IIF is committed to becoming a leading catalyst for financing infrastructure development in Indonesia. Therefore, as part of that commitment, IIF must build a healthy, open, conducive, honest and transparent business environment.

We establish a system of reporting suspicious activities via Whistleblowing System (WBS). WBS provides the opportunity and media for IIF’s employees and/or third parties to report attempts on corruption, fraudulent practices, collusive practices, and coercive practices perpetrated by IIF’s employees and/or third parties.

If one or more of the suspected activities mentioned above occur, a Disclosure Report shall be filed and reported preferably in writing to ensure clear description and understanding on the issue raised, and should either be typed or written in a legible handwriting in English or Bahasa.

The suspected activity should be reported in the form of cover letter which shall contain the identity of the person reporting [hereinafter Whistleblower].  Anonymous Whistleblower or the disclosures are permitted if it is completed with adequate supporting evidence, information, and strong indication that fraud/corruption has occurred, which could lead to further investigation .

Disclosures should be factual, not speculative with no malicious intention and should contain as much detailed information as possible to ensure proper assessment, to address the concerns and to undertake the investigative procedure.

To submit a Disclosure Report, one can use the Disclosure Reporting Form that is provided on IIF’s website.

1. IIF follows a policy of non-retaliation towards whistleblowers reporting fraud and corruption. IIF is committed to supporting and protecting whistleblowers who report breaches or alleged breaches of the Code of Conduct from victimization and discrimination. IIF is also committed to protecting the career of employees who report suspected fraud, provided they are not involved in the fraudulent or corrupt activity.
2. IIF provides protection to the whistleblowers who make disclosures in accordance with the policy. IIF also provides protection by imposing penalties on a person who takes retaliation against a whistleblower. Penalties against persons proven to have taken retaliatory action against a complainant include fines and imprisonment.

1. Email: [email protected]
2. Telephone: (+62) 21 5082 6600 ext 5076 (Internal Audit)
3. Letter: Prosperity Tower 55th floor, District 8,. Sudirman Central Business District Lot. 28, Jl. Jend. Sudirman Kav. 52-53, Jakarta 12190, Attn: Internal Audit

Allow us to express our utmost gratitude for your trust and attention.

Whistleblowing Report Handling Mechanism

Internal Audit will administer and record the information gathering of disclosures and conduct preliminary verification against the completeness of the disclosures before further process. The status of the disclosures must be tracked and updated in line with the disclosure settlement stages.

Internal Audit will conduct preliminary fact-finding to justify whether the whistleblowing process will be continued with an immediate escalation process to the Fraud and Corruption Prevention Committee to propose action plans.

After conducting fact-finding, Internal Audit to further report the disclosures to the Fraud and Corruption Prevention Committee, in the case BOD is not a suspect of the fraudulent practices. The report and proposed action plans would subsequently be discussed and concluded within the Fraud and Corruption Prevention Committee meeting. The Fraud and Corruption Prevention Committee will decide the actions to be taken, such as:

·          Dismissed the disclosure, if it fails to satisfy the requirements;

·          Assignment of Internal Audit to establish Investigation Team;

·          Assignment of external investigators or external auditors skilled in investigation, if required;

·          Cooperation with Indonesian Police;

·          Additional internal controls should be implemented by IIF.

In case that the BOD is a suspect of the fraudulent practices, Internal Audit will directly report and propose action plans to the disclosure to Audit Committee. In the case that BOC is a suspect of fraudulent practices, Internal Audit shall escalate the disclosure to the Audit Committee and propose action plans, such as the following:

·          If the suspect is the member of Audit Committee, the suspect should be excluded from Audit Committee meeting discussing such matter.

·          To further escalate the disclosure through shareholders whistleblowing channels, if the suspect is representing shareholders.

·          To propose the assignment of an independent external party to do further investigation and notify shareholders of any confirmed wrongdoing, corruption, fraud, or law/rule/policy violation.

Investigation team can only be assigned by the Fraud and Corruption Prevention Committee or Audit Committee and may include Corporate Legal, Operational Risk, Human Resources, and other Division Head as subject matter expert or external party, such as professional investigator or government official or Indonesian National Police. External party involved in the investigation should sign Non-Disclosure Agreement with IIF. Investigation team led by Internal Audit to conduct investigation and maintain confidentiality in regard to all aspect of the disclosure and investigation process.

Result of investigation shall be reported to Fraud and Corruption Prevention Committee and Audit Committee, in the case BOD is not a suspect of the fraudulent practices, or Audit Committee, in the case BOD is a suspect of the fraudulent practices. Internal Audit will coordinate with Operational Risk for updating the case in Quarterly Risk Management Report. Internal Audit shall monitor the progress of the implementation of action plans and report it to Fraud and Corruption Prevention Committee and/or Audit Committee semi-annually.

Guarantee of Confidentiality and Protection of the Whistleblower