The whistleblowing system implementation in BCA aims:
• To raise stakeholders (employees, customers, etc.) awareness in reporting the fraud or violations activities that presumably being committed in BCA without any fear and anxious, as their confidentiality is guaranteed.
• To detect and prevent fraud or violations at the earliest stage possible through the information disclosed by a whistleblower.
1. Whistleblowing Procedure
A. MediaThe media that can be utilized by the whistleblower to convey the report is accessible through BCA website (https://www.bca.co.id/en/
whistleblowing). Correspondingly, the managing team of whistleblowing system will receive directly the report
B. Acceptable Reporting Criteria
For the convenience and acceleration of the follow up process, whistleblower must meet the following reporting criteria:
1) The reporting must be based on good faith and should not be a personal complaint or a fake story with bad intention.
2) The whistleblower’s identity should be provided with a minimum of information, which include:
• Whistleblower name (anonymous is permitted);
• Whistleblower phone number that can be reached/an active email address;
3) The preliminary indication of fraudulent act or violations that are reliable and accountable with an additional of attached data (if any) which incorporated the 4W1H, as follows:
• Action/Reported actions (What);
• Alleged Parties (Who);
• Time of events (When);
• Place/location of events (Where);
• Chronology of events (How).
4) Types of fraud/violations to be reported:
Fraud A deliberate misuse or omission to mislead, deceive or manipulate BCA, customer, or other party, that takes place in a BCA environment and/or uses BCA facilities, resulted in the bank, customer, or other party suffering a loss and/or the fraud perpetrator gain direct or indirect financial benefits.
Type of fraud acts:
1. cheating, 2. scams,
3. assets embezzlement, 4. information leakage, 5. banking crimes.
Code of Conduct Violation
Measures that are not in accordance with the BCA's culture that has been formulated based on positive values that grow and develop within the BCA's employees, to achieve common goals and as a reference for the BCA's employees in making decisions and taking measures.
Conflict of Interest Violation
The acts that cause a circumstance in which a person who, in performing his or her fiduciary duty and obligation, pursues outside interests, such as personal, family related or other parties interests, that may have impaired or intruded upon his or her professional judgment and objectivity in making decisions and policies according to the authority that has been awarded by BCA to him or her.
Laws Violation Any actions that violate applicable law in Indonesia.
2. Whistleblower Protection
BCA will provide the protection to the whistleblower, which include:
• Guarantees the confidentiality of the submitted whistleblower’s identity and the report contents;
• Guarantees the protection against mistreatments that might harm the whistleblower;
• Guarantees the protection against perpetrator’s threats, intimidations, punishments or any unpleasant activities.
3. Management of Whistleblowing System (WBS) Report Flow
The following is the flow on how a report is handled by BCA regarding to the whistleblowing system:
Managing Team of WBS:
• Receive and ensure the WBS report matches with the criteria
• Forward the report to the anti- fraud bureau
Anti-fraud Bureau:
• Verify and analyze the data
• Coordinate and follow up with the relevant work units
Work Units:
• Conduct the investigation or follow up
• Submit the investigation or follow up results to the decision-making officials (if proven as fraud)
• Inform the status to the anti-fraud bureau
4. Parties who Managed the Report
The management and follow-up on the reports are handled carefully with the BCA’s internal team who were appointed by the BCA’s management, in accordance to the prevailing BCA’s internal laws and laws and regulations in Indonesia.
5. Disclosure of Internal Fraud and Complaints through Whistleblowing System in 2020
A. Number of Complaints Reported through Whistleblowing SystemThe recapitulation of reports received through the whistleblowing system is submitted to the Board of Directors periodically. As of December 2020, there were 22 (twenty-two) complaints received through the WBS with the following status:
Status Number Description
Open (still in process) 4 - In the process of investigation (1)
- Forwarded to the relevant work units for further follow-up (1) - Waiting for data from the whistleblower (2)
Closed (settled) 18 Failed to fulfill the reporting criteria:
- Personal information/complaint from customers (14)
- Inadequacy of data and the whistleblower did not provide the additional data/information as requested (4)
B. Number of Internal Fraud Cases
BCA discloses internal fraud pursuant to article 64 of OJK Regulation No.55/ POJK.03/2016 on the Implementation of GCG for Commercial Banks and Section IX item 5 of OJK Circular Letter No.13/SEOJK.03/2017 in the Implementation of GCG for Commercial Banks.
Internal fraud is defined as fraud committed by management, supervisors, permanent and contract employees, or outsourced workers. Classified as fraud is a case where the financial loss or potential financial loss exceeds Rp100,000,000.- (one hundred million rupiah).
Table of Fraud Violation Committed by Management, Permanent Employees, and Non-Permanent Emloyees Internal Fraud in 1 Year Members of BoD and BoC Permanent Employees Contract and Outsourced
Employees
2019 2020 2019 2020 2019 2020
Total Fraud - - 7 9 - -
Settled - - 7 9 - -
In the internal settlement process - - - -
Settlement process that has not
been done - - - -
Through legal process - - - -
C. Sanctions and Follow-Up on Complaints through the Whistleblowing System
If the investigation results are proven that the perpetrator committed fraud or violations, consequently the decision- making officials will impose the sanctions in accordance to the prevailing regulations.