Whistleblowing System

  Overview

The Whistleblowing System (WBS) is a system and procedure designed by the Company to receive, examine and follow up complaints with disclosures about irregularities or fraud that indicate harm or things that are not in accordance with ethical norms that occur in the work environment.

Whistleblowing Presence and Objectives

This WBS is expected to increase compliance with regulations and encourage the growth of a high ethical culture in carrying out activities related to internal and external parties.

Types of Violations that Can be Reported

Actions or deeds that can be reported include but are not limited to:

1. Acts of stealing, embezzling, abusing, and/or damaging the Company’s assets.
2. Corruption, collusion, and nepotism.
3. Bribery and/or taking/giving gifts (gratification).
4. Conflicts of interest.
5. Violations of the Company’s regulations, code of ethics, and applicable laws and regulations.
6. Other forms of action that adversely affects the Company either directly or indirectly in financial or reputational terms.

The reporting party provides an early indication that can be accounted for such as:

1. The problem or the action being complained about
2. Parties involved
3. Location of incident
4. Time of incident
5. Chronology of incident
6. Other details

Submission of Violation Report

Submission of the Company WBS Offenses Report is set forth in Whistleblower Policies and Procedures, as follows:

1. Anyone may report alleged irregularities or breaches of law that may harm the Company, its customers, shareholders, employees, investors, or the public at large.
2. Reporting may be submitted in writing, telephone, or in person. However, it is recommended that it be made in writing so that the issues conveyed can be properly understood.
3. Every individual is encouraged to reveal their identity, although not an obligation.
4. All reports should be sent directly to a party responsible for handling the report.
5. If the report is submitted via email, it is recommended to use the title ‘Whistleblower Company’ to simplify identification.
6. Although a Whistleblower is not expected to prove the truth of the allegations, they must point to a strong case in favor of their concern over a violation/alleged offense.

WBS Management

In connection with incoming complaints, the Internal Audit Unit looks for evidence from the whistleblower, or related parties, during a regular audit or an investigation audit. The audit or investigation results are submitted to the Board of Directors. If there is evidence of a violation, Human Resources team assisted by Legal team handle the matter in accordance with the applicable regulations.

Whistleblower Protection

The Company and management are prohibited from disclosing the Whistleblower’s personal data and unfairly punishing them, such as changing their position, changing their job description or workplace, or imposing punishment, threaten, abuse, or lay off the Whistleblower.

WBS Socialization

Socialization is provided to all employees of the Company and its subsidiaries. Socialization is conducted through management meeting. For new employees, socialization is provided through the employees’ induction program, which material includes the WBS.