1.      Background

Daemeter is committed to ensuring the highest standards of conduct in the delivery of our services while maintaining compliance with all applicable policies, laws, rules and regulations. To ensure that we are all held to account the whistleblowing contact channel below facilitates the reporting of possible illegal, unethical, or improper conduct when the normal channels of communication have proven ineffective or difficult.

The whistleblowing and complaints channel is available to be used by all of our employees, as well as clients, subcontractors, partners and other stakeholders that are in a business relationship with Daemeter.

Please use this channel to report corruption, fraud, discrimination, human trafficking, slavery, safeguarding children, terrorism funding, and other violations potentially related to Daemeter, our people, and our activities.

Complaints and other general grievances can also be raised through this same channel. The policy outlined here ensures that complaints are dealt with effectively, respectful of confidentiality, and with a mechanism that ensures effective feedback and proper closure.

 

2.      Whistleblowing

Employees, consultants, contractors, suppliers, and associated person(s) involved in Daemeter business should immediately report any suspicions or allegations of corruption, fraud, human trafficking, slavery, safeguarding children and young people concerns, terrorism funding, and other violations to either of the following email addresses:

grievance@daemeter.org or pengaduan@daemeter.org (in English or Indonesian language).

Where confidentiality is required, in the first instance please use an anonymous email address until an appropriate Daemeter counterpart for further dialogue can be assigned.

This whistleblowing policy and contact channel is communicated to stakeholders through mechanisms described in Section 4.0 below.

 

3.      Other Complaints

All stakeholders (including employees, subcontractors and clients) with a compliant or grievance should, in the first instance, seek to resolve by raising the complaint informally with the person concerned. They will often be able to put things right quickly.

If the stakeholder is not satisfied with the outcome of the initial investigation into the complaint and the matter has not been resolved, then stakeholders should make a formal complaint by sending to either of the following email addresses:

grievance@daemeter.org or pengaduan@daemeter.org (in English or Indonesian language).

Complaints can also be sent by mail to:

PT Daemeter Consulting (attn: Pengaduan), Jalan Tangkuban Perahu No 1, Taman Kencana, Bogor 16128 Indonesia

All complaints received will be entered into a grievance register and reviewed at Senior Management level, raised to Director level where appropriate. Daemeter commits that:

• All complaints will be investigated thoroughly
• All complaints will follow an agreed procedure
• All complaints will receive a full response within the shortest possible time
• All complaints will be recorded, monitored and used to inform and enhance future practice.

After entering the complaint in the grievance register, Daemeter will:

• Respond in writing within three working days acknowledging receipt of the complaint
• Investigate the complaint and send a written response within fourteen working days of receiving the complaint.

There may be occasions when there is a delay in response times due to the length or type of investigation. If this is the case, Daemeter will let the stakeholder know. Daemeter will inform if it is decided not to respond to the complaint, which may occur if:

• The complaint does not relate directly to something that Daemeter has done or it relates to something that Daemeter cannot comment on
• Someone pursues a complaint that has already been investigated in line with Daemeter’s complaints procedure. In this case we may choose not to reply again.
• A complainant is being abusive, prejudiced or offensive
• A complaint is incoherent or illegible.

If after receiving our response the stakeholder feel that the complaint has not been adequately addressed, the stakeholder can be directed to send it to one of Daemeter’s Directors, where the same procedure and timings as above will be followed.

 

4.      Dissemination of Whistleblowing and Complaints Policy

Employees

This whistleblowing and complaints email address and the mechanism for whistleblowing is communicated to Daemeter staff by way of incorporation in Code of Conduct which is signed by all employees. It is also posted on the Daemeter intranet and regularly communicated to employees. The onboarding procedure for all new employees involves a familiarisation session that covers the policy.

Subcontractors/Consultants

The Whistleblowing and complaints procedure and contact details is communicated to consultants via their subcontract agreements, which includes signed declarations of understanding and acknowledgement to the procedure. For long-term consultants, further familiarisation is provided annually.

Other commercial and non-commercial stakeholders

The Whistleblowing, complaints procedure and contact details are published on the company website.

 

5.      Confidentiality

All information provided in the process of reporting complaints, including suspected fraud, will be treated confidentially. However, if criminal activity is to be reported to the police, the identity of the person reporting may eventually have to be disclosed to enable external investigators or police to pursue investigations effectively. Investigation results will not be disclosed or discussed with anyone other than those who have a legitimate right or need to know.

The official version of this policy can be provided on request.