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Whistleblowing System

Intergred Whistleblowing System

In an effort to support the implementation of good corporate governance, the Company implements a Whistleblowing System (WBS) in order to prevent fraud by reporting incidents of violation behavior and fostering a culture of honesty and openness. The application of WBS is beneficial for the development of a wellmanaged violation reporting system, which can be the foundation for the Company to design the necessary evaluations and followup. WBS is also part of the early warning system for possible problems caused by a violation. For reporters, WBS provides guaranteed protection and confidentiality of identity.

ESTABLISHMENT OF ELNUSA VIOLATION REPORTING SYSTEM GUIDELINES

Violation reporting system / Whistleblowing System (WBS) of the Company is a system that manages complaints of violations and or deviations of code of ethics, law, standard procedures, management policies and other rules deemed necessary, which can harm and / or endanger the Company such as financial losses, the environment , working conditions, organizational reputation, stakeholders and others.

Information obtained from WBS will be followed up with the imposition of strict and consistent sanctions in order to have a deterrent effect for violators and for those who intend to do the same and can be input for improving the system for the Company going forward.

REPORT SUBMISSION MECHANISM

The Company has provided various media to accommodate stakeholders in submitting their reports if a violation is committed by the Company's employees with the following mechanism:

  1. Company Website: Whistleblower System Center (https:// whistleblower.elnusa.co.id/)
  2. Telephone: 021.78830850 ext 1623
  3. Delivering an official letter to: PT Elnusa Tbk up. Chairperson of the Ethics & GCG Board Graha Elnusa Lantai 16, Jl. TB Simatupang Kav. 1B, Cilandak, South Jakarta

The following are the conditions of the reporter:

  1. Reporting can be done anonymously or supplemented with the identity of the reporter by providing recommendations or preliminary evidence of provisional allegations of violation
  2. The reporter can limit identification regarding the identity of the person concerned by continuing to include evidence relating to the alleged temporary violation practice.
  3. No penalty is given to the reporting party if the violation is proven to occur. If the person involved is also involved in the violation, the report submitted can be considered to reduce / eliminate the penalty.
  4. Confidentiality of the reporter will be maintained unless the disclosure is required in connection with an investigation conducted by an authorized party or is needed to maintain the Company's position before the law.
  5. The above mechanism is not intended to convey personal complaints.

MANAGEMENT OF VIOLATION REPORTS

The Company's violation reporting system is managed by the Corporate Secretary function as the secretary of the Ethics & GCG Board with the following mechanism:

  1. The WBS manager receives reports of violations and verifies the incoming reports.
  2. The WBS manager will determine whether further information or additional evidence is needed.
  3. The verified report is then submitted to the Ethics & GCG Board

REPORT HANDLING

  1. The Ethics & GCG Board will investigate the complaint report that has been verified by the WBS Manager.
  2. If the complaint is not proven to be true, then no further process is carried out.
  3. If the report on a violation is valid and has been proven, the Ethics & GCG Board will provide a report and recommendation to the appropriate authorities (management related to the Reported Party's superior to carry out corrective actions.

REPORTER PROTECTION

  1. Reporting can be done anonymously or complemented by the identity of the reporter by providing recommendations or preliminary evidence of provisional allegations of violation practices.
  2. The reporter can limit identification regarding the identity of the person concerned by continuing to include evidence relating to the alleged temporary violation practice.
  3. No penalty is given to the reporting party if the violation is proven to occur. If the person involved is also involved in the violation, the report submitted can be considered to reduce / eliminate the penalty.
  4. Confidentiality of the reporter will be maintained unless the disclosure is required in connection with an investigation conducted by an authorized party or is needed to maintain the Company's position before the law.

SANCTIONS FOR VIOLATIONS

Sanctions are of two types, namely moral sanctions and administrative sanctions.

  1. Forms of moral sanctions include:
    a. Announced publicly;
    b. Apologize in a limited and / or open manner;
    c. Resign from his position.
  2. The form of administrative sanctions is as stipulated in the Human Resources Management Policy and applicable Company Regulations

If there are indications of criminal violations, will be continued in accordance with applicable legal provisions.