What Are the Scope of Reporting Criteria?

1. Corruption and Bribery

2. Fraud, including actions that result in a financial loss to the Company, including but not limited to:

   • Falsification, manipulation, or destruction of financial or other reports/documents;

   • Conflicts of interest, Gratification, and all forms of bribery; and

   • Other fraudulent actions, including misappropriation of assets, theft of assets, and/or facilitating a violation.

3. Other criminal acts, tincluding extortion, coercion with violence or threat to give something with the intent of obtaining a benefit for oneself or others, whether from internal or external parties, that is inconsistent with prevailing Laws and Regulations.

4. Workplace Misconduct, including any actions that create a non-conducive work situation, sexual harassment, bullying, and defamation, including gender and SARA (ethnicity, religion, race, and intergroup relations) discrimination, and any unwanted physical or non-physical actions that cause offense or lower dignity.

5. Other violations, including but not limited to:

   • Violation of the Company's Code of Ethics, as stipulated in the Company's Code of Conduct;

   • Breach of confidentiality (information leakage), except for information that is already in the public domain;

   • Bias towards one party (unfairness) and an unobjective attitude in implementing Company decisions; and

   • Violations related to environmental pollution and/or damage committed due to negligence that can result in property loss and/or endanger human health or physical safety.

How is the reporting of violations carried out?

The regulation stipulates the following provisions :

1. Reports will be received through the integrated WBS channel, OpenMIND, which has been provided by MIND ID. The channels provided include:

   • Website     : OpenMind-wbs.com

   • e-mail        : OpenMIND@kpmg.co.id

   • Whatsapp : 0811-1464-632 / 0811-646-343

   • Post Mail  : PT KPMG Siddharta Advisory, Attn: KPMG EthicsLine (MIND ID), Menara Astra Lantai 21, Jl. Jend. Sudirman Kav. 5-6, Jakarta 10220

     These channels are only accessible by an Independent Third-Party (“KPMG Consultant”). Information regarding the WBS channels must be provided and announced on the Company's Website (www.inalum.id). 

2. A case reference number is given to the Whistleblower/Reporter to be used as a reference, so they can monitor the status of the report. 
3. Considering independence and objectivity, and in accordance with applicable policies, reports will be forwarded for follow-up action to the authorized parties at INALUM, including the Ministry of State-Owned Enterprises (“BUMN”) (especially concerning members of the Board of Directors and Board of Commissioners).
4. The report submitted must meet the "4W + 1H" elements and include sufficient and relevant evidence:

How Are Reports Handled?

The Whistleblowing Team receives written reports of violations from whistleblowers submitted through the Whistleblowing media.

How Long is the Reporting Deadline?

The deadline for handling violation reports is a maximum of one (1) month.

What Forms of Confidentiality and Reward are Provided for Whistleblowers?

PThe company is required to keep the identity of the reporter and the contents of the report confidential. The company also guarantees protection for the reporter from any form of threat, intimidation, or unpleasant actions from any party as long as the reporter maintains the confidentiality of the reported case.

Whistleblowing System (“WBS”) Structure

a. Independent Third-Party

• (i) The integrated MIND ID Group WBS, including INALUM, is managed by an independent third-party appointed by MIND ID to handle the operational management of the MIND ID Group WBS reports.
• (ii) The independent third-party reports directly to the respective WBS management teams of MIND ID and INALUM
• (iii) The independent third party plays a role in maintaining the objectivity and integrity of the reporting process.
• (iv) With the involvement of an independent third party, the Reporter has the right to submit a report that will be processed confidentially and has the option to report anonymously.

b. WBS Team Member

c. Investigation Team

The investigation team is a team appointed by the Company and must follow up on the recommendations of the WBS Team in accordance with the provisions.

d. Supervisory Board (“Dewan Pengawas”)

The Supervisory Board consists of the Board of Commissioners and the Audit Committee and/or other committees.

Data Compilation