Whistleblower Procedure

Whistleblowing System 

To realize the enforcement of GCG principles and creating clean and accountable working situation, the Company adopts Whistleblowing System (WBS). WBS is part of internal control of the company to minimize risk towards violations and as a reporting medium to prevent and detect potential violations on ethic and law in the Company. Since 2016, SUCOFINDO started to implement system of reporting suspected violations, or whistleblowing system (WBS). 

Whistleblowing Mechanism 

1. The Company provides media reporting on Alleged Violations through communication media established by the company, as follows:

  • Telephone: (021) 7983777 
  • Website: https://wbs.SUCOFINDO.co.id
  • Email: wbs@SUCOFINDO.co.id
  • Fax: (021) 7986786?SMS: 08117983777 
  • Post Box: PO BOX WBS SUCOFINDO JKTM 12700

2. The Alleged Violations are recorded by the Systems Application or the WBS team.
3. The WBS Application System and the WBS Team ensure whistleblower’s willingness to reveal their identity.
4. Violations are registered by the complainant to the WBS Application System or to the WBS team. 
5. The WBS team performs validation and analysis of the violations and prepares a WBS report to be submitted to the Board of Commissioners.
 
6. The Board of Commissioners shall make recommendations to the Board of Directors in order to follow up on allegations of irregularities contained in the WBS Report. 

7. The Board of Directors as Eligible Punishment Officials (PYBR) can commission the Internal Audit Unit (SPI) and or other team appointed, to conduct a search or examination of the facts and in accordance with the applicable provisions of the Company. 

8. The Board of Directors as Eligible Punishment Officials (PYBR) can sanction employees who are proven to commit irregularities. 

 

Whistleblower Protection 

The Company is committed to keeping the identity and protecting the Whistleblower in good faith if they are willing to disclose the identity, provided there is:

  1. Availability of facilities in the reporting system to disguise the identity of the Whistleblower.
  2. Guarantee of confidentiality of the identity of the Whistleblower.
  3. Security of information and protection against retaliatory measures, in the forms of threats of physicals safety, psychological terror, family safety, property safety, job security and any other actions that threaten the Whistleblower. 
  4. The Company provides legal protection to the Whistleblower against any counter measure sin the form of lawsuits. 

Handling of Complaints 

  1. Once the report is received the WBS team will process the report and then prepare a validation report, “not a deviation” or “junk” reports will be removed from the WBS system while reports categorized as “deviation” will be followed up.
  2.  The WBS team then analyzes the report and follow up on irregularities reports.
  3. The WBS team will prepare a WBS report containing recommendations on the follow-up Alleged Irregularities Reported to be submitted to the Board of Commissioners.

Parties Managing the WBS 
The WBS is managed by a team, consisting of administration, validation and analysis of alleged violations, application and database management as well as WBS Report preparation. The WBS team comprises of employees proposed by the Board of Directors as determined by the Board of Commissioners to manage the WBS implementation. 

WBS elements of the team consist of three (3) main functions, namely:

1. WBS Administration Team, the team that manages Alleged 
Irregularities Reported, including database management, data entry Alleged Irregularities Reported from media mail, telephone and facsimile. 

2. WBS Validation Team, the team that performs the validation process by sorting Reporting Alleged Irregularities:

a. Reporting that does not meet the requirements (junk reporting).
b. Reporting that is beneficial to the Company but not included in the Reporting category of the WBS.
c. Alleged Irregularities Reporting that meets the requirements in the WBS Reporting category eligible for 
follow-up.

3. WBS Analysis team is a team that performs the Alleged Irregularities Reporting analysis for further processing including: 
a. Classification of Reporting. 
b.    Adequacy of evidence/initial indications. 
c.    Analysis of the predicted impact of risk. 
d.    Evaluation of priority.
e.    WBS Report Preparation.

Rewards and Sanctions 

a. Rewards for Whistleblower?A Whistleblower who submits a Report and has successfully prevented and or minimized violations which may harm the Company is granted a reward. Provisions on criteria and the value of rewards given will be further regulated in Decision of the Board of Directors. 

b. Sanction on False Report?In the event that the submitted Report is not based on good faith, has no basis, contains elements of false evidence, slander, defamation, then the Whistleblower may be subject to sanctions in accordance with the applicable provisions.