Governance

The whistleblowing system aims to create a comfortable work environment, by managing complaints or disclosing events that may result in financial and non-financial losses, including a deterioration of the Company’s image. Every employee of the Company and external parties can play a role and help prevent the occurrence of violations of the applicable laws and regulations and Indocement Code of Conduct. The Company through HeidelbergCement Group has published an update to these guidelines by creating a new system called “SpeakUp”, which can now be accessed through www.speakupfeedback.eu/web/heidelbergcement and/or a special telephone line for each country.

Through SpeakUp, the confidentiality of the reporting or whistleblower data is guaranteed and can be protected in line with the Company’s commitment to upholding ethics, morals, and law for any information on violations that occur. The Whistleblowing System is designed to ensure that any violations found in the Company’s environment, both external and internal, can be immediately followed up without disturbing the ongoing business stability, without affecting the Company’s image and reputation, while creating a climate of transparency of all available resources.

GUIDELINES OF WHISTLEBLOWING SYSTEM

In 2020, HeidelbergCement Group made changes to the whistleblowing system, which was originally named “MySafeWorkPlace” to “SpeakUp“, which has become effective since 1 January 2020. In principle, every type of violation of laws and regulations and Company policies or suspicion of violations can be reported, especially if it involves the following aspects:

1. Accounting/auditing related problems;
2. Alcohol and drugs;
3. Illegal or improper/fraudulent marketing or competition;
4. Forced labor on children/child abuse;
5. Conflict of interest;
6. Compliance or violation of regulations;
7. Corruption/fraud/bribery;
8. Cybercrime;
9. Data leak/privacy breach;
10. Discrimination;
11. Embezzlement;
12. Employee Relations;
13. Environmental/sustainability issues;
14. Fraud;
15. Harassment;
16. Health and safety;
17. Money laundering;
18. Theft;
19. Unlawful or unethical acts involving consumers or vendors;
20. Other compliance-related issues.

WHISTLEBLOWING MECHANISM

Incident reporting through “SpeakUp” can be done in two ways, which are:

1. 1. Via the internet, by accessing:
   www.speakupfeedback.eu/web/heidelbergcement
   This system uses the language tailored to the country of choice of the reporter and the report can be submitted in the message box available on the website page.
2. By telephone (Indonesia region only):
   The system works like a voice mailbox, using Indonesian, without an operator. This service is a toll-free service.
   The telephone numbers that can be contacted are:
   • Telkom operator: 007 803 440 559
   • Indosat operator: 001 803 440 559

PARTY MANAGING WHISTLEBLOWING SYSTEM

“SpeakUp” is managed by Company’s management in collaboration with HeidelbergCement Group.

PROTECTION FOR WHISTLEBLOWER

The Company appreciates every Employee and external parties who have contributed to the efforts to prevent, eradicate, or disclose acts of corruption in accordance with Company policy and ensure protection for whistleblowers by keeping their identities confidential. Protection is also given to Employees who conduct investigations and those who provide information related to such investigations.

TOTAL REPORT

Throughout 2022, there were four reports regarding allegation of operational incompliant incidents. All Reports have been resolved by referring to the applicable operational standards.