Overview

Whistleblower Policy

Whistleblower Policy

Kebijakan Pelaporan Pelanggaran (Whistleblowing)

PT Divistant Teknologi Indonesia (trading as "Divistant")


Last Updated: February 24, 2026


1. Introduction / Pendahuluan


PT Divistant Teknologi Indonesia ("Divistant") is committed to maintaining the highest standards of integrity, transparency, and accountability. We encourage all individuals — employees, clients, partners, vendors, and members of the public — to report any suspected misconduct, fraud, unethical behavior, or violations of law without fear of retaliation.


Kebijakan ini menetapkan mekanisme pelaporan yang aman dan terlindungi bagi siapa pun yang ingin melaporkan dugaan pelanggaran di lingkungan Divistant.


2. Scope / Ruang Lingkup


This policy applies to reports concerning:

  1. Fraud, embezzlement, or financial irregularities
  2. Bribery, corruption, or gratification (see our Anti-Bribery Policy)
  3. Violations of laws, regulations, or company policies
  4. Data breaches or misuse of personal data
  5. Harassment, discrimination, or workplace safety violations
  6. Conflicts of interest
  7. Misuse of company assets or resources
  8. Any other conduct that is illegal, unethical, or contrary to our Code of Ethics


This policy covers reports made by employees, contractors, clients, vendors, partners, and any other external parties.


3. Reporting Channels / Saluran Pelaporan


Reports can be submitted through the following channels:


a. Online Whistleblowing Form (Recommended)

Our secure, dedicated whistleblowing form is available at:

  1. divistant.com/whistleblowing

This form allows you to submit reports with or without identifying yourself.


b. Direct Contact

  1. Contact us at divistant.com/contacts with the subject "Whistleblowing Report"


c. Internal Reporting (for Employees)

  1. Direct supervisor or manager (unless they are the subject of the report)
  2. People & Culture (HR) department
  3. Senior management or leadership team


4. What to Include in a Report


To help us investigate effectively, please provide as much detail as possible:

  1. Description of the suspected violation or misconduct
  2. Names and roles of the individuals involved (if known)
  3. Dates, times, and locations of the events
  4. Any supporting evidence or documentation
  5. Whether the issue has been reported previously and to whom


5. Anonymous Reporting / Pelaporan Anonim


Divistant accepts and investigates anonymous reports. While providing your identity helps us investigate more effectively and keep you informed of progress, we understand that some situations may require anonymity. Anonymous reports can be submitted through our online whistleblowing form.


6. Confidentiality / Kerahasiaan


We treat all whistleblowing reports with the strictest confidentiality:

  1. The identity of the reporter is kept confidential to the maximum extent possible
  2. Information is shared only on a need-to-know basis with those directly involved in the investigation
  3. All investigation records are stored securely with restricted access
  4. Disclosure of the reporter's identity without their consent is prohibited, except where required by law


7. Anti-Retaliation Protection / Perlindungan dari Pembalasan


Divistant strictly prohibits retaliation against any individual who reports concerns in good faith. Retaliation includes but is not limited to:

  1. Termination, demotion, or suspension
  2. Harassment, intimidation, or threats
  3. Discrimination in work assignments, evaluations, or promotions
  4. Reduction in pay or benefits
  5. Any other adverse action taken because of the report


Any person who retaliates against a whistleblower will be subject to disciplinary action, up to and including termination. If you believe you have experienced retaliation, report it immediately through any of the reporting channels listed above.


8. Investigation Process / Proses Investigasi


All reports are handled through the following process:


  1. Receipt & Acknowledgment: Reports are acknowledged within 3 business days (where the reporter's identity is known).
  2. Initial Assessment: An initial review is conducted to determine the credibility and severity of the report and to assign the appropriate investigation team.
  3. Investigation: A thorough, impartial investigation is conducted by qualified personnel who are independent from the subject of the report.
  4. Findings & Recommendations: Investigation findings are documented and recommendations for corrective action are made to the appropriate decision-makers.
  5. Resolution & Follow-up: Appropriate corrective or disciplinary action is taken. The reporter is informed of the outcome, where possible and appropriate.
  6. Documentation: All investigation records are maintained securely for a minimum of 5 years.


9. Good Faith Reporting


This policy protects individuals who make reports in good faith — meaning the reporter genuinely believes the information provided is true at the time of reporting. Reports made maliciously, with knowingly false information, or for personal gain are not protected under this policy and may result in disciplinary action.


10. External Reporting


While we encourage internal reporting first, we acknowledge that in some cases external reporting may be necessary or preferred. You may also report concerns to relevant authorities, including:

  1. Komisi Pemberantasan Korupsi (KPK) for corruption-related matters
  2. Relevant supervisory authorities for data protection violations
  3. Law enforcement authorities for criminal matters


11. Changes to This Policy


We may update this Whistleblower Policy from time to time. Changes will be posted on our website with an updated "Last Updated" date.


12. Contact Information


For questions about this policy or to submit a report:

  1. Whistleblowing Form: divistant.com/whistleblowing
  2. General Contact: divistant.com/contacts
  3. Company: PT Divistant Teknologi Indonesia, Jakarta, Indonesia