Implementation of Whistleblowing System in Indonesia

Gabriella Widya and Desi Adhariani

Department of Accounting, Faculty of Economics and Business, Universitas Indonesia

Keywords: whistleblowing system, Indonesia

Abstract: Fraud in business context has alerted several parties to develop channels to overcome the problem, one of

which is through the whistleblowing system. This study is aimed at analyzing the whistleblowing system in

Indonesia and the best practices of the system in several Indonesian companies. The analysis showed that the

WBS implementation has been strengthen by several regulations; however, the practices should be backed up

by some steps to increase the effectiveness.

1 INTRODUCTION

Fraud is still a major concern in businesses in

Indonesia (Siregar and Tenoyo, 2015). According to

PricewaterhouseCoopers research in the Global

Economic and Fraud Survey in 2018, 49% of

companies in the world have experienced economic

crimes in the past two years. Furthermore, PwC's

findings mention that 52% of fraud was committed by

internal players and 24% was carried out by senior

management (senior management), an increase of 8%

from previous research. To overcome this fraud, the

company has also implemented several systems, such

as internal control systems and internal audits

(Siregar and Tenoyo, 2015). The company also has a

place to report, which is also called the Violation

Reporting System (SPP), if you know things related

to fraud, fraud and corruption.

The Violation Reporting System (SPP) or also

known as a whistleblowing system (WBS) is one way

to support the increase in the effectiveness of the

implementation of good corporate governance. In

order to improve the quality of corporate governance

in Indonesia, the National Committee on Governance

Policy (KNKG) has also issued SPP Guidelines or

WBS in 2008.

Although in the guidelines it has been explicitly

stated that companies must guarantee protection for

reporters, there are still many people (employees)

who are hesitant to become whistleblowers. The

reason is because the risk of being a whistleblower is

too high. There are various risks borne by the

whistleblower, ranging from being disfellowshipped

or excluded from the organization, being transferred

to other units (which are usually far from residence),

demotion, complicated promotion or career paths,

being fired, discrimination, and even physical assault.

The risk of criminalization also haunts the

whistleblower, especially those who complain about

the company's actions to the government. For

example, Vincentius Amin Sutanto, a whistleblower

in the tax evasion case of PT Asian Agri, who was

sentenced to 11 years in prison or Martono, a

whistleblower for subsidized solar embezzlement

cases of PT Gandasari Tetra Mandiri who was

sentenced to 2 years in prison. On the other hand, an

example in the government that is quite controversial

is the drama "Papa Request Stock" which had

shocked the public and ended the reporting of the

former Chairperson of the House of Representatives,

Setya Novanto to the National Police Bareskrim to

complain about the Minister of Energy and Mineral

Resources, Sudirman Said, accused of defamation,

defamation good, humiliation, and ITE violations.

From these reasons, the authors want to know how

the WBS is implemented in Indonesia, the

weaknesses of the WBS implementation, and how the

WBS best practices should be done. The author will

also give suggestions regarding these weaknesses.

Based on the background above, this paper aims to:

1. Analyzing the application of the WBS in

Indonesia, including the weaknesses.

2. Presenting the WBS best practices of several

Indonesian companies.

Widya, G. and Adhariani, D.

Implementation of Whistleblowing System in Indonesia.

DOI: 10.5220/0009399400400048

In Proceedings of the 1st International Conference on Anti-Corruption and Integrity (ICOACI 2019), pages 40-48

ISBN: 978-989-758-461-9

2 THEORETICAL BASIS

2.1 Definition of Whistleblowing

According to KNKG, the SPP guidelines state that

"whistleblowing" is the disclosure of violations or

disclosure of acts that are against the law, unethical /

immoral actions or other actions that can harm the

organization or stakeholders, which are carried out by

employees or leaders of the organization to leaders of

other organizations or institutions that can take action

on these violations. This disclosure is generally

carried out confidentially. Disclosure must be done in

good faith and is not a personal complaint on a

particular company policy (grievance) or based on

bad will / slander. According to Moeller (2009)

Whistleblowing is a facility that is given to

employees or stakeholders to report violations

independently or without identity to companies or

regulators without fear of retaliation.

Whistleblowing consists of two types, namely

internal and external (Neti, 2012). Internal

Whistleblowing is when someone reports a violation

that occurs within his organization to the authorities

within his organization. Whereas, external

Whistleblowing is conducting open reporting, or

reporting outside the organization. Whistleblowing

can be done by identity, or without identity.

2.2 Whistleblower or Whistleblower

According to KNKG, whistleblowers are employees

of the organization itself (internal parties), but there

are no reports from external parties (customers,

suppliers, communities). The reporter should provide

evidence, information, or a clear indication of the

occurrence of reported violations so that they can be

traced or acted upon. Without adequate information

the report will be difficult to be followed.

3 DISCUSSION

3.1 Application of the Violation

Reporting System (SPP) or

Whistleblowing System (WBS) in

Indonesia

3.1.1 Corporate Perspective

In order to improve the implementation of good

corporate governance, KNKG issued a Guidelines for

the Violation Reporting System in 2008. This

guideline refers to a number of legislations governing

the reporting of legislation and protection for

whistleblowers. Some of these laws include:

a. UU no. 28 of 1999 concerning the Organization of

a Clean and Free of Corruption, Collusion and

Nepotism in Article 9.

b. UU no. 31 of 1999 concerning Eradication of

Corruption Crime article 31.

In the Act, it is emphasized on the safety of the

reporter. But in this law, protection for

whistleblowers is only given for reporting

corruption, and does not apply to reporting other

crimes.

c. UU Np. 25 of 2003 concerning Article 39 to 44

Money Laundering d. UU no. 13 of 2006

concerning Protection of Witnesses and Victims

article 10 paragraph 1 e. UU no. 13 of 2003

concerning Manpower.

In this law it is stated that employers are

prohibited from terminating employment on the

grounds that workers complain about employers to

the authorities. Therefore, workers are actually

protected by law from the risk of termination of

employment (Watugigir, 2011).

This KNKG guideline was later adopted by

almost all corporations in Indonesia, especially large

corporations in Indonesia. At present, many

companies have included whistleblowing policies

both in their annual reports and through their

websites. From the company's steps to include this

information, the community can judge that in fact

these companies already have a concern and intention

to implement the WBS to improve the company's

good corporate governance.

Examples of companies whose whistleblowing

systems are explained in great detail in their annual

reports are:

a. Unilever

Unilever only limits the whistleblower to internal

parties. In the report, it is stated that all Unilever

employees and business partners can make

complaints if they find actions that are not in

accordance with the company's code of ethics. All

complaints will be managed by the Business Integrity

Officer and the Business Integrity Committee, also

known as Blue Umbrella. Some of the channels

employees can use to complain are through the line

manager, Unilever's website, hotline, Blue Umbrella

email, and Business Integrity Officer. During 2017,

there were 23 cases reported by whistleblowers.

Cases investigated as big as 20 cases and 18 cases

resolved.

Implementation of Whistleblowing System in Indonesia

Figure 3.1 WBS at Unilever

Source: Annual Report Unilever 2017

b. PT Pupuk Indonesia

Unlike Unilever, PT Pupuk Indonesia receives reports

from external parties as well as internal companies.

However, the Indonesian Fertilizer WBS channel is

still limited, namely via telephone, text messages, and

e-mail. All incoming reports will be handled by the

Violation Reporting Team (TPP). Reports made by

TPP will be accessed by directors and board of

commissioners. In 2017, there are 2 complaints

reports. However, both of them do not meet the report

criteria, so they cannot be processed further.

Figure 3.2 WBS at PT Pupuk Indonesia

Source: PT Pupuk Indonesia website

3.1.2 The Perspective of Government

Agencies

In the KNKG guideline regarding Good Public

Governance in 2006, it was stated that in achieving

the ideal conditions of Good Public Governance,

government institutions need to pay attention to five

things, namely democracy, transparency,

accountability, legal culture, and fairness and

equality. The Whistleblowing system can be one

method of government institutions to achieve good

public governance, especially in aspects of

transparency and accountability. The implementation

of a whistleblowing system is seen seriously by

government institutions. Some government agencies

that have used the whistleblowing system include:

a. Ministry of Finance

The Ministry of Finance is one of the originators of

the whistleblowing system in government institutions

(Ardityasari, 2016). This system is called WISE

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which can be accessed at http://wise.depkeu.go.id/.

The Director General of Taxes and the Directorate

General of Customs and Excise as part of the Ministry

of Finance also has its own whistleblowing system

but remains integrated with WISE to increase

employee participation and realize clean institutions

and ultimately support the achievement of maximum

state revenues.

WISE implementation began with the issuance of

Minister of Finance Decree Number 149 / KMK.09 /

2011 concerning Procedures for Reporting and

Publicizing the Implementation of Management of

Violations in the Ministry of Finance on May 10,

2011. All complaints were managed by Echelon II

units called Inspectorate Investigations, located under

the Inspectorate General of the Ministry of Finance.

During the year 2014, there were 476 complaints that

were followed up. The complaint consisted of 154

complaints of fraud and 322 complaints of non-fraud.

Out of 154 complaints of fraud, 70 complaints

including the alleged gratification. Whereas, out of

322 non-fraud complaints, 96 complaints included

service to internal and external parties. In addition,

there were 102 complaints regarding other alleged

irregularities. Examples of other irregularities are

complaints about officials outside the Ministry of

Finance, complaints about questions related to

policies, or complaints related to the recruitment

process.

Figure 3.3 WBS at Ministry of Finance

Source: WISE website, Ministry of Finance

b. KPK

The KPK's whistleblowing system is called the KPK

Whistleblower's System (KWS) which can be

accessed on the website https://kws.kpk.go.id/. The

difference between KWS and WISE is that KWS

focuses on the whistleblower, so a lot of data must be

filled. On the other hand, WISE focuses on

complaints.

Reports received by the KPK will be processed

with an internal mechanism for approximately 30

days. Within a year, complaints to the KPK could

reach 6000 complaints. All complaints are well

researched, but only half of them are worthy of

further investigation.

After the complaint was received, the KPK

considered three criteria for following up the report.

The three considerations are who the culprit is, how

much the state will lose, and what the impact will be

on the public when the case is revealed. If the report

does not meet the criteria, the report can be returned

back to the reporter (in accordance with KPK policy)

or forwarded to other agencies if the report is not in

the KPK domain. Usually, small corruption cases will

be forwarded to other institutions because the KPK is

more designed to uncover scale corruption grand

corruption.

Implementation of Whistleblowing System in Indonesia

Figure 3.4 WBS at KPK

Source: KPK Website

c. Bank Indonesia

Bank Indonesia also has a whistleblowing system

called the WBS-BI. The WBS-BI can be accessed at

https://www.bi.go.id/wbsbi/. The WBS-BI is

designed to accommodate public complaints about

alleged violations by internal parties of Bank

Indonesia. Alleged violations include bribery,

gratification, violations of the code of ethics, fraud,

corruption, and others. Until now, there have been

119 complaints, where 59.66% not followed by

inspection, 29.37% is being validated, 6.72% is in the

process of being audited, and 9.24% has been

examined.

Figure 3.5 WBS at Bank Indonesia

Source: Bank Indonesia Website

In addition to the three institutions above, in 2017,

the Witness and Victim Protection Agency (LPSK)

launched the Whistleblowing Online System

application under the name TEGAS (Integrated Inter-

System). This application is connected with 17

ministries and institutions in Indonesia, including

POLRI, the Attorney General's Office, and the BPK.

With the presence of this application, it is hoped that

the public will find it easier to complain when they

find corruption. In addition, in 2018, LPSK also

launched the 148 hotlines to help people who want to

apply for protection as witnesses or victims.

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3.2 Weakness of the Whistleblowing

System in Indonesia

3.2.1 Employee Perception (Reporter)

Both company employees and civil servants in

government agencies have a moral dilemma to

become a whistleblower. The employee who decides

to do a whistleblowing will be accused of being a

traitor who divulges secrets, but can also be said as a

hero (Sudimin, 2003). The agency where he works

can see his actions as a sign of not thanking the

agency that helped him and violated his loyalty. But

on the other hand, his responsibility to the wider

community also arose because he hid corporate

crime. The dilemma experienced by employees is one

of the causes of the whistleblowing system not

running smoothly.

In addition, even though there is already employee

protection or witness protection that has even been

included in organizational policy, employees are still

reluctant to become a whistleblower for fear of facing

many risks. The first risk that might arise is the

disclosure of the whistleblower's identity. The second

risk, and perhaps the hardest, is termination of

employment. Or, even though the employment

relationship is not broken, the relationship with the

boss and coworkers becomes tenuous and the

unpleasant situation in the workplace is unavoidable.

Another risk is the risk of criminalization, where the

employee can be prosecuted with defamation articles

or unpleasant acts. This risk can deliver the employee

to jail for a short time.

3.2.2 Legal System

The weakness of the WBS in Indonesia is also

influenced by the legal system in Indonesia. Until

now, there is no law that clearly regulates the

whistleblowing system. Whistleblowing, especially

those intended for government institutions, must be

reported to the appropriate agencies. There is no

special forum integrated between one institution and

another. Thus, the protection provided for a

whistleblower will be carried out by the institution

that receives the report.

3.2.3 Corporate Perspective

Overall, the weakness of the WBS system in the

company is located on the company's WBS channel.

Many companies rely solely on e-mail or text

messages that are not even heeded by the related

team. According to the EY survey titled the Asia

Pacific Fraud Survey 2017, only 37% of employees

were confident that their reports would be followed

up by the company's whistleblower team.

Still from the results of the EY survey, as many as

39% of employees were more comfortable using

external complaints channels, such as government

hotlines for reasons of security and anonymity.

Furthermore, as many as 1 in 4 employees stated that

they were aware of fraudulent acts within the

company, but they chose to remain silent because

they did not believe that the company would defend

them if they complained about these matters. From

the survey results it can be concluded that employee

mistrust of the company is the main cause of the

company's weak whistleblower system, especially in

security guarantees. In addition, the weakness of the

company's whistleblower system, especially those

managed internally, is the risk of the person being

reported as the person receiving the report. So,

employees are more interested in blowing the whistle

directly to the public or the government.

3.2.4 Perspective of Government Agencies

From the results of interviews conducted with the

employees of the Directorate General of Taxes in the

study of Ardityasari (2016), the WISE (Ministry of

Finance's whistleblowing system) seemed to divide

the team in the work environment. In addition, there

is a need for a clear system when receiving

complaints. One employee of the Directorate General

of Fiscal Balance stated that his co-workers had never

been questioned based on complaints from WISE.

Even though the complaint turned out to be only an

anonymous letter and a fictitious complaint. So,

according to him, there needs to be a punishment for

such persons, and an increase in the whistleblowing

system selection system itself.

In addition, the applications used in several

government institutions are still internal, and not

known at all by the community. In fact, the

community also has the right to complain if they find

irregularities or indications of fraud from these

government institutions.

Other weaknesses found i is the system overlap.

For example, within the Ministry of Finance, the

Directorate General of Taxes has its own

whistleblowing system called the Tax Complaints

Information System (SIPP) and so does the

Directorate General of Customs and Excise with the

Public Complaints Application System (SIPUMA).

The overlapping of this system implies inefficiency,

because the two directorates are still in the same

ministry.

Implementation of Whistleblowing System in Indonesia

3.3 Best Practice Whistleblowing

System

In general, there are 15 important things that need to

be in the whistleblowing system (Pamungkas, 2014),

namely:

1. Compliance Commitment

WBS must be based on the commitment to

establish a culture of compliance and ethical

behavior in the organization. This is the

responsibility of the employee, especially the

employee leader.

2. Written rules regarding WBS

WBS must be formally regulated at work. The

regulation must be a written regulation with a

complete explanation of how the WBS works,

what channels can be used to make complaints,

who can report, what data is needed to report, and

what actions can be used as the basis for reporting.

3. WBS Management Unit

In every organization, both government and

corporation, there needs to be a unit that is

responsible for this reporting. Furthermore, this

unit must follow up on all complaints, according

to predetermined criteria. The management unit

can be insourcing, or originating from within the

company, or outsourcing, which is using third

party services as a WBS manager. What needs to

be emphasized is that this management unit can

truly act independently in handling each report.

4. Parties who can become reporters

There needs to be clear rules about who can

become a reporter. As some of the examples

above, KPK and Fertilizer Indonesia stipulate that

reporters may come from internal or external

companies. Meanwhile, Unilever considers that

reporters must come from within the organization

and business partners.

5. Obligations of Employees to Report Fraud and

other Violations

The principle of loyalty that must be invested is to

be loyal to the company's overall mission, not to

superiors or colleagues. Thus, employees are

asked not to close their eyes if they see actions that

indicate fraud.

6. Definition of violations that can be reported

Reportable violations must also be clearly defined

in company regulations. Some companies

stipulate that what is meant by violation is if the

employee commits a violation of the company's

code of ethics. However, there are also those who

say that violations are when they violate certain

laws or policies. The definition of violation is

defined by each organization according to their

respective needs.

7. Submission of Clear Violation Reports

This aspect is related to what documents must be

prepared to make a complaint.

8. Availability of Report Submission Channels

The organization must determine the type of

communication channel that can be used to

receive reports. The channel must facilitate the

reporting party, not make it difficult. Some

communication channels that are often used today

are through electronic mail, telephone, text

messages, and applications. Some companies

have also implemented a hotline service.

Multinational companies like Unilever even

provide translators in their hotline service so that

reporters can be more comfortable using the

language they want, both Indonesian and English.

9. Confidentiality of Reporting Identity

This aspect is the most important aspect. The

organization must really guarantee that the

identity of the reporter will not leak everywhere,

so it will not threaten the safety of the reporter,

both the safety of the reporter himself and his

family. The organization must also focus on the

problem, not who reported it.

10. Alternative Submission of Anonymous Reports

There needs to be a special method or method if

the reporter chooses to keep his identity

confidential, or report without identity. This

identity-less submission must also be provided by

the organization.

11. Protection of reporters

Reporting protection is also an important thing

that must be guaranteed by the organization.

Without this protection, the reporter will hesitate

and tend to hide facts he knows.

12. Reward and Punishment

Organizations can give certain awards to parties

who with the courage to dismantle fraud,

corruption, or other violations in the institution.

On the other hand, the organization must process

people who deliberately provide fictitious reports

to give them a deterrent effect.

13. Notification of results of follow-up on reports

To convince the reporter that the report is being

followed up, the WBS management unit can

notify the reporter of the results of the follow-up

or the results of the investigation. If necessary,

the organization can also state the maximum

follow-up time in the WBS guidelines. For

example, the KPK included in their WBS

guidelines that reports received would be

processed for a maximum of 30 days.

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14. Understanding of the existence of WBS

Because WBS is crucial for organizations,

organizations need to provide special training for

employees regarding the WBS system, especially

how the system processes and how to report. The

WBS also needs to be communicated to the wider

community, especially to government

organizations, and large companies that do allow

external parties to provide complaints of

violations to the company.

15. Recording and reporting of WBS results to

Management

Every violation report must be recorded,

followed by each development, and reported to

the leadership to describe the magnitude of the

reported problem. This report also aims to

improve the weaknesses of organizational

management.

Modeling on WBS applied by developed

countries, the concept of whistleblowing is strictly

regulated in their positive law. The United States, for

example, already has a special law called the

Whistleblower Protection Act (WPA) in 1989.

Furthermore, the United States also has a special

agency to handle whistleblowing reports called

Office of the Special Counsel (OSC). Protection for

whistleblowers is also highly guaranteed, especially

from retaliation that may be carried out by the

reported party.

4 CONCLUSION

The rampant cases of fraud committed by companies

and corruption in government institutions

increasingly encourage the role of whistleblowing

systems as an effective disclosure step. In Indonesia,

there is still no concept of whistleblowing which is

poured into a special legal product. However, the

guidelines regarding whistleblowing have been

regulated by KNKG through the Violation Reporting

System (SPP) in 2008.

The implementation of a whistleblowing system

in Indonesia, especially in the field of corporations,

can be said to have increased, because many

companies have carried out this system in their

companies and reported it through annual reports.

Even so, there are no reports and research on the

effectiveness of the whistleblowing system in

corporations. In government, a whistleblowing

system can be said to have developed. The weakness

of the WBS regarding the absence of integration

between government institutions has been overcome

by the TEGAS application, which is an integration of

17 government institutions and LPSK. However,

problems regarding overlapping WBS still need to be

resolved. In addition, penalties for perpetrators of

fictional reports also need to be developed.

In terms of developing a whistleblowing system

in the future, organizations need to pay attention to 15

aspects of best practice whistleblowing. The

Indonesian government itself can also benchmark to

developed countries, especially the United States, in

terms of handling whistleblower reports.

4.1 Suggestions

Regarding the application of whistleblowing in

Indonesia, several steps that need to be done are:

1. Dissemination of the whistleblowing channel to the

general public, especially for government

organizations and companies that allow external

parties to participate in reporting.

2. Increasing the guarantee of reporter protection,

especially regarding the safety of the reporter and

the risk of criminalization.

3. Increase employee trust, by making strong

commitments (and implementing them) related to

issues of confidentiality and commitment to

follow up on all reports that enter the organization.

4. Continuous training to change employee mindset

and perception.

Employees must be directed to be loyal to the

company's vision and mission holistically, not

loyal to the company's physical like boss or

coworkers. Organizations must also understand

that this system is not intended to divide teams,

but to minimize fraud.

5. Benchmarking. Benchmarking can be done by

companies to similar companies, or those in the

same industry. The government can also

benchmark the governments of other countries to

see the implementation of the WBS in their

country.

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