Whistleblower Policy

Objective

PT Indodev Niaga Internet (the “Company”) is committed to implementing and improving the quality of the implementation of Good Corporate Governance (GCG) within the company for company’s personnel in a sustainable manner and in accordance with applicable policies and laws and regulations. This policy is supported by the management of the Company by taking into account the interests of stakeholders based on the principles of fairness and equality in order to achieve the purposes of this Whistleblower Policy.

Purpose

This Whistleblower Policy aims to provide procedures that allow whistleblowers to report Company’s employee for an alleged violation of law that occurred within the company or outside the company.

This Whistleblower Policy adheres to the principle of confidentiality in maintaining information to the extent permitted by law so that the identity of the whistleblower can be kept as confidential.

Scope

This scope includes:

1. A Whistleblower
2. Whistleblowing Channel
3. Acts of Reported Violations
4. Information Report
5. Investigation process
6. Investigation Report
7. Sanctions

Whistleblower Policy Procedure

1. Whistleblower

A Whistleblower is a person who reports an alleged violation or suspected criminal act under this Policy. The whistleblower can be categorized in 2 (two) with the following:

a. The Company’s Internal Whistleblower, which consists of:
i. Company Management
ii. Company Employees

b. External’s Whistleblower, which consists of:
i. Company Contractor or Supplier
ii. Client or Customer of the Company
iii. Partner or Distributor of the company

A Whistleblower may undisclosed its identity (Anonymity) confidential when disclosing and reporting allegations of this violation. The Company will always maintain the personal identity of the whistleblower under this policy.

2. Reporting Channel

The Whistleblower may report on the following channels:

Email : whistleblower@dataon.com
Website : dataon.com

If the Whistleblower is internal to the Company, the Whistleblower may also submit a report through the Whistleblower system feature on the HRIS Application/Software used by the Company.

3.  Acts of Reported Violations

A Whistleblowers may submit reports for any suspected violations or criminal acts through the reporting system as set out in this Whistleblower Policy. Examples of alleged violations or criminal acts are as follows:

Violations/ Criminal Acts

1. Corruption
2. Bribery
3. Theft
4. Embezzlement
5. Fraud
6. Conflict of Interest
7. Violate of Company Regulation
8. Violate of Employee Code of Conduct
9. Etc
 

4.  Reporting Information

The Whistleblower will provide a description of the alleged violation or criminal act by containing at least the following information:

a.  Alleged acts of violation
b.  Suspected
c.  Time of violation
d.  Place of violation
e.  Information regarding the act of violation
f.  Evidence of a violation

Based on the information on the alleged violation, the Company has appointed a Whistleblower Officer whose task is to receive, analyze and further investigate  active reports from the reporting channel.
 

5.  Investigation Process

The Whistleblower Officer is responsible for conducting the investigation process on active reports. The investigation process is carried out by 2 methods as follow:

a. Preliminary Examination

i. All incoming reports will be subjected to a comprehensive initial assessment by the Whistleblower Officer to determine whether further examination and thorough investigation are required.
ii. If the results of the preliminary examination indicate a lack of evidence or the report is incorrect, the report will not be processed further.
iii. If the results of the preliminary examination indicate an indication of a violation with sufficient initial evidence, the Whistleblower Officer will report to the Company’s Management for approval for further examination.

b.  Advanced Examination

i. The Whistleblower Officer will conduct a thorough examination of any indication of a violation or criminal act based on the initial examination.
ii. If needed, the Whistleblower Officer may conduct  communication with the Whistleblower to obtain more in-depth information.
iii. The Whistleblower Officer will make reasonable efforts to verify and prove that the report received has indeed occurred.
 

6.  Investigation Report

The Whistleblower Officer will inform the Whistleblower when the investigation process and results have been completed. However, the report does not guarantee that described in more detail.
 

7.  Sanctions

If the results of the investigation find a violation or criminal act by the Company’s Employees based on such report, the Company may apply sanctions as applicable in the Company Regulations, Employee Code of Conduct, and/or this policy, as follows:

a. Give Warning Letter; and/or
b. Conduct Termination of Employment; and/or
c. Report to the authorized institution for legal process.
 
 
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