12 August 2021

To our stakeholders:

I am pleased to confirm that PT Castlerock Consulting reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labour, Environment and Anti-Corruption.

In this annual Communication on Progress, we describe our actions to continually improve the integration of the Global Compact and its principles into our business strategy, culture and daily operations. We also commit to sharing this information with our stakeholders using our primary channels of communication.

Sincerely yours,
Mike Crosetti
Director

Castlerock is committed to the principle of equal treatment of all employees in its working environment where human rights are respected and make sure its workplace is free from discrimination and harassment. The Company operates a culture of mutual respect and dignity where harassment, bullying or discrimination of any kind are strictly prohibited.

Castlerock committed to recruit, promote and remunerate its employees solely on the basis of their ability to contribute to Castlerock’s objectives, without regard to their sex, race, disability, religion, national origin, ethnicity, sexual orientation, age or marital status unrelated to the job involved.

We recognise that discrimination against our employees deprives the Company of our full and diverse range of best services, limits our potential and is unacceptable. We therefore treat our employees with dignity and respect and provide a productive working environment free from discrimination, victimisation or harassment.

Castlerock will not tolerate discrimination against current or prospective employees who have a disability or who have had a disability in the past. We will not tolerate acts which breach this policy and all instances of such behaviour, or alleged behaviour, will be taken seriously, be fully investigated and may be subject to the Company’s disciplinary procedures. When necessary and appropriate, Castlerock will make reasonable adjustments to ensure that its employment arrangements or premises do not put a disabled person at a disadvantage. In cases of long-term illness, Castlerock will act reasonably, taking account of all the circumstances such as the individual’s ability to continue working satisfactorily, the possibility of a transfer to different duties, and any medical advice received.

Castlerock recognises that there is no risk to fellow employees or clients from normal social or work contact with an HIV-infected person. Those infected with the HIV virus will not usually be ill and their ability to work normally should be unaffected. Therefore, there is no reason to treat an individual with HIV infection differently from other employees. Employees will be expected to work normally with an individual who has, or is suspected of having, HIV/AIDS. If an employee becomes aware that a colleague is HIV infected, they are expected to treat this information as strictly confidential and should not disclose it to anyone else within or outside the Company without the individual’s consent.

Castlerock’s philosophy is to engender a supportive, fair and stimulating working environment where all our employees are given the opportunity to achieve their full potential and be rewarded for their achievements.
Working with people of different ideas, different styles and different skills sets, all of whom deliver in different ways, promotes a richer, more creative environment. People develop better and clients are served better. Such diversity is something which makes Castlerock a stronger company; it is something which we value and want to continue to enhance.

Castlerock’s workplace demographic are shown below:
The percentage of male employees shows 72% while female employee is 28%. By age, the highest percentage of Castlerock employee comes from age 50 above while age between 40-50 take the second higher percentage of 28%. This is related to the nature of its business in which longest consulting working experience is required due to the company provide advisory services to government, state-owned & private enterprises. The youngest age of Castlerock employee is 25 years old. The company complies with the prevailing Manpower Law to not employ below the minimum age of 18 years. Also, the company does not conduct any activities with or around children.

In term of diversity of religion, muslim shows 62% of the total employees. Therefore, the company has flexibility in which muslim employees may request additional time on Friday afternoon for prayers. Employees of other faiths may also apply for time off for religious obligations, as per common, reasonable practice.

By seeing the nature of Castlerock business activity to provide advisory service, the education level percentage between undergraduate and postgraduate is more or less the same between 33-34% while doctorate level shows 11%. The company also employ high school graduated to occupy support level position such as driver and office assistant.

Other human rights aspect in Castlerock is giving an option to employee with a flexible dress code. When working on Castlerock premises and where there is no expectation of either having to visit a client or being involved in a client meeting or presentation, then business-casual dress is acceptable.

Castlerock committed to making its workplace to be more appealing for good people to come and to work with Castlerock for the long term. Our aim is to recruit the best people and develop them to maximise their full potential. An infrastructure is in place to provide employees with assistance and support but employees are expected to be proactive in managing their own continuous self-development.

Castlerock endeavours to offer its employee with compensation and benefits that when valued in total are in the top half of the labor market for comparable positions. Consistent with Castlerock’s aim to operate as a meritocracy, “comparability” is based on work actually performed. Performance-based compensation represents an increasing percentage of total compensation as an employee gains experience and moves through the ranks. There is no cap or limit placed on what employees may earn through the performance-based portion of their compensation.

Castlerock provides formal, regular feedback through a number of processes including annual appraisal process, the aim of which is to ensure good, consistent performance and satisfactory progress against agreed objectives. Whilst Castlerock encourages employees to take ownership of their own development, support is provided through line manager coaching and formal training and development programmes.

Ongoing training and development of our employees is central to the success of our business. Castlerock aims to offer or support training and development (T&D) that will directly enhance an employee’s position-related capabilities and effectiveness, creating value for clients and the firm.

Castlerock always conforms to local employment legislation. Local law will always take precedence that can be seen from the followings:
• Castlerock does not have employee with below minimum standard wage
• Castlerock does not purchase goods or services that present opportunities for human trafficking or modern slavery
• Castlerock does not participate in any form of forced or bonded labor.
• Castlerock provides employee with comprehensive health insurance coverage in addition to the mandatory BPJS Manpower and Healthcare benefits. The employee health insurance covers benefits of hospitalization, outpatient, maternity, dental and vision

Castlerock recognises the importance of promoting and maintaining the general health and wellbeing of its employees. This is the reason Castlerock provides the comprehensive medical coverage as stated above.

Prior to joining Castlerock, employees are required to sign a contract of employment, appropriate to their rank. An employee’s offer letter, the contract of employment, the manuals and documents referred to therein make up the terms and conditions of their employment to which both employee and Castlerock must adhere.

Castlerock is committed to providing a clean, healthy and safe work environment, and expects employees to take every reasonable care to avoid injury to themselves, their colleagues and their clients.

Castlerock recognises and accepts its responsibilities as an employer for providing, so far as is reasonably practicable, safe and healthy work places and environments for all its employees on all Castlerock sites.

This places responsibilities on employers, employees, contractors and on-site visitors to prevent and reduce risks to health and safety. In order to be effective, it is vital that employees work in partnership with their employer in order to promote healthy and safe working practices.

Castlerock will always take all steps within its ability to meet this responsibility, paying particular attention to the provision and maintenance of:
• Equipment and systems of work
• Arrangements for the use, handling, storage and transport of articles and substances
• Information, instruction, training and supervision to enable employees to recognise hazards and contribute positively to their own health and safety at work, and to the health and safety of others
• Access to and the safe working condition of the workplace.

Castlerock employees are provided with a guide on how to maintain a healthy and safe working environment as part of their induction programme. The guide contains practical advice and guidance e.g. how to carry heavy equipment safely, how to sit comfortably at their work station etc. In addition, Castlerock appoints Office Manager as Fire and First Aid Officers.

Castlerock always ensures that employees, contractors and visitors on site must take care to minimise the risks to their own safety and the safety of other employees and the public, i.e.:
• Ensure that they understand the health and safety precautions related to their job and observe them
• Familiarise themselves with fire and first aid procedures at their place of work
• Operate a computer in such a way as to minimise any risk from repetitive strain injuries (RSI) by taking frequent short breaks
• Ensure that they are aware of how to achieve a comfortable position when seated at a desk and seek guidance from the Office Manager should they have any queries
• Comply with the safety policy rules of client or other organisations when working on their sites.
To minimize the risk of fire, employees should not bring in to the office electrical equipment without it being checked for safe operation by the IT manager.
In order to provide a healthy and comfortable working environment, all Castlerock offices have been declared ‘no smoking’ areas.
This ‘no smoking rule’ is established Company policy and any breach of the policy would be deemed as potential misconduct which could lead to disciplinary action.
Castlerock expects its employees to drive in a responsible and safe manner whilst on Company business. In particular, they should ensure that they:
• Consider whether the journey is absolutely necessary. For example, it may be possible to avoid the journey by making use of teleconferencing facilities.
• Review whether a journey by public transport may be cheaper or more appropriate. Employees should remember that the environmental impact of any journey could be reduced by using public transport
• Allocate sufficient time for their journey. Employees should take into account the time of day they will be travelling, weather conditions and the need to take regular rest breaks (at least once every two hours)
• Ensure they maintain their vehicle in good working order. Prior to long journeys, employees should conduct a check of tire pressures, oil, water and fuel levels
• Adhere to all legal requirements regarding speed limits, alcohol consumption etc.

Castlerock is committed to ensuring that all the processes, products and systems it supplies are not dangerous if used for the purposes for which they are intended

Castlerock recognises that it is not in its interest to treat the physical environment in counter-productive ways. Castlerock will therefore carefully consider the effects of its choices on the state of the environment in making business decisions

Since its operation in 1996, Castlerock has not have any reported cases of injuries, accidents and potential hazards on Castlerock's premises.

Castlerock is owned at least in part by persons subject to the laws and regulations of the United States of America. Therefore, its employees are also subject to the laws and regulations of the United States of America, including but not limited to the Foreign Corrupt Practices Act of 1997 as amended. The employee represents that it understands such Act, and that it does not and will not retain or employ directly or indirectly any official of Indonesia or any person acting in an official capacity for the Government of Indonesia, or department, agency, or instrumentally thereof. The employee agrees that they will abide by all applicable laws, rules and regulations which may be in effect from time to time.

Castlerock employees should avoid all situations that might give rise to a conflict with the interests of Castlerock or its clients, whether actual or perceived:
• Bribery, whether from or to an employee, a client, a supplier, a government or a lender, necessarily involves cheating and rule-breaking, and is therefore intrinsically unethical. All payment or receipt of bribes or kickbacks is strictly forbidden
• Because they may appear to be and can be a form of bribery, or may be suspected of swaying the recipients’ judgement, gifts and benefits may not be given to or received from clients or suppliers by Castlerock employees in the course of their work. Entertainment such as meals with clients is permissible and is covered in the expense reimbursement manual. Meals with suppliers (apart from on-site working meals) are not permitted if those present are only Castlerock and the supplier; an exception can be where, for example, other potential Castlerock clients will be present

Employees warrants and represents that no part of any monies received that will be paid by employees or employees’s agents or employees to governmental officials, agents or employees, or used as commercial bribes or as influencing an award payment or as kick-backs or as political contributions. Employees shall promptly notify the Company of any violation that becomes known to employees.

Any representative authorized by the Company may audit any and all records of employees. Further, employees agrees to make an annual certification, under oath or affirmation, as to whether or not payments in contravention of the above have been made by or on behalf of employees, and if such payments have been made, employees will furnish the Company with the identity of the recipient or recipients and the purpose and amount of all such payments.

• As a firm, Castlerock has a responsibility:
 to make clear what it considers to be acceptable conduct
 to provide guidance in the case of grey areas
 to respond deliberately, constructively and fairly to all concerns raised

• Every Castlerock employee has a responsibility:
 to read and understand Castlerock Code of Conduct
 to declare, when first joining the firm (and later if asked to do so again), any of their own or their family’s business and non-business interests that they feel could be of concern to Castlerock and any other ethical or conflict of interest issues, so that Castlerock will be aware of any actual or potential conflicts of interest that may arise.

Prior to the engagement of employee and subcontractors, the person is required to sign an agreement that they agrees to abide by all applicable laws, rules and regulations on anti-corruption and bribery. In the event of any actual breach, the Company shall immediately terminate the employment.

Since its operation in 1996, Castlerock has maintained its business integrity and comply with the applicable law for anti-corruption practices.