a.

Blackout Period is a certain mandatory period during which Insiders are prohibited from performing Securities Transactions involving Company Securities;

b.

Stock Exchange is any entity that organizes and provides systems and mechanisms for matching buy and sell offers for the Securities from parties who wish to trade in such Securities;

c.

Securities are financial instruments, including but not limited to debt acknowledgment letters, commercial papers, bonds, stocks, evidence of debt, futures contracts on the Securities, and any derivatives of the Securities issued by an issuer or a public company;

d.

Material Information is important and relevant information or facts concerning events, occurrences, or circumstances that may affect the price of the Securities on any Stock Exchange and/or the decision of the investor, prospective investor, or other Parties who are interested in such Information or facts;

e.

Insider Information is any Material Information possessed by an Insider that has not been previously released to the general public;

f.

Public Information is any Material Information that has been publicly disclosed through authorized channels;

g.

Insider Trading is a Security Transaction in securities of an issuer or a public company performed by Insiders;

h.

Insider is a:

i.

Main Shareholders is any party who either directly or indirectly holds at least 20% (twenty percent) of the total voting rights of all shares who have voting rights issued by an issuer or public company or any lower amount as determined by the Financial Services Authority;

j.

Other Party is an individual, company, joint venture, or group that is not classified as an Insider and is not engaged in transactions with the Company;

k.

Telkom or Company is Perusahaan Perseroan (Persero) PT Telekomunikasi Indonesia Tbk;

l.

Tipping is the action of an Insider to inform the Other Party on the Material Information that has not been announced to the public;

m.

Securities Transactions is the activity of buying and selling Securities;

n.

Working Unit is an organizational unit led by an official at the level of:

(1)

The purpose of this Policy is to provide guidelines in regulating Insider Trading within Telkom, so that Securities Transactions involving the Company’s Securities and the Securities of issuers, public companies or other companies conducting transactions with Telkom are conducted by Telkom’s Insiders in accordance with the principles of fairness and honesty.

(2)

The objectives of this Policy are as follows:

a.

Provisions related to Insider Trading;

b.

Provisions related to Blackout Period;

c.

Securities Transactions that are not prohibited for the Insiders of Telkom; and

d.

Obligations of Insiders to report their Securities Transactions involving the Company’s Securities.

(1)

Insider Information of Telkom comprises non-public Material Information relating to:

(2)

Below are examples of Insider Information of Telkom as defined in paragraph (1):

(1)

The Blackout Period imposed by Telkom is divided into:

(2)

The Periodic Blackout Period starts 5 (five) business days before Insider Information of Telkom becomes Public Information, specifically before the release of:

a.

the quarterly financial statements; and

b.

the annual financial statements.

(3)

The Blackout Period for specific periods of time applies when there is a corporate action or other events that may affect the price of the Company's Securities.

(4)

The Company will notify Insiders of Telkom of the implementation of the Blackout Period using the format set out in Appendix IV of this Policy.

(5)

During the Blackout Period, Insiders of Telkom are prohibited from:

(1)

The Company shall enforce a Periodic Blackout Period in accordance with Article 7 paragraph (1), paragraph (2), and paragraph (3) of this Policy.

(2)

The Periodic Blackout Period is implemented automatically without any prior determination by the working unit that manages the Investor Relations function.

(3)

Notification on the implementation of the Periodic Blackout Period to Insiders of Telkom is done by the Working Unit that manages the Investor Relations function assisted by the Working Unit that manages employee and Company communication.

(4)

The implementation process for the Periodic Blackout Period shall follow the guidelines as set out in the Appendix I of this Regulation.

(1)

The Company implements the Blackout Period for specific periods of time as determined by the Working Unit that manages the investor relations function if there are any proposed corporate actions that falls under the category of Insider Information of Telkom as referred to in Article 4 of this Regulation.

(2)

The Company may enforce the Blackout Period for specific periods of time if there are any proposed corporate actions that, in the opinion of the Working Unit that manages the investor relations function, it may affect the price of the Company's Securities.

(3)

The notification of the implementation of the Blackout Period for specific periods of time to Insiders of Telkom is made by the Working Unit that manages the Investor Relations function with the assistance of the Working Unit that manages employee or Company communications.

(4)

The Company may at any time extend the term of the Blackout Period for a certain period of time, if required.

(5)

The implementation process of the Blackout Period for specific periods of time refers to the guidelines detailed  in Appendix II of this Regulation.

a.

Securities Transactions are conducted between Insiders of Telkom who possess the same Insider Information of Telkom regarding Securities of Telkom or issuers or public companies or other companies that are engaged in transactions with Telkom and such Securities Transactions occur off the Stock Exchange; or

b.

Securities Transactions are conducted by Insiders of Telkom who possess Insider Information of Telkom with parties who are not Insiders of Telkom on Securities of issuers or public companies or other companies that are engaged in transactions with Telkom and occur off the Stock Exchange subject to the following conditions:

1.

Such Insiders of Telkom shall first disclose all Insider Information of Telkom to such non-insider party;

2.

Such parties who are not Insiders of Telkom shall agree not to use the Insider Information of Telkom for anything other than conducting such Securities Transactions involving the Securities of issuers or public companies or other companies that are engaged in transactions with Telkom with such Insider of Telkom;

3.

Such non-Insider party shall provide a written statement to the Insider of Telkom who provides such information which states that the information that will be received will be kept confidential and will not be used for any other purposes other than to conduct such Securities Transaction involving the Securities issuers or public companies or other companies that are engaged in transactions with Telkom with such Insider of Telkom; and

4.

Such non-Insider party does not conduct a Securities Transaction involving the Securities of issuers or public companies or other companies that are engaged in a transaction with Telkom within a period of 6 (six) months since the date when the information is obtained, other than to carry out a Securities Transaction with such Insider of Telkom.

(1)

The Insiders of Telkom who carry out the Securities Transactions involving the Company’s Securities that are permitted under this Regulation are required to report such transaction to the Financial Services Authority (OJK).

(2)

Reporting as referred in paragraph (1) must be done no later than 10 (ten) days from the occurrence of the Securities Transaction involving the Company’s Securities.

(3)

In the event that the deadline for submitting the report as referred in paragraph (2) falls on a Saturday, Sunday, a public holiday, or a day when OJK is not otherwise open for business the report must be submitted no later than the next business day.

(4)

In the event that an Insider of Telkom submits a report after the deadline specified in paragraph (3), such delay will be calculated starting from the first day after the deadline for submitting the report as referred to in paragraph (3).

(1)

The report as referred to in Article 13 shall contain at minimum the following information:

a.

Name, domicile, and nationality;

b.

The number of shares purchased or sold;

c.

Purchase and sale price per share;

d.

Date of transaction; and

e.

Purpose of the transaction.

(2)

The form of the report as referred to in paragraph (1) of this Article 14  can be found at Appendix III of this Regulation.

(1)

This Regulation along with its Appendices are integral and inseparable.

(2)

The Head of the Working Unit that manages the Investor Relations function is authorized to enact further provisions under this Regulation.

(3)

This Regulation can be applied to the subsidiaries of Telkom and the affiliates of Telkom through an adoption and/or ratification mechanism.

(4)

In the event that there are any amendments to provisions related to Insider Trading in the applicable laws and regulations, articles of association, decisions of the board of commissioners, and/or the company regulations, compliance with such provisions will take precedence without awaiting amendments to this Regulation.

(5)

This Regulation comes into effect on the date it is determined.

APPENDIX I

Implementation Process of Regular Blackout Period

APPENDIX II

Implementation Process of Blackout Period for Certain Period of Time

APPENDIX III

Example of Format of Report on the Securities Transaction involving Company Securities by the Insiders of Telkom to the Financial Services Authority

APPENDIX IV

Example of Format of Notification on the Implementation of Blackout Period

Name

:

Address

:

Nationality

:

Number of Shares Purchased / Sold

:

Share Purchase Price

:

Share Sale Price

:

Transaction Date

:

Purpose of the transaction

: