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TERMS & PRIVACY POLICY

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Complaint
  1. Complaints by the Unit Holder are submitted to the Investment Manager, which must be resolved by the Investment Manager using the Complaint Resolution Mechanism below.
  2. In the event that the complaint relates to the function of the Custodian Bank, the Investment Manager will submit it to the Custodian Bank, and the Custodian Bank is required to resolve the complaint using the Complaint Resolution Mechanism below.

Complaint Settlement Mechanism
  1. The Investment Manager and/or Custodian Bank will serve and resolve any complaints from the Unit Holders. The settlement of complaints made by the Custodian Bank must be forwarded to the Investment Manager.
  2. The Investment Manager and/or Custodian Bank will immediately follow up and resolve the Participation Unit Holder's complaint no later than 20 (twenty) Business Days after the date of receipt of the complaint.
  3. The Investment Manager and/or Custodian Bank may extend the period as referred to in number 2 above in accordance with the terms and conditions stipulated in the OJK Circular Letter concerning Services and Settlement of Consumer Complaints to Financial Services Businesses.
  4. The extension of the complaint settlement period as referred to in number 3 above must be notified in writing to the Participating Unit Holder who submitted the complaint before the period as referred to in number 2 ends.
  5. The Investment Manager provides information regarding the status of the Participation Unit Holder's complaint through various communication facilities provided by the Investment Manager, including through the website, letter, email or telephone (on the Contact Us page). Communication by telephone can only be made from Monday to Friday (except national holidays) at 08.00 - 17.00 WIB.

Complaint Resolution
The Investment Manager and/or Custodian Bank will serve and resolve any complaints from the Unit Holders. The settlement of complaints made by the Custodian Bank must be forwarded to the Investment Manager.
The Investment Manager and/or Custodian Bank will immediately follow up and resolve the Participation Unit Holder's complaint no later than 20 (twenty) Business Days after the date of receipt of the complaint.
The Investment Manager and/or Custodian Bank may extend the period as referred to in number 2 above in accordance with the terms and conditions stipulated in the OJK Circular Letter concerning Services and Settlement of Consumer Complaints to Financial Services Businesses.

The extension of the complaint settlement period as referred to in number 3 above must be notified in writing to the Participating Unit Holder who submitted the complaint before the period as referred to in number 2 ends.
The Investment Manager provides information regarding the status of the Participation Unit Holder's complaint through various communication facilities provided by the Investment Manager, including through the website, letter, email or telephone (on the Contact Us page). Communication by telephone can only be made from Monday to Friday (except national holidays) at 08.00 to 17.00 WIB.

BOARD OF COMMISSIONERS


Budi Haryono
Taking office as President Commissioner of PT Valbury Capital Management since 2012 and Commissioner of PT Valbury Asia Futures (formerly PT Halim Danamas International) since 1996. In his long and distinguished career, Budi Haryono has recorded many achievements, including pioneering the establishment of the Jakarta Futures Exchange. In addition, he served as Commissioner of PT Valbury Asia Securities (2000-2012), President Director of PT Gading Dana Lestari (1990-1996), Director of PT Amcol Securindo (1988-1990), Commissioner of PT Gading Putra Mahkota (1983-1986), Director of PT Gading Cempaka (1970-1990) and Commissioner of PT Trisula (1965-1969).

Erick Thirtayasa
Taking office as Independent Commissioner of PT Valbury Capital Management since October 2021. Currently holds position as Product Manager of PT Sarana Digital Mandiri from July 2018.
His previous position was Business Development at PT Valbury Sekuritas Indonesia from 2011 to June 2018.


BOARD OF DIRECTORS


Jae Yeop, Lim
Serve as President Director of PT Valbury Capital Management since 2023, with more than 20 years of experience in the capital market sector. He has Broker-Dealer Representative license from OJK and Certified Investment Manager license from Korea Financial Investment Association. Throughout his career, he served as Head of Global Strategy Division at KB Asset Management (2015-2022), Head of Global Marketing Team at Korea Investment Management (2012-2015) and Product Manager at Franklin Templeton Investment (2010-2011). He started his asset management career at KB Asset Management (2002-2008) before moving to KB Financial Holdings (2008-2010) where he was entrusted with various positions.


Wisnu Dharmawan
Served as President Director of PT Valbury Capital Management since 2017, with more than 20 years of experience in the capital market sector. Have a Trade Broker Representative, Underwriter Representative and Investment Manager Representative license from the Financial Services Authority. Throughout his career, he served as Director of Corporate Finance & Compliance at PT Valbury Sekuritas Indonesia (2009-2016), Director of Operations at PT AIM Trust (2005-2007) and Director of Operations at PT Raihanz Investment (from 2001-2004). He began his career as Research Staff – Analyst at PT Bakrie Securities (1996-1999) before moving to PT Sarijaya Permana Sekuritas where he was entrusted with various positions (1999-2005).


Dede Surjadi
He has served as Director at PT KB Valbury Asset Management since 2024. Previously he joined PT Valbury Sekuritas Indonesia from 2010 to 2016 as Branch Manager and continue to serve as Genereal Manager at PT Valbury Capital Management since 2016. Have licenses as Broker-dealer Representative, Underwriter Representative and Investment Manager Representative license from the Financial Services Authority. Starting his career at PT. Iwaki Singapore Indonesia as Senior Sales Executive (1997-1999), at PT. Duta Polykem Indo and PT. Putrisari Kimianusa as Product and Factory Manager, Purchasing Manager and Technical Support Manager (1999-2010).


FUND MANAGER


Suryo Narpati
He has served as Coordinator of the Investment & Research Function at PT Valbury Capital Management since 2018. Has a Broker-dealer Representative, Underwriter Representative and Investment Manager Representative license from the Financial Services Authority. Started his career from 2005 to 2007 as a Financial Consultant at PT Valbury Asia Futures and from 2007 to 2018 as Equity Sales at PT Valbury Sekuritas Indonesia.

BOARD OF DIRECTORS

The Board of Directors is an organ of the Company that is authorized and fully responsible for managing the Company for the benefit of the Company in accordance with the aims and objectives of the Company and represents the Company, both inside and outside the court in accordance with the provisions of the Articles of Association.

Duties and Responsibilities of the Board of Directors:

  • The Board of Directors is fully responsible for carrying out their duties for the benefit of the Company in achieving the aims and objectives set out in the Articles of Association.
  • Each member of the Board of Directors must in good faith and with full responsibility carry out their duties by observing the applicable laws and regulations.
  • The Board of Directors has the right to represent the Company inside and outside the court on all matters and in all events, bind the Company to other parties and other parties to the Company, and carry out all actions, both regarding management and ownership.
  • Provide an explanation of all matters asked by the Commissioner.

BOARD OF COMMISSIONERS

The Board of Commissioners acts based on the decision of the meeting of the Board of Commissioners and in accordance with the Articles of Association and the applicable laws and regulations.


Duties and Responsibilities of the Board of Commissioners:

  • Supervise the management policies, the course of management in general, and provide advice (recommendations) to the Board of Directors.
  • Directing, monitoring and evaluating the implementation of the Company's strategic policies.
  • If all members of the Board of Directors are temporarily dismissed and the Company does not have members of the Board of Directors, then the Board of Commissioners is temporarily obliged to manage the Company. In such case the Board of Commissioners has the right to grant temporary powers to one or more members of the Board of Commissioners at the expense of the Board of Commissioners.



Legal Basis and Reference

  • Law No. 40 of 2007 dated 16 August 2007 concerning Limited Liability Companies.
  • Law No. 8 of 1995 concerning Capital Markets.
  • Decision of the Chairman of Bapepam and LK Number: Kep-479/BL/2009 dated 31 December 2009 (V.A.3. Licensing for Securities Companies Conducting Business Activities as Investment Managers).
  • Financial Services Authority Regulation No. 10/POJK.04/2018 concerning Implementation of Investment Manager Governance.
  • The Company's Articles of Association and its amendments.

As a company built on reputation and integrity, the perceptions of shareholders and customers play an important role in determining the progress of the Company. Therefore, it is the responsibility of all elements of the Company in various lines to maintain reputation and show stakeholders that the Company has high integrity and upholds ethics in carrying out each of its activities. So that a code of ethics is needed for employee relations with the Company, fellow employees, relationships with consumers, relationships with shareholders, relations with the Government and relations with the community in order to form a corporate culture which is a manifestation of corporate values.

Company Values
  • INTEGRITY
    Integrity and sincerity which includes fairness, responsibility, transparency and honesty for the interests of shareholders.
  • EXCELLENCE
    Delivering results from good investment performance, which is consistent with a responsible corporate philosophy.
  • TRUST BASED RELATIONSHIP
    Believe in good intentions and we always maintain trust by maintaining a good partnership relationship for all parties.
  • CUSTOMER FOCUS
    Provide quality products, services, advice and sustainable values for the priority of the Customer.
  • PROFESSIONAL AND PASSIONATE
    Loving Work with Professionalism Employees have passion and professionalism in their work based on high knowledge and skills for the benefit of our customers, investors, and stakeholders (shareholders).
Fundamental Principles Of Investment Manager Ethics
  • Act in a professional and ethical manner at all times.
  • Act in the interests of the Customer.
  • Be independent and objective.

Financial Services Authority Regulations
Number 10/POJK.04/2018
regarding Implementation of Investment Manager Governance

See PDF

COMPLIANCE, RISK MANAGEMENT AND INTERNAL AUDIT

Management establishes policies to regulate the functions, duties and scope of work carried out by the Compliance Function, Risk Management and Internal Audit in accordance with the directives of applicable regulations. This includes the duties of ensuring that all employees and company activities have complied with the applicable rules and regulations and company SOPs, ensuring that existing and future products comply with applicable rules and regulations, reviewing risk management strategies and periodically evaluating the implementation of the risk management strategy, and coordinating with the Officer in Charge of Anti-Money Laundering and Prevention of the Financing of Terrorism (APU and PPT) and other related divisions within the company in an effort to monitor the implementation of APU and PPT.