Whistleblowing System

The Company has established a Whistleblowing System Policy (WSP) as a reference for the Company’s conduct and work culture. The establishment of this Whistleblowing System is a form of the Company’s commitment to manage the Company in a professional manner based on the Company’s conduct in accordance with the Company’s Code of Conduct, which was last updated on September 11, 2023.

It is hoped that this Violation Reporting System will provide early warning of potential problems arising from violations. Complaints received through the Violation Reporting Mechanism must receive attention and follow-up, including the imposition of appropriate sanctions to serve as a deterrent to violators.

Submission of Violation Reports

Guided by the Company’s Code of Conduct, any member of the Board of Commissioners, directors, existing committees and employees may submit reports of alleged violations of the implementation of the Code of Ethics to the Company personally by writing to the Good Corporate Governance Compliance Team. The Good Corporate Governance Compliance Team will provide a complaint facility for this purpose, including a guarantee of confidentiality. However, there are some important points to be considered when implementing the reporting system:

  1. All reporters must clearly identify themselves.
  2. The use of anonymous letters will be treated as initial information only, with follow-up depending on the committee’s confidence in the veracity of the reported problem.
  3. No penalty will be imposed on the reporting party if the violation actually occurs, unless the individual is also involved in a violation of the application of this Code of Conduct. In this case, disclosure of the matter may be a mitigating factor. If the violation occurred and the reporting party was not involved, the reporting party will be appropriately rewarded.
  4. The Good Corporate Governance Compliance Team will apply the principle of the presumption of innocence.

Whistleblower Protection

Confidentiality of the whistleblower will be maintained unless disclosure is made:

  1. Required in connection with government reports or investigations,
  2. Is in the best interest of the Company and consistent with the objectives of this Code,
  3. Is necessary to maintain the Company’s position before the law.

The Company will provide protection for whistleblowers from threats/actions resulting from reports of violations, and will maintain confidentiality and provide appropriate protection for whistleblowers and/or witnesses of violations and criminal acts that occur within the Company. Protection for whistleblowers also extends to administrators of the Violation Reporting System, parties conducting investigations, and parties providing information related to the complaint.

Party Responsible For Complaint Management

The GCG Compliance Team is authorized to handle complaints regarding violations. The GCG Compliance Team reports directly to the President Director. The GCG Compliance Team consists of an Investigation Team (External Investigator) and an Internal Investigation Team from SPI.

Complaint Handling Mechanism

Any report of suspected violations of the implementation of the Employee Code of Conduct will be followed up by the GCG Compliance Team. The GCG Compliance Team may coordinate and cooperate with relevant Company bodies in the implementation of these follow-up actions.

Each part of the Company’s Organs is obliged to provide full support to the GCG Compliance Team in following up on reports of alleged violations of the implementation of the Employee Code of Conduct. The results of the GCG Compliance Team’s follow-up actions shall be submitted to the Board of Directors or the Board of Commissioners in accordance with their scope and responsibilities. The GCG Compliance Team may recommend the formation of a Fact-Finding Team to further investigate reports of alleged violations of the implementation of the Employee Code of Conduct.

The findings of the fact-finding team shall be presented to the Employee Honorary Council. The Employee Honorary Council, after discussion at the Employee Honorary Council meeting, shall make recommendations to the Board of Directors or the Board of Commissioners, as appropriate, consistent with their scope and responsibilities. The Board of Directors and the Board of Commissioners shall have the authority to provide sanctions, coaching and/or other relevant matters for alleged violations of the implementation of the Employee Code of Conduct.

Enforcement of the Employee Code of Conduct will be based on relevant policies that the Company already has in place and that will be developed by the Company in accordance with developments in the conditions faced by the Company and changes in legal regulations.

Complaints Handling In 2023

The Company reported that there were no reported cases of violations that occurred within the Company in 2023. Therefore, the Company did not provide information on the number of complaints received and handled during the fiscal year and the follow-up of the complaints.