Astra Property Group (“Group”) highly upholds the Company's values, namely LIFE (Legacy, Integrity, Funtastic, and Expert) and is committed to implementing Good Corporate Governance (“GCG”) consistently. This is done in order to realize good performance while remaining compliant with regulations and legislation through the implementation of clean business practices and upholding ethics. In an effort to continuously improve the compliance of Astra Property personnel with applicable regulations and ethical standards and prevent violations from occurring, the Group has established a Whistleblowing System (WBS) policy within the Group so that the Group can run its business optimally supported by clean ethics and behavior from all Astra Property personnel. WBS is a system used to accommodate, process, follow up and create Reports submitted by the Whistleblower (as defined below) from both internal and external parties regarding violations/alleged violations that occur within the Group, including violations of GCG principles, Business Conduct Ethics Guidelines and Code of Ethics (“Astra Property Business Ethics & Code of Conduct”), company regulations/policies and applicable regulations, carried out by Astra Property personnel that can harm the Group or stakeholders. Reports obtained from the WBS mechanism will receive attention and follow-up, including the imposition of appropriate penalties in order to provide a deterrent effect for perpetrators of violations and also for those who intend to do so. Reports of violations supported by adequate initial evidence will be followed up for further audits to determine whether or not a report is proven. The audit results are the basis for Group Management to impose sanctions on the Reported Party (as defined below). WBS ensures that every Whistleblower can know the status of the development and follow-up of their report. Through WBS, a strong perception will arise that if someone commits fraud, the potential for being detected and reported will be greater. Thus, if this WBS is implemented firmly and consistently, it is expected to realize Astra Property personnel who have good performance, comply with the law, are clean, and uphold ethics
2.1. This policy applies to the Board of Commissioners, Directors, and all Employees of Companies affiliated with the Group.
2.2. Whistleblower is a person who reports an act of violation. The whistleblower can come from Internal Parties (Astra Property Group Employees) and External Parties (customers, vendors, partners, suppliers, the community and other stakeholders).
2.3. “Reported Party” means all individuals under the Group, including the Board of Commissioners, Directors, Employees and Work Partners, who are reported by the Whisleblower regarding reportable acts.
2.4. The following are examples of matters of serious concern that can be reported, among others:
a. Deviation/failure to comply with legal or regulatory obligations ;
b. Conflict of interest/abuse of power for interests other than the Company;
c. Criminal acts, such as fraud, extortion, cheating, theft, corruption, bribery, gratification, and other actions that lead to criminal acts;
d. Conditions when the health and safety of an individual /group of employees/workers is threatened ;
e. Harassment and Discrimination Act;
f. Financial Manipulation or Irregularities;
g. Intentionally concealing the existence of the above practices; and
h. Violation of Company Regulations, policies applicable in the Group, and Astra Property Business Ethics & Code of Conduct .
2.5. The structure of the WBS Reporting Management Team is as follows:
a. WBS Committee
Represents the Board of Directors and/or Board of Commissioners of the related entity in WBS Reporting. Has the following duties and responsibilities:
• Provide direction to the WBS Analysis Team and WBS Audit Team in order to facilitate the implementation of WBS Reporting management;
• Deciding on the Report that will be continued with the audit process after considering the analysis results from the WBS Analysis Team;
• Provide a Letter of Assignment (if necessary) to the Analysis Team and WBS Audit Team regarding the implementation of WBS Reporting management and handling; and
• Monitor and evaluate the progress of the implementation of WBS Reporting management and handling.
b. WBS Analysis Team
It is a team that comes from cross-functional Groups. Has the following duties and responsibilities:
• Monitor all complaints received into the WBS system;
• Conduct analysis of reports received via the WBS site;
• Collect all initial evidence of Reporting as a basis for analysis and audit decision making;
• Reporting the results of the analysis Reporting to the WBS Committee with recommendations to continue with the audit or stop; and
• Create periodic reports on handling incoming reports.
c. WBS Audit Team
It is a team that comes from cross-functional Group appointed by the Board of Commissioners and/or Board of Directors. Has the following duties and responsibilities:
• Processing WBS Reports submitted by the WBS Analysis Team after approval by the WBS Committee; and
• Making periodic reports and audit results reports on the handling of Reports that are followed up.
d. WBS Administrator
It is a team that comes from cross-functional Groups. Has the following duties and responsibilities:
• Managing username and password administration in the WBS system, namely: adding, deactivating users and resetting passwords for users;
• Periodically check/monitor the WBS system to ensure the recency of WBS Reporting; and
• Carrying out administration of complaint documents and WBS Report handling documents.
This WBS aims to improve the quality of transparency, accountability, responsibility, independence and equality as well as fairness in the implementation of GCG and prevent both material and immaterial losses to the Group.
4.1. Main Channel for Complaints & Reporting of Violations
Complaints, grievances and reports from internal and external parties can be reported to the Group through the following channels: WBS email: wbs@astraproperty.co.id
4.2. Optional Reporting Channel only for Whistleblower from Internal Parties
First Option
If an Employee has serious concerns about an act or omission that will impact the Group's business or its reputation, or will harm or endanger someone, the Employee must first raise it with his/her immediate supervisor or the relevant Department Head. This Reporting activity can be done verbally or in writing.
Second Option
If an Employee feels unable to raise matters of Serious Concern with their immediate supervisor or line manager, the Employee may raise the matter with:
The relevant Division Head or Project Director where the Group Employee works;
or
Human Capital Department Head at the Company where the Group Employees work.
Third Option
If an Employee still feels uncomfortable, the Employee can convey the matters of Serious Concern by:
Director/Executive in Charge of the relevant Company/Business Unit;
or
Human Capital Division Head Astra Property Group;
or
Vice President Director of Astra Property Group.
Fourth Option
If the Employee feels that the Serious Concern cannot be discussed through any of the options or if the first three options have been followed and the Employee still has concerns, the Employee may report to the WBS Email.
4.3. Reporting Requirements
In reporting matters of Serious Concern, the Whistleblower needs to pay attention to the following matters:
a. The Whistleblower is required to provide initial, accountable indications, including:
1) Description of the reported violation, including a summary of the incident, chronology, amount of loss (if it can be determined). 1 (one) complaint/disclosure should only be for 1 (one) violation so that handling can be more focused;
2) The parties involved, namely who should be held responsible for the violation, including witnesses and parties who benefit or are harmed by the violation;
3) Location of the violation, including the name, place or function where the violation occurred;
4) Time of violation, namely the period of violation, whether in the form of a day, week, month, year or a specific date when the violation occurred;
5) How the violation occurred and whether there is supporting evidence that the violation occurred;
6) Has the violation ever been reported to any other party;
7) Has the violation occurred before;
b. clear, relevant evidence that supports information on the subject of the report/problem being reported, either in the form of documents/letters, recordings, images, and others;
c. Information can be delivered as soon as possible to the WBS Email or other reporting options for Internal Parties as set out above;
d. To speed up and simplify the complaint/disclosure follow-up process, the Whistleblower is advised to provide information regarding personal data, which at least includes address/telephone number/mobile phone/email; and
e. Reporting must be based on good faith and not be a personal complaint or based on bad intentions/slander.
5.1 The Company guarantees the confidentiality of the Whistleblower's identity, except when disclosure is necessary in connection with reports or investigations carried out by the authorities;
5.2 The Company guarantees protection for the Whistleblower from all forms of threats, intimidation or unpleasant actions from any party as long as the Whistleblower maintains the confidentiality of the reported violation to any party;
5.3 Protection for Whistleblower also applies to parties who carry out audits and parties who provide information related to the complaint/disclosure;
5.4 In carrying out the follow-up process for each complaint/disclosure, it is mandatory to prioritize confidentiality, the principle of presumption of innocence and professionalism;
5.5 Submission of reports without identity (anonymous) will still be accepted and followed up by the WBS Analysis Team which is authorized to accept the report in accordance with existing procedures. However, submission of anonymous Reports is not recommended because anonymous Reports will complicate communication for follow-up on the Report;
5.6 Astra Property employees who violate the principle of confidentiality will be given severe sanctions in accordance with the provisions applicable in the Company; and
5.7 The company will impose sanctions for misuse of WBS, where parties (both internal and external) who submit reports in the form of slander or false reports will be given sanctions including legal proceedings and will not receive guarantees of confidentiality or protection for the Whistleblower.
Once a Whistleblower reports matters of genuine Serious Concern, the next mechanism is as follows:
6.1. The WBS Analysis Team that handles Reporting through the complaint and reporting channels set out above will review, analyze, and verify reports of indications/alleged violations, the information submitted, and supporting evidence to assess the actions that must be taken;
6.2. For potential violations committed by Employees, the WBS Analysis Team will submit a report of indications/alleged violations to the WBS Committee (Board of Directors) of the relevant entity with the following process:
a. The Board of Directors conducts discussions and provides approval/recommendations to the WBS Analysis Team to form a WBS Audit Team;
b. The WBS Audit Team conducts the audit in accordance with the WBS Procedure and reports the audit results to the WBS Analysis Team;
c. The WBS Analysis Team submits the audit results report to the Board of Directors;
d. The Board of Directors discusses the WBS Audit Report;
e. If the audit results state that the violation is PROVEN,
1) The Board of Directors submits recommendations for imposing sanctions to the Human Capital Division Team for further processing;
2) The Human Capital Division Team submits a report on the imposition of sanctions to the WBS Analysis Team for documentation;
f. If the audit results state that the violation is NOT PROVEN, the WBS Analysis Team will create and convey information to the Whistleblower that the violation is not proven and is considered completed and will store archive documents;
6.3. For potential violations committed by Member of the Board of Directors, the WBS Analysis Team will submit a report on indications/allegations of such violations to the WBS Committee (Board of Commissioners) of the relevant entity in accordance with the applicable mechanism with the following process:
a. The Board of Commissioners held discussions to appoint the WBS Audit Team, whose members consisted of Members of the Board of Commissioners and other Members appointed by the Board of Commissioners;
b. The WBS Audit Team carries out audits in accordance with applicable regulations and reports the audit results to the Board of Commissioners;
c. If the WBS audit results state that the violation is PROVEN,
1) The Board of Commissioners holds discussions to provide/determine sanctions and submits a notification letter regarding the imposition of sanctions;
2) The Human Capital Division Team forwards the notification letter regarding the imposition of sanctions to the WBS Analysis Team for documentation;
d. If the audit results state that the violation is NOT PROVEN,
1) The WBS Audit Team forwards the audit results to the WBS Analysis Team; And
2) The WBS Analysis Team creates and delivers information to the Whistleblower that the violation is not proven and is considered resolved and stores archive documents.
6.4. For potential violations committed by Member of the Board of Commissioners , the WBS Analysis Team will submit a report of indications/allegations of such violations to the WBS Committee (President Commissioner or relevant Shareholders) of the relevant entity in accordance with the applicable mechanism with the following process:
a. The President Commissioner or relevant Shareholder conducts discussions to appoint a WBS Audit Team whose members consist of Members of the Board of Commissioners and other Members appointed by the President Commissioner or relevant Shareholder;
b. Team carries out audits in accordance with applicable regulations and reports the audit results to the Board of Commissioners;
c. If the WBS audit results state that the violation is PROVEN,
1) The President Commissioner or relevant Shareholders hold discussions to provide/determine sanctions and submit a notification letter regarding the imposition of sanctions;
2) The Human Capital Division Team or President Commissioner forwards the notification letter regarding the imposition of sanctions to the WBS Analysis Team for documentation;
d. If the audit results state that the violation is NOT PROVEN,
1) The WBS Audit Team forwards the audit results to the WBS Analysis Team; And
2) The WBS Analysis Team creates and delivers information to the Whistleblower that the violation is not proven and is considered resolved and stores archive documents.
6.5. For potential violations committed by the Business Partner, the WBS Analysis Team will submit a report on indications/alleged violations to the WBS Committee (Board of Commissioners and/or Board of Directors) of the relevant entity with the following process:
a. The WBS Committee holds discussions to appoint a WBS Audit Team whose members may consist of the Board of Directors and the WBS Analysis Team;
b. The WBS Audit Team conducts audits in accordance with applicable regulations and reports audit results to the relevant entity's WBS Committee;
c. If the audit results state that the violation is PROVEN,
1) The WBS Committee holds discussions to provide/determine sanctions and submits a notification letter regarding the imposition of sanctions;
2) The WBS Committee forwards the notification letter regarding the imposition of sanctions to the WBS Analysis Team for documentation;
d. If the audit results state that the violation is NOT PROVEN,
1) The WBS Audit Team forwards the audit results to the WBS Analysis Team; and
2) The WBS Analysis Team creates and delivers information to the Whistleblower that the violation is not proven and is considered resolved and stores archive documents.
The entire evaluation process of complaints/disclosures must be made into a Minutes. The entire process of the Violation Reporting system must be well documented and reliable so that it can be accounted for.
Things that must be considered in implementing the Follow-up process for Reporting, include:
a. In carrying out the follow-up process for each Report/complaint/disclosure, the Parties handling the Report are required to prioritize the confidentiality of the Employee's identity (the Reporting Party), the principle of presumption of innocence and professionalism;
b. Parties handling Reporting are required to inform Employees (Reporting Parties) to maintain the confidentiality of cases that are of Serious Concern reported during the handling process;
c. The principle of confidentiality applies to the Team appointed to carry out internal investigation/search activities as well as parties who provide information related to complaints/disclosures; and
d. Parties who violate the confidentiality principle will be subject to sanctions in accordance with the provisions in force in the Company Regulations.
7.1. The form of sanctions against the reported party who is proven guilty is given in accordance with the provisions applicable in the Company Regulations; and
7.2. In accordance with the principle of Confidentiality, Whistleblower who submit reports in the form of slander or false reports will receive sanctions and will not receive either confidentiality guarantees or Whistleblower protection. Sanctions that can be imposed are regulated in Company Regulations or other policies regulated by the Company.
The Company is required to publish and socialize the WBS within the Group and to stakeholders outside the Group through various Company media, such as, but not limited to:
8.1 Print and distribute this policy document and communicate it in internal Group forums; and
8.2 Embed within the website, Group email, banner or other relevan.