As referred to in the Company Code of Conduct, the Company provides the official mechanism for a whistleblower to report misconduct. This mechanism, ‘Suara Matahari’, is part of our internal control system and plays a critical role in our commitment to fair working conditions.
Suara Matahari offers a range of confidential channels through which employees and other stakeholders can report if they genuinely suspect that a violation of the Code of Conduct or other misconduct has taken place, remaining anonymous if they wish. The Company’s whistleblowing policy, including the procedures and contact numbers for reporting, has been disseminated to all our employees, management, suppliers and business partners.
Suara Matahari has some features that support its accessibility, trustworthiness and effectiveness:
1. Numerous hotline channels, including toll-free phone lines, Short Message Services/SMS, website, email and mailbox;
2. Promotion of anti-fraud awareness and the whistleblowing program to all management, employees and suppliers;
3. Experienced contact centre operators who handle incoming reports;
4. Forensic investigation experts follow up the incoming reports and present the issues to management;
5. Recommendations for improvements.
Suara Matahari is under the management of an independent third-party administrator, Deloitte, to ensure objectivity and effectiveness. The setting ensures that informants have complete anonymity and protection. The Risk Management and Internal Audit Division monitors the incoming reports' status and consolidates them for reporting to the Board of Directors and the Risk Management Committee.
Suspected misconduct or violations of the Code of Conduct can be reported through any of the following channels:
• Hotline: Informants can contact Suara Matahari on +62 21 2350 7056; they have the right to remain anonymous if they choose.
• SMS: Reports can be sent by SMS to +62 81586709196.
• Email: Reports can be sent via email to firstname.lastname@example.org. The informant’s email address will not be disclosed without permission.
• Website: Reports can be sent via the Suara Matahari Website at http://suaramatahari.tipoffs.info. Reports should provide as much information as possible about the suspected violation.
• Mail: Reports can be sent via regular mail to Suara Matahari PO Box 3670/JKP 10036, Central Jakarta.
Reports submitted in writing must be accompanied by a disclosure cover sheet, which can be downloaded from the Suara Matahari website. Informants should provide at least the following information to ensure that the appropriate actions can be taken:
(i) Name(s) of those involved;
(ii) Name of a witness (if available);
(iii) Information about the incident, including date, time and location;
(v) The related nominal or assets; and
(vi) The frequency of the incident(s).
1. The Suara Matahari operator receives the whistleblowing report through one of the above channels and assigns a unique, anonymous reference number to the informant, which he or she can use when requesting information about the progress of the case.
2. The report is sent to a Deloitte analyst for assessment. The results are returned to the Company’s representative within one working day.
3. The Risk Management and Internal Audit Division determines further investigation and clarification actions. Later on, this division will present the results to the Risk Management Committee to decide on the penalties or sanctions on the suspects and determine any internal control improvements or other changes the Company needs to make.
The Company guarantees to protect informants who report in good faith from any retaliation by the allegation's subject. Informants have the following options regarding the disclosure
of their identity:
1. Full disclosure: the informant is willing to disclose his/her identity to Deloitte and the Company.
2. Partial anonymity: the informant is willing to disclose his/her identity only to Deloitte. In this case, Deloitte will keep the informant’s identity confidential from the Company.
3. Full anonymity: the informant is unwilling to disclose his/her identity to either Deloitte or the Company. The Company guarantees to protect informants who report in good faith from any retaliation by the allegation's subject
Throughout 2020, of a total of 57 cases reported, 48 were received via Suara Matahari and 9 through other channels. The cases involved internal and external parties and included alleged violations of the code of conduct, conflicts of interest, and requests for or receipts of money and/or gifts from vendors. All cases were investigated, with 29 being substantiated, 22 not substantiated, and 6 still under investigation at the time of publication of 2020 Annual Report.