About Us

PT Aberdeen Standard Investments Indonesia (PT ASII) is registered as an investment manager license holder with Otoritas Jasa Keuangan (OJK). In the course of its daily business, PT ASII and its employees must comply with the provisions of Company Law, Capital Market Law, Labour Law, OJK regulations as well as other applicable rules and regulations.

Compliance Unit is responsible for ensuring that PT ASII maintains adequate and effective compliance arrangements. These cover all regulatory requirements applicable to the financial affairs of PT ASII and to its conduct of business.

Compliance Unit regularly reviews all compliance arrangements to ensure that they are efficient and effective.

The review process includes a rigorous compliance vetting and monitoring programme which:

1. determines whether existing procedures and controls are sufficient to achieve compliance;
2. tests the robustness of existing procedures and controls.

Where weaknesses are found to exist, Compliance Unit recommends improvements and works with employees on the implementation of the new procedures. Areas which are perceived as causing potential regulatory problems or which raise particular concerns receive on-going and regular attention.

Compliance Unit is required to be involved at an early stage in all matters, which have regulatory implications. This ensures that employees receive considered guidance and prevents a breach of the regulations occurring. 

Where it is necessary for the performance of their duties, Compliance requires unrestricted access to all parts of PT ASII’s business and to all records, documents and meetings.

Compliance Reporting Structure

Compliance Unit is established as part of PT ASII structure and directly responsible to the Board of Directors. In order to ensure that business activities carried out by PT ASII comply with applicable rules and regulations, Compliance Unit as an independent unit, has unlimited access towards other business units and free from undue influence from other business units.

The Board of Directors is responsible for overseeing activities carried out by the Compliance Unit including giving approval for compliance policy and following-up identification of matters in relation to compliance requiring consideration from the Board of Directors. Any significant compliance issues are discussed in the Board of Directors meeting.

The Board of Commissioners exercises active supervision in effectiveness of implementation of compliance function including compliance policy; ensuring that the Board of Directors has followed-up identification of any matters in relation to compliance requiring consideration from the Board of Directors; evaluating and ensuring that compliance function has carried out its duties in accordance with the submitted annual work plan as well as evaluating and giving corrective recommendation for implementation of compliance function and policy.

PT Aberdeen Standard Investments Indonesia effectively implements risk management with reference to the Otoritas Jasa Keuangan regulations and Aberdeen Standard Investments policies.

Pursuant to Otoritas Jasa Keuangan regulation number 24/POJK.04/2014 concerning Guidelines of Investment Manager Functions Implementation, Risk management is a series of procedures and methodology used to identify, measure, monitor, and control risks resulting from an Investment Manager’s business activity.

Policy

Identification and Management of Risks.

A risk management framework is maintained that:

• Sets out a register of the risks;
• States an appetite for each of these risks where applicable;
• Identifies where these risks apply, quantifying the likelihood of each risk crystallising and the impact this will have on the company, whether this be financial, regulatory, reputational, on customer or on staff;
• Identifies and evaluates the design effectiveness and performance of internal controls against the appraised risks;
• Ensures that appropriate internal controls are embedded within the business processes and form part of the company’s culture;
• Responds quickly to the evolving risks within the company and the external business environment;
• Includes procedures for reporting any control failings or weaknesses to the appropriate level of management together with the details of corrective action.

Risk Management Responsibility

The first line of defence in risk management is the consideration of risk in day to day business.  This is the responsibility of all staff, all of whom have responsibilities for the maintenance of an effective risk management framework. 

The second line of defence is the monitoring of risks. This is the responsibility of Legal Compliance and Risk division.

The third line of defence is the assessment of the effectiveness of internal control. This is the responsibility of the Internal Audit Department). The frequency of audit work in any particular area is based on a reasonable assessment of the risks. Internal Audit reports its findings to the Board of Commissioner via BOC meeting. The work of Internal Audit also covers the effectiveness of other risk monitoring functions within the Legal, Compliance, and Performance Departments.

Changes to the Risk Management Policies are proposed by the Head of Compliance and Risk Management, and submitted to Board of Directors for approval. The Policy is reviewed regularly (at least bi-annually).

Risk Management Reporting Structure

In order to minimize business risk, all organizational lines need to be responsible for the management risk in all activities of the Company.

The Board of Commissioners is responsible for:

1. Approving risk management policy including risk management strategy and framework;
2. Performing active supervision of effectiveness of implementation of risk management function including risk management policy;
3. Ensuring that the Board of Directors has followed-up identification of matters in relation to risk management requiring consideration from the Board of Directors; and
4. Evaluating and giving corrective recommendation for implementation of risk management function and policy.

The Board of Directors is responsible for:

1. Following-up identification of matters in relation to risk management requiring consideration from the Board of Directors;
2. Ensuring organization structure, infrastructure and sufficient resources to support risk management function; and
3. Enhancing Investment Manager risk management culture.

Risk management function has direct line report to the Board of Directors.

In accordance with OJK regulation on implementation of corporate governance in investment manager, the coordinator of Risk Management Unit is responsible for:

1. Formulating policy including strategy to support risk management culture, which is aligned with scope and complexity of business and capability of the Investment Manager;
2. Renewing the risk management strategy;
3. Regularly monitoring and reviewing the implementation of risk management strategy;
4. Identifying significant potential and risk having impact to success in achieving Investment Manager objective;
5. Formulating and performing anticipating actions or efforts to mitigate significant risks in accordance to risks management policy;
6. Identifying matters related to risk management requiring consideration from the Board of Directors and the Board of Commissioners; and
7. Ensuring development of human resources through training or education.

The purpose of Whistleblowing policy is to describe Aberdeen Standard Investments’s approach to Whistleblowing, the aim of which is to ensure that staff can feel comfortable in reporting any well-intentioned suspicion of wrongdoing and are protected when they do so.

PT Aberdeen Standard Investments Indonesia conducts its business with highest ethical standards and in compliance with all relevant laws and regulations, and believes that Whistleblowing is both an instrument of good corporate governance and a manifestation of an open culture within the Company.

PT Aberdeen Standard Investments Indonesia offers all staff the ability to report concerns without fear of reprisal. When a member of Staff suspects wrongdoing he/she should report their concerns to his/her line manager in the first instance. When staff does not feel comfortable doing this, they have the option to by-pass their direct management line and report their concern to a designated recipient or confidential Speak Up hotline that is managed independently by Safecall Limited.

Staff are protected when they make well intentioned reporting of suspicious. Victimisation, harassment, discrimination, bullying, or any other action to deter Staff from making a Whistleblowing report, or any other action taken by way of revenge for making a report, is regarded as gross misconduct.

However, maliciously motivated reporting is also considered an act of gross misconduct.

Safecall Limited provides an independent, confidential, reporting line where staff can raise their concerns and be assured that they will be fully addressed. Reporting is treated in complete confidence, and all reports are forwarded to a designated recipient to investigate.

The responsibility for reporting any known or suspected fraud or dishonesty, or instances of unethical or illegal behavior within the Company, rests with all staff and is a contractual responsibility of all staff. It is the policy of the Company to protect staff when they make well intentioned reporting of suspicious.

PT Aberdeen Standard Investments Indonesia:

• Encourages the reporting of wrongdoing through the proper channels and takes all reasonable steps to remove obstacles which may prevent staff from making a report relating to possible unacceptable practices at work;
• Provides annual Whistleblowing training for all staff and includes this training as part of their Compliance Induction Training for all new staff, with the aim of ensuring that all staff have an appropriate level of awareness for reporting suspected wrongdoing.

Standard of Conduct

Standard of Conduct aim to ensure that all employees do the right things by knowing what is expected of them, being accountable for their own actions and knowing how to respond if someone is behaving inappropriately. Failure to adhere to the code will be subject to disciplinary actions.

All employees are expected to uphold the following:

1. Act in a fair, ethical and professional with the public, clients, prospective clients and colleagues. Strictly no engagement in any dishonesty, fraud, deceit or action that reflects adversely on his/her professional integrity, reputation or competence;
2. Place clients’ interests and integrity of investment profession before any personal interest;
3. Use reasonable care and exercise prudent judgement to achieve independence and objectivity when carrying out any professional activities such as conducting investment analysis and making investment recommendations;

Understand and comply with all applicable laws, rules, and regulations of any government or regulatory body governing his/her professional activities.

Staff Personal Account Dealing

Article 5 of OJK rule No. 43/POJK.04/2015 concerning Code of Conduct for Investment Manager prescribes that Board of Commissioners members, Board of Directors members, Investment Committee members, Investment Management team members and employees of the Investment Management firm shall inform in writing no later than 2 (two) business days to the Investment Management firm prior to and after conducting selling or traling of securities which is executed:

• By the concerned party for his interest, nominee, and/or affiliated party who has ownership of securities directly or indirectly;
• By nominee or affiliated party who is the owner of such securities owernership directly or indirectly.

PT ASII requires all employees, as a condition of their employment, to obtain prior approval for, and to disclose, details of all their personal investment dealings and those of connected parties to Compliance in order that their dealing activities are monitored.

Prevention of Insider Trading and Tipping

In the course of PT ASII’s business, representatives of capital markets services license such as investment managers may come into possession of confidential information relating to client advice and securities transactions as well as other confidential information through meeting the management of companies, analysts or other avenues.

In addition, from time to time, PT ASII or its employees may come into possession of information that is “material” and “non-public” concerning a company or the trading market for its securities.

It is however not PT ASII’s policy to deal or trade customers’ accounts in these companies on basis of non-public and price sensitive information.

Privacy Policy

PT ASII aims to protect the privacy of every current, former and prospective client as far as possible. The Group Privacy Policy describes the type of personal information PT ASII may collect, the purposes for which the information is used, the circumstances in which the information may shared, and the steps taken to safeguard the information to protect a user’s privacy.

Sanctions

Upon discovering a violation of this Code of Ethics, PT ASII may impose such sanctions as PT ASII deems appropriate, including, among other things, verbal or written warnings and censures, monetary sanctions, disgorgement, suspensions or dismissal.

Our Investments Managers regularly meet with the management and directors of companies in which we actively invest, and we also seek to mirror this approach across our other investment strategies.

Aberdeen endeavors to exercise proxy votes at all shareholder meetings where authorized to do so by clients. At companies where we have an active investment, all voting decisions are led by our investment managers.

Internal Auditing (IA) is an independent and objective assurance and consulting activity that is guided by a philosophy of adding value to improve the operations of the organization and support the Board and Executive Management in protecting the assets, reputation and sustainability of the organization and its stakeholders.

IA supports PT Aberdeen Standard Investments Indonesia (The Company) in accomplishing its goals and objectives by bringing a professional and constructive approach to evaluate and improve the adequacy and effectiveness of the organization’s risk management, control and governance processes and culture including responses to risk across all activities of the organization.

Principles and Governance

IA is committed to a philosophy of working to the highest ethical and professional standards.

IA operates within the International Professional Practice Framework established by the Chartered Institute of Internal Auditors (CIIA). As such, IA will comply with all relevant CIIA Standards and the Code of Ethics, or disclose non-conformance (subject to appropriate proportionality). IA also will adhere to all relevant Standard Life Aberdeen policies and procedures and Group Audit Internal’s own Methodology.

Authority and Positioning

Internal Auditor will report functionally to the Board of Commissioners and administratively to the President Director.

Internal Auditor is appointed and dismissed by the President Director upon the approval of the Board of Commissioners.

Any appointment/dismissal of Internal Auditor shall be reported to the OJK.

Internal Auditor will not assume responsibility for any other function or for determining the policy of the Company.

IA will be objective and independent from operational functions and have no direct operational responsibility or authority over any of the activities audited.

IA staff will not audit any activity for which they had authority or responsibility within the past year.

IA staff must have an impartial, unbiased attitude and avoid any conflict of interest.

IA’s scope is unrestricted and they hold full, free and timely access to any and all functions, records, physical properties, and personnel pertinent to carrying out any engagement.

All employees are required to assist IA in fulfilling its roles and responsibilities through taking ownership of and providing a timely response to information requests, audit findings and actions.