Violation Reporting System Mechanism Policy


Scope
This policy applies to all Bank employees (both permanent employees and contract employees), both at the clerical level (clerk/administration) and management employees, external parties who have an interest in the Bank such as customers, third parties (outsourcing), vendors, former employees ( with special consideration from the report recipient) and consultant.

Type of Violation

Infringing activity may include, but is not limited to, several categories:

  1. Fraud Related to actions that are carried out intentionally with the intention of taking personal benefits or other parties in a way that violates internal and external regulations, resulting in losses for the Bank from financial and non-financial sides.
  2. Significant operational errors
    Related to actions taken by accident or unconsciously resulting in financial or non-financial losses for the Bank.
  3. Violation of Bank provisions
    Includes all forms of violations of the Bank's internal regulations as well as regulations applicable to the banking business sector.
  4. Conflict of interest (conflict of interest) is related to the misuse of the Bank's name, facilities or good relations for personal interests in any form including receipt of money, goods and facilities from certain parties without the permission of the Management.
  5. Actions that violate moral ethics
    Related to inappropriate actions that can harm the good name of the Bank, such as conflicts of interest, use of Bank data, misuse of assets/inventory and others.
  6. Actions that violate criminal law and civil law or other laws and regulations, such as forging signatures of authorized officials, drug use, harassment, destruction of goods and others.
  7. Actions that endanger occupational safety and health, endanger the security of the Bank, including endangering the assets of third parties/customers.

Whistle Blower Reporter
Whistle Blower ("Whistleblower"), can be categorized into:

  1. Internal parties, including management employees, clerical employees, both permanent employees, contract employees and outsourcing.
  2. External parties, including former employees, vendors, customers, consultants, other external parties. Each Whistleblower is expected to be able to provide evidence in the form of data, information or initial indications of a violation, so that the reported case can be traced and followed up by the competent authorities. Reports that are still incomplete will be requested for additional information to the Whistleblower through a secure channel.

Completion of the Whistle Blower case

The Whistle Blower Report will be forwarded by the Whistle Blower Officer to the Bank's Internal Audit, confidentially without mentioning the identity of the Whistleblower at all.

The Whistle Blower case was then investigated by Internal Audit like cases of fraud and other violations. If there is disciplinary action, either against the Whistleblower or the Reported Party, including actions to rehabilitate the employee's name, the Bank is guided by the Bank's policy on Violations in the Implementation of Work (TPDPK).

Reporting Media

Reporting can be done using the following media:

  1. Written letter
  2. E-mail / e-mail addressed to ayo.lapor@nobubank.com

Confidentiality

Considering that a Whistleblower's report can provide positive benefits in handling violations, the confidentiality of the identity of the Whistleblower and the reported case needs to be maintained as best as possible.

Protection for Whistleblowers

Whistleblowers receive facilities and protection in accordance with Bank policy