Pt Medco Energi Internasional TbkIDX: MEDC

Limited Assurance Report 2025

· Issued by Pt Medco Energi Internasional Tbk
PT Medco Energi Internasional Tbk and its subsidiaries

Subject matter information included in the sustainability report as of December 31, 2025 and for the year then ended with the independent practitioner's limited assurance report



The original limited assurance report included herein is in Indonesian language

Independent Practitioner's Limited Assurance Report

Report No. 00011/2.1505/NS.0/02/0696-2/1/IV/2026

The Shareholders and the Boards of Commissioners and Directors PT Medco Energi Internasional Tbk Scope

We have been engaged by PT Medco Energi Internasional Tbk (the "Company") to perform a limited assurance engagement, as defined by the Standard on Assurance Engagement 3000 (Revised 2022) "Assurance Engagements Other than Audits or Reviews of Historical Financial Information" and Standard of Assurance Engagement 3410 "Assurance Engagements on Greenhouse Gas Statements" (collectively referred to as the "Professional Standards"), established by the Indonesian Institute of Certified Public Accountants ("IICPA"), here after referred to as the "Engagement", to report on the accompanying subject matter information included in the sustainability report of the Company and its subsidiaries (collectively referred to as the "Group") as of December 31, 2024 and for the year then ended (the "Sustainability Report") as specified in Appendix 1 of this independent practitioner's limited assurance report (the "Subject Matter Information").

Other than the Subject Matter Information as described in the preceding paragraph, which sets out the scope of our Engagement, we did not perform any procedures on the remaining information included in the Sustainability Report, and accordingly, we do not express an opinion, a conclusion, or any other forms of assurance on the following information:

  • Data sets, statements, information, systems, or approaches other than the indicators determined and selected by the Group's management for the purpose of reporting the Subject Matter Information in the Sustainability Report.

  • Any information (including sustainability information) presented or published elsewhere in the Group's reports, website, or other publications other than those presented in Appendix 1 of this independent practitioner's limited assurance report.

  • Any information (including sustainability information) prior to January 1, 2025 and subsequent to December 31, 2025.

    Criteria applied by management

    In preparing and presenting the accompanying Subject Matter Information, the Group's management applied the definitions that are applicable and relevant to the Subject Matter Information as set out in the Global Reporting Initiative Standards 2021 (the "Criteria"). Such Criteria were used for the purpose of reporting the Subject Matter Information and its inclusion in the Sustainability Report by the Group's management. As a result, the Subject Matter Information may not be suitable for other purposes.

    i

    KAP Purwanto Susanti dan Surja

    Registered Public Accountants KMK No. 69/MK/SK/2025 A member firm of Ernst & Young Global Limited



    The original limited assurance report included herein is in Indonesian language

    Independent Practitioner's Limited Assurance Report (continued)

    Report No. 00011/2.1505/NS.0/02/0696-2/1/IV/2026 (continued)

    Management's responsibilities

    The Group's management is responsible for selecting the Criteria, and for preparing and presenting the accompanying Subject Matter Information in accordance with the Criteria, in all material respects. This responsibility includes establishing and maintaining internal controls, maintaining adequate records and making estimates that are relevant to the preparation and presentation of the Subject Matter Information that it is free from material misstatement, whether due to fraud or error.

    Independent practitioner's responsibility

    Our responsibility is to express a conclusion on the preparation and presentation of the accompanying Subject Matter Information based on the sufficient and appropriate evidence we have obtained during our Engagement.

    We conducted our Engagement in accordance with the Professional Standards established by the IICPA, and the terms of reference for this Engagement as agreed with the Group's management. Those standards require that we plan and perform our Engagement to express a conclusion on whether anything has come to our attention that causes us to believe that the accompanying Subject Matter Information has not been prepared and presented, in all material respects, in accordance with the Criteria. The nature, timing, and extent of the procedures selected depend on our professional judgment, including an assessment of the risk of material misstatement, whether due to fraud or error.

    We believe that the evidence we have obtained is sufficient and appropriate to provide a basis for our limited assurance conclusion.

    Independent practitioner's independence and quality management

    We have complied with the independence and other relevant ethical requirements of the Code of Ethics for Public Accountants issued by the IICPA, which is founded on fundamental ethic principles of integrity, objectivity, professional competence and due care, confidentiality and professional behavior.

    Our Public Accounting Firm applies Standard on Quality Management 1, "Quality Management for Public Accounting Firms that Perform Audits or Reviews of Financial Statements, or Other Assurance or Related Services Engagements", established by the IICPA, which requires our Public Accounting Firm to design, implement and operate a system of quality management including policies or procedures regarding compliance with ethical requirements, professional standards and applicable legal and regulatory requirements.



    The original limited assurance report included herein is in Indonesian language

    Independent Practitioner's Limited Assurance Report (continued)

    Report No. 00011/2.1505/NS.0/02/0696-2/1/IV/2026 (continued)

    Description of procedures performed

    Procedures performed in a limited assurance engagement vary in nature and timing from and are less in extent than for a reasonable assurance engagement. Consequently, the level of assurance obtained in a limited assurance engagement is substantially lower than the assurance that would have been obtained had a reasonable assurance engagement been performed. Our procedures were designed to obtain a limited level of assurance on which to base our conclusion and do not provide all the evidence that would be required to provide a reasonable level of assurance.

    Although we considered the effectiveness of management's internal controls when determining the nature and extent of our procedures, our assurance engagement was not designed to provide assurance on internal controls. Our procedures did not include testing controls or performing procedures relating to checking aggregation or calculation of data within information technology systems.

    A limited assurance engagement consists of making enquiries, primarily of persons responsible for preparing and presenting the accompanying Subject Matter Information and related information, and applying analytical and other appropriate procedures.

    Our procedures included:

  • Enquiring key personnel to understand the process for collecting, collating and reporting the Subject Matter Information during the reporting period.

  • Performing analytical review procedures to support the reasonableness of the data used.

  • Comparing that the calculation criteria applied to the subject matters in accordance with the methodologies outlined in the Criteria.

  • Recalculating the performance metrics to confirm quantities that are stated as replicable.

  • Checking the accuracy of data used by tracing them to the underlying source information on a sample basis.

  • Undertaking site visits to oil and gas operation location, Corridor-Grissik, and to power operation location, Mitra Energi Batam (MEB) and Dalle Energi Batam (DEB)

iii



Shape the future with confidence

The original limited assurance report included herein is in Indonesian /angUape Independent Practitioner's Limited Assurance Report (continued) Report No. 00011/2.1505/NS.0/02/0696-2/1/IV/2026 (continued)

Conclusion

Based on our procedures and the evidence obtained, nothing has come to our attention that causes us to believe that the accompanying Subject Matter Information is not prepared and presented, in all material respects, in accordance with the Criteria.

Purpose of the independent practitioner's limited assurance report

This independent practitioner's limited assurance report was prepared and issued solely for inclusion in the Sustainability Report in connection with the reportinq and inclusion of the accompanyinq Subject Matter Information in the Sustainability Report by the Group's manaqement, and is not intended to be, and should not be, used for any other purposes.

KAP Purwanto Susanti dan Surja



Indrajuwana Komala Widjaja

Public Accountant Registration No. AP.0696 April 30, 2026

IV

The original subject matter information included herein is in Indonesian language

Appendix 1. Subject matter information included in the sustainability report of PT Medco Energi Internasional Tbk and its subsidiaries as of December 31, 2025 and for the year then ended GRI 2-7 - General disclosure - Employees

Indicators/disclosures

Type of entity and location

2025

1. Total number of employees, and a breakdown of this total by gender and by region (GRI 2-7)

Gender

Female

Oil & Gas (Oman, Thailand and

Singapore)

52

Male

264

Female

Oil & Gas (Indonesia)

434

Male

1,708

Female

Power (Indonesia)

132

Male

905

Region

Oman KSF

Oil & Gas (Indonesia, Oman, Thailand and Singapore)

215

Thailand (Bangkok Office)

52

Thailand (Field)

38

Singapore Office

11

Block A

162

South Sumatra Block

167

Rimau

77

South Natuna

Sea Block B

248

Lematang

15

Tarakan

22

Jakarta Office

1,193

Bangkanai

38

Sampang

10

Corridor

210

Region

MPI Headquarters

(Jakarta)

Power (Indonesia)

145

Pusaka Mini-hydro (Cianjur)

23

Cibalapulang Mini-hydro (Cianjur)

19

Ijen Geothermal

(Jakarta)

14

MEB & DEB

(Batam)

63

ELB (Batam)

73

MPE

(Palembang)

21

EPE

(Palembang)

22

TJBPS (Jepara)

216

Sarulla

Geothermal (North Tapanuli)

106

MPSI

(Pekanbaru)

43

Sumbawa Solar

PV (Sumbawa)

8

MRPR (Jakarta)

26

East Bali Solar PV (East Bali)

16

Sulut-1 (North Sulawesi) &

Timor-1 (East Nusa Tenggara)

209

Ijen Geothermal (Ijen)

33

Indicators/disclosures

Type of entity

and location

2025

Permanent

Temporary

  1. Total number of permanent employees, and a breakdown by gender and by region (GRI 2-7)

  2. Total number of temporary employees, and a breakdown by gender and by region (GRI 2-7)

Gender

Female

Oil & Gas (Oman, Thailand and Singapore)

52

-

Male

253

11

Female

Oil & Gas (Indonesia)

433

1

Male

1701

7

Female

Power (Indonesia)

111

21

Male

708

197

Region

Oman

Oil & Gas (Indonesia, Oman, Thailand and Singapore)

204

11

Thailand (Bangkok Office)

52

-

Thailand (Field)

38

-

Singapore Office

11

-

Block A

162

-

South Sumatra Block

167

-

Rimau

77

-

South Natuna Sea Block B

248

-

Lematang

15

-

Tarakan

22

-

Jakarta Office

1,185

8

Bangkanai

38

-

Sampang

10

-

Corridor

210

-

Region

MPI

Headquarters (Jakarta)

Power (Indonesia)

125

20

Pusaka Mini-hydro (Cianjur)

23

-

Cibalapulang Mini-hydro

(Cianjur)

18

1

Ijen Geothermal (Jakarta)

13

1

MEB & DEB

(Batam)

62

1

ELB (Batam)

62

11

MPE

(Palembang)

21

-

EPE

(Palembang)

22

-

TJBPS (Jepara)

212

4

Sarulla Geothermal

(Tapanuli Utara)

100

6

MPSI

(Pekanbaru)

38

5

Sumbawa Solar

PV (Sumbawa)

8

-

MRPR (Jakarta)

24

2

East Bali Solar PV (East Bali)

8

8

Sulut-1 (North Sulawesi) & Timor-1 (East

Nusa Tenggara)

64

145

Ijen Geothermal (Ijen)

19

14

4. Total number of non-guaranteed hours employees, and a breakdown by gender and by region (GRI 2-7)

Oil & Gas (Indonesia, Oman, Thailand and Singapore)

Not applicable

Power (Indonesia)

5. Total number of full-time employees, and a breakdown by gender and by region (GRI 2-7)

Oil & Gas (Indonesia, Oman, Thailand

and Singapore)

All MedcoEnergi employees are full-time employees. Please refer to Total number of permanent employees, and a breakdown by gender and by region (GRI 2-7) and Total number of temporary employees, and a breakdown by gender and by region (GRI 2-7)

disclosure for the data breakdown.

Power (Indonesia)

Indicators/disclosures

Type of entity

and location

2025

6. Total number of part-time employees, and a breakdown by gender and by region (GRI 2-7)

Oil & Gas (Indonesia,

Oman, Thailand and Singapore)

Not applicable

Power (Indonesia)

7. Methodologies and assumptions used to compile the data (GRI 2-7)

Oil & Gas (Indonesia, Oman, Thailand and Singapore)

The data has been compiled from database and manual compilation.

Power

(Indonesia)

8. Contextual information necessary to understand the data reported under GRI 2-7 a and 2-7 b (GRI 2-7)

Oil & Gas (Indonesia, Oman, Thailand

and Singapore)

All of MedcoEnergi's employees are full-time, and the majority of employees are full-time and permanent.

Power (Indonesia)

9. Description of significant fluctuations in the number of employees during the reporting period and between reporting periods (GRI 2-7)

Oil & Gas (Indonesia,

Oman, Thailand and Singapore)

Not applicable

Power

(Indonesia)

GRI 2-23 - Policy commitments

Indicators/disclosures

Type of entity and location

2025

10. Describe its policy commitments for responsible business conduct, including: i) the authoritative intergovernmental instruments that the commitments reference; ii) whether the commitments stipulate conducting due diligence; iii) whether the commitments stipulate applying the precautionary principle; iv) whether the commitments stipulate respecting human rights (GRI 2-23)

Corporate

MedcoEnergi's commitments to responsible business conduct are defined in policies that govern the Board of Commissioners, Board of Directors, the Senior Leadership and all employees to not only ensure good business conduct, but also to achieve safe, effective, and efficient business operations in accordance with all applicable laws and regulations.

Business conduct management: MedcoEnergi's governance is founded on the principles of Transparency, Accountability, Responsibility, Independence and Fairness. The Good Corporate Governance (GCG) guides us on how our organisation should be governed by the MedcoEnergi Board of Commissioners (BoC) and Board of Directors (BoD). By implementing these principles, MedcoEnergi aims to mitigate negative impacts related to poor governance, which could lead to unethical practices, financial mismanagement and diminished stakeholder confidence. The GCG can be accessed at https://www.medcoenergi.com/en/our-sustainability/governance-ethics/good-corporate-governance/.

Employee ethical conduct management: MedcoEnergi developed Code of Conduct (i.e., MedcoEnergi's Code) based on benchmarks with multinational companies and international leading practices as well as input from relevant corporate divisions. MedcoEnergi's Code is based on the corporate values of MedcoEnergi: professional, ethical, open and innovative. MedcoEnergi's Code defines the expectations, roles and responsibilities expected from MedcoEnergi people to uphold when conducting MedcoEnergi's business. This Code is aligned with international best practices in human rights, personal data privacy, anti-corruption and anti-money laundering. The Code of Supplier is part of MedcoEnergi's Code.

Indicators/disclosures

Type of entity

and location

2025

MedcoEnergi's Code can be accessed at https://www.medcoenergi.com/en/our-sustainability/governance-ethics/our-code/.

In March 2024, MedcoEnergi launched Corporate Anti-Money Laundering (AML) policy No COP-AIC-EXC-POL-003 dated 12 March 2024 to strengthen our commitment to prohibit money laundering and sets out the rules and guidelines for directors, employees and business partners in relation to the prevention of money laundering across MedcoEnergi's business. The policy can be accessed at

https://www.medcoenergi.com/en/our-sustainability/governance-ethics/sustainable-compliance/.

MedcoEnergi's Sustainability Policy outlines MedcoEnergi's commitments to maintain healthy, safe workplaces built upon a culture of mutual respect and MedcoEnergi's commitment to respect human rights, which is in line with the UN Guiding Principles for Business and Human Rights and the Voluntary Principles on Security and Human Rights. MedcoEnergi's Sustainability Policy can be accessed at https://www.medcoenergi.com/en/our-sustainability/our-approach/sustainability-policy/.

MedcoEnergi's HSE Policy outlines the Company's commitment to continuously improve HSE performance. It aims to achieve zero incidents, injuries and illnesses in all our activities and to protect MedcoEnergi's employees and stakeholders as well as the environment where we operate. The policy was updated in October 2024 to strengthen environmental governance, including enhanced stakeholder consultation, regular environmental reporting, expanded coverage of environmental dependencies, impacts, risks, and opportunities, and alignment with relevant global environmental treaties and policy objectives.

MedcoEnergi's HSE Policy can be accessed at https://www.medcoenergi.com/en/our-sustainability/health-safety/hse-policy/.

MedcoEnergi's Oil & Gas' Community Development Policy outlines MedcoEnergi's commitment to be a leading company in conducting social responsibility initiatives and activities in an ethical and sustainable manner and by listening and acting in response to the needs of the stakeholders wherever MedcoEnergi operates. MedcoEnergi's Community Development Policy can be accessed at

https://www.medcoenergi.com/en/our-sustainability/social-and-communities/creating-opportunities/.

Indicators/disclosures

Type of entity

and location

2025

MedcoEnergi's Oil & Gas' Security Policy describes MedcoEnergi's commitment to providing protection for employees, assets, facilities, operations and its reputation based on the Company's Mission, Vision and Values to secure the working environment as a foundation for sustainable business growth. MedcoEnergi's Security Policy can be accessed at

https://www.medcoenergi.com/en/our-sustainability/social-and-communities/creating-opportunities/.

The Security Policy was updated in July 2025 with the following amendment/revisions for improvement:

  • PDCA Framework: Adopted the Plan-Do-Check-Adjust (PDCA) method for a more structured and continuously improving security process.

  • MSMS Alignment: Fully aligned with the Medco Security Management System (MSMS) to ensure a consistent, company-wide security approach.

  • Digital Threats: Updated Pillar 4 to specifically cover digital threats and cybersecurity risks, recognizing their growing importance alongside physical security.

MedcoEnergi's Human Rights Policy describes MedcoEnergi's commitment to respect human rights as set out in the Universal Declaration of Human Rights (UDHR) and other instruments such as the International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work, comply with applicable laws of the countries where MedcoEnergi operates, promote human rights through the provision of accessible and affordable energy. The policy was signed on 10 January 2024 and can be accessed at https://www.medcoenergi.com/en/our-

sustainability/human-rights/.

11. Describe its specific policy commitment to respect human rights, including: i) the internationally recognized human rights that the commitment covers; ii) the categories of stakeholders, including at-risk or vulnerable groups, that the organization gives particular attention to in the commitment. (GRI 2-23)

Corporate

MedcoEnergi describes its specific commitment to respect human rights in:

  1. Code of Conduct

  2. Code of Supplier

  3. Sustainability Policy

  4. Security Policy

  5. Community Development Policy

  6. Human Rights Policy

    1. The internationally recognised human rights principles are stated in the following policies and relevant sections:

      1. Code of Conduct, page 16 in the Safe Workplace sub-section Human Rights section: "One of our Company's commitments in doing business ethically includes respecting others who work at and for the Company, treat every individual with respect, and doing our business operations in compliance to the relevant human rights laws wherever MedcoEnergi operates."

      2. Code of Supplier key elements bullet 1. "Follow the same ethical standards, including Our Code and the applied Company's policies/ procedures."

Indicators/disclosures

Type of entity

and location

2025

  1. MedcoEnergi's Sustainability Policy page 1 in the Environmental and Social Development section. "We are committed to complying with all applicable laws and regulations, to respecting human rights in line with the UN Guiding Principles for Business and Human Rights and the Voluntary Principles on Security and Human Rights, and to learning from and applying industry best practice and relevant international standards."

  2. MedcoEnergi's Oil & Gas' Security Policy paragraph 3. "MedcoEnergi is committed to complying with relevant laws and regulations, to respecting human rights in line with the UN Guiding Principles on Business and Human Rights and the Voluntary Principles on Security and Human Rights, and to learning from applying industry best practices with International Standards".

  3. MedcoEnergi's Oil & Gas' Community Development Policy paragraph 1. "MedcoEnergi is committed to creating a positive impact for the communities in our operational areas by deepening our engagement and empowering the people, creating self-reliant communities that are aligned with the United Nations Sustainable Development Goals".

  4. MedcoEnergi's Oil & Gas' Security Policy paragraph 3. "MedcoEnergi is committed to complying with relevant laws and regulations, to respecting human rights in line with the UN Guiding Principles on Business and Human Rights and the Voluntary Principles on Security and Human Rights, and to learning from applying industry best practices with International Standards".MedcoEnergi's Human Rights Policy, MedcoEnergi is committed to respecting human rights as set out in the Universal Declaration of Human Rights (UDHR) and other instruments such as the International Labour Organization Declaration on Fundamental Principles and Rights at Work. The Human Rights Policy encompasses a Management Framework, Commitments,

Grievance Mechanisms, Governance and applies to all MedcoEnergi companies and subsidiaries globally, including all business partners.

  1. The policies also mention the categories of stakeholders:

    1. Local Labour, Children, Local Communities in Code of Conduct page 16, in the Safe Workplace subsection Human Rights section.

    2. Suppliers, including suppliers of services, equipment, materials and other goods, agents, consultants, contractors, subcontractors and consortium in the Code of Supplier.

Indicators/disclosures

Type of entity

and location

2025

  1. Local Communities in MedcoEnergi's Sustainability Policy page 1, in the Environmental and Social Development and Local Community Empowerment section.

  2. Partnership with security stakeholders in MedcoEnergi's Oil & Gas' Security Policy point 6.

  3. Society & local communities and Business partners & their employees in MedcoEnergi's Human Rights Policy page 2, in Our Commitments section

  4. Directors, employees and business partners in relation to the prevention of money laundering across the Company's business. This Policy should be read inconjunction with the Code of Conduct, all relevant Company policies, procedures, and the applicable laws in all countries where the Company operations in

the Corporate Anti-Money Laundering Policy page 7.

12. Provide links to the policy commitments if publicly available, or, if the policy commitments are not publicly available, explain the reason for this (GRI 2-23)

Corporate

Links to Policies:

  • Code of Conduct: https://www.medcoenergi.com/en/our-sustainability/governance-ethics/our-code

  • Code of Supplier: https://www.medcoenergi.com/en/our-sustainability/governance-ethics/code-of-supplier/

  • Sustainability Policy: https://www.medcoenergi.com/en/our-sustainability/our-approach/sustainability-policy/

  • HSE Policy: https://www.medcoenergi.com/en/our-sustainability/health-safety/hse-policy/

  • Community Development Policy: https://www.medcoenergi.com/en/our-sustainability/social-and-communities/creating-opportunities/

  • Security Policy: https://www.medcoenergi.com/en/our-sustainability/social-and-communities/creating-opportunities/

  • Human Rights Policy: https://www.medcoenergi.com/en/our-sustainability/human-rights/

  • Corporate Anti-Money Laundering (AML):

https://www.medcoenergi.com/en/our-sustainability/governance-ethics/sustainable-compliance/

Note: MedcoEnergi summarises its commitment on Anti- Money Laundering in MedcoEnergi's website (please see https://www.medcoenergi.com/en/our-sustainability/governance-

ethics/sustainable-compliance/). Anti-Money Laundering Policy is not publicly available as

it is considered an internal company policy.

13. Report the level at which each of the policy commitments was approved within the organization, including whether this is the most senior level

(GRI 2-23)

Corporate

All of MedcoEnergi's corporate policies are approved by the Chief Executive Officer or at least one of the Board of Directors (BoD) members. The dates of approvals are either stated in the policies or elsewhere on the websites or in the internal documents.

Indicators/disclosures

Type of entity

and location

2025

These policies were approved by MedcoEnergi's Board of Directors (BoD) and communicated to all employees and relevant external stakeholders through emails, trainings and other forms of familiarisations and engagements:

  1. Code of Conduct: 4 May 2020

  2. Code of Supplier: 26 December 2022

  3. MedcoEnergi's Sustainability Policy: 8

    May 2020

  4. MedcoEnergi's HSE Policy: October

    2024

  5. MedcoEnergi's Oil & Gas' Community

    Development Policy: April 2020

  6. MedcoEnergi's Oil & Gas' Security

    Policy: July 2025 (update)

  7. MedcoEnergi's Human Rights Policy: 10

    January 2024

  8. Corporate Anti-Money Laundering: 12 March 2024

14. Report the extent to which the policy commitments apply to the organization's activities and to its business relationships (GRI 2-23)

Corporate

Code of Conduct:

Page 5 - Our Code shall be communicated to, implemented and followed by all stakeholders, including the Board of Commissioners, Board of Directors, employees, affiliates, business partners and guests of the Company without any exception and regardless of their geographical locations.

Code of Supplier:

Paragraph 1 - All of our stakeholders, including suppliers, shall follow this commitment.

Paragraph 2 - We expect this standard to be followed by all of our suppliers, including suppliers of services, equipment, materials and other goods, agents, consultants, contractors, subcontractors and consortium or other basis.

MedcoEnergi's Sustainability Policy: Paragraph 6 - This policy is mandatory and sets the expectations for all employees and business units managed by Medco Energi Internasional and it should be communicated to and understood by our stakeholders.

MedcoEnergi's HSE Policy:

Last paragraph - This policy applies to all employees and contractors of the Company and its subsidiaries.

MedcoEnergi's Oil & Gas' Community Development Policy:

Paragraph 2 - This policy applies to all community development initiatives and activities in all the Company's assets.

MedcoEnergi's Oil & Gas' Security Policy: Last paragraph - It is the responsibility of everyone in the Company to comply with this Policy and support its implementation.

MedcoEnergi's Human Rights Policy: Paragraph 4 - This commitment in this policy applies to all MedcoEnergi companies and subsidiaries globally, including all business partners from which we expect the same high standards and commitment.

Corporate Anti-Money Laundering Policy Page 7 - This policy applies to the Company's directors and employees although the Company expects that business partners and other performing work or services for on

behalf of company will comply with this policy.

Indicators/disclosures

Type of entity

and location

2025

15. Describe how the policy commitments are communicated to workers, business partners, and other relevant parties (GRI 2-23)

Corporate

MedcoEnergi's process for the company's Code of Conduct commitments requires them to be read, agreed to, and regularly signed by all workers through the annual Statement of Adherence (SoA) and Conflict of Interest (CoI) Declaration.

MedcoEnergi's process for the company's Code of Supplier commitments requires them to be read, agreed to, and signed by business partners whenever contracts are signed. The contracts between MedcoEnergi and third parties using MedcoEnergi's standard contracts include clauses that the contractors in countries where MedcoEnergi operates have committed themselves to complying with. This includes all applicable laws and regulations and MedcoEnergi's Business Ethics (Code of Conduct and Code of Supplier).

MedcoEnergi communicates the company's policy commitments to the stakeholders through:

  1. Code of Conduct & Code of Supplier:

    Posted in MedcoEnergi's website:

    • Code of Conduct: https://www.medcoenergi.com/en/ our-sustainability/governance-ethics/our-code/

    • Code of Supplier: https://www.medcoenergi.com/en/ our-sustainability/governance-ethics/code-of-supplier/

    • Internal familiarizations and engagements: Annual Statements of Adherence (SoA) - email blast in May 2025 and Conflicts of Interest (CoI) declarations - email blast in October 2025

    • External familiarization and engagements: (1) SCM e-Newsletter Q2 & Q3 period for Oil & Gas and Q4 period for Power; (2) Vendor Day (Feb 2025); (3) Contractor Forum (May 2025)

  2. MedcoEnergi's Sustainability Policy:

    • Posted in MedcoEnergi's website https://www.medcoenergi.com/en/ our-sustainability/our-approach/sustainability-policy/

    • Internal familiarizations and engagements: (1) Medco 101

      training for Leaders (Aug 2025); (2) Field Compliance 2025 Risk Awareness (Aug 2025) (3) Site Visit Audit on MEB DEB & Corridor (Nov 2025) (4) Induction to New Hire (Sep & Dec 2025)

    • External familiarizations and engagements: (1) SCM Vendor Day (Feb 2025); (2) Contractor Forum

      (May 2025); (3) SCM e-Newsletter Q4 period for Power

  3. MedcoEnergi's Oil & Gas' Community

    Development Policy:

    • Posted in MedcoEnergi's website https://www.medcoenergi.com/en/ our-sustainability/social-and-communities/creating-opportunities/

Indicators/disclosures

Type of entity

and location

2025

  1. MedcoEnergi's Human Rights Policy:

    • Posted in MedcoEnergi's website: https://www.medcoenergi.com/en/ our-sustainability/human-rights/

    • Internal familiarizations and engagements: (1) Medco 101 (Aug

      2025); (2) Human Rights Familiarisation to employees and leaders engagement in Corridor, Onshore, Thailand, Oman and SCM (Apr, May, Jun, Nov, and Dec 2025); (3) The Voluntary Principles on Security and Human Rights (VPSHR) Training (Jul 2025); (4) Induction to New Hire (Sep & Dec 2025);

    • External familiarization and engagements: (1) SCM Newsletter Q2, Q3, Q4 period for Oil & Gas and Q4 period for Power; (2) Contractor Forum (May 2025); (3) Human Rights Policy Workshop for Vendor (Jun 2025)

  2. MedcoEnergi's HSE Policy:

    • Posted in MedcoEnergi's website: https://www.medcoenergi.com/en/ our-sustainability/health-safety/hse-policy/

    • Internal familiarization and engagements: (1) Tarakan Safety Morning Meeting (Apr 2025); (2) HSEAC MM & Log. (Aug 2025)

  3. MedcoEnergi's Oil & Gas' Security Policy:

    • Posted in MedcoEnergi's website: https://www.medcoenergi.com/en/ our-sustainability/social-and-communities/creating-opportunities/

    • Internal familiarization: Security Monthly Meeting (Jul 2025)

  4. Corporate Anti-Money Laundering Policy:

    • Posted in MedcoEnergi's website: https://www.medcoenergi.com/en/ our-sustainability/governance-ethics/sustainable-compliance/

    • Internal formalization and engagements: refer to GRI 205-2

    • External formalization and engagements: refer to GRI 205-2

All MedcoEnergi's policies are available in English and Indonesian and can be accessed via MedcoEnergi's respective websites.

GRI 2-24 - Embedding policy commitments

Indicators/disclosures

Type of entity and location

2025

16. Describe how it embeds each of its policy commitments for responsible business conduct throughout its activities and business relationships, including: (GRI 2-24)

  1. How it allocates responsibility to implement the commitments across different levels within the organization;

Corporate

  1. It is part of the BoD's roles and responsibilities to oversee the implementation of the policy commitments. This is stated as follows:

    1. MedcoEnergi's Sustainability

      Manual (October 2022), pages 8-

      10 of 20, within the Sustainability Governance section: Structure & Oversight, and Roles & Responsibilities.

    2. Code of Conduct page 5: "MedcoEnergi defines a set of standards to govern the conduct of the Board of Commissioners, Board of Directors, and all employees for

the good and safety of all parties, as

well as to achieve an effective and efficient business operation conducted in accordance with all applicable laws and regulations."

This statement aligns with the 2024 Sustainability Report (page 52): "Pursuing Excellence in Our Governance", and the 2024 Annual Report (pages 98-101): "Corporate Governance."

  1. There are various divisions in the organisation with day-to-day responsibilities for implementing each of the policy commitments. This is officially stated in the following documents:

    1. MedcoEnergi's Sustainability

      Manual (October 2022), pages 10-

      20 of 20, within the Sustainability Governance section: Structure & Oversight, and Roles & Responsibilities for cross-functional divisions, and Appendix E (page 18 of 20) for ESG Governance.

    2. To support MedcoEnergi's best interests, Our Code must be communicated to, implemented by, and followed by all stakeholders, including the Board of Commissioners, Board of Directors, employees, affiliates, business partners, and guests of the Company, without exception and regardless of their geographical locations (CoC, page 5).

  2. The MedcoEnergi Sustainability Policy commitments are formally discussed in regular Sustainability and Risk Management Committee (SRMC) meetings, while the Code of Conduct and Code of Supplier are formally discussed in regular Good Corporate Governance (GCG) Committee meetings. Information about the SRMC is provided in the MedcoEnergi Sustainability Manual, pages 8-9 of 20. Further information about both the SRMC and GCG Committees can be found in the 2024 Annual Report, pages 102-103 and 108-109, and the 2024 Sustainability Report, pages 40-41 and 52-53. Meeting notes from the SRMC and GCG Committees are kept internally.

  3. Discussions and engagements about responsible business conduct between different levels or divisions in the organisation are held for cross-functional teams, employees and business partners. The activities and outcomes are reported to the GCG (Good Corporate Governance) Committee (for BoC and BoD) by the Audit and Integrity Compliance (AIC) Division.

  4. The Corporate Ethics and Compliance Committee (CECC) was established in October 2024 to ensure objective and fair processes in addressing all reported incidents, and to align with legal requirements, industry standards and international best practices. All allegation reports received through whistleblowing channels were promptly followed up by applying the principles of trust, impartiality and protection. MedcoEnergi determined appropriate and consistent

Indicators/disclosures

Type of entity

and location

2025

disciplinary actions in accordance with MedcoEnergi's procedures for addressing allegation reports. These procedures involved a thorough review by the Ethics and Compliance Committee, consisting of the Board of Directors (BoD) level, Senior Vice President Business Support, the Head of Corporate A&IC, HR, Legal and other relevant functions, as deemed necessary. This information can be accessed at: https://www.medcoenergi.com/en/our-

sustainability/governance-ethics/good-corporate-governance/.

ii. How it integrates the commitments into organizational strategies, operational policies, and operational procedures;

Corporate

1.a.MedcoEnergi has an Enterprise Risk Management (ERM) policy in place (MEI-CRM-GL -002 dated 1 July 2022), which is aligned with the Company's policies. All risks considered across the universe of risk categories reflect how responsible business conduct is implemented.

1.b.MedcoEnergi's policies align with the following economic, environmental, social, and human rights impact assessments:

  • The Sustainability Policy was defined based on the initial materiality assessment in 2018 and confirmed through a double materiality assessment in 2022.

  • The human rights assessments for the corporate level were conducted in 2022, and the results were used to establish our standalone human rights policy.

  • The Human Rights Impact Assessment (HRIA) for Block A and JOB Tomori was conducted in 2023 and finalised in January 2024. The HRIA was conducted as part of lenders' request to meet Equator Principles 4/EP4 requirements. As a follow-up to the Human Rights Impact Assessment (HRIA) in 2024, we launched respectful workplace policy which is an internal policy and conduct a series of offline and online familiarization on sites, along with human rights policy. Furthermore, we completed the Human Rights e-learning for MTBL (90 employees attended) and Corridor (302 employees attended). We also conducted familiarisation sessions for 16 Block A vendors.

1.c.As part of the annual Performance Management System (PMS) cycle, MedcoEnergi incorporates sustainability-related key performance indicators (KPIs) into MedcoEnergi's Team Performance Contracts (TPCs). MedcoEnergi aligns TPC outcomes with the Company's reward programmes, including salary reviews and performance incentives.

2. The Sustainability Assessment Guidelines for Projects December 2020 and updated in December 2024, as well as Sustainability Assessment Guidelines for Operations November 2022 documents show how Medco Oil & Gas identifies, assesses, and manages environmental and social risks across all stages in the projects and operations.

Indicators/disclosures

Type of entity

and location

2025

3. MedcoEnergi implements Operational Excellence Management System (OEMS), Anti Bribery Management System (ABMS), HSE Management System, Social Management System (SMS), Medco Security Management System (MSMS), and Contractor HSE Management System (CHSEMS). These include internal audits to monitor compliance with policy commitments. MedcoEnergi also monitors compliance with the policy commitments through the Company's Sustainability

Assessment for projects and operations.

iii. How it implements its commitments with and through its business relationships;

Corporate

MedcoEnergi's procurement practices apply pre-qualification processes, bidding criteria, or screening criteria consistent with the expectations stipulated in MedcoEnergi's Code of Conduct in the section entitled "Respecting Our Stakeholders", sub-section "Our Business Partners" and Code of Supplier.

Contracts between MedcoEnergi and third parties using MedcoEnergi's contract standards include clauses that the contractors in countries where MedcoEnergi operates, have committed themselves to complying with applicable laws and regulations and MedcoEnergi's Business Ethics (Code of Conduct and Code of Supplier).

MedcoEnergi's business processes consider the Code of Conduct's and Code of Supplier's commitments whenever the Company determines whether to initiate, continue, or terminate a business relationship.

The latest contract template, incorporating a standalone Human Rights Policy and

Sustainability Policy, was implemented in July 2024.

iv. Training that the organization provides on implementing the commitments

Corporate

MedcoEnergi provides various capability building and engagement sessions on implementing policy commitments:

  • Programmes to upgrade employees' skills and transition assistance refer to GRI 404-2.

  • Code of Conduct training refers to GRI 205-2 e through apprentice induction and Medco 101 - for New Leader

  • Code of Supplier through engagements with business partners on Vendor Day

  • The security training related to human rights training refers to GRI 410 through Gada Pratama Training.

Note: The Gada Pratama Training programme is designed for new security

guards and candidates.

GRI 203 - Indirect Economic Impacts

Indicators/disclosures

Type of entity

and location

2025

17. Extent of development of significant infrastructure

Oil & Gas

USD 681,468

investments and services supported (GRI 203-1)

(Indonesia,

Oman and

Thailand)

Power

(Indonesia)

USD 7,918

Indicators/disclosures

Type of entity

and location

2025

18. Current or expected impacts on communities and local economies, including positive and negative impacts where relevant (GRI 203-1)

Oil & Gas (Indonesia, Oman and Thailand), Power (Indonesia)

Investments in infrastructure in MedcoEnergi covers among others:

  • Road and bridge rehabilitation or development which brings better and extended access for local communities.

  • Public facilities construction or renovation for mosques, schools, lighting support, sanitation, river normalisation, water wells/clean water facility, housing for vulnerable groups, farming facilities, sports facilities, MSME Market stall center, multifunctional hall, and infrastructure to prevent flood.

These investments bring lasting impact to the receiving communities in the form of decent

and helpful public facilities for their everyday use.

19. Whether these investments and services are commercial, in-kind, or pro bono engagements (GRI 203-1)

Oil & Gas (Indonesia, Oman and Thailand), Power (Indonesia)

All investments in infrastructure are in-kind.

20. Examples of significant identified indirect economic impacts of the organization, including positive and negative impacts (GRI 203-2)

Oil & Gas (Indonesia and Thailand), Power (Indonesia)

Information on the Social Return on Investment (SROI) Report result in Rimau -Herbal Production Development Assistance and School Transportation Programme; Lematang - Forest Honey Cultivation and Improvement of Health Facilities; Thailand -Sensory Room and Coastal Classroom for Conservation are provided in 2025 MedcoEnergi Sustainability Report on page 129-131.

  1. Rimau

    • Herbal Production Development established a herbal production house for the Family Medicinal Plant (Tanaman Obat Keluarga "TOGA") group in Gajah Mati Village. The program's SROI was calculated at

1.25. This translates to a program present value of approximately IDR 92,863,225 from an investment of IDR 73,863,225 from the implementation of the program in 2022-2025.

  • Supporting School Transportation program for facilitating daily school transportation for students in Tabuan Village and Srikembang Village. The program's SROI was calculated at 2.21. This translates to a program present value of approximately IDR 477,596,848 from an investment of IDR 216,452,069 from the implementation of the program in 2022-2025.

  1. Lematang

    • Enhancing Primary Healthcare by Providing Medical Equipment, strengthened primary healthcare services at the Sumaja Makmur Puskesmas. The program's SROI was calculated at 1.28. This translates to a program present value of approximately IDR 86,458,440 from an investment of IDR 67,530,000 from the implementation of the program in 2024-2025.

    • Forest Honey Cultivation empowered local beekeepers through technical training, providing PPE, beehive boxes, fruit

Indicators/disclosures

Type of entity

and location

2025

tree seedlings, and security fencing. The program's SROI was calculated at 1.49. This translates to a program present value of approximately IDR 121,334,424 from an investment of IDR 81,362,100 from the implementation of the program in 2023-2025.

  1. Thailand

    • Coastal Classroom for Conservation to strengthen community capacity for self-managed resource stewardship and enhance local resilience. The program's SROI was calculated at 61.07. This translates to a program present value of approximately THB12,790,529 against an investment of about THB 209,429 from the implementation of the program in 2024-2025.

    • The Sensory and Physical Therapy Clinic at Chumphon Panyanukul School, Chumpon Province, aims to help students with intellectual disabilities, multiple disabilities, and autism to improve their concentration, physical readiness, and mental preparedness for learning. The program's SROI was calculated at 4.06. This translates to a program present value of approximately THB 2,565,945 against an investment of about THB 632,387 from the implementation of the program in 2022-2025.

21. Significance of the indirect economic impacts in the context of external benchmarks and stakeholder priorities, such as national and international standards, protocols, and policy agendas (GRI 203-2)

Oil & Gas (Indonesia and Thailand), Power (Indonesia)

These efforts in Sampang, Block A, Corridor, and Thailand support the realization of the following UN SDGs:

  • SDG 3 and 12 in Rimau Herbal Production Development

  • SDG 4 in Rimau Supporting School Transportation program

  • SDG 1, 2, and 3 in Lematang Enhancing Primary Healthcare by Providing Medical Equipment

  • SDG 4, 8, 10, and 15 in Lematang Forest Honey Cultivation

  • SDG 1, 4, 8, 11, 12, 14, and 17 in

    Thailand Coastal Classroom for Conservation

  • SDG 1, 4, 10, 11 and 12 in Thailand Sensory and Physical Therapy Clinic

GRI 205 - Anti-corruption

Indicators/disclosures

Type of entity and location

2025

22. Total number and percentage of operations assessed for risks related to corruption (GRI 205-1)

Number

Percentage

Oil & Gas (Indonesia, Oman, Thailand

and Singapore)

13

93%

Power

(Indonesia)

10

63%

23. Significant risks related to corruption identified through the risk assessment (GRI 205-1)

Corporate

Corporate crime liability, Procure-to-Pay (P2P) fraud risk, Conflict of Interest, Risk of OFAC & Other Sanction Compliance violation, Business Ethics violation, Risk of Harassment, and Risk of Falsifying, Misleading and Fraudulent or Manipulated Company's Data/Information.