Whistle Blowing System | HITS

Whistle Blowing System


1. Reporter - Reporting violation unit reports to the President Director with a copy to the Board of Commissioners with the following conditions:

a. The Reporting Party shall provide information on the identity of the person, at least containing the name/address/phone/mobile/facsimile/email number and photocopy of identity.

b. Reporting violations must be accompanied by supporting documents such as: documents relating to transactions conducted and or Reporting Offenses to be submitted.

c. If Reporting of Violation is submitted by the Stakeholder's representative, other than the above documents are also submitted other documents:

1)   Photocopy of proof of Stakeholder identity and representation of Stakeholders.

2)   Power of Attorney from the Stakeholders to the Stakeholder representatives stating that the Stakeholders provide the acting authority for and on behalf of the Stakeholders.

3)   If the Stakeholder's representative is a legal entity or agency, it must be enclosed with a document stating that the party filing the Reporting Offenses is authorized to represent the agency or legal entity.

d. Reporting anonymous written offenses may be made, but must be accompanied by photocopies of documents relating to transactions conducted and/or Reporting Violations to be submitted.


2. Data Supporting Reporting

a.    The complained offenses include the amount of loss (if it can be determined), and 1 (one) Complaint or Disclosure only for 1 (one) violation for the handling to be more focused.

b.   The party involved, who should be responsible for the violation, including the witnesses and the beneficiaries or the losers.

c.    The location of the offense, which includes the name, place, work unit or function of the occurrence of the violation.

d.   The timing of the violation, ie the violation period either in the form of a particular day, week, month, year or date at which the violation occurred.

e.    How the violation occurred and whether there is evidence supporting the violation.

f.    Has the violation been reported to other parties;

g.    Had the violation ever happened before.




The Company is committed to protecting a well-meaning Reporter and the Company will comply with all relevant laws and regulations applicable to the implementation of the Reporting protection system. The Company provides protection to the reporting party for the following matters:



1.    Administrative immunity.

2.    Unfair dismissal.

3.    Decrease of position or rank.

4.    Harassment or discrimination in all its forms.

5.    Adverse records in his personal data files.

6.    Protection from criminal and/or civil charges.

7.    Protection of personal security, and or the reporting family from physical or mental threats.

8.    Protection of the reporting property.

9.    Confidentiality and disguise of the identity of the complainant.

10. Provision of information without face-to-face with the complainant, at any level of probation in case the offense enters the court dispute.

11. Provide legal protection.




The President established a reporting unit of violations that is independent of the Company's day-to-day operations and consists of 2 (two) sub-units, namely:


1.    The Reporting Protection Unit is a sub-unit that receives infringement reporting, selects an infringement report for further processing by investigative sub-unit, implementation of the reporting protection program in accordance with the policy already declared.

2.    The Investigation Unit is a sub-unit responsible for further investigation of the substance of reported violations and provides recommendations for sanctions against such violations including terminating the investigation process. The violation report is not resumed if there is no evidence of infringement.




Administrative sanctions and/or other sanctions in accordance with applicable laws and regulations will apply to:


1.    The Head of the unit and/or work unit that rejects the examination by the Examining Team.

2.    The Head of the unit and/or work unit that does not follow up on the recommendation of the audit report on the complaint of the employee and the interested parties as appropriate.

3.    The Head of the unit and/or work unit protecting employees or officials who violate the rules.

4.    A Reporting Entity submitting a report of defamation or false report shall be subject to sanctions determined in accordance with applicable corporate or regulatory policies and shall not be guaranteed confidentiality or protection of the complainant.





The follow-up in the form of sanctions imposed on employees based on cases reported through the Whistleblowing System in 2020 is as much as 2 cases. The two reports are currently in the process of completion by the Company in accordance with the Company Policy.