Whistleblowing system

Reporting an act that is suspected of being a violation

PT Primaplast Indonesia Tbk is committed to implementing the principles of good corporate governance (GCG), code of conduct and applicable laws and regulations in all its activities. This commitment is expected to be able to maintain the company’s existence in achieving the company’s goals and objectives. In relation to this, PT Primaplast Indonesia Tbk (Persero) always strives to ensure that the existing GCG and internal control systems are effective enough to ward off various risks. However, sometimes even both systems can fail to provide early information regarding violations at PT Primaplast Indonesia Tbk (Persero).

A standard system or mechanism is needed at PT Primaplast Indonesia Tbk (Persero) to accommodate all complaints of violations or potential violations that can have a negative impact on the company. This system is very necessary so that no losses or risks occur. PT Primaplast Indonesia Tbk (Persero) realizes that handling every complaint of violations is a form of certainty of enforcing company rules and ethics for all PT Primaplast Indonesia Tbk (Persero) personnel in carrying out their duties.

Principles

  • The responsibility and authority for the management and implementation of the Whistleblowing System lies with the Board of Directors.
  • Submission of reports of alleged violations committed by the Reporter must provide clear information, evidence or allegations of the reported violation and fulfill the elements of 4W 1H, namely: What (what is the alleged violation known to the Reporter?), Where (where did the violation occur/committed?), When (when was the violation committed?), Who (who was involved in the violation?), How (how was the violation committed?)
  • The Company opens access to reporting by providing an application program that can be accessed by prospective Reporters.
  • Reporters can include their identity or not include their identity (anonymous).
  • The Whistleblowing System Management Team is required to accept and resolve complaints of violations as long as the report in question has been supported by the required completeness.
  • The Company guarantees confidentiality and provides protection to Reporters as long as the violation report submitted is not a false report or slander.
  • The Company will protect the identity of the Reported Party as long as the report of the violation committed by the person concerned cannot be proven conclusively.

Complaints’ Scope

The scope of complaints that will be followed up by the Whistle Blowing System Management Team are actions that can harm the Company, namely:

  • Misuse of Company facilities.
  • Threats.
  • Misappropriation of Company funds.
  • Abuse of office for personal or group interests or other interests outside the Company.
  • Embezzlement of Company assets.
  • Acceptance, giving and requesting of gratuities.
  • Violation of ethics and immoral acts.
  • Leakage of Company secrets.
  • Extortion.
  • Theft.
  • Fraud.
  • Cheating.
  • Disciplinary violations.
  • Conflict of interest.
  • Corruption.
  • Collusion.
  • Nepotism.

Authority to Handle the Whistle Blowing System

  • Alleged Violations by Employees / Outsourcing Employees / Fixed-Term Employment Agreement (PKWT) employees working in the Company -> Handling of reports of alleged violations related to and / or committed by Employees / Outsourcing Employees / Fixed-Term Employment Agreement (PKWT) employees working in the Company, including the Whistle Blowing System Management Team is the authority of the President Director.
  • Alleged Violations by the Board of Directors and / or the Board of Commissioners -> Reports of alleged violations related to and / or committed by the Board of Directors and / or the Board of Commissioners are submitted to Shareholders.
  • Reports of alleged violations related to and / or committed by members of the Board of Directors can be followed up by the Board of Commissioners in accordance with its authority as regulated by the General Meeting of Shareholders (GMS) and the Company’s articles of association.
  • Alleged Violations by Supporting Organs of the Board of Commissioners; handling of reports of alleged violations related to and / or committed by Supporting Organs of the Board of Commissioners is adjusted to the relevant provisions.

Whistleblowing System Mechanism

  • The reporter can submit a report of alleged violations via:
  • To speed up and simplify the complaint follow-up process, the reporter -> can provide information regarding personal data (address, telephone number, fax or e-mail address with an anonymous option); must provide initial information that can be accounted for (the problem being complained about, namely the main complaint or problem to be disclosed and the amount of loss (if it can be determined), and it is better if one complaint is only for one problem so that the information submitted is more focused); parties involved (who is suspected of being responsible for the incident including witnesses and who or which party benefits or is harmed); location of the incident (location, field or operating unit where the problem occurred specifically mentioning the name, place or function in question); time of incident (period of occurrence of the problem, either in the form of a month, year or specific date when the problem occurred); how the problem occurred and evidence that can be attached; information whether this case has ever been reported to another person or party; and information whether this case has ever happened before.
  • If you want to attach supporting data in the form of hard copies of documents related to the alleged violation (for example, evidence), it can be addressed to: PT Primaplast Indonesia Tbk Jl. Kaserangan – Pengampelan, RT.006/RW.003, Kaserangan, Kec. Serang, Serang Regency, Banten 42182 Telp.+62-254 8285888 UP. Head of Internal Audit Team.
  • Submission of hard copies of documents related to the alleged violation by including the email address on the document to be sent.

Protection for Reporters and Reported

  • The Company is obliged to protect the Reporter of the complaint.
  • Protection of the Reporter of the complaint is intended to encourage courage in reporting violations.
  • Protection of the Reporter includes guarantees of the confidentiality of the Reporter’s identity and the contents of the report as well as guarantees of security for the Reporter from the Company against detrimental treatment, such as unfair dismissal, demotion, intimidation, harassment or discrimination in all forms and detrimental records in personal data files.
  • The Company also provides a guarantee of confidentiality of the Reported’s identity as long as the alleged violation has not been proven.
  • The Reported must be given full opportunity to provide an explanation of the evidence found, including a defense if necessary.
  • This Protection for the Reporter is carried out by considering the principle of confidentiality between the Reporter and the Company. Leakage of this confidential nature by the Reporter will eliminate the Company’s obligation to guarantee confidentiality given to him and in certain cases can result in the loss of protection for the Reporter.

Sanctions for False Reporting

  • For internal parties the Company who send false reports or slander or reports containing elements of bad faith that are detrimental to the Company, they can be subject to sanctions in accordance with Company regulations or can be reported to law enforcement.
  • For external parties who send false reports or slander or reports containing elements of bad faith that are detrimental to the Company, they can be reported to law enforcement.