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Table 3 shows that up to the second quarter of 2019, the AKM Pension Fund has almost reached its investment portfolio
                  target. As seen in the table, the achievement of ROI (without SPI) up to the second quarter of 2019 was 4.4% of the target
                  of 8.43%, so it has reached 45.69%. From the overall ROI achievement (without SPI), land and building instruments only
                  reached 4.59% of the target, amounting to 40.07%.

                  Investment income in land and building comes from rent and disposal of land and buildings. Following the 2019
                  investment plan, one of the strategies to increase returns is the sale of land and buildings in Greenville. Until the second
                  quarter of 2019, AKM Pension Fund has followed up with the process of negotiating the sale price between the pension
                  fund and prospective buyers.

                  Besides, there is still a target for divestment of a portion of PT ASM’s shares in 2019 which has not been realized until the
                  second quarter of 2019. For this reason, the feedback given to the AKM Pension Fund is so that it can seek settlement and
                  escort prospective buyers in fulfilling the requirements of the OJK. The aim is to get cash and reduce the opportunity
                  cost due to the completion of the longer PT ASM share divestment. The AKM Pension Fund follow up is still negotiating
                  the sale and purchase price of shares with PT ASM management to get the price that has been agreed upon.

                  5.  CONCLUSION

                  The implementation of the principles of transparency and accountability of the AKM Pension Fund is not following
                  the principles of good pension fund governance set out in the POJK. The weakness of the implementation of the
                  transparency principle is that AKM Pension Fund has not made timely and adequate disclosure of information such
                  as investment portfolio developments, portfolio reports summaries, and supervision of pension fund management
                  which is easily accessible by Participants through the pension fund website. The weakness of the implementation of
                  the principle of accountability is that there are no employees to perform functions at the Risk Management Unit and
                  the Head of the SPI Unit.

                  The  planning  stage  of  the  asset  allocation  process  shows  that  the  AKM  Pension  Fund  has  not  yet  determined
                  performance measures and standards as well as guidelines for rebalancing. Then, the weakness of the implementation
                  phase is that the AKM Pension Fund has not taken steps to find a portfolio that can achieve the maximum return for
                  each particular risk level and to find the optimal asset mix, which can meet the best return and risk combination to
                  meet investment limitations. faced by the AKM Pension Fund.

                  The limitation of this study is that this study focuses on governance analysis related to the application of the principles
                  of good governance and the asset allocation process carried out by the AKM Pension Fund and the data used in
                  describing the performance evaluation is only one year. From the limitations of this study, it is hoped that the next
                  research can analyze the implementation of stewardship code in pension funds with a defined contribution program
                  and added more years in evaluating the performance of pension funds in the process of asset allocation.






























                                                                                 International Conference on Sustainability  87
                                                                                 (5  Sustainability Practitioner Conference)
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