Whistleblowing System Reporting Criteria
Violations that may be reported through the Whistleblowing System include any breach of law or company regulations committed by Samora Group employees in relation to the Samora Group work environment or directly associated with their position within the organization. These include, but are not limited to:
- •Requests for money (bribery), facilities, discounts, special privileges, or gratuities in any form.
- •Promises of appointment as a supplier, vendor, consultant, or employee outside the company’s official recruitment or procurement mechanisms.
- •Threats, hate speech, incitement, or any form of defamation.
- •Discrimination based on ethnicity, religion, race, gender, disability, physical appearance, family background, or social status.
- •Harassment, indecent conduct, or the distribution of pornographic material within the workplace.
- •Distribution of items prohibited by law and regulations (including narcotics and other illegal substances).
- •Bring sharp weapons or firearms into the workplace or during official assignments.
- •Fraudulent acts that may cause financial loss to the company.
- •Actions that may pose risks to occupational health and safety.
- •Any form of falsification or fraud carried out in the name of the company.
- •Other actions that may be categorized as violations of applicable laws or company regulations.
Whistleblowing System Reporting Mechanism
- •The whistleblower submits a violation indication report through the Whistleblowing System.
- •Whistleblowing System Team records all reports of indications of violations in the whistleblowing system application.
- •WBS committee conduct preliminary analysis (verification) of reports of violation indications according to the whistleblowing system report criteria.
- •If necessary, the WBS Team can request additional information and confirmation from the whistleblower in fulfilling the information and report data.
- •Head of Compliance validates the results of the verification of the violation indication report and decides on the follow-up to the report, namely: Follow up for investigations; or No follow-up was taken (the report was rejected) because it did not match the criteria for the WBS report.
- •The Head of Compliance appoints an Investigation team to investigate the WBS report.
- •The Investigation team submits a report on the results of the investigation (including recommendations for followup improvements).
Requirements for Whistle Blowing Reporting
Reported Violation
Subject of reporting of violations and amount of losses (if known)
Parties Involved
Samora Group personnel and the parties involved indicated violations
Time of Violation
The period of time the indication of the violation occurred
Place of Violation
Location/place of work unit where the violation occurred
Chronology of Events
Description of events/chronology of events so that there are indications of violations
Evidence of Violation
Documentation of indications of violations in the form of documents, photos, videos and other supporting information
Reports of follow-up improvements include:
- •Follow-up to the perpetrator of the indication of the violation and improvement of the weaknesses that occurred as well as the risk mitigation carried out.
- •Provide information to the reported superior in order to maintain the good name of the reported party if the WBS report is not proven.
- •The work unit is authorized to carry out follow-up improvements in accordance with applicable regulations.
- •The work unit has the authority to submit a follow-up improvement report to the WBS Management Unit.
Whistle Blowing Protection
- •Samora Group provides protection to whistleblower confidentiality of personal data and reported information.
- •The protection is also given to internal whistleblowers from pressure, postponement of promotions, discrimination, dismissal, and physical actions.
- •Protection from the risk of retaliatory actions against the whistleblower Legal assistance (in certain cases).
Whistleblowing System Report Submission
E-mail: wbs@samoragroup.co.id
Written letter addressed to:
Legal Department UP - WBS Committee Samora Group
Menara Thamrin 16th Floor
Jl. M.H. Thamrin Kav 3, Kelurahan Kampung Bali, Kecamatan Tanah Abang, Central Jakarta, DKI Jakarta. 10250, Indonesia
