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Page 1
           2024
     SUSTAINABILITY REPORT
        PT XL Axiata Tbk




 Leading in Sustainability
DIGITAL CONNECTIVITY
Page 2
          Disclaimer


PT XL Axiata Tbk and/or in this report referred to as “XL Axiata” 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 2024 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 XL Axiata Tbk
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                                                 Leading in Sustainability Digital Connectivity




      About the Theme



Sustainability    issue  is    becoming
stronger, including for technology and
telecommunication companies.

Thus, to support the sustainability commitment, the use of technologies
such as Artificial Intelligence is more optimized, paving way for those
technology and telecommunication companies to contribute to the
achievements of sustainability goals in relation to energy efficiency,
waste management, carbon footprint monitoring, smart building
management, sustainable supply chain, data based sustainability up
to transition into renewable energy. The sustainability commitmet is
continuously nurtured within XL Axiata that holds commitment to
embracing Zero Carbon Emission by 2050. Through synergy with
various partners to develop key initiatives, XL Axiata is on the right track
to accelerate the emission reduction and realize the environmental-
friendly operation as the stakeholders’ expectation. At the same time,
XL Axiata continues to develop the digital ecosystem to provide the
community with the opportunities to capture bigger positive benefits
from the advancement of digital technology in the country. With this
commitment, XL Axiata will pay a bigger role in leading the nation
towards a greener and empowered digital society.




                                                               2024 Sustainability Report         1
Page 4
                                                                                           XL Axiata Sustainability Highlights




Table of Contents



             XL Axiata
             Sustainability
             Highlights
                                             Sustainability
                                             Approach
     6   Creating Values for Stakeholders
     6   Sustainability Performance
    12   2024 Awards and Certificates

                                            28   Sustainability Approach
                                                                                       Process
                                            28   Materiality Assessment
                                                                                       Excellence
                                            28   List of Material Topics
                                            30   Sustainability Commitment of XL
                                                 Axiata
                                            32   XL Axiata’s ESG Roadmap
                                            34   Net Zero Carbon by 2050
                                            35   Initiatives for Sustainable Future   60    Corporate Oversight
                                            36   Building the Culture of              60    Corporate Governance
                                                 Sustainability
                                                                                      60    Committed to the Effective
                                            37   Contributions to the Sustainable           Implementation of GCG Practices
                                                 Development Goals (SDGs)
                                                                                      62    Structure and Composition of
                                                                                            Sustainability Governance
                                                                                      65    Nomination and Selection of
                                                                                            Governance Board
                                                                                      65    The Roles of XL Axiata’s
                                                                                            Governance Body in Impact
             Message from                                                                   Management
             the Board of                    About                                    66    Performance Assessments of the
             Directors                       XL Axiata                                      Governance Body
                                                                                      67    Remuneration Policy and Process
                                                                                      68    Annual Compensation Ratio
                                                                                      68    Management of Conflicts of
                                                                                            Interest
                                                                                      69    Sustainability Training and
    20   Report from the Board of           42   Corporate Information                      Competency Development
         Directors                          43   XL Axiata at a Glance                      Program
    24   Statement of Accountability        44   2024 Sustainability Event            70    Reporting
                                                 Highlights                           70    Stakeholder Relations
                                            48   Vision, Purpose and Core Values      71    Risk Assessment of Sustainability
                                            50   Organization Structure                     Implementation
                                            52   Group’s Structure                    73    Communication of Key Issues
                                            53   Subsidiaries                         73    Constraints, Challenges and
                                            53   Business Scale                             Opportunities of Sustainable
                                            54   Operational Area                           Finance

                                            56   Business Activities
                                            57   Association Membership
                                            57   Significant Changes in the
                                                 Company



2           PT XL Axiata Tbk
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                                                                         Leading in Sustainability Digital Connectivity




74   Business Ethics
74   Code of Conduct
75   Competitive Behaviour
75   Anti-Bribery and Anti-Corruption
     Policy
76   Data Security & Privacy
76   The Implementation of Customer
     Privacy Policy
77   Responsible Labeling and
     Marketing                                                                         About This
77   Labelling and Marketing
                                                                                       Report
77   Legal and Regulatory Compliance



                                                                                    126   Frameworks Applied
                                                                                    127   Scope and Reporting Period
                                                                                    127   Verification
                                                                                    128   GRI Universal Standard
                                                                                          Index - 2021
                                                                                    134   POJK 51/2017 Index
                                                                                    136   Feedback Form
                                                                                    137   Response to Previous Year’s
                                          Nurturing                                       Report Feedback
                                          People




                                        98    Employee Wellbeing
         Planet and                     98    Responsible Employment
         Society                              Practices
                                        106   Workforce Health and Safety
                                        111   Talent Management
                                        114   Impact on Communities
                                        114   Community Development
                                        117   Access and Affordability of our
80   Climate Impacts                          Products and Services
82   Emission & Energy                  117   Sustainable Supply Chain
85   Climate Change                     118   Product and Customer
85   Biodiversity                             Responsibilities
86   Resources Use & Efficiency         118   Customer Experience
86   Pollution                          118   Customer Protection,
86   Circular Economy                         Engagement and Satisfaction
86   Waste and Recycling                118   Protection of Customer Privacy
89   Water and Effluents                119   Product and Service Quality
89   Water Consumption                  119   Digital Leadership
                                        119   Digital Responsibilities, Inclusion
                                              and Rights
                                        123   Sustainable Innovation




         Building
         Prosperity




92   Economic Performance


                                                                                       2024 Sustainability Report         3
Page 6
XL Axiata
Sustainability
Highlights
Page 7
   Receiving Carbon
Disclosure Project
(CDP) certificate
with B score for Two
Consecutive Years
(2023 & 2024)
Page 8
                                              XL Axiata Sustainability Highlights




Creating Values for Stakeholders

XL Axiata’s sustainability footprints are built upon a series of
milestones in its sustainability journey, covering environmental,
social and governance aspects. The Company reaffirmed its
environmental commitments by consistently carrying out its
green investments, one of which was through the purchase of
1,000 Renewable Energy Certificate (REC) units.

At the same time, XL Axiata increase social participation
through the implementation of a number of corporate social
responsibility programs to deliver impactful benefits for the
society.




Sustainability Performance

      The sustainability commitment is continuously
nurtured within XL Axiata that holds commitment to
embracing Zero Carbon Emission by 2050. Through
synergy with various partners to develop key
initiatives, XL Axiata is on the right track to accelerate
the emission reduction and realize the environmental-
friendly operation as the stakeholders’ expectation.



6    PT XL Axiata Tbk
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                                                  Leading in Sustainability Digital Connectivity




Building Prosperity [OJK B.1]
Economic Performance
Production
BTS Tower                               Data Traffic (data production)
(Unit)                                  (Petabyte)

2024                   165,864          2024                                        10,547

2023                 160,124            2023                                      9,638

2022              146,023               2022                              7,991




Sales
Total Revenue                           Net Profit/Loss
(in Rp Billion)                         (in Rp Billion)

2024                   34,392           2024                                      1,847,631

2023                 32,323             2023                      1,284,448

2022              29,142                2022                  1,121,188




                      Number of Customers
                      (in Rp Million)

                      2024                                 58.8

                      2023                                57.52

                      2022                                57.48




                                                                   2024 Sustainability Report      7
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                                                                            XL Axiata Sustainability Highlights




Eco-Friendly Products
Solar Panel                                        Number of Local Workers
Total                                              Person


                  2024                                               2024


                  252                                                1,648
2023              2022                             2023              2022
250               202                              1,480             1,485



Number of Local Suppliers                          Local Supplier Contract Value
Entity                                             in Rp Billion


                  2024                                               2024


                  484                                                15,068.4
2023              2022                             2023                 2022
431               464                              13,554.4             13,708.7




Process Excellence

    Governance                                       Regulatory Compliance
    •    Supporting for SDGs                         •    Committed to the Implementation of
    •    Conducting Anti-Bribery Anti-Corruption          OJK’s Sustainable Finance in accordance
         Training                                         with POJK No. 51/POJK.03/2017 and
    •    Having employees to sign ABAC & GDS              SEOJK No. 16/SEOJK.04/2021 frameworks
         Declaration




                         1,655                                     100%
                         Employees                                 Employees
                         Joined in Anti-Bribery                    Signed ABAC & GDS
                         Anti Corruption                           Declaration
                         Training




8          PT XL Axiata Tbk
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Planet & Society [OJK B.2]

Environmental Performance
Total Water Consumption

                                                  2023
                PDAM
                m3                                7,382.32
                2024


               7,497.46*
                                                  2022

                                                  7,487.13
* A slight increase due to a higher
employee count.​




Non Renewable Energy Consumption*

Solar (Diesel)                                           Solar (Diesel)
Liter                                                    Gigajoule

                  2024                                   2024

                  1,189,149.24                           42,952.07
2023                         2022                        2023                    2022

1,393,829.51                 1,971,499.44                47,668.97               70,973.98



Fuel (Pertalite)                                         Fuel (Pertalite)
Liter                                                    Gigajoule

                  2024                                   2024

                  275,593.70                             9,156.60
2023                         2022                        2023                    2022
228,001.34                   242,090.78                  7,797.65                7,988.99
* In total the energy consumption from fuel and
solar diesel decrease compare to 2023.




                                                                                   2024 Sustainability Report         9
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                                                                                    XL Axiata Sustainability Highlights




     REC (Renewable Energy)

                        KWh 1,000,000.00
                    GigaJoule 3,600.00


 Electricity from PLN                                         Electricity from PLN
 KWh                                                          Gigajoule

                     2024                                     2024

                     956,319,188.94                           3,442,749.08
 2023                       2022                              2023                 2022
 902,853,187.65             840,667,225.92                    3,250,271.48         3,026,402.01

 Total Energy Consumption                                     Energy Intensity
 GigaJoule                                                    Gigajoule/Petabyte
                     2024                                                          2024


                     3,498,457.75*                                                 332
 2023                   2022                                  2023                 2022
 3,305,738              3,105,364.98                          290                  389
 * The increasing energy consumption in line with
 the 4% expansion of the BTS network in 2024.




                    Scope 1 Emission
                    Decreasing by


                             4.07%
 Emissions
 Ton CO2eq

                     Scope 1                        Scope 2                                Scope 3

             2024    4,082.53                       744,398.86                             4,252.47
             2023    4,255.54                       695,828.95                             5,743.82
             2022    5,834.11                       648,260.92                             -

 Total Emissions                                              Emission Intensity
 Ton CO2eq                                                    Ton CO2eq/Petabyte
                     2024                                                          2024


                     752,733.86                                                    71.37
 2023                   2022                                  2023                 2022
 705,828.32             654,095.03                            61.90                81.84




10      PT XL Axiata Tbk
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                                                                                   Leading in Sustainability Digital Connectivity




Nurturing People [OJK B.3]
Social Performance

                                                        Female Employees
                                                        Increasing by


                                                                   10.49%
Number of Employees                              Number of Female                                  Number of Male
Person
                                                 Employees                                         Employees
                                                 Person                                            Person

                 2024                                              2024                                               2024



                 1,663                                             495                                                1,168
2023                  2022                       2023                  2022                        2023                 2022
1,495                 1,501                      448                   443                         1,047                1,058

Number of Female as President                                             Number of local people occupying
Director and Director                                                     senior manager positions
Person/Total                                                              Person

2024              2023               2022                                 2024              2023               2022

2                 2                  2                                    8                 6                  3


           SOCIAL PERFORMANCE                                UNIT                    2024               2023                 2022
 Number of Training Hours                                    Hours                  53,587*)                59,156             76,518
 Number of Employees Receiving Training                      Person                    1,655                 1,502              1,491
 Average number of training hours                         Hours/Person                36.63                 39.38              63.34
 Training Fees                                            Rp in Million               7,449*)               8,314              7,690
 Employee Turnover Rate                                        %                         6.0                   11.1               14.1
 Number of Work Accidents                                    Times                          0                    3                    1
 Occupational death                                          Times                          -                    -                    -
 Total CSR Funds                                          Rp in Billion                35.62                20.73               10.42
 Number of women empowered                                   Person                1,059,479            949,261               57,000
 Number of beneficiaries from Gerakan Donasi                 Person                  66,397               41,900                 N/A
 kuota
 Router/modem donation amount                                 Unit                       214                    71               358
 Quota donation amount                                      Terabyte                251,520             689,397                  N/A
 *) The number of training programs has increased compared to the previous year, with some conducted directly by external partners.




                                                                                                   2024 Sustainability Report             11
Page 14
                                                                        XL Axiata Sustainability Highlights




2024 Awards and Certificates
Awards
                                    Environment



                             XL Axiata received a Carbon Disclosure Project (CDP) certification with B
                             score and C score for water management, thus recognizing its commitment
 Carbon Disclosure Project
                             to environmental transparency and sustainability.
   (CDP) Certification -
    16 February 2024



                             Together with Huawei, and several CSP partners, XL Axiata won the
                             Outstanding Catalyst Contribution to TM Forum Assets Award for
  Outstanding Catalyst       their catalyst project “Intelligence and Value Driven Digital Operation
Contribution to TM Forum     Transformation for Network” in recognition of their significant contributions
     Assets Award -          to the asset value of TM Forum.
      2 March 2024



                             XL Axiata received prestigious awards from Investortrust.id and BGK
                             Foundation for Best Corporate Emission Reduction Transparency (Green)
       Corporate Emission
                             and Best Corporate Emission Calculation Transparency (Gold) in 2024.
     Transparency Awards -
         16 June 2024


                             XL Axiata received at least five awards in various categories from three
                             notable events, namely the HR Asia Awards 2024, the Transparency for
                             Reducing and Calculating Best Corporate Emissions 2024, and the 20 Top
                             Companies to Watch in 2024. At the 2024 HR Asia Awards, XL Axiata
 HR Asia Awards 2024, the    was honored in the Best Workplace to Work for in Asia category, and for
Transparency for Reducing    Diversity, Equity & Inclusion. In the 2024 Best Corporate Emission Reduction
                             and Calculation Transparency event, XL Axiata was recognized for its
   and Calculating Best
                             exceptional transparency in corporate emission reduction transparency
Corporate Emissions 2024,    (Green category) and emission calculation transparency (Gold category)
and the 20 Top Companies     for 2024. At the 20 Top Companies to Watch in 2024 event, XL Axiata
    to Watch in 2024 -       was recognized as one of the top 20 companies by Bloombergtechnoz.
       16 June 2024          com. This award was given due to the promising outlook of EXCL shares
                             this year.




12       PT XL Axiata Tbk
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                                                       Leading in Sustainability Digital Connectivity




                                        Social




Best Women CEO from the    XL Axiata won three awards for its contribution for the society: Best
Women’s Tabloid Awards,    Women CEO from the Women’s Tabloid Awards, Fortune Indonesia Change
                           the World 2023, and Indonesia Most Visionary Companies Awards 2024,
Fortune Indonesia Change
                           demonstrating XL Axiata’s dedication to superior customer service and
  the World 2023, and      social responsibility has earned recognition from various groups.
Indonesia Most Visionary
Companies Awards 2024 -
     23 March 2024



                           This award, initiated by IDN Media, was presented to companies with
                           impactful programs that consistently create opportunities for society, the
Fortune Indonesia Change
                           environment, and their overall performance and reputation.
       the World -
     26 March 2024



                           This award, from Warta Ekonomi, honors companies that create long-term
                           value for all stakeholders through holistic and sustainable approaches to
Indonesia Most Visionary
                           complex challenges.
Companies Awards 2024 -
     26 March 2024



                           XL Axiata, through its Business Solutions unit, won the Marketeers
                           Sustainable Marketing Excellence Award 2024 for its ‘Building a Sustainable
 Sustainable Marketing
                           Future’ program.
Excellence Award 2024 -
      3 June 2024




                           At the Selular Award 2024, XL Axiata’s Sisternet program won ‘Best
                           Women Empowerment Program,” and XL Axiata Business Solutions won
                           “Best Operator for Business,” highlighting the Company’s commitment to
  Selular Award 2024 -
                           innovation and empowerment.
       3 July 2024




                                                                     2024 Sustainability Report         13
Page 16
                                                                         XL Axiata Sustainability Highlights




Awards
                                           Social


                              XL Axiata was recognized with the HR Excellence Award 2024 by SWA
                              Media Group and LMFEB UI for its outstanding and sustainable human
HR Excellence Award 2024      resources management.
     - 24 July 2024


                              XL Axiata received appreciation for its achievements and performance
                              by successfully winning the best award in two categories at the 2024
                              Selular Awards. Hosted by Selular.id, XL Axiata excelled in the categories
                              of Best Women Empowerment Program and Best Operator for Business.
                              Additionally, Mix Magazine presented the Indonesia CorpComm Dream
                              Team journalist choice award. XL Axiata obtained the Best Operator for
                              Business title, underscoring its achievement in developing and delivering
                              services that cater to the solutions of business professionals. In the Best
     2024 Selular Awards -
                              Women Empowerment Program category, XL Axiata’s success is attributed
         4 July 2024          to the Sisternet initiative, aimed at enhancing women’s empowerment.
                              Meanwhile, at the “Indonesia MarComm & CorComm Dream Team 2024”
                              event, XL Axiata’s Corporate Communications team achieved the “Very
                              Good” title in the Journalist’s Choice category in the telecommunications
                              industry.


                              XL Axiata successfully won three Sustainability awards at the 2024 ESG
                              Initiatives Awards. The categories won include “Best Social Impact and
                              Human Rights”, “Best Millennial and Gen Z Engagement Leadership”, and
     ESG Initiatives Awards   the “Best Leader for ESG Initiatives” award, which was presented to Reza
     2024 - 8 August 2024     Zahid Mirza, Group Head of Corporate Communications & Sustainability.


                              XL Axiata received recognition for its business performance by winning
                              an award at the prestigious 2024 Fortune Indonesia 100 Gala. The event,
                              organized by Fortune Indonesia magazine, honored the 100 largest
 2024 Fortune Indonesia       companies in Indonesia based on revenue. XL Axiata successfully secured
        100 Gala -            a spot on the Fortune Indonesia 100 list, further solidifying its position as
   17 September 2024          one of the key players in the country’s telecommunications industry.


                              Two employees from PT XL Axiata Tbk (XL Axiata), Chief Enterprise &
                              Business Officer Feby Sallyanto and Sisternet Program Owner Adelia
                              Panjaitan, were honored with Satyalancana Wira Karya Honorary Award.
                              This accolade reflects their outstanding dedication and contributions, not
 Satyalancana Wira Karya      only to XL Axiata but also to the advancement of the telecommunications
    Honorary Award -          sector in Indonesia, highlighting the Company’s commitment to empowering
   27 September 2024          Indonesian women through our #JadiLebihBaik initiative. XL Axiata was
                              the only company to receive two Satyalancana awards this year.




14       PT XL Axiata Tbk
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                                                        Leading in Sustainability Digital Connectivity




                                   Governance


                           XL Axiata’s Corporate Secretary Division received the ‘Very Good’ rating
  Corporate Secretary      in the Corporate Secretary Champions 2024 by SWA Media Group,
 Champion Award from       recognizing their excellent performance in adapting to a fast-changing era.
    SWA Magazine -
     4 April 2024



                           XL Axiata won two prestigious awards at the HR Asia Awards 2024: “Best
                           Workplace to Work For in Asia” and the ‘Diversity, Equity & Inclusion Award”,
 HR Asia Awards 2024 -     highlighting its commitment to an inclusive and diverse work environment.
     31 May 2024



                           XL Axiata won the top “Sapphire” award at the Indonesia Regulatory
                           Compliance Awards (IRCA) 2024 by Hukumonline, recognizing its
  Indonesia Regulatory
                           dedication to corporate legal compliance.
Compliance Awards (IRCA)
     - 2 June 2024


                           XL Axiata won two awards at the Spex2 Awards 2024: “The Best Execution
                           Winner in the Telecommunication Industry” and “Outstanding Achievement
                           in Sustainability & Governance”, showcasing its commitment to ESG and
    Spex2 Awards -
                           sustainability initiatives.
    2 August 2024




                                                                      2024 Sustainability Report         15
Page 18
                                                                                 XL Axiata Sustainability Highlights




Certifications



                  Certificates                           Validity                                 Issuers

ISO 9001:2015 Quality Management
                                                      5 January 2027              British Standards Institute
System (Recertification)
ISO 20000-1:2018 IT Service Management
                                                     14 January 2027              British Standards Institute
System (Recertification)
Sustainalytics
                                              1 Year (April 2024 – April 2025)    Morningstar Sustainalytics
(Medium Risk score at 27,8)
ISO 22301:2019 Business Continuity
                                                    11 December 2024              British Standards Institute
Management System (Surveillance)
ISO 14001:2015 Environmental
                                                    1 September 2025              British Standards Institute
Management System (Surveillance)
ISO 45001:2018 Occupational Health and
                                                    1 September 2025              British Standards Institute
Safety Management System (Surveillance)
ISO 27001:2013 Information Security
                                                    25 November 2026              British Standards Institute
Management System (Resertifikasi)
Occupational Health and Safety
                                                     December 2026                Ministry of Manpower
Management System
Contractor Safety Management System
                                                       March 2024                 Eni Muara Bakau
High Risk Project
Contractor Safety Management System
                                                     September 2025               PT Pertamina Persero
High Risk Project
                                                                                  International             Compliance
ICA Certificate in Compliance                                -
                                                                                  Association
Business Continuity Management                                                    National Professional Certification
                                                     30 August 2025
Professional                                                                      Agency
                                                                                  Certified Information Systems
Certified Information Systems Auditor                31 January 2023
                                                                                  Auditor – An ISACA Certification
                                                                                  National Professional Certification
Certified Risk Management Practices                  30 August 2025
                                                                                  Agency
Sustainalytics
                                              1 Year (April 2024 – April 2025)    Morningstar Sustainalytics
(Medium Risk score at 28,3)
ESG Disclosure Transparency Awards
                                                          1 Year                  Investor Trust
2023 (Predikat Commitment)

Corporate Social Responsibility of the Year               1 Year                  Marketeers


Corporate Social Responsibility Award                     1 Year                  Pamekasan Regency Municipality




16      PT XL Axiata Tbk
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                                           Leading in Sustainability Digital Connectivity




XL Axiata BTS located in Rawa Pening, Jakarta, where the Company carried out a shelter
                                         simplification initiative to reduce energy usage




                                                         2024 Sustainability Report         17
Page 20
Message from
the Board of
Directors
Page 21
     XL Axiata’s continuous
commitment to enhancing
customer experience remains a
strategic priority as emphasized
in the Double Materiality
Assessment. A seamless,
engaging customer journey
fosters loyalty and builds trust,
contributing to long-term brand
relationships.
Page 22
                                                                                       Message from the Board of Directors




Report from
the Board of Directors
Dear respected stakeholders, [OJK D.1]                            Toward the sustainability goals set for each pillar, the
                                                                  Company has made the following commitments:
Sustainability continues to be the core consideration in          - Building Prosperity: To promote economic growth
boardrooms around the world. Driven by high stakeholder              through the development of digital infrastructure
expectations and the widening impacts of sustainability,             and the enhancement of digital literacy. This supports
leaders agree on their shared responsibility for addressing          national development while ensuring the Company
sustainability issues, including climate change concerns, and        continues to contribute to societal welfare;
focus on the necessity of creating both immediate and more        - Nurturing People: To put human capital development
impactful actions.                                                   as a top priority, both for its employees and within the
                                                                     communities it serves. This includes offering educational
In XL Axiata, we have a strong adherence to Environmental,           programs, skill-building initiatives, and leadership
Social and Governance (ESG) principles by aligning strategic         development;
policies with sustainable development goals. The Company          - Process Excellence: To focus on continuous operational
continues to seek a balance between profitability and positive       improvement by adopting innovative technologies,
impacts on the environment, society and governance, thus             optimizing business processes, and upholding strong
representing our relentless efforts to deliver lasting value to      corporate governance. These efforts ensure long-term
both shareholders and stakeholders.                                  sustainability while delivering value to stakeholders;
                                                                  - Planet and Society: To reduce its environmental
XL Axiata believes that its success rests on the trust built         footprint towards the net-zero emission goal by 2050.
between the Company and the customers, business partners,            This includes energy efficiency initiatives, the use of
shareholders and communities within which it operates. The           renewable energy, and effective waste management,
foundation for this trust lies in our commitment to doing            keeping environmental responsibility central to its long-
business responsibly and ethically, every day. The Company           term goals.
consistently strives to promote a culture of integrity,
implement effective controls, and conduct appropriate due         Key Sustainability Achievements [OJK D.1.b]
diligence to detect and mitigate any risks to the business        We integrate these sustainability pillars into every
continuity.                                                       aspect of XL Axiata’s operations to ensure the Company
                                                                  thrives economically while positively contributing
Strategies to Address Sustainability Challenges [OJK              to the environment and society. In 2024, XL Axiata
D.1.a]                                                            successfully recorded a number of key achievements
Referring to the results of XL Axiata Double Materiality          across its sustainability pillars.
Assessment, the Company was able to identify and
prioritize 12 key ESG topics relating to Climate Impact, Data     Despite macroeconomic challenges indicated by food
Security and Privacy, Customer Experience and Employee            inflation, currency depreciation and job losses, and the
Wellbeing. The assessment also helped XL Axiata to achieve        increasingly competitive landscape, XL Axiata remained
critical milestones in its sustainability journey throughout      committed to sustaining the momentum of profitable
2024, driven by the alignment of strategic initiatives            growth in both the mobile and fixed segments. Financially,
and its overarching sustainability strategies. XL Axiata’s        the Company’s efforts on profitability led it to achieve a
set of comprehensive sustainability strategies define its         6.4% increase in revenue, 45.5% increase in net income and
contributions to economic sustainability and social welfare       expand the net income margin by 5.6 percentage points.
as well as its stance on climate action, its future position,     In addition, the cost leadership initiatives throughout its
prospects and prosperity. The Company’s sustainability            operations have positioned the Company as an industry
approaches are supported by innovation and lots of initiatives    leader with an EBITDA margin of 51.9%.
surrounding its 4P Pillars, i.e. Building Prosperity, Nurturing
People, Process Excellence and Planet and Society. These          The Company continued to grow the mobile subscriber
pillars aim to create a balanced, responsible and sustainable     base to 58.6 million with a healthy ARPU of Rp43,000,
business by addressing its economic, environmental and            representing a 5% yoy increase. Our postpaid offerings
social responsibilities.                                          have been established as the #1 customer choice, as
                                                                  evidenced by NPS data for the postpaid segment. Improved
                                                                  performances also occurred in XL Axiata Own Apps (MyXL
                                                                  and AXISnet) which booked 32.2 million users and increased
                                                                  by 5.0 percentage points in revenue.



20        PT XL Axiata Tbk
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                             Leading in Sustainability Digital Connectivity




     Network expansion
is being pursued
relentlessly, with XL
Axiata’s 4G network now
encompassing 165,864 4G
BTS units and counting.
This quality-lifting
investment is instrumental
in improving service
reliability and customer
satisfaction.




DIAN SISWARINI
President Director



                                           2024 Sustainability Report         21
Page 24
                                                                                       Message from the Board of Directors




In addition, the Company’s vision of becoming the “Leading        profit after business incubation. By empowering more
Converged Operator” continues to yield positive outcomes.         than one million women business owners and potential
The FMC penetration rate was 83% (as per YTD 9M’24)               entrepreneurs as of the end of 2024 by building digital
and FFB subscribers reached 1 million, positioning it as          literacy, the Sisternet program goes hand-in-hand with XL
the second largest fixed broadband operator in Indonesia.         Axiata’s development of digital infrastructure, supporting
According to Opensignal’s December 2024 Report on FBB             the country’s economic growth and contributing to a more
Experience in Indonesia, XL Axiata was the #1 operator            resilient and empowered society. Sisternet beneficiaries
in Consistent Network Quality with a score of 67.6%. This         themselves are spread across 19 cities in Indonesia.
demonstrates XL Axiata’s unwavering commitment to
preserving an exceptional customer experience and marks           The Company also demonstrated its unwavering
another milestone on its sustainability journey.                  commitment to equality and diversity in the workplace
                                                                  through the launch of XL Axiata’s Peduli Disabilitas Siap
XL Axiata’s continuous commitment to enhancing customer           Kerja (Disability Ready for Work) program. This initiative
experience remains a strategic priority due to the Double         allowed the Company to provide education and training
Materiality Assessment. A seamless, engaging customer             for more than 100 people with disabilities, several of whom
journey fosters loyalty and builds trust, contributing to long-   have now joined the Company as interns.
term brand relationships. We plan to promote more digital
literacy and ensure a safe digital environment for users.         The Company also updated several key governance
This initiative aligns with responsible business practices and    documents, including the Board Manual, Financial Limit
empowers customers to make informed decisions.                    of Authority, Work Guidelines for the Risk and Business
                                                                  Sustainability Committee, Document Management System
At the same time, XL Axiata continues to make progress            Policy, Corporate Risk Management Policy, Privacy Policy,
on its environmental commitments. The Company was                 Business Continuity Management Procedures, and others.
recognized with a Carbon Disclosure Project (CDP) –               We believe these efforts have helped the Company to
B Rating in two consecutive years, which represented              improve the quality of GCG enforcement in every aspect.
our commitment to environmental transparency and
sustainability efforts. In addition, as part of XL Axiata’s       This year the Company reinforced its commitment to
Decarbonization agenda, the Company this year realized            safeguarding personal data by earning the ISO 27701:2019
the purchase of 1,000 Renewable Energy Certificate (REC)          Privacy Information Management System (PIMS) certification,
units from PLN, reflecting our commitment to increasing the       the first telco in Indonesia to do so. The Company is also
electricity consumption from the renewable energy source.         proud to be the only telco in Indonesia to hold both CDP
                                                                  and EcoVadis ratings alongside its participation in S&P
In addition, XL Axiata’s waste management strategies in           Global’s Corporate Sustainability Assessment (CSA). These
2024 included the implementation of Sustainability Week,          frameworks serve as a benchmark for the continuous
during which the Company launched a commitment to                 improvement across the Company’s internal processes,
Zero Waste to Landfill—a tangible step toward supporting          strengthening the commitment to fully integrating
environmental sustainability and reducing its carbon              sustainability into XL Axiata core operations.
footprint. To promote sustainable behavior among
employees, the Waste Management Race was launched at              The Company’s commitment to good corporate governance
XL Axiata Head Office.                                            was recognized with two awards at the 15th IICD Corporate
                                                                  Governance Awards 2024: Top 50 Big Capitalization Public
Moreover, through the Smart Cities initiative, for example,       Listed Company, an accolade the Company has received
XL Axiata collaborated with local governments to provide          for six consecutive years, and Best Rights and Equitable
smart street lighting, making cities safer and more efficient     Treatment of Shareholders. Furthermore, the Company
in electricity consumption.                                       earned the ISO 37001:2016 Anti-Bribery Management
                                                                  System (ABMS) certification, underscoring its dedication to
On the social front, the Company continued to drive its           implementing good corporate governance and preventing
Corporate Social Responsibility (CSR) programs, such as           bribery and corruption across all business operations.
Sisternet and Gerakan Donasi Kuota, while strengthening
its Diversity, Equity, and Inclusion (DEI) efforts. In 2024, XL
Axiata reached 1.2 million beneficiaries in total from all CSR
programs (Sisternet, Gerakan Donasi Kuota, Pesantren Digital,
etc). The Sisternet program, aimed at improving societal
well-being and empowering individuals, has helped increase
the productivity of MSMEs operated by the Sisterpreneurs
by up to 78% and contributed to a 43% increase in gross




22        PT XL Axiata Tbk
Page 25
                                                                               Leading in Sustainability Digital Connectivity




Strategies to Achieve the Targets [OJK D.1.c]                          the trial for Biometric Pre-paid SIM Card Registration,
Our primary focus for 2024 was directed toward achieving               showing the Company’s commitment to continuous
profitable growth to bring sustainable dividends for our               adaption to technological advancements. The Company
shareholders. To realize this objective, the management                continued to make innovations by leveraging the latest
implemented strategic initiatives aimed at guiding it in               technologies to deliver the best possible experience for
meeting its sustainability goals. Built around XL Axiata’s 4P          our customers. These innovations are expected to provide
Pillars, the strategic initiatives to drive growth included:           convenience, security, speed, and help reduce the potential
• Completing the acquisition of First Media’s customer                 for data forgery or duplicate identities.
     base to solidify our position as the second-leading
     convergence player in the market. XL Axiata                       Closing Remarks
     is committed to delivering complete, seamless                     To conclude this report, We, the Board of Directors, would
     connectivity, entertainment, and mobile propositions to           like to extend our gratitude to all stakeholders, both internal
     all telecommunication consumers;                                  and external, for their relentless support towards XL Axiata’s
• Expanding its homepass coverage to reach more than                   sustainability goals. Despite the inevitable challenges, 2024
     6 million. We wet this objective by aligning XL Axiata’s          remained an excellent year for XL Axiata. We value every
     excellence through a strategic partnership with Link              input and piece of advice that has led XL Axiata to sustain
     Net, which allowed us to extend our reach to a broader            the momentum of growth on some of its key financial and
     customer base;                                                    operational indicators.
• Expanding the Enterprise business to capture
     international and global traffic by acquiring Axiata Global       The Company’s focus in 2025 will remain on driving profitable
     Services. This acquisition strengthens our position in            growth, fostering innovation, and enhancing customer
     the global market and enhances our capabilities to                experience. The Company will also remain committed to
     serve the growing demands of international enterprise             supporting Indonesia’s connectivity goals and be at the
     connectivity;                                                     forefront of helping to enhance the digital ecosystem in
• Consistently introducing better pricing to the mobile                Indonesia.
     market by implementing strategic measures aimed
     at enhancing pricing strategies, leveraging AI-driven             The Company has set ourselves the ultimate goal of creating
     regional and dynamic pricing;                                     long-term value that will benefit our shareholders and
• Carrying out network optimization to enhance                         stakeholders, and welcomes everyone on board to make
     profitability and resilience and realizing the full potential     valuable contributions toward this goal.
     of AI technology across business processes, product
     personalization and marketing activities to drive                 Going forward, following the merger between XL Axiata, PT
     efficiency and competitiveness.                                   Smartfren Telecom Tbk and PT Smart Telcom, which became
                                                                       definitive as of December 2024, We expect to establish
At the same time, the Company upheld its commitment to                 greater value for both internal and external stakeholders,
cost leadership and careful, strategic investments without             paving the way for a more thriving and sustainable future.
compromising the quality of products and services We
delivered to the customers. This year XL Axiata completed




                                                            Sincerely yours,




                                                            Dian Siswarini
                                                          President Director




                                                                                               2024 Sustainability Report          23
Page 26
                                                                                     Message from the Board of Directors




Statement of Accountability

Statement of Accountability of 2024
                               2024 Sustainability
                                    Sustainability
Report by
        by the
           the Board
               Boardof
                     ofCommissioners
                        Commissioners and Board
and Board of Directors
of Directors
We, the signatories, hereby stated that all information contained in the 2024 Sustainability Report of PT XL Axiata Tbk has
been comprehensively presented and that we are fully accountable for the accuracy of the content of PT XL Axiata Tbk Annual
Report.

This statement is made thruthfully.

                                                             Maret 2025
                                                  Jakarta, 3 March 2025

                                         Board of Commissioners




                                               Dr. Muhamad Chatib Basri
                                                President Commissioner




             Vivek Sood                          Dr. Hans Wijayasuriya                         Nik Rizal Kamil
            Commissioner                              Commissioner                              Commissioner




           Julianto Sidarto                      Didi Syafruddin Yahya                   Yasmin Binti Aladad Khan
      Independent Commissioner                 Independent Commissioner                  Independent Commissioner




24       PT XL Axiata Tbk
Page 27
                                            Leading in Sustainability Digital Connectivity




                    BoardDireksi
                          of Directors




                        Dian Siswarini
                       Presiden Direktur
                       President Director




 Feiruz Ikhwan        David Arcelus Oses                          Abhijit Navalekar
    Direktur
    Director               Direktur
                           Director                                    Direktur
                                                                       Director




Yessie D. Yosetya     I Gede Darmayusa                          Rico Usthavia Frans
     Direktur
     Director              Direktur
                           Director                                   Direktur
                                                                      Director




                                                        2024
                                                         2024Laporan  Keberlanjutan
                                                               Sustainability Report         25
Page 28
Sustainability
Approach
Page 29
   Implementing a double
materiality assessment to
enhance the identification
of key stakeholders and the
material topics.
Page 30
                                                                                                     Sustainability Aproach




Sustainability Approach
[OJK A.1] [GRI 2-22] [GRI 2-23]



Pursuant to the results of the double materiality assessments, XL Axiata has implemented a Sustainability Approach that
balanced the Company’s environmental, economic, social and governance performance. In addition, the Company closely
monitors the climate-change regulatory developments to ensure that the Company’s environmental responsibilities are fulfilled
across its operations.




Materiality Assessment [GRI 3-1] [GRI 3-2]

XL Axiata applies the double materiality assessment to help      engagement methods with XL Axiata’s external stakeholders,
identify key stakeholders and determine the material topics      including government/regulators, investors/shareholders,
encompassing the environmental, social and governance            industry bodies, peers, customers, partners/MSMEs, banks/
aspects. By applying the double materiality assessments,         lenders as well suppliers, consisted of monitoring, surveys,
the Company is expected to be able to mitigate risks,            consulting, interviews, and collaborating activities. The
improve stakeholder relationships and enhance business           Company engaged top vendors and ESG Warriors in a
strategy of the Company.                                         direct survey as part of the consulting activity.


In 2024, XL Axiata engaged an external independent party         Based on the results on the assessment of the importance, the
to conduct a materiality assessment with the aim at ensuring     Company received various responses from the employees,
the Company to be able to evaluate each sustainability           customers, the suppliers, and the business partners. The
matter from both financial and impact perspectives, thus         results of stakeholder engagement that was conducted in
offering a comprehensive view of sustainability risks and        two stages of assessment concluded the topics that were
opportunities.                                                   material to the Company. The determination of material
                                                                 topics is known and approved by the Board of Directors
Accordingly, the Company engaged both internal and               [GRI 2-14].
external stakeholders to help determine the sustainability-
related topics that were material to the Company. Internally,
the Company engaged members of Board of Directors,
Group Heads, and CDP Data Owners through consulting
and collaborating activities, including surveys, interviews,
and workshop, to gain their strategic perspectives and align
them with long-term goals of the Company. Meanwhile, the




         The Company engaged both internal and
     external stakeholders to help determine the
     sustainability related topics that were material to
     the Company.




28       PT XL Axiata Tbk
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                                                                                                  Leading in Sustainability Digital Connectivity




   List of Material Topics [GRI 3-2]

   The Company has concluded the material topics encompassing aspects of Environmental, Social and Governance. The
   Company further assessed the material topics through an internal workshop to determine topics priorities by rating the severity
   and likelihood of risks associated with the impacts & financial implications of each material topic. The risk rating is described
   in the following matrix:


   XL Axiata ESG Materiality Matrix

                     25                                                                                             Table of Risk Rating

                                                                                                                    Risk Rating
                                                                                                                         Extreme (25)

                     20                                                                                                  Significant (21-24)

                                                                                                                         High (14-20)

                                                                                                                         Moderate (6–13)

                     15                                                                                                  Low (1-5)
Impact Materiality




                                                                         Data Security
                                                           Business          & Privacy
                                                             Ethics

                                                                                    Sustainable
                                               Climate              Economic
                                                                                   Supply Chain
                                               Impact            Performance
                     10
                                 Resource Use
                                  & Efficiency

                                                                                   Employee
                                                               Corporate Digital   Wellbeing
                                               Impact on             Oversight
                      5
                                             Communities            Leadership

                          Biodiversity




                     0                   5                10                15            20              25

                                                         Financial Materiality




                                                                                                                2024 Sustainability Report         29
Page 32
                                                                                                      Sustainability Aproach




Sustainability Commitment of XL Axiata [GRI 2-22]

It is imperative for XL Axiata to carry out a responsible       XL Axiata continues to nurture and socialize the above
business operation as part of its support to the United         mentioned sustainability approach to employees and parties
(UN) Sustainable Development Goals (SDGs). XL Axiata            that have direct relation with the company’s supply chain so
has aligned its business strategies with the goals and is       as to improve their understanding and the implementation.
committed to making progress on environmental, social and       The socialization activities include training on topics relating
governance practices which are believed to create impactful     to the sustainability principles, in which the Company takes
benefits to its stakeholders in the telecommunications          participation from parties responsible for the implementation
industry and beyond.                                            of sustainability policies. Meanwhile, the vendors engaging
                                                                in the Company’s supply chain are required to comply
Then to drive progress towards Net Zero goals, the Company      with all applicable laws and regulations and adhere to the
has taken numerous initiatives encompassing carbon              highest ethical standards in the procurement process of
footprint reduction strategies. The Company initiated           goods/services. To ensure the fulfillment of sustainability
energy-efficiency measures throughout the operations to         principles across its business chain, XL Axiata is committed
make a significant contribution to the climate change action.   to conducting business with Zero Tolerance Policy against all
XL Axiata always keeps monitoring the emission resulted         forms of bribery and corruption, and expects the suppliers to
from its operations and the possibility of negative impacts     have such commitment as well. Suppliers are also required to
from its operations so as to ensure that the Company has        avoid child labor and forced labor practices at all operational
established a sustainable supply chain throughout its digital   areas. [GRI 2-24]
ecosystem.
                                                                Sustainability Policy of XL Axiata
XL Axiata has also established sustainable supply chain         XL Axiata’s sustainability policy is built around 4P
practices, in which the Company encourages transparency         pillars, i.e. Building Prosperity, Nurturing People, Process
and responsible practices throughout the supply chain,          Excellence, and Planet and Society. The goals of XL Axiata’s
promote human and labor rights without discriminatory           Sustainability Policy are to develop an innovative digital
practices as well as promote gender equality and diversity.     ecosystem that can close the digital gap with respect to
The Company continued to develop a diverse and                  economic, environmental, social and governance aspects. In
inclusive workplace culture by treating and providing equal     implementing the Sustainability Policy, XL Axiata refers to
opportunities for everyone.                                     an integrated environmental management policy outlined in
                                                                POL - FIN-002 HSE Policy.

                       XL Axiata Sustainability Pillars


                       BUILDING PROSPERITY

                       XL Axiata contributes to the welfare of the nation by building the economy and striving to
                       improve people’s lives.



                       NURTURING PEOPLE

                       Not only encouraging Indonesia’s progress through digital infrastructure development, XL
                       Axiata is also committed to building human resources in the digital era.



                       PROCESS EXCELLENCE

                       Good governance practices in every operational activity support XL Axiata to become a
                       strong company that continues to grow.


                       PLANET AND SOCIETY

                       XL Axiata always carries out strategies and operational activities that favor the
                       environment and society as two things that contribute to business growth.



30       PT XL Axiata Tbk
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                                                                               Leading in Sustainability Digital Connectivity




XL Axiata’s Sustainability Policy guides the Company in every aspect that leads us to the establishment of a sustainable
organization that transforms lives of the customers and brings meaningful impacts to the society. The policy reflects XL
Axiata’s dedication to environmental stewardship, social responsibility and economic viability of our operations, and the
respect for human rights.


The sustainability policy also becomes the essential guidance in establishing the Company’s sustainability strategies for the
current financial year and beyond. With ESG issues increasingly significant, XL Axiata has set ESG strategy for the 2022-2025.
The ESG strategy for 2022-2025 outlines three initiatives for each component of ESG, they are:




         ENVIRONMENT                                SOCIAL                                     GOVERNANCE
         Accelerating energy                        Promoting inclusive                        Strengthening
         efficiency and                             stakeholder                                good governance
         implementing the                           engagement.                                practices
         use of renewable and                                                                  to increase
         clean energy to reduce                                                                accountability.
         carbon emissions by
         45% by 2030.




An XL Sustainability Committee has been established to ensure that the Company continued to make progress on ESG
management. In 2024, the efforts in ESG management were rewarding as XL Axiata gained the certification of Carbon
Disclosure Project (CDP) with B score for the second year. The certification is to recognize the Company’s commitment to
implementing environmental transparency and sustainability practices.


Some initiatives supporting our achievements in ESG management included a concrete action to make the incentivization of carbon
emission for Scope 1, 2 and 3 which would serve as the baseline for carbon footprint reduction. Since 2018, the Company has calculated
carbon emissions for Scope 1 and 2 and has begun calculating the carbon emission Scope 3 for several categories as of 2023.




      XL Axiata’s Sustainability Policy guides it in
  every aspect that leads us to the establishment of
  a sustainable organization that transforms lives of
  the customers and brings meaningful impacts to
  the society.




                                                                                              2024 Sustainability Report           31
Page 34
                                                                                                                      Sustainability Aproach




XL Axiata’s ESG Roadmap


                   Environment
                   Accelerate energy efficiency efforts and adopt clean
                   and renewable energy

      Plan Focus                        2024                          Realization in 2024                                  2025

Climate Action             Site Plan:                           -   Installation of solar panels in 252   Site Plan:
- Renewable and clean      - Verify Scope 1, 2, and 3               Base Transceiver Station (BTS)        - Verify Scope 1, 2, and 3 emissions
   energies                   emissions                             locations across Indonesia to         - Purchase renewable energy to
- Energy efficiency        - Scope 3: Adding inventory              support      the     Green      BTS      support the network activities
                              GHG emission sources                  Campaign.                             - Start to implement the electronic
Energy and Emission        - Purchase renewable energy          -   Purchasing 1,000 units of                waste management
(Green Gas House/GHG)         to support our network                Renewable Energy Certificate
Management                    activities                            from PLN.                             Target:
- GHG inventory scope 1,   - Energy efficiency by piloting      -   Starting to implement waste           - GHG emission is verified by third
   2, and 3                   energy saving initiatives with        management in XL Axiata Tower.           party verificatory
- Obtainment of               partners                              Managing 1.23 tonnes of waste.        - Purchasing new source of
   environmental-based                                          -   Launching zero-waste-to landfill         renewable energy
   certification           Target:                                  on 28th Anniversary Event in
                           - GHG emission is verified by            October.
Environmental                 third party verificatory
Management                 - Purchasing renewable energy
- Water usage data            source (REC)
   monitoring
- Water efficiency
   consumption
- Inventory waste data
   and improve Reduce,
   Reuse, and Recycle
   (3R) actions




                   Social
                   Advance social empowerment through a digitally advancement
                   of inclusive social approach

      Plan Focus                        2024                          Realization in 2024                                  2025

Community                  Site Plan:                           -   Engaged over 1 million members        -   Growing Sisternet user base and
Development                - Improving        impact     for        in the Sisternet community.               expanded its impact within the
- Community partnership       beneficiaries in relation with    -   Launched Gerakan Donasi Kuota             women’s             empowerment
- Social empowerment          SDGs values                           (GDK), reaching 214 educational           ecosystem.
  impact                   - Obtaining     validation   and         institutions and providing digital    -   Expanding GDK beneficiaries and
                              scoring impact for social             literacy training for teachers and        Kelas Cerdas Digital participants
Digitization and              programs                              students in three cities.                 to enhance digital education in
Innovation                 - Advancing digital inclusion        -   Provided         logistics     and        Indonesia.
- Digitalization for          solution & collaboration with         telecommunication aid to over         -   Broadening donation categories
   society in need            partners acsross industry             2,700 disaster victims.                   in myXL and AXISNET to include
- Program innovation in                                         -   Raised       stroke      prevention       universities, communities, and
   relation to support     Target:                                  awareness         through       the       non-formal education.
   society well-being      - Sisternet to achieve 1 million         JAGATARA smartwatch.                  -   Strengthening      disaster    relief
                              users                             -   Empowered 2,600+ Pesantren                efforts by providing logistics and
                           - Enhancing       impact      and        students with IoT and digital             telecommunication aid in support
                              number      of    beneficiaries       literacy for economic growth.             of government initiatives.
                              through capabilities and skills                                             -   Continuing innovation in health
                              development                                                                     technology through JAGATARA
                           - Achieving a good SROI (Social                                                    to aid stroke prevention and
                              Return on Investment) value                                                     government health programs.
                              for both internal and external                                              -   Increasing digital accessibility and
                              parties                                                                         job opportunities for people with
                           - Increasing partnerships in                                                       disabilities while expanding IoT
                              social programs                                                                 education in Pesantren.




32       PT XL Axiata Tbk
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                                                                                 Leading in Sustainability Digital Connectivity




                    Governance
                    Strengthening Good Corporate Governance (GCG) practices
                    and data security to increase accountability

       Plan Focus                        2024                         Realization in 2024                               2025

 Ethics Compliance          Site Plan:                          Successfully achieved ISO 27701          Maintaining the current security
 - Anti bribery anti        - Mastering     awareness   and     certification,    reinforcing     our    posture     while    leveraging   the
    corruption                 understanding of XL Axiata       commitment to data privacy and           synergies to enhance cyber security
 - Risk management             GCG and data privacy ISO         compliance       excellence.     This    and data protection capabilities. XL
                               27701                            accomplishment         marked        a   Axiata is committed to ensuring a
 Privacy security           - Complying and up to date to all   significant milestone after a long       seamless       transition     without
 - Data privacy                regulations from governance      and dedicated effort, making XL          compromising security standards,
 - Cyber security              and ASEAN policies               Axiata the first telecommunications      while    also    strengthening    the
                                                                company to obtain this certification.    Company’s readiness to address
                            Target:                             By       meeting       internationally   emerging      cyber     threats   and
                            - GCG         complied   with       recognized privacy standards, the        regulatory requirements. Through
                               governance     and  ASEAN        Company successfully strengthened        collaboration and integration, we
                               policies                         its     data    governance       data    aim to establish a more resilient
                            - Trusted data ecosystem and        governance framework, enhanced           security framework that safeguards
                               obtaining ISO 27001              stakeholder trust, and set a new         the company’s critical assets and
                                                                benchmark in the industry for            reinforces trust in the data
                                                                responsible data management.             protection practices.




To ensure the relevance of XL Axiata’s Sustainability Policy           XL Axiata is also committed to fostering a culture of
with the dynamic business landscape in telecommunication               sustainability to build an organization of high integrity
industry, the Company conducts periodical reviews. XL                  and accountability. To empower progress, the Company
Axiata also socializes the sustainability policies to develop          incorporates the sustainability culture into every business
better understanding of XL Axiata’s ESG management                     activity and build awareness among all its employees of it
strategies and goals among all stakeholders, particularly              through various ways, including: [GRI 2-24]
XL Axiata employees. The Company expects everyone to                   1. Taking to the social media to communicate about
voluntarily support the policy implementation and increase                 sustainability encompassing aspects of education, ESG,
their participation in maintaining a balance between                       and creating a sustainability newsletter.
development, the well-being of the local community, and                2. Organizing Sustainability Talk, a face-to-face talk
environmental sustainability.                                              show that brings forward various sustainability topics
                                                                           presented by internal and external resources.
In the meantime, the Company always monitors the adverse               3. Initiating a series of activation activities, such as
impacts of its operations through reports collected through                providing recycle dropboxes in several office floors,
the complaint center. Towards the incoming reports or                      providing educational content about sustainability on
complaints about the negative impacts from the operation,                  XL Axiata’s social media, playing audio announcements
XL Axiata has established an integrated customer service to                of progress in reducing energy emissions during lunch
all XL Axiata’s stakeholders, particularly XL Axiata’s product             hours, creating backgrounds on laptop and computer
and service users, and provide quick responses and solutions               screens with ESG themes.
to the adverse effects through the following measures: [GRI            4. Launching a Sustainability campaign in XL Axiata internal
2-25]                                                                      employees (example: call for digitalization to reduce
1. Providing responses to follow-up customer complaints,                   paper consumption, water saving campaign).
     for first level handling. Implement an internal escalation        5. Implementation of digitalization in the process of work.
     system for quick problem resolution;                              6. Training and learning to employees for issues surrounding
2. Regular evaluation of all business processes, project                   Sustainability.
     implementation and results;
3. Open for feedback;                                                  Through the development activities of sustainability culture,
4. Open for discussion and compensate for any                          XL Axiata expects to encourage responsible business
     inconvenience caused to the customer.                             practices among its employees. In 2024, the Company held
                                                                       several training and activation programs on sustainability,
Further details about the complaint center are discussed in            such as Sustainability Week, Waste Management Race, etc.
the report’s sustainability performance section, in regards to
product and customer responsibility.




                                                                                                   2024 Sustainability Report              33
Page 36
                                                                                                    Sustainability Aproach




Net Zero Carbon by 2050

XL Axiata’s commitment to Net Zero by 2050 has consistently made progress. By receiving the CDP certification in 2024, XL
Axiata not only carved another milestone in the Company’s efforts to mitigate risks of climate change but also positioned it
as the industry leader in ESG management. The achievement also reaffirmed the Company’s commitment to transparency,
accountability, and improvement in sustainable environmental performance.


XL Axiata’s Journey Towards Net Zero
XL Axiata’s sustainability journey towards net zero can be portrayed in as follows:




           2019                                 2021                                  2022

     Started the                         Implemented ESG                      Obtained awards in
     calculation of                      principles with                      the 2022 Corporate
     carbon emissions,                   reference to the                     Emission Reduction
     covering direct                     GSMA target to                       and Calculation
     operational activities              reduce carbon                        Transparency event
     including electricity               emissions to 0 by                    with Gold and Green
     consumption.                        2050.                                categories.




           2024                                 2023

     Receiving Carbon                    • Joined Kadin Net Zero Hub, as a forum for exchanging knowledge,
     Disclosure Project                    information, broadening horizons, and sharing resources to create a
     (CDP) certificate                     low emission ecosystem in Indonesia and achieve Net Zero by
     with B score for the                  2050.
     second year. An                     • Strengthened the Green Smart City ecosystem with solutions
     external assurance                    based on Artificial Intelligence (AI), Internet of Things (IoT), and
     for Scope 1, Scope 2                  Connectivity.
     and total energy                    • Calculated the carbon emissions of Scope 3 in 2023 as a first step
     consumption was                       to determine the emission reduction target for Scope 3.
     still ongoing for                   • Obtained Carbon Disclosure Project (CDP) certification with B score
     reporting years of                    in the first submission, recognizing the Company’s commitment to
     2024                                  environmental transparency and sustainability efforts.
                                         • Conducted an external audit of GHG Emission Scope 1 and Scope 2
                                           and of total energy consumption for 2023 and 2024 reporting
                                           years.




34         PT XL Axiata Tbk
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                                                                         Leading in Sustainability Digital Connectivity




Initiatives for Sustainable Future

The Company’s strong commitment to the emission reduction, especially in Scope 2, indeed has inspired several initiatives
focusing on energy efficiency.


XL Axiata itself is to set its goal for net zero carbon by 2025. However, the Company is continuously making progress on its
contributions towards United Nation’s 2030 goal on the reduction of 45% of global carbon emissions.




                        2025                                                             2030




                        Target                                                           Target
              Reduce its emission up to                                       Reduce its emission up to

             80kg CO /TB            2                                                  45%



                      Initiatives                                                     Initiatives
            To install solar panels in 252                                    To engage 100% of top
             Base Transceiver Station                                       spenders both suppliers and
               (BTS) locations across                                       partners to support the net
                      Indonesia.                                               zero emission target.




                  The Company is continuously making progress on its
                contributions towards United Nation’s 2030 goal on the
                      reduction of 45% of global carbon emissions.




                                                                                       2024 Sustainability Report         35
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                                                                                                      Sustainability Aproach




Building the Culture of Sustainability [OJK F.1]

The activities to build the culture of sustainability within XL Axiata’s work environment include the establishment of several
policies and mechanisms that aim to build the integrity of the Company among its stakeholders


In 2024, the Company held socialization/training activities for building employee capacity in regards to the importance of
implementing sustainability culture. The Company held a Sustainability Week program to disburse the values of sustainability.
Sustainability Week is one of XL Axiata’s regular programs which engages its employees in a series of sustainability actions,
such as talk shows on ESG (Environmental, Social and Governance) issues, screening of sustainability-focused films, an
environmentally friendly bazaar, and workshop on waste management. To raise their sustainability awareness at home and the
office, particularly in the waste management, in 2024, XL Axiata held more than 15 activities under the Sustainability Week
program, which took participation of more than 350 employees.


In addition, as part of our commitment to building an accountable and integrity-driven organization as well as to protect the
Company’s interests and long-term business continuity, the Company has conducted socialization to the employees and third
parties on the importance of a whistleblowing system (Speak Up) to report any indications of violation. The followings are
socialization activities relating to the whistleblowing system (Speak Up) XL Axiata conducted in 2024:


  No              Date                                                    Activities
     1    15 March 2024            Email blast to all employee-related speak-up channel.
     2    20 March 2024            Speak up Campaign to XL official social media @lifeinxlaxiata.
     3    26 March 2024            CEO Message to All employees to use Speak Up Channel.
     4    27 March 2024            Creating Speak Up Channel button and the banner on the XL New Life application.
     5    26 April 2024            Speak Up WhatsApp Blast to All Employees.
     6    30 April – 23 May 2024   Anti-Fraud Speak Up Channel Survey.
     7    25 May 2024              Speak Up awareness to third parties.
     8    29 August 2024           Speak Up Awareness to All Employees.
     9    29 August 2024           Opening Speak Up Consultation Room at Experience Lab XL Axiata Tower, 21st Floor.
  10      2 September 2024         Speak Up Awareness to third parties/vendors, blast by Vendor Management.
     11   14 October 2024          Speak Up Standing Banner placed at Lobby XLAT
  12      December 2024            Integrity Workshop @XL Center Bandung collaboration with ROBI.
  13      3 December 2024          Integrity Workshop @XLAT collaboration with ROBI.




      Sustainability Week




36         PT XL Axiata Tbk
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                                                                           Leading in Sustainability Digital Connectivity




Contributions to the Sustainable Development
Goals (SDGs) [OJK F.25]

XL Axiata’s Sustainability Policy is aligned with 17 (seventeen) Sustainable Development Goals (SDGs). The Company has
designed various sustainability initiatives and programs that aim to support 15 (fifteen) out of 17 (seventeen) SDGs. The
Company’s contributions to SDGs are outlined as follows:


                          XL Axiata Contribution                                     SDGs                 SDGs Explanation

 -   XL Axiata Baik aims to extend social support to the families of the            NO
                                                                                    POVERTY
     employees and the surrounding community.
 -   Gerakan Donasi Kuota aims at improving the quality of the national                                 No Poverty
     education through quota donated by the society and XL Axiata’s
     customers.


                                                                                    ZERO
 -   XL Axiata Peduli extends social supports to the victims of natural             HUNGER
     disasters through distribution of emergency assistance programs.
                                                                                                        Zero Hunger
 -   XL Axiata Baik aims to extend social support to the families of the
     employees and the surrounding community.



                                                                                    GOOD HEALTH
 -   XL Axiata Peduli extends social supports to the victims of natural             AND WELL-BEING
     disasters through distribution of emergency assistance programs.                                   Good Health and
 -   XL Axiata Baik aims to extend social support to the families of the                                Well-Being
     employees and the surrounding community.


 -   Pesantren Digital reflects XL Axiata’s care for the enhanced knowledge
     of Santri/Santriwati regarding Digitalization and utilization of IoT.           QUALITY
                                                                                     EDUCATION
 -   Sisternet helps empower Indonesian women to develop and increase
                                                                                                        Quality Education
     their welfare through use of internet and technologies.
 -   Gerakan Donasi Kuota aims at improving the quality of the national
     education through quota donated by the society and XL Axiata’s
     customers.

                                                                                     GENDER
                                                                                     EQUALITY
 Sisternet helps empower Indonesian women to develop and increase their
                                                                                                        Gender Equality
 welfare through use of internet and technologies.




                                                                                    CLEAN WATER
                                                                                    AND SANITATION
                                                                                                        Clean Water and
 Water and Waste Management aims to control environmental issues.
                                                                                                        Sanitation




                                                                                    AFFORDABLE AND
 -   Green BTS is one of initiatives to lessen the Company’s dependence on          CLEAN ENERGY

     non-renewable energy.                                                                              Affordable and Clean
 -   Energy Efficiency is one initiative to support an eco-friendly business                            Energy
     operation.


                                                                                     DECENT WORK AND
                                                                                     ECONOMIC GROWTH

                                                                                                        Decent Work and
 -   Employee Benefit Policy.
                                                                                                        Economic Growth




                                                                                             2024 Sustainability Report      37
Page 40
                                                                                                      Sustainability Aproach




                         XL Axiata Contribution                               SDGs                     SDGs Explanation

                                                                              INDUSTRY, INNOVATION
                                                                              AND INFRASTRUCTURE

XL Axiata’s Internet of Things (IoT) Laboratory which serves as an                                   Industry, Innovation
innovation center to develop the IoT ecosystem in Indonesia.                                         and Infrastructure




                                                                              REDUCED
                                                                              INEQUALITY

Sisternet helps empower Indonesian women to develop and increase their
                                                                                                     Reduced Inequalities
welfare through use of internet and technologies.




-    Sisternet helps empower Indonesian women to develop and increase         SUSTAINABLE CITIES
                                                                              AND COMMUNITIES
     their welfare through use of internet and technologies.
                                                                                                     Sustainable Cities
-    Laut Nusantara.
                                                                                                     and Communities
-    Pesantren Digital reflects XL Axiata’s care for the enhanced knowledge
     of Santri/Santriwati regarding Digitalization and utilization of Io.T



                                                                              RESPONSIBLE
                                                                              CONSUMPTION AND
                                                                              PRODUCTION             Responsible
Paper, Plastic and Waste Management is an initiative to address
                                                                                                     Consumption and
environmental issues.
                                                                                                     Production



-    Green BTS is one of initiatives to lessen the Company’s dependence on
                                                                              CLIMATE
     non-renewable energy.                                                    ACTION
-    Energy Usage Efficiency.
                                                                                                     Climate Action
-    Eco Warrior.
-    Waste Management.
-    Zero Waste to Landfill Event.

                                                                              LIFE BELOW
                                                                              WATER

Mangrove Planting Initiative.                                                                        Life Below Water




                                                                              LIFE
                                                                              ON LAND
The campaign of sorting waste according to its type, one of which is with
                                                                                                     Life on Land
the aim of maintaining the ecosystem on land.




-    GCG Policy.                                                              PEACE, JUSTICE
                                                                              AND STRONG
                                                                              INSTITUTIONS
-    ABAC Policy.
                                                                                                     Peace, Justice and
-    Data Security and Privacy is conducted in accordance with ISO 27001
                                                                                                     Strong Institutions
     standards concerning Information Security Management System
     (ISMS).


                                                                              PARTNERSHIPS
-    Sisternet helps empower Indonesian women to develop and increase         FOR THE GOALS

     their welfare through use of internet and technologies.                                         Partnership    for   the
-    Pesantren Digital reflects XL Axiata’s care for the enhanced knowledge                          Goals
     of Santri/Santriwati regarding Digitalization and utilization of IoT.




38        PT XL Axiata Tbk
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                                 Leading in Sustainability Digital Connectivity




Solar Panel located in Sukasari Site, Bogor with installed capacity of 14,080 Wp




                                               2024 Sustainability Report         39
Page 42
About
XL Axiata




XL Axiata BTS located in Rawa Pening, Jakarta, where the Company carried out a shelter
simplification initiative to reduce energy usage
Page 43
      Through 4P Pillars of Building
Prosperity, Nurturing People,
Process Excellence, and Planet and
Society, the Company continuously
takes unprecedented steps forward
in tackling sustainability issues and
makes priceless contributions to
create a better future for everyone.
Page 44
                                                                                                             About XL Axiata




Corporate Information [GRI 2-1]

COMPANY NAME                PT XL Axiata Tbk
                            (Formerly PT Excelcomindo Pratama, and PT Grahametropolitan Lestari)

LEGAL                       Deed of establishment No. 55 dated October 6, 1989, as amended by Deed No. 79 dated
STATUS                      January 17, 1991, both of which were drawn up before Rachmat Santoso, S.H., Notary in Jakarta,
                            and have been ratified by the Minister of Justice of the Republic of Indonesia by virtue of his
                            Decree No. C2-515. HT.01.01.TH.91 dated February 19, 1991, and registered in Company Register
                            maintained by the Registry Office of South Jakarta District court under No. 670/Not/1991/PN.
                            JKT.SEL and No. 671/Not/1991/PN.JKT.SEL, both dated August 21, 1991, and published in the
                            State Gazette of the Republic of Indonesia No. 90 dated November 8, 1991, Supplement No.
                            4070.

SHARE OWNERSHIP             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).

                            XL Axiata’s Shareholding Percentage:
                            • Axiata Investments (Indonesia) Sdn. Bhd.: 66.25%
                            • Treasury Shares: 0.43%
                            • Public: 33.32%

TICKER CODE                 EXCL

SEGMENT BRAND


SUPPLY CHAIN                XL Axiata has partnership with a diverse range of vendors to ensure the availability of goods
[GRI 2-6]                   and services to support its business continuity. The Company also requires the suppliers to
                            adhere to sustainability principles as outlined in its procurement policy. Below is XL Axiata’s top
                            three largest supply chains/vendors (by PO) in 2024:
                            1. PT Huawei Tech Investment
                            2. PT Lintas Teknologi Indonesia
                            3. PT Nokia Solutions and Networks Indonesia

SIGNIFICANT CHANGES         End of 2024, XL Axiata announced a definitive agreement for a proposed merger with
IN THE COMPANY              PT Smartfren Telecom Tbk and PT Smart Telcom.
[OJK C.6]

ADDRESS                     XL Axiata Tower
[OJK C.2]                   Jl. H.R. Rasuna Said X5 Kavling 11-12 Kuningan Timur, Setiabudi, Jakarta Selatan, 12950 Indonesia


PHONE NUMBER                +62215761881, +62215761880

EMAIL                       corpsec@xl.co.id		

WEBSITE                     https://www.xlaxiata.co.id/

MEDIA SOSIAL                   XL Axiata Tbk               @xlaxiata_tbk                   @xlaxiata_tbk

                               @XLAxiataTbk                PT XL Axiata Tbk                @xlaxiata_tbk




42       PT XL Axiata Tbk
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                                                                             Leading in Sustainability Digital Connectivity




XL Axiata at a Glance




On 6 October 1989 under the name of PT Grahametropolitan             corporate segments and has successfully established a large
Lestari, XL Axiata marked its first commercial kick-off as a         network and reputable business with nationwide coverage.
trading and general services company. In 1996, the Company           XL Axiata provides unlimited access to Data, Voice, SMS
ventured into the telecommunications sector after XL Axiata          services and other value-added digital solutions.
secured a GSM 900 operating license and made a successful
launch of our GSM services, becoming the first private               XL Axiata’s service networks run on GSM 900/DCS 1800,
company in Indonesia to provide cellular mobile telephony            IMT- 2000/3G, and has an established reputation as the first
services.                                                            telecommunications operator in Indonesia to commercially
                                                                     launch 4.5G Ready on the 1,800 MHz spectrum. XL Axiata
Then an agreement which was sealed between Rajawali                  also strengthens its position as #1 convergence operator in
group and three foreign investors (NyNEX, AIF and mitsui)            Indonesia by completing our certifications with a content
led to rebranding in the Company’s organization as marked            provider License, Internet Services Provider (ISP), Internet
by the Company name change into PT Excelcomindo                      Interconnection Services License, Voice Over Internet
Pratama. With continuous commitment to advancing the                 Protocol License, and Leased Line License. XL Axiata also
business, the Company in September 2005 decided to                   has secured a Certificate of Operational Eligibility (SKLO),
change its status to be a publicly listed company through an         thus allowing it to deploy a 5G network in Indonesia in
Initial Public Offering (IPO) by listing its shares on the Jakarta   August 2018.
Stock Exchange (now Indonesia Stock Exchange (IDX)).
                                                                     Beyond the digital convergence, XL Axiata helps
At that time of the IPO launch, the Company was a                    empower everyone to optimize their potentials and
subsidiary of Indocel Holding Sdn. Bhd., or now well known           business opportunities through its top-notch quality
as Axiata Investment (Indonesia) Sdn. Bhd., a fully-owned            of data connection and network expansion. With the
entity of TM International Sdn. Bhd., (TMI) through TM               implementation of 4.9G technologies – Massive MIMO for
International (L) Limited.                                           faster and stable data communication, XL Axiata ensures
                                                                     its customers, including those living beyond Java Island, to
The synergy with our Malaysia-based holding brought                  have the best experience in daily communication.
another dynamic to XL Axiata’s organization as the
Company in 2009 decided to change the Company name                   Today, the Company continues to nurture the culture of
into PT XL Axiata Tbk following TMI’s name change into               innovation to leverage opportunities across telco and digital
Axiata Group Berhad (Axiata) in that year. Currently, the            sectors. The Company also makes progress in seamless data
share composition of XL Axiata shows that Axiata through             integration powered by Artificial Intelligence (AI), across
Axiata Investments (Indonesia) Sdn. Bhd. continues to                telco and digital behavior to enrich product personalization
dominate with 66.25%, followed by the public with 33.32%             offered to customers based on their preferences, thus
and Treasury Shares amounting to 0.43%.                              increasing customer engagement and shaping the
                                                                     Company’s competitive advantage.
The composition affirms XL Axiata’s position as part
of the Axiata group (Group), one of Asia’s largest                   At the same time, the Company leverages cloud technology
telecommunication groups. The Group operates market-                 to strengthen its cyber security and fraud management
leading mobile subsidiaries and associates under the brands,         system to ensure that the Company installs the latest and
such as ‘CelcomDigi’ in Malaysia, ‘Dialog’ in Sri Lanka, ‘Robi’      efficient technologies to deliver the safe and impactful
in Bangladesh, ‘Smart’ in Cambodia, ‘Ncell’ in Nepal. In             solutions for our customers.
Indonesia, XL Axiata continues to lead in both retail and




                                                                                            2024 Sustainability Report         43
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                                                                                                             About XL Axiata




2024 Sustainability Event
Highlights
         ENVIRONMENTAL
         Jakarta, 12 October 2024
         XL Axiata has taken the opportunity of its 28th anniversary to reaffirm its commitment to sustainability
         programs, including achieving Zero Waste to Landfill (no waste will be sent to landfills). In front of approximately
         4,000 employees and their families at the anniversary celebration held at Taman Mini Indonesia Indah in East
         Jakarta, XL Axiata’s management emphasized the Company’s commitment to waste management.



         Jakarta, 2 December 2024
         XL Axiata and PLN Collaborate on Power Supply and Renewable Energy Usage to Support the Utilization
         of Green Energy for Sustainability. Both have formed a strategic collaboration to supply electricity for Base
         Transceiver Station (BTS) devices and migrate to green energy. This relationship will endure for the next two
         years, beginning in September 2023 and being extended in October 2024. The goal is to integrate both
         parties’ products and explore possible opportunities, not only to provide a secure electricity supply, but also
         to develop long-term business solutions that improve public services and benefit the enterprises involved.


         Jakarta, 27 February 2024
         XL Axiata attained Carbon Disclosure Project (CDP) certification with a B grade, recognizing its commitment
         to transparent environmental practices and sustainability. This certification, issued by a non-profit CDP
         organization, highlights our dedication to ESG principles. As part of this endeavor, XL Axiata has taken a
         number of concrete steps, including conducting an inventory of carbon emissions in scopes 1, 2, and 3, to
         guide carbon footprint reduction targets.




                 SOCIAL
         Jakarta, 5 January 2024
         XL Axiata has successfully guarded and served the surge in customer data needs during the Christmas and
         New Year 2024 holidays. From monitoring on 24 December 2023 to 2 January 2024, the average service
         traffic during the Christmas and New Year period increased by 15% compared to normal days and 19%
         compared to the previous Christmas and New Year period. Meanwhile, the peak increase in service traffic
         occurred on New Year’s Eve which reached 90% compared to normal day conditions. As predicted, streaming
         services dominated the spike in service traffic. In contrast, legacy service traffic, namely conversations
         (voice) only increased by 1% and SMS by 8% compared to normal days.

         Flores, 1 February 2024
         XL Axiata distributed essential aid to those affected by the eruption of Mount Lewotobi Laki in East Flores
         Regency, East Nusa Tenggara. The aid included basic daily necessities such as rice, instant noodles, eggs,
         canned food, and cooking oil.

         Demak, 23 February 2024
         XL Axiata distributed donations to flood victims in Grobogan, Demak and Kudus, Central Java. Donations
         were distributed in the form of essential items such as rice, eggs, sugar, cooking oil, packaged fish, bottled
         drinking water, and light medicines. Donations were handed directly to local representatives spread across
         each location, starting 19 February 2024. Along with this distribution, the Company also ensured the
         operation of over 1,080 4G BTS to serve the locals around these areas.

         Medan, 6 March 2024
         XL Axiata employees together with the journalist community in Medan came together for a regular blood
         donation event at the Grha XL Medan office. The results of this social action were given to the Medan
         Children’s Oncology Foundation (YOAM) to help children with cancer.

         Jakarta, 5 March 2024
         Celebrating International Women’s Day 2024, XL Axiata through the Sisternet Program introduced
         the”FINANSISTER” feature on the Sisternet app. At the same time, through a collaboration with PT Bank
         OCBC NISP Tbk (OCBC), XL Axiata also launched a collateral-free loan facility for business capital and digital
         financial literacy education for Indonesian Womenpreneurs.


44   PT XL Axiata Tbk
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                                                               Leading in Sustainability Digital Connectivity




Jakarta, 8 March 2024
XL Axiata through XL Axiata Business Solutions (XLABS) in collaboration with Alita Praya Mitra (Alita)
launched “XL Axiata Access Sehat”, a connectivity service and smart facilitating Electronic Medical Records
(RME) in the healthcare sector, signifying a new step toward enhancing wider support to access and the
quality of healthcare services across Indonesia.

Sleman, 19 March 2024
In support of the Indonesian government’s effort to improve educational infrastructure, XL Axiata has
made an important contribution by distributing routers and data quotas to several Islamic boarding schools
(ponpes) across Indonesia. This initiative reflected the company’s commitment to enhancing digital education
in Islamic boarding school environment amidst the the month of Ramadan 1445 H.

Banjarmasin, 22 March 2024
In an effort to support digital education in Indonesia, XL Axiata distributed router and data quota donations
to Islamic institutions, including boarding schools (ponpes), across the country through the Gerakan Donasi
Kuota (GDK) program. One recipient was Rumah Harapan Foundation located in Banjar Regency, South
Kalimantan.

Surabaya, 25 March 2024
During the Ramadan momentum, in an effort to support digital education in Indonesia, XL Axiata through
the Gerakan Donasi Kuota (GDK) program, provided routers and data quotas to Islamic universities,
Islamic boarding schools, and social institutions caring for children with special needs across Indonesia.
One beneficiary was the Peduli Kasih Anak Berkebutuhan Khusus (Caring for Children with Special Needs)
Foundation in Sidoarjo, East Java.

Padang, 26 March 2024
Through XL Axiata Peduli, XL Axiata continued to assist disaster victims in Indonesia by providing assistance
to flood victims in 3 sub-districts of Pesisir Selatan Regency, West Sumatra, including Koto XI Tarusan District,
Nagari Tambang District, and Batang Kapas District.

Surabaya, 4 April 2024
Employees of XL Axiata, through the XL Axiata Ta’lim Council (MTXL Axiata) organized the “Semarak
Ramadan” program across various cities in Indonesia. They shopped for Eid clothes and aided needy orphans
in Surabaya, Bandung, and Palembang.

Jakarta, 17 April 2024
XL Axiata observed a rise in data usage during the Ramadan and Idul Fitri 1445 H holidays, spanning from
April 4, 2024, to April 14, 2024. Data sourced from the Customer Experience & Service Operation Center at
XL Axiata Tower, Jakarta, indicates a 16% increase in data service usage compared to regular days preceding
Ramadan. This surge is closely linked to individuals’ enthusiasm to return to their hometowns and enjoy the
holiday festivities during Eid.

Jakarta, 7 May 2024
Dian Siswarini, President Director & CEO XL Axiata and Co-Chair of W20 Indonesia 2022, represented
Indonesia at the CSW Session, participating in a side event titled “Addressing Poverty, Strengthening
Institutions, and Financing for Women Empowerment,” alongside officials from the Indonesian Ministry of
Women’s Empowerment and Child Protection (PPPA) and the Women’s Congress Indonesia (Kowani).

Pekanbaru, 13 May 2024
Employees of XL Axiata gathered at the Grha XL Pekanbaru office on Jalan Tuanku Tambusai Ujung No. 819,
Pekanbaru to conduct a blood donation drive. Alongside this initiative, they also distributed book donations
to children from the Darul Ilmi Orphanage located on Jl. Rawasari I, Pekanbaru City.

Central Buton, 25 May 2024
President Director & CEO of XL Axiata, Dian Siswarini, inaugurated the Al-Amin Madrasah Ibtidaiyah
development project along with its supporting facilities in Central Buton Regency, Southeast Sulawesi. The
procurement of basic education facilities cost approximately IDR800 million, funded by contributions from
XL Axiata employees and management. The The inaugural ceremony was also attended by XL Axiata’s Chief
of Human Capital Officer, M Hira Kurnia, Chair of the MTXL Foundation, Fery Firman, and other XL Axiata
employees.

Jakarta, 30 May 2024
Through its Corporate Social Responsibility (CSR) program “XL Axiata Peduli”, XL Axiata, in collaboration
with Alita Praya Mitra (Alita), has introduced JAGATARA (Jiwa Raga Sehat Sejahtera), an early detection
solution for stroke. This innovative solution featured advanced detection capabilities, integrating technology
and public health analysis on a unified platform.

Jakarta, 17 June 2024
Majlis Taklim XL Axiata (MTXL Axiata) once again enabled all members of the MTXL Axiata congregation, as
well as employees and management of XL Axiata, to perform qurbani services for Eid al-Adha 1445 H. MTXL
Axiata distributed sacrificial animals in Pasar Manggis Village, Setiabudi District, South Jakarta. Dian Siswarini,
President Director & CEO of XL Axiata, attended the handover and slaughter of the sacrificial animals


                                                                               2024 Sustainability Report             45
Page 48
                                                                                                         About XL Axiata




         Jakarta, 21 June 2024
         XL Axiata held a Sustainability Week program with various events, from talk shows, podcasts, film screenings,
         green product bazaars, to workshops on waste management. Through this program, the management invited
         the employees to care about waste management, both at home and at work. XL Axiata is also determined to
         strengthen its commitment to waste management with concrete steps to make the company’s environment
         cleaner and more sustainable.

         Jakarta, 22 June 2024
         In partnership with the Lentera Membangun Bangsa Foundation, XL Axiata has relaunched the GDK program
         under the theme “Internet Access for Indonesia’s Smart Generation.” This initiative has received approval
         from the Ministry of Social Affairs of the Republic of Indonesia, making XL Axiata the only operator that leads
         with such a donation program.

         Garut, 30 June 2024
         XL Axiata has partnered with Garut University (UNIGA) to enhance the fulfillment of the Tri Dharma of higher
         education—Education, Research, and Community Service. Through this collaboration, UNIGA students will
         leverage XL Axiata’s technology, network, and telecommunications services for learning and community
         engagement. The memorandum of agreement was signed by Garut University’s Chancellor, Dr. Ir. H. Abdusy
         Syakur Amin, M.Eng, IPU, and XL Axiata’s President Director & CEO, Dian Siswarini, at the UNIGA campus.

         Jakarta, 22 July 2024
         Employees of XL Axiata through the Majelis Ta’lim XL Axiata (MTXL Axiata), organized the Semarak Muharram
         1446H program which brought forward a theme “Happiness for Orphans.” This program was held annually
         in various cities across Indonesia. This year, XL Axiata employees simultaneously distributed aid in 15 cities
         in Indonesia.

         Bandung, 22 July 2024
         XL Axiata organized a series of training programs to enhance digital skills of people with disabilities. Apart
         from the Disability Islamic Boarding School training, XL Axiata has also prepared additional sessions aimed
         at preparing individuals with disabilities for the workforce.

         Gorontalo, 30 July 2024
         XL Axiata through its XL Axiata Peduli Program, has distributed aid to victims of the recent floods and
         landslides in Gorontalo, which occurred in July 2024. The assistance included daily necessities such as rice,
         instant noodles, eggs, canned food, and cooking oil. The aid was delivered directly to the affected victims
         at evacuation sites by XL Axiata representatives, in cooperation with the Benihbaik Foundation, at a shelter
         located in Donggala, Hulonthalangi, Gorontalo City last week.

         Surabaya, 2-3 August 2024
         XL Axiata held a series of digital competency training sessions for people with disabilities in Surabaya, aiming
         to prepare to prepare them for the workforce. A total of twenty participants with disabilities attended the
         two-day training. Beyond Surabaya these training sessions were also held in Medan, Bandung, and Jakarta.

         Garut, 17 August 2024
         Together with dozens of students from Special Needs School (SLB) Garut, the management and 79
         employees of XL Axiata celebrated the 79th Anniversary of the Republic of Indonesia. The event included a
         flag-raising ceremony and the reading of the Proclamation of Independence.

         Jakarta, 22 August 2024
         XL Axiata held “Sisternet Festival 2024,” under the theme “Women of the Future, Collaborative Women,” a
         series of new Sisternet programs aimed at empowering 1 million Indonesian women.

         Surabaya, 7 September 2024
         XL Axiata continued to expand the benefits of its “Sisternet” program, aimed at empowering Indonesian
         women to #JadiLebihBaik. One of the initiatives, i.e. ‘Sisternet Expands Benefits for Indonesian Women
         Hosts Community Gathering and Socializes the Kompetisi Modal Pintar 2024 Program, was to promote
         increased digital literacy among women who owned and managed small and medium enterprises (SMEs)
         across Indonesia.

         Padang, 9 September 2024
         XL Axiata through its Sisternet program, hosted the “Sisternet Goes To Campus” event at Andalas University
         (UNAND) in Padang, West Sumatra, under the theme “Empowering Future Female Leaders.” XL Axiata
         invited over 1,500 female students from UNAND to broaden their perspectives, address various women’s
         issues, and collaboratively explore solutions.

         17 September – 22 October 2024
         After conducting digital skill training for 115 disabled individuals, XL Axiata, through its corporate social
         responsibility (CSR) programs, XL Axiata Peduli and XL Axiata Baik, invited 20 selected disabled individuals
         to participate in the XL Axiata internship program. This program was part of the XL Axiata Peduli Disabilitas
         Siap Kerja initiative.




46   PT XL Axiata Tbk
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Bandung Regency, 25 September 2024
XL Axiata Peduli Bencana (XL Axiata Cares for Disaster) program extended support to the earthquake
victims in Cibeureum, Kertasari, Bandung Regency. The assistance included essential items for displaced
residents, such as sleeping mats, blankets, and tarpaulins.

Bekasi, 2 October 2024
XL Axiata delivered the benefits of the Gerakan Donasi Kuota Program (GDK) to 28 educational institutions
across Indonesia. This time, SMK Adhi Karya in Cabangbungin, Bekasi Regency, was among the recipients,
along with 27 other institutions. By the end of the year, XL Axiata aimed to support a total of 200 educational
institutions, including schools, pesantren (Islamic boarding schools), orphanages, and facilities for individuals
with disabilities, to access the advantages of the GDK Program.

Medan, 3 October 2024
In celebration of XL Axiata’s 28th anniversary, the employees held simultaneous blood donation drives
across 5 cities in Sumatra. The blood drives took place at XL Axiata offices in Medan, Pekanbaru, Jambi,
Bengkulu, and Palembang. The collected donations from this social initiative would be delivered to the Medan
Children’s Oncology Foundation (YOAM) and distributed to the children battling cancer in Medan. Meanwhile,
in Pekanbaru, Jambi, Bengkulu, and Palembang, the blood would be distributed through the Indonesian Red
Cross (PMI) to those in need. #SelaluAdaUntukIndonesia

Yogyakarta, 10 October 2024
XL Axiata launched “Sisternet Goes to Campus.” The program targeting at female students took place at
Universitas Muhammadiyah Yogyakarta (UMY). Hundreds of UMY female students were invited to embark on
a journey to become “Female Future Leaders” by broadening their perspectives, discussing various issues,
and exploring solutions to challenges faced by women.

Central Lampung, 15 October 2024
Located at the Salafiyah Darussa’adah Islamic Boarding School in Central Lampung, Lampung, XL Axiata
has introduced IoT solutions for maggot farming. The IoT Maggot solutions, developed by XCamp as XL
Axiata’s IoT solution development laboratory, include several monitoring features as well as temperature
and humidity controls at the Black Soldier Fly (BSF) farming site. BSF is a type of fly whose eggs develop
into maggot larvae. The benefits of this IoT-based digital solution include increased maggot productivity,
reduced operational costs, and providing data for Big Data and Artificial Intelligence purposes to facilitate
planning, forecasting, and maintenance.

Palangkaraya, 30 October 2024
Through XL Axiata Care Program (Program XL Axiata Peduli), XL Axiata has distributed aid to the flood
victims in Sanggau, West Kalimantan, and Murung Raya in Central Kalimantan. The social assistance
included essential supplies, such as rice, instant noodles, eggs, canned food, and cooking oil. XL Axiata’s
representatives in collaboration with the Benihbaik Foundation, delivered the social aids directly to affected
communities last week.

Lombok, 4 December 2024
XL Axiata supported digitalization of Islamic Boarding Schools in East Lombok by presenting IoT and AI
Solutions. Through the Pesantren Digital program, XL Axiata introduced the use of Artificial Intelligence (AI)
and Internet of Things (IoT) solutions to help empower the islamic boarding school’s economy. One of the IoT
solutions introduced was X-Maggot, a technology designed to support maggot farming as part of organic
waste management.




GOVERNANCE
November - December 2024
XL Axiata achieved ISO 27001:2022 ISMS and ISO 27701:2019 certification for Privacy Information
Management System (PIMS), making it the first telecommunications company in Indonesia with privacy
certification. In addition, XL Axiata was selected as a constituent of the IDX KEHATI ESG Sector Leaders
Index for December 2024 - May 2025, demonstrating its commitment to sustainability. XL Axiata was also
awarded the Sustainable Business Integrity Index 2024 with the Ruby category and a score of 78.95. The
company excelled in aspects of Business Integrity (Ruby, 75.00), Business and Human Rights (Diamond,
86.67), and Environment (Sapphire, 71.43).




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                                                                                                        About XL Axiata




Vision, Purpose and Core Values
[OJK C.1]




                              VISION
                               #1 Converged Operator
                                    in Indonesia
 Our vision is to become a converged digital service provider, which can combine mobile & fixed
   business/services, in a new, better, and customer-focused so that customers can enjoy the
          convenience and flexibility of our services and generate the highest NPS value.




                     PURPOSE
           We bring the world closer in a simple way
                       for a brighter life
                             This promise cannot be done alone by ourselves;
        Only through internal & external collaboration/togetherness, we can make this happen;
     We enable and empower people to stay in touch or connect with their environment and create
                                        new possibilities;
                        We are always close by to fulfil daily needs in people’s life;
     Life is getting more and more complex for people, and we are here to simplify it by providing
               seamless experiences for all our stakeholders (The world at your fingertips);
 Simplifying adds value to people’s life by saving their time, energy and money, which allow them
                                   to get more out of their life;
        We are committed to help people to continuously improve their lives in terms of welfare
          (economically) and wellbeing (fun, excitement, energy, inspiration and unleashing
                                         people’s potential).




                                           VISION AND PURPOSE REVIEW

                 The Board of Directors regularly reviews the Company’s Vision and Objectives to ensure
              that the Company’s Vision and Purpose are still aligned with the Company’s current condition
                                                       and strategy.



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CORE VALUES
                                 ICCC
                     Acronym for communication (read: I triple C)




              Uncompromising Integrity
 › I only do the right things, align with the team and seek for advice if unclear.
     › I am courageous to make bold decision and speak up when needed.




               Obsession for Customers
        › I am curious about my customers and genuinely care for them.
   › I proactively take ownership to deliver beyond customers’ expectation.




                    Courage for Change
    › I think big and fearlessly step outside my comfort zone to take risks.
                › I embrace mistakes to learn, adapt and improve.




               Passion for Collaboration
    › I welcome ideas that are different from my own and learn from them.
      › I am open and curious to explore possibilities to create synergies.




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                                                                                                         About XL Axiata




Organization Structure

                                                                              President Director & CEO




                                                                          Director & Chief         Director & Chief
                      Chief Human Capital    Finance Director & Chief
 CEO’s Office                                                           Commercial Officer -          Commercial
                             Officer             Financial Officer
                                                                        Home & Convergence        Officer - Consumer




   Group Head                                                                Group Head
                            Group Head                Group Head                                      Chief Go To
 Transformation                                                               Strategic
                           People Journey               Finance                                      Market Officer
      Office                                                                 Partnership



                               Group Head             Group Head
      Group Head                                                          Group Head Digital                Group Head
                                  People               Financial
     Internal Audit                                                          Partnership                  Commercial GTM
                               Development            Accounting


                             Group Head
                                                       Group Head
      Corporate            People Services                                     Chief                          Group
                                                    Finance Business
      Secretary               & Facility                                    Home Officer                    Head West
                                                         Control
                            Management


Group Head Risk &                                     Group Head                Group Head                  Group Head
   Compliance                                         Procurement              Home Business               Jabodetabek
     Officer                                          Management                Operations



                                                      Group Head                Group Head                  Group Head
                                                       Contract                Home Product                   Central
                                                      Management



                                                                            Chief Business                   Group
                                                                             Integration                    Head East
                                                                                Officer




                                                                                                          Kalimantan Area




                                                                                                           Sulawesi Area




                                                                                 Group Head          Group Head
                                                                                 Commerce          Customer Contact
                                                                                  Planning              Center



                                                                                Group Head
                                                                                                   Group Head Digital
                                                                              Customer Value &
                                                                                                       Channel
                                                                                 Experience
                                                                                                      Touchpoint
                                                                                Management



                                                                              Group Head Direct       Group Head
                                                                                  Channel           Indirect Channel
                                                                                Management            Management



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                                                                                                  Director & Chief
                                                                   Director & Chief
                      Director & Chief IT    Chief Strategy &                                        Enterprise
                                                                     Technology
                        Digital Officer      Analytics Officer                                  Business & Corporate
                                                                        Officer
                                                                                                   Affairs Officer



                           Group Head                                  Group Head
                                                 Group Head                             Chief Enterprise
Chief Marketing            Technology                                  Technology                               Chief Corporate
                                                  Corporate                                Business
    Officer               Security & Risk                              Strategy &                                Affairs Officer
                                                   Strategy                                 Officer
                             Controls                                   Assurance


      Group Head         Group Head IT           Group Head           Group Head              Group Head            Group Head
       Premium          Strategy Planning      Business Analysis    Network Planning       Enterprise Product        Corporate
       Segment           & Architecture           & Insights           & Design               & Marketing         Communications &
                                                                                                                    Sustainability


   Group Head Youth                            Group Head Data        Group Head              Group Head
                          Group Head IT
       Segment                                    Engineering          Program                 National &               Group
                          Core Platform
                                                & Development         Management                Strategic             Head Legal
                                                                                           Enterprise Account

                          Group Head IT
                                              (Act) Group Head         Group Head
    Group Head Mass          Business                                                         Group Head             Group Head
                                                   Applied          Service Operation
       Segment           Partner & Project                                                      Regional             Regulatory &
                                                Analytics & AI        Management
                           Management                                                      Enterprise Account       Government Rel
                                                                                               & Channel
                                                                                             Development
                          Group Head IT
                              Digital
                           Operations &
                          Transformation                                                      Group Head
                                                                                               Enterprise
                                                                                              Solutions &
                                                                                           Technical Account
                        Group Head Digital                                                   Management
                           Touchpoints

                                                                                              Group Head
                                                                                             Wholesale and
                                                                                                Reseller




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                                                                                                      About XL Axiata




Group’s Structure

                                                               Citigroup Nominees
                                       Amanah Raya
                 Khazanah                                       (Tempatan) Sdn.
                                      Trustees Berhad
                 Nasional                                        Bhd - Employee             Others
                                     - Amanah Saham
                  Berhad                                         Provident Fund
                                        Bumiputera
                                                                      Board


                  36.72%                 12.20%                     18.32%                  32.76%




                                                  Axiata Group
                                                    Berhad*
                                                    *Controlling
                                                   Shareholders
                                                        100%




                                                Axiata Investment
                                                (Labuan) Limited

                                                        100%



                                                Axiata Investment                           Public
                 Treasury
                                                   (Indonesia)                          (Shareholders
                  Shares
                                                     Sdn. Bhd                             below 5%)
                  0.43%                                 66.25%                              33.32%




                                                PT XL Axiata Tbk




      PT One              PT Princeton
                                                   PT Hipernet                XL Axiata
     Indonesia         Digital Group Data                                                            PT Link Net Tbk
                                                    Indodata              Singapore Pte. Ltd.
      Synergy                Centres

       50%                  10.71%                       51%                    100%                      20%




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Subsidiaries
                                                                                                    Total Assets as
                                                            Share
                                                                                                     of December      Operations
        Name                       Address                Ownership         Line of Business
                                                                                                       31, 2024         Status
                                                          Percentage
                                                                                                      (Rp Million)
 PT Hipernet             Graha Hyper, Jl. Makaliwe             51%          Managed Service                407,231    Operating
 Indodata                Ray a No. 24-24A Jakarta                             Provider and
                         Barat, DKI Jakarta                                    Information
                                                                           Technology Service
 PT Link Net Tbk         Centennial Tower Lt. 26 Unit         20%            Internet Services         13,916,788     Operating
                         D, Jl. Jenderal Gatot Subroto                    Provider and Cable TV
                         Kav. 24- 25 Jakarta Selatan,
                         DKI Jakarta
 PT Princeton            Menara Astra, Jalan Jenderal        10.71%        Activities relating to      2,276,099      Operating
 Digital Group Data      Sudirman Kaveling P&K V                          hosting and managing
 Centres                 Nomor 6 Jakarta Pusat, DKI                            data centres
                         Jakarta
 PT One                  Gedung Indosat Lantai 9              50%         Computer consultancy                   0      Not
 Indonesia               Jl. Medan Merdeka Barat                              and facility                            Operating
 Synergy                 No. 21 Gambir, Jakarta                              management
                         Pusat
 XL Axiata               9 Raffles Place, #26-01              100%        International operator              8,379   Operating
 Singapura Pte. Ltd.     Republic Plaza, Singapore                              service and
 (sebelumnya             048619                                              management of
 Axiata Global                                                               partnership and
 Services Pte. Ltd. |                                                             alliance
 Previously
 Axiata Global
 Services Pte. Ltd.)




Business Scale [OJK C.3]
                     Description                             Unit                2024               2023              2022
 Total Employees                                            People                 1,663              1,495             1,501
 Total Revenues                                            Rp-Billion            34,392             32,323             29,142
 Total Assets                                              Rp-Billion            86,179             87,688             87,278
 Total Liabilities                                         Rp-Billion            59,955              61,183           61,504
 Total Equity                                              Rp-Billion            26,222             26,505            25,774
 Number of Products/Services Provided                      Petabyte              10,547              9,638              7,991
 Number of Customers                                     Million-people            58.8               57.52             57.48




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                2024               2023              2022
 Axiata Investments (Energi) Sdn. Bhd.                                           66.25               66.25              66.2
                                                               %
 Treasury Shares                                                                   0.43               0.43              0.43
 Public with Less than 5% Ownership                                               33.32              33.32             33.32



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                                                  About XL Axiata




Operational Area [OJK C.3]

Operational Area and BTS Network




                 WEST




                                 HQ &
                                 JABO   CENTRAL

                                                  EAST




     Network expansion is being pursued relentlessly, with
XL Axiata’s 4G network now encompassing 165,864 4G
BTS units and counting. This quality-lifting investment is
instrumental in improving service reliability and customer
satisfaction.

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                                             165,864
                                              4G BTS




HQ & JABO                                        CENTRAL
XL AXIATA TOWER                                  MARTADINATA
Jl. H.R Rasuna Said X5 Kav.11-12, Kuningan       Jl. R.E Martadinata No 7, Bandung
Timur, Setiabudi, Jakarta Selatan 12950          Jawa Barat

WEST                                             EAST
DIPONEGORO MEDAN                                 PEMUDA
Jl. Diponegoro No.5, Medan,                      Jl. Pemuda No 94-98 Kelurahan Embong
Sumatera Utara                                   Kaliasin, Kecamatan Genteng, Surabaya,
                                                 Jawa Timur


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                                                                                                          About XL Axiata




Business Activities
[OJK C.4] [GRI 2-6]



The Extraordinary General Meeting of Shareholders on            4. Programming activities, computer consulting, and
January 11, 2024 has approved the change in XL Axiata’s             related thereto:
main business activities and supporting business activities         a. Other computer programming activities;
as the Company decided to add its Business Activities               b. Artificial Intelligence-Based Programming Activities;
pursuant to the KBLI 2020 as stipulated in the Central              c. Programming and Production Activities of
Statistics Agency Regulation No. 2 of 2020 concerning the               Immersive Media Content;
Indonesian Standard Industrial Classification (“KBLI 2020”).        d. Digital Identity Provision Activities;
                                                                    e. Activities for Providing Electronic Certificates and
As outlined in the Article 3 of the Articles of Associations,           Services Using Electronic Certificates;
the Company operates in the sectors of telecommunications,          f. Blockchain Technology Development Activities
programming activities and computer consulting, information         g. Information Security Consulting Activities.
services activities, wholesale trade, management consulting     5. Computer Consulting Activities and Other Computer
activities, and financial activities.                               Facility Management:
                                                                    a. Internet of Things (IoT) Consulting and Design
To support the business activities, the Company is allowed              Activities;
to carry out the following main business activities:                b. Other Information Technology and Computer
                                                                        Services Activities.
1. Telecommunications business activities:                      6. Information Services Activities:
   a. Administration of telecommunications networks                 a. Data Processing Activities;
       including but not limited to:                                b. Hosting and activities related thereto;
       - Wired Telecommunication Activities;                        c. Web portals and/or digital platform Without
       - Wireless Telecommunications Activities;                        Commercial Objectives;
       - Satellite Telecommunication Activities;                    d. Web portals and/or digital platforms with
       - Special Telecommunication Activities for Own                   Commercial Objectives.
           Use;                                                 7. Other Information Services Activities NOC.
       - Special Telecommunication Activities for               8. Construction:
           Defense and Security Purposes;                           a. Telecommunication Central Construction;
       - Other Telecommunication Activities.                        b. Telecommunication Installation;
   b. The operations of telecommunications services                 c. Railway Signal and Telecommunication Installation;
       including but not limited to:                                d. Land Preparation.
       - Internet Service Provider;                             9. Employment Activities:
       - Data Communication System Services;                        a. Human Resources Provision and Management
       - Internet Telephony Services for Public Use                     Function;
           (VOIP);                                                  b. Fixed-term Labor Supply Activities.
       - Internet Interconnection Services (IIS);               10. Professional, Scientific and Technical Activities:
       - Content Provider Services through Cellular                 a. Other Management Consulting Activities;
           Mobile Networks or Local fixed Wireless                  b. Advertising.
           Networks with Limited Mobility (Premium SMS          11. Rental and Leasing Activities without Option Rights of
           Content Services);                                       Digital Technology Assistive Devices.
       - Other Multimedia Services;                             12. Owned or Leased Real Estate.
       - Telecommunication Resale Services;                     13. Other Monetary Intermediaries.
       - Internet Protocol Television (IPTV) Services.          14. Call Center Activities.
2. Other telephony value-added services.
3. Wholesale Trade                                              In order to achieve the above mentioned purposes, as well
   a. Wholesale Trade of computers and computer                 as to support the main business activities of the Company,
       equipment;                                               the Company may carry out supporting business activities
   b. Wholesale Trade of Software;                              as following:
   c. Wholesale Trade of Telecommunication Equipment;           a. Planning, engineering, building, providing, developing
   d. Wholesale Trade of Electronic Parts;                          and operating, leasing, maintaining as well as procuring
   e. Wholesale Trade of Machine, Equipment, and Other              means/facilities of telecommunication, including the
       Supplies.                                                    procurement of resources to support the businesses of




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   the Company in the administration of telecommunication         d. Organizing other telecommunication services and
   services and/or networks;                                         networks including information technology services
b. Improving to the maximum extent, the relevant business            and/or networks; and
   for the administration of services and telecommunication       e. Engaging in various necessary activities to support the
   networks, therefore, it reaches the capacity which is             operation of telecommunications, wholesale trading,
   desired and required by the public in the framework of            computer programming, consulting, and related services.
   improving services to the public at large;                        This includes information services, telecommunications
c. Carrying out businesses and operational activities                construction and installation, employment services,
   (which also cover the marketing as well as the sales              professional, scientific, and technical activities, and
   of telecommunication networks and/or services which               leasing digital technology without option rights.
   are organized by the Company), carrying out the                   Additionally, it encompasses real estate, financial
   maintenance, research, and development, means and/                services, management consulting, office administration,
   or facilities of the telecommunication, organizing non-           office support, advertising, and land provision.
   formal education and training in telecommunication
   sector both domestic and overseas;




Association Membership
[OJK C.5] [GRI 2-28]

Through the end of 2024, XL Axiata was a registered member of the following associations:


 No                         Organization Name                                 Role and Contribution of the Company
  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 Supervisory Board; Member
       (ASKITEL)
  7    Kamar Dagang dan Industri Indonesia (KADIN Pusat)                  Member
  8    Kamar Dagang dan Industri Indonesia (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




Significant Changes in the
Company [OJK C.5] [GRI 2-28]
At end of 2024, XL Axiata reached a definitive agreement for a proposed merger with PT Smartfren Telecom Tbk and PT Smart
Telcom. The merger will establish PT XL Smart Telecom Sejahtera Tbk, a new telecommunications powerhouse combining
strengths of Indonesia’s trusted telecommunications operators.




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Page 60
Process
Excellence
Page 61
    Adopting the ISO 27701
standards of Privacy Information
Management System (PIMS) which
focuses on the management
of personal data privacy. No
violation of the customer data or
information privacy policy as well
as no violation to product labeling
and marketing activities.
Page 62
                                                                                                           Process Excellence




Corporate Oversight

Governance has become a strategic imperative for many organizations and increasingly becomes a critical topic at board level
when it comes to the fulfillment of the responsibilities to the stakeholders. Therefore, in XL Axiata, our commitment to Good
Corporate Governance (GCG) implementation remains intact throughout the organization’s operations. The Company make
continuous improvements to the quality of the GCG implementation, encompassing various aspects of the Company, including
the risk management mechanism and the implementation of internal control, which provide a foundation for the establishment
of an accountable organization.




Corporate Governance

COMMITTED TO THE EFFECTIVE IMPLEMENTATION OF GCG PRACTICES

XL Axiata has laid down the implementation of Good Corporate Governance (GCG) as the foundation of its sustainability
commitment, in which the Company manages and optimizes the resources based on mechanisms that will guide it in carrying
out responsible business practices and achieve the sustainability goals.


As part of the implementation of sustainable governance practices, XL Axiata continues to increase participation of the
stakeholders in implementing GCG principles (transparency, accountability, responsibility, independence, equality, and fairness)
in addition to the Company’s sustainability pillars: Building Prosperity, Planet & Society, Nurturing People, and Process
Excellence, which have been essential aspects to consider in the decision making.


The implementation of GCG principles indeed has put highlight to the Company’s commitment to establishing a vibrant and
credible business environment. Accordingly, the Company always puts regulatory compliance as well as builds the good
reputation and accountability of the Company as two of priority aspects in order to gain trust from the public at large and
other stakeholders.


XL Axiata believes that the effective implementation of governance principles will ensure its business continuity and bring
positive impact on the Company’s reputation. XL Axiata is determined to implement sound GCG practices to help shape the
competitiveness in the dynamic business situation.


Basic Guidance to Sustainable Governance
XL Axiata’s commitment to the implementation of sustainable governance is guided by the Law of the Republic of Indonesia
No. 40 of 2007 on Limited Liability Companies (“Company Law”) and its implementing regulations as well as Law of the
Republic of Indonesia No. 8 of 1995 on Capital Market, OJK Regulation No. 51/POJK.03/2017 on the Application of Sustainable
Finance for Financial Service Institutions, Issuers and Public Companies, and SEOJK No. 16/ SEOJK.04/2021 on the Formats
and Contents of Annual Report of the Issuers or Public and POJK No. 51/POJK.03/2017 concerning the Implementation of
Sustainable Finance for Financial Service Institution, Issuers, and Public Companies.




           The implementation of GCG principles indeed
      has put highlight to the Company’s commitment
      to establishing a vibrant and credible business
      environment.


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The Implementation of GCG Principles at XL Axiata
The implementation of the GCG principles in every aspect of the Company’s business operations is further explained as follows:




 ETHICAL CONDUCT                                                             ACCOUNTABLE
 XL Axiata always ensures that the decision-making process in the
                                                                             XL Axiata has determined segregation of
 company is free from conflict of interest and that any corporate
                                                                             duties, authorities, and responsibilities of each
 actions containing conflict of interest must be completed with
                                                                             organ of the Company in accordance with the
 respect to applicable regulations. XL Axiata also ensures that all
                                                                             Articles of Association, OJK regulations and
 shareholders and other stakeholders are treated equally and each
                                                                             internal policies to avoid conflicts of interests
 organ of the Company carries out its duties and responsibilities
                                                                             and establish an accountable organization.
 independently.




 DIGITALIZATION                                                         SUSTAINABILITY

 XL Axiata benefits from the digitalization in order to enhance         XL Axiata’s commitment to implementing principles
 business growth, improve the efficiency of its business                of Environmental, Social, and Corporate Governance
 processes, and deliver consistency and quality to promote              encompasses all aspects of its operations. The
 better customer experience. It will also enable the organization       Company adheres to responsible business practices
 and its Board Members to evolve and adjust to the ongoing              to ensure its operations generate positive impacts on
 wave of business model disruptions by embracing the                    the environment and society, reflecting the Company’s
 modification of its internal governance techniques, Board              dedication to long-term value creation and ethical
 leadership, structure, and processes.                                  business conduct.




 TRANSPARENCY

 XL Axiata upholds transparency through the implementation of information disclosure to the stakeholders using various
 channels of communication, including digital channels. The Company’s transparency is measured through its reports,
 corporate announcements, and other materials, both printed and digital, which are accessible for all stakeholders. The use of
 digital technologies in XL Axiata’s transparency of information not only supports efficiency and effectiveness in Corporate
 Communications activities yet it is also considered important to ensure the Company’s continuous engagement with its
 stakeholders at large.




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                                                                                                          Process Excellence




STRUCTURE AND COMPOSITION OF SUSTAINABILITY GOVERNANCE [GRI 2-9] [GRI 2-11]

To ensure the effective implementation of GCG at XL Axiata, the Company has established a structure with organs that
perform different functions, authorities, and responsibilities to ensure the execution of sustainability strategies and manage
the impacts of its business presence to the society and environment as well as the surrounding economy. XL Axiata’s GCG
structure consists of Main Organs and Supporting Organs explained further as follows:




                                    General Meeting of Shareholders




                     Board of                                               Board of
                     Directors                                            Commissioners



                     President
                                                         Nominating                             Board Risk
                  Director & CEO                                            Board Audit
                                                       & Remuneration                          & Compliance
                                                                            Committee
                                                         Committee                              Committee


                     Directors

                                                  Corporate
                                                  Secretary
                   Committees
                 under the Board
                   of Directors
                                                Internal Audit



                                                   Risk &
                                                 Compliance


                                                Sustainability
                                                    Unit




General Meeting of Shareholders                                   Board of Commissioners
As the ownership organ of the Company, the General                The Board of Commissioners serves as our Supervisory
Meeting of Shareholders (GMS) is delegated with a set of          Organ which is responsible for monitoring, overseeing
authorities not granted to either Board of Directors or the       as well as advising the Board of Directors in regard to
Board of Commissioners within the limits specified in the         the management activities and the GCG implementation
Articles of Association and applicable laws and regulations.      in the Company. The Board of Commissioners is also
Through GMS, XL Axiata facilitates its Shareholders to            allowed to request reports about the company’s business
exercise their rights and authorities to state their inputs,      performance, review, sign, and ratify annual reports as well
opinions, vote and request information that is material in the    as assess audit reports and monitor the implementation of
decision making process.                                          risk management.


In a year, XL Axiata can hold two types of GMS, i.e. Annual GMS   In addition, XL Axiata’s Board of Commissioners is also
and Extraordinary GMS. The mechanisms for holding each of         responsible for providing suggestions to shareholders
GMS has been outlined in the Company Law, the Articles of         regarding important issues faced by XL Axiata. The Board
Association and OJK regulations. In 2024, XL Axiata had an        of Commissioners carries out its duties and responsibilities
Annual GMS on May 3, 2024 where the Company agreed on             with assistance from the Board Audit Committee, the
several important decisions. Further information about the        Nominating and Remuneration Committee and the Board
implementation of GMS in 2024 is presented in XL Axiata’s 2024    Risk and Compliance Committee.
Annual Report which is published in a separate document from
this Sustainability Report.




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In its duty implementation, XL Axiata’s Board of Commissioners must respect the independence principle so as to make
decisions in an objective manner.


The members of Board of Commissioners as of December 31, 2024 were as follows:

         Name               Position         Period       Term of Office                 Legal Basis of Appointment
 Dr. Muhamad Chatib         President      2024-2029            3 Period
                                                                 rd
                                                                                He was first appointed Commissioner at the
 Basri                    Commissioner                                          General Meeting of as President Extraordinary
                                                                                Shareholders (EGMS) on 29 September 2016,
                                                                                and then reappointed at the Annual General
                                                                                Meeting of Shareholders (AGMS) on 29 April
                                                                                2019 for the 2nd term and on 3 May 2024 for
                                                                                the 3rd term.
 Vivek Sood               Commissioner     2019-2024            3rd Period      He was first appointed as Commissioner of the
                                                                                Company during the Annual General Meeting of
                                                                                Shareholders (AGMS) on 31 March 2017.
                                                                                Reappointed for a second term as Commissioner
                                                                                at the AGMS on 29 April 2019 and on 3 May
                                                                                2024 for the third time.
 Dr. Hans                 Commissioner     2024-2029            2nd Period      Appointed as Commissioner during the Annual
 Wijayasuriya                                                                   General Meeting of Shareholders on 18 May
                                                                                2020 for his first term and on 3 May 2024 for his
                                                                                second term.
 Nik Rizal Kamil          Commissioner     2024-2029            1st Period      Appointed at AGMS on 3 May 2024 for his first
                                                                                term.
 Yasmin                   Independent      2024-2029            1st Period      Appointed at AGMS on 3 May 2024 for the first
 Binti Aladad Khan        Commissioner                                          term.
 Julianto                 Independent      2024-2029            3rd Period      Appointed as Independent Commissioner of the
 Sidarto                  Commissioner                                          Company through the Annual General Meeting
                                                                                of Shareholders on 9 March 2018 for his first
                                                                                term, and reappointed for the second term at
                                                                                the Annual GMS on 29 April 2019 and on 3 May
                                                                                2024 for his third term.
 Didi       Syafruddin    Independent      2024-2029            1st Period      Appointed for his first term at AGMS on 3 May
 Yahya                    Commissioner                                          2024.


Board of Directors
The Company Board of Directors serves as the managing organ of the Company which is also responsible for the implementation
of good corporate governance principles and represents The Company inside and outside the court as regulated in the Articles
of Association. The Board of Directors consists of 6 (six) members and is led by a President Director who is responsible for
coordinating the activities of the whole members of the Board of Directors. The Board of Directors has a significant role in
the decision making process, and, determines the sustainability strategies and risk management, including social, economic,
environmental impacts, and climate actions. The Board of Directors runs the Company with assistance from Information
Technology Committee, Risk Management and Business Continuity Committee, Human Capital Committee, Gifts, Donations
and Sponsorships Committee, Ethics and Integrity Committee, Corporate Secretary, Internal Audit and Risk & Compliance.


XL Axiata’s members of Board of Directors as of December 31, 2024 were as follows:

     Name                Position          Period      Term of Office                  Legal Basis of Appointment
 Dian Siswarini      President Director   2024-2029       3 Period
                                                           rd
                                                                             She was first appointed as President Director of the
                     & Chief Executive                                       Company at the Annual General Meeting of
                     Officer (CEO)                                           Shareholders (AGMS) on 1 April 2015, and
                                                                             reappointed for a second term at the AGMS on 29
                                                                             April 2019 and on 3 May 2024 for her third term.
 David Arcelus       Director & Chief     2024-2029      2nd Period          He was first appointed as Director at the Annual
 Oses                Commercial Officer                                      General Meeting of Shareholders (AGMS) on 18 May
                     - Consumer (CCO -                                       2020 and reappointed for the second term on 3
                     Consumer)                                               May 2024.
 Abhijit Jayant      Director & Chief     2024-2029       3rd Period         He was first appointed as Director of the Company
 Navalekar           Commercial Officer                                      during the Extraordinary General Meeting of
                     –      Home     &                                       Shareholders (EGMS) on 15 August 2017. He was
                     Convergence                                             reappointed for his second term during the Annual
                     (CCO - Home &                                           General Meeting of Shareholders (AGMS) on 29
                     Convergence)                                            April 2019 and on 3 May 2024 for his third term.




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     Name               Position             Period       Term of Office              Legal Basis of Appointment
 Yessie Dianty     Director & Chief        2024-2029         3 Period
                                                              rd
                                                                           Appointed as Independent Director of the
 Yosetya           Enterprise Business                                     Company at the Extraordinary General Meeting of
                   &                                                       Shareholders (EGMS) on 10 March 2016. She was
                   Corporate Affairs                                       appointed as Director for the second trem at the
                   Officer                                                 Annual General Meeting of Shareholders (AGMS) on
                                                                           29 April 2019 and on 3 May 2024 for her third term.
 I Gede            Director & Chief        2024-2029         2nd Period    Appointed as Director for the first term at the
 Darmayusa         Technology Officer                                      Extraordinary General Meeting of Shareholders
                   (CTO)                                                   (EGMS) on 27 October 2020 and reappointed for
                                                                           his second term at AGMS on 3 May 2024.
 Feiruz Ikhwan     Director & Chief        2024-2029         2nd Period    Appointed as Director for his first term at the
                   Finance Officer                                         Annual General Meeting of Shareholders (AGMS) on
                                                                           5 May 2023 and reappointed for his second term
                                                                           on 3 May 2024.
 Rico Usthavia     Director & Chief IT     2024-2029         1st Period    Appointed for his first term at AGMS on 3 May
 Frans             Digital Officer                                         2024.



Information about profile of the governance body consists of work experience, education, gender and the others are available
in 2024 Annual Report.

Sustainability Unit [OJK E.1]
The Company has assigned a Sustainability Team under the Corporate Communications and Sustainability Department
to ensure the effective implementation of sustainability strategies at all work units under the supervision of the Board of
Commissioners and Directors. Our President Director & CEO leads the Sustainability Team so as to ensure the alignment of the
corporate strategies and the sustainability strategies and no conflict of interest in the decision-making process. The structure
of the Company’s sustainability team is presented as follows:



                                                  President Director & CEO



                                           Director & Chief Enterprise Business and
                                                   Corporate Affairs Officer



                                                  Chief of Corporate Affairs



                                          Group Head Corporate Communications &
                                                      Sustainability



                                                      Head of Sustainability




                                      People reporting to Head of Sustainability:
                                      ‘ Climate Change and Decarbonization Strategist
                                      ‘ Social Impact and Governance Coordinator




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      Name                          Position                    Term of Office          Legal Basis of Appointment
 Marwan O.            Chief Corporate                            24 November     Decree of BOD No. 47/20 dated 24
 Baasir               Affairs                                   2020 – present   November 2020
 Reza Zahid Mirza     Group Head Corporate Communications        15 October      Employee Appointment Announcement
                                                                2023 - present   No. 37/2023
 Ratu    Maulia Head of Sustainability                          9 March 2024 -   Employee Appointment Announcement No.
 Ommaya Firhah                                                     present       11/2024
 Risky       Fauzi Climate Change and Decarbonization            5 June 2023     -
 Widodo            Strategist
 Asri        Ariani   Social   Impact    and     Governance     1 January 2023   -
 Fauziah              Coordinator




NOMINATION AND SELECTION OF                                       The Nominating and Remuneration Committee plays a key
GOVERNANCE BOARD [GRI 2-10]                                       role in the nomination of a Director candidate. A Director
                                                                  can also appoint XL’s own personnel as his successor,
Mechanism for the nomination of XL Axiata’s executive             including employees who join in XL Axiata Talent Pool. The
members is regulated under Senior Executive Nomination            procedures for the appointment of a director candidate
Policy. According to the policy, the Shareholders and/or          are regulated in the Nomination Policy and shall take into
the Minority Shareholders of the Company shall propose            account the Company Law and other regulations relating
the candidates eligible for members of the Board of               to the appointment of a director. The Company will then
Commissioners and then submit them to XL Axiata’s                 review the Director candidates on periodical basis through
Nominating and Remuneration Committee through the                 an internal panel system or assign an independent third
Corporate Secretary for further review.                           party to assess their competence.


The Nominating and Remuneration Committee will discuss the        In the meantime, while appointing the Head of Sustainability
nomination proposals in the Nominating and Remuneration           Unit, the Company will refer to the qualifications set in the
Committee Meeting to ensure that all candidates have met          recruitment policy.
the required criteria, qualifications and backgrounds to be
further submitted to the GMS for approval. The Company            THE ROLES OF XL AXIATA’S GOVERNANCE
applies the criteria and qualifications as outlined POJK          BODY IN IMPACT MANAGEMENT [GRI 2-12]
No. 33/POJK.04/2014 for the appointment of member                 [GRI 2-13]
candidates of the Board of Commissioners of XL Axiata.
                                                                  As it navigate to be a greener organization, the Board
The Company also takes into account the results of reviews        of Commissioners and Board of Directors share mutual
of the organizational needs to help it determine the ideal        responsibilities for aligning the company’s strategies
composition, backgrounds and expertise required from              and direction with the sustainability policies, strategies,
the Board candidates. The Board diversity is necessary            and goals in social, economic, and environmental topics,
as they will bring together different skills, viewpoints and      including climate change issues.
backgrounds to help them in planning, oversight and making
high-quality decisions, translating into more strategic           The Board of Commissioners and Board of Directors
guidance and risk management.                                     together with the Sustainability Team will carry out
                                                                  thorough evaluation and identification of the impacts of the
The highest governing bodies of the Company adhere to the         Company’s operations, both directly and indirectly, and the
principle of independence and are free from any conflicts of      effectiveness of its sustainability policies and initiatives. In
interests.                                                        the identification process, consultations with stakeholders
                                                                  such as shareholders, regulators, the community and other
In the meantime, XL Axiata applies a Succession Policy            parties can help them gain some insights and necessary
in Board of Directors nomination process as part of the           inputs which will be treated as material aspects in the
regeneration of leadership as well as to maintain business        making of strategic decisions. This consultation can be in the
continuity of the Company. The Board of Directors                 form of face-to-face meetings, online meetings, or through
Succession Policy stipulates that candidates are entitled to      reports prepared by the Sustainability Team. The frequency
participating in self-development and personal development        of meetings or reports is adjusted to the needs.
activities, such as trainings or through a teamwork system to
solve certain problems.




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In further implementation of sustainability governance, the Board of Commissioners and Board of Directors delegate
responsibility for managing sustainability impacts to the Head of Sustainability, who is under direct supervision of Group
Head of Corporate Communications and Sustainability, and reports to the Chief of Corporate Affairs. XL Axiata’s Head of
Sustainability is responsible for:
1. Improving monitoring of sustainability activities;
2. Designing sustainability strategic initiatives and measuring their impacts;
3. Ensuring stakeholder measurement as key to monitoring sustainability achievement.


The followings are the duties and responsibilities of the roles of XL Axiata’s governance body in the management of sustainability
impacts within XL Axiata:
                     Designation                                                   Scope of Duties
 Climate Change and Decarbonization Strategist          It serves the role of ensuring the environmental-related performances
                                                        across the company such as: environmental-related data monitoring,
                                                        reporting and verification, developing net zero roadmap as part of
                                                        decarbonization journey, corporate sustainability strategy, and the
                                                        others.
 Social Impact and Governance Coordinator               It serves the role of ensuring social and governance data collection,
                                                        monitoring, conducting sustainability-based event and communication
                                                        campaigns.

Through the RBCC (Risk Management and Business                      them, which represent the indicators for the performance
Continuity Committee), and BRCC (Board Risk & Compliance            evaluation including Integrity, Leadership skills: Team
Committee), the Company’s highest sustainability governing          player/Communicator, Analytical: Analyse and Interpret
body conducts review of the reporting quality of XL Axiata’s        Information, Specialist Skills and Knowledge, and Thinker
ESG performance on quarterly basis to ensure data accuracy          - Open-minded/Strategic. To pursue objectiveness in the
and consistency. Then at year end, XL Axiata will present a         assessment process, the Company appoints the Nominating
full-year consolidated ESG performance data. In addition,           and Remuneration Committee to launch a self-assessment
the highest governing body can also add more aspects, such          of the Board of Commissioners.
as carbon emission, climate change, employment practices,
waste management, privacy & data security and other                 In the meantime, the General Meeting of Shareholders
issues considered material to the Company’s sustainability          will assess the collegial performance of the Board
impacts, as outlined in XL Axiata Materiality Assessment.           of Commissioners in the financial year based on the
                                                                    accountability report on Board of Commissioners’
PERFORMANCE ASSESSMENTS OF THE                                      supervisory duties presented in the Annual General Meeting
GOVERNANCE BODY [GRI 2-18]                                          of Shareholders. The General Meeting of Shareholders will
                                                                    then make decision on granting full repayment and release
To build a sustainable business and improve the quality of          of responsibility (acquit et de charge) to the Board of
governance, XL Axiata has a policy to make continuous               Commissioners of XL Axiata for supervisory performance
improvements to the implementation of sustainable                   during the Reporting Year.
governance. The Company therefore conducts evaluation
of the performance of the Governance Body, ensuring that            Assessment Mechanism of Performance of the
each organ of XL Axiata Governance Body is committed to             Board of Directors
performing their duties in accordance with the Company              The Board of Directors is assessed for both collegial
Law and prevailing regulations and meet the agreed targets          and individual performances, by the Nominating and
through the implementation of responsible operational               Remuneration Committee and through self-assessment.
practices. The performance assessment mechanism for                 The individual performance of each member of the Board
each XL Axiata Governance Body is explained as follows:             of Directors is assessed the Nominating and Remuneration
                                                                    Committee based on Key Performance Indicators (KPI) as
Assessment Mechanism of Performance of the                          well as the Company’s achievements and target fulfillment
Board of Commissioners                                              (if any). Meanwhile, collegial performance of the Board of
The Company applies 2 (two) mechanisms to assess Board              Directors is assessed through an accountability report
of Commissioners’ performance, namely through the                   on the company management as well as financial and
General Meeting of Shareholders and self-assessment. XL             operational achievements presented in the GMS. The GMS
Axiata applies a quantitative approach in the assessment            will then make decision on granting full repayment and
of performance of the Board of Commissioners. As part               release of responsibility (acquit et de charge) to the Board
of the cross-board assessments, the method requires each            of Directors for the management of the company during the
Board member as well as the Committees under the Board              Financial Year.
of Commissioners to fill in questionnaires distributed to




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Assessments   Results  of    the   Board                      of     Assessment of the Head of the Unit in Charge of
Commissioners and Board of Directors                                 Sustainability
In 2024, XL Axiata had an independent assessment of Board of         Adding to the general assessment criteria, XL Axiata
Commissioners and Board of Directors, in which Board members         also launched an assessment of performance of Head
were assessed for their understanding of the roles, duties and       of Sustainability to measure the effectiveness of our
responsibilities as well as the implementation of principles of      sustainability strategy implementation. The sustainability
Good Corporate Governance (“GCG”). Through the assessment,           assessment is held to ensure that the Company has
the Company could measure Board Effectiveness and get some           established a harmonious stakeholder relationships and
recommendations for GCG improvement as well as one of the            deliver impactful benefits to the sustainability program
considerations for the reappointment or even dismissal of the        beneficiaries as expected.
members of Board of Commissioner and the Board of Directors.
The results of the 2024 assessment of the performances of            Total Attendance Rates of the Board of Directors
Board of Commissioners and Board of Directors suggested              and Board of Commissioners at Board Meetings
that both Board of Commissioners has carried out the role of         [GRI 2-16]
supervising organ within the scope of duties and responsibilities    The Board of Directors and the Board of Commissioners
specified in the articles of association, prevailing regulations     of the Company are required to attend each of internal
and relevant standards. Meanwhile the Board of Directors was         board meetings which are conducted on a periodical
assessed to have fulfilled its role of being a managing organ        basis. In addition, the Board of Directors and the Board
of the Company pursuant to the Key Performance Indicators            of Commissioners are also required to attend joint
applied to Board of Directors as well as to the Company, which       meetings, showing the engagement of members of the
were agreed in the beginning of the year.                            Board of Directors or Commissioners to produce strategic
                                                                     decisions effectively and to carry out supervision over
                                                                     the management of the company. The information on the
                                                                     attendance rate of the Board of Directors and the Board of
                                                                     Commissioners at the board meetings in 2024 is presented
                                                                     in the following table:



                                                                                                   Percentage of Average
                                                                                                  Attendance of Board of
                                                               Total Board Meetings                  Directors/Board of
                     Description
                                                                      (2024)                      Commissioners at Board
                                                                                                          Meetings
                                                                                                           (2024)
 Total attendance rate of Board of Directors at                           59                                100%
 board meetings
 Total attendance rate of Board of Commissioners                          24                                100%
 at board meetings


REMUNERATION POLICY AND PROCESS                                      1. GMS will delegate power and authority to the
[GRI 2-19][GRI 2-20]                                                    Nominating and Remuneration Committee to determine
                                                                        the remuneration package including the structure
Remuneration of The Board of Commissioners                              and amount of salary, bonus and other benefits for
and Directors                                                           members of the Board of Commissioners according
XL Axiata understands that the executive compensation                   to the Company’s remuneration policy and applicable
can positively impact the business continuity of the                    standards for the relevant financial year
Company. Thus, as part of the efforts to fulfill the economic        2. GMS grants the power and authority to the Board
responsibilities to our internal stakeholders, XL Axiata                of Commissioners of the Company to determine the
has an attractive remuneration system which ensure our                  remuneration package including the structure and
executive Board members to be able to formulate and                     amount of salary, bonus and other benefits for members
deliver sustainability strategies to make progress to the               of the Board of Directors according to the Company’s
relationship between the Company, the environment, and                  remuneration policy and applicable standards for the
the community.                                                          relevant financial year.


The mechanism for determining remuneration for the Board
of Directors and Board of Commissioners of XL Axiata is
through the General Meeting of Shareholders (GMS). The
procedures are:




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Apart from the internal remuneration policy and applicable      Remuneration of Sustainability Unit
standards, XL Axiata also considers aspects including the       XL Axiata always strives to offer a competitive and attractive
results of evaluation of the Company’s and individual’s         remuneration package for its best talents, including the
target fulfillment, industry benchmarking, non-monetary         Head of Sustainability who is responsible for overseeing the
benefits as well as the work of individuals and the             implementation of sustainability strategies. The Company
Company. The Company also evaluates the amount of               accordingly has applied a remuneration scheme that is
each remuneration to ensure that the remuneration remains       aligned with that of other Company employees for the Head
competitive and attractive in accordance with market            of Sustainability.
conditions. With the assistance from the Nomination and
Remuneration Committee, the Board of Commissioners has          ANNUAL COMPENSATION RATIO [GRI 2-21]
the responsibility for overseeing the implementation of the
Remuneration Policy, including conducting an evaluation of      As the Company values every contribution of its employees,
the policy implementation periodically.                         XL Axiata is aware of the importance of providing
                                                                competitive and attractive remuneration and benefits to
                                                                retain the best talents in its team. XL Axiata ensures that
                                                                employees, including the management members, receive
                           GMS
                                                                equal pay for comparable work and experience. The fair
                                                                compensation is part of a reward system and is determined
                                                                with reference to the industry standards as well as the
  Authority to                                                  applicable labour laws and regulations.
                                            Authority to
 Nominating &
                                            the Board of
 Remuneration
  Committee
                                           Commissioners        MANAGEMENT OF CONFLICTS OF
                                                                INTEREST [GRI 2-15]
                    Recommendations
                      of Nominating                             To ensure the organizational sustainability, XL Axiata
                     & Remuneration                             regulates conflict management to to help it identify and
                       Committee                                handle conflict of interests fairly and effectively. The effective
                                                                implementation of conflict management is also expected to
 Determination                             Determination        minimize the potential negative impacts that can arise from
  of Board of                               of Board of         disagreements in decision-making process that engage
 Commissioners                               Directors
                                                                Supreme Governance Body and other Corporate Organs.
    salaries                                  salaries

                                                                XL Axiata’s conflict management policy requires parties who
Remuneration Structure of Board of Directors                    have a conflict of interest in issues being discussed in the formal
and Board of Commissioners                                      meetings to not join the meetings. They are also required to
The Company provides remuneration packages consisting of        sign on a statement of independence ensuring that they remain
fixed and variable income. Structure of fixed income of the     independent in meetings or discussions where they have conflict
Company paid to Board of Directors consists of basic salary,    of interests. The Company assigns the Corporate Secretary to
allowances (housing, transportation, telecommunication,         oversee the policy implementation.
and other regular allowances) which are all paid at end of
the month and Religious Holiday Allowance which is paid         In addition, XL Axiata applies OJK Regulation No. 42/
ahead of the religious holiday. Meanwhile, the variable         POJK.04/2020 concerning Affiliate Transactions and Conflict
income consists of bonus which is paid at certain amount in     of Interest to regulate transactions or activities engaging
accordance with individual and the company’s performances       affiliated parties. Any transactions that are deemed material
and at certain date determined by the company.                  and engage affiliated parties shall be approved by the
                                                                shareholders and reported to the authorities in a disclosure
Then, Board of Commissioners of the Company is eligible         information.
for monthly remuneration package which consists of fixed
income, they are basic salary and allowances (transportation,
telecommunication and other regularly paid allowances)
and Religious Holiday Allowance which is paid ahead of the
religious holiday.




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Concerning the significant impacts of such transactions or activities containing conflicts of interests, the Company as of
mid-2021 has been consistently socialized the regulation to the internal units to raise their awareness of the importance of
conflict management to the Company’s business continuity. XL Axiata has also introduced to the units the Standard Operating
Procedures (SOPs) for Affiliate Transaction Capital Market Reports.


Other efforts to address conflict of interests include encouraging the implementation of code of conduct in any activities of the
employees, including in interacting with colleagues, customers and other partners. The Code of Conduct regulates the ethical and
behavioral standards, which are significant factors to help the Company maintain the stakeholders’ trust as well as to build integrity at
a vibrant workplace for everyone. Board of Commissioners and Board of Directors have approved the Code of Conduct and Board of
Directors is delegated with authority to supervise the implementation.


In 2024, the Company did not identify any conflicts of interests pertaining to cross-broad membership, share ownership across
organizations conflicts with suppliers and other stakeholders, controlling shareholders, as well as affiliated transactions.


SUSTAINABILITY TRAINING AND COMPETENCY DEVELOPMENT PROGRAM [OJK E.2] [GRI 2-17]

Each of members of Board of Directors and Board of Commissioners pursue continuous developments on the competence to
support their duty implementation. Among the competence development activities, they join in seminars, trainings or become
speakers in the events relating to the industey where the Company operates. This policy is outlined in the Board Manual
presented in the 2024 Annual Report.


The Company consistently enhances the understanding and competence of its sustainability team members. Thus in 2024,
XL Axiata provided the sustainability team members with an opportunity to participate in any trainings and competency
development activities to help them better understand the values of sustainability. The trainings were:


      Name of
                                       Training Name                               Place/Date                       Organizer
     Participant
    Ratu Maulia                    IDX Net Zero Incubator                 Jakarta, August – November             Indonesia Stock
   Ommaya Firhah                                                                     2024                        Exchange (IDX)
 Risky Fauzi Widodo                IDX Net Zero Incubator                 Jakarta, August – November             Indonesia Stock
                                                                                     2024                        Exchange (IDX)
                            Workshop Sustainability Reporting:               Jakarta, October 2024            Indonesia Financial
                             Standards and Implementation                                                   Authority (OJK) Institute
                              KADIN Net Zero Hub Training:                   Jakarta, August 2024             Indonesia Business
                          Developing a Corporate GHG Emissions                                               Council for Sustainable
                                Inventory (Scope 1 and 2)                                                    Development (IBCSD)




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Reporting

STAKEHOLDER RELATIONS [OJK E.4] [GRI 2-29]

The best performance is built upon a solid teamwork. Thus, XL Axiata, strives to establish a vibrant work environment where
the Company respects the internal stakeholders, namely the employees, and establish a good industrial relationship that will
facilitate everyone to nurture their talent, creativity and develop the culture of innovation.


At the same time, XL Axiata consistently increase the participation of external stakeholders while making decisions relating to
the Company’s business operations to ensure that XL Axiata can deliver impactful benefits to all of stakeholders. To increase
the stakeholder engagement, XL Axiata has conducted the stakeholder mapping to help it identify which stakeholders that
are impacted or benefited most from its operations. XL Axiata applies principles that are described in AA1000 Stakeholder
Engagement Standard (AA1000SES) 2015 issued by Accountability. The principles guide XL Axiata in identifying stakeholders
in accordance with elements of Dependency (D), Responsibility (R), Tension (T), Influence (I), Diverse Perspective (DP), and
Proximity (P). Below is the description of XL Axiata’s relationship with its internal and external stakeholders.


                  Assignment
 Stakeholder                          Engagement Methods               Frequency                Topics/Issues Covered
                     Base
 Customers       D, R, T, I       •   Website and frontline       •   At   any    time   •   Achieving service satisfaction
                                      information                     when necessary.    •   Information on the latest products
                                  •   In-person visits            •   Once a year            and services of the Company
                                  •   Call Center Services.                              •   Obtaining solutions if there are
                                  •   Customer Satisfaction                                  questions or complaints on
                                      Survey                                                 services, 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 regulatory
                                  reports                                                compliance
 Employees       D, R, T, I       •   Internal Media (Magazine)   •   Once every 3       •   Socialization of policies and
                                  •   Employee Satisfaction           (three) months         strategies relating to employment
                                      Survey                      •   Once a year        •   Measuring employee satisfaction
                                  •   Townhall meeting (using                                rate and capture their ideas and
                                      hybrid method)                                         aspirations
 Trade Unions    D, R, T, I       Discussion of Bipartite         •   Once in three      Creating a vibrant work environment
                                  Collective Labour                   years              to pursue a harmonious bipartite
                                  Agreement (Bipartite            •   When necessary     relationship
                                  Cooperation Institution)
 Suppliers       D, R, T          •   Employment contract         If needed              •   Transparent procurement process
                                  •   Investment partners                                •   Obtaining a mutually beneficial
                                  •   Seminars and workshops                                 cooperation
 Non-            D, R, T, I, DP   Strategic cooperation to When necessary                Optimizing the impacts of the
 governmental                     carry out programs of                                  Company’s      CSR     program
 organizations                    Corporate Responsibility for                           implementation
                                  both social and environmental
                                  aspects
 Media           T, I, DP         Publication of press releases   When necessary         •   Accurate and trustworthy source
                                                                                             of information
                                                                                         •   Fulfilling   public information
                                                                                             disclosures




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                  Assignment
 Stakeholder                           Engagement Methods            Frequency                   Topics/Issues Covered
                     Base
 Community        D, R, T, I, DP   •   Meeting during social or   When necessary         •    Digital Literacy for Women
                                       CSR activity                                      •    Workshop
                                       implementation                                    •    Donation for Pesantren (Islamic
                                                                                              Boarding School) and Community
                                                                                         •    Impacted to Natural Disaster
                                                                                         •    Internet      Package    Donation
                                                                                              Movement (GDK) for Educational
                                                                                              Institution


In addition, the Company also engages the stakeholders            implementation of Risk Management System is aimed at
in determining the material topics that are most relevant         ensuring that the Company has implemented an adequate
environmental, social and governance (ESG) issues that            risk management system across its corporate governance,
XL Axiata shall address. The Company therefore applies a          business activities and operations, and the Company’s work
double materiality assessment with aim to identify material       culture. In its ERM Framework, the Company also include
topics that reflect actual or potential impacts of XL Axiata’s    identification and monitoring of ESG-related risks including
activities on the people or the environment as well as on         physical and transitional risks. Physical risks relate to physical
material topics that generate a material effect on XL Axiata’s    impacts of climate change whereas transitional risks related
financial performance.                                            to the transition to low-carbon economy.


The assessment was carried out in three stages with               XL Axiata’s risk management consists of determination of
activities in each stage including benchmarking through           the risk appetite, risk identification, analyses, and evaluation.
desktop research, deploying an online survey and organizing       Upon knowledge of each risk, the Company will prepare
meetings as well as a workshop that engaged internal              the mitigation measures and will apply tight monitoring
stakeholders (Board of Directors, Board of Commissioners,         and review of every work process. Among the risks to
Chiefs and Group Heads). In 2024, XL Axiata engaged a             consistently monitor and supervise are capital and debt
third party to conduct a materiality assessment whose             requirements as part of the sustainable financial action. The
results are already disclosed in the Chapter of Sustainability    Company has designed a policy on capital and debt structure
Approach in this 2024 Sustainability Report.                      to ensure the strategies regarding those aspects in line with
                                                                  the Company’s strategic objectives and risk appetite. XL
RISK ASSESSMENT OF SUSTAINABILITY                                 Axiata’s top management, namely Board of Commissioners
IMPLEMENTATION [OJK E.3]                                          and Board of Directors as the highest governance body
                                                                  plan, will launch discussion and supervision over with the
The implementation of sustainability risk management is           capital and debt requirements the support of market and
becoming significant as part of the Company’s business            business analysis.
strategy to align profitability goals with is environmental,
social and governance policies. Through the implementation        XL Axiata’s Risk Management Supervision Structure applies
of sustainability risk management, management of XL               Three Lines Model, a risk management approach which
Axiata will be assured that the Company has efficient and         helps the Company in risk identification and management
aligned strategies to address potential risks and realize the     as well as in preparing the mitigation steps effectively based
future opportunities.                                             on each characteristic of the risk. This risk management
                                                                  approach will limit any gaps while preventing duplication
To ensure the effectiveness of sustainability risk                of coverage. The Company applies Risk and Control Self-
management, the Company applies a Risk Management                 Assessment (RCSA) techniques for its Risk Management,
System as part of our Enterprises Risk Management (ERM)           allowing business owner to identify, manage and control
Framework into which XL Axiata integrate the principles           risks with significant impact on business objectives. The
of ISO 31000 framework, which has been guiding XL                 RCSA also helps the Company to prepare effective risk
Axiata in formulating and implementing sustainability risk        mitigation plans.
management as well as executing ESG strategies. The




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Risk Rating Matrix                                                 •   Market Risks
XL Axiata has developed a Risk Rating Matrix with reference            Risks associated with the market and country that XL
to Risk Assessment Guideline. The matrix serves as the                 Axiata is operating which may also include risk related
foundation for the Company in assessing the identified risks           to industry and competition. The Company has shifted
while giving adequate assurance to the Company that the                its floating rate debt into fixed-rate debt through the
risk management actions and resources were effective in                issuance of sharia bonds and bonds.
every business aspect and functions. Risk Rating Matrix also
helps the Company to determine the levels of risk appetite         •   Geopolitical Risks
and risk tolerance which are monitored by the management               Risks relating to any political changes or instability in
and formally reviewed as part of the Company’s strategy                a country such as a change in government, legislative
and planning process. The Company shall take a quick                   bodies, other foreign policymakers or military control
response against any risk that exceeds the appetite level. It          that may impact XL Axiata investment returns or
is then communicated to the respective Director/Chief and              impacting our operating company operations.
reported in the RBCC meeting to get an approval on the
mitigation plan.                                                   •   Governance Risk
                                                                       Risk that is associated with upholding and adopting
The followings are risk types identified in 2024 and their             good governance practices in ensuring operational
mitigations:                                                           excellence which may include non-compliance to
• Strategic & Investment Risk                                          policies, procedures, processes and internal control.
    Risks that could significantly impact the XL Axiata’s
    strategic activities, decision making and its achievement      •   Technology Risks
    of business objectives as well as risks that should be             Risk to information technology or data or applications
    predicted or monitored by Senior Leadership Team (SLT)             that negatively impact business operations. This could
    as part of strategic planning and review mechanism.                cover a range of scenarios, including software failures
                                                                       or a power outage. XL Axiata has strong commitment
•    Financial Risks                                                   to customer data privacy, integrity and availability
     Financial risks were risks associated with financial              while increasing the infrastructure capacity, including
     management of XL Axiata, comprising the stability                 by modernizing the network, increasing the network
     of the company’s financial position given its exposure            capacity as well as developing a new network.
     to a variety of treasury risks and other financial risks
     including liquidity risk, currency risk, interest rate risk   •   Cyber Risks
     and credit risk.                                                  Risks associated with associated with any exposure or
                                                                       loss related to technology infrastructure resulting from
•    Operation Risks                                                   a cyber-attack or data breach that will cause a massive
     Risks associated with XL Axiata’s core business                   negative business impact on XL Axiata. The Company
     operations i.e. Telecommunication, Digital Businesses and         held commitment to investing in technologies supporting
     Infrastructure, inadequate or failed internal processes,          the information security and obtained ISO27001
     people, and systems, or from external events that may             certification relating to customer data protection.
     disrupt the day-to-day business operations, including
     Business Continuity Risk.                                     •   People Risks
                                                                       Risks that XL Axiata faces in relation to human resource
•    Legal & Regulatory Risks                                          or people management which may include vacancy
     Risk relating to compliance with applicable laws                  in a specialized/skilled position, readiness and lack of
     and regulations, and may expose XL Axiata to legal                competency, and also safety and health of employees.
     penalties, failure to act in accordance with policies or          XL Axiata continued to invest in human resources
     best practices and integrity requirement. To address              competence and building the organizational capabilities
     the risks, the Company closely followed and observed              through recruitment of professional and young talents.
     the changes in laws, regulations and prevailing regional
     policies and building good rapport with the stakeholders,
     regulators and telecommunication association, actively
     providing advice and insight on the regulatory changes
     to the Government as well as incorporating the laws and
     regulations into the Company’s policy and procedures.




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•   ESG Risks                                                    For any incoming reports received via official SPEAK UP
    Risks relating to environment, social, climate change,       channels, the Company will assign Administrator of the
    transition, physical risks and carbon pricing policies. XL   SPEAK UP channel, which includes the Head of the Internal
    Axiata has developed the 2023-2025 ESG programs              Audit Division and the Investigation Unit, which is a function
    and conducted a Materiality Assessment to help it in         of the Internal Audit Division, to follow up the reports. If a
    mapping the programs based on a priority scale. The          report necessitates further investigation, the Company will
    Company has also established a Sustainability Team           appoint an investigator from the Company, Axiata Group
    to ensure the implementation of sustainability policies      Berhad, or a third party, to help identify the accuracy of the
    throughout its operations.                                   information contained in the reports.


COMMUNICATION OF KEY ISSUES [GRI 2-16]                           Then if the presumed acts of violation of the law or the
[GRI 2-25] [GRI 2-26]                                            code of ethics are proven in the investigation process, the
                                                                 Company will put sanction upon the employees concerned
The Company’s business is exposed to a number of risks           in accordance with the Company Regulations and applicable
that may hamper its efforts to achieve a sustainable growth,     laws.
including a breach of law in the operations that may generate
adverse impacts to the stakeholders.                             CONSTRAINTS,                  CHALLENGES    AND
                                                                 OPPORTUNITIES                  OF   SUSTAINABLE
Therefore, XL Axiata has established a reporting                 FINANCE [OJK E.5]
mechanism, which can be used by both internal and
external stakeholders, to communicate critical concerns. The     While continuing to integrate sustainability into its operations,
mechanism, which is outlined in XL Axiata Whistleblowing         XL Axiata is still exposed to constraints and challenges yet
Policy No: CEOD-04-2020, facilitates individuals who bring       also opportunities to increase our stakeholder participation
forth reports of suspected or presumed incidents, in good        in sustainability practices. Among the challenges were
faith, about a breach of internal policies or prevailing laws    the lack of understanding among the employees of the
and regulations. concerns on sustainability-related issues.      sustainability issues and some difficulties in the collection
The whistleblowing mechanism contains a set of procedures        of sustainability data and in the supervision of sustainability
that guide the whistleblowers on how to make reports and         initiative implementation. To address the challenges, the
protect them from any forms of retaliation due the reports       Company in 2024 in 2024 carried out 15 activities under
he or she submits.                                               a Sustainability Week program to raise the sustainability
                                                                 awareness among XL Axiata employees.
In addition, the Company provides stakeholders with other
alternative to report any suspicious activities through the
Speak Up channels. The report can be submitted via email
to: investigation@xl.co.id, or through phone/WhatsApp
Number at +6281937701234 and +6281933394567.




       XL Axiata has established a reporting
    mechanism, which can be used by both internal
    and external stakeholders, to communicate critical
    concerns.




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Business Ethics

CODE OF CONDUCT [GRI 2-23] [GRI 2-24]

Building integrity among the employees is essential to ensure the accomplishment of sustainability goals. XL Axiata accordingly
has introduced a code of conduct that contains behavioural and ethical regulations to guide the employees in carrying out
their daily routines professionally. The key points of the code of conduct are:




                                 Equality of Treatment
                                 Non-discriminatory treatment of employees in a healthy
                                 work environment with the application of integrity without
                                 exception.



                                 Healthy Partnership
                                 Build healthy business partnerships with third parties
                                 by complying with XL Axiata policies and applicable
                                 regulations.



                                 Anti-Corruption Culture
                                 Avoid conflicts of interest, do not accept gratuities and
                                 apply the principles of anti-corruption, collusion and
                                 nepotism.




                                 Commitment to Customers
                                 Holding a commitment to customers by building a
                                 “Trustworthy” attitude and providing appropriate solutions.



The XL Axiata Code of Conduct is consistently socialized and applies to all leaders and employees of the Company. For any
For any acts of violation of the Code of Conduct, the Company will put disciplinary action, as well as punishment, formal
warning, demotion or termination to the employees concerned based on the level of each violating act. The Board of Directors
is responsible for ensuring the implementation of the Code of Conduct at each aspect of the Company’s operations.


The Board of Directors has also established The Ethics and Integrity Committee on 30 June 2020 to assist the Board in its
oversight duties by preventing, detecting, and responding to cases of fraud or misconduct. In 2024, XL Axiata ensured that
there was no violation of the Code of Conduct.




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Competitive Behaviour

ANTI-BRIBERY AND ANTI-CORRUPTION                                  The Application of XL Anti-Bribery and Anti-
POLICY [GRI 3-3] [GRI 205-1] [GRI 205-2] [GRI 205-3]              Corruption Clauses
                                                                  The XL Anti-Bribery and Anti-Corruption Clauses
Corruption and gratification have long been recognized as         apply to members of governance bodies, employees,
critical challenges with significant impacts for economic,        representatives, agents and sub-contractors, requiring
social and environmental sustainability for many                  them to not violate anti-bribery laws. The clauses also
organizations. The detrimental impacts extend beyond              prohibits the Company partners, under any circumstances
financial losses, damaged corporate image and market trust,       and whether directly or through a third party, from giving,
which are risks a Company need to address to maintain the         requesting, promising, offering or authorizing the giving, the
business continuity.                                              entry, into any agreement to give, promise, offer or payment
                                                                  of any gratification of financial or other advantage to XL
Thus, XL Axiata has issued and consistently implements have       Axiata employees and their family members, including the
issued and consistently implemented an Anti-Bribery and           Company management members.
Anti-Corruption Policy. The policy is designed to represent
the Company’s value of “uncompromising integrity”, one of         The Company has communicated other anti-corruption
the core values of “ITS XL”. XL Axiata ensures this policy        policies and procedures to all members of governance
apply to both internal and external stakeholders, including       bodies, employees and suppliers (100%). To ensure
the Commissioners, Directors, employees, distributors,            the effective policy implementation, XL Axiata has
agents, vendors, consultants and other third parties. [GRI        communicated anti-bribery and anti-corruption policy
3-3]                                                              through employee trainings to build up better understanding
                                                                  of the policy. In 2024, training on anti-bribery and anti-
                                                                  corruption is reported below:


Training on Anti-Corruption
                                               Total Participating Employees in Anti-
             Training Name                                                                                   %
                                               Bribery and Anti Corruption Trainings
 Anti-Bribery Anti-Corruption Training                           1,655                                    99.52%

 ABAC & GDS Declaration for Employee                             1,663                                     100%


XL Axiata has built channels of communication to facilitate incoming reports on indication of corruption practices that involve
the employees. In the reporting year, the Company confirmed no incident of bribery or corruption practices taking place in XL
Axiata’s business locations. [GRI 205-3]




      The Company has communicated other anti-
  corruption policies and procedures to all members
  of governance bodies, employees and suppliers
  (100%).




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Data Security and Privacy

THE IMPLEMENTATION OF CUSTOMER PRIVACY POLICY [GRI 418-1]

XL Axiata has adopted the ISO 27001 standards for the Information Security Management System (ISMS) as a reference to
establish a clear policy regulating the use of customer personal data for various purposes. In addition as of November 2024,
the Company has adopted ISO 27701 standards of Privacy Information Management System (PIMS) which is designed upon
the existing ISO 27001 and focuses on the management of personal data privacy. According to the Company’s review of the
customer data privacy protection in 2024, XL Axiata did not record any violation of customer privacy policy.




                                     zero violation of customer
                                           privacy policy

In 2024, Data Protection Team, with the strong support of the Technology Security Team, had successfully achieved ISO 27701
Privacy Information Management System (PIMS) Certification as extension of ISO 27001 ISMS that XL had previously adopted,
reinforcing our commitment to data privacy and compliance excellence. This accomplishment marks a significant milestone
after a long and dedicated effort, making XL Axiata the first telecommunications company to obtain this certification. By
meeting internationally recognized privacy standards, the Company continue to strengthen its data governance framework,
enhance stakeholder trust, and set a new benchmark in the industry for responsible data management. By implementing
an internationally recognized standard on Data Privacy, XL Axiata aims to be the trusted convergence operator that our
stakeholder can rely on. XL Axiata wants to make sure that your personal data is treated with respect and proportionality
it deserved. During 2024, the Company also monitored our privacy implementation and recorded no complaint relating to
personal data and or information regarding personal data breaches.


In 2025, during the ongoing merger process, our primary objective is to maintain the current security posture while leveraging
the synergies of the merger to enhance cyber security and data protection capabilities.


We are committed to ensuring a seamless transition without compromising security standards, while also strengthening our
readiness to address emerging cyber threats and regulatory requirements. Through collaboration and integration, we aim to
establish a more resilient security framework that safeguards our company’s critical assets and reinforces trust in our data
protection practices.


During the merger process we will ensure that the data transfer process is in compliance with Indonesia PDP Law and that
all stake holders have the necessary support to exercise their data subject rights. Post-merger we also want to ensure your
personal data continue to be process in accordance with ISO 27701.




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Responsible Labeling and Marketing

LABELLING AND MARKETING [GRI 417-1]

XL Axiata has found a strong correlation between labelling and sustainability. Labelling is not only an effective marketing
strategy through the provision of complete information of a product but can also influence consumer purchasing decisions.
Thus, by providing clear information on the package label of the products, XL Axiata helps its product users understand
of the product benefits and use it wisely. In the context of sustainability, labels help increase consumer awareness of the
environmental impacts of a product or service they choose and make more sustainable choices. [GRI 3-3]


In the course of 2024, the Company confirmed that there was no incident of incompliance in regards to product labeling and
marketing activities. [GRI 417-2] [GRI 417-3]


LEGAL AND REGULATORY COMPLIANCE [GRI 2-27] [GRI 419-1]

The Company always adheres to best business practices as part of its prudent management, thus ensuring it to fulfill applicable
standards, laws and regulations during the reporting year, including fulfilling its socioeconomic responsibilities to its stakeholders
at large.


For XL Axiata, legal and regulatory compliance is vital to protect the brands and reputation of the Company, its subsidiaries,
associates and invested companies, as well as fundamental in pursuing its business goals. Therefore, the Company commits
to zero tolerance of any forms of bribery and corruption, tax avoidance or conducting discriminatory acts on employment.


Such commitment to conducting fair and impartial business practices and complying with applicable laws and regulations are
contained in XL’s Axiata Anti Bribery and Anti-Corruption (ABAC) Policy. Also In ABAC Policy, XL Axiata clearly regulates the
sanctions for any persons that do not comply with the policy.


In 2024, the Company did not violate regulations and rules requiring the Company to comply with. Therefore, the Company
did not receive any fine, monetary or non-monetary. The Company is committed to always be in compliance with prevailing
rules and regulations.




    In the course of 2024, the Company confirmed
that there was no incident of incompliance in regards
to product labelling and marketing activities.




                                                                                              2024 Sustainability Report           77
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Planet and
Society
Page 81
The purchase of 1,000 REC units
and the Installation of solar panels
on 252 BTS locations in Indonesia.
Page 82
                                                                                                            Planet and Society




Climate Impacts




Solar Panel located in Sukasari Site, Bogor with installed capacity of 14,080 Wp




XL Axiata is aware of the importance of environmental sustainability to shape our planet as a safe and better place for all
beings, today and tomorrow. Therefore, the Company has a strong commitment to embedding an environmental-friendly
approach into its operational strategies.



Aligning Environmental              Commitments           with        environmental management plans and strategic initiatives
Strategies [GRI 2-24]                                                 to create sustainable solutions, including driving energy
Environmental sustainability is becoming a focal point                efficiency, building awareness of a responsible waste
of telecommunication service and IT providers in recent               management, and minimizing the Company’s carbon
years. With telecommunication and IT equipment                        footprints toward Net Zero goal by 2050. The Company
contributing an estimated 1.7% of global CO2 footprint1,              is committed to using the existing resources responsibly
the telco and IT companies have been urged to address                 to address various needs of the Company without
various sustainability issues, including climate change, by           compromising the quality of services delivered to the
embedding the sustainability strategies into their everyday           customers. XL Axiata embraces energy-efficient technology
business decisions.                                                   solutions, drives recycling programs and increases
                                                                      awareness of the employees to carry out environmental-
In XL Axiata, the Company continuously strengthens its                friendly practices in their daily life.
commitments to the environmental protection, one of which
by establishing a comprehensive framework comprising the


1. https://www.un.org/sites/un2.un.org/files/circular_economy_14_march.pdf




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The Company also encourages the stakeholders at large,           The policy guides XL Axiata in planning, determining,
including the customers, suppliers, and local communities,       carrying out, monitoring and enhancing the occupational
to join these efforts and empower the progress toward the        health and safety as well as environmental management
goals.                                                           system in accordance with ISO 45001:2018, ISO 14001:2015
                                                                 and OH&S standards. The policy implementation also
To make these initiatives effective, XL Axiata has an            helps the Company to harness the prowess of digital
incorporated environmental management policy as outlined         transformation to realize the emission reduction targets and
in No. POL – FIN-002 on Occupational Health, Safety, and         improve energy utilization.
Environmental Management Systems Policy Statement (HSE
Policy) signed by XL Axiata President Director Dian Siswarini    As part of our environmental management initiatives, the
on 11 February 2022.                                             Company fulfils its regulatory commitments by applying the
                                                                 following procedures:




                                                   Environmental Aspect
                                                        and Impact
                                                    Identification (IADL)




                             4R (Reduce,
                                                                                   Hygiene
                            Replace, Reuse
                                                                                 Management
                            and Recovery)




                                                    Environmental
                                                     Management

                           Greening and
                              Plant                                                  Waste
                           Maintenance                                             Management




The Company consistently reviews the implementation of the above-mentioned initiatives to ensure that the Company has
contributed impactful benefits to the greener future. [GRI 3-3]


Environmental Cost [OJK F.4]
In 2024, XL Axiata disbursed a total of Rp86,203,200 to support its commitment to environmental management. The details
of the fund allocation are as follows:




  21%                                                           79%
                        UKL/UPL (Environmental
                        Management Business/                                             Domestic Waste
                        Environmental Monitoring                                         Management amounting
                        Business) amounting                                              Rp68,203,200
                        Rp18,000,000




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Emission & Energy

ENERGY EFFICIENCY                                                   1.    Intelligent Ventilation Cooling System (IVS), use of DC
                                                                          fans and Air Conditioning.
Energy Consumption [OJK F.6] [OJK F.7] [GRI 302-1]                  2.    Implementing PLNization and outdoorizing a number of
[GRI 302-2] [GRI 302-3] [GRI 302-4] [GRI 302-5]                           sites to eliminate the use of air conditioning as a coolant.
XL Axiata’s commitment to supporting a sustainable                  3.    The use of BTS Single RAN is to combine several types
environment is demonstrated through its implementation of                 of BTS into one. The utilization of Green BTS through
eco-friendly business operations, which include the energy-               network modernization with the latest technological
efficiency initiatives and the increasing use of renewable                devices, can save up to 50% of energy use.
energy. In recent years, the Company has been making                4.    The use of Hybrid System Charge Discharge Battery
progress on the use of renewable energy, thus lessening                   (CDC) in BTS in remote non-electric areas to reduce
the Company’s dependence on non-renewable energy                          diesel consumption by an average of 54%.
sources, such as electricity and fuel from non-renewable            5.    Reduction in the use of new refrigerants for BTS cooling
energy source, which are used in BTS. XL Axiata has been                  and XL Axiata offices.
at the forefront of the Green BTS campaign through the              6.    Descope generator, disable the generator and switch
installation of solar panels in 252 Base Transceiver Station              the power backup function completely to the battery.
(BTS) locations across Indonesia. XL Axiata Green BTS               7.    Increase the use of Solar Panels and Lithium Batteries.
concept highlights several initiatives to achieve the energy
efficiency target and potentially avoid carbon emissions of
up to 70,298 tonCO2eq in 2024. [GRI 3-3]




2024                                                                2023
 To increase the number of BTS that used solar
                                                                         Adding more BTS that used solar panels since
 panels of the total 165,864 BTS managed by XL
                                                                         100% BTS still used fossil fuels in operations.
 Axiata in 2024


In early December 2024, XL Axiata and PT PLN (Persero) formed a strategic collaboration to supply electricity for the Company’s
Base Transceiver Station (BTS) devices and help it migrate to green energy. PLN guarantees that the electricity supplied to
XL Axiata’s BTS devices will be served from its Renewable Energy Certificate (REC) product line. REC is an internationally
recognized renewable energy certificate issued by PLN that confirms that the electricity delivered to customers comes from
renewable sources. For XL Axiata, the collaboration emphasizes its unwavering commitment to sustainability through the use
of renewable energy. XL Axiata committed to purchasing 1,000 REC s in 2024 which were equal to 1,000 MWh.


XL Axiata’s energy consumption in 2024, in light of the aforementioned initiatives, is reported as follows:


Energy Consumption Within the Company [GRI 302-1]
                                                 2024                             2023                             2022
       Energy
     Consumption          Energy        Energy           Energy            Energy           Energy       Energy             Energy
      Activities          Source      Consumption       Intensity        Consumption       Intensity   Consumption         Intensity

 Renewable Energy
 REC                                       1,000,000     0.34 Gj/                      -           -                   -           -
                            PLN                 KWh      Petabyte
                                            3,600 Gj                                   -                               -




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                                                   2024                             2023                              2022
      Energy
    Consumption            Energy         Energy            Energy         Energy             Energy          Energy             Energy
     Activities            Source       Consumption        Intensity     Consumption         Intensity      Consumption         Intensity

Non-renewable Energy
Energy consumption                      956,319,188.94                   902,853,187.65                     840,667,225.93
for building lighting        PLN                  KWh                             KWh                                 KWh
and operations                          3,442,742.87 Gj                  3,250,271.48 Gj                    3,026,402.01 Gj
Energy consumption                     275,593.70 Liter                 228,001.34 Liter                        242,090.78
for Gasoline              Gasoline                                                                                    Liter
                                                             332 Gj/                          290 Gj/                             388 Gj/
                         (Pertalite)
                                            9,156.60 Gj     Petabyte          7,797.65 Gj    Petabyte           7,988.99 Gj      Petabyte
Energy consumption                          1,189,149.24                    1,393,829.51                       1,971,499.44
for Solar (Diesel)                                                                  Liter                              Liter
                            Solar       42,952.07 Liter                     47,668.97 Gj                      70,973,98 Gj
                                                                                    Liter
Total Energy Use                          3,498,457.75                    3,305,738 Gj                        3,105,365 Gj
                                                    Gj
Description:
• Fuel consumption from liters is converted to Gj using The Greenhouse Gas Protocol Initiative, 2004.
• Electricity consumption from KWh is converted to Gj using The Greenhouse Gas Protocol Initiative, 2004.


The figures on table above showed that the energy consumption in 2024 showed an increase compared to the total energy
consumption in 2023. While increases occurred in the consumption for non-renewable, this year XL Axiata was making a
significant progress in the use of renewable energy through the purchase of REC, reflecting the Company’s commitment
toward energy transition to green energy.


Energy Consumption by Operational Areas [E-04]

                                                           2024                                                2023

             Location                    Non-Renewable                                      Non-Renewable
                                            Energy                   Gigajoule                 Energy                   Gigajoule
                                          Consumption                                        Consumption
West
Listrik (KWh)                                215,279,535.78              775,006.33           196,604,370.95                   707,775.74
Solar – Diesel (Liter)                           364,579.44                  13,168.61             415,436.26                   14,207.92
Bensin (Liter)                                    84,850.51                  2,819.16               52,222.16                    1,786.00
JABO & HQ
Listrik (KWh)                               206.357.914,40                742,888.49          186,669,206.83                   672,009.14
Solar – Diesel (Liter)                            39,649.28                   1,432.13              44,794.14                     1,531.96
Bensin (Liter)                                    49,548.00                  1,646.23                    54,075                  1,849.37
Central
Listrik (KWh)                              262,406,448.04                 944,663.21          255,244,240.44                   918,879.27
Solar – Diesel (Liter)                             54,475.13                 1,967.64                67,369.11                   2,304.02
Bensin (Liter)                                     68,197.00                2,265.85                     57,953                   1,981.99
East
Listrik (KWh)                                161,564,098.32               581,630.75           162,316,387.03                  584,338.99
Solar – Diesel (Liter)                            276,700.17                 9,994.41             401,054.37                     13,716.06
Bensin (Liter)                                     72,998.19                2,425.36                 63,751.18                   2,180.29
North
Listrik (KWh)                                 110,711,192.40             398,560.29           102,018,980.40                   367,268.33
Solar – Diesel (Liter)                           453,745.22                16,389.28               465,175.63                   15,909.01
Total                                                                  3,494,857.75                                            3,305,738




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EMISSION REDUCTION

Commitment to Net Zero Carbon by 2050 [OJK F.11] [GRI 305-2] [E-06] [E-07]
XL Axiata’s strong commitment to achieving net zero by 2050 remains intact. Internally, the Company has taken a series of
initiatives to save more energy and reduce our reduce the carbon emissions. Emissions generated from the operations are the
results of the Company’s mobile energy combustion, stationary energy combustion, electricity consumption and the others. In
2024, the Company could reduce its Scope 1 emission by 11% compared to that of 2023.


GHG Emission [GRI 305-1] [GRI 305-2] [GRI 305-3] [GRI 305-4] [E-01] [E-02]


      Scope 1
      (Direct Emissions)

                  Total Emissions                                                Emission Intensity per Revenue
                  TonCO2eq                                                       TonCO2eq/Billion Rp




     2024              2023                 2022                  2024                  2023                   2022
     4,082.53          4,255.54             5,834.11              118.71                131.66                 200.20


      Scope 2
      (Indirect Emissions)

                  Total Emissions*                                               Emission Intensity per Revenue
                  TonCO2eq                                                       TonCO2eq/Billion Rp




     2024             2023                2022                    2024                  2023                   2022
     744,398.86       695,828.95          648,260.03              21,644.54             21,527.36              22,244.87


      Scope 3
      (Indirect Emissions)

                  Total Emissions                                                Emission Intensity per Revenue
                  TonCO2eq                                                       TonCO2eq/Billion Rp




     2024              2023                 2022                  2024                  2023                   2022
     4,252.47          5,743.82             (-)                   123.65                177.70                 (-)

Note:
The emissions Scope 1 and Scope 2 have been assessed by an external auditor. During the preparation of the 2024 report, audit process of
the emissions Scope 1, Scope 2 and total energy consumption were still ongoing.
* Due to 4% increased in BTS Tower


Since 2023, XL Axiata has begun calculating the Scope 3 emission to help prepare the accurate strategies to reduce the Scope
3 emission which is generated from sources that are not owned or controlled by the Company.


Details of Categories of Scope 3 Emissions in 2024 [GRI 305-3] [E-01]
                                      Category                                                    2024                    2023
 Category 4: Upstream distribution and transportation                                             143.40                   299.35
 Category 5: Waste generated from the operations                                                  928.22                  1,316.13
 Category 6: Business trips                                                                        371.12                 596.05
 Category 7: Employee travel                                                                     1,128.3   *
                                                                                                                           702.45
 Category 9: Downstream distribution and transportation                                          1,676.65                2,785.93
 Category 13: Leased downstream assets                                                             4,78 **                   43.91
 * Used the employee survey with more granular data obtained.
 ** Leased contracts for office area only until March 2024.


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In addition, following XL Axiata’s cooperation with Kadin Net Zero Hub which was signed on November 8, 2023, XL Axiata
continues to increase its sustainability-driven initiatives through its support to a low-emission ecosystem in Indonesia. In late
2024, XL Axiata, via XL Axiata Business Solutions (XLABS), signed a strategic collaboration with Xanh SM to offer new Internet
of Things (IoT) solutions to the electric transportation industry. This strategic cooperation aims to speed up the deployment of
electric vehicles in Indonesia by leveraging cutting-edge digital technologies that offer improved operational efficiency and save
expenses, thus helping companies address their sustainability issues, particularly relating to carbon emissions generated from
the transportation they use. The strategic collaboration represents XL Axiata’s commitment to driving the use of renewable
energy and environmental sustainability.


Prior to the agreement, XLABS in September 2024 sealed an agreement with PT Ide Inovatif Bangsa (Quest Motors) to equip
the platform of its electric motorcycle fleet with XL Axiata Business Solutions to create better experience for the users and
promote energy efficiency. The integration of digital connectivity into electric vehicle s will help establish the new standards
for the electric vehicle industries in Indonesia. Moreover, it will also contribute to the reduction of air pollution and energy
efficiency compared to vehicles that use fossil fuels.


XL Axiata’s role and initiatives in emission reduction and technology adoption that drives business efficiency and shapes an
environmental ly friendly industry will navigate the Company toward the net-zero carbon emission goal by 2050. [OJK F.12]


In addition, the Company has taken several other initiatives to control emissions, such as:
1. Developing Energy Monitoring System – multi platform to monitor energy consumption;
2. Developing Realtime Network Monitoring System – to monitor operations, including monitoring sites;
3. X-Camp launched ‘Xinergis’, a smart energy solution to meet the needs of real-time monitoring of electricity consumption,
    amount of clean water usage, and generator fuel consumption in buildings or offices;
4. Expanding the installation of Solar Panels (Renewable Energy); and
5. Executing more campaigns to promote energy and electricity savings among XL Axiata employees.




Climate Change

XL Axiata is aware of potential negative environmental impacts generated from its operational presence, which could escalate
the climate change issues.


Therefore, the XL Axiata Environmental Management Policy, which highlights energy efficiency efforts and the use of renewable
energy, is also specifically designed to address climate change risks. In addition, the Company has also determined some best
and sustainable practices, such as the followings:
• Encouraging periodical maintenance to operational vehicles;
• Using company vehicles that are not more than 3 years old;
• Disposing printer toner in accordance with applicable regulations Separating organic and inorganic waste;
• Encouraging employees to use reusable shopping bags. [GRI 3-3]




Biodiversity [OJK F.9] [OJK F.10] [ GRI 304-1]
XL Axiata always ensures that its operations will not create adverse impacts to the environment, including biodiversity. The
Company believes to always comply with the local regulations in areas where it operates or establishes the BTS to avoid
environmental issues. XL Axiata also ensures that its BTSs are not located in high conservation areas or protected forests
which can jeopardize the ecosystem within. The Company always supports any initiatives taken by the local governments in
the regions across Indonesia in which XL Axiata operates to ensure the sustainability of ecosystem surrounding its business
locations. [GRI 3-3]




                                                                                           2024 Sustainability Report          85
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                                                                                                               Planet and Society




Resources Use & Efficiency

POLLUTION                                                             WASTE AND RECYCLING

XL Axiata believes that its convergence services including            Managing Waste [OJK F.14] [GRI 306-1] [GRI 306-2]
the digitalization and broadband services can generate                The Company’s operations can generate various kinds
economic benefits. The benefits include increasing                    of waste, including hazardous and non-hazardous waste,
productivity and efficiency as well as economic growth, for           both in solid and liquid forms. Among the hazardous solid
the Company as well as the society. At the same time, the             waste generated from the operations are used lamps and
services also help reduce emission as people may use less             electronic waste whereas non-hazardous solid waste
transportation, thus contributing to a healthier, less-polluted       includes food waste, paper, leaves and plastic. On the other
environment.                                                          hand, the non-hazardous liquid waste generated from the
                                                                      operations include used oil.
The implementation of environmental management
and monitoring within the Company follows the set of                  If not properly managed, such waste can create ecological
requirements and in accordance with the standards of ISO              impacts to the surrounding environment. Accordingly, XL
14001:2015, ISO 45001:2018 and Government Regulation                  Axiata continues to enhance waste management efficiency
No 20 of year 2012. The standards provide a guideline                 and ensure that its operations support #BeBetter Work
for the management to supervise the implementation of                 Environment campaign. The Company accordingly engages
environmental management and monitoring, thus preventing              its internal stakeholders, particularly the employees, to join
the environmental pollution effectively.                              this effort considering their crucial role to the effective
                                                                      implementation of the commitment throughout its business
XL Axiata carries out an environmental monitoring against             processes.
all environmental aspects and impacts from the activities,
comprising air quality monitoring (ambient air quality such           In 2024, XL Axiata held a Sustainability Week program
as dust and noise), gas emission quality both from the                comprising various events, from talk shows, podcasts,
mobile source and stationary source as well as water and              film screenings, green product bazaars, to workshops on
effluent monitoring. In addition, it monitors hazardous waste         waste management. The program is expected to build
management as well as social and public health aspect.                awareness among the employees to care about managing
                                                                      waste, both at home and at work. Also at the same time,
CIRCULAR ECONOMY                                                      XL Axiata celebrated the World Environment Day on
                                                                      which the Company held a talk show titled “The Green
According to UN Economist Network a circular economy                  Scene: Empowering Eco-Lifestyle” to encourage everyone
implies the decoupling of economic growth from the use of             in the Company to make significant contributions to less
natural resources and inputs. A circular economy can also             environmental impacts.
be seen as a regenerative system in which resource input
and waste, emissions, and energy leakages are minimized               Furthermore, as part of its commitment to #Better
through long-lasting design, maintenance, repair, reuse,              environment campaign, XL Axiata has adopted a new waste
sharing, remanufacturing, and recycling activities.2                  management initiative by introducing a program called Waste
                                                                      Management Race. Through the program, the employees
As further defined by The Ellen MacArthur Foundation, there           are expected to be able to identify characteristics of waste
are three key aspects in a circular economy: the elimination          generated from its operations and separate organic, non-
of waste and pollution, keeping products and material in use          organic and plastic waste. The program also helps the
and regenerating natural systems. In XL Axiata, it applies            Company determine the best solutions for managing each
a circular economy not only to serve as a solution to the             of the waste types and minimizing environmental issues to
environmental issues but also to provide any women in the             the surroundings. The program implementation is expected
country to join efforts to make a concrete change to the              to build awareness among the employees for the importance
society and the environment.                                          of a responsible waste management for the Company. [GRI
                                                                      3-3]




2. https://www.un.org/sites/un2.un.org/files/circular_economy_14_march.pdf



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In addition, in conjunction with its 28th anniversary, XL Axiata in October 2024 launched Zero Waste to Landfill. The waste
management program was aimed at addressing the emission issue. The waste resulted from the Company’s operations
could generate 1.297 kg of CO2eq/month of direct GHG emissions. By implementing the Zero Waste to Landfill program, the
Company could save 3,605 kg of CO2eq/month of GHG emission compared to 4.902 kg of CO2eq/month of GHG emission it
could generate if it still applied the conventional waste management method.


Total Waste Generated from XL Axiata Operations [OJK F.13] [GRI 306-3] [GRI 306-4] [GRI 306-5] [E-05]

         Disposable                                 Wet waste                                        Electronic Waste (Electronic
         (ton)                                      (ton)                                            Equipment, Passive
         20.01                                      1.05                                             Equipment, iron and Cable)
                                                                                                     (ton)
         Recycled/Reused                            Dry waste                                        186.22
         (ton)                                      (ton)
         77.10                                      1.34
         Hazardous Waste
                                         Note: It is the first reporting year for XL Axiata to present its total waste volume
         (ton)
                                         generated from its operations. Therefore, the Company does not present the three-
         8.67                            year comparison as required by the regulation.




Domestic Waste
From the domestic waste generated from XL Axiata’s operations, most of the waste was recycled. Some of the waste were
processed into an alternative fuel and into compost as well as animal feed.




   XL Axiata, through the Pesantren Digital Boarding School and X-Camp programs, teaches
   students to utilize IoT solutions for Maggot cultivation.




                                                                                             2024 Sustainability Report         87
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                                                                                                               Planet and Society




Use of Environmentally Friendly Materials [OJK F.5]
XL Axiata believes that the digitalization that is widely adopted throughout its operations can contribute to the environmental
management practices, particularly waste management. The adoption of digitalization, such as in doing correspondence,
preparing legal documents, etc, helps the Company trim down the amount of paper used to print written documents, as well as
for other purposes. However, if paper printing is absolutely necessary, the Company suggests printing on both sides of the paper
or reusing waste paper that still has blank pages for draft recordings. The efficiency in paper use is not only to preserve valuable
resources but also helps the Company to control its household waste.


In addition to digitalization, XL Axiata also applies the following measures to control the use of raw materials that are not
environmentally friendly in the daily operations, including within the Company’s supply chain:



                                                                                                Product & Service
               Partner                                   Employees
                                                                                                    Delivery
  • Utilizing COUPA as an                     • Prefer reusable materials or               • Optimizing paper usage for
    integrated digital procurement              products to cut back on single-              physical vouchers, such as in
    system to reduce paper waste                use paper and plastics (plastic              XL Axiata’s 3in1 voucher.
    and support the Go Green                    cups, plastic bottles, and plastic         • Replacing copper cables to
    initiative.                                 cutlery in office space, canteen,            fibre optics that are more
  • Providing environmentally                   pantry and meeting rooms)                    environmentally friendly.
    certified raw materials, such               throughout our operations.                 • Utilizing recycled materials for
    as the use of FSC or PEFC                 • Prefer e-mail in doing                       marketing kits. [GRI 301-2]
    certified paper, to support our             correspondence with partners/              • The launch of e-Sim card
    operational needs.                          corporate customers rather
  • Agreeing to comply with XL                  than printing documents to
    Axiata sustainability principles            pursue cost and time efficiency.
    at the time of registration.




From its operation, the Company generated organic (food and food waste) and anorganic waste (metal, broken glass, plastic,
paper, cardboard, pallet, etc). All waste management which can influence the work effectiveness and efficiency have to be
reported to the management. Waste management implementation shall consider the compatibility with requirements of ISO
14001:2015 and ISO 45001:2018.


In addition to the aforementioned initiatives, XL Axiata also introduced the following measures to support our waste
management practices:




  No Plastic Zone at Workplace                     E-Waste Management                            Smart Digitalization

     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




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WATER AND EFFLUENTS [OJK F.8] [OJK F.13] [OJK F.14] [GRI 303-3] [GRI 303-4] [E-04]

The Company also manages its effluents from polluting the surrounding environment. The Company uses Wastewater Treatment
Plant (WWTP) managed by third parties to manage and produce waste that is environmentally friendly when discharged into
water bodies or city channels, the Company ensured no spill of effluent that occurred, which could generate an adverse impact
on the environment. [OJK F.15]


In 2024, XL Axiata’s operations did not produce any effluents, thus no effluent was recycled.


WATER CONSUMPTION [OJK F.8] [GRI 305-5]

Water is one of the energy sources that is widely used throughout the operations. To support the domestic activities, the
Company has its water needs supplied from Public Water Supply Company (PDAM) which is managed by a third party or the
building owners where XL Axiata offices are located.


Given the importance of water efficiency for sustainable living, we have been encouraging our employees to save more water
in daily use. The initiatives taken to control use of water in work environment include:


Water Consumption within the Company
          Water Sources                      Unit                  2024                    2023                  2022
 PDAM                                         M3                  7,497.46                7,382.32               7,487.13


Environmental Complaints [OJK F.15]
The commitment to environmental management practices through energy savings, emission reduction and waste management
has built the strong reputation of XL Axiata as a sustainable telecommunication company in Indonesia. The Company carefully
manages the sustainability risks relating to the environment to control negative impacts of its operations to the surroundings,
which may trigger complaints from the local community. In 2024, the Company received no complaint from the surrounding
community regarding the adverse impact resulting from the operations on the environment.


Suggestions and Complaints Related to Environmental Aspects [OJK F.16]
The Company has established a comprehensive communication channel to facilitate any incoming reports or complaints
surrounding the environmental aspect. The stakeholders can send their reports through the following channels:


      corpsec@xl.co.id                                                    XL Axiata Tbk

      +62215761881, +62215761880                                          XLAxiataTbk

      https://www.xlaxiata.co.id/                                         xlaxiata_tbk

                                                                          PT XL Axiata Tbk




                                                                                           2024 Sustainability Report         89
Page 92
Building
Prosperity
Page 93
    XL Axiata believes that the
implementation of a sustainability
policy will guide it to driving
long-term success and making
impactful benefits for the
people, planet and environment,
not to mention the economic
sustainability of the Company and
the society.
Page 94
                                                                                                         Buliding Prosperity




Economic Performance [GRI 201-1]

XL Axiata is aware of the importance of establishing the         forefront of implementing new technologies that can drive
economic sustainability to create long-term economic             the economic benefits, thus fostering its contributions to
growth and development without compromising the ability          sustainable development in Indonesia. [GRI 3-3]
of future generations to meet their own needs. XL Axiata’s
economic sustainability goal is to keep the balance between      In 2024, the Company recorded a direct economic income
the economic growth and responsible use of resources.            of Rp34,343 billion compared to Rp32,574 billion in the
Alongside the social and environmental sustainability, these     preceding year. The solid financial performance is attributed
three elements (social, environmental and economic) work         by the increases in quantity of products (mobile cards) sold
in harmony to create a sustainable framework that helps the      and data traffic.
Company anticipate challenges of climate change, resource
scarcity and social inequality.                                  The Company extends the direct economic value to its
                                                                 stakeholders by way of operating expenses, employee
As the Company moves toward its economic sustainability          benefits, dividend disbursements, tax payments, and CSR
goal s, XL Axiata drives innovation and adaptation in its        fund allocations. Thus, the total economic value distributed
economic activities while ensuring the implementation            in 2024 amounted to Rp33,166 billion, representing an
of the responsible practices. XL Axiata has been making          increase by 4,01% from Rp31,874 billion in 2023. Below is
continuous investments in improving its infrastructure and       a table of the Company’s total distributed economic value:
expanding its network coverage. The Company is also at the       [GRI 3-3]


Economic Value Acquisition Distribution [GRI 201-1]
                                                                                                                 (In Rp Million)

                Economic Performance                              2024                  2023                   2022
 Economic Value Acquisition
 Revenues                                                       34,391,597            32,322,651             29,141,994
 Profit (loss) exchange difference – net                           (16,326)                12,977               (61,295)
 Gain from the sale and leaseback of tower                         415,641               424,062               446,805
 Others                                                          (230,290)               (93,571)               (35,142)
 Finance income                                                    80,256                100,096                  111,718
 Share of profit/(loss) from Associate Entity                    (297,829)              (191,493)                  3,838
 Total Direct Economic Acquisition                             34,343,049             32,574,722             29,607,918
 Economic Value Distribution
 Depreciation expenses                                         (12,074,335)          (11,349,235)           (10,570,361)
 Infrastructure expenses                                       (8,942,323)           (8,995,646)             (7,733,947)
 Sales and marketing expenses                                   (2,094,192)           (2,454,775)            (2,617,998)
 Interconnection and other direct expenses                      (3,284,180)           (3,172,220)            (2,876,477)
 Salaries and employee benefits expenses                        (1,736,074)           (1,402,242)            (1,325,529)
 General and administrative expenses                             (454,990)             (413,040)              (352,698)
 Amortisation expenses                                           (216,928)              (157,216)                (7,567)
 Finance cost                                                   (3,112,802)           (2,939,979)            (2,777,385)
 Income tax expense/(benefit)                                    (579,594)             (420,069)               (231,842)
 Cash dividends paid                                             (635,296)             (549,023)              (544,078)
 Community expenditure                                            (35,628)               (20,735)               (10,419)
 Total Economic Value Distribution                              33,166,342             31,874,180            29,048,301
 Retained Economic Value                                          1,176,707              700,542                559,617




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Comparison of Target and Realization of Production Performance, Portfolio, Financing, or Investment,
Income and Profit and Loss [OJK F.2]
                                                                              Realization         Realization        Realization
                      Description                             Unit
                                                                                2024                2023               2022
 Number of BTS                                                Unit              165,864              160,124            146,023
 Number of Customers                                   Million People               58.8               57.52               57.48
 Total Data Traffic                                        Petabyte               10,547              9,638                7,991
 Income                                                    IDR-Billion           34,392              32,323               29,142
 Net Profit/Loss                                           IDR-Million         1,847,631          1,284,448             1,121,188


Comparison of Target and Realization of Investments in Environmentally Sound Projects [OJK F.3]
XL Axiata has been consistently increasing its sustainable footprints through investment in environmentally sound projects.
Throughout 2024, the Company has financed the following environmentally sound projects:


          Year                                Target                                               Realization
          2024              Additional Renewable Energy Attribute 1,000 Units of Renewable Energy Certificates (RECs)
                            and Additional 4 sites of solar panel. which are equal to 1,000 MWh. Additional 4 sites of
                                                                   solar panel.
          2023              Addition of Solar Panel Site                     A total of 46 additional solar panels were installed in
                                                                             2023.
          2022              202 Solar Panel Sites                            a. XL Axiata designed solar panels and began the
                                                                                installation in 2022.
                                                                             b. UKL/UPL (Environmental Management Business/
                                                                                Environmental Monitoring Business) Report Fee of
                                                                                Rp20,000,000/year for Tanjung Morawa (Opex).
                                                                             c. Cost of Making Temporary Storage Place (TPS) B3
                                                                                of Rp130,000,000 (Capex) in Tanjung Morawa.




The Effects of Climate Change on Economic                                Adding to the climate risk impacts, the Company has
Sustainability [GRI 201-2]                                               identified the opportunities that lie ahead. As more people
Climate change challenges with wide impacts on the                       are aware of the importance of lifestyle change particularly
environment, biodiversity, human health, as well as economy              relating to the energy use, it drives innovations and
and social life have become an issue that insists quick and              technologies to support the mitigation efforts of the climate
shared responses from the global communities.                            change risks.


As XL Axiata learn that issue, the Company has identified                Defined Benefits Program and Other Pension
both actual and potential climate change impacts. The                    Plan Obligations [GRI 201-3]
Company in 2024 recorded no actual or potential climate                  One of the factors supporting economic sustainability
change impact that could hamper its business growth.                     is the ability of companies to pay the defined benefits
                                                                         and pensions for their retiring employees. XL Axiata has
Therefore, our contributions to reduce the effects of                    designed its employee benefits and pension policy with
climate change include strong commitment to reducing                     respect to the Manpower Law. As outlined in the Company
the greenhouse gas emissions throughout operations and                   Regulations and Collective Labour Agreement (CLA), the
increasing the use of renewable energy. Although XL Axiata               Company’s retirement age is at 56 years old.
understands that tackling climate change is a collective
effort, the Company continuously makes progress toward
net zero emission. These efforts align with the global
transition towards greener energy systems.




                                                                                                2024 Sustainability Report          93
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                                                                                                          Buliding Prosperity




The Company provides its employees with a comprehensive          The Company assigns Tax Division Head under the auspices
pension plan which consists of:                                  of the Finance Director (CFO) to closely monitor the
1. DPLK (Financial Institution Pension Fund), which is           taxation and non-tax revenues while consistently improving
   paid as definite contributions with the Company’s             the understanding of the employees of taxation and PNBP
   contribution of 7% of wages whereas the employees             through internal trainings and workshops. A guidance is also
   contribute 3% of wages.                                       given to its partners, employees or related stakeholders
2. JP (Pension Guarantee) from BPJAMSOSTEK in the                on the latest regulations that have tax implications for
   form of a definite contribution of 3% of wages where          cooperation between the Company and these parties both
   2% of contributions are paid by the Company and 1% of         in terms of business and employment.
   contributions from employees.
                                                                 The Company pursues a conservative taxation approach
The Company will adjust the maximum wage limit periodically      by taking into account risk factors and existing business
according to Government Regulation (PP) No. 45 of 2015. XL       opportunities. For all new business schemes, a joint review is
Axiata calculated the estimated actuarial liabilities as of 31   necessarily done with several parties, including the taxation
December 2024 and 2023 based on actuarial assessments            team to review and analyze the tax implications.
by independent actuaries, as outlined in their reports dated
February 5, 2025, respectively.                                  Then to ensure its tax compliance, the Company has complied
                                                                 with all prevailing laws and regulations and maintains the
As of 31 December 2024, the Company allocated Rp252,541          communication with relevant tax office. The Company will
million to pay the post employment benefits, representing        also review the tax strategy on an annual basis and with
anincrease from Rp232,675 million allocated in 2023. XL          respect to the results of tax audits by the Directorate
Axiata recorded 1,663 employees who retired during the           General of Taxes (DGT) which is authorized to formulate
reporting period and has paid its defined contribution           and implement tax policies in Indonesia. Verification is also
obligations to those retiring employees.                         launched to verify tax and PNBP compliance through an
                                                                 audit process conducted by internal and external auditors,
Financial Assistance From the Government [GRI                    such as audits of financial statements and taxes.
201-4]
Throughout 2024, XL Axiata did not receive financial             The Company does not tolerate any conduct of tax
assistance from the government in any forms.                     noncompliance and encourages all stakeholders to use a
                                                                 violation reporting mechanism to report such misconduct.
Tax Payment Contribution [GRI 207-1] [GRI 207-2]
[GRI 207-3] [GRI 207-4]                                          The results of the applying taxation strategy review in 2024
The Company distributes its economic benefits to the             suggested that the strategy has aligned well with the current
government through tax payments. The tax contribution            situation. The Company is committed to quickly adapting to
helps balance the economic stability and represents its          any changes in existing tax regulations, when necessary.
support toward the Sustainable Development Goals (SDGs).
                                                                 The Company’s consolidated tax report is presented in the
XL Axiata fulfils its tax obligations according to Indonesia’s   financial statements audited by the public accountant.
taxation policies. The Company will utilize international tax
provisions when necessary. In 2024, the Company has paid
its tax obligations, including 11% of value added tax (VAT),
income tax article 21 and income tax article 23.




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XL Axiata Tbk (XL Axiata), through Sisternet, is organizing the 2024 ‘Kompetisi Modal
Pintar (Smart Capital Competition)’ to support Indonesian women-owned micro, small,
                                        and medium enterprises (MSMEs) in scaling up.




                                                     2024 Sustainability Report         95
Page 98
Nurturing
People
Page 99
Recruiting 152 new employees
with decreasing turnover
rate to 6.0% and recording a
direct economic income of
Rp34,343 billion.
Page 100
                                                                                                         Nurturing People




Employee Wellbeing




Blood Donation Activity by XL Axiata Employees




Responsible Employment Practices
Human Capital is XL Axiata’s valuable assets that contribute to the company’s growth. Accordingly, XL Axiata has introduced
a comprehensive Human Resources (HR) management, a strategic approach to managing its employees, involving the
establishment and execution of policies, programs and procedures. XL Axiata HR management policy is founded upon the
principles of equality and equal opportunity, in which the Company is committed to providing everyone in the company equal
chances to join our recruitment process, developing their career life and participating in various development programs,
regardless their ethnicity, religion, race, social status, physical condition, or gender. [OJK F.18] [GRI 3-3]




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To manage and produce quality employees, the Company               2. Cultural Alignment
has appointed the Human Capital Committee (HC                         The assessment process requires talents to demonstrate
Committee), which was established by the Board of                     their personal values and how well they align with XL
Directors on 12 July 2019. The committee adheres to a set             Axiata’s values, which is further divided into values and
of duties and responsibilities as outline in Law No. 13 of            management leadership models.
2003 on Manpower and its relevant regulations, which have
been amended to include Law No. 11 of 2020 concerning              3. Commitment
Job Creation. As of 2023, Human Capital Committee has                 XL Axiata will evaluate the candidate’s professional
introduced digitalized Human Capital management system,               motivation and aspirations for building a career towards
which includes Human Capital Super App (XLife), which acts            the intended position.
as an integrated touch point for employees. [GRI 3-3]
                                                                   4. Agility
Employee Recruitment [GRI 401-1]                                      Our increasingly dynamic business characteristics
XL Axiata’s success depends on the quality of the people.             demand a talent who is responsive and adaptive
Therefore, it is important to recruit professional talents that       to navigate the challenges posed by rapid change
meet the organization’s future development needs.                     (volatility), unforeseen issues and events (uncertainty),
                                                                      organizational complexity (complexity), and unclear
So as to help find the best candidates, XL Axiata introduces          situations or conditions (ambiguity), commonly known
a talent management system to build up a team of team of              as VUCA.
highly competent and experienced talents. This structured
system allows us to identify, develop, motivate, retain, and       Non Discrimination Policy [GRI 406-1]
place the most exceptional talent within the Company               XL Axiata adheres to a transparent and fair manner in
and gives them the opportunity to grow. XL Axiata talent           its recruitment process and is committed to not apply
management system starts from the talent acquisition, in           discrimination against the job applicants/candidates. The
which the Company carries out a transparent recruitment            recruitment upholds diversity in terms of gender, skills,
process and ensure no discriminatory measure to take               education, work experience, and age, and the candidates
place. XL Axiata will oversee employee management until            will be selected regardless their ethnicity, physical condition,
they reach the retirement period, all with respect to relevant     race, religion and even political views. In addition, as outlined
labour regulations in Indonesia.                                   in its Anti-Bribery and Anti-Corruption policy, the Company
                                                                   discourages multiple family members from working for the
XL Axiata Recruitment Process                                      Group to avoid nepotism. Then, apart from the recruitment,
● SOURCING & SHORTLISTING PROCESS, which                           the Company applies the discrimination policy in determining
   involves setting up the requirements and job description        job rotation and/or promotion. [GRI 3-3]
   by the users.
● SELECTION PROCESS, which involves a series of                    As the manifestation of its support for non-
   activities of selecting applicants.                             discrimination, XL Axiata has been taking an active
● ON BOARDING, which involves nurturing corporate                  participation in the women empowerment initiatives,
   culture, vision and mission, etc, among the employees.          one of which is through Sisternet program. In 2024,
                                                                   the Company held two initiatives titled ‘Festival Sisternet
XL Axiata engages third-party job recruitment companies,           2024’ and ‘Kompetisi Modal Pintar 2024’ to increase
both domestic and international, as well as optimizes              women’s participation in advancing the economy through
platforms, such as LinkedIn, Job Street, job fairs, and others,    supports for growth of women-led micro, small and medium
to acquire the best talents. In the recruitment access, XL         enterprises. “Sisternet Festival 2024,” which brought forward
Axiata will evaluate the applicants based on some factors,         a theme “Women of the Future, Collaborative Women,” was
including:                                                         a series of new Sisternet programs aimed at empowering 1
                                                                   million Indonesian women. The event was held at XL Axiata
1.   Competence                                                    Tower, Jakarta, in August 2024. In addition, XL Axiata
     Talents will be assessed based on their ability,              through Sisternet held “Smart Capital Competition 2024”.
     expertise, and knowledge relevant to the intended             The competition was held in collaboration with Pendopo, a
     position. Applicants are required to demonstrate              platform that curated native Indonesian items and preserved
     functional competencies according to the scope of job         the country’s cultural history. A total of 20 female MSMEs
     responsibilities, as well as leadership and pivotal duties    competed for a business capital reward of Rp115 million.
     obtained through their work experience. The Company
     classifies functional and leadership competencies to
     various levels pertaining to the different responsibilities
     of each position.




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To accommodate the Company’s business development needs, XL Axiata in 2024 recruited 152 new employees consisting of
114 male employees and 38 female employees, compared to a total of 166 new recruits in 2023. Below is the data comparison
on employee recruitment for the last 2 (two) years: [GRI 401-1]


Employee Recruitment By Age And Regions
                                                      2024                                         2023
             Description
                                           Male                 Female                 Male                 Female
 Employees By Age
 <25 years old                                 5                   3                       2                    5
 25-30 years old                               17                  11                      34                  23
 30-35 years old                               41                  10                      39                  17
 35-40 years old                               28                  9                       20                   4
 40-45 years old                               19                  2                       9                    5
 45-50 years old                               2                   2                       7                    -
 >50 years old                                 2                    1                       1                   -
 Total                                         114                 38                      112                 54
 Based on Regions
 Head Office                                   74                  33                      107                 46
 Region-West                                   18                   1                      19                   -
 Region-Jabo                                    0                  0                       7                    3
 Region-Central                                13                  2                       15                   1
 Region-East                                    5                   1                      8                    -
 Kalimantan Area                                2                  0                       6                    3
 Sulawesi Area                                 2                    1                      4                    1
 Region-North                                   -                   -                       -                   -
 Total                                         114                 38                      112                 54
 Note: Only in XL Axiata



Despite our active recruitment, the Company also saw a total of 95 employees leaving the Company throughout 2024. This
figure, if compared to total of 168 employees who left the Company in 2023, represented a decrease by 43.45%.


Employee Turnover
The successful implementation of HR management system is one of which measured from the employee turnover rate. The
employee turnover also indicates the company’s retention and overall management effectiveness. XL Axiata is committed to
establishing a vibrant as well as safe and healthy work environment that will always motivate and energize all employees to
come to work. The Company ensures that everyone is equipped with adequate facilities and know-how on how to carry out
their duties and responsibilities.


In 2024, the employee turnover rate was 6.0%, compared to 11.2% in 2023. The figure reflected the improvement in XL Axiata’s
HR management. The table below outlines the employee turnover rates for 2024.


Employee Turnover
                                                      2024                                         2023
         Employee Turnover
                                        Male         Female             Total       Male         Female             Total
 Incoming employees                      114            38              152          112            54              166
 (recruitment)*
 * Only in XL Axiata




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Outgoing Employees
                                                        2024                                               2023
            Descriptions
                                         Male          Female          Total             Male              Female        Total
 Natural retirement                        2              4              6                49                 14            63
 Passed Away                               3              0               3                2                 0             2
 Resigned**                               47              17             64               45                 29            74
 Dismissed for Misconduct                  6              3              9                 6                 0             6
 Expired Contract                          9              4              13               17                 6             23
 Total                                    67              28             95               17                 6             23
 Head Office                              67              28             95               119               49            168
 Percentage                              6.0%           5.8%            6.0%             11.4%             10.9%          11.2%
 **Reasons for Resignation




                                                        2024                                               2023
            Descriptions
                                         Male          Female          Total             Male              Female        Total
 At Own Request                           42              17             59               45                 29            74
 Not at Own Request                       22              11             33               74                20             94


Employee Demographics [OJK C.3] [GRI 2-7] [GRI 405-1]
Employee diversity is important in many ways as it can bring benefits for our company. XL Axiata creates a positive work culture
through the inclusion and diversity of employees. The Company’s inclusion and diversity policy reinforcement is reflected in the
age and gender composition of its employees, from staffs to top management levels. [GRI 3-3]


In 2024, the Company employed a total of 1,663 staffs compared to 1,495 employees in 2023, reflecting an increase by 11.24%.
The employee diversity of the Company for the last 2 (two) years is described in the following table based on gender, age,
business unit, educational background, position in the organization, and employment status.


                                  Proportions                                                  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                                                                                 -                   -
 45-50 years old                                                                                 2                   4
 >50 years old                                                                                   12                  9
 By Gender
 Male                                                                                            11                  10
 Female                                                                                          3                   3


                                  Proportions                                                  2024                 2023
 Employees
 By Age
 <25 years old                                                                                        20                   8
 25-30 years old                                                                                  138                 156
 30-35 years old                                                                                 359                 353
 35-40 years old                                                                                 363                 343
 40-45 years old                                                                                  377                 351
 45-50 years old                                                                                 282                  231
 >50 years old                                                                                    124                 109



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                             Proportions                                2024                     2023
Employees
By Gender
Male                                                                         1,168                1,047
Female                                                                       495                   448


Employee Composition by Operational Area and Gender

                                              2024                                    2023
         Operational Area
                                  Male       Female       Total     Male             Female         Total
Head Office                         871       446         1,317      812               408          1,220
Region-West                          63          9          72        45                 8              53
Region-Jabo                         49          15          64        36                 11             47
Region-Central                       73         13          86        53                 9              62
Region-East                          72          8          80        62                 6              68
Kalimantan Area                      22          3          25         21                4              25
Sulawesi Area                        18          1          19         18                2              20
Region-North                           -         -                      0                0                0
Total                             1,168       495        1,663     1,047               448          1,495

Employee Composition by Operational Area and Employment Status
                                              2024                                    2023
         Operational Area
                               Permanent    Contract      Total   Permanent          Contract       Total
Head Office                        1,197       120        1,317      1,113              107         1,220
Region-West                          39         33          72        33                20              53
Region-Jabo                          38         26          64         18               29              47
Region-Central                       41         45          86        28                34              62
Region-East                         48          32          80        36                32              68
Kalimantan Area                       6         19          25          5               20              25
Sulawesi Area                         8         11          19          9                11             20
Region-North                          0          0           0          0                0                0
Total                             1,377       286        1,663     1,242               253          1,495


Employee Composition by Employment Status and Gender
                                              2024                                    2023
           Description
                                  Male       Female       Total     Male             Female         Total
Permanent                           931       446         1,377      843               399          1,242
Contract                           237          49         286       204                49           253
Temporary                           319       600          919          0                0                0
Honorer                               0          0           0          0                0                0
Grand Total                       1,168       495        1,663     1,047               448          1,495




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Employee Composition by Job Title and Gender
                                                      2024                                        2023
             Job Level
                                       Male          Female          Total          Male         Female          Total
 President Director                        -              1               1            0               1               1
 Director                                  5              1               6            4               1               5
 Chief                                     8             0                8             7             0                7
 Group Head                               33             16              49           34             15              49
 Head                                    132            47              179          126             47              173
 Lead                                     14              7              21            0              0               0
 Staff/Individual Contributor           976            423          1,399            876           384           1,260
 Total                                 1,168           495          1,663          1,047           448           1,495


Composition of Employees by Age and Gender

                                                      2024                                        2023
         Employment Status
                                       Male          Female          Total          Male         Female          Total
 <25 years old                             7             13              20            3              6               9
 25-30 years old                          81            57              138           87             59              146
 30-35 years old                        244             115             359          232             112             344
 35-40 years old                        262             101             363          235             94              329
 40-45 years old                        279             98              377          256             87              343
 45-50 years old                        207             75              282           172            58              230
 >50 years old                            88            36              124           62             32              94
 Total                                 1.168           495          1,663          1,047           448           1,495


Composition of Employees by Education and Gender
                                                      2024                                        2023
         Employment Status
                                       Male          Female          Total          Male         Female          Total
 S2/S3                                   143            57              200           59             29              88
 S1                                     959            409          1,368            855            367          1,222
 Diploma                                  66            29               95          133             52              185
 High School Equivalent                    0             0               0             0              0               0
 Total                                 1,168           495          1,663          1,047           448           1,495

XL Axiata has also given the opportunity to applicants for internship. In 2024, total interns that joined in the Company is
described in the table below: [GRI 2-8]


Interns
                                                      2024                                        2023
            Information
                                           Male                 Female                  Male                Female
 Interns                                       60                  52                   167                   179
 Based on Internship Location
 Head Office                                   52                 42                    159                   160
 Region-West                                    7                   4                       3                   2
 Region-Jabo                                    -                   3                       2                    1
 Region-Central                                 -                   -                       -                   4
 Region-East                                    -                   -                       3                   12
 Kalimantan Area                                1                   3                       -                    -
 Sulawesi Area                                  -                   -                       -                    -
 Region-North                                   -                   -                       -                    -




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Proportion of Senior Management from Local Communities [GRI 202-2]
XL Axiata is committed to creating a more diverse workforce. Therefore, XL Axiata continues to increase its participation on
local economic growth through job opening for local workforce. The Company welcomes candidates from local communities,
who can meet the requirements for certain positions, to join and develop their career paths in the Company, including in the
executive management level.


In 2024, the number of the Company’s senior management members which were of local recruits composed 1% to total
workforce. The proportion of senior management coming from local communities is further described in the following table:


                                 Descriptions                                           2024                   2023
 Number of Employees                                                                    1,663                  1,495
 Number of Local Employees                                                             1,648                   1,480
 Number of Local Employees Occupying Senior Manager Positions                               8                      7
 Number of Female Employees                                                              495                    448
 By Region
 Jabodetabek                                                                            1,381                  1,267
 Outside Jabodetabek                                                                     282                    228


Child Labour and Forced Labour [OJK F.19] [GRI 408-             hours with clear time limits, to avoid the occurrence of
1] 409-1]                                                       forced labour is in line with Law of the Republic of Indonesia
XL Axiata is aware that such infringement to human              No. 19 of 1999 on the Ratification of ILO Convention No. 105
rights principles can take place in the Company’s work          Concerning the Abolition of Forced Labour. The Company’s
environment. Therefore, the Company addresses issues            compliance with regulations on the prohibition of child
surrounding human rights by designing an effective human        labour and forced labour resulted in no incidents or finding
resources management, which include treatment to the            of cases of child labour and forced labour and there were no
people and the determination of safety policies and working     instances of human rights violations in the Company during
hours.                                                          the reporting year.


XL Axiata strictly prohibits child labor and forced labor       Collective Bargaining Agreements [GRI 2-30]
practices throughout the Company’s operations anywhere          The Company together with Labour Union has prepared a
in Indonesia. XL Axiata has very strict recruitment policy,     Collective Labour Agreement (CLA) that covers 100% of XL
including the minimum age of employees and employee             Axiata employees. All parties must adhere to the principles
working hours.                                                  agreed in the CLA in managing the employment issues.


The policy also regulates final education which indicates       Remuneration and Employee Welfare [GRI 202-1]
that each candidate belongs to the adult category, while        [GRI 405-2] [GRI 401-2]
the agreed working hours are 8 (eight) hours 1 (one) day        XL Axiata recognizes its employees’ contribution to the
and 40 (forty) hours 1 (one) week for 5 (five) working days     Company by providing attractive remuneration packages
in 1 (one) week, in accordance with article 77 of Law No. 13    for employees. AX Axiata adheres to the applicable
of 2003 concerning Manpower. As for employees who for           regulations, including the Law on Manpower, Law No. 11 of
some reason work extra hours, the Company grants them           2020 concerning Job Creation, and Government Regulation
with overtime pay whose amount is determined based on           No. 36 of 2021 Wage Policy, in formulating its remuneration
XL Axiata’s internal provisions.                                system.


The HR management policy also applies to our subsidiaries       Other factors to consider in determining the minimum
and vendors, requiring them to adhere to the prevailing         wage of the employees include the achievement of decent
labor laws and regulations in Indonesia as well as universal    living needs for employees by taking into account the price
principles of human rights. The commitment reflects our         of basic necessities, inflation rate, standard of living, and
respect to Law of the Republic of Indonesia No. 20 of 1999      other variables in accordance with the Company’s financial
on the Ratification of ILO Convention No. 138 Concerning        capacity, industry’s average rate and business locations
Minimum Age for Admission to Employment, and Law of the         where it operates. XL Axiata’s recruitment system does
Republic of Indonesia No. 1 of 2000 on the Ratification of      not distinguish the structures and number of minimum
the ILO Convention No. 182 Concerning The Prohibition and       wages based on gender, to reflect our commitment to ILO
Immediate Action for The Elimination of The Worst Forms         Convention No. 100/1951 on Equal Remuneration for Men
of Child Labour. Meanwhile, the implementation of working       and Women Workers for Work of Equal Value.




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Wage Ratio Against Minimum Wage Standard of Regional Governments [OJK F.20]
The Company’s salary ratio has aligned well with the applicable requirement where it operates with the average ratio of 101%
to regional minimum wage standard.


In addition to remuneration, XL Axiata’s employees are also entitled to facilities and benefits whose type and amount are
adjusted to the employee’s position in the organization. The followings are the facilities and benefits granted to the employees:
[GRI 401-2]


                                                                                               2024
                   Remuneration/Facility Type                                                           Non-Permanent
                                                                      Permanent Employees
                                                                                                          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 of Worship                                                                 √                              √
 Progressive Leave                                                                √                              √
 Others
 Healthcare                                                                       √                              √
 Life Insurance                                                                   √                              √
 Description:
 √: provided
 x: not provided


To boost employee productivity, XL Axiata formulates rewards that are given in the form of:
● My Flexpro, a development plan of a one-fits-all employee non-cash program (i.e. Medical Plan Benefits, Let’s Learn
    Program, Annual Leave) that not only covers health benefit programs and educational purposes, but also includes travel,
    health, additional leave purchases, and pension programs;
● Provision of Tuition Fees;
● Opportunities for participating in Individual Development programs;
● Travel for Employees to appreciate their performance and target achievement; and
● Token Appreciation, a non-cash reward granted to employees who have demonstrated active engagement and huge
    contribution to the company’s strategic initiatives programs.




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Maternity Leave [GRI 401-3]
Some other facilities granted to the employees are Annual Leave and Special Leave which aim at providing the employees an
opportunity to have more quality time with their families. For female employees in particular, XL Axiata adds three months of
Maternity Leave to their list of facilities without any adverse impact on their job rights or positions. Additionally, Fathers are
granted two days of leave to accompany their wives during childbirth.


In 2024, the Company granted Maternity and Paternity Leave for 25 staffs, consisting of 15 Female employees and 10 Male
employees. Of these, 15 employees have returned to work after their leave period ended. The description is as follows:


                                                                                2024                           2023
                           Description
                                                                         Male          Female           Male          Female
 Number of employees eligible for Maternity Leave                       1,019           324             917            296
 Number of employees taking Maternity Leave                                10             15             59              25
 Number of employees returning to work                                     10             15             53              24
 Total number of employees returning to work after Maternity               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                10             15             53              24
 work and can be maintained




Workforce Health and Safety [OJK F.21] [GRI 403-1]
XL Axiata strives to balance the triple bottom line of people,      3. Establish a secure, pleasant, eco-friendly, and productive
planet and profit to achieve long-term success and viability.          workplace to enhance productivity.
This commitment is ensured by protecting the safety,
health, and welfare of the Human Resources which is our             Legal References
most valuable resource. As part of the implementation of            XL Axiata refers to laws and regulations governing
Human Resources Management System, XL Axiata applies                occupational health and safety and its derivatives in order
occupational health and safety principles to establish a safe       to implement the HSEMS accurately, they are:
and healthy work environment to promote a sustainable               1. Law No. 1 of 1970 on Occupational Safety.
workplace. A sustainable workplace is believed to be able           2. Law No. 13 of 2003 concerning Manpower.
to enhance productivity and the quality of employee                 3. Law No. 11 of 2020 on Job Creation has been updated
performance.                                                            with Law No. 6 of 2023 on the Ratification of Government
                                                                        Regulation in Lieu of Law No. 2 of 2022 on Job Creation
The Company accordingly implements Health, Safety, and                  into Law.
Environment Management System (HSEMS) which adheres                 4. Government Regulation of the Republic of Indonesia
to the provisions outlined in Government Regulation No. 50              No. 50 of 2012 on the Implementation of Occupational
of 2012 on the Implementation of Occupational Safety and                Health and Safety Management System (HSEMS).
Health Management System, ISO 45001:2018 (Occupational              5. Presidential Decree No. 22 of 1993 concerning Diseases
Health and Safety Management System), and ISO 14001:2015                Arising from Employment Relations.
(Environmental System Management).                                  6. Occupational Health, Safety and Environment Policy
                                                                        (HSE) of XL Axiata.
The Company’s strong commitment to integrating HSE                  7. HSEMS Policy Manual of XL Axiata.
principles in every aspect of its business operation aims to
establish a sustainable workplace with zero accidents and no        HSE Management within XL Axiata [GRI 403-8]
occupational disease. Apart from that, the implementation           XL Axiata’s HSE policy, which was signed by XL Axiata’s
of HSEMS also aims to realize the following goals: [GRI 3-3]        CEO Dian Siswarini on 11 February 2022, reflects the
1. Improve the efficiency of planned, measurable, and               Company’s dedication to providing customer satisfaction
    integrated occupational safety and health measures.             and ensuring the establishment of an efficient, healthy,
2. Involve     management,       workers/laborers,    and/or        secure, and eco-friendly workplace for both employees and
    trade unions/trade unions to prevent and decrease               customers. Given the characteristics of our business, XL
    occupational accidents and diseases.                            Axiata introduces continuous improvements to the policy to
                                                                    ensure its relevance with the current business trends and
                                                                    applicable regulatory framework.

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XL Axiata’s commitment to implementing HSE within               In addition to HSE policy, XL Axiata introduces internal
the Company is supported by all XL employees. Still, to         regulations regarding sexual harassment. As outlined in
ensure the effectiveness, the Company has appointed the         Article 51, the regulation specifies certain behaviors that can
Facility Compliance and HSE Assurance unit under the            result in termination of employment, including committing
Facility Operation and HSE Department to carry out and          immoral acts or engaging in unlawful activities, such as
supervise the policy implementation. In particular, the Unit    gambling within the Company (point f), attacking, molesting,
is responsible for the following duties:                        threatening, or intimidating co-workers or entrepreneurs in
● As Enterprises Business Partner                               the Company’s work environment (point g).
● Conducting Hazard Identification and Risk Control (IBPR)
● Identifying Environmental Aspects and Impacts (IADL)          Occupational Health and Safety Advisory
● Conducting Compliance Tests for Laws and Regulations          Committee (P2K3) [GRI 403-4] [GRI 403-8]
     concerning HSE                                             To strengthen the HSE implementation within the Company,
● Setting Goals, Objectives and Programs for Occupational       Occupational Health and Safety Advisory Committee (P2K3)
     Health, Safety and Environment (HSE)                       of XL Axiata shares responsibility for overseeing the HSE
● Perform Documentation (HSE Policy, HSE Procedure,             aspects and serves as a forum for the management and
     HSE Work Instructions, HSE Parameter Standards, and        employees to communicate and develop same perspective
     HSE Forms)                                                 as well as contribute effectively in HSE implementation
● Applying Contractor Safety Management System                  within the Company. The establishment of P2K3 is officially
     (CSMS)                                                     outlined in the DKI Jakarta Provincial Disnakertrans & Energy
● Organizing HSE Monthly Meetings                               with No. 2866 of 2022, dated 20 December 2022, and
● Conducting HSE Competency Training                            Directors’ Decree dated 15 November 2023 concerning the
● Measuring HSE Performance                                     Formation of the P2K3 Team. P2K3 represents all employees
● Organizing HSE Inspections                                    who are members of XL Axiata.
● Conducting HSE Audits; Internal Audit at least once a
     year, second party Audit (Vendors and Partners) at least   To support its duty implementation, the Company has
     once a year and External Audit (3rd Party) at least once   appointed several executives to membership structure of
     every 3 (three) years                                      the Occupational Safety and Health Advisory Committee
● Conducting HSE Management Review Meetings at least            (P2K3):
     once a year                                                ● Chairman of P2K3: I Gede Darmayusa (Director of
● Improvement and Corrective Action.                               Technology)
                                                                ● Vice Chairman 1 P2K3: M. Hira Kurnia (Chief Human
The Organization Structure of Facility Operation & HSE             Capital Officer)
– Facility Compliance and HSE Assurance Department is           ● Deputy Head 2 P2K3: Feby Sallyanto (Chief Enterprise &
described in the following chart:                                  SME Officer)
                                                                ● Secretary of P2K3: Andi Chandra (General Occupational
                                                                   Safety and Health Expert Certification)
                President Director & CEO
                                                                Members:
                                                                ● Group Head
               Chief Human Capital Officer                      ● Head
                                                                ● Employees
                                                                ● XL Workers’ Union

 Group Head - People Service & Facility Management



            Head Facility Operation and HSE



            Compliance and HSE Assurance




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                                      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)




       Head Office                     Region - Jabo                    Region-West                   Region - Central
        (Member)                         (Member)                        (Member)                        (Member)



1. Group Head                    1. Group Head                  1. Group Head                    1. Group Head
2. Head                          2. Head                        2. Head                          2. Head
3. Empolyees                     3. Empolyees                   3. Empolyees                     3. Empolyees
4. XL Workers’ Union             4. XL Workers’ Union           4. XL Workers’ Union             4. XL Workers’ Union




P2K3 is tasked with the following duties:                      HSE Targets
1. Building an HSE conscious culture                           XL Axiata aligns its HSE targets with sustainability strategies
2. Provide XL Axiata safety performance reports every          to increase awareness of its both internal and external
   quarter to the Manpower Office                              stakeholders of the importance of Zero Work Accident
3. Socializing HSE to employees Chairman of P2K3               Fatalities as part of its operational achievement and to
   (Director & Chief Technology Officer) Region - Jabo         establish a sustainable organization.
   (Member) Head Office (Member) Region-West (Member)
   Region - Central (Member)                                   HSE Work Programs in 2024
4. Implementing various HSE aspect trainings                   In 2024, the Facility Operations and HSE Department
5. Ensuring HSE programs and monitoring the effectiveness      and the Facility Compliance and HSE Assurance unit has
   of their implementation                                     designed and implemented a number of work programs as
6. Develop risk control measures against HSE hazards in        part of its duties and responsibilities. The Unit launched an
   the work environment                                        identification of HSE aspects including potential negative
7. Organizing management reviews held once a year.             impacts to environment caused by the Company’s
                                                               operations and preparing the mitigations. Further details
P2K3’s Duty Implementation in 2024                             about HSE work programs are presented below:
As part of its duties and responsibilities, XL Axiata’s P2K3
carried out a number of activities in 2024:
1. Management Walk Through (4 times);
2. Management Review Meetings (2 times);
3. P2K3 XL Axiata became the key speaker in a seminar
    “HSE in the Telecommunication Industry” held by HSE
    Activists in Telecommunication Industry Network on 31
    January 2024;
4. Mining Executive Talk.




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1.   HSE Identification [GRI 403-2]                                Work Accidents and Occupational Diseases [GRI
     According to risk assessment and audit, some HSE              403-9] [GRI 403-10]
     aspects that could be identified by the Facility Operations   XL Axiata always strives to achieve operational excellence
     and HSE Department and the Facility Compliance and            throughout our operations. This also means zero accidents
     HSE Assurance unit include the aspects of employee            and no occupational disease taking place in our business
     health, work permit for every job, safety compliance by       environment. In the past 3 (three) years XL Axiata
     drivers/vehicle, tools and equipment condition which          has identified the rate of work accidents taking place
     must be appropriate for the work and safe for use, the        throughout XL Axiata’s operations, which was at low level.
     proper use of personal protective equipment, and the          In 2024, XL Axiata did not record any work accident rate
     energy use.                                                   as per 200,000/1,000,000 man hours, emphasizing its
                                                                   commitment to realizing the operational excellence with
2. HSEMS Audit [GRI 403-2]                                         a zero fatality.
   To measure the effectiveness of the HSE implementation,
   XL Axiata engages third parties to conduct periodic             Improving the Quality of Health at Work [GRI 403-
   audits or assessments. The assessment process                   3] [GRI 403-6]
   includes preparation and documentation of HSD plans,            Employee welfare is always XL Axiata’s top priority.
   compliance with HSEMS-based work safety protocols,              Therefore, XL Axiata has granted free access for all
   monitoring standards, development of skills and                 employees to healthcare facilities, which include fitness
   capabilities, and other relevant factors.                       centers, day care and lactation rooms for breastfeeding
                                                                   mothers, and a number of XL Axiata’s sports communities
     Pursuant to the audit results in 2023, which is still valid   such as XL Axiata Da Bikes, XL Axiata Runner, XL Axiata
     thru 2026, the Company scored 93.37% (Satisfactory) in        Basketball, XL Axiata Futsal & Football, MTXL (Majlis Taklim
     accordance with Government Regulation No. 50 of 2012          XL) and XL Axiata Music. Through these efforts, XL Axiata
     concerning the Implementation of Occupational Safety          expects to see an increase in employee health, creativity
     and Health Management System. Also to support its HSE         and productivity which are believed to be the foundation
     implementation, XL Axiata has applied ISO 45001: 2018         underlying sound corporate growth.
     for Occupational Safety and Health Management System
     and ISO 14001: 2015 for Environmental Management              In addition, XL Axiata has established a health clinic.
     System.                                                       Supported by skilled medical staffs, all XL Axiata employees
                                                                   can access free occupational health services at the clinic
3. Remedial and Precautionary Measures [GRI 403-7]                 anytime during office hours.
   Against the potential hazards, XL Axiata has taken the
   corrective actions for unsafe conditions, unsafe actions,       HSE Trainings [GRI 403-5]
   and work accident investigations, which resulted in a           To improve the capacity of members of the Facility
   81% correction rate.                                            Operations and HSE Department and the Facility Compliance
                                                                   and HSE Assurance unit, XL Axiata provides them with
4. Contractor Safety Management System (CSMS)                      opportunity to participate in various HSE trainings. The
   XL Axiata’s HSE management system also applies to               trainings also aim at increasing awareness of the importance
   contractors working within the XL Axiata’s environment.         of HSE implementation to promote a sustainable workplace.
   We assess their safety commitment on periodical basis           Below are HSE trainings in 2024:
   to ensure the effectiveness of HSE implementation
   throughout our supply chain.


5. Management Review Meeting (RTM)                                      In the past 3 (three)
   Led by P2K3 Chairman, the Company held a management
                                                                   years XL Axiata has
   review meeting of the HSE implementation of the year.
   The meeting results showed that the zero accident goal          identified the rate of work
   was fulfilled in 2024 with zero LTR. The goals relating to
                                                                   accidents taking place
   the implementation of HR development, ISO 45000 and
   ISO 14000 standards were well maintained. XL Axiata             throughout XL Axiata’s
   was presented with Indonesia Safety Excellence Award
                                                                   operations, which was at
   (ISEA) 2024.
                                                                   low level.




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Training on Exercise Emergency Response
           Premises          Drill Type             Date                                    Evidence
HQ-XL Axiata Tower                Fire         22 October 2024    BCP Drill NOC Report
ROS Bandung                       Fire          02 March 2024     Q1 - RO Bandung - Fire Fighting Simulation Report
                             Earthquake         22 June 2024      02 - RO Bandung - Socialization of Earthquake Emergency
                                                                  Response Report
                             Bom Threat         28 September      03 - Socialization of K3 Emergency Response to the Bomb
                                                    2024          Threat 2024 RO Bandung Report
RO Medan                          Fire          09 March 2024     01 - RO Medan - Fire Fighting Simulation (DAMKAR)
                             Earthquake         20 September      03 - RO Medan - Earthquake Evacuation Simulation
                                                    2024
                                  Riot          20 June 2024      Q2 - RO Medan - Riot Handling Simulation
ROS Pekanbaru                     Fire         17 February 2024   Q1 - RO Pekanbaru - Fire Fighting and Simulation Training
                             Earthquake          21 June 2024     Q2 - RO Pekanbaru - Earthquake Simulation
                             Bom Threat        30 August 2024     Q3 - RO Pekanbaru - Emergency Response to Bomb Threats
ROS Palembang                     Fire          09 March 2024     Q1 - RO Palembang - Fire Fighting Simulation Exercise
                             Earthquake         22 June 2024      Q2 - RO Palembang - Emergency Simulation (Earthquake)
                             Bom Threat         07 September      Q3 - RO Palembang - Bomb Threat Training
                                                    2024
RO Surabaya                       Fire         27 February 2024   RO Surabaya - Fire simulation Report
                             Earthquake          28 May 2024      RO Surabaya - Earthquake Simulation Report
                             Bom Threat          27 July 2024     RO Surabaya - Bomb Threat Simulation Report
ROS Bali                          Fire          23 March 2024     RO-Bali - PMK Training Report
                             Earthquake         22 June 2024      RO Bali - Earthquake Emergency Response Training Report
                             Bom Threat          27 July 2024     RO Bali - Bomb Threat Simulation Report
ROS Makassar                      Fire          07 March 2024     RO Makassar - Fire simulation Report
                             Earthquake          21 June 2024     RO Makassar - Earthquake Simulation Report
                             Bom Threat          27 Juli 2024     RO Makassar - Bomb Threat Simulation Report


HSE Competency and Internal Trainings
 No.                                      Training Title                                       Date              Participants
HSE Internal Training
       1    E-learning                                                                    6 February 2024             1,343.7
      2     Workshop & Awareness ISO 45001:2018, 14001:2015 and 22301:2018                 28 May 2024                  98
      3     Internal Audit                                                                 30 May 2024                  11
      4     Refreshment IBPR dan IADL                                                      19 June 2024                 21
      5     Refreshment on HSE Report Filling, PTKP, and Accident Report                  12 August 2024                16
      6     APAR Training for XL Axiata Floorwarden                                       31 August 2024                10
      7     Sharing K3 to Interns Teman Tuli                                             17 September 2024              19
      8     SMK3 Audit Training                                                          27 September 2024              2
      9     Bomb Threat                                                                   26 October 2024               12
      10    Chemical Management & MSDS                                                   15 November 2024               22
      11    Conducting Work Accident Investigations                                      22 November 2024               15




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 No.                                     Training Title                                      Date               Participants
 HSE External Training - Competency
       1   Work Accident Investigation Certificated BNSP                               18 - 20 September                 1
                                                                                              2024
     2     TOT KKNI Level Certificated BNSP                                           21 - 23 October 2024               2
     3 Lead Auditor ISO 14001 Certificated IRCA                                           28 October -                   1
                                                                                       1 November 2024
     4     Class D Firefighters Certificated Menaker                                 28 - 30 October 2024                10
     5     Lead Auditor ISO 45001 Certificated IRCA                                    25 - 30 November                  1
                                                                                             2024
     6     First Aider (First Aid Officer) Sertifikat Menaker                        2 - 6 December 2024                 4
     7     Lead Auditor ISO 45001 Certificated IRCA                                  16 - 20 December 2024               1




Talent Management [OJK F.22] [GRI 404-1] [GRI 404-2]

Given our business characteristics, adaptive employees can play a vital role in the Company’s sustainability efforts by embracing
sustainable practices and demonstrating a commitment to the Company’s social and environmental goals. Therefore, it is
important for the Company to provide its employees with the right knowledge through trainings to develop their individual
competence and increase their participation in advancing the Company’s business. [GRI 3-3]


Throughout 2024, XL Axiata has held several trainings and development programs with focus on 10 key capabilities aligned
well with XL Strategy. The key capabilities are:
1. Convergence mindset and understanding
2. Partnership, Collaboration, Creativity
3. Agility
4. Change Leadership (Transformation leader)
5. Customer Experience (CX)
6. Advance Analytic, AI/ML
7. Digital Savvy
8. Cloud Technology
9. 5G
10. Enterprise Business


Based on the key capabilities, we designed key training programs for the employees in 2024. Below is the information on
training programs held in January-February 2024. and some employee training programs were also held for the rest of the
year.

                                    Training Name                                          Date                Participant

 Harvard Business School                                                              3 January 2024                 1
 Coaching session, implementation of B2b, B2C, Channel & Distribution                 8 January 2024               163
 Best Analytics Series - Data Engineer Stream "Data Warehouse And ETL"                9 January 2024                36
 XSEED UPSKILL #5 - AI/Machine Learning                                               9 January 2024                25
 XSEED UPSKILL #6 - Financial Acumen & Product Fit Market Strategy                    12 January 2024               45
 XSEED UPSKILL #7 - Pitching & Business Presentation                                  16 January 2024               45
 Best Analytics Series - Data Analytics Stream "Tableau For Business Intelligence"    16 January 2024               19
 Best Analytics Series - Data Science Stream "Unsupervised Machine Learning"          16 January 2024               10
 Best Analytics Series - Data Engineer Stream "Big Data Processing"                   18 January 2024               18
 Algorithm Data Innovation Conference                                                 19 January 2024               2
 XSEED Checkpoint Progress #3                                                         19 January 2024               45
 Generative AI for Everyone                                                           21 January 2024                1




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                                 Training Name                                            Date              Participant

 Best Analytics Series - Data Science Stream "Time Series & Forecasting"             23 January 2024            10
 XSEED Semi Final                                                                    24 January 2024            45
 Best Analytics Series - Data Engineer Stream "Data Pipelines & Workflow             30 January 2024             7
 Management"
 Business Partnership Mastery                                                        31 January 2024            22
 Sales & Distribution Team Development Program - Sales Solution & Integration        31 January 2024            14
 (Batch 1)
 XSEED Final Pitching                                                                31 January 2024            45
 Sales & Distribution Team Development Program - Sales Solution & Integration        1 February 2024            15
 (Batch 1)
 Classification in Machine Learning                                                  1 February 2024             1
 Best Analytics Series - Data Science Stream "Classification In Machine Learning"    1 February 2024            10
 Enablement Technical Design SDWAN – Fortinet                                        2 February 2024            25
 Best Analytics Series - Data Analytics Stream "PowerBI For Business Intelligence"   6 February 2024            26
 Harvard Business School                                                             11 February 2024            1
 Engineer Stream “Final Project Intro”                                               13 February 2024            1
 Best Analytics Series - Data Engineer Stream "Final Project Intro"                  13 February 2024            7
 Best Analytics Series - Data Engineer Stream "Mentoring"                            15 February 2024            7
 Best Analytics Series - Data Engineer Stream "Neural Network & Deep Learning"       15 February 2024           10
 Strategic Sales Excellence (Batch 1)                                                15 February 2024           20
 Course & Exam Certification - CHRP                                                  15 February 2024            1
Coaching and Mentoring - Amazon SageMaker 101 Workshop (SageMaker                    16 February 2024           16
Immersion Day)
Enablement Technical Design SDWAN - Fortinet Batch 2                                 19 February 2024           32
Sales Territory Management (Batch 1)                                                 19 February 2024           20
HEC Executive Program - Leading a Technology Driven Organization                     21 February 2024            12


The number of employees participating in 2024 training programs reached 1,663 employees, compared to 1,502 employees in
2023, with a total training hours of 53,587 or 36.6 hours per employee.


S-01 Gender Equality
                                                         Male                                      Female

               Position                                           Employee                                   Employee
                                         Total Employees                             Total Employees
                                                                 Percentage                                 Percentage
Entry-level                                       0                     0%                     0                     0%
Mid-level                                       990                   59.5%                 430                25.9%
Senior-level                                    165                    9.9%                   63                3.8%
Executive-level                                   13                   0.8%                    2                 0.1%
Total Employees                                1,168                  70.2%                 495                29.8%




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S-02 Total Male and Female Employees Based on Age Group
                                                               Position
 Age Group                                                                                                                       Total
                     Entry-level                 Mid-level                 Senior-level                 Executive-level
 (Years Old)                                                                                                                   Employees
                 Male           Female    Male         Female         Male           Female            |Male       Female
    18-25           0               0        7                12          0               0               0              0            19
    25-35           0               0      308               168          4                1              0              0           481
    35-45           0               0      463               166          82              33              3              0           747
    45-55           0               0      206               83           79              28              9               1          406
     >55            0               0        6                 1          0                1              1               1           10


Competency Development Costs
To support the effective trainings, the Company has allocated a budget whose amount was determined based on needs and
the Company’s financial capabilities. In 2024, total training and development costs incurred amounted to Rp7,449,117,233,
compared to Rp8,314,806,611 incurred in 2023.


            Description                      Unit                     2024                        2023                        2022
 Training Fee                                    Rp                7,449,117,233               8,314,806,611            7,690,000,000


Employee Performance Assessment [GRI 404-3]
The Company conducts assessment of employee performances to measure the employee productivity and contribution to the
Company’s business development. The employee performance assessment process is carried out objectively and transparently
based on the Company’s Key Performance Indicators (KPIs) agreed in the beginning of the year.


The Company’s KPIs is aligned with CEO KPIs and KPIs per Directorate, and followed by the establishment of individual
employee KPIs. This approach guarantees that the Company’s KPIs are aligned with individual employees’ goals.


For individual employee, the Company will assess their KPIs twice a year or every semester with respect to the mid-year
performance review aspects. The assessment process allows the management to intervene into performance issues that arise
at the end of the year or if results deviate from expectations.


Throughout 2024, the Company has assessed performances of 1,656 employees, compared to 1,478 employees who received
year-end performance assessment in 2023. Of the figure, the total male employees who received performance assessment
were 1,168, whereas the total female employees who were assessed were 495. The report on the performance assessment of
XL Axiata’s employees in 2024 is presented below:


                                                                                          Assessment Results and Relevance of
                                         Number of Employees Assessed
                                                                                                 Career Development
           Employee Level
                                                                                                               Mutation/
                                         Male           Female             Total          Promotion                            Demosi
                                                                                                               Rotation
 Chief                                      8                  0                 8                 1                0                0
 Group Head                                33                 16                49                4                 0                0
 Head                                     146                 54               200               12                 2                0
 Staff/Individual Contributor             976                423           1,399                 60                19                0
 Total                                   1,168               495          1,656                  77                21                0




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Impact on Communities

Community Development [OJK F.23] [GRI 413-1] [GRI 413-2]

XL Axiata has been closely following the key technologies and trends to ensure that XL Axiata can deliver best-in-class and
impactful solutions to our users and the public at large. However, based on our evaluation of the whole operations of the
Company, XL Axiata learns that its operation can generate actual and potential positive as well as negative impacts.


Positively, through a responsible use of technology, XL Axiata addresses variety needs of communications, including to
enhance internal and external communication, establish collaborative works, drive flexibility, innovation and efficiency as well
as improve customer experience.


Corporate Social Responsibilities
Apart from communication perspectives, the Company also extends the impactful benefits of its operations to other aspects.
Realized through the implementation of Corporate Social Responsibility (CSR) programs, the Company expects its solutions to
be able to contribute to the achievements of Sustainability Development Goals (SDGs).


Employee Engagement Survey
Employee engagement can have positive impacts on retention. Therefore, to measure the employee satisfaction towards
XL Axiata’s HR management system, XL Axiata conducts regular employee engagement survey. In 2024, the employee
engagement survey was held online, drawing participation of 672 employees. The survey results suggested that
XL Axiata remained committed to maintaining employee satisfaction and participation by maintaining the quality
of the work experience. The company chose a more relevant survey to reflect employee engagement more
accurately, covering important aspects such as Employee Services, Performance Review, and Corporate Agenda.


Through various initiatives such as mentoring, feedback sessions, and townhall meetings, XL Axiata demonstrates great
concern for employee welfare and career development. [GRI 3-3]


                                                                                                           Contribution To
      Category         Program          Coverage                           Impact
                                                                                                               SDGs
 Social            Gerakan Donasi      Nationwide      Improving the quality of education nationwide       TANPA
                                                                                                           KEMISKINAN
                                                                                                                                  PENDIDIKAN
                                                                                                                                  BERKUALITAS
                                                                                                                                                          BERKURANGNYA
                                                                                                                                                          KESENJANGAN



                   Kuota (GDK)                         through the increasing participation of XL
                                                       Axiata’s service users and the public at large to
                                                       voluntarily donate their quota to be further
                                                       distributed to schools across the country
                   XL AXIATA           Nationwide      Providing social supports for the employees’        TANPA
                                                                                                           KEMISKINAN
                                                                                                                                  TANPA
                                                                                                                                  KELAPARAN
                                                                                                                                                         KEHIDUPAN SEHAT
                                                                                                                                                         DAN SEJAHTERA



                   BAIK                                families and surrounding communities through
                                                       participation of XL Axiata employees and
                                                       partners
                                                                                                            BERKURANGNYA
                                                                                                            KESENJANGAN




                   XL AXIATA           Nationwide      Providing social supports to the victims of         TANPA
                                                                                                           KEMISKINAN
                                                                                                                                  TANPA
                                                                                                                                  KELAPARAN
                                                                                                                                                         KEHIDUPAN SEHAT
                                                                                                                                                         DAN SEJAHTERA



                   PEDULI                              natural disasters through distribution of
                                                       emergency assistance programs
                                                                                                            BERKURANGNYA
                                                                                                            KESENJANGAN




                   Pesantren           Nationwide      Enhancing knowledge of Santri/Santriwati            PENDIDIKAN
                                                                                                           BERKUALITAS
                                                                                                                                   KOTA DAN PERMUKIMAN
                                                                                                                                   YANG BERKELANJUTAN




                   Digital                             through training programs on Digitalization, and
                                                       utilization of IoT
 Economy           Sisternet           Nationwide      Empowering women everywhere in Indonesia to         PENDIDIKAN
                                                                                                           BERKUALITAS
                                                                                                                                  KESETARAAN
                                                                                                                                  GENDER
                                                                                                                                                          BERKURANGNYA
                                                                                                                                                          KESENJANGAN



                                                       develop and increase their welfare through use
                                                       of internet and technologies, thus preparing
                                                       them for 4.0 industry
                                                                                                            KOTA DAN PERMUKIMAN
                                                                                                            YANG BERKELANJUTAN




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                                                                                                             Contribution To
     Category          Program           Coverage                            Impact
                                                                                                                 SDGs
 Environment        Laut Nusantara       Nationwide      Helping to reduce the impact of climate change,     PENDIDIKAN
                                                                                                             BERKUALITAS
                                                                                                                           KOTA DAN PERMUKIMAN
                                                                                                                           YANG BERKELANJUTAN




                                                         supporting underwater life and preventing
                                                         seawater intrusion using an application that is
                                                         developed through a synergy between the
                                                         Marine Research and Observation Institute
                                                         (Ministry of Marine Affairs and Fisheries) and XL
                                                         Axiata


XL Axiata’s commitment to share its sustainability values to        Social
stakeholders at large is reflected in the allocation of budgets     The Company continued to increase its social contributions
for its social performance in the three executive years:            through programs, including Gerakan Donasi Kuota (GDK),
                                                                    XL Axiata Peduli. Through GDK and Pesantren Digital, XL
                                                                    Axiata has been distributing quota donated by its customers
Total CSR Funds Disbursed
Rp (billion)                                                        through Gerakan Donasi Kuota to about 200 educational
                                                                    institutions. The program participants could flexibly choose
2024                                      35.63                     the target category and nominal quota to be donated
                                                                    through myXL and AXISNET apps. The free internet quota
2023                 20.73                                          has validity period of 12 months. In total, the quota donated
                                                                    in 2024 amounted 226,380 GB with total beneficiaries
2022     10.41                                                      reaching 66,397, which included students, teachers, and
                                                                    event participants.


Budget Implementation In 2024                                       The Company also distributed routers to Islamic boarding
                                                                    schools under Pesantren Digital program. XL Axiata held
Environmental                                                       several other activities, including X-Maggot Prototype
Through Laut Nusantara, the Company created some                    & Installation, Maggot Cage Installation + Maggot Larva,
initiatives for the apps users, namely Postpaid hotline billing     Support & Monitoring by IoT XCampteam, Digital Literacy
payment. Total beneficiaries of the program reached to              Class, Community Partner Engagement, and distributing
7,725 people.                                                       Zakat of the employees. Total beneficiaries of the program
                                                                    reached 3,337, including students of Islamic boarding
                                                                    schools.




     Gerakan Donasi Kuota at SMK Adhi Karya Bekasi, October 2024




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                                                              -   Ifthar Sharing, on 3 April 2024;
                                                              -   Employee Homecoming (Mudik Bareng Karyawan) on 5
                                                                  April 2024;
                                                              -   Safari Ramadan 2024, in May 2024, to distribute
                                                                  donation at 13 different locations
                                                              -   XL Axiata Mengajar at SMA Negeri Baubau and Madrasah
                                                                  Ibtidaiyah Al-Amin on 8 May 2024;
                                                              -   Touring to Garut, West Java and visiting the Special
                                                                  Needs School (SLB) and special needs orphanage, in
                                                                  commemorating the 79th Independence Day of Republic
                                                                  of Indonesia on 17 August 2024;
                                                              -   Internship program for 19 people with disabilities, which
                                                                  took place on 17 September 2024-25 October 2025;
                                                              -   Distributing donation for schools, islamic boarding
                                                                  schools and orphanage at 18 locations, during XL
                                                                  Axiata’s 28th Pre-Anniversary event in September 2024.
                                                                  The event was conducted by Sobatbaik XL.


                                                              Economic
                                                              In 2024, the Company had empowered more than 1 million
Meanwhile, through XL Axiata Peduli Bencana activity, the     Indonesian female entrepreneurs, helping them to go digital
Company donated basic necessities for the disaster victims,   through a series of activities including educational events,
such as vitamin, clean water, food, mask, medicine, and       social media activation, sponsorship, digital promotion,
the others, such as communication access, health support      business incubation, development app and female future
and local micro business empowerment. Through XL Axiata       leader.
Peduli Stroke JAGATARA activity, the Company distributed
JAGATARA (Stroke Riskmeter-Smartwatch) to stroke              The Company’s Social and Environmental Investment
patients. Total beneficiaries of the program reached 47,384   In total, the beneficiaries of the various activities carried
people.                                                       out above reached 1,184,829 people. To support all of
                                                              these activities, the Company has allocated Rp35.63 billion,
The Company also increased its social contributions through   including non-financial sponsorship that XL Axiata has
XL Axiata Baik program. Launched in February 2021, the XL     monetized into rupiah. Regarding social activities in 2024,
Axiata baik program aims to build an environmental care       The Company recorded a Social Return on Investment
culture among its employees, which is expected to inspire     (SROI) value of 4,11, meaning that for every Rp1 the
many other people to carry out impactful actions for both     Company invested, the Company was able to generate
internal as well as external stakeholders. By engaging the    a social return of Rp4.11. The more than 1 ratio shows
employee club, the program has four pillars, namely:          that the social activities or programs carried out by the
- Making cash donation                                        Company have been effective in generating benefits
- Entertaining/relaxing activities                            or adding value to the stakeholders, meaning that
- Knowledge sharing                                           the benefits offer greater value than the value of the
- Environmental activities                                    investment spent.


In 2024, under XL Axiata Baik program, the Company has        In the meantime, the Company also strives to control the
done the following initiatives:                               potential adverse impacts from its operations by fulfilling
- Facility Day 2024, on 29 January 2024, aimed at building    the regulatory commitments, including the adoption of both
    a teamwork among XL Axiata’s Facility Management          national and international standards required for ensuring a
    team members;                                             seamless delivery of its products and services.
- Blood Donor activities, to celebrate the month of HSE on
    13 February 2024 engaging 126 donors and to celebrate
    ATSI’s anniversary on 5 September 2024 engaging 150
    donors;




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Access and Affordability of our Products and
Services

XL Axiata ensures everyone has access to the its wide range of products and services, including connectivity and ICT portfolios
which are dedicated to our Enterprise clients. XL Axiata Business Solutions empower business entities of various sectors and
of any size to accomplish their business goals and achieve success. Our enterprise business successfully maintained resilience
by posting significant growth and market penetration.


As of now, the Company has served more than 8,700 corporate clients across 330 industry sectors, and has a network of over
165,864 BTS. Our SME segment also has successfully reached over 20,000 SMEs with over 40% quarterly growth on the launch
of XL Satu Biz. It was supported with comprehensive suite of converging products, including internet fiber connectivity, mobile
devices, and business applications. These achievements demonstrate the Company’s strong market position and commitment
to providing innovative solutions to businesses of all sizes in Indonesia.


Then XL Axiata also expanded opportunities on its enterprise solutions by launching a Smart Mining and Smart Manufacturing
suite for key industries, initiated energy-saving Smart Energy Monitoring, and partnered for AI-powered IoT solutions, all while
driving sustainability through Smart Street XL Axiata AR 2024 questionnaire: BOD October 2024 Lighting implementation
across multiple regions. These initiatives not only enhanced our service offerings but also contributed to increased efficiency
and cost savings for our enterprise customers




Sustainable Supply Chain [GRI 204-1]

XL Axiata’s success is built upon good relationships with various stakeholders, including its business partners who share same
values and perspective on sustainable value creation. The Company has established a supply chain that consists of selected
and verified local suppliers to join and add value to XL Axiata’s range of products and services. Given the dynamic global
situation, the local engagement is expected to establish a sustainable supply chain, in the forms of competitive pricing and
quality as well as relatively timely delivery of products and services.


The Company ensures transparency and regulatory compliance during the selection process of the suppliers, in which the
Company provides them with equal opportunities to participate in the procurement process. In 2024, the Company has
collaborated with both local and foreign suppliers to provide goods and services for the Company. The composition of both
local and foreign suppliers in the reporting year was 90 : 10 as described in the following table: [GRI 3-3]


                                             Total Vendors                            Contract Value (Rp billion)
         Descriptions
                                     2024                    2023                    2024                      2023
 Local (Indonesia)                    484                     431                  15,068.4                   13,554.4
 Foreign (Overseas)                     53                    48                      460.4                      377.4
 Total                                537                    479                  15,528.8                    13,931.8


In interacting with its business partners, XL Axiata pursues the highest ethical standards in all procurement activities. As
referred in Axiata Supplier Code of Conduct (“Code”), the Company has provided a clear statement of its expectation from
suppliers in all procurement dealings, ensuring that they closely follow the acceptable procurement ethics. These principles are
applied throughout the selection process of suppliers and suppliers’ compliance is strictly monitored.




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Product and Customer
Responsibilities
    As people become increasingly aware of the
impacts of their product choices on social and
environmental aspects, XL Axiata has been seeking
more innovative ways on how to deliver safe and
quality products and services, which align with
the ethical and sustainability perspective of its
customers as well as can add values to them.

Customer Experience

CUSTOMER PROTECTION, ENGAGEMENT                                   PROTECTION OF CUSTOMER PRIVACY [GRI
AND SATISFACTION [OJK F.17]                                       418-1]


XL Axiata has a large consumer base with complex priorities       To protect our customer privacy, XL Axiata has designed a
regardless their demographic. Therefore, to cater to the          policy that regulates the use of customer personal data and
varied needs of its customers, the Company has dived into         the policy is available on the Company’s website. According
each market segment through a series of researches it has         to the policy, XL Axiata may use the customer personal data
launched to learn about the customer preferences. Other           for a variety of purposes, including:
than research, XL Axiata also conducts activities such as:        - To offer personalized services based on customer’s
[418-1]                                                               device location, ad viewing history, and other
                                                                      information;
-     Benchmarking products, promos, prices, journeys and         - To compile customer database;
      other benefits with other operators;                        - To send service messages, surveys, and product and
-     Regular customer satisfaction surveys which will be our         service information;
      reference for improving the product and service quality;    - To meet its regulatory compliance by disclosing
-     “Market knowledge insights” to get better understanding         customer data to contractors, payment channels,
      of market/consumer perceptions of products, brands,             regulatory bodies, law enforcement agencies, and
      trends, competition and consumer purchasing power;              government authorities.
-     Monitoring and analyzing performance to help us offer
      necessary improvements or corrections.                      Also to protect customers from phishing, XL Axiata advises
                                                                  customers not to share their personal identity information
The results of the above-mentioned activities will provide        or phone number with unknown parties. Customers can
the Company with some recommendations that will help              conduct verification of messages they receive from XL
it improve the customer experience, thus fulfilling some          Axiata by contacting XL Axiata’s customer service at any
of the customer responsibilities. XL Axiata also has strong       time. Customers can make any calls to XL Axiata Customer
commitment to delivering equal treatment to all customers,        Service Center for 24 hours, 7 days a week.
regardless their ethnicity, religion, race, gender, skin color,
political views, and so forth. XL Axiata believes that by         XL Axiata also ensures that its customer data privacy has been
treating consumers equally, XL Axiata has complied with           in line with the prevailing laws and regulations. XL Axiata has
Consumer Protection Law.                                          adopted ISO 27001 for the Information Security Management
                                                                  System (ISMS) as part of the customer retention. As of
                                                                  November 2024, the Company has also adopted ISO 27701
                                                                  standards for Privacy Information Management System (PIMS)
                                                                  as the extension of ISO 27001 standards of ISMS. [GRI 3-3]

118         PT XL Axiata Tbk
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The Company’s commitment to ensuring the customer               PRODUCT AND SERVICE QUALITY
satisfaction are realized through the following approaches:
[GRI 3-3]                                                       Through network convergence, XL Axiata is enhancing its
1. Providing products that are safe and meet applicable         adaptability and agility to support diverse growth areas,
    standards and regulations, including compliance with        such as mobile home and enterprise services. By leveraging
    ICNIRP (International Commission on Non-Ionizing Radio      a robust infrastructure of 165,864 BTS stations and 190,000
    Protection) rules;                                          Km optical fibers, XL Axiata is well-positioned to meet the
2. Establishing intensive relationships through marketing       evolving demands of our customers.
    communications and direct service media with customers;
3. Providing clear product information and guarantee            Also to ensure the product and service quality, the Company
    consumer protection of customer data privacy;               has launched initiatives to improve its security system. The
4. Providing understanding to potential customers and           Company used GPO (Governance-Protection-Operations)
    customers about matters related to the product;             framework to identify gaps, prioritize initiatives to fix them,
5. Realizing investment in the development of main and          and measure its security posture. The security posture was
    supporting infrastructure and implementing product          improved by completing the Company’s IT security policies,
    development programs according to the development           implementing necessary protection, and monitoring and
    of information technology;                                  taking actions on any identified weaknesses or attempts to
6. Providing customer service facilities and resolve all        breach its security.
    customer complaints;
7. Carrying out regular customer satisfaction surveys as a
    means of quality improvement.


For the period of 2024, XL Axiata did not receive any
complaint relating to the breaches of personal data and/
or information.




Digital Leadership

DIGITAL RESPONSIBILITIES, INCLUSION &                           In line with commitment to increasing benefits of our service
RIGHTS                                                          solutions, XL Axiata also has responsibility to ensure the
                                                                safety of products and services. XL Axiata launches periodical
Impacts of Products/Services [OJK F.28]                         product reviews to assess the impacts and/or benefits of
Customers satisfaction is an absolute priority for XL           each product and services prior to and after their public
Axiata. Therefore, the Company’s primary focus in product       releases. XL Axiata has a dedicated team to ensure that:
development is always to ensure that XL Axiata’s products       1. Each product design has met market needs;
and services shall bring benefits to the customers and other    2. Products and features shall have passed “quality
stakeholders at large.                                               assurance” tests prior to the market release;
                                                                3. The Company has built a customer journey supported by
With the Company’s vision to become No. 1 Converged                  SOPs, policies and systems that support the security of
Operator in Indonesia, XL Axiata increases the benefits              customer data such as registration, activation, purchase,
of its business presence by introducing the converged                payment to deactivation.
services to address various needs of telecommunication
and data communication of Indonesian people. XL Axiata’s        As part of the assessment process, XL Axiata accordingly
commitment to putting service quality and customer              implements 3 key actions: Rationalization, Simplification
satisfaction as top priorities indeed has helped millions of    and Automation, which include activities such establishing
its service users, including the children at schools, improve   an Enterprise Product Catalog, a consistent structure
business performance, have better and stable access to          and foster collaboration across product lines for seamless
entertainment services, enjoy better ways of doing work         integration with Order Management Systems. The Company
from home as well as easily access various information that     also develops Artificial Intelligence (AI) and digital
will benefit the people’s daily lives.                          automation to support decision-making, convergence
                                                                and personalization since the application of AI helps us
                                                                create more personalized customer profiles, thus helping us
                                                                to create accurate products for our customers.




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XL Axiata also establishes more effective parameterization that will ease it in future product development and/or maintenance.
The Company engages the internal IT team to conduct quality control of each product to release or in the market. The
assessment is done with respect to the following criteria:


                                                  Enterprise Product Catalog
             Rationalization                              Simplification                             Automation
 -    Reduce 17K to 12K product variants -      Reduce unnecessary API Interaction     -   Reduce turn-around-time by 50%
 -    Map out product portfolio to                                                         from 7 days to 3 days
      maximum of 13 product family                                                     -   Automated Testing
      templates


Meanwhile to anticipate any negative impact resulting              Customer Service
from its operations, XL Axiata has established a complaint         XL Axiata thinks it significant to develop good communication
center. As part of its responses to incoming reports from          with its stakeholders, be it internal or external stakeholders.
the customers, XL Axiata takes the following measures to           The Company therefore has established several channels
rectify any negative impacts:                                      of communication to facilitate any incoming reports,
1. Providing quick responses to follow up on customer              complaints or inquiries from our customers as well as to give
    complaints, for first level handling. Implement an internal    new updates about the Company’s products and services.
    escalation system for handling;
2. Conducting regular evaluations;                                 To deliver quality customer service, these are the key
3. Being open for feedback;                                        aspects to take into account by the Company:
4. Being open for discussion and compensate if it causes           1. The establishment of a Call center through Integrated
    inconvenience to the customer.                                    Customer Service;
                                                                   2. The establishment of Customer Experience & Service
In 2024, XL Axiata’s products and reviews were already                Operation Center (CE & SOC);
evaluated for safety and impacts. Based on The evaluation          3. The Implementation of Customer Privacy Policy;
results, XL Axiata is assured that no incidence of                 4. Conducting customer satisfaction surveys;
noncompliance concerning the health and safety impacts             5. Providing appreciation to customers.
of products and services and there was no infringement of
customer data privacy policy in the delivery of XL Axiata’s        1.   Integrated Customer Service
products and services. [OJK F.27] [GRI 416-1] [GRI 416-2]               XL Axiata has assigned Service Management Directorate
                                                                        to ensure the delivery of quality customer service. This
Recalled Products [OJK F.29]                                            Directorate manages a Customer Service Center (call
Pursuant to the results of our product reviews, the Company             center) that is ready to serve our customers for 24 hours
believes that it has provided impactful solutions to address            and 7 days a week. The call center accommodates any
the varied needs of its customers. In 2024, The Company                 inquiries from existing and potential customers about
has conducted a review of all products on the market and                its products and services or any incoming reports
found no adverse impact from the telco products and the                 or complaints. Any calls or inquiries from customers
digital solutions distributed or delivered to the users and the         received through the call center will be promptly
public at large. Therefore, no product was being recalled or            addressed in accordance with the Standard Operation
discontinued during the year.                                           Procedure for Handling Customer Service Complaints
                                                                        based on the Company’s Customer Priorities.




    The Company also develops Artificial Intelligence (AI)
and digital automation to support decision making,
convergence and personalization.




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      The Customer Service Center provides integrated customer service through various channels of communications, including:


                                      12 customer messaging service and contact
 5 Call Center touch                  customer service through digital touch points:
 points:                              •   Livechat via MyXL App                                                 In 2024, XL Axiata
 •        817 via XL Number           •   Livechat Priorities via MyXL Prioritas apps
                                      •   Livechat via web xl.co.id
                                                                                                                 served customers
          (Customer Regular)
 •        (021) 57959817 via non-     •   Social media via Facebook (@myxlcare)                                       through
          XL Number                   •   Correspondence via email Customerservice@xl.co.id
 •        818 via XL Number           •   Livechat via Axisnet App                                              92 XL Centers,
          (Customer Priorities)       •   Livechat via Axis web axis.co,id                                      including XLC Online,
 •        820    via  Nomor     XL    •   Live chat via MyXL Home App                                                established
          (Customer Home)             •   Social media via Facebook @XLhomeid (XL Satu)
                                                                                                               throughout Indonesia.
 •        08170123442 via non-XL      •   Correspondence via email to xlhomecs@ xl.co.id (XL Satu)
          Number (Customer Home)      •   Messenger via Whatsapp 08170010820 (XL Satu)
                                      •   Livechat via web xlaxiata.co.id


2. Customer Experience & Service Operation Center (CE & SOC)
   Adding to our integrated customer services, XL Axiata since 2018 has established a Customer Experience & Service
   Operation Center (CE & SOC), which is designed to ensure that XL Axiata has carefully addressed and managed all customer
   complaints and reports as well meet the quality of network and services as the customer expectation. Equipped with an
   integrated monitoring room, the establishment of CE & SOC helps provide clear visibility for the Company to monitor the
   quality of delivered services at real time with nationwide service coverage.


  No.                        CE & SOC FUNCTION                                              ADVANTAGES OF CE & SOC
     1.      Become an integrated service quality monitoring center.         Built with network elements consisting of hundreds of
             For this reason, the Company developed an integrated            thousands of alarms powered by machines, rather than
             monitoring room for 4 NOCs (Network Operation                   manually, thus successfully increasing the speed and
             Centers), namely: Telco Network, IT Infrastructure, IT          accuracy of services.
             apps, and Billing.
     2.      Facilitate coordination in overcoming potential problems Can anticipate future needs, especially regarding network
             related to network performance and service quality.      development plans and the adoption of the latest
                                                                      technology.
     3.      Monitor the dynamics of services, including use of
             customer service facilities.

     To always improve the quality of the Integrated Customer Service, XL Axiata conducts evaluation in accordance with
     criteria established by the Total Complaints based on Ministry of Communication and Digital Affairs (KOMDIGI) Standards
     for Complaint Topic. The criteria are:


                                                                              Komdigi
          Service Performance                    Parameter                                       2024           2023          2022
                                                                             Standards
 Customer Complaint Handling          Percentage   of   customer                 ≥ 95%           97.86%         98.99%        99.41%
 Standards                            complaint management
 Standard Service                     Number of service interruption               ≤ 2%                  0.5        0.6           0.6
                                      reports per 1,000 customers
 *) For 2024, it has not been validated by the Ministry of Communication and Digital Affairs (Komdigi)


The evaluation results suggested that reports on service interruption improved from 0.6% in 2023 to 0.5 in 2024, thus reflecting
the Company’s commitment to enhancing the customer experience. XL Axiata also manages several communication channels
to monitor public complaints or reports. The Company will use such public information to improve quality of products and
services. [OJK F.24]




                                                                                                     2024 Sustainability Report      121
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                                                                                                                      Nurturing People




Report on Public Complaints based on Report Status
                                                   2024                               2023                            2022
            Report Status
                                           Total       Percentage           Total         Percentage        Total        Percentage
 Resolved                                1,635,365          99.99%          1,181,139         99.93%      1,808,086          100.00%
 In Process                                      233         0.01%                  882       0.07 %                0            0%
 Unresolved                                        0               0%                0                0             0                 0
 Total                                  1,635,598         100.00%          1,182,021         100.00%      1,808,086          100.00%


Report on Public Complaints based on Mechanism
                                                   2024                               2023                            2022
            Report Status
                                           Total       Percentage           Total         Percentage        Total        Percentage
 WBS                                             N/A           N/A                  N/A          N/A              N/A            N/A
 Email                                     209,091          12.78%          274,835           23.25%        281,204           15.55%
 Telephone (hotline), digital, walk      1,426,507          87.22%           907,186          76.75%       1,526,882          84.45%
 in
 Total                                  1,635,598         100.00%          1,182,021         100.00%      1,808,086          100.00%


Total Complaints based on Topics
                                 Resolved                          In Process                    Unresolved
 Complaint Topic                                                                                                              Total
                            Total            %             Total                %             Total           %
 Mobile Internet          190,379        99,998%          328,609           99.94%               213         0.06%           190,379
 Charging                 349,423        99,987%           183,620          99.81%               355          0.19%          349,423
 Registration             348,780        99,996%           138,767          99.92%               112         0.08%           348,780
 Others                   746,783        99,977%           530,143          99.96%              202          0.04%           746,783
 Total                 1,635,365         99,986%          1,181,139          99.9%              882          0.07%       1,635,365


1. Customer Satisfaction Survey [OJK F.30]                              2. Customer Appreciation
XL Axiata encourages for any input from customers to                       XL Axiata believes that brand loyalty among its customers
improve products and services and increase customer                        is built around a good relationships and communication
satisfaction levels. XL Axiata collects feedback from                      between the Company and customers. To appreciate its
customers through surveys conducted periodically. XL                       customers and increase their engagement, XL Axiata
Axiata conducts Net Promoter Survey (NPS) every day to                     has taken several initiatives in 2024, which are explained
obtain information on customer perceptions of XL Axiata’s                  as follows:
brand and service quality, so as to identify factors that affect
customer satisfaction and improve customer experience.


In 2024, TNPS results showed an increase from 2023 to
2024 by 36% (Source: Medallia) and reflected the growth of
customer satisfaction 4x faster than competitors. (Source:
Kantar Indonesia).




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SUSTAINABLE INNOVATION [OJK F.26]                             •   Keeping up with technological developments and build
                                                                  products tailored to new technologies and market
As XL Axiata agrees that the corporate image will not only        needs.
be determined solely from its financial and operational       •   Conducting market research with the Market Intelligence
performances, XL Axiata always drives culture of innovation       team to be able to find out updates and trends in the
among the employees of the Company. XL Axiata                     telco world in the community.
welcomes any fresh ideas of product designs to meet           •   Discussing internally with the IT & Network team to
evolving customer expectations, to build up our competitive       utilize new features, as part of the product development
advantage and possibly, to attract strategic collaborations       mission.
with business partners that are ready to venture into the     •   Conducting regular reviews and evaluations of existing
new business philosophy behind the product innovations as         products, to define features that can be further
a driver of future growth.                                        developed.


Therefore in 2024, XL Axiata has launched a series of         In addition, as part of the journey to align the Company’s
innovative customer experience. The Company believes          products and services with sustainability values, XL Axiata
that product innovation will help it create new markets       integrates its sustainability principles into the product
and opportunities for growth and improve competitiveness      innovation process, from ideation to the launch. The
as it strives to meet needs and preferences of customers,     Company therefore considers sustainability aspects, such as
stakeholders and regulators.                                  reusability and recyclable to avoid waste while focusing on
                                                              circularity of the product design. The Company also takes
Below is the list of steps the Company takes in developing    into account, and optimization of less-emission and less-
products and services:                                        pollution energy and resources when the Company wants
• Evaluation with NPS.                                        to generate better impacts and benefits of the products.
• Brainstorming to get new product ideas and innovations.     The Company also aligns customer values and expectations
• Benchmarking with local and foreign operators and           while focusing on the design-for-value.
   similar businesses.




                                                                                     2024 Sustainability Report        123
Page 126
About This
Report
Page 127
     The Sustainability Report is XL
Axiata’s media of communication with
its stakeholders about the sustainability
performances of the Company. This
report is expected to clearly reflect our
sustainable commitment, performance
and transformation. XL Axiata has
been consistent in publishing the
Sustainability Report once a year.
Page 128
                                                                                                            About This Report




Frameworks Applied

XL Axiata’s 2024 Sustainability Report has applied the following frameworks:
● POJK No. 51/OJK.03/2017
● SEOJK No. 16/SEOJK.04/2021
● Reference to GRI Standards 2021


XL Axiata’s 2024 Sustainability Report reports the sustainability information with GRI standards’ option of “with reference to”.
The Company has closely followed the requirements and disclosures of GRI 1: Foundation in the preparation of the Company’s
sustainability report.


The Company also adhere to reporting principles for defining the report quality, which include:




                      Accuracy                                                 Completeness

                                                                               Sustainability
                      Balance
                                                                               Context

                      Clarity                                                  Timeliness

                      Completeness                                             Verifiability



The reporting principles gives XL Axiata a guidance for preparing a quality and proper presentation of the reported information,
thus helping it make decisions on the impactful contributions for the sustainable development.


The Company has also aligned the sustainability reporting with other statutory and regulatory reporting, in particular the
annual report and the financial statements of the Company.


The report has inserted the content indexes of each framework applied at the end of the report to make our reported
information traceable and to increase credibility and transparency of our report.




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Scope and Reporting Period

XL Axiata is committed to publishing a Sustainability Report on an annual basis. The report is released as an integrated part
of XL Axiata’s annual report that is published in a separate document. The sustainability reporting period is in line with the
reporting period of the Company’s financial statement, extending from 1 January to 31 December, which has been audited by
Public Accounting Firm and has consolidated the reports of the Company and the subsidiaries. The report was released on 21
February 2025 or within the timeframe set by OJK for the submission of the sustainability report. [GRI 2-3]


The scope of reported information covers financial, environmental, social and governance performances of PT XL AXIATA Tbk,
and unless stated otherwise. [GRI 2-2]


There is no restatement of information in this report. [GRI 2-4]




Verification
In regard to the Verifiability principle, the Company has not assigned an external assurance to review its 2024 Sustainability
Report. [GRI 2-5] [OJK G.1]


The Company launched an internal verification to ensure the credibility and quality of the reported information. The Company
has assigned the Highest Governance Body consisting of the Board of Commissioners, Board of Directors and Sustainability
Unit, which were the organs responsible for accuracy and transparency of sustainability information, including the material
topics, to validate the reported information. The Company also made reviews and acknowledgement of the reported data on
a quarterly basis (BRCC and RBCC) whereas the final data approval was on 15 February 2025.


For further information or inquiries about this Report, please contact the following address: [GRI 2-3]


PT XL AXIATA TBK
Head Office
Corporate Communication Department


XL Axiata Tower
Jl. H.R Rasuna Said X5 Kav. 11-12
Kuningan Timur, Setiabudi, Jakarta Selatan 12950


Telp:(62-21) 576 1881
Fax: (62-21) 579 59928
Email: corpcomm@xl.co.id ; corpsec@xl.co.id




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                                                                                                 About This Report




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            42
Disclosures 2021   2-2 Entities included in the        55, 127
                   organization’s sustainability
                   reporting
                   2-3 Reporting period,                127
                   frequency and contact point
                   2-4 Restatements of                  127
                   information
                   2-5 External assurance               127
                   Activities and Employees
                   2-6 Activities, value chain and     42, 56
                   other business relationships
                   2-7 Employees                        101
                   2-8 Workers who are not              103
                   employees
                   Sustainable Governance
                   2-9 Governance structure and          62
                   composition
                   2-10 Nomination and selection         65
                   of the highest governance body
                   2-11 Chair of the highest             62
                   governance body
                   2-12 Role of the highest              65
                   governance body in overseeing
                   the management of impacts
                   2-13 Delegation of responsibility     65
                   for managing impacts
                   2-14 Role of the highest              28
                   governance body in
                   sustainability reporting
                   2-15 Conflicts of interest            68
                   2-16 Communication of critical      67,73
                   concerns
                   2-17 Collective knowledge of          69
                   the highest governance body
                   2-18 Evaluation of the                66
                   performance of the highest
                   governance body
                   2-19 Remuneration policies            67
                   2-20 Process to determine             67
                   remuneration
                   2-21 Annual total compensation        68
                   ratio




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                              Disclosure                                          Omission                   GRI Sector
 GRI Standard                                           PAGE        Requirement                              Standard
                           Index No. Titles                                        Reason    Explanation      Ref. No.
                                                                      Omitted
                   Policy Strategies and Implementations
                   2-22 Statement on sustainable        28, 30
                   development strategy
                   2-23 Policy commitments              28, 74
                   2-24 Embedding policy              30, 33, 74,
                   commitments                            80
                   2-25 Processes to remediate          33, 73
                   negative impacts
                   2-26 Mechanisms for seeking            73
                   advice and raising concerns
                   2-27 Compliance with laws and          77
                   regulations
                   2-28 Membership associations           57
                   Stakeholders Engagement
                   2-29 Approach to stakeholder           70
                   engagement
                   2-30 Collective bargaining            104
                   agreements
Material Topics
GRI 3: Material    3-1 Process to determine               28
Topics 2021        material topics
                   3-2 List of material topics            28
DISCLOSURE OF SPECIFIC TOPICS
Economic Impacts
                   201 Economic performance
GRI 3:             3-3 Management of material             92
Management         topics
Approach 2021
GRI 201:           201-1 Direct economic value            92
Economic           generated and distributed
Performance        201-2 Financial implications and       93
2016               other risks and opportunities
                   due to climate change
                   201-3 Defined benefit plan             93
                   obligations and other
                   retirement plans
                   201-4 Financial assistance             94
                   received from government
                   202 Market presence
GRI 3:             3-3 Management of material             92
Management         topics
Approach 2021
GRI 202: Market    202-1 Ratios of standard entry        104
Presence 2016      level wage by gender compared
                   to local minimum wage
                   202-2 Proportion of senior            104
                   management hired from the
                   local community




                                                                                     2024 Sustainability Report         129
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                                                                                               About This Report




                              Disclosure                                     Omission                 GRI Sector
 GRI Standard                                          PAGE    Requirement                            Standard
                           Index No. Titles                                   Reason    Explanation    Ref. No.
                                                                 Omitted
                    204 Procurement practices
GRI 3:              3-3 Management of material          117
Management          topics
Approach 2021
GRI 204:            204-1 Proportion of spending        117
Procurement         on local suppliers
Practices 2016
                    205 Anti-corruptions
GRI 3:              3-3 Management of material          75
Management          topics
Approach 2021
GRI 205: Anti-      205-1 Operations assessed for       75
corruption 2016     risks related to corruption
                    205-2 Communication and             75
                    training about anti-corruption
                    policies and procedures
                    205-3 Confirmed incidents of        75
                    corruption and actions taken
Environmental Impacts
                    302 Energy
GRI 3:              3-3 Management of material          82
Management          topics
Approach 2021
GRI 302: Energy     302-1 Energy consumption           82-83
2016                within the organization
                    302-2 Energy consumption           82-83
                    outside of the organization
                    302-3 Energy intensity             82-83
                    302-4 Reduction of energy          82-83
                    consumption
                    302-5 Reductions in energy         82-83
                    requirements of products and
                    services
                    303 Water and Effluents
GRI 3:              3-3 Management of material          81
Management          topics
Approach 2021
GRI 303: Water      303-3: Water Withdrawal             89
and Effluents       303-4: Water Discharge              89
2018
                    303-3: Water Consumption            89
                    304 Biodiversity
GRI 3:              3-3 Management of material          85
Management          topics
Approach 2021
GRI 304:            304-1: Operational sites owned,     85
Biodiversity 2016   leased, managed in, or adjacent
                    to, protected areas and areas of
                    high biodiversity value outside
                    protected areas




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                           Disclosure                                     Omission                   GRI Sector
 GRI Standard                                        PAGE   Requirement                              Standard
                        Index No. Titles                                   Reason    Explanation      Ref. No.
                                                              Omitted
                 305 Emissions
GRI 3:           3-3 Management of material           82
Management       topics
Approach 2021
GRI 305:         305-1 Direct (Scope 1) GHG           84
Emissions 2016   emissions
                 305-2 Energy indirect (Scope         84
                 2) GHG emissions
                 305-3 Other indirect (Scope 3)       84
                 GHG emissions
                 305-4 GHG emissions intensity        84
                 305-5 Reduction of GHG               89
                 emissions
                 GRI 306: Waste
GRI 3:           3-3 Management of material           86
Management       topics
Approach 2021
GRI 306: Waste   306-1: Waste generation and          86
2020             significant waste-related
                 impacts
                 306-2: Management of                 86
                 significant waste-related
                 impacts
                 306-3: Waste generated               87
                 306-4: Waste diverted from           87
                 disposal
                 306-5: Waste directed to             87
                 disposal
                 401 Employment
GRI 3:           3-3 Management of material           98
Management       topics
Approach 2021
GRI 401:         401-1 New employee hires and         99
Employment       employee turnover
2016             401-2 Benefits provided to full-     104
                 time employees that are not
                 provided to temporary or part-
                 time employees
                 401-3 Parental leave                 106
                 403 Occupational health and safety
GRI 3:           3-3 Management of material           106
Management       topics
Approach 2021
GRI 403:         403-1 Occupational health and        106
Occupational     safety management system
Health and
Safety 2018
                 403-2 Hazard identification, risk    109
                 assessment, and incident
                 investigation
                 403-3 Occupational health            109
                 services
                 403-4 Worker participation,          107
                 consultation, and
                 communication on occupational
                 health and safety




                                                                             2024 Sustainability Report         131
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                               Disclosure                                     Omission                 GRI Sector
  GRI Standard                                          PAGE    Requirement                            Standard
                            Index No. Titles                                   Reason    Explanation    Ref. No.
                                                                  Omitted
                    403-5 Worker training on            109
                    occupational health and safety
                    403-6 Promotion of worker           109
                    health
                    403-7 Prevention and                109
                    mitigation of occupational
                    health and safety impacts
                    directly linked by business
                    relationships
                    403-8 Workers covered by an         106
                    occupational health and safety
                    management system
                    403-9 Work-related injuries         109
                    403-10 Work-related ill health      109
                    404 Training and education
GRI 3:              3-3 Management of material            111
Management          topics
Approach 2021
GRI 404: Training   404-1 Average annual training         111
and Education       hours per employee
2016                404-2 Programs for upgrading          111
                    employee skills and transition
                    assistance programs
                    404-3 Percentage of                   113
                    employees receiving regular
                    performance and career
                    development reviews
                    405 Diversity and Equal Opportunity
GRI 3:              3-3 Management of material            101
Management          topics
Approach 2021
GRI 405:            405-1 Diversity of governance         101
Diversity and       bodies and employees
Equal               405-2 Ratio of basic salary and     104
Opportunity         remuneration of women to men
2016
                    406 Non Discrimination
GRI 3:              3-3 Management of material            98
Management          topics
Approach 2021
GRI 406: Non        406-1: Incidents of                   99
Discrimination      discrimination and corrective
2026                actions taken
                    408 Child labor
GRI 3:              3-3 Management of material            98
Management          topics
Approach 2021
GRI 408: Child      408-1 Operations and suppliers      104
Labor 2016          at significant risk for incidents
                    of child labor
                    409 Forced or compulsory labor
GRI 3:              3-3 Management of material            98
Management          topics
Approach 2021
GRI 409: Forced     409-1 Operations and suppliers      104
or Compulsory       at significant risk for incidents
Labor 2016          of forced or compulsory labor




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                            Disclosure                                       Omission                   GRI Sector
 GRI Standard                                        PAGE      Requirement                              Standard
                          Index No. Titles                                    Reason    Explanation      Ref. No.
                                                                 Omitted
                  413 Local communities
GRI 3:            3-3 Management of material          114
Management        topics
Approach 2021
GRI 413: Local    413-1 Operations with local        114-116
Communities       community engagement,
2016              impact assessments, and
                  development programs
                  413-2 Operations with              114-116
                  significant actual and potential
                  negative impacts on local
                  communities
                  416 Customer health and safety
GRI 3:            3-3 Management of material          119
Management        topics
Approach 2021
GRI 416:          416-1 Assessment of the health      120
Customer Health   and safety impacts of product
and Safety 2016   and service categories
                  416-2 Incidents of non-             120
                  compliance concerning the
                  health and safety impacts of
                  products and services
                  417: Marketing and Labeling
GRI 3:            3-3 Management of material           77
Management        topics
Approach 2021
GRI 417:          417-1: Requirements for product      77
Marketing and     and service information and
Labeling 2016     labeling
                  417-2: Incidents of non              77
                  compliance concerning product
                  and service information and
                  labeling
                  417-3: Incidents of non
                  compliance concerning
                  marketing communications
                  418 Customer Privacy
GRI 3:            3-3 Management of material          118
Management        topics
Approach 2021
GRI 418:          418-1: Substantiated complaints     118
Customer          concerning breaches of
Privacy 2016      customer privacy and losses of
                  customer data




                                                                                2024 Sustainability Report         133
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                                                                                                         About This Report




POJK 51/2017 Index [OJK G.5]

  INDEX
                                                      INDEX NAME                                               PAGE
    NO.
SUSTAINABILITY STRATEGY
A.1          Explanation of Sustainability Strategy                                                              28
SUSTAINABILITY PERFORMANCE HIGHLIGHTS
B.1          Economic Performance Highlights                                                                     7
B.2          Environmental Performance Highlights                                                                9
B.3          Social Performance Highlights                                                                       11
COMPANY PROFILE
C.1          Vision, mission, and value of Sustainability                                                        48
C.2          Company’s Address                                                                                   42
C.3          Scale Enterprises                                                                               53, 54, 101
C.4          Products, services, and business activities                                                       56-57
C.5          Member of Association                                                                               57
C.6          Change of Significant Organization                                                                  57
DIRECTORS STATEMENT
D.1          Directors Statement                                                                               20-23
SUSTAINABILITY GOVERNANCE
E.1          Management of Sustainable Finance Implementation                                                    64
E.2          Competency Development related to Sustainable Finance                                               69
E.3          Risk Assessment for Sustainable Finance Implementation                                            71-73
E.4          Stakeholders Engagement                                                                           70-71
E.5          Challenges of Sustainable Financial Implementation                                                  73
SUSTAINABILITY PERFORMANCE
F.1          Building A Culture of Sustainability                                                                36
Economic Performance
F.2          Comparison of performance Target and Production, Portfolios, Financial Target, or                   93
             Investment, revenue and Profit and Loss
F.3          Comparison of performance Target and Production, Portfolios, Financial Target, or                   93
             Investment on Financial Instruments or Projects in line with Sustainable Finance
             Implementation
Environmental Performance
General
F.4          Environmental Costs                                                                                 81
Material Aspects
F.5          The Use of Environmentally Friendly Materials                                                       88
Energy Aspects
F.6          The number and the intensity of energy use                                                          82
F.7          The efforts and achievements made energy efficiency including the use of renewable energy           82
             sources
Water Aspects
F.8          Water Consumption                                                                                   89
Biodiversity Aspects
F.9          The impact of operational areas near or in the area of conservation or biodiversity                 85
F.10         Biodiversity Conservation Efforts                                                                   85
Emission Aspects
F.11         The number and intensity of Emissions Produced Base by Type                                         84
F.12         The efforts and achievement of emission Reduction undertaken                                        85




134       PT XL Axiata Tbk
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  INDEX
                                                   INDEX NAME                                                 PAGE
    NO.
Aspect of Waste and Effluents
F.13        The Amount of Waste and Effluent Generated by Type                                                87, 89
F.14        Waste and Effluent Management Mechanism                                                             86
F.15        Spill that Occurred (if any)                                                                        89
Aspect of Environmental Complaints
F.16        The number and material environmental complaints received and resolved.                             89
Social Performance
F.17        The Company’s commitment to deliver products and/or services equivalent to the consumer             118
Employment Aspects
F.18        Equality of Employment Opportunities                                                                98
F.19        Child Labor and Forced Labor                                                                       104
F.20        The Minimum Wage                                                                                   105
F.21        Environmental work decent and safe                                                                 100
F.22        Training and Competency Development for Employees                                                 111-112
Community Aspects
F.23        Operational Impacts to Local Communities                                                            114
F.24        Public Complaints                                                                                   121
F.25        Environmental Social Responsibility Activity                                                    37, 115-116
Responsibility on the Development of Sustainable Finance Products and/or Services:
F.26        Innovation and Development of Sustainable Finance products and/or services                         123
F.27        Customer Safety                                                                                    120
F.28        Impact of Products/Services                                                                      119-120
F.29        The number of products recalled                                                                    120
F.30        Survey of customer satisfaction                                                                    122
OTHERS
G.1         Written Verification from an Independent Parties (if any)                                          127
G.2         Feedback Sheet                                                                                     136
G.3         Response to Previous Year's Report Feedback                                                        137
G.4         POJK 51/2017 Index                                                                               134-135




                                                                                      2024 Sustainability Report          135
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                                                                                                           About This Report




Feedback Form [OJK G.2]

Thank you to you for reading the 2024 Sustainability Report of PT XL Axiata 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 Sheet 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?




136      PT XL Axiata Tbk
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                                                                          Leading in Sustainability Digital Connectivity




Identity of Sender:

Name :

E-mail :



Identify by stakeholder category:
a. Shareholder
b. Government/Regulator
c. Community
d. Customer
e. Employee
f. Business Partners
g. Mass Media
h. NGO
i. Others, please state .............


                                               Please return this form to:

                                                 Corporate Secretary
                                                PT XL AXIATA TBK

                                                    XL Axiata Tower
                                    Jl. H.R Rasuna Said X5 Kav. 11-12 Kuningan Timur,
                                             Setiabudi, Jakarta Selatan 12950


                                                                                         e-mail: corpcomm@xl.co.id;
           Phone: (62-21) 576 1881               Fax. (62-21) 579 59928
                                                                                                 corpsec@xl.co.id




Response to Previous Year’s
Report Feedback [OJK G.3]
XL Axiata welcomes any feedbacks or advice from the stakeholders to help us improve the quality of the Company’s ESG
report in the coming year. However, until the 2024 Sustainability Report was submitted, XL Axiata did not receive any feedback
for the previous report.




                                                                                         2024 Sustainability Report        137
Page 140
2024
                     Sustainability Report
                     PT XL Axiata Tbk


PT XL Axiata Tbk
XL Axiata Tower
Jl. HR Rasuna Said X5. Kav.11 – 12,
Kuningan Timur, Setiabudi, Jakarta Selatan
Jakarta 12950 - Indonesia
Tel. (62-21) 576 1881
Fax. (62-21) 576 1880
www.xlaxiata.co.id

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Pages140
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Names mentioned 71 people and organisations named in the text · linked when the evidence is strong

linked org XL Axiata Tbk p.1 ×628
linked org Fortune Indonesia p.15 ×7
linked person DIAN SISWARINI · President Director p.23 ×10
linked org Smartfren Telecom Tbk p.25 ×7
linked person Dr. Hans Wijayasuriya p.26
linked person Nik Rizal Kamil · Commissioner p.26 ×2
linked person Julianto Sidarto p.26
linked person Didi Syafruddin Yahya p.26 ×2
linked person Yasmin Binti Aladad Khan p.26
linked person Feiruz Ikhwan · Director & Chief p.27 ×2
linked person David Arcelus Oses · Director & Chief p.27 ×2
linked person Abhijit Navalekar p.27
linked person Yessie D. Yosetya p.27
linked person I Gede Darmayusa · Director & Chief p.27 ×3
linked person Rico Usthavia Frans · Director & Chief IT p.27 ×2
linked org Axiata Group Berhad p.44 ×4
linked org Axiata Investments p.44 ×3
linked org Huawei Tech p.44
linked org Bank OCBC NISP Tbk p.46 ×2
linked org Link Net Tbk p.54 ×4
linked org Axiata Investment Indonesia p.55
linked org Smart Telecom p.59
possible org Adhi Karya p.49 ×2
possible person Gatot Subroto p.55
possible — Ratu · Maulia Head of Sustainability p.67
possible person Andi Chandra p.109
unresolved org Ministry of Manpower Management System Contractor Safety Management System p.18
unresolved org PT Pertamina Persero High Risk Project International p.18
unresolved org PT Smart Telcom p.25 ×3
unresolved person Dr. Muhamad Chatib Basri President Commissioner Vivek Sood · Commissioner p.26 ×5
unresolved org PT Excelcomindo Pratama p.44
unresolved org PT Grahametropolitan Lestari p.44
unresolved person Rachmat Santoso · Notaris p.44
unresolved org Minister of Justice p.44
unresolved org Axiata Investment (Indonesia p.44 ×2
unresolved org PT Huawei Tech Investment p.44
unresolved org PT Lintas Teknologi Indonesia p.44
unresolved org PT Nokia Solutions p.44
unresolved org PT Grahametropolitan p.45
unresolved org PT Excelcomindo p.45
unresolved org Indonesia Stock Exchange p.45
unresolved org Indocel Holding Sdn. Bhd. p.45
unresolved org TM International Sdn. Bhd. p.45
unresolved person H. Banjarmasin p.47
unresolved org Ministry of Women’s Empowerment and Child Protection p.47
unresolved person H. MTXL Axiata p.47
unresolved org Ministry of Social Affairs p.48
unresolved person Dr. Ir. H. Abdusy Syakur Amin p.48
unresolved org PT Princeton p.54 ×2
unresolved org PT Hipernet p.54 ×2
unresolved org Singapore Pte. Ltd. p.54
unresolved org Operating Singapura Pte. Ltd. p.55
unresolved org Previously Axiata Global Services Pte. Ltd. p.55
unresolved org Axiata Investments (Energi) Sdn. Bhd. p.55
unresolved org XL Smart Telecom Sejahtera Tbk p.59 ×2
unresolved person Dr. Hans · Commissioner p.65
unresolved — Yasmin · Independent p.65
unresolved — Julianto · Independent p.65
unresolved — Abhijit Jayant · Director & Chief p.65
unresolved — Marwan O. · Chief Corporate p.67
unresolved — Baasir · Affairs p.67
unresolved — Reza Zahid Mirza · Group Head Corporate Communications p.67
unresolved — Risky · Fauzi Climate Change and Decarbonization p.67
unresolved — Survey p.72
unresolved — governmental p.72
unresolved org PT PLN (Persero) p.84
unresolved org PT Ide Inovatif Bangsa p.87
unresolved — CFO · Director p.96
unresolved org Sustainability Digital Connectivity XL Axiata Tbk p.97
unresolved org Ministry of Marine Affairs and Fisheries p.117

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