WHISTLEBLOWING REPORTING MECHANISM
BRI provides a special channel used to report violation to the President Director, these are: SMS, Written Letter and Webmail BRI. The information submitted in the violation report is protected.

Types of Reports
Information on violation report which may filed through WBS are:

  1. Violation on the Company’s SOOP
  2. Violation on BRI’s Code of Conduct
  3. Violation on the prevailing ethics and norms
  4. Action of law violation (harassment toward the employees or superordinate, blackmail, drug abuse, sexual harassment, and other criminal actions)
  5. Actions that endanger the work safety and health or endanger the Bank’s security or that could be detrimental to the Company
  6. Fraud

Information Reported
Every violation has to be reported in clear and responsible manner. The information conveyed in the violation report consists of: violation, party involve, time of violation, place of violation, chronology of violation, and violation evidence as preliminary information for investigation.

Reporting Procedures
The reporter may use various information tools of WBS: SMS, Written Letter and BRI Webmail to WBS Manager depicted below:

Whistle Blowing System Reporting Procedure

WHISTLEBLOWER PROTECTION
BRI provides protection and confidentiality assurance to all whistleblowers that disclose any violations or suspected breaches. The protection includes:

  1. Confidentiality of the whistleblower
  2. Confidentiality of the information reported and only use the information as preliminary information on investigation process.
  3. Protection from vengeful actions committed by reported parties or institutions (protection from pressures, delay on promotion, dismissal, legal lawsuit, material threat, to physical violence.
  4. The protection may be extended to the member of the family of whistlerblower.
  5. The protection does not include legal protection to the whistlerblower.
  6. To the whistlerblower with good intent to report the indication of violation and should the whistleblower involve in a violation (Justice Collaborator) and proved to be guilty and received Disciplinary Punishment, hence the whistleblower will be considered to give dispensation on the Disciplinary Punishment compare to other violators.

REPORT HANDLING
Every violation report in WBS will be proceeded to further action. The handling procedure is conducted through the following mechanism:

Reporting Process

  1. WBS Management
    Verify the reliability of the report by collecting additional information or prepare second opinion on the violation report.
  2. Head of Internal Audit Unit
    Determine the reliability of the report within 20 working days, with decision below:
    • Should the report be reliable, then the head of SKAI will ask the Investigation Team to check the allegation of the report as well as determining the investigation scope based on urgency and risk impact significance.
    • Should the report be unreliable and there is a clear information, the WBS Manager will report the violation to the related Head of the Working Unit.
    • Should the report be unreliable and no clear information, the WBS Manager will document the report under the Non Follow Up category.
Whistle Blowing System Reporting Process

Investigation Process
Investigation Team
Conducts investigation or Special Audit of the allegation of the violation.

Should the violation be proved and indicated for internal fraud, the investigation team will refer the violation case to Discipline Violation Checking Team, Policy and Human Resources Development Division to further proceed in accordance to S.152-DIR/SDM/05/2009 on Disciplinary Regulation.

Whistle Blowing System Investigation Process

Monitoring Process
Investigation Team
Reporting investigation result to related Head of Working Unit and WBS Manager within five working days after the investigation process ends.

WBS Manager

  • Monitor progress report through WBS system.
  • Monitor implementation of the follow-up progress on internal control improvement from Head of related Working Unit.
Whistle Blowing System Monitoring Process

Evaluation Process
Head of Related Working Units

  • Prepare internal control improvement follow up for every alleged violation proved.
  • Determine motives of improper complaints. Should a fake complaint or slander be found, hence the reporter should be sanctioned.
WBS Manager
Prepare evaluation report on WBS implementation

Head of Internal Audit Working Unit
  • Reporting evaluation result on WBS implementation to the President Director and Audit Committee every quarter.
  • Using the evaluation result as a consideration on preparing Annual Audit Plan.
Whistle Blowing System Evaluation Process

WBS SYSTEM MANAGER
BRI’s whistle blowing system is directly managed by the Head of Internal Audit Working Unit under the control of the President Director. WBS Management consist of two processes:

  • Reporting, Monitoring and Documentation Process These processes is managed by the WBS Manager Team, under direct coordination of the head of Internal Audit Working Unit.
  • Investigation Process The process is conducted by the Investigation team which is part of the Internal Audit Working Unit. Should a violation allegation is urgent or significantly impacted, the Investigation Team at the Head Office will conduct the investigation. Should the risks are not significantly impacted and not urgent, the investigation is conducted by the Audit Team at the Inspection Offices in the regional level.

TOTAL WBS REPORTS FILED AND FOLLOWED UP IN 2016 AND ACTION FOLLOWED
The number of violations reported in 2016 were 99 reports. Cumulatively, the total reports filed since the implementation of WBS up to 31 December 2016 were 1,654 reports with the details as follows:

Recap of WBS Report
  up to. 2010 2011 2012 2013 2014 2015 2016
Q1Q2Q3Q4
Total Reports16127833327826723834261623
Total1.654

The reports received in 2016 were divided into report classification, sources of report, identity attachment from the reporter, and the media for reporting, as follows:

Classification of WBS Report
Period Σ Source of Reports Identity of Reporter Media Classification of Reports
Internal External Yes No SMS Letter Phone/Verbal Complaint/Input Violations Report
Quarter I34304112327611024
Quarter II2618811152240917
Quarter III161425111600313
Quarter IV231948151940914
Total9981183564841413168

In general, total complaint/report as of 31 December 2016 was lower in quantity than that of the previous year. However, the percentage of report classified as violation was higher as reflected in the following table:

Development of WBS Report
Note 31 December 2015 31 December 2016
InputIndication of violationInputIndication of violation
Amount109 (45,79%)129 (54,21%)31 (31,31%)68 (68,69%)
Total Amount23899