What needs to be reported?

If you see suspicious events such as:

1. Cheating (unfairness)

An action carried out by a person / group of IPC Personnel with the intention of benefitting themselves or others, by using a false name or false dignity, by deception, or a series of lies, or when a person/group of IPC personnel persuade others to give benefits in ways that are not right and against the law.

Examples of cheating:

  • Approve orders to suppliers who have a ‘special relationship’.
  • Paying or not paying vendors who have ‘special relationships’, which directly provide commercial benefits or other forms of competitive benefits for other vendors.
  • Recruiting candidates who have a ‘special relationship’ with the perpetrator, while other candidates have better qualifications.

2. Corruption

Actions of IPC persons who improperly and illegally enrich themselves or enrich parties with a “special relationship” to themselves by abusing the power entrusted to the aforementioned persons.

Examples of acts of corruption:

  • Abusing power for personal or group interests.
  • Receiving benefits (for example money, gifts, hospitality) which are in conflict with their job’s responsibilities.
  • Using budgets, assets, services, and subsidiary information for activities outside the business venture.
  • Receive benefits (in any form) other than the salary and benefits they are entitled to.

3. Theft

An activity/action of taking an item which is wholly or partially owned by another person, with the intension of owning the item illegally (KUHP Article 362).

Examples of theft:

  • Taking other people’s property without the consent of the owner.
  • Using other people’s identities to obtain goods and services.
  • Selling items and storing proceeds from the sale in secret.
  • Misusing / taking for no reason the rights of money / goods / data / documents belonging to the company and / or customers in the work environment.

4. Violation of company policies and company regulations

Any intentional or planned activities / actions carried out by IPC individuals that are contrary to the policies and internal regulations of the Company and its subsidiaries. Perpetrators of this violation can be threatened with sanctions according to both internal and external applicable regulations.

Examples of violations of company policies and regulations:

  • Carrying out duties outside of the established procedures and instructions.
  • Leaking company information, such as budgets, offers from suppliers, business strategies, and so on to unauthorized people.
  • Making and / or using and / or providing and / or changing and / or copying and / or duplicating false data and / or information that it harms the company and / or customers and / or investors / potential investors.
  • Improper provision of credit facilities or payment extension for external parties while the action violates existing regulations and potentially damages the company and its Subsidiaries.

5. Conflict of Interest

A situation / condition in which IPC Individuals or major shareholders (because of their position in the Company and/or its Subsidiaries) either intentionally or unintentionally misuse their authority for their personal interests, causing conflicts between the interests of certain parties and economic interests of the Company & its Subsidiaries.

These conditions can affect the quality of decisions on mandated tasks and the outcome of these decisions can be detrimental to the Company and its Subsidiaries.

Examples of conflicts of interest:

  • Receiving gifts in the form of money or entertainment from vendors or suppliers.
  • Receiving financial or non-financial assistance from vendors or suppliers.
  • Person or a partner that has interests conflicting with business activities of the company.
  • Appointing certain parties as providers of goods/services due to underlying economic interests related to the designated party.

6. Bribery 

An action / activity of intentionally and consciously accepting goods or promises while knowing that they were given and taken with the intention of influencing the receiver to perform or not to perform particular actions, leading to a condition which is oppositional to his authority or obligations concerning the public interest. (Article 3 of Law No. 11 Year 1980 concerning Bribery).

In a broad sense, the definition of gift includes giving money, goods, rebates, commissions, loans without interest, travel tickets, lodging facilities, travel, free medical treatment, and other facilities. (Article 12B of Law No. 20 of 2001 concerning Amendments to Law number 31 of 1999 concerning Eradication of Corruption Crimes).

Examples of bribery / gratification:

  • Receiving rewards directly or indirectly in any form from any party related to a business transaction.
  • Receiving benefits in any form that affect upcoming judgment or business decisions.

7. Embezzlement

Actions/activities deliberately and consciously carried out against the law to own something that is wholly or partly owned by another person, who is currently in their position of power not because of crime. (KUHP Article 372). Examples of embezzlement:

  • Under wielded authority or because of other reasons, deliberately and unlawfully owning an object that is wholly or partly owned by the company.
  • Performing dishonest actions by hiding the company’s property / assets without the company’s knowledge in order to own, control, or use them for other purposes.

8. Deception

Activities / actions carried out intentionally and consciously with a purpose of benefiting oneself or others unlawfully through the use of false names, false dignity, deception, or a series of lies in order to influence others to give goods, impose debts, or grant write-offs. (KUHP Article 378).

Examples of fraudulent actions:

  • A party’s ruse which causes another party to sign a contract, given the condition that without the ruse taking place, the contract will not be signed.
  • Deliberately providing damaged products, resulting in financial losses.
  • Working independently or in collaboration with other parties to deceive a supervisor or the company by using fake signatures or fake invoices.

9. Extortion

Unlawfully benefitting one’s self or others by forcing a person with violence or threat of violence to give something wholly or partly belonging to that person or another, or to impose or write off any debt. (KUHP Article 368).

Examples of extortion:

  • Performing illegal levies in any form in carrying out their duties for the interest(s) of a particular person(s)/group(s)/party.
  • Requesting a sum of money or gifts to potential suppliers in lieu of a job.
  • Requesting a sum of money or gifts to customers in lieu of a special service.

(*) Member of IPC

Members of the board of directors, board of commissioners, committee members, permanent / non-permanent / outsourced employees of PT. Pelabuhan Indonesia II (Persero) and its Subsidiaries.