In an Effort to support the implementation of Good Corporate Governance, the Company implements a Whistleblowing System (WBS) to prevent fraud by reporting violations and encouraging a culture of honesty and transparancy. Until now, the Company does not yet have a WBS with a separate independently mechanism and management. The Violation Reporting System in the scope of the Company is attached to the mechanism of reporting violations in the organizational structure.

Violation Reporting Mechanism and Channel

Mechanisms for violation reporting in the Company are as follows:

  • An employee who wants to report a violation can submit the report to his/her superior. The superior is entitled to acknowledge the information about the violation submitted by the concerned employee.
  • The superior will forward the report to the HR Division, where the HR Division is entitled to acknowledge the information about violation submitted by the superior and concerned employee.
  • If the HR Division sees a violatjion from the report, HR Division will forward the information to the Internal Audit Unit.
  • Internal Audit Unit will conduct an investigation on the report provide by the HR Division; including collecting evidenc. If all audit investigation conducted by Internal Audit Unit did not indicate any violation, the Internal Audit Unit is entitled to terminate the reporting process. However, if the audit invetigations conducted by the Internal Audit Unit indicated a violation, the Internal Audit Unit will report the ciolation to the Board of Directors.
  • The Board of Directors will take necessary actions related to violation informed by the Internal Audit Unit.

Form of Action

The Board of Directors will take necessary actions by adjusting to the Company’s mechanism and after coordinating with Internal Audit Unit, Human Resources Division, and related parties. The forms of action are as follows:

  • Warning letter with tiered levels (SP 1, SP 2 and SP 3).
  • Termination.
  • Violation is forwarded to the court proceedings.

The mechnism of decision making on actions taken refers to the prevailing laws and regulations, Articles of Association and other regulations inherent in the Company’s orgazational structure and mechanism.