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4.  RESULTS AND ANALYSIS

               4.1.  Implementation of AKM Pension Fund Governance
               The results of the analysis of comparing the disparity in the implementation of AKM Pension Fund governance following
               POJK Number 16 / POJK.05 / 2016 are as follows.


                      Table 1 Results of Gap Analysis of AKM Pension Fund Governance Implementation following POJK
                                                Number 16 / POJK.05 / 2016
                No.          Principles                    Application                     Gap
                 1.   Transparency
                    Disclosure of information in a   a.   AKM Pension Fund has compiled a Pension Fund  The AKM Pension Fund
                    timely, adequate, clear, accurate,   Regulation (PDP) which has been endorsed by   website does not yet
                    comparable, and easily accessible   the Financial Services Authority (OJK)  provide information such as
                    manner to related parties  b.   Balance sheets and calculation results of   balance sheets and results of
                                                 business results, development of investment   business results calculations,
                                                 portfolios, a summary of supervisory reports   development of investment
                                                 from the Supervisory Board is submitted   portfolios, adequate summary
                                                 through the magazine every semester  reports, on time, and easily
                                             c.   The information displayed such as   accessible to participants
                                                 balance sheets and results of business
                                                 results calculations, investment portfolio
                                                 developments, summary reports have not been
                                                 submitted promptly
                 2.   Accountability
                    The competence of all instruments   a.   The accountability of the management to the   There are no employees
                    in the pension fund is following   Founder has been carried out through the   who carry out the Risk
                    their duties and responsibilities as   media of work meetings with the Founder and   Management Unit and Head
                    well as understanding their role in   compiling the Accountability report to the   of the SPI Unit
                    implementing Good Pension Fund   founder
                    Governance               b.   Regularly held Strategic Committee Meetings
                                                 (Komstrag)
                                             c.   In the AKM Pension Fund organizational
                                                 structure, there is a Risk Management unit.
                                                 However, there are no employees who have
                                                 served in the unit. In its implementation,
                                                 the duties and responsibilities of the risk
                                                 management function are carried out /
                                                 concurrently by the Internal Control System
                                                 unit. Besides, currently, there is a vacancy for the
                                                 SPI Unit Head.

                    Performance measures are based   a.   Assessment of the performance of the   There is no documentation
                    on agreed measures consistently   Management and the Supervisory Board   of a reward & punishment
                    and have a reward and punishment   is carried out using the performance   system
                    system                       measurement of the Founders
                                             b.   AKM Pension Fund does not have a reward &
                                                 punishment system documentation
                 3.   Responsibility
                    The principle of prudence in risk   a.   The Portfolio Placement Allocation Plan has   Corresponding
                    control is guided by the applicable   been prepared through an analysis note
                    regulations              b.   The Pension Fund has investment guidelines
                                                 thus investment activities can be carried out
                                                 following applicable regulations, in particular,
                                                 according to the Investment Direction by the
                                                 Founder
                                             c.   The investment implementation guidelines set
                                                 out the criteria for placement in each asset class;
                                                 purchase stage; sales stage; and exit policies so
                                                 that investment can be implemented prudently.
                 4.   Independence
                    Pension funds are not dominated by  There is analytical procedure from the Investment   Corresponding
                    any party and are not influenced by  Management Section, reviewed and approved by the
                    unilateral interests and are free from  Strategic Committee in the allocation of investment
                    conflicts of interest    process.






         82     International Conference on Sustainability
                (5  Sustainability Practitioner Conference)
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