI 102- 52]                                                                and Public Companies and based on GRI Standard
                                                                                                               which is officially effective as of July 1, 2018.
                                                                                                               [GR I 102-54]
               The report includes our data and information
               based on the scope for the reporting period                                                     GRI recommends the use of external assurance by
               January 1, 2020 to December 31, 2020, which                                                     an independent third party to ensure the quality and
               contains about our activities from economic,                                                    reliability of the information presented in this report.
               environmental and social aspects with performance                                               However, it is not a requirement to be “compliant”
               comparison of the previous one or two years.                                                    with the Code. Since this is our first Sustainability
               This report only discusses Saratoga’s performance.                                              Report, we have not guaranteed an independent third
               There are no restatements that improve the                                                      party. However, we guarantee that all information
               previous report and there are no significant                                                    disclosed in this report is true, accurate and factual.
                                                                                                               [GR I 102-56]
               changes compared to the previous report because
               this report is our first report, and in the future we
               will publish Sustainability Report every 1 year.
               [G R I 1 0 2 -45 ] [GRI 102- 48] [GRI 102- 49]
               [G R I 1 0 2 -50 ] [GRI 102- 51] [GRI 102- 52]
PT S ARATOGA I NVESTAM A SE D AYA T B K .   | S U S TA I N A B I L I T Y R E P O R T 2 0 2 0                                                          21

                                                                                               PRINCIPLES FOR DETERMINING
                                                                                               QUALITY OF THE REPORT

                                                                                               In preparing this report, we adhere to the six (6)
                                                                                               quality principles recommended by GRI, namely:

                                                                                               • Balance
                                                                                               The report presents positive and negative aspects
                                                                                               of company performance.

                                                                                               • Comparability
                                                                                               The report contains economic, environmental and
                                                                                               social performance in the reporting year, along with
                                                                                               previous years so that stakeholders can compare
                                                                                               the existing performance.

                                                                                               • Accuracy
                                                                                               Laporan disampaikan secara akurat dan terperinci
                                                                                               sehingga pemangku kepentingan bisa menilai
                                                                                               kinerja yang ada.

                                                                                               • Punctuality
                                                                                               The report are prepared regularly according
                                                                                               to the schedule set by the company.

               We hope that this report can be a source                                        • Clarity
               of information for stakeholders to find out                                     The report contains economic, environmental
               about the sustainability performance we carried                                 and social performance with clear and
               out in 2020. For two-way communication, we                                      easy-to-understand information disclosure.
               provide Feedback Form at the end of this
               report. With this form, we hope readers and                                     • Reliability
               users of this report can provide suggestions,                                   The report contains verifiable economic,
               feedback, opinions, etc. which are very useful for                              environmental, and social performance.
               improving the quality of reporting in the future.

               REPORTING STAGE AND PRINCIPLES

               Our Sustainability Report is an integral part of
               Saratoga’s Annual Report. In preparing this report,
               we considered the principles of stakeholder
               engagement, sustainability context, materiality,
               and completeness to serve as a reference in
               determining the content of the sustainability report.
PT S ARATOGA I NVESTAM A SE D AYA T B K .             | S U S TA I N A B I L I T Y R E P O R T 2 0 2 0                                                                 22

               Process of Determining Content of the Report
               [G R I 1 0 2 -46 ]

               Process of determining the content of Saratoga’s
               sustainability report is compiled based on results
               of internal discussions. There are four stages in
               the sustainability report. In general, these four
               stages were carried out during the reporting
               period and were included in our planning.
               Four stages of the report-making process are:

                   STAGE 1                                            STAGE 2                               STAGE 3                           STAGE 4

                   We identify sustainability                         The process                           The process of                    Assess material topics
                   topics that are relevant                           of prioritizing                       validation and                    that are appropriate
                   to the characteristics of                          sustainability topics                 approval of the                   to the context of
                   our business and their                             and issues that will                  disclosure of                     sustainability. This
                   impact on stakeholders.                            be reported through                   information presented             process is carried out
                   This identification                                internal discussions                  in accordance with                by taking into account
                   process is carried                                 and prioritizing each                 predetermined                     the suggestions from
                   out through internal                               aspect.                               material topics.                  stakeholders, both
                   discussions.                                                                                                               internal and external.

               Content Determination Flow
               of the Report

                       Topic                           Aspect                            Disclosure of Management Approach + Indicator

                                     Step 1                                                  Step 2                              Step 3
                                     Identification                                          Priority                            Validation

                                    Sustainability Context                                   Materiality                       Completeness

                                                                              Stakeholder Engagement

                                                                                           Step 4
                                                                                           Review

                                              Sustainability Context                                     Stakeholder Engagement
PT S ARATOGA I NVESTAM A SE D AYA T B K .                     | S U S TA I N A B I L I T Y R E P O R T 2 0 2 0                                                                                             23

                 DETERMINE MATERIALITY                                                                                  Material topic boundaries describe impact of the
                                                                                                                        influence of each material topic on stakeholders,
                 This sustainability report has been prepared as a                                                      both internal and external. The determination
                 form of our commitment in upholding the principles                                                     of material in this report is prepared based on
                 of                       sustainability    and      balanced             development.                  internal meetings.
                 Information in this report is the implementation and
                 impact of the Company’s economic, environmental                                                        Meanwhile, the determination of report content is
                 and social performance in 2020, and this report is                                                     based on the principles of stakeholder inclusiveness,
                 also the first sustainability report for us so that there                                              materiality, sustainability context and completeness.
                 is no reporting limit compared to the previous year.
                                                                                                                        Material topics in this report, as stated in the GRI
                 Through materiality analysis, we identify these                                                        standards, are topics that have been prioritized
                 topic                       choices       based    on        what         is     important             by      us    for         inclusion       in         the   report.      Impacts
                 to us and also to our stakeholders. Then we                                                            that are used to determine priorities include
                 assessed potential relevant topics that have                                                           economic,             environmental                  and   social    impacts.
                 been identified. From materiality analysis there
                 were 5 material topics and topic boundaries.                                                           The          report         contains             an        explanation        of
                 [GR I 10 2 -46 ] [GRI 102- 47] [GRI 103- 1]
                                                                                                                        the         impact         on        each        material        topic.     The
                                                                                                                        following          table        is    a       list    of   material       topics
                                                                                                                        based on the results of internal discussions.

                 Materiality
                 Matrix

                                                     LOW                        ME DIUM                              HIGH

                                                                                                                            1
                                                                                                                 5
                                                                                                                                       HIG H

                                                                                                                                2
                                                                                                                        4

                                                                                                                                3
              Influence on Stakeholders

                                                                                                                                       ME DIU M

                                                                                                                                                                  1    Economic Performance

                                                                                                                                                                  2    Anti Corruption

                                                                                                                                                                  3    Employee
                                                                                                                                       LO W

                                                                                                                                                                  4    Training and Education

                                                                                                                                                                  5    Community Empowerment

                                                       Influence on PT Saratoga Investama Sedaya Tbk.
PT S ARATOGA I NVESTAM A SE D AYA T B K .       | S U S TA I N A B I L I T Y R E P O R T 2 0 2 0                                                  24

               Material Topic Boundaries
               [G R I 1 0 3 -1] [GR I 102- 42] [GRI 102- 43] [GRI 102- 44] [GRI 102-46] [GR I 102-47]

                  No.      Material                 Why This                 Number                                Boundaries
                           Topic                    Topic is
                                                    Material
                                                                                                   Saratoga   Business   Government   Community
                                                                                                              Partner

                  1.       Economic                 Has significant          201-1
                           Performance              impact on
                                                    stakeholders

                  2.       Anti Corruption          Has significant          205-1
                                                    impact on
                                                    stakeholders

                  3.       Employee                 Has significant          401-1
                                                    impact on
                                                    stakeholders

                  4.       Training and             Has significant          404-2
                           Education                impact on
                                                    stakeholders

                  5.       Community                Has significant          413-1
                           Empowerment              impact on
                                                    stakeholders
PT S ARATOGA I NVESTAM A SE D AYA T B K .           | S U S TA I N A B I L I T Y R E P O R T 2 0 2 0                                                                                          25

               STAKEHOLDERS                                                                                       Stakeholder            involvement              is     carried       out
                                                                                                                  through          stakeholder             engagement           approach
               We         strives          to    involve        stakeholders                in         our        by gathering all the opinions and feedback
               operational                activities,     since         stakeholders                   are        needed           to    achieve           company         sustainability.
               important                 figures    to      us.        Relationship                with
               stakeholders is our focus on the Company where                                                     Basis for selecting stakeholders is based on
               then we emphasize the importance of the impact                                                     results of internal discussions on November 6,
               of sustainability program on stakeholders that                                                     2020. This discussion was conducted to identify
               have a direct effect on company implementation.                                                    material         topics      for        Sustainability       Reporting.
                                                                                                                  We         identify              stakeholders          based          on
               To that end, we identify stakeholder groups                                                        their      level       of        influence       and       interaction.
               in       all         of     our     operations                which           include              [GR I 102-42]

               shareholders,                    employees,              non-governmental                          By knowing stakeholders, we understand their
               organizations, partners and government agencies.                                                   interests        and      are      committed          to     facilitating
               [G R I 1 0 2 -42 ]
                                                                                                                  each stakeholder in expressing their opinions
                                                                                                                  and      thoughts           in     an     effective,       transparent,
                                                                                                                  timely          manner,          and      taking      into       account
                                                                                                                  stakeholders           opinions          in     making       decisions.

                                                                                                                  The      following          table        represents        our    efforts
                                                                                                                  in       our           approach               with       stakeholders.
               Table of Stakeholder
               Engagement
               [G R I 1 0 2 -40 ] [GRI 102- 42] [GRI 102- 43] [GRI 102- 44]

                Stakeholder              Engagement                   Frequency                              Key Topics Proposed                      Stakeholder
                                         Method                                                                                                       Expectations

               Stakeholder                GMS                         • Annual GMS                           • Discussion on budget/                  • The Company has excellent
                                                                        in one year.                           financial accountability report,         performance and sustainability
                                                                        Extraordinary GMS                      appointment and dismissal of             so that is able to make positive
                                                                        when needed                            the Board of Directors and               contribution to all stakeholders
                                                                                                               the Board of Commissioners

                                                                      • Public Expose                        • Once a year                            • Performance Update

               Employee                   Regular meeting             When needed                            Employment / welfare                     Get comfortable work environment,
                                                                                                                                                      provide adequate employee benefits
                                                                                                                                                      and provide opportunities for growth

               Government                 • Policy maker/             When needed                            • Contribution to the State              The Company is able to achieve
               and Policy                   regulator                                                        • Compliance                             a predetermined work plan
               Makers                     • Regular reporting                                                  with applicable laws
                                            to regulators and
                                            government

               Work                       • Employment                When needed                            Commercial relationship                  • Objective procurement process
               Partners                     contract                                                                                                  • To obtain mutually
                                          • Investment                                                                                                  beneficial cooperation
                                            Partners
                                          • Other Companies
                                          • Banking
                                            Association

               Media                      • Press Release             When needed                            Program Implementation                   • Trusted sources of news
                                          • Media Visit                                                                                               • Accurate reporting
                                          • Press Gathering
                                          • Press Conference
PT S ARATOGA I NVESTAM A SE D AYA T B K .   | S U S TA I N A B I L I T Y R E P O R T 2 0 2 0                                                       26

               Advice and                                                                      Input from external parties to this report is our
                                                                                               commitment to improve our sustainability report.
               Response                                                                        For questions, input and comments on this report
                                                                                               can be sent to:   [GR I 102-53]

                                                                                               CORPORATE SECRETARY
                                                                                               PT Saratoga Investama Sedaya, Tbk.
                                                                                               Menara Karya 15th Floor
                                                                                               Jl. H.R. Rasuna Said Block X-5 Kav 1-2,
                                                                                               South Jakarta 12950

                                                                                               Phone :
                                                                                               +62 21 5794 4355

                                                                                               Fax :
                                                                                               +62 21 5794 4355

                                                                                               Website :
                                                                                               www.saratoga-investama.com

                                                                                               Email :
                                                                                               investor.relations@saratoga-investama.com
                                                                                               corporate.secretary@saratoga-investama.com
Sustainable
   Economic
Performance
PT S ARATOGA I NVESTAM A SE D AYA T B K .             | S U S TA I N A B I L I T Y R E P O R T 2 0 2 0                                                                          28

                              Corporate
                              Governance

               Good                Corporate                    Governance                       (GCG)        CORPORATE GOVERNANCE FRAMEWORK
                                                                                                              [GR I 102-18]
               and            integrity         are         essential              in        bringing
               the                company                 towards                   sustainability.           Saratoga’s        Corporate     Governance      Framework
                                                                                                              present check and balance system between
               We are committed to continue prioritize the                                                    the authority of shareholders, the Board of
               principles               of      Corporate               Governance                   that     Directors and management with the aim to
               are in line with the company’s values in the                                                   protect         Saratoga’s    interests   and       those   of
               implementation of all operational activities. We                                               shareholders and to create sustainable value.
               always ensure that the principles of corporate
               governance are well implemented in all aspects                                                 We strive to continue to improve management
               of the business and at all levels of the Company.                                              services        effectively    and    efficiently     to    all
                                                                                                              stakeholders in a number of strategic steps.
               Five GCG principles consists of Transparency,
               Accountability,                  Responsibility,                  Independence                 at Saratoga, the implementation of GCG aims to:
               as      well        as        Fairness       and         Equality           have          an   i. Enforce Company policies from Management
               important            role        for     us       in      realizing           business             to all levels.
               sustainability by taking into account the interests                                            ii. Regulate and control all company activities
               of       all       stakeholders,             especially              shareholders.                through the implementation of formal and clear
               [G R I 1 0 3 -1]
                                                                                                                  rules and mechanisms.
                                                                                                              iii. Always improve accountability
               The Board of Directors of the Company are                                                          of the company’s management to shareholders.
               responsible              for     sustainable               issues,         in      every       iv. Create good communication between
               process that occurs at Saratoga, we always ensure                                                  the Company and all shareholders, and
               that        sustainability             principles            are         considered,           v. Ensure Company compliance with applicable
               including when making investment decisions.                                                       laws and regulations, including and especially
                                                                                                                 those related to regulations and guidelines
                                                                                                                 issued by the Financial Services Authority (OJK),
                                                                                                                 as well as the Indonesia Stock Exchange (IDX).
PT S ARATOGA I NVESTAM A SE D AYA T B K .         | S U S TA I N A B I L I T Y R E P O R T 2 0 2 0                                                                          29

                                                       GE N E R AL ME E TI N G OF SHA R EHOLDER S

                Board of Commissioners                                                                 Board of Directors              President Director

     Audit Committee                          Nomination &                                             Investment             Portfolio                  Investment Director
                                              Remuneration                                               Director             Director*
                                               Committee

                                                                     Investment Committee

                                                                                                                            Head of Legal                   Head of HR &
                                                                                                                             Division and                    GA Division
                                                                                                                              Corporate
                                                                                                                              Secretary
              * Directors who served resigned as Director of Portfolio on the AGMS on June 17, 2020

               AUDIT COMMITTEE                                                                              • Ensure that internal controls are developed

               Audit committee is in charge of assisting the                                                    and implemented efficiently and effectively.

               Board of Commissioners and the implementation                                                • Ensure risk management processes are

               of its supervisory function, especially related to                                               adequate and implemented effectively

               internal control system, financial reports and                                               • Ensure the Company’s compliance with

               external auditors. Audit Committee conducts its                                                  applicable laws and regulations, including

               duties based on Audit Committee charter that has                                                 regulations from relevant authorities.

               been approved by the Board of Commissioners
                                                                                                            CODE OF CONDUCT OF THE COMPANY
               and      published            on        the      Company’s                website.
                                                                                                            AND ITS SOCIALIZATION
                                                                                                            [GR I 102-16]
               SCOPE OF DUTIES AND
               RESPONSIBILITIES                                                                             The Company’s Code of Conduct is a guideline
                                                                                                            that      applies     to   all        company      employees
               Audit       Committee              is     tasked           with         providing
                                                                                                            including       the   Board      of    Directors    and   the
               professional            and        independent                  opinions               to
                                                                                                            Board of Commissioners. This is a guideline
               the     Board         of     Commissioners                   regarding                the
                                                                                                            for how to interact and relate to stakeholders.
               implementation                   of           supervisory                 function
               of      the        management                   of        the          Company.
                                                                                                            This Code of Conduct is made with the aim that
               Main responsibilities of the Audit Committee are:                                            the Company carries out its commitment to
               • Ensure the integrity of the Company’s financial                                            behave, have appropriate manner and to apply
                 reporting and the implementation of internal                                               sanctions for violations that occur in the Company.
                control system, and effectiveness and quality of
                audit process by internal and external auditors.
PT S ARATOGA I NVESTAM A SE D AYA T B K .   | S U S TA I N A B I L I T Y R E P O R T 2 0 2 0                                                                      30

                        Whistleblowing
                        System
               We      establish      an       official         mechanism                  that   Reports of violations of suspected violations
               facilitates    reporting         of       suspected               violations       will be made confidentially, consistent with the
               (whistleblowing) to report violations. Through                                     need for further investigation and the identity
               this system employees can report any case of                                       of the whistleblower will not be disclosed.
               violation, whether in the form of fraud or violation
               of the GCG guideline, Code of Conduct, the                                         All    reports        will   be    followed    up   by   the
               Company’s        Articles     of      Association,               prevailing        Company.         Internal     Audit     will   ensure    that
               laws and regulations, confidential information,                                    investigations are carried out as quickly and
               and other violations to the Internal Audit unit.                                   sensitively      as     possible   without     compromising
                                                                                                  the quality and depth of the investigations.
                                                                                                  [GR I 205-1]
               This system was created in order to avoid conflicts
               or disputes between the parties involved and to
               find appropriate solutions to problems that arise.
PT S ARATOGA I NVESTAM A SE D AYA T B K .   | S U S TA I N A B I L I T Y R E P O R T 2 0 2 0                                                                 31

               Anti Corruption and
               Anti Fraud Policy
               As stated in the Company’s Code of Conduct,                                           3
               this policy covers the following matters:
                                                                                                    Gifts and entertainment
               [G R I 2 0 5 -1]
                                                                                                    Gifts and entertainment can promote goodwill
                                                                                                    in business relationship, however problems can
                1
                                                                                                    arise if this things become expected rewards
               Anti-bribery, embezzlement of funds
               and facility payments                                                                in a negotiation that could lead to a conflict of

               All of our employees, including their families,                                      interest in the company’s business relationship.

               are not allowed to give or accept bribes, facility
               payments, embezzlement or other forms for any                                        We set a limit on the value of gifts and entertainment
               reason. Giving, requesting, accepting bribery                                        that employees can receive, which is a maximum
               facilities directly or indirectly in any form by our                                 of USD 200 (Two Hundred Dolar US). Gifts and
               employees or their families cannot be accepted.                                      entertainment that exceed this value may not
                                                                                                    be accepted, except in circumstances where it
                                                                                                    is not possible for the employee to refuse the
                  2
                                                                                                    gift, the employee may accept the gift and then
               Anti money laundering                                                                hand it over to the Human Resources Division
               All of our employees, including their families,                                      to be used for the needs of the Company.
               are        prohibited   from        being          involved             in      or
               assisting in money laundering. Employees who
               are involved in these activities even if they are
               not intentionally subject to criminal and civil
               sanctions against themselves and the Company.
PT S ARATOGA I NVESTAM A SE D AYA T B K .   | S U S TA I N A B I L I T Y R E P O R T 2 0 2 0                                                32

                                                          Governance Principles

     As a public company, we are recommended to implement 5 aspects, 8 principles, and 25 recommendations
     related to the implementation of aspects and principles of Corporate Governance as regulated by the Financial
     Services Authority through Circular Letter No. 32/SEOJK.04/2015 on Governance Guidelines for Public Companies
     dated November 17, 2015. Based on the principle of compliance or clarity, public companies are required to
     provide alternative explanations and implementation if the recommendations have not been implemented.

     Recommendation                                                                              Description
                                                                                                 (have or have not complied)

      1   Public Companies have voting procedures, either for open voting or close voting,       Complied
          which focusing on independency and the interest of the shareholders

      2   All members of the Board of Directors and the Board of Commissioners                   Complied
          of the public companies are present in the Annual General Meeting of Shareholders

      3   Summary of the minutes of the General Meeting of Shareholders are available on         Complied
          the website of the public companies for at least 1 (one) year

      4   The public companies have a communication policy                                       Complied
          with the shareholders or investors

      5   The public companies disclose such communication policy with the shareholders          Complied
          or investors on the website

      6   Determination on the number of the member of the Board of Commissioners considering    Complied
          the condition of the public companies

      7   Determination on the composition of the member of the Board of Commissioners           Complied
          based on the variety of required skill, knowledge, and experience

      8   The Board of Commissioners shall have self-assessment policy to assess                 Complied
          the performance of the Board of Commissioners

      9   Such self-assessment policy to assess the performance of the Board of Commissioners    Complied
          shall be disclosed in the Annual Report of the public companies

      10 The Board of Commissioners has a policy with regards to the resignation of the member   Explain. We have already had BOD
         of the Board of Commissioners if being involved in financial crime                      Charter, Code of Conduct, Corporate
                                                                                                 Governance Code and Company
                                                                                                 Regulation, however, specific provisions
                                                                                                 on this matter is still being prepared.

      11 The Board of Commissioners or the Nomination and Remuneration Committee prepares        Complied
         succession policy for nomination process of a member of the Board of Directors

      12 Determination on the number of the member of the Board of Directors considering the     Complied
         condition of the public companies and effectivity in making a decision

      13 Determination on the composition of the member of the Board of Directors                Complied
         based on the variety of required skill, knowledge, and experience

      14 The Director supervises the accounting or financial division shall has the skill        Complied
         and/or knowledge in accounting sector
PT S ARATOGA I NVESTAM A SE D AYA T B K .   | S U S TA I N A B I L I T Y R E P O R T 2 0 2 0                                                 33

     Recommendation                                                                                        Description
                                                                                                           (have or have not complied)

     15   The Board of Directors shall have self-assessment policy to assess the performance
                                                                                                           Complied
          of the Board of Directors

     16   Such self-assessment policy to assess the performance of the Board of Directors shall be
                                                                                                           Complied
          disclosed in the Annual Report of the public companies

     17   The Board of Directors has a policy with regards to the resignation of the member of
                                                                                                           Complied
          the Board of Directors if being involved in financial crime

     18   The public companies have a policy to avoid insider trading                                      Complied

     19   The public companies have anti-corruption and anti-fraud policy                                  Complied

     20   The public companies have a policy on selecting and improving the performance
                                                                                                           Explain
                                                                                                           Not relevant with the Company’s
          of its supplier or vendor
                                                                                                           business activities

     21   The public companies have a policy with regards to the compliance of the creditors’ rights       Complied

     22   The public companies have whistleblowing system policy                                           Complied

     23   The public companies have a policy on granting long term incentives to the Board of Directors
                                                                                                           Complied
          and the employees

     24   The public companies utilize the information technology more broadly other than the website as
                                                                                                           Complied
          the media for disclosure of information

     25   The Annual Report of the public companies disclose the ultimate beneficial owner in the
          shareholding of the public companies at least 5% (five percent), other than the disclosure
                                                                                                           Complied
          of the ultimate beneficial owner in the shareholding of the public companies through
          the main shareholder and the controller
PT S ARATOGA I NVESTAM A SE D AYA T B K .      | S U S TA I N A B I L I T Y R E P O R T 2 0 2 0                                                                               34

                             Sustainable
                             Economy

               When the Covid-19 Pandemic hit Indonesia in                                        main commodities are gold and copper. MDKA is
               2020, it cannot be denied that it was a year full                                  not significantly affected by the pandemic, with
               of tests. But in the midst of that, we continue to                                 successful preventive measures, MDKA imposes
               improve operational performance effectively and                                    strict quarantine for staff who fly to the site,
               efficiently. This can be seen in Saratoga’s economic                               stright           testing        and         carrying                 out
               value gain in 2020, which is IDR 775 million.                                      extensive              tracking             and                tracing.
               [G R I 1 0 3 -1]

               One of our strategies is to diversify our investments,                             This      year     MDKA       also    signed        memorandum
               hence              when   the   pandemic              occured,            having   of understanding (MOU) with Eternal Tsingshan
               a diverse portfolio is very helpful for our finances.                              Group         Limited         (Tsingshan)           to         develop
               Therefore, Saratoga’s portfolio business in 2020                                   an               acid-ferrous           metal                  project
               remains strong. As an example, one of our                                          (AIM)        to       unlock         the       added             value
               investee companies, PT. Merdeka Copper Gold                                        of      Wetar         Copper         ore.    AIM           provides
               Tbk (MDKA), has experienced a significant increase                                 significant        increase     potential      because           it    is
               in commodity prices throughout 2020. Their                                         estimated to have a long project life and an
                                                                                                  attractive rate of return which is expected to
                                                                                                  reach      commercial         production       in        two     years.

                                                                                                  Apart from MDKA, our other investee is PT. Mulia
                                                                                                  Bosco Logistik (MBL). During this year, MBL
                                                                                                  saw an increase in shipments of pharmaceutical
                                                                                                  products, agricultural commodities and consumer
                                                                                                  goods. In addition, demand for frozen food and
                                                                                                  beverage as well as domestic franchises also
                                                                                                  grew significantly. This, in turn, boosted the
                                                                                                  positive growth of the national cold chain industry.

                                                                                                  These conditions provide wider opportunities
                                                                                                  for MBL to improve its performance in line with
                                                                                                  investment support from Saratoga to increase
                                                                                                  MBL liquidity and upgrade cold storage facilities.
PT S ARATOGA I NVESTAM A SE D AYA T B K .       | S U S TA I N A B I L I T Y R E P O R T 2 0 2 0                                    35

               Our cost leadership strategy                                     ECONOMIC
               has had a profound impact                                        VALUE GAIN
                                                                                IDR in Billion
               on our financial condition,
               and       has       helped       investee
               companies                  to    emerge
                                                                                                                        Total
               during pandemic. Following                                                                     2018      Economic
                                                                                                                        Value
               are      the       economic        values
                                                                                                                        Obtained
               generated and distributed by
               Saratoga throughout 2020:                                                                                1.161.808
               [G R I 2 0 1 -1] [GR I 102- 7]
                                                                                    1.146.608                 15.200

                                                                                                              2019      Total
                                                                                                                        Economic
                                                                                                                        Value
                                                                                                                        Obtained

                                                                                    2.015.037                   6.641
                                                                                                                        2.021.678

                                                                                                              2020      Total
                                                                                                                        Economic
                                                                                                                        Value
                                                                                                                        Obtained

                                                                                                                        775.587
                                                                                    767.972                   7.615

                                                                                Business           Other
                                                                                Revenue            Revenue/
                                                                                                   Expense
PT S ARATOGA I NVESTAM A SE D AYA T B K .            | S U S TA I N A B I L I T Y R E P O R T 2 0 2 0                                                                          36

                   ECONOMIC VALUE
                   DISTRIBUTION
                   IDR in Billion

                                                   2018                                       2019                                  2020

                                                   72.071                                    60.635                                77.801
                 Operational
                      Costs

                   Employee                        66.316                                    96.379                               104.426
                 Salaries and
                     Benefits

                                               138.387                                   157.014                               182.227
                       Total
                       Operational
                       Payments and
                       Employee
                       Salaries

                                                       2018                                2019                       2020
                                                                                                                                             Contribution to
                                                                                                                                             State Income
                              Dividends                200.759                             298.198                    148.976
                                                                                                                                             through Taxes

                                                                                                                                             Saratoga     is    committed
                     Expenses for the                  214.675                             135.909                    66.926                 to    comply       with     the
                        Government
                                                                                                                                             law    and    fulfilling    the
                    (taxes, royalties, etc.)
                                                                                                                                             responsibility to pay taxes.
                                                                                                                                             Every year, we always
                                                                                                                                             fulfill this commitment. In
                     Expenses for the                  1.126                               217                        10.214
                          community                                                                                                          2020, Saratoga continued
                                                                                                                                             to    contribute    by     paid
                                                                                                                                             taxes on time. In 2020
                                                                                                                                             we were not involved in

               Total Economic Value                                                                                                          any legal or tax matters.
                         Distributed
                                                       554.947                             591.338                    408.343

            Economic Value withheld                    606.861                             1.430.340                  367.244
            (difference in economic value
                acquired and distributed)

    note:       • The Company’s economic performance is submitted on consolidated basis with audited financial reports.
                • The calculation of economic value presented in sustainability reporting uses the method recommended in the GRI Standard.
Social
Performance
PT S ARATOGA I NVESTAM A SE D AYA T B K .          | S U S TA I N A B I L I T Y R E P O R T 2 0 2 0                                                                                  38

                             Excellent
                             Human Resources

               Having             competent            Human             Resources                (HR)      To      ensure         an      effective,        sustainable      and
               is       one        of        the       keys         to        develop                 the   integrated HR Management system, we have
               Company                  in         a         sustainable                   manner.          implemented             a     number        of    integrated      HR
                                                                                                            development              and        management              programs.
                                                                                                            [GR I 103-1]
               Throughout Saratoga’s history, we have always been
               committed to continue to support employees in                                                We      have         made     optimal       efforts    to    manage
               their work as well as make innovation to overcome                                            human          resources       by    refining      Saratoga’s     HR
               challenges of the times by creating safe and                                                 Policies and Procedures. In addition, anticipation
               comfortable work environment. This is done to                                                of business development is also carried out
               help employees develop themselves and their                                                  by planning HR needs, both in terms of the
               careers in line with our business sustainability.                                            number (people quantity) of labor and quality
               [G R I 1 0 3 -1]
                                                                                                            (people quality) required for the next five years.
               We always strive to achieve sustainability through
               business development in various fields. We realize                                           We also regulate policies related to matters
               that these goals will be difficult to achieve without                                        such           as     business       conduct,          organization,
               the support of competent Human Resources.                                                    recruitment             and         selection,         performance
                                                                                                            appraisal           system,    training     and       development,
               As concrete step, we have compiled a program to                                              employee               compensation              and         benefits.
               improve the quality of reliable human resources in
               line with the strategy of Company Development. We                                            In     recruiting           new     employees,         we      always
               believe that the management of Human Resources                                               open           opportunities        for      everyone         without
               who have high work ethic, are committed, consistent                                          discrimination on the basis of race, color, gender,
               and motivated will give the best results that will                                           religion, political opinion or ancestry. In the
               impact the progress of Saratoga and Indonesia.                                               reporting year, we did not have any incidents
                                                                                                            of discrimination both internally and externally.
                                                                                                            [GR I 406-1]
PT S ARATOGA I NVESTAM A SE D AYA T B K .      | S U S TA I N A B I L I T Y R E P O R T 2 0 2 0                                                              39

                        Saratoga’s
                        Employees Profile
                        [G R I 1 02- 8]

                COMPOSITION OF EMPLOYEES
                BY GENDER

                           49,12%                                                          50%                                       49,15%
                           28 people                                                       29 people                                 29 people

                                2018                                                              2019                                   2020

                                          50,88%                                                         50%                                     50,85%
                                          29 people                                                      29 people                               30 people

                     Male                    Female

                COMPOSITION OF EMPLOYEES                                                                       COMPOSITION OF EMPLOYEES
                BY ORGANIZATIONAL LEVEL                                                                        BY STATUS

                               3                       23    31                                                            5                       52

               2018                                                                                           2018
               57 people                                                                                      57 people

                               4                      22      32                                                           4                         54

               2019                                                                                           2019
               58 people                                                                                      58 people

                               3                      22          34                                                       4                            55

               2020                                                                                           2020
               59 people                                                                                      59 people

                     Director               Manager &                    Staff &                                     Non Permanent     Permanent
                                            Supervisor                   Non Staff                                   Employees         Employees
PT S ARATOGA I NVESTAM A SE D AYA T B K .   | S U S TA I N A B I L I T Y R E P O R T 2 0 2 0                                                               40

                COMPOSITION OF EMPLOYEES                                                       COMPOSITION OF
                BY LEVEL OF EDUCATION                                                          EMPLOYEES BY AGE

                        19,30%                                                                         12,28%                                 21,05%
                        11 people                                                                      7 people                               12 people

                                                2018                                                                       2018

             8,77%
             5 people

                                                                      71,93%                                                                29,82%
                                                                                                     36,84%
                                                                              41 people                                                     17 people

                                                                                                     21 people

                          17,24%
                                                                                                       13,79%
                                                                                                                                               18,97%
                          10 people
                                                                                                       8 people
                                                                                                                                               11 people

                                                2019                                                                       2019
             8,62%
             5 people

                                                                      74,14%                                                                29,31%
                                                                                                     37,93%
                                                                                                                                            17 people
                                                                              43 people
                                                                                                     22 people

                          16,95%                                                                            8,47%
                                                                                                                                               25,42%
                          10 people                                                                         5 people

                                                                                                                                               15 people

                                                2020
                                                2019                                                                       2020
             8,47%
             5 people

                                                                      74,58%                                                                23,73%
                                                                                                     42,37%
                                                                                                                                            14 people
                                                                              44 people
                                                                                                     25 people

              Level of Education                                                               Age

                     Undergraduate             Diploma                   Others                      > 50              41 - 50    31 - 40
PT S ARATOGA I NVESTAM A SE D AYA T B K .    | S U S TA I N A B I L I T Y R E P O R T 2 0 2 0                                                        41

                NEW EMPLOYEES COMPOSITION
                BASED ON GENDER

                                            2018                                      2019                        2020

                      Male        4 people                                1 people                     1 people

                    Female        3 people                                1 people                     1 people

               Remuneration
               Remuneration is one of the steps we take to                                      In 2020, we distributed total remuneration of
               create competent Human Resources with quality                                    Rp101,864,885,000 to all employees. This is a form
               culture and work ethic. In practice, we implement                                of our appreciation to employees who have given
               a remuneration scheme adhering to the principles                                 the best performance to the Company. Saratoga
               of internal fairness and external competitiveness.                               is also committed to provide remuneration in
                                                                                                accordance with applicable government regulations.
               In addition to increase productivity, our remuneration
               scheme will help each individual to obtain the                                   Remuneration and bonuses are determined based
               same rights in providing compensation and wages.                                 on an annual performance assessment of each
                                                                                                employee.
PT S ARATOGA I NVESTAM A SE D AYA T B K .       | S U S TA I N A B I L I T Y R E P O R T 2 0 2 0                               42

               Saratoga Employee Remuneration in 2020
               [G R I 4 0 1 -2]

                 No.         Employee Remuneration                                                 Permanent   Non-Permanent
                             and Benefits [GRI 401- 2]                                              Employee        Employee

                 1.          Basic Salary

                 2.          THR

                 3.          Transportation Allowance

                 4.          Leave Allowance

                 5.          Service Period Appreciation

                 6.          Production Service

                 7.          Medical Benefits (BPJS Kesehatan)

                 8.          BPJS Tenaga Kerja

                 9.          Meal Allowance

                 10.         Position Allowance

                 11.         Grief Compensation for Employees Family

                 12.         Shift Allowance

                 13.         Attendance Incentives

                 14.         Telecommunication Allowance

                 15.         Pregnancy Allowance

                 16.         Marriage Allowance

                 17.         Umrah/Hajj Bonus

                 18.         Corporate Clinic

                 19.         Annual Bonus

                 20.         Housing

                 21.         Recreation

                 22.         Reimbursement Allowance

                 23.         Family Allowance

                 24.         Educational Assistance
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