The Company's is committed to create a clean and responsible work situation. Thus, the Company prepares and implements a whistleblowing system. Whistleblowing System is 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, Partnership Agreements, contracts with external parties, company secrets, conflicts of interest, and regulations applicable. The Company is always required to carry out its business activities based on the principles of Corporate Governance (GCG), as well as complying with applicable laws and regulations.
Whistleblowing system is expected to be able to act as early warning detection for the possibility of problems due to a violation. Complaints obtained from the violation reporting mechanism need attention and follow-up, including the imposition of appropriate penalties in order to provide a deterrent effect for violators.
The mechanism to submit the whistleblowing report refers to the Procedure for Complaints of Violation against Code of Conduct Number: DOK.WIKA-BGPDSEKUM-PM-02 dated May 6, 2018. All Company employees could submit reports regarding alleged violations to the Company's GCG Compliance Team through media letters addressed to the Company’s Head Office.
The Company presents several important things in terms of reporting violations:
- The whistleblower could provide information about the reporter's identity data (name, home/office address, contact telephone number or without giving anonymous data);
- The whistleblower could provide information about violations (theft, corruption, fraud, legal or regulatory violations, bribery, conflicts of interest and ethics), 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 availability of evidence that supported reports of violations in the form of documents, photos, recordings, CCTV, SMS, and others.
Protection to Whistleblower
The Company is obliged to guarantee security to the whistleblower related to the threats/actions obtained as a result of reports of violations and keep confidential and provide appropriate protection to the reporter and/ or be a witness of violations and criminal acts that occur in the Company's internal. Protection of whistleblowers is also applied to managers of the violation reporting system, parties who carried out investigations, as well as those who provide information related to the complaint.
The mechanism for handling violation reporting are as follows:
- The GCG Compliance Team has the duty to:
- Receive complaints of violations, record and put it into standard formats;
- Review or investigate the initial indication for 14 (fourteen) working days against the complaint/disclosure and summarize it;
- 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 Internal Audit Unit;
- Report the results of internal and external investigations to the President Director or President Commissioner.
- The President Director or President Commissioner decides matters related to the report on the results of investigation of the Company's GCG Compliance Team, including:
- Whistleblowing case is closed, if not proven;
- Impose sanctions in accordance with the applicable provisions, if proven and related to administrative actions;
- 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 External Investigation Team and the Internal Investigation Team from Internal Audit Unit.
Reports Received during 2020
During the period of 2020, there were no reports of cases of violations occurring within the Company. Thus, it could be concluded that during 2020 there were no violations reported by employees to the Management Team for Gratification Reporting and Complaints of Whistleblowing.