The Company has a whistleblowing mechanism that is managed internally (about wrongdoings of the Company’s organs and employees). This whistleblowing mechanism is a form of the Company’s efforts to address frauds, corruptions, and wrongdoings against the Company’s policies and regulations, as well as applicable laws and regulations. In other words, this mechanism is intended to prevent the management from taking adverse actions to other employees and the Company.

Parties Managing Complaint Reports

Any wrongdoing related to fraud, corruption or any other misconduct which may harm the Company can be informed to the Whistleblowing Handling Team (Tim Pengelola Pelaporan Pelanggaran/TPPP).

Mechanism of Conveying and Handling the Whistleblowing

The whistleblowing mechanism begins with information from a whistleblower, either as a mail or an e-mail, to the the Whistleblowing Handling Team. The team will then hold a special meeting to examine and decide whether the complaint received meet requirements for a further follow-up. Decision of the special meeting is reported to the Board of Commissioners and / or Board of Directors for their approval regarding the followings:

a. In the case that a complaint is considered as not able to be followed up, an approval from the Board of Commissioners or Directors is needed to close the case;
b. In the case that a complaint is considered as able to be followed up, an approval from the Board of Commissioners or Directors is needed to further examine and investigate the case;
c. If the Team, after taking into consideration its limited authority and competence, needs to ask for assistance from Internal Audit / expert / consultant / external auditor, then this kind of assistance must be approved in advance by the Board of Commissioners or Board of Directors; and
d. In the event that results of the examination and investigation prove the wrongdoing against the Company’s internal regulations, the Team will recommend to the Human Resources Department to impose sanctions on the wrongdoer according to the Company’s regulation. In the
case of the criminal wrongdoing against prevailing laws and regulations, then it will be followed up in a case-by case manner.

Whistleblower Protection

The Company provides protection for the whistleblower, including:
1. Guaranteed confidentiality of the wrongdoer’s identity;
2. Guaranteed confidentiality of information conveyed;
3. Guaranteed protection of possible threats, intimidation, punishment or other unpleasant actions from the wrongdoer; and
4. For the internal whistleblower, the Company guarantees protection and the whistleblower is not imposed with:
a. Dismissal;
b. Demotion of position or rank;
c. Any kind of harassment or discrimination;
d. A disserving notation in their (personal file record).

In addition to above mentioned protection, for any well intentioned whistleblower, the Company will also seek legal protection as stipulated in prevailing laws and regulations.

Whistleblowing Case

Throughout 2018, no complaint is raised through the whistleblowing system. However, in case of any complaint in the future, it will be handled and a strict, consistent sanction will be imposed to the proven wrongdoing. Therefore, it is expected to give a deterrent effect to the wrongdoer and anyone else intending to commit misconduct