LEGAL OPINION

To
Dear Mr. Muhammad Dzaki
VP of Operations Polyrific
- In place

Regarding : Legal Opinion regarding Regulations or rules for paying employee salaries.

Yours faithfully,

Referring to Mr. Muhammad Dzaki's email on Monday, June 13, 2023, some of the contents
are as follows:

"For your information, so far we have paid employee salaries through banks, and sometimes
there are problems when sending funds from the US. There is a maximum limit that can be
sent in one transfer, so under certain conditions Ms. Monica must make transfers more than
once a month.

Another condition is that there are some permanent employees who prefer that part of their
salary be fixed in USD, as during the previous part-time period, which is not possible if
payments are made through a bank.

In order to facilitate this, we plan to divide the salary payment channels as follows.

 Most of the salary will still be paid through the bank, and this will be the basis for
calculating benefits, including BPJS TK, BPJS Health, THR, and other employee benefits or
rights mandated by law.
 A small part of the salary will be paid through other channels, in this case we will try to
use Payoneer. This will later be as if a portion of their salary is paid directly from Polyrific
in the US, without going through the KPPA.
 In the future, it is possible that Payoneer will be used to pay part-timer salaries, which
are currently using PayPal.

Ask for help from Jova to analyze and provide a legal opinion regarding this matter, does it
have the potential to violate existing government regulations/rules."

From the above, I, as the legal admin of Polyrific, submit the following legal opinion:

Previously, we said that in giving a legal opinion, we have an understanding of the following
matters:

1. That this Legal Opinion is only limited to related parties, in this case POLYRIFIC
2. All copies of documents provided to me are in accordance with the originals
3. All of these documents are issued by and given to the authorities.

A. LEGAL BASIS

1) Undang-undang No. 13 Tahun 2003 tentang Ketenagakerjaan

2) Undang-Undang Nomor 11 Tahun 2020 tentang Cipta Kerja
3) Peraturan Pemerintah Nomor 36 Tahun 2021
B. LEGAL ANALYSIS

Previously, it was explained that Indonesian employees who work at KPPA are workers who
are protected by law in Indonesia. In this case, all matters related to employees at Polyrific
Indonesia are regulated in the Undang-Undang Ketenagakerjaan.

The form and method of payment of wages is regulated in the UU Cipta Kerja which was
passed down to PP No. 36 of 2021 CHAPTER VIII articles 53 to 57:

“Article 53
1. Wages must be paid by the Employer to the Worker/Labourer concerned.
2. Employers are required to provide proof of payment of wages which contains details of
the wages received by the worker/laborer at the time the wages are paid.
3. Payment of wages by employers is carried out based on work agreements, company
regulations or collective bargaining agreements.
4. Wages as referred to in paragraph (1) can be paid to third parties based on a power of
attorney from the Worker/Labourer concerned.”

From the provisions of article 53 above, we can see that the payment of wages or salaries is
made based on a work agreement that we usually call PKWT or PKWTT, company regulations
or collective agreements if any.

“Article 54
1. Payment of wages must be made in the rupiah currency of the Unitary State of the
Republic of Indonesia.
2. Wages as referred to in paragraph (1) must be paid in full in each period and per date of
payment of wages.”

In accordance with article 54 paragraph 1 it is explained that the payment of wages or

salaries must, which means that all companies are required, to be made in the rupiah
currency of the Unitary State of the Republic of Indonesia.

“Article 56
1. Wages are paid at the place stipulated in the Work Agreement, Company Regulations or
Collective Bargaining Agreement.
2. In the event that the place for paying Wage is not regulated in the Work Agreement,
Company Regulations, or Collective Bargaining Agreement, the Wage payment shall be
made at the Worker/Labourer's place of work.

Article 57
1. Wages can be paid directly to Workers/Labourers or through a bank.
2. In the event that the wages are paid through a bank, the wages must be cashed by the
worker/labourer on the date of payment of wages agreed by both parties."

In Articles 56 and 57 it is regulated regarding the place and method of payment of wages or
salaries of employees, where we can set out the payment procedure or explain further in the
work agreement or company regulations.

C. LEGAL OPINION

1) In my opinion, as the legal admin of Polyrific Law No. 13 of 2003, Law Number 11
of 2020 concerning Job Creation, Government Regulation Number 36 of 2021
remains the basic reference for the salary payment system at Polyrific
 2) All forms of efforts to facilitate the First Party, in this case the Company, in paying
employee salaries will be included in the Work Agreement and Company
Regulations, if urgent, they can be included in the Collective Agreement.
3) The online payment system using Paypal is not prohibited in any law, so that the
payment method can be made from the Second Party where in this case the
Employee has no objections and has been stated in the Employment Agreement.

D. RECOMMENDATION

1) Make additional explanations or mention Payroll methods in the Employment

Agreement and Company Regulations at Polyrific. Especially if you are going to
make payments using Paypal to be explained at the beginning before the
Employment Agreement was agreed.
2) For employees who are already running, a Collective Agreement can be drawn up
regarding salary payments agreed by both parties, where the collective agreement
will end in accordance with the previous Employment Agreement.
3) For some permanent employees who prefer to have a fixed portion of their salary
in USD if referring to the law above, this cannot be done at the moment, if possible
it will be included in non-fixed allowances.

E. CONCLUSION

Regarding this matter Most of the salary will still be paid through the bank, and will be the
basis for calculating benefits, including BPJS TK, BPJS Health, THR, and other employee
benefits or rights mandated by law. Then a small portion of the salary will be paid through
other channels, in this case using Payoneer, which is as if a portion of the employee's salary
is paid directly from Polyrific in the US, without going through the KPPA it will not potentially
violate existing government regulations/rules, because of In terms of rules that explain this
matter, there are no rules, and payment of salaries follows the Company's own regulations.

So that we can conclude that, there are several Company Regulations that must be amended
or corrected, which will then be re-stated in the Employment Agreement regarding payroll
which is adjusted to the policy or desire to make it easier for the Company to pay the
salaries of its employees either by the usual transfer method or using Paypal.

Pati, 16 July 2023

Jova Hepasuda