Whistleblowing System

The Company implements the Whistleblowing System as a mechanism to avoid and reduce the possibility of violations, which is not limited to business ethics and work ethics (code of ethics), Articles of Association of the Company, Partnership Agreements, contracts with external parties, company secrets, conflicts of interest, and the applicable regulations. The Company is always required to carry out its business activities based on the principles of Corporate Governance (GCG), as well as complying with the applicable laws and regulations.

The whistleblowing system is expected to be able to serve as an early warning detection for the possibility of issues due to a violation. Complaints obtained from the whistleblowing mechanism require attention and follow-up, including the imposition of appropriate penalties in order to provide a deterrent effect for violators.

Whistleblowing Mechanism

The mechanism to submit the whistleblowing report refers to the Procedure for Complaints of Violation against the Code of Conduct No. DOK.WIKA-BG-PDSEKUM-PM-02 dated May 6, 2018. All Company employees could submit reports regarding the alleged violations to the Company’s GCG Compliance Team through media letters addressed to the Company’s Head Office.

The Company presents several important matters in terms of reporting violations:

  1. The whistleblower could provide information about the reporter’s identity data (name, home/office address, contact telephone number or anonymously without giving any data);
  2. The whistleblower could provide information about violations (theft, corruption, fraud, legal or regulatory violations, bribery, conflicts of interest and ethics), the people or parties reported or allegedly involved, the amount or value of the Company’s losses if it can be determined, the place and time of the incident , as well as an explanation of the occurrence, chronology and the availability of evidence that supports the violation report in the form of documents, photos, recordings, CCTV, SMS, and others.

Protection to Whistleblower

The company guarantees protection for reporters related to threats/actions received as a result of reports of violations and keeps confidential and provides proper protection to reporters and/or witnesses to violations and criminal acts that occur within the Company. Protection for reporters also applies to managers of the violation reporting system, parties carrying out investigations, as well as parties providing information related to the complaint.

Whistleblowing Mechanism

The mechanism for handling violation reporting are as follows:

  1. The GCG Compliance Team has the duty to:
    1. Receive violation complaints, record and put it into the standard formats;
    2. Review or investigate the initial indication for 14 (fourteen) working days against the complaint/ disclosure and summarize it;
    3. Cooperate with External Investigators to carry out further investigations if the substance of the complaint/disclosure is related to the Board of Directors, Board of Commissioners, Managers or the Company’s reputation and/or caused substantial losses and/or have not been followed up by the IAU;
    4. Report the results of the internal and external investigations to the President Director or President Commissioner.
  2. The President Director or President Commissioner decides matters related to the report on the investigation results of the Company’s GCG Compliance Team, including:
    1. Whistleblowing case is closed, if cannot be proven;
    2. Impose sanctions in accordance with the applicable provisions, if proven and related to administrative actions;
    3. Forward the violation case to the authorized investigator, if proven and related to general crime or corruption. In this case, the person in charge of the Company coordinates with the legal department to ensure there is sufficient evidence.

Parties in Charge of Whistleblowing

The Company grants authority to the GCG Compliance Team to manage complaints of Violations. The GCG Compliance Team is directly responsible to the President Director. The GCG Compliance Team consists of the Investigation Team (External Investigator) and the Internal Investigation Team from the IAU.

Reports Received During 2022

During the 2022 period, there were no reports of violations that occurred within the Company. Thus, it can be concluded that during 2022 there were no irregularities or violations reported by employees to the Gratuity Reporting and Violation Complaints Management Team.