Sunindo Group

Introduction

As a manifestation of GCG and internal control, the Company has created a reporting system called the Whistleblowing System (WBS). With this system, the Company encourages each individual of the Company and external parties to report any ethical violations conducted within the Company with accountable evidence so that they can be followed up.

This system is implemented to mitigate potential risks and create a company environment that is free from Corruption, Collusion and Nepotism (KKN) practices, and behave ethically in running/managing the Company. The Company guarantees the confidentiality of identity and provides protection to the Whistleblower.

Definition

Whistleblowing System (WBS)

is a mechanism established to receive and review reports of violations received by the Company, examine reported violations, provide the necessary protection related to the reports received and complete the handling of reports of violations.

Whistleblower

is an individual or institution that submits a report of violation in the Company

The Reported Party

is a Personnel of the Company, either alone or in collaboration with other parties, who based on the Violation Report is suspected of committing a violation.

The Whistleblowing Management Team (WBS)

is a team appointed by the Board of Directors to receive and review reports of violations, propose examinations of reported violations and the necessary protection related to the reports received and monitor the completion of handling reports of violations.

The Investigation Team

is a team appointed by the Board of Directors to conduct an investigation that aims to reveal the actual facts or events about the offense that occurred.

Supporting Evidence

is data and information that is in accordance with the actual facts or events about the alleged violations that occurred.

Violation

is an act committed by Personnel of the Company, either alone or in collaboration with others, which is contrary to the laws and regulations, Company regulations or applicable norms and ethics and can harm the Company.

Violation Report

is information submitted by the Whistleblower through the WBS which contains an explanation of the violation that occurred.

Analysis Report

is an information submitted by the WBS Management Team to the Board of Director which contains an overview of the violations that occurred, the proposed further handling and the necessary protection.

Related Management

is management or head of the relevant department of the reported party.

Report Submission Mechanism

The Company has provided various media to accommodate stakeholders in submitting their reports if a violation is committed by The Company's employees with the following mechanism

Company Website

www.sunindogroup.com

E-mail of WBS Team

wbs@sunindogroup.com

The following are the conditions of the reporter:

Reporting can be done anonymously or supplemented with the identity of the reporter by providing evidence of provisional allegations of violation
The Company guarantees the confidentiality of the Reporter's Identity
The Company guarantees the protection of the WBS Management Team and Investigation Team as well as parties conducting the investigation as well as parties providing information related to the complaint

Types of Violations

Corruption / Embezzlement

Actions of employees who improperly and illegally enrich themselves or enrich their relatives by abusing the power and/or position entrusted to them.

Burglary

Obtaining goods or things either wholly or partially belonging to another person or Company against the law.

Fraud

Fraudulent acts committed in such a way as to benefit oneself/group with or without detriment to the Company.

Bribery

Accepting or giving gifts by employees.

Conflict of Interest

A situation where a personnel of the Company who has power, position and authority is suspected of having a personal interest in any use of his/her authority either intentionally or unintentionally so that it can affect the policies and decisions taken which can harm the Company.

Immorality

Forms of behavior or acts of indecency, harassment or sexual harassment with coworkers, subordinates or superiors or company leaders and their families.

Actions that violate the law and Company regulations

Committing violations of applicable laws and regulations that result in losses to the Company, neglecting the implementation of Company policies and procedures.

Management of Violation Reports