WHISTLEBLOWING SYSTEM SAMORA GROUP
The Whistle Blowing System (WBS) is a reporting tool for Samora Group employees in particular, and the public to report any behavior or actions that were indicated to have violated the code of conduct, GCG principles, and both Samora Group internal applicable regulations and prevailing laws, by Samora Group employees.
WHISTLE BLOWING SYSTEM REPORT
Whistle Blowing System is represents the management’s commitment of the Samora Group to implement good corporate governance and strives to maintain a healthy and productive business environment for all stakeholders of the Samora Group
Whistle Blowing System Report Criteria
Types of violations that can be reported include any violations of the law or company regulations committed by Samora Group employees within the Samora Group's workplace or related to their positions within the Samora Group, including but not limited to:
- Requests for money (bribery), facilities, discounts, privileges, and gratuities in any form.
- Promises of being appointed as suppliers, vendors, consultants, or hired as employees, outside the mechanisms established by the Company.
- Threats, hate speech, incitement, and any form of defamation. Discrimination based on race, religion, gender, disability, physical appearance, family background, or social status.
- Harassment, indecent behavior, the publication of pornography, and indecent acts in the workplace. Dissemination of prohibited items under the law and regulations (drugs, etc.)
- Carrying sharp weapons or firearms to the workplace or during official duties.
- Fraudulent actions that may harm the company's finances.
- Actions that may endanger safety and occupational health.
- All forms of forgery and impersonation in the name of the company.
- Other matters that can be considered violations of the law and company regulations.
Whistle Blowing System Reporting Mechanism
- The whistleblower submits a violation indication report through the Whistleblowing System.
- Whistleblowing System Team records all reports of indications of violations in the whistleblowing system application.
- WBS committee conduct preliminary analysis (verification) of reports of violation indications according to the whistleblowing system report criteria.
- If necessary, the WBS Team can request additional information and confirmation from the whistleblower in fulfilling the information and report data.
- Head of Compliance validates the results of the verification of the violation indication report and decides on the follow-up to the report, namely: Follow up for investigations; or No follow-up was taken (the report was rejected) because it did not match the criteria for the WBS report.
- The Head of Compliance appoints an Investigation team to investigate the WBS report.
- The Investigation team submits a report on the results of the investigation (including recommendations for followup improvements).
Requirements for Whistle Blowing Reporting
Reports on indications of violations should at least contain the following:
Subject of reporting of violations and amount of losses (if known)
Samora Group personnel and the parties involved indicated violations
Time of Violation
The period of time the indication of the violation occurred
Place of Violation
Location/place of work unit where the violation occurred
Chronology of Events
Description of events/chronology of events so that there are indications of violations
Evidence of Violation
Documentation of indications of violations in the form of documents, photos, videos and other supporting information
Reports of follow-up improvements include
- Follow-up to the perpetrator of the indication of the violation and improvement of the weaknesses that occurred as well as the risk mitigation carried out.
- Provide information to the reported superior in order to maintain the good name of the reported party if the WBS report is not proven.
- The work unit is authorized to carry out follow-up improvements in accordance with applicable regulations.
- The work unit has the authority to submit a follow-up improvement report to the WBS Management Unit.
Whistle Blowing Protection
- Samora Group provides protection to whistleblower confidentiality of personal data and reported information.
- The protection is also given to internal whistleblowers from pressure, postponement of promotions, discrimination, dismissal, and physical actions
- Protection from the risk of retaliatory actions against the whistleblower Legal assistance (in certain cases).
Whistle Blowing System Report Filling
Written letter addressed to:
The Legal Department Samora Group
Jl. M.H. Thamrin, RT.2/RW.1, Kb. Sirih, Kec. Menteng, Kota Jakarta Pusat, Daerah Khusus Ibukota Jakarta 10250, Indonesia