Source file signed link, expires in 15 minutes
Extracted text 175
Page 1
Connecting Indonesia:
One Purpose - One Planet
Sustainability Report
2025
PT XLSMART Telecom Sejahtera Tbk
2025
Sustainability Report | PT XLSMART Telecom Sejahtera Tbk
Sustainability Report
2025
PT XLSMART Telecom Sejahtera Tbk
XLSMART Tower
Jl. HR Rasuna Said X5. Kav.11–12,
East Kuningan, Setiabudi, South Jakarta
Jakarta 12950, Indonesia
Tel. (62-21) 576 1881
Fax. (62-21) 576 1880
e-mail. corpsec@xlsmart.co.id
www.xlsmart.co.id
Page 2
PT XLSMART Telecom Sejahtera Tbk and/or in this report referred to as “XLSMART” or “the Company”, engages in the telecommunication services, discloses its achievements in economic, social, environmental, governance performance as well as sustainability management and strategies in this 2025 Sustainability Report. The Sustainability Report is part of the Annual Report which is published in a separate document. This report contains material data and information for stakeholders, including forward-looking statements containing future projections and conditons, except for the historical matters. The Company understands that risks and uncertainties from various factors can affect operational performance and future business conditions. The Company therefore cannot ensure that the data and information regarding future projections stated in this Report are correct, accurate, and can be entirely fulfilled. B PT XLSMART Telecom Sejahtera Tbk
Page 3
Connecting Indonesia:
One Purpose - One Planet
Connecting Indonesia:
One Purpose - One Planet
The merger between XL Axiata and Smartfren is more than a strategic
move. It combines complementary strengths, unites infrastructure, and
aligns a shared vision to create a stronger, more inclusive connectivity
landscape. This is a transformation that connects millions of Indonesians
to opportunities while advancing a future built on sustainability.
We manifest this shared aspiration through impactful initiatives that
strengthen our presence across the nation. Through integrated distribution
and stronger infrastructure, we keep our trusted brands alive while
accelerating innovation to expand access for all.
Our initiatives emphasize the transition to renewable energy, the
implementation of eco-friendly operations, and the empowerment of
communities through programs that advance digital literacy, foster
entrepreneurship, and build local capacity. These efforts are anchored in
strong governance that ensures every initiative is carried out with integrity
and accountability. Together, these endeavours enable technology to
create tangible impact where it matters most.
We believe connectivity is a bridge to opportunity and a foundation for
a better future. It enables people to grow, communities to prosper, and
the planet to be protected for generations to come. With this purpose
guiding us, XLSMART is shaping a digital future where every connection
contributes to a more inclusive and sustainable Indonesia, one where
people and the planet thrive together.
2025 Sustainability Report 1
Page 4
Table
of Contents
39 Sustainability Commitment of
XLSMART
40 XLSMART’S ESG Roadmap
Sustainability 41 Net Zero Carbon by 2050 Sustainability
Performance 41 Our Journey Towards Net Zero
Governance
Highlights 42 Initiatives for Sustainable Future
72 Committed to the Effective
Implementation of GCG Practices
6 Go Beyond Together 43 Strengthening the Culture of
75 Structure and Composition of
Sustainability
8 Sustainability Performance Sustainability Governance
45 Contributions to the Sustainable
16 2025 Awards and Certifications 78 The Roles of XLSMART’s
Development Goals (SDGs)
Governance Body in Impact
18 2025 Sustainability Event Management
Highlights
79 Performance Assessments of
Governance Body
81 Nomination and Selection of
Governance Body
82 Remuneration Policy and Process
About XLSMART 83 Sustainability Training and
Message from the 48 Corporate Information Competency Development
Program
Board of Directors 49 Significant Changes in the
Company 85 Risk Assessment of Sustainability
25 Message from the Board of Implementation
Directors
50 Purpose, Vission, and Core Values
86 Constraints, Challenges and
32 Statement of Accountability Opportunities in Sustainability
52 XLSMART at A Glance
Implementation
54 Our Transformation
87 Management of Conflict of
60 Organization Structure Interest
62 Group’s Structure 88 Anti-Bribery and Anti-Corruption
Policy
63 Subsidiaries, Associates, and
Framework for Joint Ventures 89 Stakeholder Relations
Accelerating the 64 Business Scale 90 Communication of Key Issues
Sustainability 64 Shareholder Composition 91 Whistleblowing System
Journey 65 Association Membership 92 The Implementation of Customer
36 Our Sustainability Strategy Privacy Policy
66 Operational Area
36 Materiality Assessment 92 Code of Conduct
68 Business Activities
37 List of Material Topics 93 Legal and Regulatory Compliance
2 PT XLSMART Telecom Sejahtera Tbk
Page 5
Connecting Indonesia:
One Purpose - One Planet
Environmental
Stewardship Stronger Ensuring
Performance Responsible and
96 Integrating Environmental
Stewardship into Our Operations from People Ethical Business
98 Energy Consumption Empowerment 152 Post-Merger Improvements to
Customer Experience
100 Reducing GHG Emission 121 Our Workforce
152 Customer Protection,
101 Waste Management 126 Employment Practices
Engagement and Satisfaction
103 Resources Use & Efficiency 128 Employee Wellbeing within an
156 Labelling and Marketing
Equal and Inclusive Entity
105 Technology to Preserve 157 Digital Responsibilities, Inclusion
Biodiversity 132 Occupational Health and Safety
and Rights
106 Future Environmental Priorities 137 Defined Benefits Program and
158 Integrating Sustainability into
Other Pension Plan Obligations
Innovations
107 Environmental Compliance
137 People Development Strategies
Going Forward
Solid Performance About This Report
to Empower the 162 About This Report
Shaping Inclusive
Nation 162 Reporting Principles
and Sustainable 163 Reporting Scope and Boundaries
110 Economic Performance
Digital Future 163 External Assurance
114 Market Presence Expansion and
Indirect Economic Impact 140 Delivering Impact on Society
163 Feedback from Stakeholders
114 Sustainable Supply Chain 147 Measuring Our Social Impact and
164 Feedback From
Value Creation
115 Financial Assistance from the
165 GRI Universal Standard Index -
Government
2021
116 Taxation Policy
171 POJK 51/2017 Index
2025 Sustainability Report 3
Page 6
Page 7
Sustainability Performance Highlights
Page 8
Sustainability
Performance Highlights
Highlight
Go Beyond Together
At XLSMART, value creation is measured not only
by performance, but by the legacy we build for the
future. As a digitally driven company committed
to accelerating sustainable innovation and carbon
neutrality, we believe that responsible growth creates
enduring value for people, communities, and the planet.
In 2025, XLSMART moves forward as a unified force
with a strengthened vision and renewed purpose.
Through it all, sustainability defines how we lead.
It shapes how we invest, how we innovate, and
how we perform. From strengthening governance
to accelerating digital inclusion and advancing
environmental responsibility, every step we take
reflects our commitment to long-term value creation.
We believe growth must go beyond numbers. It must
expand opportunities, protect the environment, and
earn trust through responsible leadership. This is how
our ambition manifests in measurable
progress throughout 2025.
6 PT XLSMART Telecom Sejahtera Tbk
Page 9
Connecting Indonesia:
One Purpose - One Planet
Sustainable Fitch has
assigned XLSMART
Entity Rating Entity Score
2 67
Designated XLSMART as a
"Social Pure Player"
in recognition of its overall social contribution.
This rating reflects a good sustainability profile, driven by the
environmentally and socially positive nature of fibre and 4G
network provision.
Sustainable Fitch noted that XLSMART’s business activities as
environmentally and socially positive due to energy-efficient
networks and wide connectivity that supports digital inclusion,
including under-served regions.
As published on Sustainable Fitch Website https://www.sustainablefitch.com/corporate-
finance/sustainable-fitch-assigns-xlsmart-entity-rating-of-2-03-03-2026
2025 Sustainability Report 7
Page 10
Sustainability
Sustainability
Performance Highlights
Sustainability Performance
All 2025 figures presented in this Sustainability Performance Highlights represent the performance of XLSMART
following the merger. Data from Smartfren are primarily consolidated from April to December 2025 after the
completion of the merger process, with limited data availability for the period prior to the merger.
Meanwhile, figures for 2024 and 2023 represent the performance of XL Axiata Legacy prior to the merger. Given the
change in reporting scope and consolidation period, certain figures may not be directly comparable with those of
previous years.
Economic Performance [B.1]
Production
Data Traffic
BTS Tower
(Data Production)
(Unit)
(Petabyte)
225,649 14,566
2024 165,864 2023 160,124 2024 10,547 2023 9,638
Sales
Total Revenue
(Rp Billion)
42,485
2024 34,392 2023 32,323
Net Profit/Loss Number of Customers
(Rp Billion) (Million)
(4,415) 73.00
2024 1,847,631 2023 1,284,448 2024 58.80 2023 57.52
8 PT XLSMART Telecom Sejahtera Tbk
Page 11
Connecting Indonesia:
One Purpose - One Planet
Eco-Friendly Products
Number of Local
Solar Panel
Workers
(Total)
(Person)
259 3,214
2024 252 2023 250 2024 1,648 2023 1,480
Number of Local Suppliers
Local Suppliers Contract Value
(Entity) (Rp Billion)
602 36,730.4
2024 484 2023 431 2024 15,068.4 2023 13,554.4
2025 Sustainability Report 9
Page 12
Sustainability
Performance Highlights
Environmental Performance [B.2]
Total Water Consumption
PDAM
(m3)
27,198.99
2024 7,497.46 2023 7,382.32
Non Renewable Energy Consumption
Fuel (Pertalite) Fuel (Pertalite)
(Liter) (Gigajoule)
312,322.00 10,376.00
2024 275,593.70 2023 228,001.34 2024 9,156.60 2023 7,797.65
Diesel Renewable Energy
(Liter) (kWh)
1,030,365.97 3,334,087.00
2024 1,189,149.24 2023 1,393,829.51 2024 1,000,000.00 2023 -
Diesel Renewable Energy
(Gigajoule) (Gigajoule)
37,216.82 12,002.71
2024 42,952.07 2023 47,668.97 2024 3,600.00 2023 -
10 PT XLSMART Telecom Sejahtera Tbk
Page 13
Connecting Indonesia:
One Purpose - One Planet
Electricity from PLN Electricity from PLN
(kWh) (Gigajoule)
1,282,346,871.00 4,616,448.74
2024 956,319,188.00 2023 902,853,187.65 2024 3,442,749.08 2023 3,250,271.48
Total Energy Energy Intensity
Consumption (Gigajoule/Petabyte)
(Gigajoule)
4,664,042.47 3,642.92
2024 3,498,457.75 2023 3,305,738. 74 2024 332 2023 290
Energy Intensity
(Gigajoule/Revenue
Rp Billion)
0.10
2024 0.10 2023 0.10
Emissions
Scope 1 Scope 2 Scope 3
(TonCO2eq) (TonCO2eq) (TonCO2eq)
3,476.89 988,304.73 477.17
2024 4,082.53 2024 744,398.86 2024 4,252.47
2023 4,255.54 2023 695,828.95 2023 5,743.82
Scope 1 Scope 2 Scope 3
(TonCO2eq/ (TonCO2eq/ (TonCO2eq/
Rp Billion) Rp Billion) Rp Billion)
0.86 23.28 0.01
2024 118.71 2024 21,644.54 2024 123.65
2023 131.66 2023 21,527.36 2023 177.70
2025 Sustainability Report 11
Page 14
Sustainability
Performance Highlights
Total Emissions
(TonCO2e)
992,258.79
2024 752,733.86 2023 705,828.32
Emission Intensity Environmental Cost
TonCO2eq/Petabyte (Rp Million)
4,217.68 560.36
2024 71.37 2023 61.90 2024 86.20 2023 20
Emission Intensity
(TonCO2eq/Rp Billion)
0.09
2024 0.00 2023 0.00
Waste
Disposable Recycled/Reused
(Ton) (Ton)
24.48 73.29
2024 20.01 2023 - 2024 86.20 2023 -
Digital Innovation for Sustainable Environment
PowerSense (Smart Energy)
IoT-enabled air conditioning control system for BTS shelter towers to improve energy efficiency.
Xinergis (Smart Building and Energy Monitoring)
IoT-enabled monitoring system for electricity, generator, and water consumption.
HydroponiX (Smart Agriculture)
IoT-enabled hydroponic systems that support sustainable urban farming.
X-Maggot (Smart Waste Management)
IoT-enabled organic waste processing using Black Soldier Fly larvae.
12 PT XLSMART Telecom Sejahtera Tbk
Page 15
Connecting Indonesia:
One Purpose - One Planet
Social Performance [B.3]
Number of Employees
(Person)
3,239
2024 1,663 2023 1,495
Number of Male Number of Female
Employees Employees
(Person) (Person)
2,307 932
2024 1,168 2023 1,047 2024 495 2023 448
Number of Female as Number of Local People
President Director and Occupying Senior Manager
Director Positions
(Person) (Person)
1 13
2024 2 2023 2 2024 8 2023 6
Number of Training
Number of Employees
Hours
Receiving Training
(Hours)
(Person)
145,893 3,222
2024 53,587 2023 59,156 2024 1,655 2023 1,502
Average Number of
Training Fees
Training Hours
(Rp Million)
(Hours/Person)
45 16,195,525.11
2024 36.63 2023 39.38 2024 7,449 2023 8,314
2025 Sustainability Report 13
Page 16
Sustainability
Performance Highlights
Employee Number of Work
Turnover Rate Accidents
(%) (Times)
0.65 5
2024 6.0 2023 11.1 2024 0 2023 3
Occupational death Total CSR Funds
(Times) (Rp Billion)
0 28.10
13
2024 0 2023 0 2024 35.62 2023 20.73
Number of Women Number of Beneficiaries
Empowered from Gerakan Donasi Kuota
(Person) (Person)
1,231,134 111,875
2024 1,059,479 2023 949,261 2024 66,397 2023 41,900
Router/Modem Quota Donation
Donation Amount Amount
(Unit) (Terabyte)
216 180,576
2024 214 2023 71 2024 251,520 2023 689,397
14 PT XLSMART Telecom Sejahtera Tbk
Page 17
Connecting Indonesia:
One Purpose - One Planet
Governance Performance [B.3]
1 Committed to the implementation of OJK’s Sustainable Finance framework in
accordance with POJK No. 51/POJK.03/2017 and SEOJK No. 16/SEOJK.04/2021,
ensuring structured sustainability reporting and alignment with Indonesia’s
sustainable finance roadmap.
2 Conducting Anti-Bribery and Anti-Corruption (ABAC) training programmes to
strengthen employee awareness, reinforce ethical standards, and mitigate
corruption risks across the organisation.
3 Requiring employees to sign ABAC and Gift Donation Sponsorship (GDS)
Declarations as a formal commitment to integrity, transparency, and responsible
business conduct.
4 Encouraging employees to participate in sustainability capacity-building
programmes through the United Nations Global Compact Academy to strengthen
understanding of global responsible business principles, including anti-
corruption, human rights, labour standards, climate action, and sustainability
governance.
5 Supporting the Sustainable Development Goals (SDGs) through the integration of
sustainability principles into governance practices and operational decision-
making processes.
6 Assigning a Sustainability Team under the Corporate Communications and
Sustainability Department.
7 Reinforcing strong governance practices, with no fraud incidents recorded and
no complaints submitted through the Whistleblowing System (WBS) throughout
the year.
Employees Joined in Anti- Employees Signed ABAC and
Bribery and Anti-Corruption GDS Declaration
Training
3,239 100%
2024 1,655 2024 100%
2025 Sustainability Report 15
Page 18
Sustainability
Performance Highlights
2025 Awards and Certifications
AWARDS
Throughout 2025, the Company and its legacy entities received several national recognitions, reflecting the strength
of its public relations strategy, ESG commitment, and community empowerment programmes, with selected awards
highlighted as follows:
Bina UMKM Award 2025 Electricity and Anugerah Ekonomi Hijau 2025 Tjipta UMKM Awards 2025
14 May 2025 Telecommunications Category: Emissions Reduction 3 October 2025
CFCD Foundation Infrastructure Sector through Digitalization Eka Tjipta Foundation
Gold Award in the MSME Mentor July 2025 August 2025 PT XLSMART Telecom
Category through a community- IDX Channel Eka Tjipta Foundation Sejahtera
based CSR programme, under Anugerah ESG 2025 Detikcom Fostered MSME
one of the Company’s CSR Food Category for MSME
pillars in the education sector, Cavatoz
Teman Pintar Indonesia.
Fostered MSME
Silver Award in the Fostered MSME Digitalisation Category
MSME Category, awarded to for MSME Dapur Kriyakriyuk
Ducrija, led by Ms. Anik
Purwanti from the Teman MSME
Sragen community
Sustainable Solution Award Women In Tech Award Top Leader Warrior The Most Caring & Creative
October 2025 October 2025 October 2025 Company in Telco & Utility
Sinar Mas Digital Day Change Maker Sustainability Warrior Industry
Sinar Mas Digital Day MIX Marcomm October 2025
MIX Marcomm
16 PT XLSMART Telecom Sejahtera Tbk
Page 19
Connecting Indonesia:
One Purpose - One Planet
CERTIFICATIONS
Certificates Validity Issuers
ISO 9001:2015 Quality Management System
5 January 2027 British Standards Institute
(Recertification)
ISO 20000-1:2018 IT Service Management System
14 January 2027 British Standards Institute
(Recertification)
1 Year (April
Sustainalytics (Medium Risk score at 27.8) Morningstar Sustainalytics
2024-April 2025)
ISO 14001:2015 Environmental Management System
1 September 2025 British Standards Institute
(Surveillance)
ISO 45001:2018 Occupational Health and Safety
1 September 2025 British Standards Institute
Management System (Surveillance)
ISO 27001:2013 Information Security Management System
25 November 2026 British Standards Institute
(Recertification)
December 2026 Ministry of Manpower
Occupational Health and Safety Management System
September 2025 Eni Muara Bakau
Contractor Safety Management System High Risk Project
30 August 2025 National Professional
Business Continuity Management Professional
Certification Agency
30 August 2025 National Professional
Certified Risk Management Practices
Certification Agency
1 Year (April
Sustainalytics (Medium Risk score at 28.3) Morningstar Sustainalytics
2024-April 2025)
ISO 27001:2022 Information Security Management System 31 December 2025 TUV Rheinland
2025 Sustainability Report 17
Page 20
Sustainability
Performance Highlights
2025 Sustainability Event Highlights
Environment
August & October 2025
Sustainability Week
XLSMART organised the EcoFusion Sustainability Week to promote sustainable
lifestyle practices among employees. The programme featured various activities
including upcycling workshops, sustainability talks, eco-friendly product bazaars,
and digital engagement challenges focused on sustainable fashion and responsible
textile waste management.
Through the initiative, more than 400 pieces of clothing weighing approximately 120
kg were diverted from potential textile waste through upcycling and reuse activities.
Around 300 employees participated in the programme, helping raise awareness of
sustainable lifestyle practices and environmental responsibility within the
organisation.
11 October 2025
Zero Waste to Landfill-Axis Nation Cup 2025
XLSMART implemented a Zero Waste to Landfill approach during the AXIS Nation
Cup 2025 event. During the event, approximately 4,200 kilograms of waste were
collected and managed through sustainable waste processing schemes. Around
34.8% of the waste was recycled, 7.32% was composted, and 57.87% was converted
into Refuse-Derived Fuel (RDF) as an alternative energy source. Through this initiative,
the programme successfully prevented approximately 3,839 kg CO₂e emissions while
also promoting environmental awareness among participants and spectators of the
event.
Monthly
Waste Management Race
The Waste Management Race program is a competition that encourages active
participation in the proper and responsible sorting of organic, inorganic, and plastic
waste. This initiative aims to raise awareness and foster good habits among
employees in managing waste at the source, while creating a positive impact on the
environment through measurable and sustainable collective action.
Social
XLSMART PESANTREN DIGITAL
Throughout 2025, XLSMART has strengthened its commitment to promoting digital
literacy through the Digital Pesantren CSR program. This program aims to enhance
the ability of students and teachers to utilize technology and expand access to digital
learning within the pesantren environment. Through training and mentoring, this
program has reached 1,340 beneficiaries in Lombok, Aceh, Padang, Pasuruan,
Demak, and Denpasar (Bali). This initiative has had a significant impact on improving
digital skills, creating more adaptive learning environments, and opening up
opportunities for personal development in the digital age. Through Digital Pesantren,
XLSMART continues to contribute to building a generation that is better prepared and
empowered for the future.
12 November 2025 18 November 2025 26 November 2025
Pesantren Digital Pesantren Digital Pesantren Digital
Lombok Aceh City Padang City
3 December 2025 10 December 2025 18 December 2025
Pesantren Digital Pesantren Digital Pesantren Digital
Pasuruan City Demak Denpasar
18 PT XLSMART Telecom Sejahtera Tbk
Page 21
Connecting Indonesia:
One Purpose - One Planet
Sisternet
Throughout 2025, Sisternet continues to strengthen its commitment to empowering
Indonesian women through various strategic initiatives, including SheInspire, the
Sisternet Festival, the W20 Summit, Smart Webinars, the Smart Capital Competition,
and the national #1JutaSisterDigital campaign. Through the Sisternet app and a
series of offline and online educational classes, these programs have reached more
than 1.3 million beneficiaries in 21 cities across Indonesia, with support from 41
strategic partners, including the Indonesian Ministry of Women’s Empowerment and
Child Protection (PPPA) and the Ministry of Communication and Digital (Komdigi).
This cross-sector collaboration is key to expanding access to digital literacy, skills
development, and economic opportunities for women, while fostering a more
inclusive and sustainable ecosystem.
25 July 2025 17-18 October 2025 25 October 2025
Sisternet SheInspire, Sisternet Festival 2025 Webinar Pintar Sisternet
Class III Women’s Prison XLSMART Tower, Jakarta Online, Via Zoom
Mataram, Lombok
13 November 2025 27 November 2025 11 December 2025
Webinar Pintar Sisternet #1 Webinar Pintar Sisternet #2 Webinar Pintar Sisternet
Online, Via Zoom Online, Via Zoom Online, Via Zoom
14 December 2025 18-19 December 2025
Sisternet’s Padel Day 2025 Sisternet SheInspire
Centercourt Club Permata Hijau, Bapas Kelas I Denpasar, Bali
Jakarta
XLSMART PEDULI DISABILITAS
In 2025, XLSMART launched the “Peduli Disabilitas Berdaya” CSR program to
promote independence and skill development among people with disabilities,
enabling them to actively participate in social and economic life. This program is
conducted both offline and online and has reached 443 beneficiaries in Batam,
Semarang, Bengkulu, and Kediri. Through training and mentoring, participants are
equipped with practical skills to develop their potential. This initiative has had a
positive impact on boosting self-confidence, creating economic opportunities, and
fostering a more inclusive environment.
10 September 2025 18 September 2025 26 September 2025
XLSMART Peduli Disabilitas XLSMART Peduli Disabilitas XLSMART Peduli Disabilitas
Online, Nationwide Online, Nationwide Semarang
7 October 2025 22 October 2025 29 October 2025
XLSMART Peduli Disabilitas XLSMART Peduli Disabilitas XLSMART Peduli Disabilitas
Bengkulu Kediri Online, Nationwide
XLSMART PEDULI BENCANA
Throughout 2025, the XLSMART Disaster Relief Program has provided assistance to a
total of 4,436 beneficiaries across various flood-affected regions in Indonesia,
including Bali, West Lampung, Sukabumi, Tapanuli, West Sumatra, Aceh, and
surrounding areas. This initiative reflects the company’s commitment to responding
to emergencies quickly and effectively, while supporting community recovery through
coordinated assistance across various affected locations.
January 2025 January 2025 January 2025
XLSMART Peduli Bencana Banjir XLSMART Peduli Bencana Erupsi XLSMART Peduli Bencana Longsor
Lampung Mount Halmahera Pekalongan
March 2025 September 2025 September 2025
XLSMART Peduli Bencana Banjir XLSMART Peduli Bencana Banjir XLSMART Peduli Bencana Banjir
Bekasi Denpasar Lampung
September 2025 October 2025 December 2025
XLSMART Peduli Bencana Banjir XLSMART Peduli Bencana Banjir XLSMART Peduli Bencana Banjir
South Tapanuli Cisolok Sukabumi Mandailing Natal
December 2025
XLSMART Peduli Bencana Banjir
Padang Pariaman
2025 Sustainability Report 19
Page 22
Sustainability
Performance Highlights
KELAS CERDAS DIGITAL
Total Beneficiaries: 6,645
This program focuses on improving the digital literacy and skills of the community,
particularly students, as part of an effort to support inclusive and sustainable digital
transformation across various regions.
23 September 2025 25 September 2025
Kelas Cerdas Digital Kelas Cerdas Digital Ungaran
Jakarta, SMK Strada 1 Jakarta SMK Kanisius Ungaran
30 September 2025 28 October 2025 12 December 2025
Kelas Cerdas Digital Bekasi Kelas Cerdas Digital Indramayu Kelas Cerdas Digital Blitar
SMA Ananda Bekasi SMK Endang Ayu Darmaayu, SMK PGRI 2 Blitar
Indramayu
BUNDA PINTAR
Total Beneficiaries: 2,035
Throughout 2025, the Bunda Pintar Program has benefited a total of 2,035
participants, focusing on empowering women by improving their literacy, skills, and
capacity to support family well-being. This initiative is part of a commitment to
promoting women’s active roles in the community and creating sustainable social
impact.
28 January 2025 25 April 2025 26 April 2025
Bunda Pintar Bunda Pintar, KB Mi’rojul Muta’alimin Bunda Pintar
Miss Desi’s House, Tegal Tegalwangi, Tegal RM Limas Kembar, Boyolali
27 April 2025 27 April 2025 28 April 2025
Bunda Pintar Bunda Pintar Bunda Pintar
Berjaya Café, Pontianak Balai Kelurahan Pajagalan, Sumenep Betewe Café, Denpasar
28 April 2025 30 April 2025
Bunda Pintar, Taman Widawati Bunda Pintar, Aula Kantor Kelurahan
Gondang, Tulungagung Sukamulya, Bandung
TEMAN PINTAR
Total Beneficiaries: 16,013
Throughout 2025, the Bunda Pintar Program has benefited a total of
16,013beneficiaries, with a focus on empowering women through the enhancement of
literacy, skills, and capacity to support family welfare. During the year, the program
also conducted a total of 95 activities/events across various regions. This initiative
forms part of the commitment to promoting the active role of women in communities
and creating sustainable social impact.
15 January 2025 25 January 2025 26 January 2025
Teman Pintar Teman Pintar Teman Pintar
Budi Luhur University Batik Laweyan Village Gallery Smartfren Jember
TEMAN UMKM
Total Beneficiaries: 6,645
Throughout 2025, the Teman Pintar Program has benefited a total of 16,013
beneficiaries. As a large-scale digital literacy outreach programme implemented
across schools, universities, and community spaces, the initiative promotes
responsible internet use, strengthens digital awareness, and encourages students
and young communities to develop productive digital competencies.
7 March 2025
Teman UMKM
PLUT KUMKM
20 PT XLSMART Telecom Sejahtera Tbk
Page 23
Connecting Indonesia:
One Purpose - One Planet
TEMAN KREASI
Total Beneficiaries: 10,297
The Content Creator Academy program is designed to develop the digital skills of the
younger generation in the field of creative content creation. With a total of 10,297
beneficiaries, the program provides training and mentoring to enhance participants’
storytelling, content production, and digital platform utilization skills, enabling them to
adapt and remain competitive in the creative economy era.
15 March 2025 18 March 2025 19 March 2025
Teman Kreasi Teman Kreasi Teman Kreasi
Celebes Kearifan Madani Ponpes Al-Mu’awanah Ponpes Al Hikmah Cilacap
21 March 2025
Teman Kreasi
Kampus STAI Muhammadiah
SPECIAL EVENTS
Special Events consist of strategic engagements and flagship activities that
complement the Company’s community initiatives. These events include participation
in global forums and collaborative programmes that broaden outreach, strengthen
partnerships, and support wider social and sustainability dialogues.
17 November 2025 6 December 2025
W20 Summit, Johannesburg, BersalingSilang, NuArt Space,
South Africa Bandung
Governance
25 July 2025 25 October 2025
Training Data Privacy for Customer XLSMART successfully maintained its
Relationship Representative (CRR) of ISO 27701 Privacy Information
XL Center and Smartfren Gallery. Management System (PIMS)
certification from the British Standards
Institution (BSI), demonstrating the
Company’s continued commitment to
strengthening data privacy governance
and protecting customer information.
2025 Sustainability Report 21
Page 24
Page 25
Message from the Board of Directors
Page 26
Message from
the Board of Directors
"The Company kept its
focus firmly on improving
the offer to our customers:
delivering a more
personalized, competitively
priced, and better value
offer while driving cost
efficiency and enhanced
network performance."
RAJEEV SETHI
President Director
24 PTPT
XLSMART
XLSMART
Telecom
Telecom
Sejahtera
Sejahtera
Tbk
Tbk
Page 27
Connecting Indonesia:
One Purpose - One Planet
Message from
the Board of Directors
Dear esteemed stakeholders, STRATEGIES TO ADDRESS SUSTAINABILITY
CHALLENGES [D.1.A]
The 2025 reporting year represents a pivotal chapter
in the journey of XLSMART, marked by transformation, Through the strategic formation of XLSMART, the
purpose-led direction, and a strengthened commitment telecommunications industry shifted from 4 (four) main
to sustainable value creation. As global environmental operators to 3 (three), a change that is expected to
and social challenges continue to intensify, drive the industry towards a healthier market. In recent
sustainability is no longer viewed as a supplementary years, the mobile industry has been facing a decline
initiative; it has become central to how the Company due to price wars and aggressive customer acquisition
defines strategic success, manages risk, and delivers strategies, which have diluted value and dampened
meaningful outcomes for society. XLSMART embraces growth.
this imperative not as an obligation, but as an integral
part of its identity and approach to long-term value The integration of two very different entities introduced
creation for all stakeholders. a complex set of sustainability-related challenges.
Timely integration of networks, cultures, brands,
This transformation was anchored by a significant systems, and processes is critical to managing
milestone. On 17 April 2025, XLSMART officially customer experience disruption and subscriber churn.
commenced operations, bringing together the These extended beyond operational integration to
networks, resources, brands, and organisational include the harmonisation of governance standards,
cultures of XL Axiata, PT Smartfren Telecom Tbk, and alignment of environmental and social commitments,
PT Smart Telecom into a single, unified organization. responsible management of cultural transition, and the
The merger combined complementary strengths in maintenance of business continuity amid heightened
scale, spectrum, talent, and technological capability, stakeholder expectations.
establishing a stronger and future-ready platform
to support Indonesia’s digital and sustainable In addition to establishing very close monitoring and
development. evaluation with dedicated war rooms to manage key
tracks of the integration processes, regular reviews
XLSMART’s approach to sustainability is grounded in were held with key business partners pivotal to
the consistent application of Environmental, Social, XLSMART’s National Roaming (NR) and Multi-Operator
and Governance (ESG) principles across strategy, Core Network (MOCN) Implementation plans. This
operations, and corporate culture. Sustainability has delivered synergy realizations ahead of plan. The
considerations inform how the Company allocates Company recognises that the manner in which these
capital, deploys technology, governs risk, and engages challenges are addressed will materially influence
with stakeholders. This integration reflects the XLSMART’s long-term resilience and credibility.
Company’s conviction that long-term value creation
is inseparable from responsible governance, social Following the merger, XLSMART undertook a
inclusion, and sound environmental stewardship. reassessment of its sustainability priorities by
integrating the Double Materiality Assessment
outcomes of the legacy entities with emerging risks
and opportunities arising from the expanded business
model. This process enabled the Company to sharpen
its focus on sustainability topics most relevant to
long-term value creation, including Community
Development, Best Place to Work, Customer
Engagement, GHG Emissions, as well as Data Privacy
and Security.
2025 Sustainability Report 25
Page 28
Message from
the Board of Directors
These priority areas guide how XLSMART identifies KEY SUSTAINABILITY ACHIEVEMENTS [D.1.B]
sustainability-related risks, captures strategic
opportunities, and allocates resources within Throughout the reporting period, XLSMART continued
an environment shaped by rapid technological to integrate sustainability considerations into its
advancement, climate transition pressures, and strategic and operational activities amid a dynamic
evolving regulatory and societal expectations. macroeconomic and industry environment. Despite the
Sustainability considerations are embedded into complexity of the integration process, the Company
strategic planning and decision-making processes, remained focused on maintaining service quality,
ensuring that near-term business objectives remain strengthening financial discipline, and preserving
aligned with long-term resilience. customer trust, while laying a solid foundation for
sustainable growth.
To translate these priorities into action, XLSMART
organises its sustainability initiatives around strategic During the first year following the merger, XLSMART
pillars that guide value creation, human capital prioritised operational stabilisation while embedding
development, operational excellence, as well as sustainability considerations into business execution.
environmental and social responsibility. This framework This period was characterised by disciplined
supports responsible growth by aligning business integration, prudent financial management, and
performance with national development objectives targeted investments aimed at strengthening long-
and global sustainability aspirations, while remaining term resilience amid macroeconomic volatility and
responsive to stakeholder expectations. It also enables an increasingly competitive telecommunications
the Company to balance short-term performance landscape.
with long-term resilience in a disciplined and forward-
looking manner. Financial Resilience and Economic Sustainability
Despite the complexity of the integration, XLSMART
To strengthen the Company’s response to increasingly has passed most of its Year-1 merger milestones. Cost
complex sustainability challenges, in 2025 the optimization and asset utilization are on track, the
Company encouraged employees across key functions customer base stabilized faster than expected, and
to participate in structured learning through the United we are now beginning to see revenue synergies as a
Nations Global Compact Academy. The Academy offers result of the market reparation and enhanced customer
comprehensive courses covering among others anti- experience yielded by improvements in network quality
corruption, business integrity, human rights, climate and coverage.
and environmental stewardship, SDG integration
and financing, sustainability regulations, and Post XLSMART merger, ARPU recovery was the primary
transformational governance. Through this initiative, growth driver. Q4 2025 sees ARPU hikes along with
we are enhancing internal capability to anticipate traffic growth which has been driving Industry Revenue
regulatory developments, manage sustainability uplift. This signal early indicator of price repair taking
risks, and embed responsible business practices into hold, which should support margin recovery and
strategic and operational decision-making. The number improved monetization of rising data volumes for the
of employees who joined and completed courses under remainder of the year.
this programme in 2025 were 51 employees.
Our merger strategy has been validated convincingly
The Company also regularly collaborates with by our results. By the end of 2025, we had achieved
regulators, authorities, and key stakeholders, including our synergy target of US$250 million, achieving early
industry peers, to shape policies and regulations aimed savings from site rationalisation optimising capex, and
at protecting consumer rights while ensuring a fair and maintaining a healthy balance sheet. All of which were
sustainable industry. Such collaboration is essential for supported by robust governance. We are now on track
enabling industry players to deliver the best possible to deliver total synergies of US$250-300 million upon
services to customers. completion of the integration.
26 PT XLSMART Telecom Sejahtera Tbk
Page 29
Connecting Indonesia:
One Purpose - One Planet
Throughout 2025, the Company delivered solid The merger also positions XLSMART as the only
operational performance as a unified post-merger operator running three distinct brands; XL, AXIS, and
entity. Revenue reached Rp42,485 billion, reflecting Smartfren. Each brand targets a specific segment with
expanded scale, stronger data monetisation, and its own strengths and value proposition, strengthening
improved service portfolio integration. Normalized our ability to reach and penetrate a broader customer
EBITDA amounted to Rp20.1 trillion, demonstrating base. Particularly in Smartfren, expanded coverage
resilient operating fundamentals and disciplined cost has enabled customers to be more connected across
management during the integration phase. Indonesia.
The strengthened financial foundation translated into Network rationalisation was executed with structured
broader economic contribution. Total direct economic environmental controls. Site dismantling activities
value generated reached Rp41,432,011 million. This were accompanied by responsible decommissioning
value was channelled back into the economy through practices and strengthened waste handling procedures
strategic reinvestment in infrastructure expansion, to minimise environmental impact and ensure
workforce remuneration, operational ecosystem regulatory compliance. These measures supported both
support, financial obligations, and shareholder returns. operational efficiency and environmental stewardship.
Economic value distribution totalled Rp42,924,235 The launch of XL Ultra 5G+ in Bali in December
million during the year. Capital was prioritised toward represented an early milestone in the Company’s next-
network modernisation and nationwide expansion generation connectivity roadmap. Beyond enhancing
to enhance long-term competitiveness and service consumer experience, 5G capability is expected to
reliability. The Company also ensured sustained support advanced use cases across entertainment,
investment in human capital through salaries and enterprise solutions, Internet of Things, and digital
employee benefits, while maintaining operational innovation, contributing to long-term economic and
excellence through interconnection and core operating social value.
expenditures. Financial discipline was reflected in
responsible capital servicing and fulfilment of tax Digital Transformation, IT Integration, and
obligations to the Government. Governance
Post-merger, XLSMART advanced a unified IT
As part of its commitment to delivering shareholder transformation agenda anchored in an AI-ready
value, the Company distributed cash dividends architecture. The rationalisation of legacy systems and
amounting to Rp4.01 trillion during 2025. This optimisation of cloud usage reduced duplication and
distribution underscores management’s confidence in lowered maintenance intensity, contributing to improved
the Company’s long-term fundamentals and capital cost efficiency and strengthened governance. These
allocation discipline during the post-merger integration initiatives enhanced data integration across finance,
period. sales, marketing, and analytics functions, supporting
faster and more informed decision-making.
Network Transformation and Infrastructure
Efficiency As digital engagement expanded, governance
Network integration and optimisation remained frameworks were reinforced to address cybersecurity,
central to sustainability performance. During the year, data protection, and responsible technology
the Company consolidated more than 50,000 sites, deployment. The Company achieved ISO 27701:2019
enabling significant improvements in network efficiency Privacy Information Management System certification,
and coverage. The combination of spectrum assets reflecting strengthened data privacy governance,
from the legacy entities increased overall network alongside continued implementation of enterprise risk
capacity by approximately three times, strengthening management and business continuity controls.
nationwide service reliability across mobile, home, and
enterprise segments. With this, we are well-positioned
to deliver leadership in network through larger coverage
and better customer experience for our customers.
2025 Sustainability Report 27
Page 30
Message from
the Board of Directors
Customer Experience and Market Sustainability cloud-based systems to minimize printing requirements
Customer sustainability outcomes were reflected in and the physical distribution of documents, further
improvements across service quality, engagement, reducing its environmental footprint. Also, the Company
and trust. The mobile subscriber base grew 36% YoY has advanced its energy transition through the purchase
across XL, Axis, and Smartfren brand, or reached of 3,000 Renewable Energy Certificates (RECs) from
73 million, supported by an improved Average Revenue PLN as part of its commitment to supporting the use
Per User of approximately Rp45,000, representing of clean energy, in line with its long-term target of
a 26% year-on-year increase. In parallel, sustained achieving net-zero emissions by 2050.
focus on customer experience contributed to a notable
improvement in Net Promoter Score (NPS), which was Waste management initiatives were reinforced
recorded at an increase of 21% in 2025. through structured programs aimed at reducing landfill
dependency, supported by internal engagement
The Company’s digital acceleration strategy also campaigns to promote responsible behaviour across
delivered measurable results. Increased engagement operations. In 2025, a significant contributor to waste
with digital platforms, including MyXL, AXISNet, and volumes was the large-scale dismantling of redundant
mySmartfren, drove strong user growth. By the end BTS sites following network integration. To mitigate
of the year, MyXL recorded over 41.4 million active associated risks, the Company implemented controlled
users, representing a 28.6% year-on-year increased dismantling protocol supported by internationally
compared to 32.2 million users reported last year. certified vendors specialising in telecommunications
Higher digital engagement provides deeper insights equipment decommissioning and e-waste recovery.
into customer preferences and behaviour, enabling These vendors operate under ISO 14001 and ISO
enhanced monetisation opportunities through cross- 45001 standards and provide full traceability for both
selling and upselling. hazardous and non-hazardous waste streams, from site
removal through transport and final processing. High-
Environmental Stewardship and Climate Action value components that remain reusable are extracted
XLSMART is committed to accelerating carbon neutrality for refurbishment, while non-recoverable materials
through environmentally responsible, sustainable digital are channelled to licensed recycling facilities to prevent
innovation, and integrates environmental stewardship, improper disposal and environmental leakage.
social progress, and strong governance into every
step of its journey. The Company has implemented Overall, the consolidated environmental expenditure
emissions reduction initiatives through the digitalization for 2025 increased significantly to Rp560,362,896
of network infrastructure, including the replacement compared with Rp86,203,200 in 2024. While
of conventional shelters with outdoor cabinets that expenditure data from legacy entities provide useful
eliminate the need for air conditioning. This initiative historical reference, XLSMART will establish a
has resulted in total carbon emissions of 992,258.79 consolidated baseline for environmental expenditure
TonCO2e across Scope 1, Scope 2, and Scope 3. During commencing in 2025 to more accurately reflect
the year, the Company established a consolidated the scale, integration status, and operational
carbon emissions baseline, including relevant Scope 3 characteristics of the merged entity going forward.
categories, providing a foundation for consistent post-
merger measurement and decision-making. Social Impact and Human Capital Development
Social sustainability remained a core element of
XLSMART has also adopted drone technology for XLSMART’s commitment to inclusive growth and
aerial surveys and safety inspections, reducing reliance shared value creation. Throughout the reporting year,
on conventional operational vehicles that generate the Company continued to expand access to digital
fuel-related emissions. In parallel, the Company is opportunities and economic empowerment through
progressively digitalizing services and integrating a range of community-based initiatives, reaching
approximately 1.4 million beneficiaries across various
regions of Indonesia.
28 PT XLSMART Telecom Sejahtera Tbk
Page 31
Connecting Indonesia:
One Purpose - One Planet
In 2025, XLSMART introduced a flagship corporate Clear communication and transparency were critical
social responsibility initiative, XLSMART CSR Tri Karsa, components of the integration process. From the
designed as an integrated framework encompassing outset, the Company adopted a “preserve and
three strategic priorities: Philanthropy, Women grow” approach to its people across both legacy
Empowerment, and Education. This framework reflects organisations, fostering collaboration and cross-
the Company’s long-term approach to social impact, learning as the new operating model evolved. Building
focusing on addressing immediate community needs trust and supporting employees well-being remained
while strengthening capabilities that support economic a priority, supported through structured two-way
participation and social resilience. Total CSR funds communication platforms such as the iCARE Employee
disbursed during the year amounted to Rp28.10 billion. Helpdesk, the FriYay program, Leader Forums, and
As a result, the calculated Social Return on Investment iCARE4U, alongside regular direct dialogue between
(SROI) ratio reached 1 : 2.54, indicating that each Rupiah management and employees across directorate and
invested generated Rp2.54 Rupiah in social value. regions.
In parallel, culture and collaboration were central to Governance and External Recognition
the Company’s efforts to unify people, behaviors, and The Company prioritized transparency and regulatory
mindsets under a single purpose following the merger. compliance throughout the integration process,
To support this transition, XLSMART defined its North supported by continuous engagement with internal and
Star as becoming Indonesia’s most engaged and high- external auditors and, where necessary, the regulator.
performing telecom workforce, one in which every Key post-merger focus areas included strengthening
individual drives impact, learns continuously, and governance around the adoption, implementation
thrives within a culture of ownership, feedback, and and testing of our Company’s AI architecture, as well
continuous improvement. as enhancing cybersecurity and data governance
frameworks to safeguard customer information amid
XLSMART is also fostering a new culture, i-CARE, increasing digital engagement.
embedding Integrity and Customer-centricity as the
core to achieving the Company’s vision. This culture In line with the integration of our Double Materiality
fosters a collaborative, growth-minded environment Assessment results into our strategic priorities, ESG
and has supported the seamless blending of the 2 is firmly embedded within the Company’s integration
(two) legacy organizations, accelerating employee strategy. During the first year following the merger,
productivity post-merger period. XLSMART focused on ESG data integration, policy
harmonisation, and reinforcing ESG accountability
Engagement and ownership were key enablers in across procurement, technology, and operational
advancing this objective. The Company gathered input functions. These efforts support compliance with
from employees across both legacy entities on the applicable global standards and contribute to the
cultures and practices they valued most and integrated Company’s ambition to establish itself as a benchmark
these insights into a collective vision of becoming for digital sustainability in Indonesia.
Indonesia’s best place to work by 2027. This vision
empowers employees to act with an ownership mindset In terms of external recognition, XL Axiata achieved a
and full accountability for outcomes, while enabling the CDP Climate Change score of “B”, placing the company
embedding of an agile, performance-driven culture, above many regional peers. In 2024 and 2025, the
supported by harmonised performance management newly merged XLSMART focused on harmonizing
system with clear KPIs across all levels. Complementing methodologies and preparing a robust, unified dataset
these efforts, the Gear Up Program represents a and internal ESG disclosures aligned with GRI and POJK
significant investment in reskilling and upskilling across 51.
a range of 5G, artificial intelligence, data analytics,
cyber security, and other digital competencies,
strengthening the Company’s competitiveness, agility,
and leadership within the digital ecosystem.
2025 Sustainability Report 29
Page 32
Message from
the Board of Directors
During this integration period, we continued our To support these priorities, XLSMART is recalibrating
participation in global rating assessments, beginning its investment portfolio toward areas with strong
with the S&P Global Corporate Sustainability growth potential and clear sustainability relevance. Key
Assessment. In 2025, we achieved an improved S&P focus areas include the expansion of fixed broadband,
Global CSA score of 43, an increase of 6 points from the development of enterprise digital solutions, and
37, previously recorded under XL Axiata Legacy. This readiness for next-generation connectivity. The
improvement reflects strengthened ESG performance, advancement of 5G capabilities is viewed as a critical
enhanced policy alignment, and more integrated enabler, supporting not only future revenue growth
governance and reporting practices under the new but also productivity gains, innovation, and broader
XLSMART structure. digital inclusion. With more than 26,000 active 5G
sites, complemented by strategic partnerships and
We also maintained participation in Sustainable new product initiatives, the Company is well positioned
Fitch Ratings, while temporarily limiting submissions to deliver a differentiated 5G experience for both
to selected agencies to safeguard data accuracy consumer and enterprise customers.
and consistency throughout the transition. In 2025,
XLSMART obtained a rating of 2 from Sustainable Fitch Across all business segments, XLSMART will continue
Ratings, where 1 represents the highest rating and 5 the to leverage data and AI-driven analytics to deepen
lowest. This result underscores the robustness of our customer engagement, enhance service relevance,
sustainability governance framework and the progress and improve operational efficiency. At the same time,
made in embedding ESG management across the the Company recognises that the increased adoption
merged entity. of advanced technologies requires heightened
responsibility. Accordingly, robust governance
Starting next year, we plan to re-enter CDP with frameworks for data protection, cybersecurity, and
complete XLSMART data and gradually expand the responsible deployment of artificial intelligence
participation in broader sustainability ratings to are embedded as integral elements of the Company’s
benchmark performance at a global level. Collectively, growth strategy.
these milestones demonstrate progress that extends
beyond metrics. They reflect the successful integration Over the next three years, XLSMART will transition
of governance structures, systems, and a strengthened from integration to acceleration, with a clear focus
data foundation required to support a scalable and on initiatives that strengthen compliance, reduce
long-term Decarbonisation pathway under the new environmental impact, and deepen our contribution to
entity. Indonesia’s digital inclusion agenda. In support of this
direction, the Company has defined three key targets.
STRATEGIES TO ACHIEVE THE TARGETS [D.1.C]
• First, our Net Zero Roadmap baseline will be
Looking ahead, XLSMART remains committed to developed starting 2026 and aligned with
pursuing growth that is both profitable and sustainable international best practices such as SBTi. This
as the foundation for long-term value creation. roadmap will define Decarbonisation pathways for
The Company’s strategic direction is guided by the our network, data centers, supply chain (Scope 3),
imperative to translate post-merger scale into enhanced and operations. It will include near-term science-
efficiency, operational resilience, and responsible based targets, energy-efficiency commitments,
expansion. In this context, the Company has defined renewable energy strategies, and supplier
three strategic initiatives: completing the integration engagement programs.
and unlocking efficiency, accelerating revenue through
digital and enterprise-led opportunities, and reinforcing
financial resilience.
30 PT XLSMART Telecom Sejahtera Tbk
Page 33
Connecting Indonesia:
One Purpose - One Planet
• Second, we will scale our Circular Economy and CLOSING REMARKS
e-Waste Management program across the merged
network footprint. In connection with the rollout of On behalf of the Board of Directors, we extend our
approximately 30% of tower infrastructure over sincere appreciation to all stakeholders for the trust
the coming years, XLSMART is formalizing a unified and partnership shown to XLSMART throughout this
policy for e-waste disposal that fulfils Indonesia’s transformative year. The establishment of XLSMART
environmental and HSE regulations (including has been made possible through the collective efforts
B3 waste requirements). This includes vendor of our customers, employees, partners, regulators,
compliance (ISO 14001/45001), due-diligence and the communities we serve, providing a strong
checks, and transparent end-to-end tracking of foundation for the Company to move forward with
waste, from collection to final recycling. clarity, resilience, and purpose.
• Third, we are strengthening our community impact Looking ahead, the Board remains confident in
programs, including digital literacy for women and XLSMART’s ability to navigate change with discipline
youth, and initiatives under Sisternet and other and integrity. Guided by sound governance and a
flagship CSR platforms. These programs support continued focus on responsible growth, the Company
national priorities for digital inclusion and responsible will further strengthen its foundations, enhance
technology usage, while fostering employee customer experience, and contribute meaningfully
involvement in sustainability and community to a more inclusive and resilient digital ecosystem in
activities. Indonesia.
Finally, our priorities also include ESG data integration, Sustainable value creation is built patiently through
policy alignment across the merged entity, advancing trust, enduring partnerships, open dialogue, and a
Double Materiality Assessment results into Board- shared commitment to outcomes that extend beyond
approved priorities, and embedding ESG accountability short-term results. XLSMART welcomes continued
across procurement, technology, and operations. This engagement with all stakeholders as we work together
ensures that XLSMART not only complies with POJK to create value that is meaningful, responsible, and
51 and emerging global standards but also positions enduring for society today and for future generations.
itself as a leading digital sustainability benchmark in
Indonesia.
With sincere regards,
Rajeev Sethi
President Director
2025 Sustainability Report 31
Page 34
Message from
the Board of Directors
Statement of Accountability
Statement of Accountability of 2025 Sustainability Report by
the Board of Commissioners and Board of Directors
We, the signatories, hereby stated that all information contained in the 2025 Sustainability Report of PT XLSMART
Telecom Sejahtera Tbk has been comprehensively presented and that we are fully accountable for the accuracy of
the content of PT XLSMART Telecom Sejahtera Tbk Sustainability Report.
This statement is made thruthfully.
Jakarta, 14 April 2026
Board of Commissioners
M. Arsjad Rasjid P. M.
President Commissioner
Vivek Sood Nik Rizal Kamil L. Krisnan Cahya
Commissioner Commissioner Commissioner
David R. Dean Sean Quek
Commissioner Commissioner
Willem Lucas Timmermans Retno Lestari P. Marsudi Robert Pakpahan
Independent Commissioner Independent Commissioner Independent Commissioner
32 PT XLSMART Telecom Sejahtera Tbk
Page 35
Connecting Indonesia:
One Purpose - One Planet
Board of Directors
Rajeev Sethi
President Director
Antony Susilo Yessie D. Yosetya Andrijanto Muljono
Director Director Director
Feiruz Ikhwan Merza Fachys Shurish Subbramaniam
Director Director Director
David Arcelus Oses Jeremiah Ratadhi Sanjay Vaghasia
Director Director Director
2025 Sustainability Report 33
Page 36
Message from
the Board of Directors
34 PT XLSMART Telecom Sejahtera Tbk
Page 37
Connecting Indonesia:
One Purpose - One Planet
Framework
for Accelerating
the Sustainability Journey
2025 Sustainability Report 35
Page 38
Framework for Accelerating
the Sustainability Journey
At XLSMART, sustainability is a core business discipline. It underpins how we build trust, manage risk, and deliver
reliable connectivity at scale. Our purpose – to connect every Indonesian for a better life - sets the strategic
direction, while our strategy ensures this purpose is translated into clear directions, robust systems, and measurable
performance.
Following the merger, our sustainability journey is designed to achieve three objectives. First, to protect business
continuity in a sector where network resilience, cybersecurity, and regulatory compliance are fundamental. Second,
to accelerate inclusive digital growth by improving access, affordability, and digital literacy. Third, to establish
credible climate and resource pathways that respond to investor expectations and evolving reporting standards.
Sustainability is not treated as a standalone agenda. It is embedded into how we prioritise network investments,
manage digital and operational risks, develop talent, and engage communities. Through this approach, sustainability
becomes a driver of long-term value creation for customers, employees, and the broader ecosystem.
Our Sustainability Strategy
[OJK A.1] [GRI 2-22] [GRI 2-23]
Our purpose goes beyond connectivity. By prioritising sustainable environments through green innovation and ESG
leadership, XLSMART empowers customers to enjoy a better, more responsible quality of life.
Our sustainability strategy is anchored in the principle of double materiality, reflecting two complementary
perspectives. The first considers how sustainability-related topics may give rise to the financial risks and opportunities
for XLSMART. The second assesses how our operations and value chain may generate impacts on people and the
environment.
This strategy has been developed to support a post-merger organisation. It integrates the legacy strengths of
XL Axiata and Smartfren, while establishing a unified sustainability direction for XLSMART. It also enhances the
Company’s preparedness for evolving sustainability disclosure expectations, including ISSB IFRS S1 and S2, and IAI
PSPK 1 and 2, which increasingly emphasise decision-useful, financially relevant sustainability information.
In practice, the strategy focuses on the sustainability topics that are most material to the business and stakeholders.
These priorities are translated into governance structures, targets, programmes, and performance tracking. This
ensures sustainability is managed with the same discipline as other strategic priorities.
Materiality Assessment [GRI 3-1]
In 2025, XLSMART refreshed its Double Materiality Assessment to reflect the post-merger structure and evolving
stakeholder expectations. The assessment was designed to ensure that sustainability priorities remain aligned with
the Company’s expanded operational footprint, regulatory developments, and investor expectations.
The review considered both impact materiality and financial materiality perspectives. It evaluated how XLSMART’s
activities affect society and the environment, as well as how sustainability-related risks and opportunities may
influence the Company’s financial performance, long-term resilience, and enterprise value.
36 PT XLSMART Telecom Sejahtera Tbk
Page 39
Connecting Indonesia:
One Purpose - One Planet
The process incorporated stakeholder engagement, peer benchmarking within the telecommunications sector, and
regulatory horizon scanning to ensure alignment with emerging disclosure standards, including ISSB IFRS S1 and S2
and relevant Indonesian sustainability frameworks. An independent external party supported the review to enhance
objectivity and methodological robustness.
Engagement involved representatives from investors, employees, customers, suppliers, business partners, and
relevant institutions. Internal validation was conducted with senior management and the Board of Directors to ensure
alignment with strategic priorities and governance oversight. The final material topics were reviewed and approved
by the Board of Directors in accordance with established governance procedures [GRI 2-14].
List of Material Topics [GRI 3-2]
The assessment confirmed that stakeholders place the highest priority on operational reliability and digital trust.
Network quality, availability, and reliability ranked as the most critical material topic. Cybersecurity, customer
engagement, and data security and privacy were also identified as high-priority areas.
People-related topics remain central in a post-merger organisation. Employment practices, employee wellbeing,
and talent development are critical to effective integration and sustained performance. Supply chain conduct also
emerged as a material priority, reflecting the operational complexity of the telecommunication sector. Environmental
topics are increasingly important from both impact and financial perspectives. Stakeholders highlighted greenhouse
gas (GHG) emissions, energy, as well as waste management and end-of-life management treatment as key areas
of focus.
The following list summarises the material topics identified through the stakeholder survey and internal assessment
process. The sequence of topics presented below does not represent a ranking of priority. Instead, it reflects the
consolidated list of material issues considered relevant to XLSMART’s business activities and sustainability impacts.
Prioritised Topics from Survey
Network quality, availability and reliability Supplier conduct and engagement
Cybersecurity Greenhouse gas (GHG) emissions, energy, decarbonisation
Customer engagement Products and services that benefit society and the environment,
innovation
Data security and privacy Competitive behavior and an open internet
Employment practices, compensation and benefits Climate impacts and adaptation
Regulatory compliance Responsible product design, labeling, and marketing
Digital inclusion, product accessibility and affordability Community development
Health, safety and wellbeing Diversity, inclusion, and equal opportunity
Talent development Resource use and efficiency
Waste, product and end-of-life management, circular Water usage
economy
MATERIAL TOPICS REFINEMENT AND BUSINESS-AS-USUAL (BAU) IDENTIFICATION
To enhance clarity, strengthen accountability, and avoid fragmented management, certain material topics were
refined and consolidated. Cybersecurity is managed as an embedded component of data security and privacy,
reflecting its role as a key control mechanism within the broader data protection framework. Community development
is addressed with diversity, inclusion, and equal opportunity embedded as core outcomes of the Company’s social
impact approach. Industry business-as-usual (BAU) topics remain disclosed as part of ongoing reporting, ensuring
continued transparency while enabling management focus on priority material issues.
2025 Sustainability Report 37
Page 40
Framework for Accelerating
the Sustainability Journey
No. Original Sub-topics Rationale for CombiningSub-topics Updated Topics
1 Cybersecurity • XLSMART has implemented digital data management system for • Data security &
Data security & customer and corporate information. privacy
privacy • Cybersecurity programs directly support and enable data security • Cybersecurity
and privacy outcomes. embedded as a
• Data security and privacy governance covers digital and non-digital sub-topic
data, information protection, data retention, behavioral controls, and
regulatory compliance (including social media governance).
2 Community Community development initiatives promote diversity, inclusion, and • Diversity, inclusion
development equal opportunity through: and equal
Diversity, inclusion, • Programs targeting diverse and underserved communities, including opportunity
and equal local communities, women, persons with disabilities, and other embedded as
opportunity minority groups. outcomes
• Access-based initiatives supporting education, healthcare, and • Community
digital inclusion. development
• Inclusive program design involving stakeholders through community
needs assessment.
• Employment access initiatives promoting diversity, inclusion, and
equal opportunity in workforce practices
3 Business-as-usual Business-as-usual ESG topics for the telecommunications industry are • Business-as-usual
ESG topics identified, monitored, and disclosed as part of ongoing reporting to (BAU)
ensure continuity and regulatory compliance. • Disclosed as ongoing
topics
Aligning Prioritised Topics with XLSMART’s Value Creation Framework
Creating Value for Creating Value for
Stakeholders Purpose & Vision Stakeholders
Shareholder
Regulatory
Commitment
Mandate Axiata
XLSMART’s Guiding principles
ESG-related Regulations and Net Zero Target (SBTi Approved)
Vision • Scope 1 and 2 reduction of 42%
Priorities Purpose
Most Loved by 2030 and 90% by 2050
We connect every
Indonesia Company • Scope 3 emissions reduction of
Komdigi Indonesian for a
by Customer in 25% by 2030 and 90% by
Cybersecurity, data privacy and better life
2027 2050
security, women empowerment,
digital talent, customer
services, product quality,
e-waste
Indonesia Net Zero by 2060
Tri Karsa
Decarbonisation and GHG
reporting mandate for
publicly listed companies Operationalisation of Purpose & Vision
(upcoming) - Ongoing commitment
POJK 51/2017
Education
Sustainability reporting
Women Gerakan Donasi
Philanthropy Empowerment Kuota, Content
Laws on Publicly
Peduli Bencana, Sisternet, Female Creator Academy,
Listed Companies
Peduli Kesehatan, Future Leader, Pesantren Digital,
Ethics and
Peduli Disabilitas SheInspire, Bunda Kelas Cerdas
compliance, CSR
Pintar Digital, Teman
UMKM
Refocusing Prioritised Topics from DMA
38 PT XLSMART Telecom Sejahtera Tbk
Page 41
Connecting Indonesia:
One Purpose - One Planet
STRATEGIC FOCUS AREAS
As a result of the assessment process, XLSMART consolidated its priorities into 5 (five) strategic focus areas. These
focus areas translate material topics into clear management intent and execution priorities. The focus areas presented
below are interconnected and carry equal strategic importance in guiding the Company’s sustainability approach.
Focus Area Strategic Intent
Community Development Strengthen local ecosystems through digital inclusion and access to education.
Best Place to Work Build a unified culture, enhance skills, and improve employee experience.
Customer Engagement Elevate accessibility, affordability, and digital literacy to strengthen trust.
GHG Emissions Establish decarbonisation and energy-efficiency pathways.
Data Privacy & Security Strengthen cybersecurity maturity and regulatory compliance readiness.
Sustainability Commitment of XLSMART
[GRI 2-22] [GRI 2-24]
Sustainability at XLSMART is embedded into how Waste to Landfill practices at selected large-scale
we create value, manage risk, and sustain long- events demonstrates that sustainable operations must
term competitive advantage, while advancing our be measurable, operationally feasible, and extend
purpose to connect every Indonesian for a better life. beyond office environments into broader ecosystem
Our approach integrates environmental stewardship, engagement.
social empowerment, and strong governance as
interconnected pillars that reinforce operational In the social dimension, XLSMART translates
resilience and enable inclusive growth. This integrated digital connectivity into meaningful inclusion and
framework reflects our commitment to accelerating empowerment. We invest in digital literacy and
the transition toward carbon neutrality in parallel with capability-building programs designed to expand
responsible digital innovation. access and opportunity across diverse communities.
Through initiatives such as digital literacy workshops
In the environmental dimension, we recognise and partnerships that support students, micro, small,
the scale and reach of our telecommunications and medium enterprises (MSMEs), and underserved
operations and the climate challenges associated populations, we promoted more equitable participation
with energy-intensive infrastructure. XLSMART is in Indonesia’s digital economy.
committed to progressing toward net-zero emissions
by embedding environmentally responsible innovation Our inclusion efforts extend to targeted programs that
into our business model. We strengthen operational empower women, support people with disabilities,
efficiency across network and facility assets, and expand affordable digital access in frontier and
implement targeted energy-saving initiatives, and rural areas. These initiatives contribute to narrowing
pursue scalable renewable energy solutions where the digital divide and fostering broader societal
feasible. Carbon emissions and energy consumption participation in economic and social development,
are monitored systematically to inform investment reinforcing our commitment to an inclusive and future-
decisions, operational priorities, and performance ready digital ecosystem.
management. This disciplined approach aligns
environmental management with our broader net- In the governance dimension, XLSMART upholds
zero ambitions, supporting continuous improvement, high standards of integrity, transparency, and
enhanced accountability, and responsible value chain ethical conduct across all operations and business
engagement. relationships. We apply a zero-tolerance approach
to bribery and corruption, ensure compliance with
Climate action is further reinforced through practical applicable laws and regulations, and set clear
initiatives that integrate sustainability into day-to-day expectations for third parties and suppliers regarding
operations. For example, the implementation of Zero ethical conduct, labour standards, and responsible
2025 Sustainability Report 39
Page 42
Framework for Accelerating
the Sustainability Journey
business practices. These expectations encompass Collectively, these commitments support our strategic
respect for human and labour rights, including non- priorities and respond to stakeholder expectations,
discriminatory practices and the prohibition of child and while reinforcing how sustainability contributes to
forced labour throughout our supply chain. Governance XLSMART’s long-term value creation. By integrating
effectiveness is reinforced through structured oversight, environmental responsibility, social inclusion, and
continuous communication, capability development, strong governance into everyday decision-making,
and accountability mechanisms to ensure sustainability we enhance operational resilience, enable inclusive
principles are consistently understood, implemented, growth, and contribute meaningfully to national
and monitored across the organisation. development objectives through credible and
measurable sustainability performance.
XLSMART’S ESG Roadmap
As a post-merger organisation, XLSMART is integrating In 2026, XLSMART will undertake a baseline and
the ESG foundations of both legacy entities into a single, re-baseline process for key ESG metrics, including
unified direction. The roadmap is being refined to ensure climate-related indicators. While XL Axiata previously
that sustainability governance, programmes, and established a baseline in 2022, the merger requires the
performance management remain consistent during development of a refreshed, consolidated baseline that
the transition, while strengthening alignment with the reflects the full operational footprint of XLSMART. This
Company’s updated Double Materiality Assessment re-baseline will serve as the reference point for future
(DMA) and evolving disclosure expectations. target setting.
The five DMA focus areas provide a structured lens for In 2027, the Company plans to finalise its roadmap
prioritisation and management oversight. In 2025, the towards Net Zero Carbon by 2050, alongside the
Company focused on integrating ESG data, policies, development of ESG KPIs and performance targets
and reporting practices from both legacy organisations aligned with the consolidated baseline and DMA
to establish a consolidated foundation. As this is the outcomes. This phased approach ensures that long-
first year of post-merger consolidation, emphasis is term ambitions are supported by credible data,
placed on integration and comparability rather than structured governance, and measurable performance
performance variance. indicators.
During this transition phase, sustainability execution
is guided by three integration enablers that ensure
consistency across the merged organisation:
Good Corporate
Environmental Care Social Responsibility Governance
Digital innovation to support Commitment to responsible Commitment to strong and
XLSMART’s net-zero carbon digitalisation that creates effective corporate governance
mission positive social impact
40 PT XLSMART Telecom Sejahtera Tbk
Page 43
Connecting Indonesia:
One Purpose - One Planet
These enablers support consistent execution and governance while the consolidated ESG roadmap and KPI
architecture are being formalised.
WHAT WE HAVE DONE FOR OUR HOMELAND
Received a Sustainable Fitch ESG Entity Rating of “2” with an ESG score of 67 for the 2025
Sustainable Fitch ESG
performance. The rating reflects a good sustainability profile, supported by the
Rating
environmentally and socially positive impact of fibre and 4G network services.
Sustainability Week Successfully diverted 120 kg of employee fashion waste into upcycled products in 2025,
Program transforming unused materials into meaningful solutions.
Waste Management A total of 31,219 tonnes of waste were diverted from landfill across XLSMART offices in
Program Kuningan, Sabang, and BSD, supporting more responsible daily operations
Zero Waste to Landfill Achieved 3,839 kg CO2e emission avoidance during the AXIS Nation Cup 2025, engaging
Event 11,000 spectators in a collective zero-waste initiative.
Net Zero Carbon by 2050
XLSMART has set a long-term ambition to achieve Net Zero Carbon by 2050, in line with global climate objectives
and the decarbonisation pathway of the telecommunications sector. This commitment reflects our recognition that
climate change presents both physical and transition risks for a capital-intensive and energy-dependent business
such as ours, while also creating opportunities to improve operational efficiency, strengthen resilience, and align with
evolving investor and regulatory expectations.
The progress we have made toward achieving this ambition is supported by a structured approach to carbon
management, transparency, and external validation. In 2025, XLSMART received a “B” score from the Carbon
Disclosure Project (CDP) for the third consecutive year, demonstrating consistent performance in disclosure
and climate management practices.
As a merged entity, XLSMART will conduct a baseline and re-baseline process in 2026, taking into account the
legacy baseline established in 2022 and the expanded operational footprint following the merger. This consolidated
baseline will provide the foundation for finalising the roadmap towards Net Zero Carbon by 2050 and defining
supporting ESG targets and KPIs, which are planned to be completed in 2027.
Our Journey Towards Net Zero
Our decarbonisation journey has evolved progressively, marked by continuous emissions measurement, governance,
and strategic alignment with national and global climate initiatives.
2025 Sustainability Report 41
Page 44
Framework for Accelerating
the Sustainability Journey
Initiated the calculation of greenhouse gas emissions, covering direct operational activities and electricity
2019
consumption, as the first step toward establishing a comprehensive emissions baseline.
Adopted ESG principles with reference to GSMA climate commitments, aligning the Company’s long-term
2021
direction with the sector’s ambition to achieve net zero emissions by 2050.
Received recognition at the 2022 Corporate Emission Reduction and Calculation Transparency event, securing
2022
awards in both the Gold and Green categories.
Advanced our climate management framework through several key milestones:
· Joined the Kadin Net Zero Hub, as a platform for knowledge exchange, collaboration, and resource sharing to
support the development of a low-emissions ecosystem in Indonesia and the national Net Zero 2050 ambition.
· Strengthened the Green Smart City ecosystem by deploying solutions based on Artificial Intelligence (AI),
Internet of Things (IoT), and Connectivity.
2023 · Calculated Scope 3 carbon emissions for the first time, as an initial step toward defining emissions reduction
pathways beyond direct operations.
· Submitted climate disclosures to CDP for the first time and achieved a “B” score, signalling a solid foundation
in climate governance and transparency.
· Undertook external assurance of Scope 1 and Scope 2 greenhouse gas emissions and total energy consumption
for the 2023 and 2024 reporting years.
Maintained a “B” score in CDP, demonstrating consistency in climate disclosure quality and management
2024
practices, supported by continued external assurance of Scope 1, Scope 2, and total energy consumption data.
Received a Sustainable Fitch ESG Entity Rating of “2” with an entity score of 67 for the 2025 performance. The
2025 assessment also acknowledged the Company’s climate-related disclosures, including greenhouse gas emissions
and energy management practices, supporting continued progress in strengthening climate governance.
Initiatives For Sustainable Future
XLSMART’s decarbonisation commitment is translated into concrete actions, with a primary focus on reducing
emissions from electricity consumption, which represents the largest share of the Company’s carbon footprint.
Our transition strategy is anchored in three levers: improving energy efficiency across network and facility assets,
increasing the use of renewable energy, and engaging the value chain to support the development of a lower-carbon
ecosystem.
In the short to medium term, priority is given to Scope 2 emissions reduction through operational efficiency and
clean energy deployment. One of the key initiatives is the installation of solar photovoltaic systems at selected Base
Transceiver Station (BTS) sites, which directly reduces reliance on grid electricity and lowers operational emissions
intensity. By 2025, solar panels had been installed at 259 BTS locations across Indonesia, contributing to the
achievement of an emission intensity reduction target of 80 kg CO₂ per terabyte of data traffic.
2025 Target
Reduce emissions intensity to
Initiatives
Installation of solar panels at
80kg CO2/TB 259
locations Base Transceiver Station (BTS)
across Indonesia.
Status : Achieved above target
Beyond operational measures, XLSMART recognises that long-term decarbonisation cannot be achieved without
value-chain engagement. Towards 2030, the Company is strengthening collaboration with strategic suppliers
and partners, particularly high-spend vendors, to align emission reduction efforts, improve data transparency,
and encourage the adoption of low-carbon practices across the supply chain. This approach supports the gradual
extension of climate action from direct operations to upstream and downstream activities, in line with the Company’s
preparation for Scope 3 target setting.
42 PT XLSMART Telecom Sejahtera Tbk
Page 45
Connecting Indonesia:
One Purpose - One Planet
2030 Target
Reduce emissions intensity to
Initiatives
Engage 100% of top
45% spenders
including suppliers and partners to support
the net zero emission ambition
Status : Ongoing
These initiatives form part of a broader transition pathway that aligns with global climate goals and Indonesia’s
Net Zero 2060 agenda, while also responding to increasing investor and regulatory expectations for credible,
measurable, and verifiable climate action.
Strengthening the Culture of
Sustainability [OJK F.1] [GRI 2-24]
Sustainability transformation is shaped by 5. Accelerating the digitalisation of business processes
organisational culture, leadership commitment, to reduce resource intensity, improve operational
and active employee participation. Embedding efficiency, and support more sustainable ways of
sustainability into daily behaviour is essential to ensure working.
that policies, targets, and operational standards are 6. Providing structured sustainability-related
consistently translated into measurable practices training and learning programs to strengthen
across the Company. employees’ understanding of ESG principles,
climate responsibility, ethical conduct, and their
To enable this, XLSMART integrates sustainability roles in supporting the Company’s sustainability
principles into day-to-day business activities and commitments.
builds awareness among employees through multiple
channels, including: XLSMART SUSTAINABILITY ACTIVITIES
1. Leveraging internal and external digital
communication channels to disseminate XLSMART’s sustainability activities demonstrate the
sustainability-related content, covering ESG topics, Company’s commitment to embedding environmental
climate action, and social impact, supported by and social responsibility into daily operations and
regular sustainability newsletters and thematic organisational culture. Throughout 2025, these
campaigns. activities served as practical platforms to build
2. Organising Sustainability Talks through in-person awareness, encourage behavioral change, and
and hybrid forums featuring internal leaders and reinforce employee ownership of the ESG agenda. Key
external experts to discuss key sustainability issues, initiatives during the year included:
best practices, and emerging trends relevant to the 1. Waste Management Race, a monthly program
telecommunications industry. conducted across office to encourage improved
3. Implementing behavioural activation initiatives in waste segregation and responsible disposal
the workplace, such as recycling drop boxes on practices.
office floors, sustainability education content on 2. Upcycling Workshop, creative sessions where
internal platforms, periodic audio announcements employees transform unused materials into
on energy efficiency and emissions reduction, and functional products while learning about waste
visual ESG messaging through digital backgrounds reduction and sustainable consumption.
and office communication media. 3. Employee Sustainability Engagement programs,
4. Launching internal sustainability campaigns that collaborative activities that involve employees
promote responsible resource use and low-impact directly in sustainability initiatives and reinforce
work practices, including digitalisation to reduce shared ownership of the company’s ESG agenda.
paper consumption, water-saving initiatives, and
other environmental awareness programs.
2025 Sustainability Report 43
Page 46
Framework for Accelerating
the Sustainability Journey
4. Sustainability Week Talk show, an interactive series The same standards are applied beyond internal
featuring internal and external speakers discussing operations. The implementation of a Zero Waste to
sustainability challenges, green innovation, and the Landfill approach at the AXIS Nation Cup 2025, in
role of employees in driving positive change. collaboration with Waste4Change, demonstrates how
5. Sustainability Week Exhibition, showcasing internal sustainability discipline extends to large-scale
environmental initiatives, eco-friendly innovations, public events. Through systematic waste segregation,
and the Company’s commitment to building more recycling, composting, and conversion into Refuse-
sustainable operations. Derived Fuel, around 4,200 kilograms of waste were
6. Zero Waste to Landfill Implementation, applied diverted from landfill, resulting in an estimated 3,839
at selected large-scale events to strengthen kg CO₂e in avoided emissions. This underscores that
responsible waste management practices and sustainability is treated as an operational requirement,
minimise landfill impact. not merely an internal campaign.
7. Post-Merger E-Waste Management Programme,
initiated to ensure responsible handling, segregation, In addition, 2025 marked the initiation of a post-merger
and environmentally sound disposal of electronic electronic waste (e-waste) management programme,
equipment and network-related assets across the designed to ensure responsible handling, segregation,
consolidated organisation. and disposal of electronic equipment and network-
related assets across the consolidated organisation.
These activities form a coherent pathway for This programme strengthens lifecycle management
embedding sustainability into the way employees practices and supports compliance with environmental
work and make decisions. They begin with awareness- standards in line with the Company’s expanded
building, progress toward behavioral change, and are operational footprint.
ultimately reflected in operational practices and event
executions. Creative platforms such as EcoFusion Sustainability
Week further strengthen this connection by linking
At the employee level, initiatives such as Sustainability environmental issues to everyday contexts, including
Week, the Waste Management Race, and upcycling fashion, lifestyle, and consumption. The diversion of
workshops function as learning and activation approximately 120 kilograms of textile waste through
platforms. In 2025, Sustainability Week engaged upcycling activities and the strong level of participation
hundreds of employees through talk shows, exhibitions, reflect a shift from awareness to consistent practice.
and interactive sessions that combined knowledge-
sharing with practical action. Programs like the Waste Through this progression, from awareness to culture,
Management Race and creative workshops encourage XLSMART reinforces a shared understanding that
everyday practices such as waste segregation, resource sustainability is integral to how employees take
efficiency, and responsible consumption, helping to responsibility in their respective roles. What begins
transform sustainability from policy into habit. as communication and engagement evolves into
daily habits and is reflected in operational execution.
As these behaviours become embedded, sustainability This cultural foundation is critical to ensuring
principles are increasingly integrated into workplace that XLSMART’s sustainability commitments are
systems and operational processes. This is reflected consistently implemented and sustained over the long
in ongoing efforts to optimise energy use in data term.
centres and network facilities, strengthen electronic
and operational waste management, and promote
environmentally responsible practices across offices
and business units.
44 PT XLSMART Telecom Sejahtera Tbk
Page 47
Connecting Indonesia:
One Purpose - One Planet
Contributions to the Sustainable
Development Goals (SDGs) [OJK F.25]
XLSMART aligns its sustainability programs with the United Nations Sustainable Development Goals (SDGs) as a
globally recognised reference framework. This alignment ensures that the Company’s digital expansion, social
investment, and community engagement initiatives contribute to inclusive growth, social resilience, and Indonesia’s
long-term national development priorities. Through this alignment, the SDGs provide an overarching structure that
connects XLSMART’s material sustainability priorities with global development objectives, reinforcing the relevance,
coherence, and impact of the Company’s sustainability strategy.
Material Focus Area Strategic Relevance Aligned SDGs
Network quality, availability and Enabling inclusive digital infrastructure, economic
reliability participation, and service continuity across regions
Data security, privacy and Protecting digital rights, customer trust, and institutional
cybersecurity integrity in the digital economy
Digital inclusion, accessibility Expanding equitable access to education, information, and
and affordability economic opportunity
Employment practices, talent Building future-ready human capital and inclusive, resilient
development, health and workplaces that support performance, engagement, and
wellbeing long-term organisational sustainability
GHG emissions, energy Supporting the transition to low-carbon operations and
efficiency and climate resilience climate-resilient infrastructure
Waste management and Reducing environmental footprint while strengthening
circular economy resource efficiency across operations and the value chain
Community development and Strengthening social resilience through and inclusive
stakeholder engagement collaboration and long-term development partnerships
2025 Sustainability Report 45
Page 48
Message from
the Board of Directors
46 PT XLSMART Telecom Sejahtera Tbk
Page 49
Connecting Indonesia: One Purpose - One Planet About XLSMART 2025 Sustainability Report 47
Page 50
About
XLSMART
Corporate Information [GRI 2-1]
PT XLSMART Telecom Deed of establishment No. 55 dated 6 October 1989, as
Sejahtera Tbk (formerly amended by Deed No. 79 dated 17 January 1991, both of
PT XL Axiata Tbk) which were drawn up before Rachmat Santoso, S.H.,
COMPANY LEGAL Notary in Jakarta, and have been ratified by the Minister of
NAME The name change STATUS Justice of the Republic of Indonesia by virtue of his Decree
became effective as of 21 No. C2-515. HT.01.01.TH.91 dated 19 February 1991, and
April 2025 following the registered in Company Register maintained by the Registry
completion of PT XL Office of South Jakarta District court under No. 670/
Axiata Tbk’s merger with Not/1991/PN. JKT.SEL and No. 671/Not/1991/PN.JKT.SEL,
PT Smartfren Telecom both dated 21 August 1991, and published in the State
Tbk and PT Smart Gazette of the Republic of Indonesia No. 90 dated 8
Telecom on 17 April 2025. November 1991, Supplement No.4070.
Axiata Investment (Indonesia) Sdn. Bhd. is a subsidiary of the Axiata Group Berhad, the largest
telecommunications company in Asia, which also owns Celcom (Malaysia), Dialog (Sri Lanka),
Robi (Bangladesh), Smart (Cambodia), Ncell (Nepal), Idea (India), and M1 (Singapore).
SHARE
OWNERSHIP XLSMART’s Shareholding Percentage:
33.19% 34.691%
Axiata Investments (Indonesia) Sdn. Bhd
PT Bali Media Telekomunikasi
PT Wahana Inti Nusantara
PT Global Nusa Data
Public 4.663%
24.568%
2.847%
EXCL
TICKER SEGMENT
CODE BRAND
XLSMART works closely with a diverse network XLSMART Tower
of vendors to ensure that the goods and Jl. H.R. Rasuna Said X5 Kavling 11-12
services supporting its operations are delivered East Kuningan, Setiabudi, South/Selatan
SUPPLY reliably and efficiently. The Company requires ADDRESS Jakarta, 12950 Indonesia
CHAIN all suppliers to uphold sustainability principles [C.2]
[GRI 2-6] and responsible sourcing as outlined in its
procurement policy. Below is XLSMART’s top
three supply chains/vendors based on
purchase order value in 2025:
+622157959817
1. PT Huawei Tech Investment
PHONE +62215761880
2. PT Lintas Teknologi Indonesia
3. PT Nokia Solutions and Networks Indonesia NUMBER
corpsec@xlsmart.co.id @xlsmart @xlsmart
EMAIL
MEDIA @xlsmart @xlsmart
SOCIAL
@xlsmart
https://www.xlsmart.co.id/
WEBSITE
PT XLSMART Telecom Sejahtera Tbk
48 PT XLSMART Telecom Sejahtera Tbk
Page 51
Connecting Indonesia:
One Purpose - One Planet
Significant Changes in the Company
[C.6]
On 15 April 2025, PT XL Axiata Tbk (XL), PT Smartfren Telecom Tbk (SF), and PT Smart Telecom (ST) signed the
Merger Deed No. 33 dated 15 April 2025, where SF and ST agreed to merge with XL as the surviving company, and
therefore, SF and ST status cease to exist by operation of law (Merger).
As part of the Merger, there are several amendments in XL’s Articles of Association, including the change of name
of XL to PT XLSMART Telecom Sejahtera Tbk. These changes in the Articles of Association have become effective
with the obtainment of approval and/or notification receipt from the Minister of Law of the Republic of Indonesia
(MOL) as follows: (i) Decision of MOL on Approval of Amendments to the Articles of Association of the Company
No. AHU-0026805.AH.01.10.TAHUN 2025 dated 16 April 2025, (ii) Receipt of Notification of Amendments to the
Articles of Association of the Company by MOL No. AHU-AH.01.03-0102806 dated 16 April 2025, and (iii) Receipt
of Notification of Amendments to the Articles of Association of the Company by MOL No. AHU-AH.01.03-0104486
dated 17 April 2025.
2025 Sustainability Report 49
Page 52
About
XLSMART
Purpose, Vission, and Core
Values [C.1]
As a newly unified entity, XLSMART is charting a path toward a more connected and sustainable
Indonesia. Drawing on the shared aspirations of its founding companies, the Company seeks to
enrich digital experiences while creating long-term value for customers, employees, society, and
the environment. Every step of XLSMART’s transformation is guided by excellence, inclusivity, and
innovation, thus ensuring that growth goes hand in hand with social and environmental responsibility.
PURPOSE
We connect every Indonesian for a better life
The reason XLSMART exists is to be fully Vision and Purpose Review
committed for Indonesians to live beyond The Board of Directors regularly reviews the
through connectivity. With excellence Company’s Vision and Purpose to ensure
commitment, excellence innovation to products their continued alignment with XLSMART’s
and services, we believe we are able to improve current business conditions, strategic
and empower the quality of life of individuals, direction, and long-term sustainability
communities, and social well-being. objectives.
VISION
By 2027, to be Indonesia's Most Loved Company for our customers, the best place to
work for our people, and the most efficient service provider.
01 02 03
To be Indonesia’s most loved Best place to work for our At the same time, to be
company for our customers. people where our employees the most efficient service
Being innovative and going can thrive, grow, and provider by being resourceful
above and beyond to deliver perform in a supportive and and driving for maximum
the best experience for our nurturing culture. By doing so, growth and profitability to
customers, so that they love attracting and retaining the ensure business sustainability
us, trust us, choose for us, be best talent. in the long run.
loyal to us, and recommend
us to their loved ones.
50 PT XLSMART Telecom Sejahtera Tbk
Page 53
Connecting Indonesia:
One Purpose - One Planet
CORE VALUES
Integrity
Integrity is a non-negotiable foundational value. It’s a licence to play for
participation in XLSMART.
Strive to deeply
understand customer
needs through active
listening and continuous
improvement, in order to Embrace diverse
deliver the best possible perspectives, opinions,
experience for our and feedback are
customers. welcomed and valued,
enabling effective
e r collaboration to grow
o m
st t
and win together.
CuHear
at
L ike e as
t
Ac ners Rise
Ow On
Responsibilities are
carried out end-to-end
to achieve excellent
results, wholeheartedly
very A joyful work environment
E
joy
and efficiently to achieve is created by simplifying
the best outcomes for n
E p complexities and building
Ste
XLSMART. positive energy, while
victories are consistently
celebrating wins and
learn from mistakes
together.
2025 Sustainability Report 51
Page 54
About
XLSMART
XLSMART at A Glance [C.1]
From Legacy to Leadership: The Journey to XLSMART
Our journey began more than three decades ago with on the 1,800 MHz spectrum. The Company further
the establishment of PT Graha Metropolitan Lestari strengthened its convergence leadership through
on 6 October 1989, marking our first commercial certifications as Content Provider, Internet Service
venture as a trading and general services company. Provider (ISP), Internet Interconnection Services,
In 1996, the Company made a strategic leap into the VoIP, and Leased Line License, while also securing an
telecommunications sector after obtaining a GSM 900 Operational Eligibility Certificate (SKLO) that enabled
operating license, becoming Indonesia’s first private the commercial deployment of 5G in August 2018.
cellular mobile operator to launch GSM services and
provide cellular mobile telephony services. As digital connectivity becomes the foundation of
progress, we continue to serve a pivotal role in enabling
An agreement between the Rajawali Group and three people and businesses to thrive in the digital era. The
international investors (NyNEX, AIF, and Mitsui) brought Company expands access to high-speed and reliable
new momentum to the Company’s growth, leading to networks across the archipelago through continuous
a rebranding as PT Excelcomindo Pratama. Driving investment in advanced technologies, including
further expansion, the Company reached a significant 4.9G (Massive MIMO), ensuring that communities
milestone in September 2005 by becoming a publicly beyond Java have access to the same quality of digital
listed company through an Initial Public Offering (IPO) experience as those in major cities.
on the Jakarta Stock Exchange (now the Indonesia
Stock Exchange/IDX). Innovation remains at the heart of our growth. The
Company continues to strengthen its digital capabilities
At the time of the IPO, the Company was a subsidiary through the integration of Artificial Intelligence (AI) and
of Indocel Holding Sdn. Bhd., now known as Axiata data analytics to deepen customer understanding,
Investments (Indonesia) Sdn. Bhd., a fully-owned enhance network performance, and deliver more
entity of TM International Sdn. Bhd. (TMI) through TM personalized solutions that meet diverse needs. These
International (L) Limited. The synergy with our Malaysia- endeavours not only drive engagement but also
based holding brought strategic alignment and regional reinforce XLSMART’s position as a leading convergence
strength. In 2009, following TMI’s transformation into operator in Indonesia.
Axiata Group Berhad, the Company changed its name
to PT XL Axiata Tbk. To safeguard this expanding digital ecosystem,
XLSMART leverages cloud technology to build a
In Indonesia, the Company built a strong presence more secure and resilient operational framework. Our
across both retail and corporate segments, providing cybersecurity and fraud management systems are
Data, Voice, SMS, and a wide array of digital solutions continuously enhanced to ensure the integrity, reliability,
with nationwide coverage. Operating on GSM 900/ and trustworthiness of every digital interaction thus
DCS 1800 and IMT-2000/3G, the Company became a reflecting our commitment to safe, efficient, and
pioneer by commercially launching 4.5G Ready services inclusive connectivity for all.
52 PT XLSMART Telecom Sejahtera Tbk
Page 55
Connecting Indonesia:
One Purpose - One Planet
XLSMART: A New Force in Indonesia’s Digital Future
Building upon a strong foundation of innovation and possibilities that reflect XLSMART’s commitment to
connectivity, 2025 marked a historic transformation expanding horizons across Indonesia and beyond.
as PT XL Axiata Tbk, PT Smartfren Telecom Tbk, and Carrying the tagline “Bersama, Melaju Tanpa Batas”
PT Smart Telecom officially united under the name: PT (“Go Beyond, Together”), XLSMART embraces the
XLSMART Telecom Sejahtera Tbk. The merger signifies spirit of collaboration while also inviting customers,
not only a consolidation of resources and expertise but communities, and partners to journey forward as one
also the realization of a unified vision to accelerate in creating meaningful connections and empowering
Indonesia’s digital future. Through this integration, every Indonesian for a better life.
XLSMART is all set to deliver inclusive, intelligent, and
sustainable digital experiences for customers across XLSMART brings together the complementary
the nation. strengths of XL Axiata and Smartfren under a unified
leadership and shared aspirations. The Company
As part of this transformation, XLSMART unveiled continues to operate the well-established XL, AXIS, and
a new corporate identity that redefines its vision Smartfren brands for mobile cellular and broadband
and purpose for the digital era. The Infinity World services, while serving SMEs and corporate clients
logogram represents limitless connectivity and endless through XLSMART for Business. With over 94.5
opportunities, symbolizing a dynamic gateway to new million customers, each connection matters, and we
are committed to delivering transformative digital
experiences.
2025 Sustainability Report 53
Page 56
About
XLSMART
Our Transformation
1989 1991 1996 1998
Established on 6 Changed its name Received a GSM 900 Introduced the proXL
October 1989 under to PT Graha Cellular System brand as the Company’s
the name PT Graha Metropolitan license and first prepaid product.
Metropolitan Lestari. commenced
Lestari, the commercial
Company initially operations, initially 2000
operated as a 1995 targeting Jakarta,
Successfully expanded
trading and general Bandung, and
Changed its operations to Sumatra
services enterprise. Surabaya.
name to PT and Batam.
This foundation later
Excelcomindo
became the
Pratama through
stepping stone for
its future
a partnership 1997 2001
with the Rajawali
transformation into Constructed • Secured DCS 1800
Group and
a major an integrated spectrum allocation.
foreign
telecommunications microcell • Completed
investors—
operator in network construction of the
NyNEX, AIF, and
Indonesia. within primary fiber-optic
Mitsui.
Jakarta’s network.
Golden • Launched M-Banking
Triangle area. and M-Fun services.
2010 2013 2015
• Launched LTE services on the
Axiata Investments • Entered into a
1,800 MHz band, extending
(Indonesia) Sdn. Bhd., the Conditional Sale and
coverage to 35 cities.
Company’s principal Purchase Agreement
• Became the first
shareholder, divested a 20% (CSPA) with Saudi
telecommunications operator
stake via Private Placement to Telecom Company
in Indonesia to commercially
increase public shareholding. (STC) and Teleglobal
introduce 4.5G-ready
Investment B.V. (a
technology on this spectrum,
subsidiary of STC) to
strengthening its leadership in
2009 acquire PT Axis
mobile broadband.
Telekom Indonesia
• Initiated the first Limited (AXIS).
Public Offering through a • Successfully tested
Rights Issue for
1,418,000,000 new shares.
4G technology during 2014
the APEC Summit.
• TM International Sdn. Bhd. • Completed acquisition of AXIS in
officially rebranded as Axiata March and effected a merger in April.
Group Berhad (“Axiata”), and • Conducted live 4G-LTE trials with
PT Excelcomindo Pratama
Tbk adopted the new name PT
2012 Huawei and Ericsson.
• Implemented corporate rebranding,
XL Axiata Tbk to reflect a • ETISALAT divested 9.1% including an updated logo to reflect a
unified identity and synergy of its shares through an new strategic direction.
within the Group. The majority offering to institutional • By this time, XL Axiata had evolved
of shares were subsequently investors, increasing into a major nationwide operator
owned by Axiata through public ownership from providing data, voice, SMS, and
Axiata Investments 20.2% to 33.5%. various value-added services across
(Indonesia) Sdn. Bhd. • Deployed more than Indonesia through its GSM 900/DCS
11,000 new BTS to 1800 and IMT-2000/3G networks.
strengthen network
coverage.
54 PT XLSMART Telecom Sejahtera Tbk
Page 57
Connecting Indonesia:
One Purpose - One Planet
2005 2007
Became a subsidiary of TM • Introduced an Rp1 per second tariff.
Group and successfully • ETISALAT, the Middle East’s second-
conducted an Initial Public largest telecommunications company,
2002 Offering of 1,427,500,000 acquired a stake in XL Axiata.
• Obtained network allocation shares on the Indonesian • Began consolidating brands under the
for Kalimantan and Sulawesi. Stock Exchange (formerly XL Prepaid and XL Postpaid banners.
• Launched leased-circuit and Jakarta Stock Exchange)
Internet Protocol (IP) services. under the ticker EXCL. The
listing marked the Company’s 2008
transition to a public entity
• Following TM Group’s demerger, two
and demonstrated market
entities were formed: Telekom Malaysia
2004 confidence in its long-term
Berhad and Axiata Group (formerly TM
growth potential.
Rebranded the corporate International Berhad), with Axiata
identity and expanded the Group becoming parent to Indocel
proXL product family, Holding Sdn. Bhd. via TM International
introducing Jempol (L) Limited.
(prepaid), Bebas
2006 • Axiata Group, through Indocel Holding
(prepaid), and Xplor Launched 3G network Sdn. Bhd., acquired the Company’s
(postpaid). services. shares from Khazanah Nasional
Berhad, resulting in an 83.8%
ownership interest by year-end.
2017 2018 2019
• Expanded the network to 101,000 BTS, • Commenced operation of • Completed the Australia–
with 63% of new deployments supporting Universal Service Indonesia–Singapore
3G and 4G technologies. Obligation (USO) network submarine cable system
• Extended 4G LTE coverage to 360 cities/ services in 40 locations in collaboration with
regencies, supported by over 17,000 4G across four provinces. Vocus Group and Alcatel
BTS and 45,000 3G BTS. • Launched Laut Submarine Networks.
• Executed a Conditional Sales and Purchase Nusantara, an application • Expanded the network
Agreement to divest the Company’s shares developed in collaboration footprint to 130,000 BTS,
in PT XL Planet (Elevenia) and SK Planet with government including over 40,000
Global Holdings Pte. Ltd. ministries and 4G-enabled sites.
• Collaborated with the Ministry of organizations to enhance • Princeton Digital Group
Communication and Information on the fishermen’s productivity (PDG) agreed to acquire a
Fishermen Go Online program via the and safety. 70% stake in the
Nelayan Pintar (Smart Fishermen) • Inaugurated the IoT Lab Company’s data center
application. XCAMP in partnership with portfolio.
• Participated in the construction of the the Ministry of • Commercially launched
Australia–Indonesia–Singapore Communication and Narrowband IoT (NB-IoT)
submarine cable communication system, Information and the across 31 cities/
connecting Australia and Singapore via Ministry of Industry. regencies.
Indonesia. • Earned the Certificate of • Extended USO coverage
Operational Eligibility to 298 locations across
(SKLO) for 5G network multiple provinces.
2016 deployment, marking an
important step toward
• Deployed additional BTS
in remote areas including
• Expanded to 84,000 BTS, including commercial readiness for Natuna (Riau Islands),
approximately 8,200 4G BTS, providing next-generation Musi Rawas (South
coverage to nearly 100 cities. connectivity. Sumatra) and the west
• Completed a fully subscribed public coast of Lampung.
offering raising USD500 million.
2025 Sustainability Report 55
Page 58
About
XLSMART
2020
• Announced a share buyback program of Rp500 billion, executed from 7 April to 6 July 2020.
• Partnered with Google Cloud to migrate workloads and implement Anthos for a secure hybrid multi-cloud
application management platform.
• Adopted SAP S/4HANA Cloud, becoming the first telecommunications company in Southeast Asia to implement this
cloud ERP solution.
• Supported government ministries and agencies with donations and programs to assist communities adapting to the
COVID-19 pandemic.
• Supported a government initiative to extend 4G services to 861 non-3T villages for the 2021–2022 period.
2021
• Attained ISO/IEC 20000-1:2018 and ISO 9001:2015 certifications.
• Entered a partnership with Helios Data (California) to implement Secure Data Sharing technology.
• Began USO BTS operations in collaboration with the Telecommunication and Information Accessibility Agency
(BAKTI) in locations including Musi Rawas and North Musi Rawas (South Sumatra).
• Partnered with FiberStar to expand the XL HOME fiber network.
• Collaborated with NTT Ltd. to deploy private cloud infrastructure in preparation for the 5G ecosystem.
• Launched XL SATU, Indonesia’s first convergence service integrating XL HOME and XL Prepaid.
• Extended 4G coverage to 2,431 remote villages in Lampung province and expanded 4G services in Aceh to 193
districts and 5,102 villages.
• Attained the MEF-CE 3.0 International Certification through XL Business Solutions (Busol).
• Received Ministry of Communication and Informatics approval for operation feasibility testing of 5G network
services.
• Implemented the Zero-Touch Operation platform, including enhancements to Network Operation Centre (NOC)
capabilities.
• Supported national vaccination efforts by establishing the Indonesia Bangkit Vaccination Centre (drive-thru) in
Depok and continued vaccination initiatives at RSUP H Adam Malik in Medan; the Depok center was inspected by
President Joko Widodo, accompanied by Minister of Health, Budi Gunadi Sadikin, the Governor of West Java, Ridwan
Kamil, the Rector of Universitas Indonesia, Prof. Ari Kuncoro, S.E., M.A., Ph.D, and the Hospital Director, Dr. Astuti
Giantini.
• Advanced ESG commitments aligned with GSMA targets, including long-term commitments toward net-zero
emissions by 2050.
• Launched Desa Digital Nusantara (DDN) to facilitate digital technology adoption and empower villages.
• Dian Siswarini, President Director & CEO of the XL Axiata, and Yessie D. Yosetya, Chief Strategic Transformation & IT
Officer, attended the inauguration of the Indonesian G20 presidency in their capacity as chair of G20 Empower.
• Expanded VoLTE coverage to 403 cities and regencies.
2022
• Acquired 2,805 shares representing a 51% stake in PT Hipernet Indodata (telecommunications and IT managed
services), for approximately Rp358.438 billion.
• Completed the construction of Sea Cable Communication System (SKKL), linking Batam, Indonesia, to Sarawak,
Malaysia, also known as the Batam Sarawak International Cable System (BaSIC) in partnership with PP
Telecommunication Sdn. Bhd., strengthening international connectivity.
• Axiata Group Berhad and XL Axiata jointly acquired 66.03% of PT Link Net Tbk’s shares for approximately RM2.63
billion; XL Axiata subsequently held a 20% stake in Link Net.
• The Echo submarine cable system (“Golden Buoy”) was docked in Tanjung Pakis, Karawang, scheduled for
integration into XL Axiata’s network to enhance fiber backbone connectivity.
• Announced intention to issue XL Axiata Shelf Offering Bonds II Phase I of 2022 and Shelf Offering Sukuk Ijarah III
Phase I of 2022 for Rp1.5 trillion each.
• Convened an Extraordinary General Meeting of Shareholders (EGMS) to seek approval for a capital increase via a
Limited Public Offering III (LPO III) by pre-emptive rights.
• Collaborated with Link Net to introduce internet convergence services, integrating products from First Media and XL.
This collaboration encompasses high-speed internet services devoid of quota restrictions, streaming content, cable
TV, and online storage from First Media, coupled with the XL Joint Quota Package offering extensive internet data
services.
• Participated actively in Women20 and G20 Empower initiatives; resulting in the election of XL Axiata’s President
Director & CEO, Dian Siswarini, as Co-Chair of Women20 Indonesia, and the election of Director & Chief of Digital
Transformation & Enterprise Business Officer, Yessie D. Yosetya, as Chair of G20 Empower.
56 PT XLSMART Telecom Sejahtera Tbk
Page 59
Connecting Indonesia:
One Purpose - One Planet
2023
• Successfully completed the Capital Increase through Pre-emptive Rights III (“PMHMETD III”), generating proceeds
of Rp5 trillion to strengthen the Company’s financial position and support future growth initiatives.
• Advanced the implementation of ESG principles by deploying Green BTS on a large scale. This initiative included the
use of Intelligent Ventilation Cooling Systems (IVS), DC fans, and air conditioning systems that collectively reduced
energy consumption by up to 50%. The modernization program has encompassed more than 90% of XL Axiata’s
BTS network since its inception in 2014.
• Partnered with Cisco to enhance 5G and Cloud network readiness for the Internet of Things (IoT) through end-to-
end automation and optical network advancements, thereby strengthening IoT connectivity services across
Indonesia.
• Officially launched the e-SIM service, enabling customers to activate mobile connections without a physical SIM
card. The service offers a seamless registration process via QR code, providing convenience and flexibility for users
anywhere and anytime.
• Reinforced the strategic synergy between Axiata Group, XL Axiata, and Link Net to expand convergence services
nationwide. The initiative aims to reach 8 million home passes within five years and strengthen XL Axiata’s position
as Indonesia’s leading convergence operator by capitalizing on the low penetration of fixed broadband and the
rising demand for integrated digital solutions.
• Continued the development of SD-WAN+ solutions tailored for corporate clients, offering simplified deployment,
centralized management, and improved cost efficiency—ensuring sustainable value creation for businesses in an
increasingly digitalized global market.
• Introduced “XL SATU BIZ,” a high-speed internet service for small and medium-sized enterprises (SMEs), providing
robust Wi-Fi connectivity, generous data quotas, and a complimentary Majoo subscription that integrates ERP
software to enhance business efficiency and productivity.
• Strengthened internet infrastructure at the new capital city (IKN) by installing four units of Mobile 4G BTS in key
project areas, including the Presidential, Vice-Presidential Palaces, and around the workers’ mess. The IKN network
is connected to Kalimantan’s main infrastructure and the international link via the Batam–Sarawak–Entikong
submarine cable system.
• Collaborated with Link Net to develop one million new home-passed networks across more than ten cities and
regencies, including regions outside Java, marking a significant expansion of broadband connectivity in
underserved areas.
• Facilitated public mobility by ensuring 4G signal coverage across all Light Rail Transit (LRT) routes and stations in
Cibubur and Bekasi, supported by more than 2,300 4G BTS units.
• Consolidated the Company’s leadership in convergence services through the XL SATU product line. The upcoming
integration of Fiber To The Room (FTTR) technology will further enhance user experience, while service coverage
expanded to 63 cities and regencies, with Batam as the latest addition.
• Partnered with Nokia Indonesia to strengthen ESG initiatives in line with Indonesia’s national target of reducing
carbon emissions by 43.2% by 2030. Within its operational framework, the Company aims for a 45% carbon
emission reduction from the 2020 baseline by 2030.
• Successfully expanded 4G LTE coverage throughout the Jakarta MRT network, including all underground lines and
stations, ensuring seamless connectivity for passengers and enabling continuous monitoring to maintain service
excellence.
• Introduced green mining solutions through private networks that enable environmentally responsible mining
operations. By leveraging IoT-based fleet management and automation, the solution enhances efficiency, reduces
operational costs, and improves employee safety in hazardous areas.
• Partnered with Hipernet to launch Open Wi-Fi and Managed Wi-Fi services under XL SATU BIZ, empowering SMEs
with advanced digital infrastructure to support business growth.
• Extended 4G services to 861 outermost, underdeveloped, and frontier regions across Indonesia, fulfilling
government-mandated connectivity obligations.
• Received the Gold Flag certification for the Occupational Safety and Health Management System (SMK3) from
Indonesia’s Ministry of Manpower, recognizing the Company’s excellence in workplace safety management.
• Supported Axiata Group Berhad’s structural transformation initiative to accelerate the evolution of its Indonesian
subsidiaries, XL Axiata and Link Net, into a “ServeCo” and “FibreCo” framework to enhance strategic focus and
operational efficiency.
• Collaborated with Indosat Ooredoo Hutchison, Axiata Digital Labs, and Amazon Web Services (AWS) to launch the
SinergiAPI Portal—Indonesia’s first GSMA Open Gateway-based API platform—empowering developers with
standardized network API access through the Linux Foundation’s CAMARA project.
2025 Sustainability Report 57
Page 60
About
XLSMART
2024
• As part of the global GSMA Open Gateway initiative, XL Axiata, Telkomsel, Indosat Ooredoo Hutchison, and
Smartfren jointly launched three API services—Number Verify, SIM Swap, and Device Location—enhancing digital
security and customer experience across Indonesia’s telecommunications ecosystem.
• Achieved CDP certification following a rigorous five-month evaluation process by the global non-profit CDP
organization, underscoring XL Axiata’s steadfast commitment to ESG excellence and transparent environmental
disclosure.
• Signed a Memorandum of Understanding (MoU) with Huawei to establish a strategic collaboration focused on
Artificial Intelligence (AI) integration in digital business operations.
• Partnered with Cisco to introduce a cloud-delivered IoT connectivity management platform under the “IoT
Connectivity+” product, enabling customers to scale their IoT businesses securely and efficiently.
• In collaboration with Nokia, successfully concluded a five-year network modernization program encompassing
approximately 4,400 sites, involving comprehensive infrastructure replacement and network expansion.
• Through XL Axiata Business Solutions (XLABS), launched smart manufacturing solutions that utilize IoT technology
to support the digital transformation of Indonesia’s manufacturing sector by improving operational efficiency and
product quality.
• Entered a new phase of strategic development as Axiata Group and Sinar Mas signed a non-binding MoU to explore
a potential merger between XL Axiata and Smartfren, paving the way for the formation of “MergeCo”.
• Partnered with PT Mobil Anak Bangsa (MAB) through XLABS to deliver essential ICT services—including IoT and fixed
connectivity—supporting Indonesia’s growing electric bus industry and contributing to sustainable mobility.
• Strengthened cybersecurity capabilities by becoming the exclusive partner of ITSEC Asia in supporting DEFEND
IT360’s cybersecurity solutions tailored for SMEs, further expanding XLABS’ B2B service portfolio.
• Enhanced the XL Center Online platform with improved design, functionality, and service range under the
#JadiLebihBaik initiative, offering features equivalent to physical outlets such as eSIM registration, lost card
replacement, premium number selection, smartphone bundling, and streamlined ticket tracking.
• Expanded Fixed Mobile Convergence (FMC) network coverage to Sulawesi with the launch of XL SATU Fiber in
Morowali Regency, ensuring broader access to high-quality broadband services.
• Formed a partnership with PT Ide Inovatif Bangsa (Quest Motors) to integrate XLABS’ digital solutions into its electric
motorcycle platforms, supporting innovation in Indonesia’s green mobility ecosystem.
• Introduced “HYFE” by XL PRIORITAS, a new internet service package offering flexible options and enhanced user
experience to meet the evolving digital needs of customers.
• Opened a new office and XL Center in Balikpapan to reinforce service quality and network presence in East
Kalimantan, coinciding with XL Axiata’s 28th anniversary celebration.
• Reaffirmed the Company’s sustainability commitment during its anniversary celebration by achieving a Zero Waste
to Landfill event, in collaboration with Waste4Change for responsible waste management.
• Through XLABS, launched “XL Axiata HydroponiX,” an IoT-based smart farming solution designed to improve the
productivity and quality of hydroponic agriculture.
• Officially integrated First Media’s home internet services into XL Axiata effective 27 September 2024, following the
merger of Link Net and XL Axiata under a B2C business transfer agreement signed on 22 May 2024.
• On 11 December 2024, XL Axiata and Smartfren announced a strategic merger valued at approximately IDR104
trillion (US$6.5 billion), establishing PT XLSMART Telecom Sejahtera Tbk (“XLSMART”). This landmark merger
creates a leading telecommunications entity poised to drive innovation, elevate service quality, and accelerate
Indonesia’s digital transformation.
58 PT XLSMART Telecom Sejahtera Tbk
Page 61
Connecting Indonesia:
One Purpose - One Planet
2025
• On 25 March 2025, the EGMS approved the business merger between the Company, PT Smartfren Telecom Tbk
(“SF”), and PT Smart Telecom as outlined in the Merger Plan summary published on 11 December 2024 (as
supplemented and/or amended in accordance with applicable laws and regulations).
• On 16 April 2025, PT XLSMART Telecom Sejahtera Tbk (“XLSMART” or “IDX: EXCL”) marked its official establishment
as a unified telecommunications entity, born from the legal consolidation of PT XL Axiata Tbk, PT Smartfren Telecom
Tbk, and PT Smart Telecom. This landmark moment signifies the beginning of a bold new chapter in Indonesia’s
digital era, with XLSMART poised to redefine connectivity, drive innovation, and elevate customer experience across
the archipelago.
• XLSMART unveiled its new corporate identity featuring the Infinity World logogram, symbolizing limitless
connectivity and boundless innovation, alongside its inspiring new tagline, “Bersama, Melaju Tanpa Batas” (“Go
Beyond, Together”).
• Signed a strategic partnership agreement with two global technology companies, PT Huawei Tech Investment and
PT ZTE Indonesia, to support the management of national network operations as well as the development of
employee knowledge, competencies, and technological expertise in the fields of technology and digital innovation.
• For Smartfren brand, XLSMART officially expanded 4G LTE and VoLTE coverage to new regions, including the
Province of Aceh, the Bali Regencies of Gianyar, Klungkung, and Karangasem, as well as Kupang City in East Nusa
Tenggara, providing customers with faster and more reliable data access.
• Introduced “Sarah,” a virtual assistant powered by Generative AI (GenAI), as part of Smartfren Care’s digital
transformation. Sarah delivers faster, more personalized, and solution-oriented customer service experiences across
digital platforms.
• XLSMART through its business arm XLSMART for Business, held the BRAVO 500 SUMMIT, an international strategic
forum that brought together industry players, regulators, and global technology partners on a collaborative stage.
The event drew around 500 companies, 1,500 top-level executives from diverse industries, and over 30 expert
speakers from the public and private sectors. XLSMART also introduced Enterprise Smart Technology & Automation
(ESTA), which is XLSMART’s unified digital platform to assist industrial sectors function more efficiently, securely, and
measurably.
• To enhance customer protection and satisfaction, XLSMART launched “Credit Control,” an innovative feature that
allows customers to lock their prepaid credit, preventing unauthorized use for paid SMS, subscription content, or
out-of-plan internet access—offering greater transparency and control over service usage.
• Signed a strategic agreement at the Bali Annual Telkom International Conference (BATIC) 2025, committing to
expanded collaboration in network development, service quality improvement, and the creation of new business
opportunities within the telecommunications ecosystem.
• Through XLSMART for Business, XLSMART partnered with ASTRAtech to develop a 5G-based Autonomous Drone for
Goods Delivery, designed to accelerate logistics distribution and support digital transformation in Indonesia’s
manufacturing sector.
• XLSMART has now implemented SIM card registration utilising face recognition technology. This service is still
optional for customers, in line with current regulations. To assure data accuracy, a biometric system connected to the
national population database. This initiative represents XLSMART’s support for the government’s program to
expedite national digital transformation while enhancing customer data security.
• Integrated the unified operational and service quality monitoring center (Customer Experience & Service Operation
Centre-CE & SOC) into a single location, the XLSMART Building in Bumi Serpong Damai (BSD) City, South Tangerang.
The CE & SOC integrates two formerly distinct Network Operation Centres (NOC), one owned by XL Axiata at the XL
Axiata Tower in Kuningan, Jakarta, and the other by Smartfren in BSD, South Tangerang. The CE & SOC have been
operationally integrated since July 2025, representing an important point in XLSMART’s post-merger phase, which
prioritises network stability as well as operational efficiency and effectiveness.
• XLSMART through Smartfren has earned a national record for “Telecommunications Service Provider Organizing the
Most Running Events in a Single Year” with its flagship program, Smartfren Fun Run 2025. Over the past year,
Smartfren has successfully hosted a series of fun run events in 22 cities across Indonesia, engaging over 15 thousand
participants of various ages and backgrounds.
• XLSMART through its XL service brand, has reaffirmed its commitment to providing a superior experience for
customers and the general public. XL services with XLSMART network support has officially presented XL Ultra 5G+
which was ready to fully cover Denpasar City and Badung Regency, Bali, as well as 11 other cities/regencies spread
across various regions in Indonesia, as of 17 December 2025.
2025 Sustainability Report 59
Page 62
About
XLSMART
Organization Structure
Director &
Director
Chief Strategy
& Chief
and Home
Commercial
Business
Officer
Officer
Go To Commercial Commercial Home Home
Marketing
Market Sales Marketing Business Sales
Home
Home
Mass Commercial Product & Commercial Sales Strategic
Tradi Sales Product &
Segment GTM ARPU Mgmt. Planning Convergence Partnership
Marketing
1
Omni and Customer Home Sales
Youth Customer Home Digital
Region West Beyond Contact Convergence
Segment Success Operations Partnership
Telco Center 2
Product Home
Sales
Premium Portfolio Brand CVM Convergence
Region Jabo Vertical &
Segment & Trading Comm. Management Channel &
Telesales
Policy GTM
Portfolio Region Commercial Channel Migration
CLM
Mgmt. Central PDCA Management Mgmt.
Marketing Direct
Region East
Strategy Channel
Digital
Region
Channel
Kalimantan
Touch Point
Region
Sulawesi
60 PT XLSMART Telecom Sejahtera Tbk
Page 63
Connecting Indonesia:
One Purpose - One Planet
President Director & CEO
Director & Chief
Director Director & Chief Director
Enterprise Director & Director & Chief Director & Chief
& Chief Information & Chief
and Strategic Chief People Technology Regulatory
Financial Technology Integration
Relationship Officer Officer Officer
Officer Officer Officer
Officer
Industrial
Enterprise Enterprise
Enterprise Human Human Relations, Strategy & Risk &
Business Business Procurement Deputy CITO
Synergy Office Capital Resources GA & Building Analytics Compliance
Technology Solutions
Facility Mgmt.
SCM System
Investor Tech. IT Corporate
Business Enterprise Enterprise Revenue Proc, IT Strategy Risk &
Relations Category People HR Strategy Employee Strategy & Platforms Transformation Corporate Internal Corporate Business
Analyst & Product & Synergy Assurance & Automation & Business Legal Compliance
& Financial Management Journey & PMO Relations Alignment & Analytics & IMO Office Strategy Audit Secretary Control
Dev. Marketing Mgmt. Interconnect & Vendor Partner
Project Delivery
Mgmt.
National & Network IT
Enterprise Finance OD & Talent RAN Regulatory Synergy Business
Enterprise Strategic Electronics, Technology People General Commercial Digital
Buss Finance Business Acquisition Planning & Gov. Realization & Analysis &
Technology Enterprise Tower & Procurement Development Affairs Platforms Touchpoint
Performance Control Relations Accounting Insight
Fiber Optics Delivery
IT & People Network
Enterprise Enterprise Treasury & Building Planning Regulatory Applied
Wholesale & Contract Network General Services People IT Core NR, MOCN &
Marketing & Partnership Finance BP Facility & Design - Relations & Analytics
Reseller Mgmt. Services Procurement & Facility Mgmt. Platform New Site
Sales NSMG Mgmt. 1 Enterprise Mgmt. 1 Transport Compliance & AI
Procurement Mgmt.
People Network Data
Enterprise Logistics Talent & Building Network Tech. Corp.
Enterprise Regional Financial Legal Tower Strategy Assurance Engineering
Partnership & Indirect People Facility Planning & Security & Comm. &
Sales SMG Enterprise Accounting Operations Operation Alignment & & Service &
Mgmt. 2 Procurement Development Mgmt. 2 Dev. - Core Risk Control Sustainability
Analytics Quality Development
Solution Enterprise Collection & Data
Material Fiber & Reward,
& Tech Pricing & Finance BP Network IT Digital Site Government
Mgmt. & InBuilding HRIS &
Account Program Product and Ops Ops Dismantling & Architect
Warehousing Management Policy
Mgmt. Mgmt. Commercial
System & HR Service Ops IT
Enabler Operations Mgmt. Transformation
Vendor Data
Management Privacy
2025 Sustainability Report 61
Page 64
About
XLSMART
Group’s Structure
PT Gerbangmas
Axiata Group PT Prima Mas PT Infinity
Tunggal
Berhad Abadi Investama
Sejahtera
100%
Axiata 99.99% 99.99% 99.99%
Investments
(Labuan) Limited
100%
Axiata
Investments Public Treasury PT Global PT Bali Media PT Wahana Inti
(Indonesia) Sdn Shareholders Shares Nusa Data Telekomunikasi Nusantara
Bhd
34.69% 24.60% 6.01% 4.66% 24.57% 2.85% 2.61%
PT XLSMART Telecom
Sejahtera Tbk
18.32% 51% 20% 50% 100% 100% 10.71%
XL Axiata
Singapore
PT Mora PT One PT Princeton
PT Hipernet PT Link Net Pte. Ltd. (d/h PT Distribusi
Telematika Indonesia Digital Group
Indodata Tbk Axiata Global Sentra Jaya
Indonesia Tbk Synergy Data Centres
Services Pte.
Ltd.)
50.95%
PT Data
Enkripsi
Informasi
Teknologi
62 PT XLSMART Telecom Sejahtera Tbk
Page 65
Connecting Indonesia:
One Purpose - One Planet
Subsidiaries, Associates, and
Joint Ventures
Direct Ownership
PT Hipernet Indodata
Address Graha Hyper Jl. Makaliwe Raya No. 24-24A West Jakarta, DKI Jakarta
Shareholding Percentage 51%
Business Line Managed Service Provider and Information Technology Service
Total Assets as of 31 December 2025 (Rp million) 455,605
Operational Status Active
PT Link Net Tbk
Address Centennial Tower 26th Floor Unit D
Jl. Jenderal Gatot Subroto Kav. 24-25 South Jakarta, DKI Jakarta
Shareholding Percentage 20%
Business Line Internet Services Provider and Cable TV
Total Assets as of 31 December 2025 (Rp million) 15,448,528
Operational Status Active
PT One Indonesia Synergy
Address Indosat Building, 9th Floor
Jl. Medan Merdeka Barat No. 21 Gambir, Central Jakarta, DKI Jakarta
Shareholding Percentage 50%
Business Line Computer consultancy and facility management
Total Assets as of 31 December 2025 (Rp million) -
Operational Status Active
PT Princeton Digital Group Data Centres
Address Astra Tower, 37/F Jl. Jend. Sudirman Kav 5-6 Central Jakarta 10220,
DKI Jakarta
Shareholding Percentage 10.71%
Business Line Activities relating to hosting and managing data centres
Total Assets as of 31 December 2025 (Rp million) 3,703,542
Operational Status Active
XL Axiata Singapore Pte. Ltd. (formerly Axiata Global Services Pte. Ltd)
Address 9 Raffles Place, #26- 01 Republic Plaza, Singapore 048619
Shareholding Percentage 100%
Business Line International operator services and partnership and alliance management
Total Assets as of 31 December 2025 (Rp million) 26,122
Operational Status Active
2025 Sustainability Report 63
Page 66
About
XLSMART
PT Distribusi Sentral Jaya
Address CBD Lot, Jl. Pahlawan Seribu No.45 12A, Lengkong Gudang, Serpong District,
South Tangerang, Banten 15321
Shareholding Percentage 100%
Business Line Wholesale Services
Total Assets as of 31 December 2025 (Rp million) 250,398
Operational Status Active
Indirect Ownership
PT Data Enkripsi Informasi Teknologi*
Address Graha Hyper Jl. Makaliwe Raya No. 24-24A West Jakarta, DKI Jakarta
Shareholding Percentage 50.95%
Business Line Cybersecurity services
Total Assets as of 31 December 2025 (Rp million) 14,148
Operational Status Active
* PT Hipernet Indodata owns 99.9% direct ownership in PT Data Enkripsi Informasi Teknologi.
Business Scale
Description Unit 2025 2024 2023
Total Employees People 3,239 1,663 1,495
Total Revenues Rp-Billion 42,446 34,392 32,323
Total Assets Rp-Billion 115,318 86,179 87,688
Total Liabilities Rp-Billion 85,310 59,956 61,183
Total Equity Rp-Billion 30,009 26,222 26,505
Number of Products/Services Provided Petabyte 14,566 10,547 9,638
Number of Customers Million-people 73.00 58.80 57.52
Shareholder Composition
Axiata Investment Indonesia is a subsidiary of the Axiata Group Berhad, the largest telecommunications company in
Asia which also owns Celcom (Malaysia), Dialog (Sri Lanka), Robi (Bangladesh), Smart (Cambodia), Ncell (Nepal),
Idea (India), and M1 (Singapore).
Shareholder Unit 2025 2024 2023
Axiata Investments (Indonesia) Sdn. Bhd.* 34.69 66.25 66.25
PT Bali Media Telekomunikasi* 24.56 - -
%
Treasury Shares 0 0.43 0.43
Public with Less than 5% Ownership 33.23 33.32 33.32
*Axiata Investments (Indonesia) Sdn. Bhd and PT Bali Media Telekomunikasi are the Company’s controlling shareholders along with PT Global Nusa
Data (4.663%) and PT Wahana Inti Nusantara (2.847%).
64 PT XLSMART Telecom Sejahtera Tbk
Page 67
Connecting Indonesia:
One Purpose - One Planet
Association Membership [C.5] [GRI 2-28]
Throughout 2025, XLSMART actively participated and contributed to the following industry associations:
No Organization Name XLSMART’s Role and Contribution
1 Global Mobile Suppliers Association (GSA) Member
2 Submarine Cable Association (ASKALSI) Supervisory Board; Inter-Institutional Relationship,
Training; Event & Certification; Legal & Regulatory;
Restoration & Facility Management; Member
3 Indonesia Service Dialogue (ISD Council) Member
4 Association of Indonesian Telecommunications Operator (ATSI) Supervisory Board; Secretary General; Member
5 Indonesian Telematics Society (MASTEL) Member and Manager
6 Telecommunications Interconnection Clearing Association (ASKITEL) Supervisory Board; Member
7 Indonesian Chamber of Commerce and Industry (KADIN) Member
8 Indonesian Chamber of Commerce and Industry (KADIN DKI Jakarta) Member
9 Asosiasi Penyelenggara Jasa Internet Indonesia (APJII) Member
10 Metro Ethernet Forum (MEF) Member
11 Indonesian Corporate Secretary Association (ICSA) Member
12 Dewan TIK Nasional (Wantiknas) Advisory Team Member
13 KADIN NET ZERO Hub Member
2025 Sustainability Report 65
Page 68
About
XLSMART
Operational Area [C.3]
Operational Area and BTS Network
2
1
3 4
Head Office
1
XLSMART TOWER
Jl. H.R Rasuna Said X5 Kav.11-12, East Kuningan,
Setiabudi, South Jakarta 12950
Region-West
2
DIPONEGORO MEDAN
Jl. Diponegoro No.5, Medan,
North Sumatra
CENTRAL EAST
3 4
MARTADINATA PEMUDA
Jl. R.E Martadinata No 7, Bandung Jl. Pemuda No 94-98 Embong Kaliasin
West Java Subdistrict, Genteng District, Surabaya,
East Java
66 PT XLSMART Telecom Sejahtera Tbk
Page 69
Connecting Indonesia:
One Purpose - One Planet
165,530
4G BTS
4,864
5G BTS
2025 Sustainability Report 67
Page 70
About
XLSMART
Business Activities [C.4] [GRI 2-6]
Pursuant to Article 3 of the latest Articles of Association, XLSMART’s objectives and scope of business encompass
activities in telecommunications, large-scale trade, programming, computer consulting and related services,
information services, telecommunications construction and installation, employment activities, as well as
professional, scientific, and technical activities. The Company also engages in rental and leasing activities
without option rights, real estate, financial services, office administration and support services, advertising, land
preparation, and other supporting business activities.
To achieve the aforementioned aims and objectives, the Company may engage in the following business activities:
1. Telecommunications Business 2. Large Scale Trade:
Activities: • Large Scale Trade in Computers and
a. Operation of telecommunications networks, Computer Equipment;
including but not limited to: • Large Scale Trade of Software;
• Cable Telecommunication Activities; • Large Scale Trade in Telecommunication
• Wireless Telecommunications Activities; Equipment;
• Satellite Telecommunication Activities; • Large Scale Trade in Electronic Spare Parts;
• Special Telecommunication Activities for • Large Scale Trade in Machinery, Equipment,
Own Use; and Other Supplies;
• Special Telecommunication Activities for • Wholesale Trade Based on Service Fees or
Defense and Security Purposes; Contracts.
• Other Telecommunication Activities;
• Special Broadcasting
Telecommunications Activities;
3. Computer Programming and
• The Development of Internet-Based
Consultancy Services and other
Trading Applications (e-Commerce)
Activities Related thereto:
Activities.
• Other Computer Programming Activities;
• Artificial Intelligence Programming Activities;
b. Provision of telecommunications services
• Immersive Media Content Programming and
including but not limited to:
Production Activities;
• Internet Service Provider;
• Digital Identity Provision Activities;
• Data Communication System Services;
• Activities for Providing Electronic Certificates
• Internet Telephony Services for Public
and Services Using Electronic Certificates;
Purposes (ITKP);
• Blockchain Technology Development
• Internet Interconnection Services (NAP);
Activities;
• Content Provider Services through Cellular
• Information Security Consultancy Activities;
Mobile Networks or Wireless Local Area
• Computer Consulting and Other Computer
Networks with Limited Mobility;
Facility Management Activities;
• Other Multimedia Services;
• Internet of Things (IoT) Consulting and
• Telecommunication Resale Services;
Design Activities;
• Internet Protocol Television (IPTV)
• Information Technology Activities and Other
Services;
Computer Services.
• Other Telephony Value-Added Services.
68 PT XLSMART Telecom Sejahtera Tbk
Page 71
Connecting Indonesia:
One Purpose - One Planet
4. Information Services Activities:
• Data Processing Activities;
• Hosting and Related Activities;
• Web Portals and/or Digital Platform without Commercial Purposes;
• Web Portals and/or Digital Platforms with Commercial Purposes;
• Other Information Services Activities-Not Included in Others.
5. Construction: 7. Professional, Scientific, and Technical
• Telecommunication Central Construction; Activities:
• Telecommunication Installation; • Management Consultancy Activities;
• Railway Signal and Telecommunication • Advertising.
Installation;
• Land Preparation.
8. Rental and Leasing Activities without
Option Rights for Technological Aids.
6. Employment Activities: 9. Owned or Leased Real Estate.
• Provision of Human Resources and 10. Other Monetary Intermediaries.
Management of Human Resources Function; 11. Call Center Activities.
• Specific Time Labor Provision Activities. 12. Software Publishing.
13. Other Publishing Activities.
14. Telecommunication Equipment
Repair.
For the purpose of realizing the aforementioned aims and objectives, the Company may engage in the following
business activities:
a. Plan, engineer, build, provide, develop and operate, lease, maintain and procure telecommunication facilities/
facilities including procurement of resources to support the Company’s business in providing telecommunication
services and/or networks;
b. Increase as much as possible the business of providing telecommunication services and networks, so as to
achieve the capacity desired and needed by the community in order to improve services to the community;
c. Run business and operational activities (which also includes marketing and sales of telecommunication
networks and/or services provided by the Company), carrying out maintenance, research, development, means
and/or facilities of the telecommunication, organizing non-formal education and training in telecommunication
sector both domestic and overseas;
d. Provide other telecommunication services and networks including information technology services and/or
networks; and
e. Carry out the other activities deemed necessary to support and/or be related to telecommunication operations,
large scale trade trading activities, programming activities, computer consulting activities and related activities,
information services activities, telecommunication construction and installation, employment activities,
professional, scientific and technical, rental and leasing activities without option rights for digital technology
tools, real estate, financial services activities, management consulting activities, office administration activities,
office support activities, advertising and land provision.
Throughout 2025, the Company carried out all of the aforementioned business activities, except for Internet Protocol
Television (IPTV) Services, Digital Identity Provision Activities, Activities for Providing Electronic Certificates and
Services Using Electronic Certificates, Telecommunications Installation, Other Telephony Value-Added Services,
Special Telecommunication Activities for Defense Security Purposes, Telecommunication Central Construction,
Railway Signal and Telecommunication Installation Specific, Telecommunication Activity for Own Use, Immersive
Media Content Programming, Production Activities, Satellite Telecommunication Activities, and Land Preparation.
2025 Sustainability Report 69
Page 72
Sustainability
Governance
70 PT XLSMART Telecom Sejahtera Tbk
Page 73
Connecting Indonesia:
One Purpose - One Planet
Sustainability
Governance
2025 Sustainability Report 71
Page 74
Sustainability
Governance
Committed to the Effective
Implementation of GCG Practices
At XLSMART, strong governance is more than a and SEOJK No. 16/SEOJK.04/2021 on the Formats
framework, it reflects how the Company stays true to and Contents of the Annual Report of Issuers or Public
its values in every decision, and how integrity guides Companies. The Company also adopts additional
each part of the business. Good Corporate Governance reference and frameworks, such as Roadmap of
(GCG) has long been the foundation for responsible Indonesian Corporate Governance Guidelines issued
operations, resource optimization, and building by OJK, the ASEAN Corporate Governance Scorecard
lasting trust with stakeholders. Through the consistent (ACGS) issued by the ASEAN Capital Market Forum
implementation of governance practices, the Company (ACMF), and the Indonesian General Guidelines
ensures that accountability and ethical conduct are for Corporate Governance issued by the National
deeply in its culture. Governance Policy Committee (KNKG).
GCG also serves as the compass that links business XLSMART’s GCG Principles
performance with long-term sustainability. It provides XLSMART continues to uphold GCG principles in every
direction for how decisions are made, how risks aspect of its operations. These values guide how the
are managed, and how opportunities are pursued Company engages with stakeholders and bring to life
in a responsible and transparent manner. These its sustainability pillars: Building Prosperity, Planet &
governance practices help the Company create value Society, Nurturing People, and Process Excellence.
not only for shareholders, but also for customers, The following table outlines how each GCG principle is
employees, partners, and communities. They reflect a applied within the Company’s governance framework.
belief that growth built on strong ethics leads to long-
lasting impact. Specifically, XLSMART’s GCG practices are guided
by the Indonesian Corporate Governance General
XLSMART’s commitment to the implementation of Guidelines (Pedoman Umum GCG Indonesia/PUGKI)
sustainable governance is grounded in compliance with 2021, as revised by the National Committee on
the Law of the Republic of Indonesia No. 40 of 2007 on Governance Policy (KNKG). In line with these guidelines,
Limited Liability Companies (“Company Law”) and the Company consistently applies the fundamental
its implementing regulations, as well as the Law of the principles of Ethical Conduct, Accountability,
Republic of Indonesia No. 8 of 1995 on Capital Markets, Transparency, and Sustainability, which together form
OJK Regulation No. 51/POJK.03/2017 concerning the the foundation of XLSMART’s governance framework.
Implementation of Sustainable Finance for Financial
Service Institutions, Issuers, and Public Companies, The principles are as follows:
72 PT XLSMART Telecom Sejahtera Tbk
Page 75
Connecting Indonesia:
One Purpose - One Planet
XLSMART’s GCG Principles
The corporation places a premium on honesty in its operations, treats all stakeholders with respect,
fulfills its commitments, and consistently cultivates and maintains moral values and trust. It
considers the interests of shareholders and other stakeholders based on the principles of fairness
and equity. The corporation is managed independently, ensuring that no individual corporate entity
can dominate or intervene in the affairs of another.
Implementation at XLSMART
In practice, all decision-making processes at XLSMART are designed to prevent and manage
potential conflicts of interest. Should any corporate action involve a conflict, it will only be carried
out in strict compliance with prevailing laws and regulations. The Company guarantees that all
shareholders receive fair and equal treatment in accordance with applicable legal provisions.
ETHICAL Furthermore, XLSMART ensures that shareholders and stakeholders have the right to provide
CONDUCT input, express opinions, and obtain balanced and transparent information regarding the
Company’s performance and governance practices.
Through the consistent application of these principles, XLSMART strengthens its ethical foundation,
reinforces stakeholder confidence, and ensures that integrity remains at the heart of its corporate
governance culture.
The corporation is fully accountable for its performance, presenting information in a transparent
and equitable manner. It is essential that the corporation is managed correctly, with measurable
outcomes aligned with corporate interests while also considering the interests of shareholders and
stakeholders. Accountability is vital for achieving sustainable performance.
Implementation at XLSMART
The Company takes full responsibility for the accuracy, integrity, and timeliness of information
disclosed to shareholders and stakeholders. Each corporate organ, the General Meeting of
Shareholders (GMS), the Board of Commissioners, and the Board of Directors, carries out its duties
and responsibilities in accordance with applicable laws, the Articles of Association, and established
ACCOUNTABILITY governance policies. Through effective oversight, internal control mechanisms, and performance
evaluation systems, XLSMART ensures that accountability is maintained at every organizational
level, thereby supporting sound decision-making and long-term corporate sustainability.
To maintain objectivity in its business operations, the corporation disseminates material and
relevant information in a manner that is accessible and comprehensible to stakeholders. The
corporation takes the initiative to disclose not only those matters required by laws and regulations
but also other significant issues that are vital for decision- making by shareholders, creditors, and
other stakeholders.
Implementation at XLSMART
The Company disseminates relevant and material information through multiple communication
channels to ensure broad and equitable access. These include the Annual Report, audited Financial
Statements published via the Indonesia Stock Exchange (IDX) platform, the Company’s official
TRANSPARENCY website, and other public information media such as newspapers or press releases. XLSMART also
complies with periodic and incidental disclosure obligations as required by the Financial Services
Authority (OJK) and the IDX. Through these measures, XLSMART reaffirms its commitment to
transparency as a means of strengthening stakeholder trust and promoting accountability
throughout the organization.
2025 Sustainability Report 73
Page 76
Sustainability
Governance
The corporation adheres to legal regulations and is committed to fulfilling its social and
environmental responsibilities, thereby contributing to sustainable development through
collaboration with relevant stakeholders to enhance their well-being in alignment with business
interests and the sustainable development agenda.
Implementation at XLSMART
In practice, XLSMART consistently applies the principles of Environmental, Social, and Corporate
Governance (ESG) across all operational and strategic activities. The Company is committed to
minimizing its environmental footprint, promoting responsible resource management, and
advancing social empowerment through inclusive and impactful programs. XLSMART also ensures
SUSTAINABILITY that its governance systems reflect transparency, ethics, and accountability, reinforcing its
dedication to responsible business conduct. By embedding sustainability into its core operations,
XLSMART creates long-term value for stakeholders and contributes to a more resilient and
sustainable future.
The Company asserts that digitalization will stimulate business growth, enhance the efficiency of
existing processes, and ensure consistency and quality. Additionally, it will empower the
organization and its Board Members to adapt to ongoing disruptions in business models by
implementing modifications to its internal governance techniques, Board leadership, structure,
and processes.
DIGITIZATION
The Company continuously refines its governance mechanisms to anticipate emerging risks, strengthen stakeholder
trust, and uphold its responsibility to society and the environment. Through these ongoing efforts, XLSMART ensures
business continuity and reinforces its leadership in responsible and sustainable telecommunications.
ACGS 2024 Assessment Result
96.82 reflecting the Company’s strong commitment to upholding the highest standards of governance,
transparency, and ethical conduct in all aspects of its operations.
Item(s) Not
Scorecard Level 1 Total item Items Adopted Adoption Rate
Applicable
Part A 30 3 22 81.48%
Part B 22 0 18 81.82%
Part C 34 0 31 91.18%
Part D 63 0 31 91.18%
Total Score (Level 1 & 2) 96.82
Note: Cut Off Date as of 30 June 2024
74 PT XLSMART Telecom Sejahtera Tbk
Page 77
Connecting Indonesia:
One Purpose - One Planet
Structure and Composition of
Sustainability Governance [GRI 2-9] [GRI 2-11]
XLSMART’s sustainability governance structure is designed to ensure clear accountability, effective oversight, and
smooth coordination across all levels of the organization. The governance framework comprises Main Organs and
Supporting Organs. Within this structure, the Company has established a dedicated Sustainability Unit responsible
for integrating Environmental, Social, and Governance (ESG) considerations into business strategies. Each organ
carries a distinct yet complementary roles, ensuring that sustainability principles are embedded in every key business
decision.
General Meeting of Shareholders
Board of Board of
Directors Commissioners
President
Director
Risk Nominating Board
Audit
& Compliance & Remuneration Investment
Committee
Committee Committee Committee
Company
Directors
Corporate
Secretary
Board of
Directors
Committees
Internal Audit
Risk &
Compliance
General Meeting of Shareholders
The General Meeting of Shareholders (GMS) functions as the highest decision-making body within the Company’s
governance structure. As the ownership organ, the GMS holds exclusive authorities not granted to the Board of
Commissioners or the Board of Directors, in accordance with the Articles of Association and prevailing laws and
regulations. Through this forum, Shareholders are given the opportunity to exercise their rights, express opinions,
and request information that supports transparency and accountability in the Company’s decision-making process.
Each year, the Company may convene two types of GMS: the Annual GMS and the Extraordinary GMS. The
mechanisms governing both types of meetings are regulated under the Company Law, the Articles of Association,
and OJK regulations. In 2025, XLSMART held its Annual GMS on 5 March 2025 and Extraordinary GMS on 5 March
2025, 12 August 2025, and 21 November 2025, during which several important resolutions were approved. Further
details regarding the 2025 GMS implementation are available presented in XLSMART’s official website and in the
2025 Annual Report, published as a separate document from this Sustainability Report.
2025 Sustainability Report 75
Page 78
Sustainability
Governance
Board of Commissioners
The Board of Commissioners serves as the supervisory body of the Company, entrusted with overseeing management
performance and the consistent application of GCG principles. The Board of Commissioners is responsible for
monitoring the implementation of the Company’s strategies, evaluating reports submitted by the Board of Directors,
reviewing audit outcomes, and providing constructive guidance to ensure effective risk management and business
sustainability. To maintain objective and independent oversight, the Company has established a clear separation
between the roles of the Chairman of the Board and the CEO.
The Board of Commissioners also provides recommendations to Shareholders on key matters concerning the
Company’s direction and performance. To support its supervisory duties, the Board is assisted by three committees
under its purview: the Audit Committee, the Nomination and Remuneration Committee, and the Risk and Compliance
Committee. The Board of Commissioners performs its duties with independence and objectivity to ensure that all
decisions remain in the best interest of the Company.
Pursuant to the resolution of the Extraordinary General Meeting of Shareholders convened on 25 March 2025, the
shareholders approved the cessation of tenure of all members of the Board of Commissioners effective as of the
Merger Effective Date, and appointed new members of the Board of Commissioners. Accordingly, the composition
of the Board of Commissioners as of December 31, 2025 was as follows:
Name Position Period Term of Office Legal Basis of Appointment
M. Arsjad Rasjid President Commissioner First Period 21 April 2025 until the closing Resolution of the
P.M. of the Annual General Extraordinary General
Meeting of Shareholders in Meeting of Shareholders
2029. dated 25 March 2025.
Vivek Sood Commissioner Fourth Period 21 April 2025 until the closing Resolution of the
of Annual General Meeting of Extraordinary General
Shareholders 2029. Meeting of Shareholders
dated 25 March 2025.
L. Krisnan Cahya Commissioner First Period 21 April 2025 until the closing Resolution of the
of Annual General Meeting of Extraordinary General
Shareholders 2029. Meeting of Shareholders
dated 25 March 2025.
Nik Rizal Kamil Commissioner Second Period 21 April 2025 until the closing Resolution of the
of Annual General Meeting of Extraordinary General
Shareholders 2029. Meeting of Shareholders
dated 25 March 2025.
Sean Guek Commissioner First Period 21 April 2025 until the closing Resolution of the
of Annual General Meeting of Extraordinary General
Shareholders 2029. Meeting of Shareholders
dated 25 March 2025.
David R. Dean Commissioner First Period 21 April 2025 until the closing Resolution of the
of Annual General Meeting of Extraordinary General
Shareholders 2029. Meeting of Shareholders
dated 25 March 2025.
Retno Marsudi Independent First Period 21 April 2025 until the closing Resolution of the
Commissioner of Annual General Meeting of Extraordinary General
Shareholders 2029. Meeting of Shareholders
dated 25 March 2025.
Robert Pakpahan Independent First Period 21 April 2025 until the closing Resolution of the
Commissioner of Annual General Meeting of Extraordinary General
Shareholders 2029. Meeting of Shareholders
dated 25 March 2025.
Willem Lucas Independent First Period 21 April 2025 until the closing Resolution of the
Timmermans Commissioner of Annual General Meeting of Extraordinary General
Shareholders 2029. Meeting of Shareholders
dated 25 March 2025.
76 PT XLSMART Telecom Sejahtera Tbk
Page 79
Connecting Indonesia:
One Purpose - One Planet
Board of Directors
The Board of Directors is responsible for leading the Company’s management and ensuring that all operational
activities are carried out in accordance with good governance principles, the Articles of Association, and applicable
laws and regulations. As the executive organ, the Board of Directors represents the Company both inside and outside
of legal proceedings and ensures the effective implementation of strategies that drive growth, innovation, and
sustainability.
The Board of Directors consists of six members, led by a President Director who coordinates and oversees the
execution of duties across all Directorates. In fulfilling its responsibilities, the Board determines the Company’s
direction and sustainability strategies, manages potential social, economic, and environmental impacts, and
oversees climate-related actions. The Board is supported by several key committees and key functions, including
the Information Technology Committee, Risk Management and Business Continuity Committee, People Committee,
Gifts, Donations and Sponsorships Committee, Ethics and Integrity Committee, Corporate Secretary, Internal Audit,
and Risk & Compliance functions.
Pursuant to the resolution of the Extraordinary General Meeting of Shareholders held on 12 August 2025, shareholders
approved the cessation of tenure of all members of the Board of Directors effective as of the Merger Effective Date,
and appointed the new members of the Board of Directors. Accordingly, the composition of the Board of Directors as
of 31 December 2025 was as follows:
Name Position Period Term of Office Legal Basis of Appointment
Rajeev Sethi President Director & First Period 16 April 2025 until the closing Resolution of the Annual
Chief Executive Officer of the Annual General General Meeting of
(CEO) Meeting of Shareholders Shareholders dated 25 March
2029. 2025.
Antony Susilo Director & Chief Financial First Period 16 April 2025 until the closing Resolution of the
Officer of the Annual General Extraordinary General
Meeting of Shareholders Meeting of Shareholders
2029. dated 25 March 2025.
David Arcelus Director & Chief Second Period 16 April 2025 until the closing Resolution of the
Oses Commercial Officer of the Annual General Extraordinary General
Meeting of Shareholders Meeting of Shareholders
2029. dated 25 March 2025.
Andrijanto Director & Chief First Period 16 April 2025 until the closing Resolution of the
Muljono Enterprise & Strategic of the Annual General Extraordinary General
Relationship Officer Meeting of Shareholders Meeting of Shareholders
2029. dated 25 March 2025.
Feiruz Ikhwan Director & Strategy & Second Period 16 April 2025 until the closing Resolution of the
Home Business Officer of the Annual General Extraordinary General
Meeting of Shareholders Meeting of Shareholders
2029. dated 25 March 2025.
Shurish Director & Chief First Period 16 April 2025 until the closing Resolution of the
Subbramaniam Technology Officer of the Annual General Extraordinary General
Meeting of Shareholders Meeting of Shareholders
2029. dated 25 March 2025.
Yessie D. Yosetya Director & Chief Third Period 16 April 2025 until the closing Resolution of the
Information Technology of the Annual General Extraordinary General
Officer Meeting of Shareholders Meeting of Shareholders
2029. dated 25 March 2025.
Merza Fachys Director & Chief First Period 16 April 2025 until the closing Resolution of the
Regulatory Officer of the Annual General Extraordinary General
Meeting of Shareholders Meeting of Shareholders
2029. dated 25 March 2025.
Jeremiah Ratadhi Director & Chief People First Period 16 April 2025 until the closing Resolution of the
Officer of the Annual General Extraordinary General
Meeting of Shareholders Meeting of Shareholders
2029. dated 25 March 2025.
Sanjay Vaghasia Director & Chief First Period 12 August 2025 until the Resolution of the
Integration Officer closing of the Annual General Extraordinary General
Meeting of Shareholders Meeting of Shareholders
2029. dated 12 August 2025.
2025 Sustainability Report 77
Page 80
Sustainability
Governance
The Roles of XLSMART’s Governance
Body in Impact Management [GRI 2-12] [GRI 2-13]
[GRI 2-14]
At XLSMART, sustainability governance is built on collective leadership and shared accountability. The governance
body ensures that sustainability impacts are systematically identified, managed, and embedded into corporate
decision-making. Through this structure, the Company aligns its strategies with long-term sustainability
commitments while creating value for all stakeholders.
The Board of Commissioners oversees the overall direction of sustainability impact management, ensuring that
policies and initiatives comply with regulatory requirements and reflect stakeholder priorities. The Board of Directors
translates this oversight into strategic actions through policy development, target setting, and resource allocation
that advance XLSMART’s key sustainable priorities including climate action, circular economy, and social impact.
To support effective execution, both Boards work closely with the Sustainability Unit and cross-functional teams to
assess the Company’s actual and potential impacts. These assessments inform the prioritization of material topics,
guide target setting, and ensure that identified impacts are addressed through measurable initiatives and continuous
performance monitoring.
In implementing sustainability governance, the Boards delegate day-to-day responsibility for managing
sustainability impacts to the Head of Sustainability, who reports to the Group Head of Corporate Communications
and Sustainability. The Head of Sustainability is responsible for:
1. Strengthening the monitoring of sustainability performance;
2. Designing strategic initiatives and evaluating their impacts;
3. Ensuring stakeholder engagement as a key component in assessing sustainability achievements.
The specific roles within XLSMART’s governance body in managing sustainability impacts are as follows:
Climate Change and Decarbonisation Strategist
Ensures environmental performance across the Company by carrying out
data monitoring, reporting and verification, developing the net-zero
roadmap, and integrating corporate sustainability strategies.
Social Impact and Governance Coordinator
Oversees the collection and monitoring of social and governance
data, and coordinates sustainability-related events and
communication campaigns.
78 PT XLSMART Telecom Sejahtera Tbk
Page 81
Connecting Indonesia:
One Purpose - One Planet
Performance Assessments of
Governance Body [GRI 2-18] [G-04]
XLSMART conducts periodic evaluations of the Meanwhile, the collective performance of the Board
performance of both the Board of Commissioners and of Directors is reviewed by the GMS based on the
the Board of Directors. The assessments cover strategic accountability report on the Company’s management,
leadership, compliance, risk management, and which includes financial, operational, and sustainability
sustainability performance. The results form the basis results. Based on this evaluation, the GMS grants
for strengthening governance practices and enhancing acquit et de charge to the Board of Directors for its
accountability reflecting the Company’s commitment management throughout the financial year.
to continuous improvement and transparent leadership.
In 2025, the Company carried out an independent self-
Performance Assessment Mechanism for the assessment of the Board of Directors. A quantitative
Board of Commissioners approach was employed for the evaluation,
XLSMART applies two complementary mechanisms to utilizing structured questionnaires completed by
assess the performance of the Board of Commissioners, all Board members, as well as peer assessments
namely through the GMS and a self-assessment conducted among them. The evaluation covered
process. The Company adopts a structured and Board effectiveness, peer reviews, and cross-Board
quantitative approach to performance measurement, assessments.
ensuring objectivity and transparency in the evaluation
process. The focus of the evaluation was to clarify roles, duties,
and responsibilities, while assessing compliance with the
The GMS evaluates the collective performance of GCGprinciples. The results provide recommendations
the Board of Commissioners during the reporting for strengthening GCG practices and are taken into
year based on the supervisory accountability report consideration in the reappointment of individual Board
presented at the Annual GMS. The outcome of this members.
assessment forms the basis for granting full release
and discharge of responsibility (acquit et de charge) Assessments Results of the Governance Body
to the Board of Commissioners for the execution of its In 2025, XLSMART conducted an independent
supervisory duties throughout the financial year. assessment of the performance of both the Board
of Commissioners and the Board of Directors.
On the other hand, the self-assessment process was The assessment evaluated both of the Boards’
coordinated and reviewed by the Nominating and understanding of their roles, duties, and responsibilities,
Remuneration Committee, in accordance with its as well as their implementation of GCG principles.
mandate to oversee the performance evaluation of
the Board of Commissioners. The assessment was Based on the 2025 self-assessment, the Board of
conducted using a quantitative approach, with data Commissioners effectively performed its supervisory
collected through structured questionnaires distributed and advisory functions in accordance with prevailing
to each member of the Board of Commissioners, its laws, regulations, and corporate governance
Committees, and the Board of Directors as part of the standards. The Board demonstrated a high level of
cross-evaluation process. integrity, competence, and commitment in overseeing
the Company’s management and ensuring alignment
Assessment Mechanism of Performance of the with XLSMART’s strategic objectives and GCG
Board of Directors principles.
The Board of Directors is evaluated on both individual
and collective bases through self-assessment and by the The Board of Directors’ assessment also resulted in
Nomination and Remuneration Committee. Individual positive results. Based on the evaluation, the Board
assessments refer to the agreed Key Performance of Directors has satisfactorily fulfilled its duties
Indicators (KPI), which cover both financial and non- and responsibilities in accordance with applicable
financial aspects, including sustainability targets, regulations and relevant standards.
operational achievements, and risk management
effectiveness.
2025 Sustainability Report 79
Page 82
Sustainability
Governance
The Board of Commissioners and Directors were also Attendance at Board Meetings
assessed on their implementation of sustainability As part of its performance evaluation process,
aspects, in line with the established KPIs and strategic XLSMART monitors the attendance and participation
objectives. Insights from this assessment provided of the Board of Commissioners and the Board of
valuable input for the continuous improvement Directors in meetings throughout the year. This serves
of sustainability governance practices and serve as an indicator of their active engagement and their
as considerations in future appointments or commitment to providing effective governance
reappointments of the Board members. oversight.
Assessment of the Head of the Sustainability Unit Meetings of the Board of Directors and
In addition to evaluating the performance of the Boards, Commissioners [G-02]
XLSMART also conducts a dedicated assessment of Throughout 2025, the Board of Commissioners held 18
the Head of Sustainability to measure the effectiveness meetings, including 4 Joint Meetings held together with
of sustainability strategy implementation across the Board of Directors. Details regarding the frequency
the organization. The evaluation focuses on the of meetings, attendance by the Board of Directors
achievement of sustainability goals, the quality of and the Board of Commissioners, the agenda, and
stakeholder engagement, and the tangible impact of other details concerning the meetings of the Board of
programs on beneficiaries. Directors and the Board of Commissioners can be found
in the Company’s Company’s Annual Report.
Performance reviews are conducted through the Risk
Management and Business Continuity Committee As part of the performance evaluation process,
(RBCC) and the Board Risk & Compliance Committee XLSMART monitors the attendance and participation of
(BRCC), which act as the highest governing bodies the Board of Commissioners and the Board of Directors
overseeing sustainability performance. Both committees in meetings held throughout the year. This serves as an
conduct quarterly reviews of ESG performance reports indicator of their active involvement and commitment
to ensure data accuracy, consistency, and reliability. At to conducting effective governance oversight. Where
the end of each year, the consolidated ESG performance appropriate, the scope of the evaluation is expanded
report is reviewed and evaluated to identify progress, to include material topics, such as carbon emissions,
challenges, and opportunities for improvement. The climate change, labor practices, waste management,
results of these reviews serve as an important reference as well as data privacy and security, in accordance with
for enhancing sustainability governance, strengthening the results of the Company’s Materiality Assessment.
data reliability, and refining the Company’s future
sustainability targets and initiatives. Throughout 2025, the Board of Commissioners held 18
(eighteen) meetings, along with 4 (four) Joint Meetings
When relevant, the scope of evaluation is expanded held together with the Board of Directors.
to include material topics such as carbon emissions,
climate change, employment practices, waste
management, and data privacy and security,
as identified through the Company’s Materiality
Assessment.
80 PT XLSMART Telecom Sejahtera Tbk
Page 83
Connecting Indonesia:
One Purpose - One Planet
Nomination and Selection of
Governance Body [GRI 2-10] [G-06]
XLSMART is committed to appointing leaders who decision-making. The Company’s highest governing
embody integrity, professionalism, and accountability. bodies also uphold independence and remain free from
The nomination and selection of members of the Board conflicts of interest.
of Commissioners and Board of Directors are carried
out transparently, and in accordance with applicable Meanwhile, the nomination of the Board of Directors
regulations and Company policies. XLSMART follows the Succession Policy, which aims to ensure
evaluates candidates based on expertise, experience, leadership continuity and smooth business succession.
ethical conduct, and alignment with the Company’s This policy encourages potential successors to
sustainability vision to ensure that each Board member participate in self-development and professional
contributes meaningfully to responsible and effective training programs, including team-based problem-
governance. solving initiatives. The Nomination and Remuneration
Committee plays a central role in the nomination
The nomination of the Company’s executive members process, while the Board of Directors may also identify
is governed by the Senior Executive Nomination potential successors from within the organization,
Policy. In line with this policy, Shareholders and/or including those in the Talent Pool.
Minority Shareholders may propose candidates for the
Board of Commissioners, after which the proposals The appointment procedures for Director candidates
are submitted to the Nomination and Remuneration are regulated under the Nomination Policy and
Committee through the Corporate Secretary for further comply with the Company Law and other applicable
review. regulations. The Company periodically reviews Director
candidates through internal assessment panels or
The Nomination and Remuneration Committee by engaging independent third-party to assess their
evaluates the proposed candidates in its meetings to competencies.
ensure that they meet all required criteria, qualifications,
and professional standards before being submitted In appointing the Head of the Sustainability Unit, the
to the GMS for approval. The Company applies the Company refers to the qualifications outlined in the
requirements stipulated in POJK No. 33/POJK.04/2014 Recruitment Policy to ensure that the selected candidate
regarding the appointment of members of the Board of has the expertise required to lead the Company’s
Commissioners. sustainability initiatives effectively.
In determining nominations, the Company also To further strengthen the integrity of the nomination
considers the results of organizational needs and selection process, XLSMART ensures that diversity
assessments to ensure an optimal composition in terms and independence remain core considerations when
of expertise and background. The Company values forming the composition of its governing bodies. The
Board diversity, recognizing that a mix of different skills, Company believes that balanced representation across
perspectives, and experiences contributes to stronger gender, experience, and independent viewpoints
strategic direction, effective oversight, and high-quality enhances governance quality and supports inclusive,
accountable decision-making.
Board Diversity and Independence [G-01]
Management Level Male Female Number of Independent Personnel
Board of Commissioners 88% 12% 33%
Board of Directors 90% 10% -
2025 Sustainability Report 81
Page 84
Sustainability
Governance
Remuneration Policy and Process
[GRI 2-19] [GRI 2-20]
XLSMART’s remuneration policy is designed to stipulated in the Company’s Remuneration Policy for
attract, motivate, and retain competent leaders the applicable financial year.
who drive sustainable long-term sustainable value • The Board of Commissioners is authorized to
creation. The policy and process emphasize fairness, determine the salary, bonuses, and other benefits
competitiveness, and accountability, while aligning for members of the Board of Directors, based on
executive rewards with corporate performance, the same principles and within the framework of the
individual contribution, and the Company’s ethical and Company’s Remuneration Policy for the relevant
sustainability commitments. financial year.
Remuneration of the Board of Commissioners In determining remuneration, the Company takes
and Board of Directors into account several key considerations, including
XLSMART recognizes that a well-structured corporate performance, individual performance
remuneration framework supports business continuity targets, industry benchmarks, and non-monetary
and effective leadership. As part of its responsibility benefits. The overall remuneration structure is reviewed
to internal stakeholders, the Company ensures that regularly to ensure its competitiveness and alignment
remuneration encourages the Board to formulate with market conditions.
and deliver strategies that advance sustainable
relationships between the Company, the environment, The Board of Commissioners is responsible for
and the community. overseeing the implementation of the Remuneration
Policy and periodically evaluating its effectiveness
to ensure that it continues to support the Company’s
strategic objectives and uphold principles of fairness,
GMS
transparency, and accountability.
Remuneration Structure of the Board of
Authority to
Authority to
Commissioners and Board of Directors
Nominating & The remuneration structure for the Board of
the Board of
Remuneration
Committee
Commissioners Commissioners and Board of Directors is governed
by the Remuneration Policy for Senior Executives. It
comprises the following components:
Recommendations
of Nominating 1. Basic Salary
& Remuneration 2. Benefits
Committee 3. Bonus (applicable solely to members of the Board of
Directors)
Determination of Determination
Board of of Board of Remuneration of the Sustainability Unit
Commissioners Directors
XLSMART maintains a competitive and equitable
salaries salaries
remuneration system for all employees, including the
Head of Sustainability, who is responsible for leading
the implementation of the Company’s sustainability
The remuneration for members of the Board of strategies. The remuneration scheme for this position
Commissioners and the Board of Directors is determined follows the same structure applied to other employees
through the GMS, based on the recommendations and at equivalent levels, ensuring fairness, consistency, and
authority granted to the relevant governance bodies. recognition of the strategic importance of the role.
The procedure is outlined as follows: Annual Compensation Ratio [GRI 2-21]
• The Nomination and Remuneration Committee XLSMART ensures fair and competitive remuneration
is granted the authority to determine the salary, across all employee levels through a structured and
bonuses, and other benefits for members of the transparent process. The Company upholds the
Board of Commissioners, in accordance with the principle of equal pay for equal work, with compensation
structure, policy, and amount of remuneration determined based on role, performance, and prevailing
82 PT XLSMART Telecom Sejahtera Tbk
Page 85
Connecting Indonesia:
One Purpose - One Planet
market benchmarks. Regular reviews are conducted to maintain alignment with industry standards, business
outcomes, and applicable labour regulations, reinforcing accountability, equity, and the Company’s commitment to
sustainable talent management.
Information regarding aggregate remuneration amounts for the Board of Commissioners, Board of Directors, and
Head of the Sustainability Unit is not disclosed due to confidentiality policies. While sustainability performance
indicators are incorporated qualitatively into managerial assessments, the linkage between ESG performance and
remuneration is currently being refined to ensure stronger alignment with the Company’s sustainability objectives.
Remuneration structures are periodically reviewed and benchmarked against industry practices to ensure
competitiveness and continued alignment with the Company’s performance and sustainability commitments.
Sustainability Training and Competency
Development Program [E.2] [GRI 2-17] [G-05]
XLSMART believes that strengthening sustainability governance begins with continuous learning and capacity
building. The Company ensures that members of the Board of Commissioners, Board of Directors, and sustainability-
related functions have access to development programs that enhance their knowledge, skills, and awareness of ESG
issues relevant to their responsibilities.
Each member of the Board of Commissioners and Board of Directors is encouraged to pursue ongoing professional
development through seminars, workshops, and industry events related to governance, sustainability, and
telecommunications. This commitment to continuous learning is reflected in the Company’s Board Manual, which
outlines the requirement for regular competency enhancement to support effective oversight and strategic decision-
making.
In parallel, XLSMART strengthens the competencies of its Sustainability Unit and cross-functional teams through
targeted training programs. These include courses, certifications, and learning sessions focused on sustainability
reporting, climate action, human rights, circular economy, and other emerging ESG topics. Throughout 2025, the
Company facilitated various sustainability-related trainings and professional development activities as follows:
Name of
Training Name Place/Date Organizer
Participant
Ratu Maulia Setting Science-Based Targets 29 June 2025 UN Global Compact Academy
Ommaya E-waste Policy and Extended Producer 16-17 September 2025 International
Firhah Responsibility (EPR) Telecommunication Union
1.0 Welcome to GHG Accounting: Scope 1, 2, and 3 29 October 2025 UN Global Compact Academy
Emissions
The Net-Zero Standard 29 October 2025 UN Global Compact Academy
Asril Praboe The Net-Zero Standard 4 September 2025 UN Global Compact Academy
Anom How to understand and take action on the Global 6 September 2025 UN Global Compact Academy
Goals
Developing an integrated health, environment and 9 September 2025 UN Global Compact Academy
climate strategy for your company
Gender Equality: How Business Can Accelerate The 24 September 2025 UN Global Compact Academy
Pace of Change
1.1 Accounting for your Scope 1, 2 and 3 Emissions 30 October 2025 UN Global Compact Academy
Adiba Putri Setting Science-Based Targets 29 June 2025 UN Global Compact Academy
Rahmahakim 1.0 Welcome to GHG Accounting: Scope 1, 2, and 3 24 October 2025 UN Global Compact Academy
Emissions
The Net-Zero Standard 30 October 2025 UN Global Compact Academy
2025 Sustainability Report 83
Page 86
Sustainability
Governance
Sustainability Unit [E.1]
To ensure sustainability is embedded throughout the organization, XLSMART has established a dedicated
Sustainability Unit under the Corporate Communications and Sustainability Department. The Unit plays a
strategic role in coordinating sustainability initiatives across business lines and ensuring alignment between ESG
commitments.
The Sustainability Unit operates under the supervision of the Board of Commissioners and the Board of Directors,
with direct leadership from the President Director & CEO. This structure ensures that sustainability considerations are
integrated into the Company’s business strategy and decision-making processes while maintaining independence
and preventing conflicts of interest.
President Director & CEO
Director and Chief Regulatory Officer
Group Head Corporate Communications & Sustainability
Head of Sustainability
People reporting to Head of Sustainability:
• Climate Change and Decarbonisation Strategist
• Social Impact and Governance Coordinator
The members of XLSMART’s Sustainability Unit as of 31 December 2025 were as follows:
Name Position Term of Office Legal Basis of Appointment
Merza Fachys Director and Chief 16 April 2025-present Resolution of the Extraordinary General
Regulatory Officer Meeting of Shareholders dated 25 March
2025
Reza Zahid Mirza Group Head Corporate 15 October 2023- Employee Appointment Announcement No.
Communications present 37/2023
Ratu Maulia Ommaya Firhah Head of Sustainability 9 March 2024-present Employee Appointment Announcement No.
11/2024
Asril Praboe Anom Sustainability 16 April 2025-present No. 0722A-RM-XLS-IV-2025
Adiba Putri Rahmahakim Social Impact & 23 April 2025-present No. 0013-RM-XLS-IV-2025
Governance Coordinator
84 PT XLSMART Telecom Sejahtera Tbk
Page 87
Connecting Indonesia:
One Purpose - One Planet
Risk Assessment of Sustainability
Implementation [E.3]
As a company operating in a fast-moving To strengthen accountability and clarity in how risks
telecommunications landscape, our ability to are managed across the organization, XLSMART
anticipate, understand, and respond to emerging risks adopts the Three Lines Model. This structure defines
is what keeps us resilient and future-focused. We see clear responsibilities for managing, overseeing, and
sustainability risk management as a way to align our independently reviewing risks. The first line manages
pursuit of growth with our responsibilities toward the risks within its business operations, the second line
environment, society, and good governance, ensuring provides oversight and guidance, while the third line,
that profitability and purpose advance together. through internal audit, ensures independent assurance.
Together, these lines create a unified framework that
Our approach is built on a strong governance foundation reduces overlaps, fills potential gaps, and enhances
through the Enterprise Risk Management (ERM) overall consistency and transparency.
Framework, which integrates ISO 31000 principles.
Within this framework, sustainability considerations Supporting this framework is the Risk and Control
are not treated as an afterthought, but embedded into Self-Assessment (RCSA) process, which enables
strategic planning, investment decisions, and day-to- each business unit to actively identify, evaluate, and
day operations. It enables us to map out climate-related manage the risks most relevant to their activities. The
risks, both physical risks such as extreme weather process encourages accountability at every level
affecting network infrastructure, and transition risks and helps embed a culture where risk awareness and
such as policy shifts and market changes toward low- sustainability are understood as shared responsibilities.
carbon technologies.
To ensure that risk decisions are data-driven and
Each risk is carefully assessed based on its likelihood proportionate, XLSMART also applies a Risk Rating
and potential impact, followed by clear mitigation Matrix, which helps categorize and prioritize risks,
measures that ensure business continuity. XLSMART’s ensuring that each one is assessed accurately and
process begins by defining risk appetite and tolerance, managed effectively. It serves as a practical tool for
which guides how we prioritize and respond to setting risk tolerance levels and for ensuring that
potential disruptions. Among the risks that we our mitigation strategies are aligned with corporate
consistently monitor and supervise are capital and debt priorities. When a risk exceeds the defined threshold,
requirements as part of the sustainable financial action. it is immediately escalated to senior management and
The Company has established a policy on capital reviewed through the Risk-Based Control Committee
and debt structure to ensure the strategies regarding (RBCC) to determine the most appropriate course of
those aspects are in line with the Company’s strategic action.
objectives and risk appetite. Oversight from our Board
of Commissioners and Board of Directors ensures that This integrated and forward-looking approach to risk
every major decision reflects both market realities and management allows XLSMART to remain both resilient
our risk appetite, strengthening the Company’s ability and adaptive in a rapidly changing environment. It not
to adapt and thrive responsibly. only safeguards the Company from uncertainty but
also positions us to anticipate opportunities arising
from technological advancement and sustainable
innovation.
2025 Sustainability Report 85
Page 88
Sustainability
Governance
Guided by this approach, XLSMART has identified several key sustainability risks in 2025 that require focused,
proactive, and continual management, namely:
Risk Description
Strategic and Risks that may significantly affect the Company’s strategic activities, decision-making processes, and
Investment Risk achievement of business objectives. These risks are monitored by the Senior Leadership Team (SLT) as part
of the strategic planning and review process.
Financial Risk Risks related to the Company’s financial management and stability. These include treasury-related exposures
such as liquidity risk, foreign exchange risk, interest rate risk, and credit risk.
Operational Risk Risks arising from the Company’s core business operations, including telecommunications services, digital
businesses, and infrastructure management. These risks may result from inadequate or failed internal
processes, people, systems, or external events that disrupt daily operations, including business continuity
risks.
Legal and Risks related to compliance with applicable laws and regulations that may expose the Company to legal
Regulatory Risk penalties or non-compliance with established policies and best practices. The Company monitors regulatory
developments, maintains strong engagement with regulators and industry associations, and integrates
regulatory requirements into its internal policies and procedures.
Market Risk Risks arising from market conditions and the competitive landscape in which the Company operates,
including industry developments and macroeconomic factors. To mitigate these risks, the Company has
shifted part of its floating-rate debt to fixed-rate debt through the issuance of sukuk and bonds.
Geopolitical Risk Risks associated with political changes or instability, including changes in government policies, legislative
decisions, or geopolitical developments that may affect investment returns or operational performance.
Governance Risk Risks related to the implementation of good corporate governance practices. These may include non-
compliance with internal policies, procedures, or control mechanisms that could affect operational
effectiveness and accountability.
Technology Risk Risks related to information technology infrastructure, data systems, or applications that may disrupt
business operations. These risks may arise from system failures, infrastructure disruptions, or technological
vulnerabilities. The Company continuously strengthens its network infrastructure by modernising systems,
increasing capacity, and enhancing reliability.
Cyber Risk Risks arising from cyber threats, including cyber-attacks or data breaches that may disrupt operations or
compromise sensitive information. The Company continues to invest in information security technologies and
maintains ISO 27001 certification to support the protection of customer data.
People Risk Risks associated with human capital management, including shortages in specialised or skilled positions,
competency gaps, and employee health and safety. The Company addresses these risks through
continuous talent development, recruitment of professional and young talents, and initiatives to strengthen
organisational capabilities.
Constraints, Challenges and
Opportunities in Sustainability
Implementation [E.5]
As XLSMART continues to strengthen its sustainability foundation, we acknowledge that advancing sustainability
implementation is a journey that involves both challenges and opportunities. The transition toward a more responsible
business approach brings challenges that are both technical and cultural.
Some of the constraints may stem from post-merger integration complexity, harmonisation of ESG data and
governance frameworks, evolving regulatory and stakeholder expectations, and the need to balance short-term
financial performance with long-term sustainability commitments. Nonetheless, these challenges also create
opportunities for innovation, capacity building, and more efficient resource utilization which support XLSMART’s
transition toward sustainable business practices.
To provide a structured overview, the table below outlines key areas that may represent potential constraints,
challenges, and opportunities identified during the implementation process:
86 PT XLSMART Telecom Sejahtera Tbk
Page 89
Connecting Indonesia:
One Purpose - One Planet
Approaches to Overcome Obstacles / Opportunities for Further Development
Obstacles /Challenges
Challenges and Sustainability Implementation
Integration of networks, systems, Establishment of a structured cross- Stronger operational integration and
governance standards, and ESG functional integration monitoring sustainability standardisation
commitments following the merger mechanism, strengthened governance
harmonisation, and unified ESG data
consolidation
Alignment of sustainability priorities Reassessment of Double Materiality Sharper focus on high-impact topics such
across legacy entities and evolving Assessment and embedding ESG into as Climate Impact, Data Privacy, Network
double materiality outcomes strategic planning and Board oversight Resilience, and Employee Wellbeing
Increased regulatory, cybersecurity, and Strengthening risk management, ISO Positioning XLSMART as a trusted digital
data privacy expectations amid digital 27701 certification, enhanced operator with robust governance and
acceleration cybersecurity governance, and AI responsible technology deployment
oversight framework
Environmental impact from large-scale Implementation of controlled Acceleration of circular economy
network rationalisation and site decommissioning protocols, engagement practices and structured Decarbonisation
dismantling of certified vendors, strengthened roadmap toward Net Zero 2050
e-waste traceability mechanisms, and
renewable energy adoption
Cultural integration and employee Implementation of new corporate culture Development of a high-performing,
alignment post-merger (i-CARE), harmonised KPI systems, and digitally skilled workforce capable of
structured employee engagement driving sustainable innovation
platforms
Management of Conflict of Interest
[GRI 2-15] [G-09]
XLSMART has established clear policies and procedures to prevent and manage conflicts of interest at all levels of
the organization. These measures are integral to the Company’s sustainability governance framework, ensuring that
decisions related to ESG matters are made objectively and in the best interest of stakeholders. By upholding fairness
and transparency in every aspect of governance, XLSMART reinforces accountability and trust as the foundation of
sustainable business conduct.
The Company’s Conflict of Interest Policy outlines the mechanisms to identify, disclose, and manage potential
conflicts that may arise in decision-making processes involving the Board of Commissioners, Board of Directors,
or other governing bodies. Members with a conflict of interest in any agenda item are required to abstain
from discussions and decision-making, and to formally declare their position through a signed statement of
independence. The Corporate Secretary is responsible for overseeing the implementation of this policy and ensure
consistent adherence across the organization.
Conforming with applicable regulations, XLSMART also refers to OJK Regulation No. 42/POJK.04/2020 concerning
Affiliate Transactions and Conflicts of Interest. Any transaction involving affiliated parties or deemed to contain
a potential conflict must be transparently disclosed and, where required, submitted for approval by the General
Meeting of Shareholders and reported to the relevant authorities.
To strengthen awareness of conflict management, the Company continuously communicates the policy and related
procedures to internal units, emphasizing their importance in maintaining governance integrity and long-term
business continuity. Throughout 2025, there were no identified cases of conflicts of interest involving cross-board
memberships, share ownership, affiliated transactions, or engagements with suppliers and other stakeholders.
2025 Sustainability Report 87
Page 90
Sustainability
Governance
Anti-Bribery and Anti-Corruption Policy
[F.1] [GRI 205-3] [ACGS B.4.5] [G-07]
Integrity is non-negotiable at XLSMART. The Company believes that long-term success must be built on honesty,
fairness, and transparency in every aspect of our operations. Guided by this principle, XLSMART enforces an Anti-
Bribery and Anti-Corruption (ABAC) Policy that establishes clear standards and expectations for all employees,
management, and business partners. [GRI 3-3]
The policy reflects XLSMART’s strong commitment to uphold the highest ethical standards, ensure fair treatment
of shareholders, and maintain compliance with applicable laws and regulations. It prohibits all forms of bribery,
including offering, receiving, or participating in activities that could be construed as corrupt practices. This prohibition
extends to all stakeholders, including the Board of Commissioners, Board of Directors, employees, business partners,
vendors, consultants, agencies, and distributors.
The governance of ABAC-related activities is managed under XLSMART’s Risk & Compliance (RC) Division and is
supported by a comprehensive framework, policies, procedures, and the Code of Conduct. To foster an open and
transparent culture, XLSMART provides the Speak Up Channel, a whistleblowing mechanism aligned with the Axiata
Group-wide system. Any retaliation or discrimination against individuals who report potential violations in good faith
is strictly prohibited.
XLSMART ensures that its anti-corruption policies and procedures are communicated across all levels of the
organization through continuous awareness programs, internal audits, and compliance reviews. Regular training
is also provided to reinforce understanding and accountability, empowering every employee to act ethically in all
situations. New employees whose roles are directly affected by ABAC are required to complete relevant training
within a prescribed period after joining XLSMART. All personnel must participate in mandatory ABAC training
programs, which are monitored for completion by the RC Division.
In 2025, XLSMART continued to strengthen its anti-corruption governance as part of the post-merger integration
process, aligning policies, procedures, and training modules across all entities under one unified standard. The
following table provides an overview of the Company’s anti-bribery and anti-corruption trainings:
Total Participating Employees in Anti-
Training Name %
Bribery and Anti Corruption Trainings
Awareness & Socialization ISO 37001: 2016 Anti Bribery Management 3,239 100
System (ABMS)
ABAC & GDS Operational and VITAL system Hands on 3,239 100
Communication on Anti-Corruption Policy & Procedures [GRI 205-2]
In 2025, XLSMART continued to communicate its anti-corruption policies and procedures to all employees and
key business partners. The communication and training sessions were conducted through both online and onsite
channels, ensuring equal access across regions and management levels. All employees and selected business
partners participated in anti-corruption awareness programs, reinforcing the Company’s commitment to ethical
conduct and zero tolerance for corruption.
The Company regularly assesses all business operations and high-risk functions for potential exposure to bribery
and corruption. In 2025, no operations were identified as having significant risks related to corruption, and there were
no confirmed incidents of bribery or corruption across the Company’s business activities. Reports and indications of
misconduct are managed through the Company’s established communication and reporting channels. [GRI 205-1]
88 PT XLSMART Telecom Sejahtera Tbk
Page 91
Connecting Indonesia:
One Purpose - One Planet
Stakeholder Relations [E.4] [GRI 2-29]
XLSMART recognises that sustainable performance is built on constructive and transparent engagement with
stakeholders. As a unified entity following the merger, XLSMART continues to strengthen relationships with both
internal and external stakeholders to ensure that business decisions reflect stakeholder expectations, regulatory
requirements, and long-term value creation.
Internally, the Company fosters a collaborative and inclusive work environment that respects employees as strategic
partners in delivering service excellence and innovation. Externally, XLSMART actively engages customers,
shareholders, regulators, suppliers, communities, and other relevant institutions to ensure that its operations
generate shared value while managing risks responsibly.
To enhance the quality of engagement, XLSMART conducts structured stakeholder mapping to identify stakeholders
who are most affected by, or have significant influence over, the Company’s operations. The mapping refers to the
AA1000 Stakeholder Engagement Standard (AA1000SES) 2015 issued by Accountability, using the elements of
Dependency (D), Responsibility (R), Tension (T), Influence (I), Diverse Perspective (DP), and Proximity (P).
Below is an overview of XLSMART’s key stakeholder groups and engagement mechanisms:
Assignment
Stakeholder Engagement Methods Frequency Topics/Issues Covered
Base
Customers D, R, T, I • Website and frontline • At any time when • Achieving service satisfaction
information necessary • Information on the latest
• In-person visits • Once a year products and services of the
• Call Center Services Company
• Customer Satisfaction • Obtaining solutions if there are
Survey questions or complaints on
products and services
• Obtaining an idea of customer
satisfaction and dissatisfaction
numbers
Shareholders D, R, I GMS Once a year The Company is able to achieve
targets in accordance with the
targets set in the previous GMS
Regulators D, R, T, I, DP Submission of compliance 4 (four) times a year Submitting information on
reports regulatory compliance
Employees D, R, T, I • Internal Media (Magazine) • Once every 3 • Socialiation of policies and
• Employee Satisfaction (three) months strategies relating to
Survey • Once a year employment
• Townhall meeting (using • Measuring employee
hybrid method) satisfaction rate and capture
their ideas and aspirations
Trade Unions D, R, T, I Discussion of Bipartite • Once in three Creating a vibrant work
Collective Labour Agreement years environment to pursue a harmonious
(Bipartite Cooperation • When necessary bipartite relationship
Institution)
Suppliers D, R, T • Employment contract If needed • Transparent procurement
• Investment partners process
• Seminars and workshops • Obtaining a mutually beneficial
cooperation
Non-D, R, T, I, D, R, T, I, DP Strategic cooperation to carry When necessary Optimising the impacts of the
DP out programs of Corporate Company’s CSR program
governmental Responsibility for both social implementation
organizations and environmental aspects
2025 Sustainability Report 89
Page 92
Sustainability
Governance
Assignment
Stakeholder Engagement Methods Frequency Topics/Issues Covered
Base
Media T, I, DP Publication of press releases When necessary • Accurate and trustworthy source
of information
• Fulfilling public information
disclosure
Community D, R, T, I, DP Meeting during social or CSR When necessary XLSMART Tri Karsa
activity implementation
Following the completion of the merger, XLSMART conducted a refreshed Double Materiality Assessment in 2025 to
ensure that the sustainability priorities of the unified entity reflect the combined operational footprint, risk exposure,
stakeholder landscape, and strategic direction of the post-merger organisation. The updated assessment was
necessary to:
• Integrate stakeholder perspectives from both legacy entities;
• Re-evaluate ESG risks and opportunities arising from the expanded network scale and digital ecosystem;
• Align sustainability priorities with evolving regulatory expectations and investor scrutiny; and
• Establish a unified materiality baseline for XLSMART going forward.
To ensure objectivity and methodological integrity, XLSMART engaged an independent third party to support
the assessment process. The resulting prioritised material topics and strategic focus areas now underpin the
Company’s post-merger sustainability direction and are elaborated in the chapter “Our Framework to Accelerating
Sustainability Journey” of this Sustainability Report.
Communication of Key Issues [GRI 2-16] [GRI 2-25]
[GRI 2-26]
The Company communicates key sustainability issues and partners through official briefings and leadership
through internal meetings, management reviews, communications. This transparent approach helped
and digital communication platforms to ensure that maintain trust, reduce uncertainty, and ensure that the
important updates and emerging concerns are shared transition aligned with XLSMART’s long-term vision for
across all relevant levels of the organization. Material or responsible and sustainable growth.
urgent matters identified during these discussions are
escalated to senior management for review and follow- In line with its commitment to openness and
up actions. accountability, XLSMART provides channels for
employees and stakeholders to raise concerns,
In 2025, XLSMART also placed a strong emphasis share feedback, or communicate sustainability-
on open and consistent communication throughout related issues. These include formal and informal
its merger process, recognizing it as a significant communication platforms, as well as the Whistleblowing
governance milestone that shaped the Company’s System, which serves as an avenue for reporting
structure, culture, and sustainability priorities. Regular suspected misconduct or violations of ethics and
updates were provided to employees, regulators, compliance standards.
90 PT XLSMART Telecom Sejahtera Tbk
Page 93
Connecting Indonesia:
One Purpose - One Planet
Whistleblowing System [GRI 2-26] [B.7.1-2]
To strengthen accountability and integrity, XLSMART • Substance abuse;
maintains a confidential and accessible whistleblowing • Theft and misuse of assets;
system. This mechanism allows employees and • Workplace and people;
stakeholders to report any suspected violations of the • Retaliation from Speaking up.
Code of Conduct or unethical behaviour without fear
of retaliation. All reports are investigated fairly and XLSMART upholds a strict non-retaliation policy to
independently, ensuring that corrective actions are protect whistleblowers who submit reports in good
taken promptly and transparently. faith. Every report received through the Speak Up
Channel is directed to the Group Head of Internal Audit
The Company provides the Speak Up Channel as a of PT XLSMART Telecom Sejahtera Tbk and reviewed
confidential platform for employees, outsourced staffs, by the Investigation Unit under the Internal Audit
suppliers, business partners, contractors, customers, Division, which determines the appropriate course of
and other stakeholders to report any suspected illegal action. Where further examination is necessary, an
acts, unethical behaviour, or other forms of misconduct. investigator will be appointed, who may be an internal
resource or an independent external party, depending
Reports can be submitted conveniently through on the nature and complexity of the case.
XLSMART’s dedicated email investigation@XLSMART.
co.id or telephone lines 081937701234. The Speak Up Whistleblowers can monitor the progress of their
Channel welcomes disclosures related to a wide range submissions and respond to follow-up questions by
of issues, including but not limited to: accessing the Speak Up Channel using their unique
• Accounting, internal controls, auditing, or IT; case number and password. Should no additional
• Anti-competitive behavior; information or evidence be provided within 14 days
• Breach of the Company’s policies or national laws; when requested, the investigation process will be closed
• Bribery and corruption; due to insufficient data.
• Data confidentiality or privacy;
• Conflict of interest; In 2025, a total of 16 (sixteen) complaints were received
• Fraud and breach of trust; through the whistleblowing channels or reported
• Gifts, entertainment, and hospitality; directly to the Investigation Unit. The status of these
• Harassment and sexual misconduct; cases is as follows:
• Health, Safety, Security, and the Environment; • 8 (eight) cases have been resolved;
• Malpractice; • 3 (three) cases were unsubstantiated; and
• Abuse of power/authority; • 5 (five) cases remain under ongoing investigation.
• Money laundering;
• Social media and business communications; All substantiated cases resulted in appropriate
corrective actions. No retaliation cases were recorded.
Whistleblowing System Socialization
The Whistleblowing System has been continuously socialized to relevant XLSMART stakeholders through the
following communication channels:
Target Audience Socialization Channels
All XLSMART Employees Employee portal, Email Blast, and Direct Socialization during Company Townhall
All Vendors & Partners Vendor Portal
Public XLSMART Official Website
2025 Sustainability Report 91
Page 94
Sustainability
Governance
The Implementation of Customer
Privacy Policy [GRI 418-1]
Safeguarding customer data and ensuring information security are integral to XLSMART’s governance practices.
The Company continues to adopt internationally recognized standards to strengthen its data protection framework.
XLSMART applies the ISO 27001 Information Security Management System (ISMS) as the foundation for securing
information assets and managing potential cybersecurity risks across its operations. Building on this framework, the
Company has achieved certification for the ISO 27701 Privacy Information Management System (PIMS), an extension
of ISO 27001 that governs the management of personal data privacy. This certification positioned XLSMART as the
first telecommunications company in Indonesia to achieve such recognition, reflecting its commitment to privacy
excellence and regulatory compliance. [GRI 3-3]
Following the completion of the merger, XLSMART is focused on establishing an integrated cybersecurity and data
protection framework that unites the strengths of both legacy systems. The Company is undertaking a comprehensive
harmonization of data governance policies, security protocols, and digital infrastructures to ensure consistent privacy
practices across all operational entities. This includes aligning data management procedures with the Personal Data
Protection (PDP) Law, strengthening access controls, and enhancing monitoring mechanisms to detect and respond
to potential threats more swiftly. These ongoing efforts are intended not only to maintain compliance but also to
enhance the Company’s ability to manage operational risks, safeguard critical assets, and strengthen technological
readiness in addressing increasingly complex cybersecurity challenges.
Throughout 2025, XLSMART continued to ensure that all data handling and processing activities complied with the
PDP Law and ISO 27701 standards. The Company also provided support to stakeholders in exercising their data
subject rights, reaffirming its commitment to transparency and accountability. According to the Company’s review
of customer data privacy protection in 2025, there were no recorded incidents or violations of the customer privacy
policy.
Code of Conduct [GRI 2-23] [GRI 2-24] [G-07]
The Code of Conduct serves as our ethical compass, guiding every employee and leader in their daily activities and
decision-making. It embodies our values of integrity, respect, and accountability. To strengthen governance and
uphold ethical business practices, the Board of Directors established the Ethics and Integrity Committee on June 30,
2020, which supports the Board by preventing, detecting, and responding to any potential fraud or misconduct.
The Code of Conduct is formally endorsed by the Board of Directors and serves as a mandatory reference for all
employees, contractors, and business partners. It is also reviewed periodically and communicated across the
organization to ensure consistent understanding and adherence. The key points of the Code of Conduct are:
92 PT XLSMART Telecom Sejahtera Tbk
Page 95
Connecting Indonesia:
One Purpose - One Planet
Equality of Treatment Healthy Partnership
Non-discriminatory treatment Build healthy business
of employees in a healthy partnerships with third parties
work environment with the by complying with XLSMART’s
application of integrity without policies and applicable
exception. regulations.
Commitment to
Anti-Corruption Culture
Avoid conflicts of interest, do Customers
not accept gratuities and apply Holding a commitment
the principles of anti-corruption, to customers by building
collusion, and nepotism. a “Trustworthy” attitude
and providing appropriate
solutions.
The Code of Conduct applies to all leaders and employees of the Company. To ensure consistent implementation, it is
regularly reviewed and communicated to ensure consistent understanding and adherence across the organization.
The Company ensures that its Code of Ethics is easily accessible to all employees through XLSMART Apps, the
internal corporate platform. New employees receive the Code during onboarding, and it is also publicly available
on the Company’s official website (https://www.xlsmart.co.id). In addition, the Company regularly circulates the
Integrity Fulfillment Statement, highlighting key ethical commitments such as anti-corruption, anti-collusion, and
anti-nepotism. Each employee is required to sign this Statement, which is then archived and managed by People
Directorate. In December 2025, the Company completed the distribution of the Integrity Fulfillment Statement, with
all employees having signed and acknowledged it.
Throughout 2025, the Ethics and Integrity Committee conducted reviews of investigation results and ensured that
appropriate disciplinary actions were implemented in accordance with the Company’s internal regulations and Code
of Ethics. In 2025, XLSMART recorded no violations of the Code of Ethics, demonstrating the strong commitment of
all employees to comply with the Company’s ethical standards.
Legal and Regulatory Compliance
[GRI 2-27] [GRI 419-1]
XLSMART maintains strict adherence to all applicable laws, regulations, and industry standards. In 2025, the
Company did not record any significant fines, sanctions, or instances of non-compliance related to environmental,
social, or governance matters.
2025 Sustainability Report 93
Page 96
Environmental
Stewardship
94 PT XLSMART Telecom Sejahtera Tbk
Page 97
Connecting Indonesia:
One Purpose - One Planet
Environmental
Stewardship
2025 Sustainability Report 95
Page 98
Environmental
Stewardship
The establishment of XLSMART marked a significant internal controls to ensure consistency with national
shift in how the Company manages and governs its and global frameworks. As part of this governance
environmental responsibilities. The merger not only enhancement, environmental and ESG responsibilities
combined networks, systems, and operational scale, were embedded across procurement, network
but also brought together two legacy organizations operations, and technology functions, reinforcing
with different levels of ESG maturity and reporting shared accountability throughout the organization.
practices. This integration created a unique opportunity
to rebuild the Company’s environmental governance on In parallel, XLSMART continued its participation in
a stronger, more cohesive foundation. selected global ESG assessments, including the S&P
Global Corporate Sustainability Assessment and
Prior to the merger, the Company had demonstrated Sustainable Fitch, while intentionally limiting external
steady progress in reducing greenhouse gas (GHG) submissions during the integration period to safeguard
emissions through network modernization, the data accuracy and reliability. With governance
deployment of energy-efficient technologies, and structures and integrated datasets now in place, the
renewable energy procurement via Renewable Energy Company plans to re-engage with CDP beginning next
Certificates. The Company had also begun expanding year and to expand its participation in international
visibility into Scope 3 emission categories, particularly sustainability ratings, including Sustainalytics and Fitch
those related to purchased goods, services, and capital ESG, as a fully unified entity.
equipment. These historical achievements now serve
as important reference points as XLSMART establishes Through this foundational phase, XLSMART has
consolidated environmental baselines for the merged established the systems, governance mechanisms,
entity. and data integrity required to support long-term
environmental performance. These advancements
Throughout 2024 and 2025, XLSMART focused on position the Company to transition from integration to
harmonizing methodologies and aligning environmental acceleration, enabling more ambitious Decarbonisation
data across its combined operations. Key efforts initiatives, deeper value-chain engagement, and the
included consolidating monitoring systems, unifying scaling of renewable energy and circular-economy
emission-calculation methods, and strengthening initiatives across the merged network footprint.
Integrating Environmental Stewardship
into Our Operations [GRI 2-24]
Environmental stewardship at XLSMART is anchored in the Company’s Environmental Management Policy,
which is aligned with ISO 14001:2015 and ISO 45001:2018. This policy provides the framework for identifying,
managing, and monitoring environmental aspects and impacts across the organization, while clearly defining the
roles and responsibilities of management, operational teams, and contractors in ensuring regulatory compliance
and preventing environmental harm. As part of its environmental management initiatives, the Company fulfils its
regulatory commitments through the application of the following procedures: [GRI 3-3]
96 PT XLSMART Telecom Sejahtera Tbk
Page 99
Connecting Indonesia:
One Purpose - One Planet
Environmental
Aspect and Impact
Identification (IADL)
4R (Reduce,
Replace, Reuse Hygiene
and Recovery) Management
Greening and
Plant Waste
Maintenance Management
Environmental
Management
In 2025, XLSMART strengthened its environmental ENVIRONMENTAL COSTS [F.4]
management approach by consolidating monitoring
mechanisms across the merged entity and harmonizing As a newly merged entity, 2025 marks the first year
operational requirements across business units. As in which XLSMART consolidates environmental
part of this roadmap, the Company plans to enhance expenditures across three legacy operational systems.
supervisory controls for contractors and field operations Environmental costs cover a range of activities, including
starting in 2026 to further reinforce compliance and waste management, environmental monitoring,
oversight across implementation activities. These environmental impact management, energy efficiency
improvements were embedded into the planning initiatives, and compliance with national health, safety,
and execution of network modernization initiatives, and environmental (HSE) regulations. This also includes
site upgrades, and expansion activities, ensuring the activities related to Environmental Management and
consistent application of environmental safeguards Environmental Monitoring (UKL/UPL), which constitute
across all business units. regulatory environmental management and monitoring
obligations under Indonesia’s environmental
As a telecommunications company with a nationwide framework.
operational footprint, XLSMART recognizes that
environmental performance is closely linked to the Throughout the year, XLSMART consolidated
design, operation, and maintenance of its digital environmental expenditure reporting across the
infrastructure. The merger presents an opportunity legacy entities and strengthened its internal recording
to reduce environmental impacts through the framework to ensure that environmental costs are
consolidation of overlapping sites, modernization captured consistently across operational regions. The
of legacy equipment, and deployment of higher- Company also standardized reporting procedures and
efficiency technologies across a unified network. supporting documentation to improve transparency
The effectiveness of these initiatives is evaluated and traceability of environmental expenditures.
through periodic audits, inspections, and performance This integration process forms an important step in
monitoring, supporting continuous improvement establishing a unified environmental expenditure
and ensuring alignment with internal policies and baseline for the merged organization.
applicable regulations.
2025 Sustainability Report 97
Page 100
Environmental
Stewardship
The consolidated environmental expenditure for 2025 amounted to Rp560,362,896, compared to Rp86,203,200
in 2024, which primarily covered UKL/UPL obligations and domestic waste management. The significant increase
mainly reflects higher UKL/UPL reporting fees and expanded waste management coverage following the
merger. UKL/UPL report fees increased significantly from Rp18,000,000 in 2024 to Rp364,500,000 in 2025 as
environmental management and monitoring activities were implemented across all operational regions. Domestic
waste management expenses also increased from Rp68,203,200 to Rp195,862,896 due to the addition of head
office and regional offices, which expanded the scope of waste management services.
While expenditure data from the legacy entities provide useful historical context, XLSMART has established 2025
as the baseline year for consolidated environmental expenditure, reflecting the scale and operational scope of
the merged organization. Accordingly, prior year figures should be interpreted with consideration of differences in
operational coverage.
UKL/UPL Report Fee (Environmental
Domestic Waste Management
Management/Environmental Monitoring)
2025 2025
Rp364,500,000 Rp195,862,896
2024 Rp18,000,000 2024 Rp68,203,200
Total
2025 2024
Rp560,362,896 Rp 86,203,200
Note: 2024 figures reflect XL Axiata Legacy (pre-merger), while 2025 figures reflect XLSMART (post-merger). Figures may not be directly
comparable with previous years.
Energy Consumption [GRI 302-1] [GRI 302-3] [OJK F.6] [OJK F.7]
Energy remains the largest contributor to XLSMART’s Insights from these evaluations guide the deployment
environmental footprint and is therefore a material focus of more energy-efficient equipment, site consolidation
of the Company’s environmental management efforts. measures, renewable-energy integration, and
Following the merger, the scale of energy consumption operational controls that strengthen overall energy
expanded significantly, requiring the consolidation performance across the network. [GRI 3-3]
of monitoring systems, the standardization of
measurement methodologies, and the integration of Network Energy Optimization
energy-efficiency requirements into network planning XLSMART implements a range of initiatives to improve
and modernization initiatives. XLSMART evaluates energy efficiency across its telecommunications
energy performance through technical inspections, infrastructure, including:
centralized monitoring dashboards, and comparative 1. Upgrading BTS equipment to more efficient
assessments across legacy networks to identify technologies, achieving electricity savings of up to
inefficiencies and determine improvement priorities. 50% compared with previous systems.
2. Migrating legacy indoor BTS sites to outdoor
configurations to reduce air-conditioning
requirements.
98 PT XLSMART Telecom Sejahtera Tbk
Page 101
Connecting Indonesia:
One Purpose - One Planet
3. Utilizing Single RAN BTS technology to consolidate Prior to the merger, XL Axiata was among the early
multiple BTS systems into a single platform, adopters of Green BTS solutions, installing solar panels
combined with Green BTS modernization using the at 252 locations. Based on historical performance
latest technological devices, resulting in energy assessments, the application of CDC systems at BTS
savings up to 50%. sites in non-electrified areas enabled an average
4. Decommissioning generators by disabling generator diesel-use reduction of 54%. These results reflect
usage and shifting backup power functions entirely legacy XL Axiata performance and are currently being
to battery systems. consolidated into a unified baseline as XLSMART
5. Expanding the use of solar panels and lithium battery harmonizes methodologies for its 2025 environmental
solutions across network sites. inventory.
RENEWABLE ENERGY DEPLOYMENT [GRI 302-4] In addition, the Company’s collaboration with PT PLN
[GRI 302-5] (Persero) to supply renewable electricity through
Renewable Energy Certificates (REC) continued in 2025.
Solar-energy utilization remains a strategic priority for The REC program verifies that electricity allocated to
XLSMART. Across the legacy XL Axiata and Smartfren BTS operations originates from renewable sources and
networks, hundreds of BTS sites had transitioned to reinforces XLSMART’s transition toward cleaner energy
solar-assisted or hybrid power systems prior to the use across its network. In 2025, XLSMART purchased a
merger. These installations continue to operate under total of 3,000,000 kWh of REC, contributing directly to
XLSMART and form the foundation for a broader the Company’s renewable-energy portfolio for the year.
renewable-energy transition. Solar and hybrid systems
help reduce diesel consumption at off-grid sites and
support the Company’s shift toward a low-carbon
operational model.
Energy Consumption within the Company [E-03]
Energy 2025 2024 2023
Energy
Consumption Energy Energy Energy Energy Energy Energy
Source
Activities Consumption Intensity Consumption Intensity Consumption Intensity
Renewable Energy
Solar Panel 334,087 kWh - - - -
1,202.71 GJ - - - -
9.10 GJ/
REC PLN 3,000,000 Petabyte 1,000,000 kWh 0.34 GJ/ - -
kWh Petabyte
10,800 GJ 3,600 GJ - -
Non-renewable Energy
Energy PLN 1,282,346.871 3,642,917 GJ/ 956,319,188.94 332 GJ/ 902,853,187.65 290 GJ/
consumption kWh Petabyte kWh Petabyte kWh Petabyte
for building lighting
4,616,448.74 3,442,742.87 3,250,271.48 GJ
and operations
GJ GJ
Energy Gasoline 312,322.00 275,593.70 228,001.34
consumption (Pertalite) Liter Liter Liter
for Gasoline
10,376.00 GJ 9,156.60 GJ 7,797.65 GJ
Energy Diesel 1,030,365.97 1,189,149.24 1,393,829.51
consumption Liter Liter Liter
for Solar (Diesel)
37,216.82 GJ 42,952.07 GJ 47,668.97 GJ
Total Energy Use 4,664,042.47 3,498,457.75 3,305,738 GJ
GJ GJ
Note:
· 2023 figures reflect XL Axiata legacy operations (pre-merger), while 2025 figures reflect XLSMART (post-merger). Smartfren data are primarily
consolidated from April to December 2025 following the completion of the merger, with limited data available prior to the merger period.
Accordingly, figures may not be directly comparable with previous years.
· Fuel consumption from liters is converted to gigajoules (GJ) using conversion factors from The Greenhouse Gas Protocol Initiative, 2004.
· Electricity consumption from kWh is converted to gigajoules (GJ) using conversion factors from The Greenhouse Gas Protocol Initiative, 2004.
2025 Sustainability Report 99
Page 102
Environmental
Stewardship
Reducing GHG Emission [GRI 305-1] [GRI 305-2] [GRI 305-3]
[GRI 305-4] [GRI 305-5] [OJK F.11] [E-01] [E-02]
XLSMART manages its GHG emissions through a structured process that includes identifying emission sources,
assessing materiality, setting reduction priorities, and implementing targeted mitigation measures. This framework
covers Scope 1, Scope 2, and Scope 3 emissions and is integrated into network planning, energy procurement, and
operational decision-making. Emissions performance is monitored regularly using harmonized methodologies
across the merged entity and reviewed to support continuous improvement in line with regulatory requirements and
the Company’s long-term Decarbonisation objectives. [GRI 3-3]
Starting in April 2025, GHG emissions data from Smartfren were integrated into the Company’s reporting system
following the completion of the merger. Accordingly, 2025 represents the first year of consolidated emissions
reporting. Smartfren data are primarily consolidated from April to December 2025 following the completion of the
merger, with limited data available prior to the merger period. A new baseline has therefore been established in 2025
to reflect the full operational scope of the merged entity. While prior-year data are presented for transparency, year-
on-year comparisons should consider changes in reporting boundaries and category coverage.
Scope of GHG Emission
2025 2024 2023
Emission Emission Emission
Scope of GHG Intensity Per Intensity Per Intensity Per
Unit Total Total Total
Emission Revenue Revenue Revenue
Emission Emission Emission
TonCo2e/ TonCo2e/ TonCo2q/
Billion Rp Billion Rp Billion Rp
Scope 1 (Direct TonCO2eq 36,476.89 0.0817 4,082.53 118.71 4,255.54 131.66
Emission)
Scope 2 (Indirect 988,304.73 23.254 744,398.86 21,644.54 695,828.95 21,527.36
Emission)
Scope 3* (Indirect 477.17 0.0112 4,252.47 123.65 5,743.82 177.70
Emission)
Note (*):
· 2024 data covered Category 4, 5, 6, 7, 9, and 13 of XL Axiata Legacy (pre-merger).
· 2025 data cover only Category 6 (Business Trips) and Category 7 (Employee Travel) while 2025 figures reflect XLSMART (post-merger). Figures
may not be directly comparable with previous years.
The significant decrease in Scope 3 emissions in 2025 compared to prior years primarily reflects limited category
coverage during the integration phase rather than a structural reduction across the full Scope 3 value chain.
Scope 3 Emissions Breakdown [GRI 302-2]
In 2023 and 2024, the Company disclosed multiple Scope 3 categories, including upstream and downstream
transportation, waste generated from operations, business travel, employee travel, and leased assets. During the
2025 integration period, the Company prioritized the calculation and disclosure of two Scope 3 categories, namely
Category 6 (Business Trips) and Category 7 (Employee Travel), based on data availability and system readiness
across the merged entity.
Category 2025 2024 2023
Category 6: Business Trips 357.48 371.12 596.05
Category 7: Employee Travel 119.69 1,128.3 702.45
Note:
· 2024 and 2023 figures reflect XL Axiata Legacy (pre-merger), while 2025 figures reflect XLSMART (post-merger), with Smartfren data included
from April–December 2025. Figures may not be directly comparable with previous years.
· 2024 Employee Travel figure used the employee survey with more granular data obtained.
100 PT XLSMART Telecom Sejahtera Tbk
Page 103
Connecting Indonesia:
One Purpose - One Planet
The Company plans to progressively expand Scope 3 These initiatives demonstrate how digital technology
category coverage in 2026 following the harmonization can accelerate the adoption of electric mobility and
of data systems and operational reporting processes support the development of cleaner, more efficient
across the merged entity. transportation systems in Indonesia. XLSMART
continues to build on these foundations as part of
Supporting Low-Emission Ecosystems Through its long-term commitment to enabling low-carbon
Technology and Industry Partnerships [OJK F.12] ecosystems. Several operational measures introduced
Beyond reducing emissions within its own operations, prior to the merger also continued in 2025, including:
XLSMART continues to advance initiatives established 1. Development of a multi-platform Energy Monitoring
prior to the merger to support Indonesia’s broader System to track and analyze energy consumption;
transition toward a low-emission ecosystem. The 2. Development of a real-time Network Monitoring
Company’s collaboration with Kadin Net Zero Hub, System to oversee operational performance,
initiated in November 2023, remains an important including site monitoring;
platform for industry-wide climate action and aligns 3. Implementation of smart energy management
with the national Decarbonisation agenda. initiatives, including Xinergis by X-Camp for real-
time monitoring of electricity, water, and generator
Prior to the merger, the Company began advancing fuel consumption, and Powersense, an IoT-based
technology-driven climate solutions through strategic system to optimize air conditioner energy use;
partnerships, which now form part of XLSMART’s 4. Expansion of solar panel installations as part of the
ongoing approach. These initiatives include: Company’s renewable energy initiatives;
• A strategic collaboration with Xanh SM to deploy 5. Procurement of renewable electricity through
Internet of Things solutions that enhance the Renewable Energy Certificates (REC);
performance and energy efficiency of electric 6. Implementation of internal campaigns to promote
vehicle fleets, helping reduce transportation-related energy efficiency and electricity savings among
emissions and improve operational efficiency. employees.
• A partnership with PT Ide Inovatif Bangsa (Quest
Motors) to integrate digital connectivity into electric
motorcycle fleets, enabling real-time monitoring,
route optimization, and more efficient energy use
compared with vehicles powered by fossil fuels.
Waste Management [GRI 306-1] [GRI 306-2] [OJK F.14]
Telecommunication activities generate a wide range Employee engagement remains a key enabler of
of waste streams, including hazardous (B3) and effective waste management. Prior to the merger,
non-hazardous materials from network equipment, XL Axiata implemented internal initiatives such as
batteries, lamps, electronic components, cooling Sustainability Week, Waste Management Race,
systems, office operations, and field maintenance. The and World Environment Day activations to promote
establishment of XLSMART in 2025 resulted in a larger responsible waste segregation and reduction. These
and more complex operational footprint, requiring programs continue under XLSMART and have been
waste to be managed under a unified and strengthened expanded to reach employees across the merged
environmental standard. operational footprint. Messaging emphasizes
practical actions, including reducing single-use
XLSMART identifies waste-related impacts across its plastics, minimizing paper consumption, accurate
operations, assesses risks associated with improper waste segregation, and participation in internal-
storage or disposal, and implements mitigation waste tracking initiatives within office and technical
measures through standardized handling procedures, environments.
contractor supervision, and regulatory compliance
checks. Hazardous waste is collected, transported, and
processed exclusively by licensed third-party service
providers, while non-hazardous waste is minimized
through recycling initiatives, material substitution, and
internal awareness programs. [GRI 3-3]
2025 Sustainability Report 101
Page 104
Environmental
Stewardship
In 2025, a significant contributor to the Company’s Through this approach, XLSMART ensured that the
waste generation was the large-scale dismantling of dismantling of decommissioned BTS sites did not result
redundant base transceiver station (BTS) sites following in uncontrolled accumulation of electronic waste or
network integration. This dismantling was necessary to unmanaged hazardous materials. The process also
eliminate overlapping infrastructure, enhance energy supports the Company’s broader resource-efficiency
efficiency, and modernize network architecture. The objectives by maximizing material recovery and
process generated substantial volumes of electronic reducing landfill disposal.
components, metals, batteries, cabling, and mixed
materials, all of which required strict environmental This dismantling initiative aligns with XLSMART’s
controls. circular economy commitment, under which materials
are recovered, repurposed, and returned to productive
To mitigate environmental risks, XLSMART implemented use whenever feasible. By extending the useful life of
a controlled dismantling protocol supported by components, reducing dependence on virgin resources,
internationally certified vendors specializing in and ensuring that residual waste is processed through
telecommunications equipment decommissioning certified recycling channels, the Company embeds
and e-waste recovery. These vendors operate in circularity into its network modernization activities and
accordance with ISO 14001 and ISO 45001 standards reinforces a regenerative approach to infrastructure
and provide full traceability for both hazardous and lifecycle management.
non-hazardous waste streams, from site removal
through transportation and final treatment. Reusable
components are extracted for refurbishment, while
non-recoverable materials are directed to licensed
recycling facilities to prevent improper disposal and
environmental leakage.
102 PT XLSMART Telecom Sejahtera Tbk
Page 105
Connecting Indonesia:
One Purpose - One Planet
Total Waste Generated from Operations [OJK F.13] [GRI 306-3] [GRI 306-4] [GRI 306-5] [E-05]
Descriptions Unit 2025 2024
Disposable Ton 24.48 20.01
Recycled/Reused Ton 73.29 77.10
Hazardous Waste* Ton 3.04 8.67
Wet Waste Ton 2.1 1.05
Dry Waste Ton 18.27 1.34
Electronic Waste (Electronic Equipment, Passive Equipment, Iron and Ton N/A* 186.22
Cable)
Note (*):
· Other than hazardous waste, 2024 figures reflect XL Axiata Legacy (pre-merger), while 2025 figures reflect XLSMART (post-merger), with
Smartfren data included from April–December 2025. Figures may not be directly comparable with previous years.
· Figures of hazardous waste represent XL Axiata Legacy only.
· The appointment of a certified e-waste management vendor for e-waste generated from network dismantling activities was finalized in Q4
2025. As measurement commenced in Q4, comprehensive data collection and reporting will begin in 2026.
DOMESTIC WASTE MANAGEMENT [OJK F.14]
Domestic waste from XLSMART’s daily operations primarily consists of organic waste from office activities and
inorganic materials such as plastic, paper, cardboard, metal scraps, broken glass, and packaging materials.
Although non-hazardous, this waste requires structured handling to maintain operational efficiency and prevent
unnecessary environmental burden.
Most domestic waste is recycled through licensed third-party waste management operators, while certain fractions
are repurposed into alternative fuel, compost, or animal feed, thereby reducing the amount of waste sent to landfills.
All waste-handling procedures comply with the requirements of ISO 14001:2015 and ISO 45001:2018, and are
routinely monitored to ensure proper segregation, recording, and disposal.
No Plastic Zone at E-Waste Management Smart Digitalization
Workplace Care
by providing reusable cutlery by recycling IT and Network by introducing e-Business Card
packs for employees waste through a licensed third Solution to reduce printing of
party business cards
Resources Use & Efficiency [OJK F.14]
Resource efficiency is embedded into XLSMART’s operational philosophy through the adoption of digital processes,
environmentally responsible procurement, and the optimization of material use. The increased use of eSIM
technology, the deployment of fiber-optic infrastructure in place of copper, and the prioritization of certified raw
materials reflect the Company’s commitment to reducing material intensity and supporting circular practices.
XLSMART also promotes employee awareness by encouraging the use of reusable products, minimizing paper
printing, and transitioning operational materials to recycled or eco-certified alternatives. These efforts contribute to
lower resource consumption and a more sustainable operating environment.
2025 Sustainability Report 103
Page 106
Environmental
Stewardship
· Utilizing COUPA as an integrated digital procurement system to reduce paper waste and support
the Go Green initiative.
· Providing environmentally certified raw materials, such as the use of FSC or PEFC certified paper,
to support our operational needs.
Partner · Agreeing to comply with XLSMART sustainability principles at the time of registration.
· Prioritize reusable materials or products to reduce single-use paper and plastics, including plastic
cups, plastic bottles, and plastic cutlery in office spaces, canteens, pantries, and meeting rooms.
· Prioritize e-mail in doing correspondence with partners and corporate customers instead of
printing documents, supporting cost efficiency and faster communication.
· Encourage responsible waste management practices by implementing waste segregation into
three categories: organic, non-organic, and plastic across office areas.
Employees · Conducted the Waste Management Race, a competition for each floors with the best waste
segregation practices. The winning team received a giant trophy (piala bergilir) and a shared
buffet snacks reward to reinforce positive behavioral change and collective accountability.
· Optimizing paper usage for physical vouchers, such as in 3in1 voucher.
· Replacing copper cables to fibre optics that are more environmentally friendly.
· Utilizing recycled materials for marketing kits. [GRI 301-2]
Products and · The launch of e-Sim card
Service Delivery
WATER USE [OJK F.8] [GRI 303-3] [GRI 303-5] [E-04]
Beyond energy optimization, the Company manages water use to minimize environmental impact while supporting
operational excellence. Although telecommunications operations are not water-intensive, XLSMART maintains
oversight of its water consumption to ensure responsible use of shared natural resources. Water is primarily used in
office facilities, data centers, and employee activity areas, supplied through Public Water Supply Company (PDAM)
which are managed by third parties or building management.
Water Consumption
PDAM
(m3)
2025 2024 7,497.46
27,198.99 2023 7,497.46
Note:
· 2024 and 2023 figures reflect XL Axiata legacy (pre-merger).
· 2025 figures reflect the combined full-year data of XL Axiata and Smartfren under XLSMART.
· Figures may not be directly comparable with previous years.
The significant increase in water consumption in 2025 was primarily driven by the expansion of the Company’s
operational footprint following the merger, including the addition of office buildings, regional facilities, and data
center infrastructure. Renovation activities at the Sabang Head Office during the year also contributed to higher
water usage. As operational activities expanded across these facilities, overall water consumption increased
compared to the previous year.
104 PT XLSMART Telecom Sejahtera Tbk
Page 107
Connecting Indonesia:
One Purpose - One Planet
Effluent Control and Pollution Prevention [OJK F.13] Environmental monitoring covers ambient air quality,
[OJK F.14] [OJK F.15][GRI 303-4] [E-04] including dust and noise levels, mobile and stationary
XLSMART’s operations do not generate industrial emission sources, and water quality around operational
effluents, wastewater is limited to domestic sanitation sites. These procedures enable the Company to identify
from office facilities and data centers and is managed environmental risks at an early stage and implement
through Wastewater Treatment Plants (WWTP) owned corrective actions promptly to prevent pollution.
and operated by building management or licensed Regular supervision also ensures that hazardous
third-party operators. These systems ensure that waste, wastewater, and operational by-products are
effluent meets regulatory quality standards before managed safely and responsibly.
discharge into water bodies or municipal channels.
Throughout 2025, no spills, leakages, or effluent- In addition, XLSMART contributes indirectly to pollution
related environmental incidents were reported. reduction through its digital and broadband services. By
enabling remote work, digital transactions, and online
XLSMART also ensures full compliance with learning, the Company helps reduce transportation
environmental regulations through systematic needs, thereby lowering associated emissions for
monitoring of air emissions, noise levels, wastewater, customers and the broader community.
effluents, and hazardous waste handling. These controls
are implemented in alignment with ISO 14001:2015, ISO
45001:2018, and applicable government regulations,
including Government Regulation No. 20/2012 on
environmental management and pollution prevention.
Technology to Preserve Biodiversity [OJK F.9]
[OJK F.10] [GRI 304-1]
XLSMART ensures that all network infrastructure, including BTS towers, fiber-optic routes, and supporting facilities, is
located outside protected areas and biodiversity-sensitive zones. In line with regulatory requirements, all operational
sites are screened against spatial planning regulations and environmental criteria to ensure that they do not interfere
with ecologically significant areas. [GRI 3-3]
The Company maintains close coordination with local authorities to ensure that any maintenance, upgrade, or site
improvement activities remain compliant with environmental guidelines and do not disrupt surrounding natural
ecosystems. Based on these assessments, XLSMART did not operate in conservation areas, protected forests, or
other high-biodiversity zones during 2025.
In addition to regulatory compliance, XLSMART supports ecosystem sustainability through technology-enabled
initiatives, namely:
2025 Sustainability Report 105
Page 108
Environmental
Stewardship
Initiative Focus Area Environmental Contribution Implementation Status
HydroponiX (Smart Sustainable urban • Promotes sustainable agriculture practices Managed by CSR
Agriculture) farming through IoT- • Reduces water and nutrient waste through beneficiaries as part of
enabled hydroponic precise monitoring community
systems • Supports food production in limited urban empowerment programs
spaces
• Provides real-time cultivation data for better
decision-making
X-Maggot (Smart Organic waste • Supports sustainable organic waste reduction Managed by CSR
Waste Management) processing using Black • Diverts waste from landfills beneficiaries
Soldier Fly larvae with • Encourages circular waste management
IoT monitoring practices
PowerSense (Smart IoT-based AC control in • Optimizes energy consumption Ongoing implementation
Energy) BTS shelter towers • Prevents electricity overuse at BTS shelter towers in
• Supports potential energy savings and reduced the JABODETABEK region
environmental impact
Xinergis (Smart IoT-based monitoring of • Enables responsible and efficient resource Active across several
Building/Energy electricity, generator, management XLSMART regional offices
Monitoring) and water usage • Provides data-driven insights for sustainability
performance
Future Environmental Priorities
As XLSMART transitions from integration to Energy-transition initiatives will remain a strategic
acceleration, the Company is preparing a set of priority. XLSMART is expanding its Green BTS program
forward-looking environmental priorities that will guide and initiating preparations for Green Data Center
its sustainability agenda over the next three years. development, with a focus on low-PUE, efficient
cooling technologies, and scalable renewable-
A key focus is the development of the Net Zero energy solutions. These initiatives will accelerate the
Roadmap, scheduled to commence in 2026 and aligned Company’s shift toward a more energy-efficient and
with international frameworks such as the Science climate-resilient network.
Based Targets initiative (SBTi). This roadmap will define
Decarbonisation pathways across network operations, In addition, several operational components will
data centers, supply chains, and office facilities, be refined beginning in 2026, including baseline
supported by near-term science-based targets, measurements for business travel emissions, employee
renewable-energy strategies, and energy-efficiency commuting, and product life-cycle impacts. These
commitments across both existing and new sites. With enhancements will support a more comprehensive
the merged entity projected to operate between 47,000 Scope 3 emissions assessment and inform supplier-
and 49,000 sites by the end of 2026, the deployment engagement programs aimed at reducing value-chain
of low-power and energy-efficient equipment will be emissions.
critical to reducing operational emissions. [OJK F.12]
The Company will also scale its circular economy and
e-waste management framework. XLSMART is finalizing
a unified policy for hazardous and electronic waste that
complies with Indonesia’s environmental regulations,
including B3 waste standards. This framework
incorporates vendor compliance requirements, end-
to-end traceability, and partnerships with certified
recyclers capable of managing large-scale electronic
waste nationwide. Given that the merger resulted in the
largest consolidated waste stream in the Company’s
history, this initiative represents a core pillar of
XLSMART’s environmental responsibility.
106 PT XLSMART Telecom Sejahtera Tbk
Page 109
Connecting Indonesia:
One Purpose - One Planet
Environmental Compliance [OJK F.15] [OJK F.16]
XLSMART maintains strict oversight of environmental risks across its operational footprint to ensure that activities
such as network maintenance, equipment mobilization, and site operations do not cause disturbance or adverse
impacts to surrounding communities. The Company’s practices in energy efficiency, emission reduction, and
responsible waste management contribute to minimizing potential environmental externalities.
Throughout 2025, no complaints were received from local communities regarding environmental impacts arising
from XLSMART’s operations. This outcome reflects the effectiveness of preventive controls and the Company’s
commitment to responsible operations during the post-merger integration period.
To support transparency and continuous improvement, XLSMART provides dedicated communication channels
through which stakeholders may submit reports, suggestions, or complaints related to environmental matters.
These channels ensure that any environmental concerns are promptly reviewed and addressed in accordance with
established internal procedures.
e-mail: corpcomm@xlsmart.co.id @xlsmart @xlsmart
Phone: (021) 579 59817/576 1880 @xlsmart @xlsmart
2025 Sustainability Report 107
Page 110
Solid Performance to
Empower the Nation
108 PT XLSMART Telecom Sejahtera Tbk
Page 111
Connecting Indonesia:
One Purpose - One Planet
Solid Performance to
Empower the Nation
2025 Sustainability Report 109
Page 112
Solid Performance to
Empower the Nation
Economic Performance [GRI 201-1]
With the establishment of XLSMART as a unified entity Total data traffic reached 14,566 Petabytes in 2025,
following the merger, 2025 marks a transformative increasing from 10,547 Petabytes in 2024. The
milestone in strengthening Indonesia’s digital economy. growth reflects the continued acceleration of digital
The integration has significantly expanded network scale, consumption, increasing reliance on mobile data
customer reach, infrastructure assets, and operational services, and the structural shift toward digital-first
capability, positioning XLSMART as one of the largest economic activity in Indonesia. The enlarged customer
digital connectivity providers in the country. This year’s base of 73.0 million subscribers in 2025, compared to
performance showed that the integration is progressing 58.8 million in 2024, demonstrates the multiplier effect
as planned and is expected to be completed within eight of post-merger integration in expanding market access
quarters from Legal Day 1 (16 April 2025). and service delivery.
Economic sustainability remains a core priority. The Economic Value Generated and Distributed [GRI
Company recognises the importance of maintaining 201-1]
long-term economic growth and development without Following the merger, XLSMART’s expanded operational
compromising the ability of future generations to meet scale strengthens its capacity to generate and distribute
their own needs. XLSMART’s economic sustainability economic value across Indonesia’s digital ecosystem.
goal is to balance business expansion with responsible The Company manages its economic performance
resource utilisation, ensuring that financial resilience through disciplined financial oversight, responsible
is aligned with environmental stewardship and capital allocation, and continuous infrastructure
social progress. Together, these three pillars operate investment to support national connectivity expansion.
in harmony to create a sustainable framework Post-merger integration included harmonisation of
that enables the Company to anticipate structural financial systems, optimisation of procurement and
challenges such as climate change, resource scarcity, capital planning processes, and alignment of investment
digital inequality, and evolving regulatory expectations. priorities to ensure sustainable growth and operational
efficiency. Economic performance is evaluated through
As the Company advances toward its economic key indicators including revenue growth, profitability,
sustainability goals, XLSMART continues to drive retained earnings, infrastructure expansion, and
innovation and adaptation across its economic activities customer base development. Performance reviews are
while ensuring responsible practices remain embedded conducted regularly at executive and Board levels to
throughout operations. Continuous investments in ensure alignment with strategic objectives and long-
infrastructure enhancement and nationwide network term value creation. [GRI 3-3]
expansion remain central to this strategy. The Company
is also at the forefront of implementing new technologies Through this structured approach, the Company ensures
that generate broader economic benefits, thereby that economic growth supports shareholder returns
reinforcing its contribution to Indonesia’s sustainable while simultaneously strengthening employment,
development agenda. [GRI 3-3] domestic supply chain circulation, and broader digital
inclusion across Indonesia.
Following the merger, XLSMART operates at
significantly greater scale, managing 225,649 BTS Financially, the Company demonstrated a solid
in 2025 compared to 156,864 in 2024 and 160,124 in performance throughout the year. Following the
2023. This expanded infrastructure directly supports merger, the combined entity continued to deliver
digital inclusion, strengthens national connectivity positive performance, supported by significant revenue
resilience, and enhances productivity across sectors growth and improved contribution from data and
including MSMEs, education, financial services, digital
entrepreneurship, and government services.
110 PT XLSMART Telecom Sejahtera Tbk
Page 113
Connecting Indonesia:
One Purpose - One Planet
digital services. XLSMART recorded revenue of Rp42.5 Rp33,166,342 million in 2024. The Company distributed
trillion, up 23% from Rp34.4 trillion in 2024, supported economic value through:
by improved contribution from data and digital • Infrastructure development and network expansion
services. While profitability declined due to merger- • Employee salaries and benefits
related expenses, the Company maintained normalized • Interconnection and other direct operating expenses
EBITDA growth of 13% to Rp20.1 trillion, in line with the • Sales and marketing activities
post-merger target. • Finance costs and capital servicing
• Tax payments to the Government
Net profit/(loss) in 2025 amounted to Rp(4,414,102) • Dividend payments to shareholders
million, compared to Rp1,847,631 million in 2024. The • Community investment programmes
2025 position reflects the financial impact of merger
integration, including harmonisation of accounting Retained economic value in 2025 amounted to
treatments, consolidation adjustments, and Rp(1,492,224) million, compared to Rp1,176,707
integration-related expenditures, while maintaining million in 2024. This reflects the Company’s continued
operational continuity and revenue stability. reinvestment to strengthen network modernisation,
support integration optimisation, and sustain long-
Total direct economic acquisition in 2025 reached term strategic development.
Rp41,432,011 million, compared to Rp34,343,049
million in 2024. The total economic value distributed in Below is the table of the XLSMART’s total economic
2025 amounted to Rp42,924,235 million, compared to value acquisition and distribution:
(In Rp Million)
ECONOMIC PERFORMANCE 2025 2024 2023
ECONOMIC VALUE ACQUISITION
Net Revenue 42,445,960 34,391,597 32,322,651
Profit (loss) exchange difference - net 8,699 (16,326) 12,977
Gain from the sale and leaseback of tower 141,227 415,641 424,062
Others (1,055,559) (230,290) (80,900)
Finance income 97,860 80,256 100,096
Share of profit/(loss) from Associate Entity (206,176) (297,829) (191,493)
Total Direct Economic Acquisition 41,432,011 34,343,049 32,587,393
ECONOMIC VALUE DISTRIBUTION
Depreciation expenses (17,585,538) (12,074,335) 11,347,758
Infrastructure expenses (12,327,392) (8,942,323) 8,995,646
Sales and marketing expenses (2,299,737) (2,094,192) 2,454,775
Interconnection and other direct expenses (4,909,568) (3,284,180) 3,172,220
Salaries and employee benefits expenses (4,286,366) (1,736,074) 1,402,242
General and administrative expenses (841,999) (454,990) 413,040
Amortisation expenses (428,521) (216,928) 157,216
Finance cost (4,015,661) (3,112,802) 2,939,979
Income tax expense/(benefit) 848,669 (579,594) 420,069
Cash dividends paid 2,893,778 (635,296) 549,023
Community expenditure 28,100 35,628 20,735
Total Economic Value Distribution 42,924,235 33,166,342 31,872,703
Retained Economic Value (1,492,224) 1,176,707 714,690
2025 Sustainability Report 111
Page 114
Solid Performance to
Empower the Nation
Comparison of Target and Production Performance, Portfolio, Financing Target, or Investment, Income
and Profit and Loss [F.2]
The Company monitors the achievement of operational and financial targets through measurable production and
performance indicators. In 2025, the first full year following the merger, operational scale expanded significantly
compared to the prior year.
The number of BTS reached 225,649 units in 2025, compared to 156,864 units in 2024. The substantial increase
reflects network consolidation, infrastructure integration, and optimisation of combined assets following the merger.
The expanded infrastructure strengthens service reliability and nationwide coverage.
Based on the financial indicators presented in the table below, the Company recorded revenue growth of 23% in
2025, in line with its target of maintaining growth at market level. EBITDA margin reached 42%, remaining within the
targeted range of low to mid 40%.
Capital expenditure in 2025 amounted to Rp11.19 trillion, slightly above the planned investment target of approximately
Rp10 trillion. The higher capital allocation reflects continued investment in network integration, infrastructure
expansion, and technology upgrades following the merger.
Net profit/(loss) in 2025 amounted to Rp(4,414,102) million compared to Rp1,847,631 million in 2024. The loss is
primarily attributable to integration-related adjustments, consolidation costs, and other non-recurring impacts
associated with the merger process.
Financial Indicators 2025 Actual 2025 Targets 2024 Actual
Revenue Growth 23% In line with the market 6%
EBITDA Margin 42% Low to mid 40% 52%
Capital Expenditure Rp11.19 trillion Approximately Rp10 trillion Rp7.38 trillion
Comparison of Targets and Investment Realization in Environmental Preservation Projects [F.3]
In 2025, the Company allocated capital expenditure toward renewable energy integration as part of its operational
infrastructure planning. This investment aligns with XLSMART’s commitment to accelerating carbon neutrality
through environmentally responsible and sustainable digital innovation, ensuring that network expansion is
progressively supported by cleaner energy sources.
For the reporting year, the Company set a target to increase renewable energy attributes and expand solar panel
installations across its network infrastructure. The realisation in 2025 included:
• Installation of 9 new solar panel sites, with 2 sites decommissioned, resulting in a net increase of 7 sites and
bringing the cumulative total to 259 solar panel sites.
• Acquisition of 3,000 RECs, equivalent to 3,000 MWh of renewable energy attributes.
Year Target Realisation
2025 Additional renewable energy · Acquisition of 3,000 RECs equivalent to 3,000 MWh.
attributes and solar panel site · Installation of 9 new solar panel sites at Smartfren legacy locations,
installations with 2 sites decommissioned, resulting in a net increase of 7 sites and
bringing the total to 259 solar panel sites, compared to 252 in the
previous year.
2024 Additional renewable energy · Acquisition of 1,000 RECs equivalent to 1,000 MWh.
attributes and 4 solar panel site · Installation of 4 solar panel sites.
installations
2023 Addition of solar panel site Installation of 46 solar panel sites.
installations
112 PT XLSMART Telecom Sejahtera Tbk
Page 115
Connecting Indonesia:
One Purpose - One Planet
The increase in RECs procurement reflects an In 2025, XLSMART employed a total of 3,239
intentional shift toward renewable energy sourcing employees, reflecting the expanded organisational
within the Company’s operational energy mix. RECs structure following the merger. The enlarged entity
are internationally recognised instruments that enable creates broader employment opportunities while
a corporate user to claim the environmental benefits reinforcing the Company’s commitment to inclusive
of electricity generated from renewable sources, workforce development. Recruitment processes remain
even when the physical electricity consumed remains competency-based, ensuring that candidates from
sourced from conventional electricity sources. This local communities who meet the required qualifications
approach is consistent with prevailing industry are provided equal opportunity to grow within the
practices and broader energy transition collaborations. organisation.
Solar panel installations contribute directly to Meanwhile, in 2025, the Company had 23 individuals
reducing reliance on conventional electricity sources serving in senior leadership positions. Of this number,
at selected operational sites, particularly within 13 were Indonesian nationals, representing 56.5% of
network infrastructure where energy reliability and total senior leadership positions. Senior management
efficiency are critical. The combined approach of on- positions occupied by employees recruited from local
site solar deployment and REC acquisition strengthens communities increased compared to the previous
the Company’s renewable energy footprint while year, reflecting continued efforts to strengthen local
maintaining operational stability. leadership representation. This reflects the Company’s
continued effort to ensure that leadership representation
Environmental capital allocation is incorporated into incorporates local insight, operational familiarity, and
annual infrastructure and energy planning processes contextual understanding of the markets in which it
to ensure alignment between network expansion, operates.
energy efficiency improvements, and long-term
decarbonisation objectives. Workforce distribution across regions further
demonstrates the Company’s operational footprint.
PROPORTION OF SENIOR MANAGEMENT FROM While a significant proportion of employees are based
LOCAL COMMUNITIES [202-2] in Jabodetabek, consistent with the concentration of
corporate headquarters and network management
XLSMART recognises that sustainable economic functions, the Company also maintains workforce
growth must be supported by meaningful participation presence in other regions to support nationwide
of local communities in its workforce and leadership operations. Through structured career pathways,
structure. As part of its commitment to strengthening competency development programmes, and
domestic economic contribution, the Company succession planning initiatives, XLSMART aims to
prioritises the development and advancement of local build sustainable leadership pipelines from within
talent across operational and managerial levels. For local communities. This approach ensures continuity,
the purpose of this disclosure, senior management strengthens institutional knowledge, and supports
refers to top leadership positions within the Company’s long-term organisational resilience.
organisational structure. [GRI 3-3]
The Company’s workforce composition and
representation of local communities within senior
management are presented in the table below:
Descriptions 2025 2024 2023
Total Employees 3,239 1,663 1,495
Local Employees* 3,214 1,648 1,480
Senior Leadership Positions (Total) 23 14 13
Senior Leadership from Local Communities 13 8 3
Local Representation in Senior Leadership (%) 56.5% 57.1% 23.1%
Female Employees 932 495 448
Female Representation in Senior Leadership 1 3 3
By Region
Jabodetabek 2,414 1,381 1,267
Outside Jabodetabek 825 282 228
*Local Employees refer to Indonesian nationals employed by the Company (non-expatriates)
2025 Sustainability Report 113
Page 116
Solid Performance to
Empower the Nation
Market Presence Expansion and Indirect
Economic Impact [GRI 203-2]
Beyond direct economic value generated, XLSMART The enlarged network footprint enables faster
contributes to broader economic development through deployment of advanced technologies, including
significant indirect impacts arising from its network 5G rollout, while improving customer experience
expansion and digital connectivity services. Following through more consistent service performance. As
the merger, XLSMART expanded its operational scale digital connectivity becomes increasingly central to
nationwide and strengthened its capacity to accelerate commerce, financial inclusion, and service delivery,
network investments, improve service quality, and strengthened infrastructure directly supports broader
extend coverage reach across both urban centres and participation in Indonesia’s digital economy.
underserved areas.
The downstream economic impacts include:
The integration of network assets and operational • Improved productivity for SMEs, supported by
systems enhances resilience, optimises capacity stronger and more consistent connectivity for
utilisation, and improves overall service quality. By daily operations, digital marketing, and online
consolidating infrastructure and operating under a transactions.
unified network framework, XLSMART strengthens • Increased digital financial transactions, enabled
Indonesia’s digital backbone and improves economic by more reliable mobile data access and platform
accessibility for millions of users who rely on stable stability.
connectivity for daily economic activity. • Expansion of the digital services ecosystem,
including e-commerce, digital content, and cloud-
based solutions.
• Greater employment multiplier effects across the
digital value chain as network expansion stimulates
demand for supporting services and local partners.
Sustainable Supply Chain [204-1]
XLSMART’s success is built upon strong and Supplier selection is conducted through transparent
collaborative relationships with its stakeholders, and structured procurement mechanisms to ensure
including business partners who share a common fairness, regulatory compliance, and alignment with
commitment to sustainable value creation. The ethical standards. All suppliers are provided equal
Company recognises that supply chain management opportunity to participate in procurement activities
plays a critical role in maintaining operational under clearly defined evaluation criteria. Performance
continuity, service quality, and long-term value and compliance are monitored throughout the
creation. Therefore, supplier governance is embedded contractual relationship to manage operational, legal,
within the Company’s procurement framework and risk and reputational risks. [GRI 3-3]
management processes.
In 2025, XLSMART collaborated with 659 vendors,
The Company has established a supply chain consisting an increase from 537 vendors in 2024. Of this total,
of selected and verified suppliers who contribute to 602 vendors were local suppliers, representing
the delivery of its products and services. In navigating approximately 91% of the total supplier base, compared
dynamic global economic conditions, local engagement to 484 local vendors in 2024. This demonstrates a
remains a strategic priority to support supply chain consistent prioritisation of domestic suppliers within the
resilience, competitive pricing, quality assurance, and Company’s procurement structure.
timely delivery of goods and services.
114 PT XLSMART Telecom Sejahtera Tbk
Page 117
Connecting Indonesia:
One Purpose - One Planet
From a contract value perspective, total procurement spending reached Rp37,513.0 billion in 2025, significantly
higher than Rp15,528.8 billion in 2024, reflecting expanded operational scale following the merger. Of this amount,
Rp36,730.6 billion, or more than 97% of total procurement value, was allocated to local suppliers. In comparison,
Rp15,068.4 billion was distributed to local suppliers in 2024.
This substantial allocation to domestic vendors illustrates the Company’s direct contribution to Indonesia’s economic
ecosystem, supporting local enterprises, supply chain capacity building, and regional economic participation.
The detailed composition is presented below:
Total Vendors Contract Value (Rp Billion)
Descriptions
2025 2024 2023 2025 2024 2023
Local (Indonesia) 602 484 431 36,730.6 15,068.4 13,554.4
Foreign (Overseas) 57 53 48 782.2 460.4 377.4
Total 659 537 479 37,513.0 15,528.8 13,931.8
In interacting with business partners, XLSMART upholds the highest ethical standards across all procurement
activities. As stipulated in the Axiata Supplier Code of Conduct (“Code”), the Company clearly communicates its
expectations regarding responsible business conduct. Compliance with these standards is monitored throughout the
engagement lifecycle.
Vendor selection and onboarding require suppliers to comply with applicable legal standards, fair business practices,
labour protection principles, and anti-corruption requirements. All suppliers are required to confirm that:
• Child labour and forced labour are strictly prohibited.
• Workers operate in safe and lawful conditions.
• Operational permits and legal documentation are valid.
• Bribery and corruption are not tolerated.
Vendor assessments are conducted prior to engagement, and corrective actions are implemented where non-
compliance or potential risks are identified. Where feasible, XLSMART prioritises regional suppliers to support local
economic ecosystems and community-based participation within its supply chain network.
Financial Assistance from the
Government [GRI 201-4]
Throughout 2025, XLSMART did not receive any financial assistance from the Government in any form. The Company
operates independently without reliance on direct government grants, subsidies, tax relief, or other forms of financial
incentives.
2025 Sustainability Report 115
Page 118
Solid Performance to
Empower the Nation
Taxation Policy [GRI 207-1] [GRI 207-2] [GRI 207-3] [GRI 207-4]
XLSMART recognises taxation as a fundamental To ensure compliance, the Company adheres to all
component of its economic contribution to Indonesia. applicable laws and maintains open communication
Through responsible tax payments, the Company with relevant tax authorities. The tax strategy is
supports national fiscal capacity, macroeconomic reviewed annually and in consideration of outcomes
stability, and public development priorities aligned with from tax audits conducted by the Directorate General
the SDGs. of Taxes (DGT). Compliance is further verified through
internal and external audit processes, including
The Company manages taxation as an integral part of financial statement audits and tax examinations.
its financial governance framework. Tax compliance,
risk management, and regulatory monitoring are The Company maintains zero tolerance toward tax
embedded within corporate oversight structures to non-compliance. Stakeholders are encouraged to
ensure alignment with prevailing laws and long-term utilise established whistleblowing mechanisms to
business sustainability. The management of taxation report any suspected violations. The Company’s
matters is conducted through structured governance, consolidated tax position is disclosed within the audited
internal control systems, and periodic evaluation financial statements prepared by an independent
mechanisms. [GRI 3-3] Public Accounting Firm.
XLSMART fulfils its tax obligations in accordance with THE EFFECTS OF CLIMATE CHANGE ON
prevailing Indonesian taxation laws and regulations. ECONOMIC SUSTAINABILITY [GRI 201-2]
Where applicable, international tax provisions are
utilised in compliance with regulatory frameworks. In Climate change presents multidimensional risks
2025, the Company met its statutory tax obligations, affecting environmental systems, economic stability,
including Value Added Tax (VAT), Income Tax Article infrastructure resilience, and community welfare. As a
21, Income Tax Article 23, and other applicable tax digital infrastructure provider operating an extensive
requirements. network footprint across Indonesia, XLSMART
recognises that climate-related risks may have direct
Tax governance is overseen by the Head of Tax Division and indirect implications on operational continuity,
under the supervision of the Finance Director (CFO), capital expenditure, and long-term asset performance.
ensuring effective monitoring of taxation and non-
tax state revenue obligations, including PNBP where The Company has identified both physical and
relevant. The Company continuously strengthens transition-related climate risks within its operational
internal tax competency through structured trainings landscape. Physical risks include exposure of network
and workshops to enhance employees’ understanding infrastructure, including BTS sites and supporting
of taxation matters. Guidance is also provided to facilities, to extreme weather events, flooding, heat
business partners, employees, and related stakeholders stress, and other climate-related disruptions that may
regarding regulatory updates that may have tax affect service reliability or increase maintenance costs.
implications for business cooperation and employment Transition risks may arise from evolving regulatory
arrangements. requirements, carbon-related policies, shifts in energy
pricing, and changing stakeholder expectations
XLSMART adopts a conservative taxation approach, regarding decarbonisation.
taking into account regulatory risk, business substance,
and long-term sustainability considerations. For In 2025, the Company did not record material climate-
new business schemes or material transactions, related impacts that significantly disrupted business
cross-functional reviews are conducted, including operations. However, climate risk considerations are
consultation with the taxation team, to assess and embedded within infrastructure planning, energy
analyse tax implications prior to execution. management strategies, and capital allocation
decisions to enhance long-term resilience. The
assessment of climate-related risks and opportunities
continues to be strengthened in line with evolving global
sustainability disclosure practices.
116 PT XLSMART Telecom Sejahtera Tbk
Page 119
Connecting Indonesia:
One Purpose - One Planet
To mitigate potential impacts, XLSMART remains As the regulatory landscape evolves, XLSMART
committed to reducing greenhouse gas emissions continues to enhance transparency and integrate
across its operations and increasing the use of climate-related considerations into strategic planning
renewable energy. The expansion of solar panel and financial decision-making processes. The
installations and procurement of Renewable Energy Company recognises the growing importance of
Certificates form part of the Company’s operational structured climate-related financial disclosures within
energy transition strategy. These initiatives reduce global capital markets. Thus, XLSMART is progressively
exposure to conventional electricity sources while strengthening governance oversight, refining risk
supporting national decarbonisation objectives. identification methodologies, and enhancing data
integration capabilities to prepare for future alignment
Beyond risk mitigation, the Company also recognises with internationally recognised sustainability reporting
climate-related opportunities. Increasing public frameworks, including IFRS Sustainability Disclosure
awareness of energy efficiency and sustainable Standards.
consumption drives demand for digital solutions
that enable remote working, digital transactions,
smart infrastructure, and reduced physical mobility.
Strengthened digital connectivity supports lower-
carbon economic activity by facilitating virtual services
and dematerialised transactions.
2025 Sustainability Report 117
Page 120
Stronger Performance
From People Empowerment
118 PT XLSMART Telecom Sejahtera Tbk
Page 121
Connecting Indonesia:
One Purpose - One Planet
Stronger Performance
from People Empowerment
2025 Sustainability Report 119
Page 122
Stronger Performance
From People Empowerment
EcoFusion Sustainability Week
The 2025 merger created a unified talent ecosystem The Human Capital Committee oversees key aspects of
that brings together diverse skills, perspectives, workforce governance and organizational development.
and professional experiences across the combined Established on 12 July 2019, the committee carries out
organization. This integration enables XLSMART to responsibilities aligned with national labor regulations,
strengthen operational capacity, expand service including those amended under the Job Creation Law.
excellence, and accelerate digital transformation. Our It provides direction on workforce planning, capability
people play a central role in ensuring that the Company strengthening, and employee relations while guiding the
remains agile, innovative, and ready to meet the ongoing harmonization of post-merger Human Capital
evolving needs of customers across Indonesia. policies.
As the Company harmonizes systems and aligns post- To support the Company’s transformation agenda, the
merger structures, workforce management becomes a committee has introduced a digitalized Human Capital
strategic enabler of long-term performance. XLSMART management system that streamlines employee
focuses on building a resilient and future-ready processes and services. Integrated through the Human
talent base through standardized job architecture, Capital Super App (XLSMART App), the system enables
strengthened capability development, and continuous access to administrative services, learning modules,
learning initiatives that equip employees to navigate and performance information through a single
the increasingly dynamic digital landscape. These platform, strengthening data-driven decision-making
pathways ensure that every individual is positioned and improving overall employee experience.
to contribute meaningfully to the Company’s goals,
whether through frontline service, network operations, In 2025, XLSMART was recognized as Indonesia Best
or enterprise solutions. Collectively, these efforts foster CX-EX Strategy 2025 by SWA Magazine (14th edition)
a strong and integrated workforce that supports the with a “Very Good” rating. This award marked as the
Company’s operational excellence and sustained Company’s recognition in its human capital initiatives
growth trajectory. and the Company’s commitment in the employee’s
development. With customer experience (CX) and
Following the 2025 integration, the Company aligned employee experience (EX) strategy implementation to
policies, decision-making structures, and workforce enhance customer loyalty and employee productivity.
practices to ensure that employees operate under The award itself validates the Company’s strategy
a consistent and equitable framework. This reflects of balancing customer satisfaction and employee
the Company’s commitment to equality and equal engagement. This is in line with the Company’s
opportunity, ensuring that every individual has fair integration strategy, to focus on empowering and
access to recruitment, development pathways, collaborative employees to deliver an exceptional
and career progression in line with applicable labor customer experience.
regulations. [F.18]
120 PT XLSMART Telecom Sejahtera Tbk
Page 123
Connecting Indonesia:
One Purpose - One Planet
Our Workforce
XLSMART’s workforce now represents the combined 1. Recruitment process with merit based selection,
talent pool of the three operators that merged in 2025. inclusivity and equal opportunity helped by digital
This integration creates a broader mix of competencies, recruitment tools and platforms utilized to improve
digital capabilities, and operational experience that efficiency, broaden talent reach, and enhance
supports the Company’s transformation across mobile, candidate experience.
home broadband, and enterprise services. 2. Bringing in specialized skills particularly in digital
technology, data analytics, network optimization,
Workforce planning during the first year of integration cybersecurity, and enterprise solutions.
focuses on ensuring that talent availability aligns with 3. Bringing in a deep pool of talents that enables the
network consolidation, digitalization priorities, and internal employees to explore cross-functional roles
strengthened customer experience initiatives. The through a comprehensive and transparent selection
merged workforce enables greater operational scale process.
and provides flexibility for future business needs. 4. Prioritizing the harmonization of recruitment and
talent management systems to align process,
Recruitment Approach and New Hires [GRI 401-1] standards and experiences while also supporting
In 2025, the recruitment process aligned with the sustainable career development for all employees.
Company’s post-merger strategic priorities. XLSMART 5. Ensuring the people roles to achieve high
focused on filling roles that were newly created or performance, adaptive, and aligned with the
refined as part of the new organizational structure. The Company’s business needs.
recruitment approach is outlined as follows:
Throughout the year, 137 new employees joined
XLSMART. A comparison of new hires over the last two
years is presented below:
Employee Recruitment by Age and Region [S-02]
2025 2024 2023
Description
Male Female Male Female Male Female
Employees by Age
<25 years old 1 3 5 3 2 5
25-30 years old 20 12 17 11 34 23
30-35 years old 38 19 41 10 39 17
35-40 years old 18 6 28 9 20 4
40-45 years old 9 1 19 2 9 5
45-50 years old 6 1 2 2 7 -
>50 years old 3 0 2 1 1 -
Total 95 42 114 38 112 54
Based on Regions
Head Office 46 31 74 33 73 46
Region-West 10 1 18 1 4 -
Region-Jabo 10 1 0 0 7 3
Region-Central 9 4 13 2 10 1
Region-East 12 3 5 1 8 -
Kalimantan Area 3 1 2 0 6 3
Sulawesi Area 5 1 2 1 4 1
Region-North - - - - - -
Total 95 42 114 38 112 54
2025 Sustainability Report 121
Page 124
Stronger Performance
From People Empowerment
Employee Turnover [F.21] [GRI 401-1] [S-03]
The first year of integration also brought natural employee movement as structures, roles, and responsibilities
were refined. Redeployment, role adjustments, and voluntary departures formed part of the transition phase as the
organization consolidated functions and aligned operating models.
In 2025, a total of 233 employees left the Company. The turnover rate reached 7.2%, reflecting early-stage
adjustments that typically occur after a large-scale merger. As role clarity improved and teams operated under
more consistent processes, workforce stability also strengthened. The comparison of turnover between 2025 and
2024 is presented below:
2025 2024 2023
Employee Turnover
Male Female Total Male Female Total Male Female Total
Incoming employees 95 42 137 114 38 152 112 54 166
(recruitment)
Outgoing Employees
2025 2024 2023
Outgoing Employees
Male Female Total Male Female Total Male Female Total
Natural retirement 4 0 4 2 4 6 49 14 63
Passed Away 0 0 0 3 0 3 2 0 2
Resigned** 115 76 191 47 17 64 45 29 74
Dismissed For 11 4 15 6 3 9 6 0 6
Misconduct
Expired Contract 17 6 23 9 4 13 17 6 23
Total 147 86 233 67 28 95 17 6 23
Head Office 114 77 191 67 28 95 119 49 168
Percentage 48.9% 33.0% 82.0% 6.0% 5.8% 6.0% 11.4% 10.9% 11.2%
**Reasons for Resignation
2025 2024 2023
Outgoing Employees
Male Female Total Male Female Total Male Female Total
At Own Request 119 76 195 42 17 59 45 29 74
Not at Own Request 28 10 38 22 11 33 74 20 94
Total Employee Turnover Rate [S-03]
Descriptions Total in 2025 % in 2025
Total resigned/terminated employees 233 7.2
Total new/replacement employees 137 4.2
Total Permanent Employees [S-04]
Descriptions Total in 2025 % in 2025
Total employees managed by Contractors and/or Consultants 717 22.14
Employee Demographics [C.3] [GRI 2-7] [GRI 405-1]
Employee diversity remains an important foundation for building an inclusive and collaborative organization. As
XLSMART brings together employees from different backgrounds and legacy entities, the Company ensures equal
opportunities and a consistent employee experience across all groups. [GRI 3-3]
122 PT XLSMART Telecom Sejahtera Tbk
Page 125
Connecting Indonesia:
One Purpose - One Planet
The workforce composition in 2025 highlights the expansion of key directorates, particularly Commercial-Consumer,
Technology, Finance, and Enterprise & Strategic Relationship, alongside the establishment of new functions such as
Regulatory and the Integration Office. This distribution demonstrates the Company’s post-integration organizational
scaling and its deliberate effort to align workforce capacity with evolving business priorities.
Employee Demographics by Directorate
Description 2025 2024
CEO’S Office 144 98
People 99 98
Finance 308 173
Strategy & Home Business 210 164
Commercial-Consumer 1,242 540
Technology 415 207
Information Technology 354 308
Enterprise & Strategic Relationship 285 173
Regulatory 61
Integration Office 121
Grand Total 3,239 1,663
The diversity profile is further detailed in the following tables:
Employee Composition by Age and Gender
Proportions 2025 2024 2023
Board of Commissioners and Board of Directors
By Age
<25 years old - - -
25-30 years old - - -
30-35 years old - - -
35-40 years old - - -
40-45 years old 3 - -
45-50 years old 3 2 4
>50 years old 17 12 9
By Gender
Male 22 11 10
Female 1 3 3
Proportions 2025 2024 2023
Employees
By Age
<25 years old 69 20 8
25-30 years old 297 138 156
30-35 years old 568 359 353
35-40 years old 682 363 343
40-45 years old 724 377 351
45-50 years old 594 282 231
>50 years old 305 124 109
By Gender
Male 2,307 1,168 1,047
Female 932 495 448
2025 Sustainability Report 123
Page 126
Stronger Performance
From People Empowerment
Employee Composition by Operational Area and Gender
2025 2024 2023
Operational Area
Male Female Total Male Female Total Male Female Total
Head Office 1,529 714 2,243 871 446 1,317 812 408 1,220
Region-West 166 43 209 63 9 72 45 8 53
Region-Jabo 124 34 158 49 15 64 36 11 47
Region-Central 218 71 289 73 13 86 53 9 62
Region-East 182 48 230 72 8 80 62 6 68
Kalimantan Area 37 5 42 33 3 25 21 4 25
Sulawesi Area 51 17 68 18 1 19 18 2 20
Region-North - - - - - - - - -
Total 2,307 932 3,239 1,168 495 1,663 1,047 448 1,495
Employee Composition by Operational Area and Employment Status
2025 2024 2023
Operational Area
Permanent Contract Total Permanent Contract Total Permanent Contract Total
Head Office 1,918 325 2,243 1,197 120 1,317 1,113 107 1,220
Region-West 131 78 209 39 33 72 33 20 53
Region-Jabo 100 58 158 38 26 64 18 29 47
Region-Central 169 120 289 41 45 86 28 34 62
Region-East 142 88 230 48 32 80 36 32 68
Kalimantan Area 20 22 42 6 19 25 5 20 25
Sulawesi Area 42 26 68 8 11 19 9 11 20
Region-North - - - - - - - - -
Total 2,522 717 3,239 1,377 286 1,663 1,242 253 1,495
Employee Composition by Employment Status and Gender
2025 2024 2023
Description
Male Female Total Male Female Total Male Female Total
Permanent 1,778 744 2,522 931 446 1,377 843 399 1,242
Contract 529 188 717 237 49 286 204 49 253
Temporary 2,199 3,108 5,307 319 600 919 - - -
Honorary - - - - - - - - -
Total 4,506 4,040 8,546 1,186 495 1,663 1,047 448 1,495
Gender Equality [S-01]
Male Female
Job Level
Total Employees (%) Total Employees (%)
Entry Level (Staff /Individual Contributor) 1,973 85.52% 828 88.88%
Mid-Level (Head + Group Head) 312 13.53% 103 11.05%
Senior Level (Chief + Director) 21 0.91% 1 0.11%
Executive Level (President Director) 1 0.04% 0 0.00%
Total Employees 2,307 100% 932 100%
124 PT XLSMART Telecom Sejahtera Tbk
Page 127
Connecting Indonesia:
One Purpose - One Planet
Number of Employees by Job Level, Age Group, and Gender [S-02]
Entry Level Mid-Level Senior Level Executive Level Total
Age Group (Years)
Male Female Male Female Male Female Male Female Employees
18-24 0 0 17 19 3 5 0 0 44
25-34 0 0 318 221 191 107 0 0 837
35-44 0 0 475 156 565 188 3 0 1,387
45-55 0 0 194 87 502 140 12 1 936
Above 55 0 0 0 1 20 7 7 0 35
Total 0 0 1,004 484 1,281 447 22 1 3,239
Number of Temporary Employees [S-04]
Descriptions Total in 2025 % in 2025
Total employees managed by Contractors and/or Consultants 5,307 62.1
Employee Composition by Job Title and Gender
2025 2024 2023
Job Level
Male Female Total Male Female Total Male Female Total
President Director 1 - 1 - 1 1 - 1 1
Director 8 1 9 5 1 6
Chief 13 - 13 8 - 8 4 1 5
Group Head 59 18 77 33 16 49 7 0 7
Head 253 85 338 132 47 179 34 15 49
Lead - - - 14 7 21 126 47 173
Staff/Individual 1,973 828 2,801 976 423 1,399 876 384 1,260
Contributor
Total 2,307 932 3,239 1,168 495 1,663 1,047 448 1,495
Composition of Employees by Age and Gender
2025 2024 2023
Age Group
Male Female Total Male Female Total Male Female Total
<25 years old 36 33 69 7 13 20 3 6 9
25-30 years old 159 138 297 81 57 138 87 59 146
30-35 years old 372 196 568 244 115 359 232 112 344
35-40 years old 494 188 682 262 101 363 235 94 329
40-45 years old 568 156 724 279 98 377 256 87 343
45-50 years old 454 140 594 207 75 282 172 58 230
>50 years old 224 81 305 88 36 124 62 32 94
Total 2,307 932 3,239 1,168 495 1,663 1,047 448 1,495
Composition of Employees by Education and Gender
2025 2024 2023
Education Level
Male Female Total Male Female Total Male Female Total
S2/S3 201 72 273 143 57 200 59 29 88
S1 1,878 772 2,650 959 409 1,368 855 367 1,222
Diploma 216 76 292 66 29 95 133 52 185
High School Equivalent 12 12 24 0 0 0 0 0 0
Total 2,307 932 3,239 1,168 495 1,663 1,047 448 1,495
2025 Sustainability Report 125
Page 128
Stronger Performance
From People Empowerment
Interns [2-8]
2025 2024 2023
Information
Male Female Male Female Male Female
Intern Count 63 79 60 52 167 179
Based on Internship Location
Head Office 58 69 52 42 159 160
Region-West 1 2 7 4 3 2
Region-Jabo - 2 - 3 2 1
Region-Central 1 - - - - 4
Region-East 3 5 - - 3 12
Kalimantan Area - 1 1 3 - -
Sulawesi Area - - - - - -
Region-North - - - - - -
Employment Practices
Non-Discrimination and 40 working hours per week under a five-day work
XLSMART upholds a non-discrimination principle arrangement. Employees who work additional hours
across all stages of employment. This commitment receive overtime compensation in accordance with
applies to recruitment, job placement, development internal provisions and applicable regulations.
opportunities, performance assessment, promotion,
remuneration, and termination. All employment This policy extends to subsidiaries, business partners,
decisions are based on competence, performance, and vendors, all of whom are required to comply with
and organizational requirements, without reference to indonesian labour laws and internationally recognized
gender, age, ethnicity, religion, physical condition, or human rights principles. XLSMART’s commitment
political views. During the 2025 reporting period, the aligns with:
Company recorded no incidents of discrimination. [F.18] • Law no. 20 Of 1999-ratification of ILO convention
[GRI 3-3][GRI 406-1] no. 138 Concerning minimum age for admission to
employment.
Child Labour and Forced Labour [F.19] [GRI 408-1] • Law no. 1 Of 2000-ratification of ILO convention no.
[GRI 409-1] 182 Concerning the elimination of the worst forms of
XLSMART acknowledges that risks related to human child labour.
rights violations, including child labour and forced • Law no. 19 Of 1999-ratification of ILO convention no.
labour, may arise in any work environment if not 105 Concerning the abolition of forced labour.
managed effectively. To mitigate these risks, the
company maintains a comprehensive human capital These references guide the company in ensuring that
management framework governing fair treatment, work arrangements, job assignments, and contractual
safe working conditions, and compliance with labour terms do not create conditions that may constitute
regulations across all operational areas. [GRI 3-3] forced labour.
The company strictly prohibits child labour and forced Throughout the 2025 reporting period, the company
labour in all forms. Recruitment policies require all recorded no incidents of child labour or forced labour,
candidates to meet the minimum legal working age and human-rights violations related to these issues
and to submit verifiable educational documents to were identified across its operations. This reflects the
confirm eligibility. Working-hour arrangements follow effective implementation of company policies and its
article 77 of law no. 13 Of 2003 concerning manpower, ongoing commitment to protecting employee rights.
which stipulates a maximum of 8 working hours per day
126 PT XLSMART Telecom Sejahtera Tbk
Page 129
Connecting Indonesia:
One Purpose - One Planet
Collective Bargaining Agreements [GRI 2-30] Following the 2025 merger, the company initiated the
XLSMART maintains a constructive relationship with process of harmonizing employment provisions from
employee representatives and ensures that labour the legacy entities into a single unified cla framework.
rights remain protected throughout the post-merger During this transition, the existing cla remains fully
transition. All employees are covered by a collective in effect and continues to apply to 100 percent of
labour agreement (CLA) developed jointly with the employees. Any policy updates or workforce changes
labour union, which serves as a binding reference for are discussed with the labour union in accordance
managing employment matters, including working with labour regulations and established consultation
conditions, grievance mechanisms, remuneration, mechanisms.
benefits, and dispute resolution.
This approach ensures that employees retain clear
protection of their rights and that all employment-
related decisions remain aligned with mutually agreed
principles between the company and the labour union.
Description 2025
Total employees covered by CLA 100% employees
Legacy source of CLA XL Axiata CLA (effective and applicable during transition period)
Coverage for Smartfren employees Covered under unified employment policies during the harmonization period
post-merger
Key areas governed by CLA Working conditions, benefits, grievance procedures, dispute resolution, and
termination provisions
Consultation mechanism Regular meetings between Company and the Labour Union; reviews aligned with
national labour regulations
Harmonization progress In progress; unified CLA framework planned for phased implementation
Base Transceiver Station - BTS, Jawa Timur
2025 Sustainability Report 127
Page 130
Stronger Performance
From People Empowerment
Employee Wellbeing within an Equal and
Inclusive Entity
Remuneration and Employee Welfare [GRI 202-1] [GRI 405-2] [GRI 401-2]
XLSMART ensures that all employees receive fair and competitive remuneration that reflects their role, performance,
and contribution to the organization. The Company’s remuneration framework complies with the Manpower Law,
the Job Creation Law, and Government Regulation No. 36 of 2021 on Wage Policy. Harmonization of remuneration
structures across the merged entities is carried out gradually to ensure consistency, internal equity, and alignment
with industry benchmarks. In determining wages, XLSMART considers living cost, inflation trends, business locations,
and the Company’s financial capacity. The wage structure does not differentiate based on gender. This approach
reflects the Company’s commitment to equal remuneration in accordance with ILO Convention No. 100 on Equal Pay
for Work of Equal Value. [GRI 3-3]
Regional Minimum Wage [F.20]
The Company maintains full compliance with applicable minimum wage regulations across all operational areas. In
2025, the Company’s wage structure reached an average of 101 percent of the regional minimum wage standard.
The Lowest Salary at
Region Minimum Wage Ratio Comparison to UMP
XLSMART
Region-West Rp4,014,072 Rp5,700,000 1.42
Region-Jabo Rp5,396,760 Rp5,700,000 1.06
Region-Central Rp3,454,827 Rp5,700,000 1.65
Region-East Rp4,961,753 Rp5,700,000 1.15
Kalimantan Area Rp3,599,181 Rp5,700,000 1.58
Sulawesi Area Rp3,880,137 Rp5,700,000 1.47
In addition to base salary, employees receive a comprehensive range of benefits tailored to their employment status
and job level. The benefits include allowances, leave entitlements, insurance coverage, and other welfare programs
designed to support employee wellbeing, as follows: [GRI 401-2]
2025
Remuneration/Facility Type
Permanent Employees Non-Permanent Employees
Basic Salary √ √
Long-term incentives in the form of cash or stocks √ √
Allowances
Holiday Allowance √ √
Income Tax Allowance √ √
Leave allowance √ √
Transportation allowance √ √
Communication allowance √ √
Education allowance √ √
Leave
Annual Leave √ √
Maternity Leave √ √
Menstrual Leave √ √
Leave for the Purpose of Worship √ √
Progressive Leave √ √
Others
Healthcare √ √
Life insurance √ √
128 PT XLSMART Telecom Sejahtera Tbk
Page 131
Connecting Indonesia:
One Purpose - One Planet
To boost employee productivity, XLSMART also formulates a range of rewards delivered in the form of:
• My Flexpro, a flexible non-cash employee development program (covering Medical Plan Benefits, the Let’s Learn
Program, and Annual Leave) that supports health benefits, education, wellness, additional leave purchases, and
pension programs;
• Tuition Fee support;
• Opportunities to participate in Individual Development programs;
• Employee travel programs as recognition for performance and target achievement; and
• Token Appreciation, a non-cash reward granted to employees who have demonstrated strong engagement and
significant contributions to the company’s strategic initiatives.
With a spirit to become “Best Place to Work” the Company implemented work environment that supported by health
screening programs, mental health support and collaborative platforms and activities that engaged in the XLSMART
Employee Club. The Company also support Uncommon Day Program where the leaders are encouraged to engage
with their teams during working hours through positive activities that strengthen togetherness and engagement,
such as environmental care initiatives, group movie sessions, collective CSR activities, and other team-building
initiatives. We also conduct Pulse Check Surveys to monitor employee conditions and perceptions, enabling timely
corrective actions when necessary. In addition, we provide various supporting facilities such as EV charging stations,
inter-office shuttle bus services, and a prayer facility.
Maternity Leave [401-3]
The Company grants maternity leave in accordance with national labour regulations and ensures that employees
who take maternity leave have the right to return to their roles without penalty. The following table presents maternity
leave data for 2025 compared to the previous two years:
2025 2024 2023
Description
Male Female Male Female Male Female
Number of employees eligible for maternity leave 1,989 536 1,019 324 917 296
Number of employees taking maternity leave 40 23 10 15 59 25
Number of employees returning to work 37 19 10 15 53 24
Total number of employees returning to work after maternity 37 19 10 15 53 24
leave ends, who are still employed 12 months after returning
to work
The rate of employees taking maternity leave who return to 92.50% 82.61% 100,00% 100,00% 89,83% 96,00%
work and can be maintained
In 2025, 63 employees took maternity leave and 56 returned to work, representing a return to work rate of 88.89 %.
After twelve months, 56 of them continued their careers with XLSMART, demonstrating a retention rate of 100.00%
and reflecting a workplace environment that enables employees to return and continue their careers confidently.
Employee Training and Development [F.22] [GRI 404-1, 404-2] [ACGS C.6.2]
Capability development plays a central role in preparing employees for the Company’s digital transformation
and expanded operational scale. Training programs are designed to strengthen technical, leadership, and digital
competencies, ensuring that employees can adapt to evolving business needs. [GRI 3-3]
In 2025, XLSMART’s learning framework focuses on key strategic capabilities as follows:
1. Digital and system operational excellence;
2. Collaborative and adaptive leadership;
3. Governance and anti-bribery compliance;
4. Customer-centric transformation;
5. 5G and connectivity-driven business enablement;
6. AI and data literacy;
7. Digital trend foresight;
8. Continuous learning culture through digital platforms.
2025 Sustainability Report 129
Page 132
Stronger Performance
From People Empowerment
Based on the aforementioned key capabilities, the Company has carried out the following training and development
programs:
Training Title Date Participants
Socialization: ABAC & GDS Operational and VITAL System Hands-on (Batch 7) 5 May 2025 320
Socialization ABAC & GDS Operational and VITAL System Hands-on (Batch 8) 5 May 2025 293
Working as One: Leading Teams & Collaboration for Success 17 June 2025 248
Awareness & Socialization ISO 370001:2016 Anti Bribery Management System 18 June 2025 180
From Customer Perspective to Leadership Action in Times of Change 15 September 2025 259
5G to Business: Transforming Industries and Revolutionizing Connectivity 22 September 2025 515
AI for Everyone Seminar: Exploring of AI 24 September 2025 576
Podcast: Future Digital Trend 30 September 2025 616
Online Learning though XLEARN & LinkedIn Learning 1 January - 21 December 991
2025
[S-05]
Average Training Hours per Employee Total Employees Participating in Percentage of Employees Participating
in 2025 Training and Development in Training and Development
45.2 3,222 99%
XLSMART also encourages employees to elevate their easy access to information on HR-related policies and
skills. With a program called “Gear Up”, the Company practices. In addition, employee data management
allocates adequate resources to covering the leadership based on analytics has been implemented, enabling
development, technical skills training, soft skills training faster and more accurate decision making. Meanwhile,
and internalization of work culture. The Company also the Company also provides a digital application
encourages employees to become self-driven learners called XLSMART Super App to facilitate employees
by providing eLearning platforms to strengthen a and continue to expand the implementation of digital
learning environment for all levels of organization. The solutions to build an end-to-end digital HR ecosystem in
Gear Up program itself delivered through a combination support of the Company’s organizational performance
of in class training, live online sessions, and self-paced and long-term growth.
learning. In 2025, the program has reached more than
20,000 training participants, with 40 programs across To ensure that training and development programs
192 training batched and achieving satisfaction score remain effective and aligned with business priorities,
of 4.6 out of 5. Another initiative that successfully XLSMART allocates a dedicated budget for employee
encourages the employees were the sharing program development each year. The allocation is determined
from one chief to other division that help the employees based on capability needs, strategic focus areas, and
to recognise the Company process as a whole entity. the Company’s financial capacity.
In terms of digital transformation, employees were In 2025, total training and development expenses
equipped with relevant competencies in areas such as reached Rp16,195,525,115, compared to
data analytics, artificial intelligence, digital platforms, Rp7,449,117,233 in 2024. These investments reflect the
network technology, and agile ways of working, ensuring Company’s continued commitment to strengthening
alignment with the Company’s evolving business and employee competencies, supporting digital
operational needs. Various work processes helped transformation, and preparing the workforce for post-
with the utilization of AI through a chatbot, to give an merger operational needs.
130 PT XLSMART Telecom Sejahtera Tbk
Page 133
Connecting Indonesia:
One Purpose - One Planet
Training Fee
2025
Rp 16,195,525,115
2024 Rp7,449,117,233 2023 Rp8,314,806,611
Employee Performance Assessment [404-3] Performance assessments are conducted twice a
XLSMART evaluates employee performance to year, covering mid-year and year-end reviews. This
measure individual contributions to business objectives approach allows the Company to monitor progress,
and ensure alignment with the Company’s strategic identify development needs, and address performance
priorities. The assessment process is conducted gaps before they affect year-end results.
objectively and transparently, based on Key
Performance Indicators (KPIs) that are agreed upon at n 2025, all of the Company’s employees participated
the beginning of each year. in various training programs throughout the reporting
period, as part of the Company’s commitment to
The Company’s KPI framework is cascaded from enhancing their competencies and supporting the
the CEO to each Directorate and then translated achievement of the Company’s objectives. The detailed
into individual KPIs. This cascading process ensures results of the 2025 performance assessments are
consistency across levels and strengthens the link presented in the following table:
between employee goals and organizational targets.
Number of Employees Assessed
Employee Level
Male Female Total
2025
Chief 11 0 11
Group Head 59 18 77
Head 255 85 340
Staff/Individual Contributor 1,978 831 2,809
Total 2,303 934 3,237
In 2025, the performance assessment process also entered a transition phase as XLSMART harmonized KPI
structures, scoring mechanisms, and evaluation cycles across the merged organization. This integration ensures that
employees from different legacy entities are assessed under a consistent, transparent, and equitable framework.
2025 Sustainability Report 131
Page 134
Stronger Performance
From People Empowerment
Occupational Health and Safety
[F.21] [GRI 403-1]
XLSMART remains committed to maintaining a safe, 5. Presidential Decree No. 22 of 1993 concerning
healthy, and sustainable working environment for all Diseases Arising from Employment Relations.
employees across its integrated operations. As the 6. Occupational Health, Safety and Environment
Company enters its first year as a merged organization, Policy (HSE) of XL Axiata.
the harmonization of Occupational Health and Safety 7. HSEMS Policy Manual of XL Axiata.
(OHS) practices forms a critical foundation for ensuring
operational continuity, employee wellbeing, and a HSE Management Structure [GRI 403-8]
culture of shared responsibility throughout the new XLSMART continues to adopt the HSE policy that was
organizational structure. signed by XL Axiata’s CEO, Dian Siswarini, on 11 February
2022. The policy reflects the Company’s commitment to
The Company implements a comprehensive Health, ensuring an efficient, healthy, secure, and eco-friendly
Safety, and Environment Management System (HSEMS) workplace for employees, partners, and customers.
that adheres to Government Regulation No. 50 of 2012 Although the organization has transitioned into an
on Occupational Safety and Health Management integrated entity following the 2025 merger, the principles
System, ISO 45001:2018 on Occupational Health and outlined in this policy remain relevant and continue to
Safety Management System, and ISO 14001:2015 on guide the XLSMART’s HSE practices. The Company also
Environmental Management System. These standards implements ongoing enhancements to ensure alignment
guide XLSMART in strengthening OHS governance and with evolving business needs, regulatory developments,
ensuring that all employees, regardless of their legacy and industry standards.
entity, operate under consistent and reliable safety
protocols. [GRI 3-3] The Company’s commitment to implementing HSE
across all operations is supported collectively by
The implementation of HSEMS aims to: employees from both legacy organizations. To ensure
1. Improve the effictiveness of planned, measurable, effective and consistent implementation, XLSMART
and integrated occupational health and safety has designated the Facility Compliance and HSE
programs. Assurance Unit, under the Facility Operations and HSE
2. Engage management, workers, and/or trade unions/ Department, to lead, coordinate, and supervise the
trade in preventing and reducing occupational execution of the HSE Management System. This unit
accidents and illnesses. plays a central role in ensuring regulatory compliance,
3. Establish a safe, comfortable, environmentally monitoring operational risks, and maintaining robust
responsible, and productive workplace that internal controls across the integrated business.
supports improved performance.
The Facility Compliance and HSE Assurance Unit is
Legal References responsible for:
To ensure accuracy and regulatory alignment, • Serving as Enterprise Business Partner
XLSMART refers to the following laws and regulations • Conducting Hazard Identification and Risk Control
when implementing its Occupational Health and Safety (IBPR)
Management System: • Identifying Environmental Aspects and Impacts
1. Law No. 1 of 1970 on Occupational Safety. (IADL)
2. Law No. 13 of 2003 concerning Manpower. • Conducting compliance assessments for HSE-
3. Law No. 11 of 2020 on Job Creation has been related laws and regulations
updated with Law No. 6 of 2023 on the Ratification • Setting goals, objectives and programs for
of Government Regulation in Lieu of Law No. 2 of Occupational Health, Safety, and Environment
2022 on Job Creation into Law. (HSE)
4. Government Regulation of the Republic of • Preparing and maintaining HSE documentation
Indonesia No. 50 of 2012 on the Implementation (policies, procedures, work instructions, standards,
of Occupational Health and Safety Management and forms)
System (HSEMS). • Implementing the Contractor Safety Management
System (CSMS)
132 PT XLSMART Telecom Sejahtera Tbk
Page 135
Connecting Indonesia:
One Purpose - One Planet
• Organizing monthly HSE Meetings Occupational Health and Safety Advisory
• Conducting HSE competency training Committee (P2K3) [GRI 403-4] [GRI 403-8]
• Monitoring and Measuring HSE Performance To strengthen the implementation of Occupational
• Conducting HSE Inspections Health and Safety across the Company, XLSMART
• Conducting HSE Audits; internal audits (at least has established the Occupational Health and Safety
once a year), second-party audits (vendors and Advisory Committee (P2K3). The Committee functions
partners, at least once a year), and external audits as a joint forum for management and employees
(third-party, at least once every three years) to oversee HSE aspects, maintain consistent
• Holding HSE Management Review Meetings at least communication, and ensure active participation in the
once a year Company’s HSE programs. In 2025, P2K3 officially held
• Implementing corrective and improvement actions. a Kick-Off Meeting marking the commencement of
its new management term for the 2025–2028 period,
The organizational structure of the Facility Operation reinforcing the Company’s collective commitment to
& HSE-Facility Compliance and HSE Assurance fostering a stronger and more sustainable XLSMART
Department is illustrated in the following chart: HSE Culture. Chaired by the Director & Chief Regulatory
Officer, P2K3 serves as a key communication forum
between management and employees.
President Director & CEO The establishment of P2K3 is formally regulated under
the Decree of the DKI Jakarta Provincial Manpower,
Transmigration and Energy Office No. 2866 of 2022
Chief Human Capital Officer dated 20 December 2022, and reinforced through the
Directors’ Decree dated 15 November 2023 regarding
the Formation of the P2K3 Team. P2K3 represents
employees across the organization and ensures that
Group Head - People Service & Facility Management
HSE governance aligns with applicable regulations and
companywide standards.
Head Facility Operation and HSE To support its duties, the Company has appointed the
following leaders and members to the P2K3 structure:
• Chairman of P2K3: Merza Fachys (Director & Chief
Department is illustrated
Compliance in the
and HSE following chart:
Assurance Regulatory Officer)
• Vice Chairman 1 P2K3: Marco Sumampouw (Chief
IR, GA, BFM Officer)
In addition to its HSE policy, XLSMART enforces internal • Secretary of P2K3: Mery Pangloli (Facility Planning
regulations that specifically address sexual harassment & Development)
and other prohibited conduct. As outlined in Article
51, the regulation defines actions that may result in Members:
termination of employment, including: • Group Head
• Engaging in immoral acts or unlawful activities such • Head
as gambling within Company premises. • Employees
• Attacking, molesting, threatening, or intimidating • XLSMART Workers’ Union
co-workers or other individuals within the
Company’s work environment (point g).
2025 Sustainability Report 133
Page 136
Stronger Performance
From People Empowerment
P2K3 ORGANIZATIONAL STRUCTURE
Chairman of
P2K3 (Director &
Chief Technology
Officer)
Vice Chairman 1 Deputy Head 2
P2K3 P2K3
(Chief Human (Chief Enterprise
Capital Officer) Business Officer)
Secretary of
P2K3 (General
Occupational Safety
and Health Expert
Certification)
Region-
Head Office Region-Jabo Region-West East Region Kalimantan Sulawesi
Central
(Member) (Member) (Member) (Members) (Members) (Members)
(Member)
1. Group Head 1. Group Head 1. Group Head 1. Group Head 1. Group Head 1. Group Head 1. Group Head
2. Head 2. Head 2. Head 2. Head Representative Representative Representative
3. Employees 3. Employees 3. Employees 3. Employees 2. Head 2. Head 2. Head
4. XL Workers’ 4. XL Workers’ 4. XL Workers’ 4. XL Workers’ Representative Representative Representative
Union Union Union Union 3. Employee 3. Employee 3. Employee
Representatives Representatives Representatives
P2K3 is tasked with the following duties: 3. Compliance with applicable laws and regulations as
1. Building an HSE-conscious culture; well as other requirements related to Occupational
2. Providing safety performance reports every quarter Health, Safety, and Environment (HSE).
to the Manpower Office; 4. Improvement of the effectiveness of the
3. Socializing HSE to employees through the Chairman HSE management system by strengthening
of P2K3 (Director & Chief Technology Officer) and communication network systems, developing
members representing Region-Jabo, Head Office, strong relationships with interested parties, and
Region-West, and Region-Central; implementing digital system applications.
4. Implementing various HSE-related trainings; 5. Development of human resources with high
5. Ensuring HSE programs are effectively implemented awareness while encouraging consultation
and their performance; processes and active participation of all workers
6. Develop risk-control measures against HSE hazards related to occupational health, safety, and
in the work environment; environmental practices.
7. Organizing management reviews held once a year. 6. Implementation of the HSE management system and
the execution of continual improvement to achieve
P2K3’s Duty Implementation in 2025 the occupational health, safety, and environmental
As part of its duties and responsibilities, P2K3 carried targets that have been established.
out a number of activities in 2025, including:
1. Provision of a safe, healthy, and environmentally
friendly workplace to prevent work accidents,
occupational diseases, and environmental issues.
2. Risk assessment as the basis for decision-making,
planning, and implementation of the Occupational
Health and Safety (OHS) management system.
134 PT XLSMART Telecom Sejahtera Tbk
Page 137
Connecting Indonesia:
One Purpose - One Planet
HSE Targets 11. Management Walk Through programs.
XLSMART aligns its HSE targets with the Company’s 12. HSE audit programs.
sustainability strategy to strengthen awareness among 13. Follow-up actions on inspection and audit findings.
internal and external stakeholders of the importance 14. Infrastructure improvement programs related to
of achieving zero work-accident fatalities as part of its workplace safety and operational facilities.
operational performance and long-term organizational 15. Procurement of safety tools, personal protective
resilience. equipment (PPE), and work uniforms.
16. Workplace environmental measurement and
HSE Work Programs in 2025 monitoring.
Further details of the 2025 HSE work programs are 17. HSE coordination meetings.
presented below: 18. Updating HSE documentation, including policies
1. HSE communication program implementation. and standard operating procedures (SOP).
2. Contractor HSE Plan implementation for 2025.
3. HSE Management Review implementation. Hazard Identification, Risk Assessment, and
4. Basic Safety e-Learning program for employees. Incident Investigation [GRI 403-2]
5. HSE Award program implementation. XLSMART implements a comprehensive HSE
6. HSE operational and competency training management system that includes hazard identification,
programs. risk assessment, and incident investigation for both
7. Development of HSE e-learning modules and employees and contractors. This process covers field
learning materials. technicians, tower climbers, and fiber optic maintenance
8. Emergency preparedness programs. personnel who face high-risk working conditions. All
9. Regulatory compliance testing and monitoring. incidents are investigated to identify root causes and
10. HSE inspection programs across operational preventive measures. [GRI 403-2].
facilities.
Identified Risk Potential Impact Affected Workers Control Measures/Mitigation
Working at height (tower Falls from height, serious Tower climbers, field Mandatory harness and fall protection,
climbing) injury, fatality engineers, work-at-height certification, double
contractors lanyard use, daily equipment inspection,
supervision approval before ascent
Electrical hazards in fiber Electric shock, burns, Fiber optic Lockout tagout procedures, insulated tools,
optic work equipment damage technicians, electrical safety training, pre-work voltage
contractors testing
Weather and environmental Slips, heat stress, exposure Tower workers, fiber Weather monitoring, work postponement
risks during outdoor work to lightning or strong winds teams, site protocol, hydration breaks, PPE
surveyors requirements
Working near active roads Traffic accidents, collision Field technicians, Traffic cones, signage, reflective vests,
and public areas risk contractors, coordination with local authorities
installation teams
Manual handling and lifting Muscle strain, back injury Tower riggers, fiber Manual handling training, lifting aids,
of heavy equipment optic teams, two-person lift rules
logistics handlers
Exposure to dust, fiber Respiratory issues, eye Fiber optic splicing Masks, safety goggles, controlled work
particles, and chemicals irritation teams areas, proper waste disposal
2025 Sustainability Report 135
Page 138
Stronger Performance
From People Empowerment
Identified Risk Potential Impact Affected Workers Control Measures/Mitigation
Use of power tools and Cuts, lacerations, Technicians, Tool inspection, PPE gloves, safety briefings
cutting equipment equipment-related injury contractors before use
Working in remote or Delayed emergency Tower teams in rural Lone worker protocol, GPS-based
isolated sites response, communication areas, field monitoring, routine check-in procedures
issues engineers
Vehicle and transportation Road accidents during site All field teams Defensive driving training, vehicle
risks mobilization maintenance schedule, journey
management planning
Psychosocial risks (fatigue, Reduced focus, higher Field workers, Shift rotation, workload review, rest
long shifts, pressure) incident likelihood shift-based staff requirements
To prevent and mitigate occupational health and Workplace Accidents and Occupational Diseases
safety risks throughout its value chain, XLSMART [F.21] [GRI 403-1] [GRI 403-9] [GRI 403-10] [ACGS C.6.1]
applies strict safety requirements for contractors, XLSMART is committed to maintaining operational
especially those involved in tower construction and excellence across all its business activities, including
fiber optic maintenance. All partners must comply with by ensuring zero workplace accidents and preventing
the Company’s HSE standards, participate in safety work-related illnesses. For three consecutive years, the
briefings, and undergo regular monitoring to ensure Company has consistently recorded a zero accident
safe practices are implemented at all times [GRI 403-7]. rate per 200,000 or 1,000,000 man-hours and zero
fatalities.
Work Accidents and Occupational Diseases [GRI
403-9] [GRI 403-10] HSE Trainings [GRI 403-5] [S-05]
XLSMART always strives to maintain operational To enhance the capabilities of members of the Facility
excellence across all its activities, including ensuring Operations and HSE Department and the Facility
zero workplace accidents and preventing any Compliance and HSE Assurance unit, XLSMART
occupational diseases. Over the past three years, the provides continuous opportunities to participate in
Company has consistently recorded a very low level of various HSE training programs. These trainings aim to
workplace incidents. In 2025, XLSMART again reported strengthen awareness of the importance of effectice
a zero accident rate per 200,000 or 1,000,000 man- HSE implementation and support the creation of
hours, reaffirming the Company’s commitment to a sustainable, safe workplace. Below are the HSE
maintaining a safe working environment with zero trainings conducted in in 2025:
fatalities.
Training Title Date Participants
Emergency Response & HT Usage for XLST Floor Warden 3 February 2025 35
Basic Life Support & First Aid for XLST Floor Warden 13 February 2025 40
Internal Audit for HSE & Enterprise team 20 June 2025 10
Workshop & Awareness ISO 45001:2018, ISO 14001:2015, & ISO 22301:2018 4 July 2025 8
HSE Inspection for FO team 26 July 2025 59
HSE Awareness for FO Sabang team 2 August 2025 25
Accident Investigation for FO team 26 September 2025 52
Emergency Response & Basic Life Support for BSD & Sabang Floor Warden 6 November 2025 121
Hazard Identification & Risk Assessment for Partner 25 December 2025 10
E-Learning Basic HSE for all employee April-December 2025 1,995
Improving the Quality of Health at Work [GRI 403-3] [GRI 403-6]
Employee wellbeing remains a key priority for XLSMART. As part of the Company’s commitment to maintaining a
safe, healthy, and supportive workplace, employees are provided access to a wide range of health and wellness
facilities. These include fitness centers, daycare services, and lactation rooms for breastfeeding employees, as well
as several employee-led sports and wellness communities such as cycling, running, basketball, futsal, football,
religious study groups, and music communities. These initiatives aim to promote physical and mental wellbeing,
strengthen social connection, and enhance overall productivity.
136 PT XLSMART Telecom Sejahtera Tbk
Page 139
Connecting Indonesia:
One Purpose - One Planet
To further reinforce its health support programs, XLSMART also operates an internal health clinic staffed by certified
medical professionals. Employees may access occupational health services during office hours at no cost. The clinic
provides preventive care, early detection services, and routine health consultations, helping employees maintain
optimal health while fulfilling their responsibilities.
Through these facilities and initiatives, XLSMART strives to create a work environment that encourages healthy
habits, minimizes health-related risks, and supports sustained employee performance as the organization continues
its post-merger transformation.
Defined Benefits Program and Other
Pension Plan Obligations [GRI 201-3]
A company’s economic sustainability is supported in part by its ability to meet defined benefit and pension obligations
for retiring employees. XLSMART has structured its employee benefits and pension policies in accordance with the
Manpower Law. As stipulated in the Company Regulations and Collective Labour Agreement (CLA), the Company’s
statutory retirement age is 56 years old.
The Company provides employees with a comprehensive pension program consisting of:
1. DPLK (Financial Institution Pension Fund), which is a defined-contribution plan in which the Company contributes
of 7% of wages and employees contribute 3%.
2. JP (Pension Guarantee) from BPJAMSOSTEK in the form of a defined-contribution scheme amounting to 3% of
wages, of which the Company contributes 2% and employees contribute 1%.
The Company adjusts the maximum wage limit periodically in accordance with Government Regulation (PP) No.
45 of 2015. XLSMART calculated the estimated actuarial liabilities as of 31 December 2025 and 2024 based on
independent actuarial assessments issued in reports dated 5 February 2025, respectively.
As of 31 December 2025, the Company allocated Rp490,365 million to fund post-employment benefits, an increase
from Rp252,541 million allocated in 2024. XLSMART recorded 4 (four) employees retiring during the reporting period
and has fulfilled its defined contribution obligations for all retirees.
People Development Strategies
Going Forward
Entering the next phase of integration, XLSMART human capital has become one of a critical enabler of sustainable
growth, operational excellence, and long-term value creation. Building on the foundation established during the
post-merger integration period, the Company’s human capital strategy going forward is focused on strengthening
organizational capability, accelerating digital readiness, and fostering a high-performance, inclusive, and future-
ready workforce. With the new work culture, the Company initiate to continue the contribution to broader ESG
objectives by promoting equal opportunity, ethical labor practices, and long-term employability.
2025 Sustainability Report 137
Page 140
Shaping Inclusive and
Sustainable Digital Future
138 PT XLSMART Telecom Sejahtera Tbk
Page 141
Connecting Indonesia:
One Purpose - One Planet
Shaping Inclusive and
Sustainable Digital Future
2025 Sustainability Report 139
Page 142
Shaping Inclusive and
Sustainable Digital Future
Delivering Impact on Society [F.23] [F.25]
[GRI 413-1]
Gerakan Donasi Kuota at SMK Negeri 1 Cimahi, Jawa Barat
In 2025, XLSMART entered its first full year as one united company. The merger did more than combine networks
and capabilities, it opened a greater mission to serve, empower, and uplift communities across Indonesia with wider
reach and improved access to technology.
With broader reach comes greater responsibility, and XLSMART remains committed to ensuring that digital
transformation is accessible, meaningful, and beneficial for all segments of society, including underserved
populations, vulnerable groups, and communities outside major cities. Digital progress must translate into tangible
benefits for those who rely on technology for education, income, services, and daily communication.
Our social performance is managed through a structured approach covering planning, implementation, monitoring,
and evaluation to ensure measurable and sustainable outcomes. Focus areas are defined based on community
needs, stakeholder expectations, and historical learning. XLSMART works with ministries, regional governments,
NGOs, schools, libraries, and employee volunteers to expand reach and strengthen impact. Progress is monitored
through participation data, assessments, and community feedback to support continuous improvement. [GRI 3-3]
140 PT XLSMART Telecom Sejahtera Tbk
Page 143
Connecting Indonesia:
One Purpose - One Planet
Across Indonesia, our efforts are built on three priorities, based on the XLSMART CSR Tri Karsa:
Untuk Indonesia
TRI KARSA
XLSMART CSR
Women
Philantrophy Education
Empowerment
• Peduli Bencana • Sisternet • Gerakan Donasi Kuota
• Peduli Kesehatan • Female Future Leader • Content Creator Academy
• Peduli Disabilitas • SheInspire • Pesantren Digital
• Bunda Pintar • Kelas Cerdas Digital
• Teman UMKM
Related SDGs: Related SDGs: Related SDGs:
Community development and empowerment from and for all
XLSMART CSR programs
Total CSR Funds Disbursed
2025
Rp 28.10 billion
2024 Rp35.63 billion 2023 Rp20.73 billion
2025 Sustainability Report 141
Page 144
Shaping Inclusive and
Sustainable Digital Future
XLSMART PEDULI A similar initiative was implemented in Cianjur, West
Java, where employee donations were used to build a
Disaster Response and Emergency Aid small mosque equipped with a clean water facility that
Under the XL Axiata Peduli program, XLSMART provided serves both religious activities and community access.
emergency relief aid to communities affected by natural The infrastructure allows residents to obtain water
disasters in West Halmahera, Bandar Lampung, and without relying on distant sources, reducing household
Pekalongan. The assistance was distributed directly to burdens and improving hygiene for families in the area.
residents through XLSMART representatives and local
partners, ensuring fast and targeted delivery on the Both projects were funded through employee zakat
ground. and infaq collected and managed by MTXLSMART. By
building permanent infrastructure rather than short-
In West Halmahera, assistance was provided to term assistance, XLSMART ensures that support
communities impacted by the eruption of Mount Ibu, remains beneficial for years to come. These efforts
including residents of Sangaji Nyeku Village in Tabaru reflect the Company’s commitment to strengthening
District. Emergency relief packages included masks, community welfare, expanding access to basic needs,
blankets, drinking water, and basic necessities. In and uplifting vulnerable groups beyond gender-
Bandar Lampung, XLSMART supported families focused programs.
affected by severe flooding in Way Lunik, Panjang
District, providing essential food supplies, baby Digital Inclusion for People with Disabilities
formula, and children’s meals. Distribution was carried XLSMART strengthened digital accessibility through
out by XLSMART’s regional sales team to ensure direct Inklusi Disabilitas Berdaya 2025, a tailored digital-
delivery to evacuation areas. A similar initiative was empowerment program for users with visual, hearing,
carried out in Petungkriyono, Pekalongan Regency, and mobility impairments. Delivery combined online
where residents affected by flash floods received learning and onsite sessions supported by accessible
drinking water, bread, and daily necessities through the materials, sign-language interpretation, and hands-
Company’s local partners. on digital practice to help participants gain confidence
and familiarity with technology.
In parallel with aid distribution, technical teams were
deployed to ensure that telecommunication services Throughout the program, participants received
in all three locations remained operational. Most 4G practical digital-skills education, covering safe internet
services continued running during the disaster, enabling usage, content creation, social media promotion,
residents, first responders, and local authorities to stay and basic skills in online business development.
connected in emergency conditions. Motivational sessions and peer discussions were
included to strengthen self-confidence and encourage
Clean Water Infrastructure by MTXLSMART communication skills, particularly for participants
MTXLSMART also provides long-term infrastructure preparing to enter the workforce or build small
support to help underserved communities gain access businesses from home.
to basic public facilities. One of the flagship initiatives
in 2025 was the clean water infrastructure project Over 100 beneficiaries participated. Caregivers
in Nagakeo, East Nusa Tenggara (NTT). In this area, reported improved motivation and independence, with
residents and students at Pondok Pesantren Al-Ummah several participants beginning to promote products
Al-Islamiyah had limited access to clean water and and services through social platforms with guidance
were required to walk long distances to collect water for from mentors. The program shows how inclusive digital
daily needs. tools expand opportunity.
To address this, MTXLSMART funded and built a Mass Circumcision for Children with Disabilities
complete clean-water system consisting of a water Through the Majelis Taklim XLSMART (MTXLSMART),
tower, distribution pipelines and filtration systems. employees organized a series of mass circumcision
The project was carried out over four months and now programs for children with disabilities. The first was
supplies clean water for daily consumption, sanitation, held in Medan at Rumah Difabel Khadijah Sharaswaty
and religious activities for approximately 550 students Indonesia, involving social partners and medical
and surrounding residents. The facility is operated professionals. Sixty children with visual, hearing,
directly by local community managers, ensuring physical, and intellectual disabilities received free
sustainability and continuous benefit to the village. circumcision, medical care, and gift packages.
142 PT XLSMART Telecom Sejahtera Tbk
Page 145
Connecting Indonesia:
One Purpose - One Planet
The program is fully funded through employee zakat contributions managed by MTXLSMART, demonstrating
employee-driven community solidarity. Similar activities were repeated in Banyumas and Tegal, benefited an
additional 128 children with events designed to be child-friendly, safe, and inclusive. Beyond the medical process,
XLSMART installed activity booths, distributed worship kits, and supported family connectivity through SIM
registration services at the venue.
Sistenet Festival
SISTERNET Advancing Women’s Digital Participation through
#1JutaSisterDigital
Women’s empowerment has been one of XLSMART’s Through Sisternet, XLSMART launched
longest-running social priorities. Through Sisternet, #1JutaSisterDigital, a national gender-inclusive digital
XLSMART provides digital learning, entrepreneurship acceleration program developed with the Ministry
development, financial literacy, and mentoring to of Communication and Digital Affairs (Komdigi). The
strengthen women’s access to future skills and economic initiative was formalized during the BRAVO-500
independence. As of 2025, Sisternet had reached Summit 2025 in Jakarta, marking one of Indonesia’s
more than 1.3 million beneficiaries, including students, largest public-private efforts to increase female
young professionals, micro entrepreneurs, and women participation in the digital economy.
in rural areas. The approach is built on nationwide
access, hybrid learning models, and partnerships with The initiative integrates Sisternet’s application with
ministries, universities, TBM communities, and women- Komdigi’s Learning Management System, enabling
led organizations. nationwide access to curated digital-literacy modules
and technology modules directly on the Sisternet app.
These modules cover cybersecurity, fintech, digital
content creation, and responsible digital behavior.
2025 Sustainability Report 143
Page 146
Shaping Inclusive and
Sustainable Digital Future
A core component is the expansion of the Female Future The program focuses on economic empowerment
Leader AI Bootcamp (FFL). Previously reaching 70,000 and psychosocial recovery for women preparing for
beneficiaries, the program will train over 100,000 reintegrate into society. Training consists of:
Indonesian women in AI fundamentals through hybrid
learning, combining digital bootcamps, campus- Soft-skill Training (online)
based workshops, and online mentoring. Around 20 • Public speaking;
universities and women-focused communities are • Entrepreneurship and financial literacy;
involved, helping extend coverage to rural and remote • Mental-wellness and confidence development.
areas.
Hard-skill Training (onsite)
To secure long-term impact, XLSMART positioned • Bread and pastry production;
BRAVO-500 Summit as a platform to mobilize support • Tufting and textile-based craftwork; and
from Indonesia’s top 500 corporations, regulators, • Product marketing.
technology leaders, startups, and the media. The
initiative encourages private-sector adoption of Each Lapas is supported by a local mentor providing
gender-inclusive technology ecosystems and safer post-training guidance, business incubation, and
digital spaces for women. psychosocial support post-release. The program aims
to reduce social stigma, strengthen self-esteem, and
Currently, Sisternet has 1.3 million beneficiaries help former inmates re-enter the workforce with a
consisting of MSME women, students, professionals, marketable skill set.
and women in correctional facilities. With
#1JutaSisterDigital running from September 2025 to Key results from the first implementation phase:
December 2026, XLSMART targets to grow it to 2.4 • 500 women trained across 10 cities;
million empowered women, one of the largest digital- • 98% reported improved emotional management;
empowerment movements in the nation. • 100% reported increased confidence in
communication; and
This program directly supports national priorities, • Inmate-run micro-businesses saw a 5% sales
including Indonesia Emas 2045, SDG 5 (Gender increase during the program period.
Equality), SDG 4 (Quality Education), SDG 8 (Decent
Work and Economic Growth), and SDG 9 (Industry, In July 2025, the closing ceremony for the 2024–2025
Innovation and Infrastructure). cycle was held at Lapas Perempuan Kelas III Mataram,
NTB, attended by KemenPPPA and senior leadership
from XLSMART. Following a positive evaluation,
Empowering Women in Correctional Institutions XLSMART and KemenPPPA announced an expansion
through SheInspire plan through 2026, including:
XLSMART also delivers empowerment for women • Extended post-release mentoring;
with limited access to formal education and economic • Digital marketing support;
opportunities: female inmates in correctional • Product photography training;
institutions. • Access to e-commerce channels; and
• Collaboration with Balai Pemasyarakatan for
Through Sisternet and the Ministry of Women reintegration support.
Empowerment and Child Protection (KemenPPPA),
XLSMART implemented SheInspire Sinergi Berdaya: Through SheInspire, XLSMART goes beyond one-
Bersinar Bangkit Bersama across 10 female correctional time training, building an ecosystem for long-term
institutions (Lapas Perempuan) in Indonesia, including independence and second chances. Support continues
Yogyakarta, Tangerang, Bandung, Lampung, Lombok, after release through mentoring and access to online
Kerobokan, Medan, Makassar, Denpasar and NTB. marketplaces, helping women earn independent
income and reduce vulnerability during reintegration
into society.
144 PT XLSMART Telecom Sejahtera Tbk
Page 147
Connecting Indonesia:
One Purpose - One Planet
Strengthening Community Resilience and To ensure comfort and safety, participants received
Supporting Local Livelihoods souvenirs, allowances, and travel insurance throughout
the trip. Premium travel services were provided for 40
Ramadan Social Programs: Semarak Ramadhan top-performing retailers, who won the Sales Racing
1446H Competition, earning a trip home using Innova and
During the holy month of Ramadan, MTXL Axiata Alphard units. Winners represented 10 retail outlets
carried out the Semarak Ramadhan 1446H program across Depok, Bogor, East Jakarta, South Jakarta,
through “Berbagi Kebaikan”, an employee-led initiative North Jakarta, Kabupaten Bekasi, Kota Bekasi, and
that distributes essential food packages to communities Kabupaten Tangerang.
in need across Sumatra. The assistance reached
orphans, the elderly, Islamic teachers, converts, bilal, In addition to retailer support, XLSMART also organized
and mosque caretakers, and economically vulnerable a separate Mudik Bareng program for employees and
families in Palembang, Medan, and Pekanbaru. their families, covering destinations in West Java,
Central Java, Yogyakarta, East Java, and Sumatra.
In Palembang, MTXL Axiata collaborated with Taman Approximately 135 employees and family members
Pendidikan Al-Qur’an Griya Mutiara to distribute 33 joined the departure from the Company’s Head Office
packages at the XL Axiata Palembang office. In Medan, in Jakarta using 3 dedicated buses.
more than 300 packages were delivered at Masjid
Taqwa Kampung Dadap through a collaboration The program is part of XLSMART’s effort to support safe
with Lazismu, Bank Indonesia, Pimpinan Cabang and affordable homecoming trips while strengthening
Muhammadiyah Kampung Dadap, and Pimpinan traditional distribution channels and partner
Cabang ‘Aisyiyah. In Pekanbaru, 33 packages were motivation. This initiative also expresses the Company’s
distributed directly at the XL Axiata Pekanbaru office. appreciation for its partners and contributes to national
traffic management efforts by providing safe and
The program was fully funded by monthly zakat organized travel alternatives during the peak holiday
and infaq contributions voluntarily collected from season.
employees and management, managed transparently
by MTXL Axiata. Beyond seasonal charity, these funds Gebyar Muharram 1447H: Nationwide Employee-Led
also support long-term community initiatives. Over Philanthropy
the years, MTXL Axiata has helped build bridges, Beyond Ramadan, XLSMART employees also
clean water facilities, village electricity access, houses continued their social contribution through the annual
of worship, local roads, home renovations, and the Gebyar Muharram 1447H, implementing the theme
construction of community water depots to ensure #GebyarBerbagi and #BersamaDiMuharram. The
clean water availability. The initiative also includes program distributed food packages, school supplies,
blood donation drives, mass circumcision programs financial assistance and access-to-education support
for both general and disabled children, and other social in more than ten cities across Indonesia, including
support activities carried out regularly in multiple cities. Jakarta, Pekanbaru, Bandung, Palembang, Pontianak,
Banjarmasin, Surabaya, Makassar, and Banten.
Mudik Bareng: Safe Travel Access for Retailers and
Employees A key component of the program was a mass
XLSMART held the annual Mudik Bareng Gratis program circumcision held simultaneously at:
for retail partners and employees in the Jabodetabek • XLSMART Tower, South Jakarta;
area. A total of 600 participants traveled to destinations • XLSMART Sabang, Central Jakarta; and
across West Java, Central Java, Yogyakarta, and East • Cirebon, supported by trained medical professionals
Java. The Company prepared 12 large buses, 5 Innova, from Lembaga Inisiatif Zakat Indonesia and DT
and 5 Alphard units to support the trip. Peduli Cirebon.
2025 Sustainability Report 145
Page 148
Shaping Inclusive and
Sustainable Digital Future
More than 100 children benefited from this event, which Strengthening Digital Inclusion and National
included hygiene facilities, medical support, and post- Connectivity
procedure recovery. Additional community activities
included: Participation in UN CSW69: Global Advocacy on
• Movie day for orphaned children; Gender and Digital Inclusion
• MuharRUN (charity run); To elevate Indonesia’s position in the global gender
• Charity rally; equality movement, XL Axiata participated in the 69th
• Archery for children; Commission on the Status of Women (CSW69) at the
• “Belanja Bareng” (Shopping with orphans); and United Nations Headquarters in New York.
• Installation of clean water and community bridges.
Through a side event titled “Shaping an Inclusive Digital
The program was entirely funded by monthly Economy: Indonesia & India’s Leadership and ASEAN’s
employee zakat and sedekah contributions managed Collaborative Vision”, XL Axiata presented Indonesia’s
by Majelis Ta’lim XLSMART (MTXLSMART). Over the initiatives to create safe, equitable digital access for
years, MTXLSMART has gradually expanded its role women, especially MSME owners and vulnerable
from short-term charity to tangible infrastructure groups. The engagement strengthened XLSMART’s role
development, which includes building: as a regional advocate for digital equality in Southeast
Asia. [GRI 413-1]
Bridges Key highlights included:
• 1+ million women trained through Sisternet since
2015;
• Improved access to digital education and financial
Clean water installations
literacy for women; and
• Internal Diversity & Inclusion policy with 33%
of managerial positions held by women, above
Community electricity access infrastructure industry average.
Participation in CSW69 aligned with Indonesia’s
commitment to:
Public roads
• Reduce gender-based online harassment and
cyber-violence;
• Expand access to digital skills development for
Houses of worship women;
• Advance inclusion for rural and low-income women;
and
• Accelerate progress toward SDG 5 and Indonesia
Community Donations to Orphanages Emas 2045.
Separately, XLSMART also provided operational and
living support to Panti Asuhan Putri Tunas Harapan Support for National Events: 2025 Pacu Jalur Festival
Aisyiyah in Pontianak. Senior leadership conducted Ahead of the internationally-recognized Festival
a direct visit, distributing staple goods, educational Pacu Jalur in Riau, XLSMART upgraded over 41 BTS
supplies, and support to foster children and caregivers. and added 2 new sites specifically to support event
The donation was part of the wider XLSMART Berbagi traffic. Across Riau province, more than 700 BTS were
initiative. upgraded to improve network reliability and throughput.
Enhanced network reliability supports tourism activity,
Another donation initiative was implemented in Karo, digital content sharing, MSME transactions, and media
North Sumatera, where XLSMART distributed school coverage, boosting cultural visibility and strengthening
supplies, Qur’an, Mukena, and Iqro learning books for economic potential for Kuansing and surrounding
children at the foothills of Mount Sinabung. The event regions.
included coordination with local community leaders,
religious educators, and academic representatives.
146 PT XLSMART Telecom Sejahtera Tbk
Page 149
Connecting Indonesia:
One Purpose - One Planet
Measuring Our Social Impact and
Value Creation
Each of our programs is designed to leave a sustainable We have calculated the investment deployed through
impact. A woman who once felt limited now has the several community empowerment programs. Based on
confidence to build her own income. A student in a small the Social Return on Investment analysis, the program
town can study with reliable internet access. A family recorded a ratio of 1:2.54. This means that for every
affected by a disaster can call for help because the Rp1 invested by the Company, the program generated
network remains active. These are the real changes we Rp2.54 in social value for stakeholders. This outcome
are committed to creating. affirms the Company’s commitment to delivering social
investments that are effective, well-targeted, and
To evaluate impact meaningfully, XLSMART uses the capable of generating a positive multiplier effect on
Social Return on Investment (SROI) method, which community welfare.
measures intangible outcomes such as confidence,
emotional well-being, employability, and community XLSMART also identifies, monitors, and minimize
preparedness. SROI helps quantify how the Company potential adverse impacts during program execution.
resources translate into tangible benefits for society. All activities are implemented in line with national and
international standards to ensure that beneficiaries are
In 2025, XLSMART reached thousands of beneficiaries treated with respect, safety, and dignity. Continuous
across Indonesia through the XLSMART CSR Trikarsa feedback from communities and program partners
programs. Total beneficiaries reached 232,696 informs our approach, ensuring each cycle becomes
people across multiple regions in Indonesia. To deliver more impactful and inclusive. Monitoring results,
these efforts, the Company allocated Rp28.10 billion, including coordination with local authorities, safety
including non-financial contributions monetized into protocols, and post- activity evaluations indicated
Rupiah for reporting purposes. no significant negative impacts were recorded
throughout the execution of XLSMART’s programs, and
SROI assessments were applied to flagship programs no public complaints were recorded related to their
including Sisternet, XLSMART Peduli, Pesantren Digital, implementation. [GRI 413-2] [F.24]
Gerakan Donasi Kuota, Kelas Cerdas Digital, Bunda
Pintar and Teman Pintar. XLSMART is committed to ensuring that its operational
activities respect and support the interests of
surrounding communities. We strive to maintain safe,
orderly, and considerate operations, especially in areas
located close to residential neighborhoods or public
facilities.
2025 Sustainability Report 147
Page 150
Shaping Inclusive and
Sustainable Digital Future
XLSMART wants communities to feel heard and supported at all times. To ensure that communities can reach us
easily whenever needed, XLSMART provides dedicated communication channels that can be used for inquiries,
feedback, or operational concerns. The following contacts are available for public communication and coordination.
Corporate Governance Corporate Communication & Investor Related
Sustainability Program
corpsec@xlsmart.co.id ir@xlsmart.co.id
corpcomm@xlsmart.co.id
Product Inquiries, Complaints or Network-Related
XL AXIS SMARTFREN
customerservice@xlsmart.co.id cs@axis.co.id customercare@smartfren.com
Contribution to Sustainable Development Goals (SDGs)
Program Coverage Impact Contribution to SDGs
Sisternet Nationwide Empowering women everywhere in Indonesia to develop
and increase their welfare through use of internet and
technologies, thus preparing them for 4.0 industry.
Bunda Pintar Nationwide The Bunda Pintar Program empowers women by improving
digital access and literacy through free internet and hybrid
digital literacy training, enabling them to use the internet
productively, safely, and sustainably while strengthening
their role as digital change agents in families and
communities.
Gerakan Donasi Kuota Nationwide Improving the quality of education nationwide through the
(GDK) increasing participation of XLSMART’s service users and
the public at large to voluntarily donate their quota to be
further distributed to schools across the country.
Content Creator Nationwide Nurtures students’ creativity and introduces opportunities
Academy in the digital and creative economy, equipping them with
mentorship and hands-on experience to explore future
careers in the digital industry.
Teman UMKM Nationwide The program strengthened sustainable business literacy,
expanded networks among MSMEs and youth communities,
and fostered a community-based growth ecosystem. Its
impact goes beyond improving skills and digital exposure,
contributing to local economic empowerment and
promoting an inclusive, sustainable community
development model aligned with the company’s ESG social
commitments.
148 PT XLSMART Telecom Sejahtera Tbk
Page 151
Connecting Indonesia:
One Purpose - One Planet
Program Coverage Impact Contribution to SDGs
Kelas Cerdas Digital Nationwide Strengthens youth digital literacy by equipping students
with essential digital skills and safety awareness,
empowering them to use technology responsibly while
fostering a positive and inclusive digital environment in
schools.
Pesantren Digital Nationwide Enhancing knowledge of Santri/Santriwati through AI
Digital Workshop for education, business and philanthropy.
XLSMART Peduli Nationwide Providing social supports to the victims of natural disasters
Bencana through distribution of emergency assistance programs.
XLSMART Peduli Nationwide Upscaling Digital Capacity of Disabilities through AI Digital
Disabilitas Workshop for education, business and philanthropy.
2025 Sustainability Report 149
Page 152
Ensuring Responsible
and Ethical Business
150 PT XLSMART Telecom Sejahtera Tbk
Page 153
Connecting Indonesia:
One Purpose - One Planet
Ensuring Responsible and
Ethical Business
2025 Sustainability Report 151
Page 154
Ensuring Responsible
and Ethical Business
Post-Merger Improvements to
Customer Experience
The 2025 merger not only integrated governance and • Introduction of Credit Control, a feature that allows
operations, but also delivered significant improvements prepaid customers to lock their balance and prevent
to the customer experience across networks, services, unauthorized deductions for paid SMS, subscription
and digital channels. XLSMART now brings together content, or out-of-plan data usage, providing
the well-established XL, AXIS, and Smartfren brands greater transparency and control.
under one ecosystem, supported by shared resources, • Implementation of SIM card registration using facial
integrated infrastructure, and unified service standards. recognition, integrated with the national population
Key initiatives introduced during the first year of the database to enhance accuracy, prevent identity
merger include: misuse, and support the government’s digital-
• Integration of the Customer Experience & Service transformation agenda.
Operation Center (CE & SOC) into a single national • Strategic partnerships with Huawei and ZTE,
command center in BSD. The facility consolidates strengthening nationwide network operations
two previously separate Network Operation Centers and enhancing employee capabilities in digital
(NOCs) and enables real-time monitoring, faster innovation and technology.
escalation, and coordinated issue resolution across • For enterprise clients, XLSMART for Business
business units. expanded digital and connectivity through platforms
• Expansion of 4G LTE and VoLTE coverage through such as ESTA and partnerships with technology
the For Smartfren brand, reaching new areas providers, supporting digital transformation and
including Aceh, Gianyar, Klungkung, Karangasem, operational efficiency across multiple industries.
and Kupang City-strengthening network reliability
and ensuring faster, more stable data access in both Collectively, these initiatives demonstrate how the
urban and regional areas. merger is translating into tangible service improvements
• Launch of “Sarah,” a Generative AI–powered virtual for customers, supported by a stronger brand
assistant, enabling faster, more personalized, and ecosystem, enhanced network reliability, improved
solution-oriented customer interactions across protection features, and more modern digital care.
Smartfren Care digital platforms.
Customer Protection, Engagement
and Satisfaction
XLSMART serves millions of customers from across Customer Data Privacy and Security [GRI 418-1]
diverse regions, demographics, digital-literacy levels, Digital trust begins with privacy. XLSMART manages
and purchasing power segments. In such a varied personal information responsibly and strictly within
landscape, customer relationships must be built on three boundaries of the law. The Company’s Privacy
foundations: protection, engagement, and satisfaction. Information Management System is anchored in ISO
XLSMART ensures that customers receive safe, 27701 and ISO 27001 certifications and has been
transparent, equitable, and responsive service through consolidated into a single framework following the
a structured approach that integrates governance, merger.
analytics, and intelligent service operations. [F.17]
152 PT XLSMART Telecom Sejahtera Tbk
Page 155
Connecting Indonesia:
One Purpose - One Planet
XLSMART also applies a Privacy by Design and Default Protection from Spam and Fraud Calls
principle, ensuring that every new digital feature Beyond customer education, XLSMART prevents
undergoes privacy risk assessments, encryption spam calls, spoofed caller identities, and fraudulent
validation, and cybersecurity reviews prior to. Key messages. The Company uses automated detection
initiatives in 2025 include: and blocking systems capable of monitoring unusual
• Strengthened biometric SIM registration supported call and messaging patterns and restricting numbers
by secure integration with the national population that show high-risk activity in accordance with
database; Komdigi’s guidelines. Suspicious numbers may be
• Multi-factor authentication and AI-based anomaly limited, blocked, or escalated to regulators for further
detection to prevent unauthorized access; action, helping prevent identity misuse and financial
• Annual independent privacy audits; fraud.
• Mandatory employee certification on personal data
ethics; The urgency of these efforts is underscroed by national
• Launch of the Data Transparency Portal, enabling data. A public study covered in Tempo reported that
customers to manage their data permissions in real Indonesians receive an average of 16 spam calls per
time. month, and around 89 percent of calls from unknown
numbers identified as spam. Indonesia ranks second
Customer Protection and Fair Treatment in the Asia-Pacific region, behind Hong Kong. ANTARA
The Company complies with the Consumer Protection News, referencing the Global Call Threat Q4 2024
Law and adopts clear terms of service, transparent report, also noted that Indonesia remains among the
pricing, and secure data-handling practices. Customer countries with the highest spam exposure in Asia-
protection is reinforced through: Pacific, averaging 14 spam calls per person per month
• Standard Operating Procedures for inquiry and and approximately 86 percent of unknown incoming
complaint handling; numbers categorized as spam. Regulator enforcement
• Secure verification for all customer interactions; is increasing. According to a statement covered by
• Data privacy safeguards aligned with national Selular.id, the Ministry of Communication and Digital
regulations; Affairs (Komdigi) blocked approximately 1.3 million
• Real-time service monitoring to minimize service phone numbers in 2024 due to suspected fraudulent or
disruptions; spam activities.
• Accessible service channels through call centers,
chat, and digital platforms; Building on XL Axiata’s previous fraud-prevention
systems–which limited SMS misuse and enabled
These measures ensure that customers receive reporting of scam messages, XLSMART continues
transparent, reliable, and safe services throughout their to strengthen its detection and filtering capabilities.
digital journey. While spam remains an industry wide challenge, the
Company actively collaborates with regulators and
To protect users from fraud, XLSMART continuously employs data-based monitoring to limit high-risk
educates customers not to share personal information numbers and enhance user protection. Customers may
with unknown parties and to verify suspicious report suspicious calls via call centers, WhatsApp, or
communications through the 24-hour Customer the MyXL application for immediate handling.
Service Center. As of 2025, there were no confirmed
data breaches or violations of privacy policies. This Customer Engagement
outcome reaffirms the effectiveness of XLSMART’s Customer engagement at XLSMART is driven by data,
responsible data governance practices. research, and continuous feedback from millions of
users to ensure services remain relevant, reliable, and
accessible. The Company assesses customer behavior,
product performance, and service interactions to
identify priorities, monitor satisfaction, and optimize
digital journeys. Engagement activities include:
2025 Sustainability Report 153
Page 156
Ensuring Responsible
and Ethical Business
• Product, pricing, and digital journey benchmarking against peer operators
• Market insight studies to understand perception, purchasing power, and emerging user trends
• Digital sentiment monitoring through social media and applications
• Regular satisfaction surveys supported by TNPS analytics
To facilitate direct communication, XLSMART provides a 24/7 Integrated Customer Service managed by the Service
Management Directorate. Customers can access support anytime through:
Call Centers
• 817 via XL Number (Customer Regular)
• (021) 57959817 via non-XL Number
• 818 via XL Number (Customer Priorities)
• 820 via Nomor XL (Customer Home)
• 08170123442 via non-XL Number (Customer Home)
Digital Channels
• Live chat via MyXL App • Live chat via Axis web axis.co.id
• Live chat Priorities via MyXL Prioritas apps • Live chat via MyXL Home App
• Live chat via web xl.co.id • Social media via Facebook @XLhomeid (XL Satu)
• Social media via Facebook (@myxlcare) • Correspondence via email to xlhomecs@ xl.co.id
• Correspondence via email (XL Satu)
customerservice@xl.co.id • Messenger via Whatsapp 08170010820 (XL Satu)
• Live chat via Axisnet App • Live chat via web xlaxiata.co.id
Physical Service Points
• 93 XL Centers, including XLC Online nationwide
• 51 Smartfren Galleries
• 7 Smartfren Mini Gallery Corporate
Customer Satisfaction Through real-time dashboards, machine-powered
Satisfaction is assessed through service quality, alarms, and predictive analytics, the CE & SOC enables
responsiveness, and issue resolution. The establishment earlier detection of network anomalies, faster escalation
of Customer Experience & Service Operation Center processes, and coordinated cross-unit resolution.
(CE & SOC) marks a major post-merger milestone. The This integrated system also provides a single national
center consolidates two previously separate Network view of customer-service performance, significantly
Operation Centers (NOCs), formerly located at the XL strengthening XLSMART’s ability to maintain service
Axiata Tower in Kuningan and the Smartfren facility reliability and enhance customer satisfaction.
in BSD, into a single integrated hub at the XLSMART
Building in Bumi Serpong Damai (BSD) City, South The CE & SOC functions not only as a command center,
Tangerang. Fully operational integrated since July 2025 but also as a strategic hub that supports predictive and
the CE & SOC prioritizes nationwide network stability, preventive operations. Its key functions and advantages
operational efficiency, and service effectiveness. are outlined below:
Function Advantage
Serve as an integrated center for monitoring service quality. To Built with network elements consisting of hundreds of thousands
support this function, the Company developed has developed a of alarms powered by machines, rather than manually, thus
unified monitoring room that consolidates 4 NOCs (Network successfully increasing the speed and accuracy of services.
Operation Centers): Telco Network, IT Infrastructure, IT apps,
and Billing.
Facilitate coordinated handling of potential issues related to Can anticipate future needs, especially regarding network
network performance and service quality. development plans and the adoption of the latest technology.
Monitor service dynamics comprehensively, the utilization of
customer service channels and facilities.
154 PT XLSMART Telecom Sejahtera Tbk
Page 157
Connecting Indonesia:
One Purpose - One Planet
Service Performance and Complaint Resolution
To always improve the quality of Integrated Customer Service, XLSMART conducts regular evaluations based on the
categories established in the Total Complaints criteria, following the Complaint Topic Standards set by Komdigi. The
criteria are as follows:
Report on Service Performance
Komdigi
Service Performance Parameter 2025 2024 2023
Standards
Customer Complaint Handling Percentage of customer ≥ 95% 99.59% 97.86% 98.99%
Standards complaints resolved
Standard Service Number of service interruption ≤ 2% 0.3 0.5 0.6
reports per 1,000 customers
The evaluation results indicate that reports on service interruptions improved from 0.5% in 2024 to 0.3% in 2025,
reflecting the Company’s commitment to enhancing customer experience and strengthening post-merger network
integration.
XLSMART also manages multiple communication channels to monitor public complaints and reports. The Company
uses this public feedback to improve the quality of its products and services. [F.24]
Report on Public Complaints based on Report Status
2025 2024 2023
Report Status
Total % Total % Total %
Resolved 1,343,312 99.99 1,635,365 99.99 1,181,139 99.93
In Process 1,498 0.01 233 0.01 882 0.07
Unresolved 0 0 0 0 0 0
Total 1,344,810 100.00 1,635,598 100.00 1,182,021 100.00
Public Complaint Reports based on Complaint Mechanism
2025 2024 2023
Report Mechanism
Total % Total % Total %
WBS N/A N/A N/A N/A N/A N/A
Email 452,728 33.70 109,091 12.78 274,835 23.25
By phone (hotline), digital, or walk in 892,082 66.30 1,426,507 87.22 907,186 76.75
Total 1,344,810 100.00 1,635,598 100.00 1,182,021 100.00
Total Complaints based on Topics
Resolved In Process Unresolved
Complaint Topic Total
Total % Total % Total %
Mobile Internet 167,096 12.44 70 4.67 0 0 167,166
Charging 212,679 15.83 254 16.96 0 0 212,933
Registration 253,820 18.90 248 16.56 0 0 254,068
Others 709,717 52.83 926 61.82 0 0 710,643
Total 1,343,312 100.00 1,498 100.00 0 0 1,344,810
2025 Sustainability Report 155
Page 158
Ensuring Responsible
and Ethical Business
Customer Satisfaction Surveys [F.30]
XLSMART strives to strengthen customer satisfaction to ensure that service quality and overall experience remain
consistent throughout the integration process. Customer feedback continues to be collected, primarily through the
daily Net Promoter Survey (NPS). This survey aims to capture information on customer perceptions of XLSMART’s
brand and service quality, identify factors that affect customer satisfaction and improve the customer experience.
Insights from these surveys are used to identify key drivers of satisfaction and inform improvement initiatives across
the merged platforms, enabling the Company to refine digital journeys, enhance response times, and elevate the
end-to-end customer experience. In 2025, TNPS results showed an increase from 2024 to 2025 by 21%.
Labelling and Marketing [GRI 417-1]
XLSMART ensures that every product label and marketing material provides accurate, complete, and truthful
information regarding product features, usage terms, pricing, and benefits. Transparent communication is essential
for building customer trust, particularly in a diverse market with varying levels of digital literacy.
To ensure compliance, all promotional materials-across digital, print, broadcast, and influencer-based channels-
undergo a multi-layered internal approval process. This review includes verification on tariff clarity, service
limitations, auto-renewal mechanisms, and potential risks associated with third-party content or subscription
services. Marketing teams are required to follow ethical guidelines and ensure that visuals, taglines, and calls-to-
action do not mislead or create false expectations.
XLSMART adheres to the Consumer Protection Law, Komdigi's marketing and advertising standards, and internal
communication policies. The Company also applies clear disclosures on internet speed limits, fair usage policies,
subscription terms, and any potential additional fees to ensure transparency for customers. For services with auto-
renewal features, reminder notifications are provided, and customers have full control to activate or deactivate
the service through accessible digital channels. Customer feedback obtained from call centers, social media, and
complaint channels is continuously used to refine communication materials and prevent recurring misunderstandings,
particularly for value-added services and promotional offerings. [GRI 3-3]
In 2025, XLSMART recorded no incidents of non-compliance related to product labeling, misleading promotions, or
marketing activities. This outcome reflects the effectiveness of the Company’s preventive controls, ethical marketing
practices, and commitment to responsible communication. [GRI 417-2] [GRI 417-3]
156 PT XLSMART Telecom Sejahtera Tbk
Page 159
Connecting Indonesia:
One Purpose - One Planet
Digital Responsibilities, Inclusion
and Rights [F.28]
XLSMART envisions a digital ecosystem where To uphold product and service quality, XLSMART
technological progress is inclusive, responsible, and applies a security framework known as Governance-
protective of users from online harm. To support this Protection-Operations (GPO). This framework helps the
vision, the Company continues to implement initiatives Company identify gaps, prioritize improvements, and
that expand access for underserved communities, strengthen overall security readiness. Improvements
enhance digital literacy, and promote responsible online include the completion of IT security policies,
behaviour, through programs such as: deployment of enhanced protection systems, and
• Smart Connectivity for All, supporting affordable continuous monitoring to detect and mitigate attempted
internet access in remote and rural areas; breaches or vulnerabilities.
• Digital literacy and cyber-awareness programs for
youth, women, and MSMEs; Aligned with the Company’s commitment to ensuring
• Credit Control, a feature to prevent unintended data the benefits and safety of its service solutions,
deductions for prepaid users; XLSMART conducts periodic reviews to assess product
• “Sarah”, a Generative AI-powered virtual assistant, impact and quality both before and after public release.
enabling customers-including those in remote A dedicated team ensures that:
regions or with limited access to physical centers- to 1. Each product design meets aligns with actual
receive personalized, real-time support; market needs.
• Facial recognition-based SIM registration, securely 2. All products and features pass rigorous quality
integrated with the national population database; assurance testing before launch.
and 3. Customer journeys are supported by procedures,
• ESTA (Enterprise Smart Technology & Automation) policies and systems that safeguard customer data
enabling business clients to optimize digital from registration and activation through purchase,
operations safely and efficiently. payment, and deactivation.
XLSMART’s policies are aligned with international As part of this assessment process, XLSMART adopts
standards, including GSMA Principles for Responsible three key approaches: rationalization, simplification
Mobile Connectivity and OECD Digital Ethics, which and automation. These include establishing an
emphasize fairness, accountability, and respect for Enterprise Product Catalog with standardized
user rights in the digital ecosystem. [GRI 3-3] structures across product lines to support seamless
integration with the Order Management System. The
Product and Service Quality, Safety and Impact Company also develops artificial intelligence and digital
[GRI 416-1] [GRI 416-2] [F.27] [F.29] automation to support decision-making, convergence
Through network convergence, XLSMART is enhancing and personalization, enabling more accurate and
its agility and adaptability to support mobile, home customer-centric product offerings.
internet and enterprise services. By integrating the
network assets of XL Axiata and Smartfren into a unified XLSMART further optimizes parameter settings to
infrastructure of 225,649 BTS stations, the Company support future product development and lifecycle
optimizes spectrum allocation, expands VoLTE maintenance. The internal IT team conducts quality
coverage and improves service stability in high-traffic control for every product-both pre-launch and for those
areas. This strengthened network foundation positions, already in the market. Product assessment are carried
the Company to meet evolving customers needs with out with the following objectives:
broader coverage and superior reliability.
2025 Sustainability Report 157
Page 160
Ensuring Responsible
and Ethical Business
Enterprise Product Catalog
Rationalization Simplification Automation
• Reduce product variants from 17,000 to 12,000 Reduce unnecessary • Reduce turnaround time by 50% from 7 days
• Structure the product portfolio into a maximum of 13 API Interaction to 3 days
product family templates • Implement automated testing
Meanwhile, to anticipate any negative impact resulting In 2025, XLSMART’s products and services were
from its operations, XLSMART has established a evaluated for safety and impact. Based on this review,
dedicated complaint center. As part of its response to the Company recorded:
customer reports, the Company applies the following • No incidents of non-compliance related to health
measures: and safety impacts;
1. Providing prompt responses, for first-level complaint • No violations of customer data privacy policies;
handling and implementing an internal escalation • No product recalls;
system; • No health or safety incidents related to XLSMART’s
2. Conducting regular evaluations; services.
3. Maintaining openness to feedback;
4. Facilitating dialogue and providing compensation These results reflect the Company’s commitment to
when service issues cause inconvenience to delivering safe, secure and high-quality products and
customers. services for customers across Indonesia.
Integrating Sustainability Into
Innovations [F.26] [F.27] [GRI 416-1] [GRI 416-2]
Innovation at XLSMART is designed to create solutions XCamp Labs IoT functions as the Company’s innovation
that are safe, efficient and meaningful for customers hub for prototyping Internet of Things solutions,
and society. Every idea is evaluated not only for its automation tools, and smart connectivity use cases.
technical performance, but also for its environmental, The lab provides a collaborative environment for
social and governance impact. product developers, engineers, and data specialists to
test, refine, and validate ideas before scaling.
Following the 2025 merger, XLSMART continues to
build a stronger innovation ecosystem grounded in At the enterprise level, XLSMART has ESTA (Enterprise
responsibility and purpose. Ideas developed through Smart Technology & Automation) serves as a unified
XCamp Labs IoT and the ESTA platform are assessed digital platform that supports business clients in
for customer value, accessibility, safety and long- improving operational efficiency and cyber resilience.
term environmental impact as part of the Company’s ESTA was formally introduced during the BRAVO 500
sustainability-led approach to innovation. This ensures SUMMIT in July 2025, an industry forum hosted by
each solution from concept to commercialization. In XLSMART that brought around 500 companies, 1,500
this way, innovation becomes more than technology. It executives and more than 30 expert speakers to discuss
becomes a pathway to inclusive, secure, and future- the role of Artificial Intelligence and Cybersecurity
ready progress for Indonesia. across key sectors. These initiatives reflect that
innovation at XLSMART is not only technology-driven,
but also aligned with responsible and secure digital
development.
158 PT XLSMART Telecom Sejahtera Tbk
Page 161
Connecting Indonesia:
One Purpose - One Planet
As XLSMART strengthens its post-merger innovation 3. Credit Control Feature
pipeline, sustainability principles guide product planning XLSMART introduced Credit Control feature to
and solution development. These principles help ensure help prepaid customers protect their balance
that new solutions remain efficient, safe and relevant for from unintended deductions for SMS, subscription
customers. XLSMART is still harmonizing the innovation content, or out-of-plan data usage. This feature
processes of XL Axiata and Smartfren. During this enhances transparency, prevents accidental
transition, sustainability considerations are integrated charges, and supports responsible digital
into planning, testing, and refinement to ensure new consumption.
solutions deliver customer value with responsible
resource use and ethical technology practices. 4. Facial Recognition for SIM Registration
To strengthen customer protection and reduce
Our Innovations in 2025 identity misuse, XLSMART implemented facial
Two flagship innovations demonstrate how recognition for SIM registration, integrated with the
sustainability and innovation move together at national population database. The system enhances
XLSMART: data accuracy while supporting the government’s
digital transformation agenda.
1. Autonomous Drone for Goods Delivery
Developed in collaboration with ASTRAtech, this 5. ESTA-Enterprise Smart Technology & Automation
innovation supports more efficient and safer Through XLSMART for Business, the Company
logistics by reducing dependence on conventional launched ESTA, a unified digital platform that
transport and shortening delivery time, particularly enables secure and efficient enterprise operations.
in remote areas. It aligns with national digital ESTA enhances automation, digital processes
transformation goals and contributes to smarter management, and cybersecurity readiness. The
supply chain operations. platform was introduced during the BRAVO 500
SUMMIT to industry stakeholders representing 500
2. Generative AI-powered “Sarah” companies, 1,500 senior executives, and more than
“Sarah” provides fast, personalized assistance 30 expert speakers.
through digital platforms, helping customers resolve
issues without waiting for manual intervention. The
solution improves accessibility for customers in
remote areas, supports users with limited mobility,
and reduces dependence on physical service
centers.
2025 Sustainability Report 159
Page 162
About
This Report
160 PT XLSMART Telecom Sejahtera Tbk
Page 163
Connecting Indonesia:
One Purpose - One Planet
About
This Report
2025 Sustainability Report 161
Page 164
About
This Report
About This Report [GRI 2-2] [GRI 2-3]
PT XLSMART Telecom Sejahtera Tbk prepares and The Sustainability Report is released as an integrated
publishes a Sustainability Report on a consistent basis component of XLSMART’s Annual Report, which is
as a key communication medium for stakeholders, published as a separate document. The sustainability
presenting the Company’s sustainability performance, reporting period is aligned with the Company’s
commitments, and progress. This report represents the financial reporting period. The report was released in
first full-year sustainability disclosure of XLSMART as 14 April 2026 or within the timeframe stipulated by the
a unified entity following the merger and reflects the Financial Services Authority (OJK) for the submission
integration of sustainability performance, governance, of Sustainability Report. The previous Report was
and data across the combined organisation. The report published in March 3, 2025.
discloses XLSMART’s economic, environmental, social,
and governance (ESG) performance for the period The preparation of this report refers to the following
from 1 January to 31 December 2025, unless otherwise regulatory frameworks and standards:
stated. • OJK Regulation No. 51/POJK.03/2017 on the
Implementation of Sustainable Finance;
The financial information presented in this Sustainability • SEOJK No. 16/SEOJK.04/2021 on the Form and
Report forms part of the consolidated data of the Content of Annual Reports;
Company and its subsidiaries and has been audited by • Global Reporting Initiative (GRI) Standards 2021
an independent Public Accounting Firm in accordance with the “with reference” option.
with applicable auditing standards. Non-financial
information, including policies, programmes, and The content indexes for each applicable framework
environmental and social performance, is presented are presented at the end of this report to enhance
based on clearly defined reporting boundaries, whether traceability, credibility, and transparency of the
covering all entities or specific operational units, as disclosed information.
relevant.
Reporting Principles
To ensure the quality, consistency, and credibility of the disclosed information, this Sustainability Report has been
prepared in accordance with the following principles:
Accuracy Clarity Completeness Timeliness
Comparability Sustainability Verifiability
Balance
Context
These principles guide the determination of report content, scope, measurement methodologies, and presentation,
ensuring that the information fairly, transparently, and comprehensively reflects the Company’s sustainability
performance.
162 PT XLSMART Telecom Sejahtera Tbk
Page 165
Connecting Indonesia:
One Purpose - One Planet
Reporting Scope and Boundaries
The scope of this report covers the sustainability performance of PT XLSMART Telecom Sejahtera Tbk and its
subsidiaries, encompassing economic, environmental, social, and governance aspects. The reporting boundaries
follow the Company’s consolidated structure following the merger, reflecting the integration of entities and operations
within the XLSMART Group, and are aligned with the consolidation applied in the Company’s financial statements,
unless otherwise specified for certain disclosures.
The scope of topics and disclosures is determined based on the results of the Double Materiality Assessment, which
identifies priority sustainability issues according to their financial significance to the Company as well as their
impacts on society and the environment. The assessment serves as the basis for determining the focus area and
depth of reporting in this Sustainability Report. There were no restatements of information in this report. [GRI 2-4]
External Assurance [G.1] [GRI 2-5] [GRI 2-14]
For the current reporting year, the Company did not engage an external assurance provider to independently verify
this Sustainability Report. Nevertheless, internal verification and control processes were implemented to ensure the
accuracy, consistency, and reliability of the disclosed information.
The highest governance body, comprising the Board of Commissioners, the Board of Directors, and the Sustainability
Unit, is responsible for overseeing the accuracy and transparency of sustainability information, including the
validation of material topics and key disclosures. Sustainability data and reporting progress are reviewed on a
quarterly basis through the BRCC and RBCC, with final approval granted in 14 April 2026.
Feedback from Stakeholders [G.3] [GRI 2-26]
XLSMART welcomes feedback and input from stakeholders as part of its commitment to continuous improvement in
sustainability performance and reporting quality. As of the submission of this Sustainability Report, the Company did
not receive any feedback related to the previous year’s report.
For further information or inquiries regarding this Sustainability Report, please contact:
PT XLSMART Telecom Sejahtera Tbk Phone: +622157959817, +62215761880
XLSMART Tower
Jl. H.R Rasuna Said X-5 Kav. 11-12 East Kuningan,
e-mail: corpsec@xlsmart.co.id
Setiabudi, South Jakarta 12950
2025 Sustainability Report 163
Page 166
About
This Report
Feedback From [G.2]
Thank you to you for reading the 2025 Sustainability Report of PT XLSMART Telecom Sejahtera Tbk. To improve the
content of the Sustainability Report in the coming years, we hope that you will be willing to fill out this Feedback Form
by circling one of the answers and filling in the available points.
1. The Sustainability Report is interesting and easy to understand:
a. Agree b. Disagree c. Don’t Know
2. This report already describes the Company’s performance in supporting the realization of sustainable development:
a. Agree b. Disagree c. Don’t Know
3. This report increases your confidence in the sustainability of the Company.
a. Agree b. Disagree c. Don’t Know
4. The materials and data in this Sustainability Report are quite complete.
a. Agree b. Disagree c. Don’t Know
5. Are the designs, layouts, graphics and photographs in this Sustainability Report good?
a. Agree b. Disagree c. Don’t Know
6. What material topics are most important to you?
7. What material topics are least important to you?
8. What information is considered to be lacking from this Sustainability Report and needs to be added to future Sustainability
Reports?
Identity of Sender: Identify by stakeholder category:
a. Shareholder
Name : b. Government/Regulator
c. Community
E-mail : d. Customer
e. Employee
f. Business Partners
g. Mass Media
h. NGO
i. Others, please state .............
164 PT XLSMART Telecom Sejahtera Tbk
Page 167
Connecting Indonesia:
One Purpose - One Planet
GRI Universal Standard Index - 2021
Disclosure Omission GRI Sector
GRI Standard PAGE Requirement Standard
Index No. Titles Reason Explanation Ref. No.
Omitted
GENERAL DISCLOSURES
Organization and Reporting Practices
GRI 2: General 2-1 Organizational details 48
Disclosures 2021 2-2 Entities included in the 162
organization’s sustainability
reporting
2-3 Reporting period, frequency 162
and contact point
2-4 Restatements of information 163
2-5 External assurance 163
Activities and Employees
2-6 Activities, value chain and 48
other business relationships
2-7 Employees 122-126
2-8 Workers who are not 126
employees
Sustainable Governance
2-9 Governance structure and 75
composition
2-10 Nomination and selection of 81
the highest governance body
2-11 Chair of the highest 75
governance body
2-12 Role of the highest 78
governance body in overseeing
the management of impacts
2-13 Delegation of responsibility 78
for managing impacts
2-14 Role of the highest 78
governance body in sustainability
reporting
2-15 Conflicts of interest 87
2-16 Communication of critical 90
concerns
2-17 Collective knowledge of the 83
highest governance body
2-18 Evaluation of the 79
performance of the highest
governance body
2-19 Remuneration policies 82
2-20 Process to determine 82
remuneration
2-21 Annual total compensation 82-83
ratio
Policy Strategies and Implementations
2-22 Statement on sustainable 36, 39-40
development strategy
2-23 Policy commitments 36
2-24 Embedding policy 43-44
commitments
2025 Sustainability Report 165
Page 168
About
This Report
Disclosure Omission GRI Sector
GRI Standard PAGE Requirement Standard
Index No. Titles Reason Explanation Ref. No.
Omitted
2-25 Processes to remediate 90
negative impacts
2-26 Mechanisms for seeking 91
advice and raising concerns
2-27 Compliance with laws and 93
regulations
2-28 Membership associations 65
Stakeholders Engagement
2-29 Approach to stakeholder 89-90
engagement
2-30 Collective bargaining 127
agreements
Material Topics
GRI 3: Material 3-1 Process to determine material 36-37
Topics 2021 topics
3-2 List of material topics 37-38
DISCLOSURE OF SPECIFIC TOPICS
Economic Impacts
Economic performance 201
GRI 3: 3-3 Management of material 110
Management topics
Approach 2021
GRI 201: 201-1 Direct economic value 111
Economic generated and distributed
Performance 201-2 Financial implications and 116-117
2016 other risks and opportunities due
to climate change
201-3 Defined benefit plan 137
obligations and other retirement
plans
201-4 Financial assistance 115
received from government
Market presence 202
GRI 3: 3-3 Management of material 128
Management topics
Approach 2021
GRI 202: Market 202-1 Ratios of standard entry 128
Presence 2016 level wage by gender compared to
local minimum wage
202-2 Proportion of senior 113
management hired from the local
community
Procurement practices 204
GRI 3: 3-3 Management of material 114
Management topics
Approach 2021
GRI 204: 204-1 Proportion of spending on 115
Procurement local suppliers
Practices 2016
166 PT XLSMART Telecom Sejahtera Tbk
Page 169
Connecting Indonesia:
One Purpose - One Planet
Disclosure Omission GRI Sector
GRI Standard PAGE Requirement Standard
Index No. Titles Reason Explanation Ref. No.
Omitted
Anti-corruptions 205
GRI 3: 3-3 Management of material 88
Management topics
Approach 2021
GRI 205: 205-1 Operations assessed for 88
Anti-corruption risks related to corruption
2016 205-2 Communication and 88
training about anti-corruption
policies and procedures
205-3 Confirmed incidents of 88
corruption and actions taken
Environmental Impacts
302 Energy
GRI 3: 3-3 Management of material 98
Management topics
Approach 2021
GRI 302: Energy 302-1 Energy consumption within 99
2016 the organization
302-2 Energy consumption 100
outside of the organization
302-3 Energy intensity 99
302-4 Reduction of energy 99
consumption
302-5 Reductions in energy 99
requirements of products and
services
303 Water and Effluents
GRI 3: 3-3 Management of material 104
Management topics
Approach 2021
GRI 303: Water 303-3: Water Withdrawal 104
and Effluents 303-4: Water Discharge 104
2018
303-3: Water Consumption 104
304 Biodiversity
GRI 3: 3-3 Management of material 105
Management topics
Approach 2021
GRI 304: 304-1: Operational sites owned, 105
Biodiversity 2016 leased, managed in, or adjacent
to, protected areas and areas of
high biodiversity value outside
protected areas
305 Emissions
GRI 3: 3-3 Management of material 100
Management topics
Approach 2021
GRI 305: 305-1 Direct (Scope 1) GHG 100
Emissions 2016 emissions
305-2 Energy indirect (Scope 2) 100
GHG emissions
305-3 Other indirect (Scope 3) 100
GHG emissions
305-4 GHG emissions intensity 100
305-5 Reduction of GHG 100-101
emissions
2025 Sustainability Report 167
Page 170
About
This Report
Disclosure Omission GRI Sector
GRI Standard PAGE Requirement Standard
Index No. Titles Reason Explanation Ref. No.
Omitted
GRI 306: Waste
GRI 3: 3-3 Management of material 101
Management topics
Approach 2021
GRI 306: Waste 306-1: Waste generation and 102
2020 significant waste-related impacts
306-2: Management of significant 101-102
waste-related impacts
306-3: Waste generated 103
306-4: Waste diverted from 103
disposal
306-5: Waste directed to disposal 103
401 Employment
GRI 3: 3-3 Management of material 121
Management topics
Approach 2021
GRI 401: 401-1 New employee hires and 121-122
Employment employee turnover
2016 401-2 Benefits provided to 128
full-time employees that are not
provided to temporary or
part-time employees
401-3 Parental leave 129
403 Occupational health and safety
GRI 3: 3-3 Management of material 132
Management topics
Approach 2021
GRI 403: 403-1 Occupational health and 132
Occupational safety management system
Health and 403-2 Hazard identification, risk 135-136
Safety 2018 assessment, and incident
investigation
403-3 Occupational health 136-137
services
403-4 Worker participation, 133-134
consultation, and communication
on occupational health and safety
403-5 Worker training on 136
occupational health and safety
403-6 Promotion of worker health 136
403-7 Prevention and mitigation 136
of occupational health and safety
impacts directly linked by business
relationships
403-8 Workers covered by an 132
occupational health and safety
management system
403-9 Work-related injuries 136
403-10 Work-related ill health 136
168 PT XLSMART Telecom Sejahtera Tbk
Page 171
Connecting Indonesia:
One Purpose - One Planet
Disclosure Omission GRI Sector
GRI Standard PAGE Requirement Standard
Index No. Titles Reason Explanation Ref. No.
Omitted
404 Training and education
GRI 3: 3-3 Management of material 129
Management topics
Approach 2021
GRI 404: Training 404-1 Average annual training 130
and Education hours per employee
2016 404-2 Programs for upgrading 129-130
employee skills and transition
assistance programs
404-3 Percentage of employees 131
receiving regular performance
and career development reviews
405 Diversity and Equal Opportunity
GRI 3: 3-3 Management of material 122
Management topics
Approach 2021
GRI 405: Diversity 405-1 Diversity of governance 122-123
and Equal bodies and employees
Opportunity 2016 405-2 Ratio of basic salary and 128
remuneration of women to men
406 Non Discrimination
GRI 3: 3-3 Management of material 126
Management topics
Approach 2021
GRI 406: Non 406-1: Incidents of discrimination 126
Discrimination and corrective actions taken
2026
408 Child labor
GRI 3: 3-3 Management of material 126
Management topics
Approach 2021
GRI 408: Child 408-1 Operations and suppliers at 126
Labor 2016 significant risk for incidents of
child labor
409 Forced or compulsory labor
GRI 3: 3-3 Management of material 126
Management topics
Approach 2021
GRI 409: Forced 409-1 Operations and suppliers at 126
or Compulsory significant risk for incidents of
Labor 2016 forced or compulsory labor
413 Local communities
GRI 3: 3-3 Management of material 140
Management topics
Approach 2021
GRI 413: Local 413-1 Operations with local 140-149
Communities community engagement, impact
2016 assessments, and development
programs
413-2 Operations with significant 147
actual and potential negative
impacts on local communities
2025 Sustainability Report 169
Page 172
About
This Report
Disclosure Omission GRI Sector
GRI Standard PAGE Requirement Standard
Index No. Titles Reason Explanation Ref. No.
Omitted
416 Customer health and safety
GRI 3: 3-3 Management of material 157
Management topics
Approach 2021
GRI 416: 416-1 Assessment of the health 157-158
Customer Health and safety impacts of product and
and Safety 2016 service categories
416-2 Incidents of non- 158
compliance concerning the health
and safety impacts of products
and services
417: Marketing and Labeling
GRI 3: 3-3 Management of material 156
Management topics
Approach 2021
GRI 417: 417-1: Requirements for product 156
Marketing and and service information and
Labeling 2016 labeling
417-2: Incidents of non 156
compliance concerning product
and service information and
labeling
417-3: Incidents of non 156
compliance concerning marketing
communications
418 Customer Privacy
GRI 3: 3-3 Management of material 92, 152
Management topics
Approach 2021
GRI 418: 418-1: Substantiated complaints 92
Customer Privacy concerning breaches of customer
2016 privacy and losses of customer
data
170 PT XLSMART Telecom Sejahtera Tbk
Page 173
Connecting Indonesia:
One Purpose - One Planet
POJK 51/2017 Index [OJK G.4]
INDEX NO. INDEX NAME PAGE
SUSTAINABILITY STRATEGY
A.1 Explanation of Sustainability Strategy 36
SUSTAINABILITY PERFORMANCE HIGHLIGHTS
B.1 Economic Performance Highlights 8-9
B.2 Environmental Performance Highlights 10-12
B.3 Social Performance Highlights 13-15
COMPANY PROFILE
C.1 Vision, mission, and value of Sustainability 50-51
C.2 Company’s Address 48
C.3 Scale Enterprises 66-67
C.4 Products, services, and business activities 68-69
C.5 Member of Association 64
C.6 Change of Significant Organization 49
DIRECTORS STATEMENT
D.1 Directors Statement 25-31
SUSTAINABILITY GOVERNANCE
E.1 Management of Sustainable Finance Implementation 84
E.2 Competency Development related to Sustainable Finance 83
E.3 Risk Assessment for Sustainable Finance Implementation 85-86
E.4 Stakeholders Engagement 89-90
E.5 Challenges of Sustainable Financial Implementation 86-87
SUSTAINABILITY PERFORMANCE
F.1 Building A Culture of Sustainability 43-44
ECONOMIC PERFORMANCE
F.2 Comparison of performance Target and Production, Portfolios, Financial Target, or Investment, 112
revenue and Profit and Loss
F.3 Comparison of performance Target and Production, Portfolios, Financial Target, or Investment 112
on Financial Instruments or Projects in line with Sustainable Finance Implementation
ENVIRONMENTAL PERFORMANCE
General
F.4 Environmental Costs 97-98
Material Aspects
F.5 The Use of Environmentally Friendly Materials 103-104
Energy Aspects
F.6 The number and the intensity of energy use 99
F.7 The efforts and achievements made energy efficiency including the use of renewable energy 98-99
sources
Water Aspects
F.8 Water Consumption 104
Biodiversity Aspects
F.9 The impact of operational areas near or in the area of conservation or biodiversity 105-106
F.10 Biodiversity Conservation Efforts 106
Emission Aspects
F.11 The number and intensity of Emissions Produced Base by Type 100
F.12 The efforts and achievement of emission Reduction undertaken 41-43, 100-101
2025 Sustainability Report 171
Page 174
About
This Report
INDEX NO. INDEX NAME PAGE
Aspect of Waste and Effluents
F.13 The Amount of Waste and Effluent Generated by Type 103
F.14 Waste and Effluent Management Mechanism 103
F.15 Spill that Occurred (if any) 105
Aspect of Environmental Complaints
F.16 The number and material environmental complaints received and resolved 107
SOCIAL PERFORMANCE
F.17 The Company’s commitment to deliver products and/or services equivalent to the consumer 152
Employment Aspects
F.18 Equality of Employment Opportunities 120
F.19 Child Labor and Forced Labor 126
F.20 The Minimum Wage 128
F.21 Environmental work decent and safe 122
F.22 Training and Competency Development for Employees 129-131
Community Aspects
F.23 Operational Impacts to Local Communities 140-149
F.24 Public Complaints 147
F.25 Environmental Social Responsibility Activity 140-146
Responsibility on the Development of Sustainable Finance Products and/or Services:
F.26 Innovation and Development of Sustainable Finance products and/or services 158-159
F.27 Customer Safety 157-158
F.28 Impact of Products/Services 157
F.29 The number of products recalled 158
F.30 Survey of customer satisfaction 156
OTHERS
G.1 Written Verification from an Independent Parties (if any) 163
G.2 Feedback Sheet 164
G.3 Response to Previous Year's Report Feedback 163
G.4 POJK 51/2017 Index 171-172
172 PT XLSMART Telecom Sejahtera Tbk
Page 175
Sustainability Report 2025 PT XLSMART Telecom Sejahtera Tbk XLSMART Tower Jl. HR Rasuna Said X5. Kav.11–12, East Kuningan, Setiabudi, South Jakarta Jakarta 12950-Indonesia Tel. (62-21) 576 1881 Fax. (62-21) 576 1880 e-mail. corpsec@xlsmart.co.id www.xlsmart.co.id
Names mentioned 108 people and organisations named in the text · linked when the evidence is strong
unresolved
person
Positions
· Director
p.15
unresolved
org
PT XLSMART Telecom Category
p.18
unresolved
person
Anik Purwanti
p.18
unresolved
org
Ministry of Manpower Occupational Health and Safety Management System
p.19
unresolved
org
Ministry of Women’s Empowerment
p.21
unresolved
org
Ministry of Communication and Digital
p.21
unresolved
org
PTPT XLSMART XLSMART Telecom Telecom Sejahtera Sejahtera Tbk
p.26
unresolved
org
Sejahtera Tbk
p.50
unresolved
person
Rachmat Santoso
p.50
unresolved
org
Minister of NAME
p.50
unresolved
org
PT XL
p.50
unresolved
org
Axiata Tbk
p.50
unresolved
org
State Tbk
p.50
unresolved
org
Axiata Investment (Indonesia
p.50
unresolved
org
PT Global Nusa Data Public
p.50
unresolved
org
PT Huawei Tech Investment
p.50 ×2
unresolved
org
PT Lintas Teknologi Indonesia
p.50
unresolved
org
PT Nokia Solutions
p.50
unresolved
org
Minister of Law
p.51
unresolved
org
PT Graha Metropolitan Lestari
p.54
unresolved
org
PT Excelcomindo Pratama. Driving
p.54
unresolved
org
Indonesia Stock Exchange
p.54 ×2
unresolved
org
Indocel Holding Sdn. Bhd.
p.54
unresolved
org
TM International Sdn. Bhd.
p.54 ×2
unresolved
org
PT Graha
p.56 ×2
unresolved
org
PT Axis
p.56
unresolved
org
Excelcomindo Pratama Tbk
p.56 ×2
unresolved
org
PT XL Planet
p.57
unresolved
org
Global Holdings Pte. Ltd.
p.57
unresolved
org
Ministry of Industry.
p.57
unresolved
org
NTT Ltd.
p.58
unresolved
org
Ministry of Communication and Informatics
p.58
unresolved
org
Minister of Health
p.58
unresolved
person
Prof. Ari Kuncoro
p.58 ×2
unresolved
person
Dr. Astuti Giantini.
p.58
unresolved
org
PT Hipernet Indodata
p.58 ×3
unresolved
org
PP Telecommunication Sdn. Bhd.
p.58
unresolved
org
PT Link Net Tbk’s
p.58
unresolved
org
Ministry of Manpower
p.59
unresolved
org
PT Mobil Anak Bangsa
p.60
unresolved
org
PT Ide Inovatif Bangsa
p.60 ×2
unresolved
org
PT Smart Telecom. This
p.61
unresolved
org
PT ZTE Indonesia
p.61
unresolved
org
PT Gerbangmas Axiata Group
p.64
unresolved
org
PT Prima Mas
p.64
unresolved
org
PT Infinity Tunggal Berhad
p.64
unresolved
org
PT Bali Media
p.64
unresolved
org
PT Wahana Inti
p.64
unresolved
org
PT Princeton
p.64
unresolved
org
PT Hipernet
p.64
unresolved
org
Pte. Ltd.
p.64
unresolved
org
PT Distribusi Telematika
p.64
unresolved
org
Sentra Jaya Indonesia Tbk
p.64
unresolved
org
Data Centres Services Pte. Ltd.
p.64
unresolved
org
PT Data Enkripsi Informasi Teknologi
p.64 ×2
unresolved
org
PT Princeton Digital Group Data Centres
p.65
unresolved
org
Active XL Axiata Singapore Pte. Ltd.
p.65
unresolved
org
Axiata Global Services Pte. Ltd
p.65
unresolved
org
PT Distribusi Sentral Jaya
p.66
unresolved
org
PT Data Enkripsi Informasi Teknologi. Business Scale Description
p.66
unresolved
org
Financial Services Authority
p.75
unresolved
—
Executive
· of the Annual General
p.79
unresolved
—
Oses
· Commercial Officer
p.79
unresolved
—
Muljono
· Enterprise & Strategic
p.79
unresolved
—
Subbramaniam
· Technology Officer
p.79
unresolved
—
Reza Zahid Mirza
· Group Head Corporate
p.86
unresolved
—
Asril Praboe Anom
· Sustainability
p.86
unresolved
person
Non-D, R, T, I,
p.91
unresolved
org
Townhall All Vendors & Partners
p.93
unresolved
org
PT PLN
p.101
unresolved
—
CFO
· Director
p.118
Extraction attempts how the parser did, and what it refused
Nothing structured was extracted from this document — the attempts below say why.
No extraction attempted yet.