Morgan Stanley Capital International (MSCI) ESG Index

No Sustainability Indicator Explanation Evidence
Key Issue: Carbon Emission    
Component: Carbon Emission Target    
1.1 Carbon emissions target progress: Carbon emissions target comprehensiveness

Telkom has established quantitative carbon reduction targets covering Scope 1 and Scope 2 GHG emissions across TelkomGroup entities, with 2023 as the base year. Under the TelkomGroup Climate Transition Plan, launched in 2025, the Company targets a 20% reduction in Scope 1 and Scope 2 emissions by 2030 and net-zero emissions by 2060.

In 2025, Scope 1 and Scope 2 emissions represented approximately 53% of TelkomGroup’s total reported GHG emissions (1% Scope 1 and 52% Scope 2). Therefore, the current quantitative emissions-reduction targets cover approximately 53% of the total reported emissions footprint.

TelkomGroup also inventories Scope 3 emissions, with the inventory expanded in 2025 to include Categories 4, 7, 9, and 12. However, Scope 3 emissions are not currently covered by quantitative emissions-reduction targets.

Telkom Sustainability Report 2025 – Decarbonization Strategy (pp. 74–75);

Figure 29 TelkomGroup’s Transition Journey toward Net Zero Emissions by 2060;

TelkomGroup GHG Emission Performance (pp. 70–73);

TelkomGroup Sustainability Targets 2030 (p. 61);

Appendix 8 Methodology for Setting Greenhouse Gas Emission Reduction Targets (p. 233).

1.2 Carbon emissions target progress: Carbon emissions target progress

TelkomGroup monitors progress toward its environmental targets annually against the 2023 baseline. In 2025, market-based Scope 1 and Scope 2 GHG emissions increased by 3.7%, or 77,002.7 tCO?e, versus the baseline. Scope 1 emissions decreased by approximately 44%, primarily due to the transition to biodiesel (B40, B30, B20, and B10), while Scope 2 emissions increased by 3%, mainly due to asset expansion and the broader reporting scope across TelkomGroup. The 2025 performance reflects the early stage of implementation of the Climate Transition Plan, which was formulated in the second half of 2025.

For other environmental targets, TelkomGroup achieved a 73% diversion rate for fiber-optic cable waste, exceeding the 70% minimum target for 2030. Total waste generation was reduced by 24% in 2025, compared with the 70% minimum reduction target for 2030, indicating that further progress is required to achieve the long-term target.

Telkom Sustainability Report 2025 – Decarbonization Strategy (p. 74);

Table 18 GHG Emission Reduction Performance in 2025 Compared to the 2023 Base Year (pp. 110–111);

Table of Material Topics, 2030 Targets, and 2025 Achievements (p. 69).

1.3

Carbon emissions target progress: Carbon emissions target verification

As of the 2025 reporting period, TelkomGroup’s short- and long-term emission reduction targets had not yet been validated by the Science Based Targets initiative (SBTi). The targets were established with reference to Indonesia’s national commitment to achieving net-zero emissions by 2060 and TelkomGroup’s internal target-setting methodologies, including the relevant methods, assumptions, and limitations disclosed in Appendix 8 of the 2025 Sustainability Report.

Nevertheless, the underlying GHG emissions data used to monitor progress were independently verified by PT TÜV Rheinland Indonesia for the period January 1–December 31, 2025. The verification was performed in accordance with ISO 14064-3:2019 at a limited assurance level, using ISO 14064-1 as the applicable criteria. Separately, the 2025 Sustainability Report received external assurance from PT TÜV Rheinland Indonesia regarding its compliance with the GRI Standards 2021.

Telkom Sustainability Report 2025 – Appendix 11 GHG Emission Verification Opinion (pp. 241–242, Report No. TRID-GHG-N12-26008);

Appendix 10 Sustainability Report External Assurance Statement (pp. 237–240);

External Assurance (p. 8);

Appendix 8 (p. 233).

2.1

Carbon emissions performance relative to peers: Carbon emissions intensity industry relative score

TelkomGroup measures and publicly discloses revenue-based GHG emissions intensity, providing a standardized measure of emissions performance relative to business activity. In 2025, Scope 1 and Scope 2 GHG emissions intensity was 14.9 tCO?e per billion Rupiah of revenue on a market-based basis and 15.2 tCO?e per billion Rupiah of revenue on a location-based basis. Energy intensity was 63.8 GJ per billion Rupiah of revenue.

Scope 1 and Scope 2 emissions intensity is also disclosed at the entity level. In 2025, market-based emissions intensity was 6.4 tCO?e per billion Rupiah of revenue for Telkom, 15.9 tCO?e per billion Rupiah of revenue for Telkomsel, and 1.4 tCO?e per billion Rupiah of revenue for Mitratel.

TelkomGroup calculates GHG emissions in accordance with the GHG Protocol Corporate Accounting and Reporting Standard and ISO 14064-1, applying the operational control approach for organizational boundary consolidation. The reported 2025 GHG emissions inventory was independently verified by PT TÜV Rheinland Indonesia, providing external verification of the underlying emissions data.

Telkom Sustainability Report 2025 – Table 17 GHG Emission and Energy Performance (pp. 104–109);

Appendix 7 Greenhouse Gas Emission Calculation Methodology (pp. 231–232);

Appendix 11 GHG Emission Verification Opinion (pp. 241–242).

2.2

Carbon emissions performance relative to peers: Carbon emissions intensity industry relative trend score

TelkomGroup’s revenue-based Scope 1 and Scope 2 GHG emissions intensity increased gradually from 14.1 tCO?e per IDR billion of revenue in 2023 to 14.4 tCO?e in 2024 and 14.9 tCO?e in 2025 (market-based). Energy intensity followed a similar trend, increasing from 62.1 GJ per IDR billion of revenue in 2023 to 62.4 GJ in 2024 and 63.8 GJ in 2025.

The increase was primarily driven by the expansion of assets and services, including higher data traffic and data center capacity, together with an expanded data-collection scope across TelkomGroup. The 2023 and 2024 figures were restated following adjustments to the electricity data-collection methodology; therefore, the three-year trend is presented using the restated figures for comparability.

In response, TelkomGroup is implementing six decarbonization levers under its Climate Transition Plan: energy conservation and equipment modernization; electrification; renewable energy and energy storage; RECs/PPAs; carbon offsets; and leveraging the decarbonization of the national electricity grid.

Telkom Sustainability Report 2025 – Table 17 GHG Emission and Energy Performance (pp. 104–109);

Decarbonization Strategy and Figure 30 TelkomGroup Key Decarbonization Initiatives (pp. 74–75);

Table 1 Restatement of Information Due to Methodology Adjustments and Data Verification (p. 7).

No Sustainability Indicator Explanation Evidence
Key Issue: Labor Management    
Component: Labor Management Strategy    
3.1

Workforce eligible for non-pay benefits

TelkomGroup provides paid parental leave regardless of gender or job level, including 7 days of paid paternity leave and 3 months of paid maternity leave, with maternity leave extendable to up to 6 months based on specific medical indications. These benefits are part of the Company’s non-monetary remuneration framework, which also includes various leave entitlements and employee development opportunities such as scholarships and professional certification programs.

In 2025, 921 employees took maternity leave, with a 96.1% return-to-work rate and a 95.1% employee retention rate. TelkomGroup also applies equitable remuneration practices regardless of gender. The reported ratio of base salary and total remuneration between female and male employees was 1:1 across all employment levels.

Telkom Sustainability Report 2025 – Compensation and Benefits, Remuneration and Leave Policies (p. 124);

Table 23 Types and Terms of Employee Leave (p. 125);

Table 24 Return-to-Work and Employee Retention Rates (p. 125);

GRI disclosures 401-2, 401-3, and 405-2.

Key Issue: Privacy & Data Security    
Component: Privacy & Data Security Core Risk Management    
4.1

Rights provided to consumers regarding the control of their data

TelkomGroup acts as both a data controller and data processor and applies transparency, accountability, and compliance principles in the processing of personal data in accordance with Law No. 27 of 2022 on Personal Data Protection. Customers generally have the right to modify or delete their personal data and to receive notifications of personal data protection incidents. Additional data subject rights vary depending on the service, applicable legal basis, and processing context.

TelkomGroup provides information on data subject rights and privacy terms through relevant product websites and dedicated privacy-related customer service channels. For Telkomsel, these include the Privacy Policy page, cs@telkomsel.co.id, and hotline 188; for IndiHome, these include the applicable terms and conditions page, customercare@telkom.co.id, and hotline 147.

TelkomGroup also applies data retention and deletion requirements, including deletion of customer data following subscription termination, subject to applicable regulations and a minimum three-month retention period under TelkomGroup’s Data Operation Management Standards and Government Regulation No. 52 of 2000. Compliance with data subject rights is subject to internal and external audit in accordance with TelkomGroup’s Personal Data Protection Oversight Guidelines. In 2025, TelkomGroup recorded zero external complaints concerning alleged customer privacy violations.

Telkom Sustainability Report 2025 – Data Usage and Retention Policy to Protect Customer Rights (pp. 194–195);

Helping Our Customers Understand Their Personal Data Rights (p. 195);

Data Protection Governance (p. 191);

TelkomGroup Personal Data Protection Guidelines (p. 193).

Component: Privacy & Data Security Supplemental Risk Management    
5.1

Privacy enhancing technologies and initiatives

TelkomGroup applies the “Privacy by Design” principle by incorporating data privacy considerations from the initial design stage of applications, products, projects, and processes. Privacy impact assessments are systematically supported through the “Patuh PDP” platform, including Records of Processing Activities (RoPA) and Personal Data Protection Impact Assessments (DPIA/PIA). For AI development, projects are required to undergo an early-stage Privacy Threshold Analysis (PTA), with personal data protection impact assessments conducted throughout the AI lifecycle, where applicable.

Technology-based controls include encryption covering 32 critical databases containing personal information, 17 applications, 11 updated operating systems, and two encryption platforms as of 2025. TelkomGroup is also exploring Privacy-Enhancing Technologies (PETs), including User and Entity Behavior Analytics (UEBA), through demonstrations and proofs of concept with 12 technology providers, and conducted red-teaming exercises in Q3–Q4 2025.

TelkomGroup’s data governance maturity score improved from 1.97 to 2.98, progressing toward the “Defined” maturity level. These practices are supported by ISO 27701:2019 Privacy Information Management System certification and ISO 27001 certifications under the 2013 and 2022 standards.

Telkom Sustainability Report 2025 — Personal Data Protection (PDP) Compliance and Data Governance Framework (p. 192); Data Protection Policy (p. 192);

Figure 98 TelkomGroup Personal Data Protection Efforts (p. 193);

Data Usage and Retention Policy (p. 195);

AI Governance and Security at TelkomGroup and Figure 101 AI Lifecycle and Personal Data Protection Obligations (pp. 198–199).

5.2

Consent policy for use of consumer data for secondary purposes

TelkomGroup establishes an appropriate lawful basis before processing personal data, in accordance with the Personal Data Protection (PDP) Law. Depending on the processing activity, the lawful basis may include a contract, valid and explicit consent, or another legally recognized basis, including processing necessary for service delivery or regulatory compliance.

Data subject consent is incorporated into TelkomGroup’s Data Governance Framework together with controls covering data architecture, metadata, data quality, encryption, access control, and audit trails. Requests for personal data from external parties are reviewed by the Data Governance (DG) Council, including assessment of the processing purpose, data transfer method, and encryption requirements. Third-party processing is governed by data protection agreements and subject to controls throughout the processor lifecycle, from pre-engagement assessment through processing and post-contractual oversight.

In 2025, 100% of data requests from government and law enforcement agencies were fulfilled in compliance with applicable regulations. No third-party requests for data monetization or business consulting purposes were received. Third-party data disclosures were subject to Non-Disclosure Agreements aligned with TelkomGroup’s Data Governance policies, Data Control Standards, and the PDP Law. In total, 117 data-transfer use cases were securely managed using encryption in accordance with established procedures.

Telkom Sustainability Report 2025 — Controlled Secondary Data Processing and Figure 100 Data Processing Cycle (pp. 196–197);

Data Governance Framework and Figure 97 Telkom Data Governance Committee (p. 192);

Data Usage and Retention Policy (pp. 194–195).

No Sustainability Indicator Explanation Evidence
Key Issue: Business Ethics    
4.1

Oversight of Ethics Issues

Telkom’s business ethics and anti-corruption framework is subject to oversight by the Board of Commissioners and Board of Directors. The Audit Committee, under the Board of Commissioners, oversees and evaluates complaints received through the whistleblowing system, including Code of Ethics violations, in accordance with POJK Regulation No. 55/POJK.04/2015 and Section 301 of the Sarbanes-Oxley Act of 2002. An Investigation Committee conducts investigations, while employee-related ethical matters are addressed by the Ethics Committee (Employee Disciplinary Committee).

Telkom has maintained an SNI ISO 37001:2016 Anti-Bribery Management System (ABMS) since 2020. Under the ABMS governance structure, the Board of Commissioners acts as the Governing Body and the Board of Directors as Top Management, supported by the Anti-Bribery Compliance Function Committee (FKAP). FKAP comprises functions covering Anti-Bribery and Gratification Control; Evaluation and Internal Audit; Investigation and Handling; and Development and Documentation.

The Human Capital Service Operation unit monitors implementation of the Code of Ethics across TelkomGroup, with monitoring results and periodic evaluations reported to the Board of Directors. This governance structure provides formal Board-level oversight, independent complaint-handling and investigation mechanisms, and dedicated functions for anti-bribery compliance and ethics management.

Telkom Sustainability Report 2025 — Ethical Business Practices, Role of the Board and Management (p. 184);

Anti-Corruption and Bribery, Anti-Bribery Management System (SMAP) and Figure 95 Telkom FKAP Committee Structure (p. 185);

Telkom Integrity Line (pp. 187–189).

4.2

Regular Audits of Ethical Standards

TelkomGroup’s business ethics awareness and implementation, including workforce-wide business ethics surveys, are reviewed and audited annually through internal and external audit mechanisms. These activities form part of the Company’s entity-level internal control environment, which is aligned with the COSO Internal Control Framework.

The FKAP Committee routinely assesses corruption, bribery, and fraud risks across relevant operational areas and business units. In 2025, Telkom conducted a 100% bribery risk assessment for the Recruitment and Procurement functions identified as having bribery risks within the scope of its ISO 37001:2016 Anti-Bribery Management System. Telkom also implemented the KPK’s Corruption Prevention Guidelines (PANCEK), achieving a verification score approaching 100% in 2025.

Complaints submitted through the Telkom Integrity Line are reviewed by Internal Audit, investigated by the Investigation Committee, and the resulting findings are evaluated by the Audit Committee. This framework demonstrates formal risk assessment, monitoring, investigation, and oversight mechanisms for potential business ethics and anti-corruption issues.

Telkom Sustainability Report 2025 — Business Ethics Oversight and Evaluation (p. 184);

Anti-Bribery Management System (ABMS) and Anti-Corruption and Anti-Bribery Policy (pp. 185–186);

Figure 96 Telkom Integrity Line Procedure and Table 51 Data on Complaints Received via WBS (pp. 188–189).

4.3

Anti-Corruption Policy for Suppliers

Telkom applies its anti-corruption policy across its supplier base and has established formal compliance mechanisms to mitigate corruption, bribery, and conflict-of-interest risks in the procurement process. All business partners are required to sign an Integrity Pact prohibiting corruption, price collusion, and conflicts of interest, while also committing to ESG principles covering environmental sustainability, gender equality, human rights, OHS, and responsible corporate governance.

The Anti-Bribery Management System (SMAP) is integrated into supplier due diligence and procurement controls. These include supplier ownership verification, blacklist screening, reviews of internal and external corruption-related cases, and conflict-of-interest checks against employee and family information up to the second degree of kinship. Suppliers are also subject to SMAP due diligence and ongoing performance and ESG monitoring. Significant non-compliance may result in termination of the business relationship and blacklisting.

In 2025, Telkom, Mitratel, Telin, and Sigma provided anti-corruption policy and procedure awareness to 100% of their 1,852 business partners. No supplier relationships were terminated due to corruption or other instances of non-compliance during the reporting period.

Telkom Sustainability Report 2025 — Anti-corruption and Anti-bribery Policy, implementation of the Anti-Bribery Management System (SMAP) in the procurement process (p. 186);

Table 50: Achievements in Anti-corruption Awareness Raising for TelkomGroup Business Partners (p. 187);

Responsible Supply Chain, Sustainable Procurement Process (pp. 200–202);

Stakeholder Engagement, SMAP due diligence for suppliers (p. 51).

4.4

Employee Training on Ethical Standards

TelkomGroup has established mandatory annual mechanisms to strengthen employee awareness and implementation of business ethics and anti-corruption policies. All employees are required to sign an Integrity Pact and complete relevant compliance training, including modules on the Anti-Bribery Management System (SMAP) and gratuities. Training and awareness are delivered through e-learning, workshops, training sessions, and internal communication channels.

In 2025, 100% of Telkom’s Board of Directors and employees received information on anti-corruption policies and procedures and completed anti-corruption training. At selected subsidiaries, 100% of the Boards of Directors of TDE, Sigma, Metra-Net, and Telkom Infra also received anti-corruption information and training. At the TelkomGroup level, anti-corruption policy and procedure information reached 94.9% of employees, while training coverage reached 76.0%. Coverage by employee level was: Senior Management—92.2%/89.4%; Middle Management—98.0%/88.5%; Supervisors—99.7%/74.5%; and other employees—85.4%/65.2% for information dissemination/training, respectively.

Telkom also conducted Integrity Strengthening training for all Telkom employees in 2025, covering business ethics, corporate culture, Respectful Workplace, LHKPN, gratuities, SMAP, and employee discipline. Anti-corruption awareness was further extended throughout the supply chain, with anti-corruption policies and procedures disseminated to 100% of business partners, beginning at the technical clarification stage of the procurement process.

Telkom Sustainability Report 2025 — Prevention of Corruption, Bribery, and Fraud (p. 186);

Table 49 Achievements in Anti-Corruption Awareness and Training at TelkomGroup in Financial Year 2025 (p. 186);

Code of Ethics Policy and Code of Ethics awareness (p. 184);

Table 50 Achievements in Anti-Corruption Awareness for TelkomGroup Business Partners (p. 187).