Make a Change, Speak Up!

Whistleblower Program

Make a Change, Speak Up!

Asia Pulp & Paper (APP) Sinar Mas does not tolerate fraud. any violation within company that can affect the company's reputation and business sustainability. 

We encourage everyone to help us to fight fraud and report it to us when you see or experience fraudulent activities In APP. 


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APP Sinar Mas would like to promote a reputation for high performance and quality in order to strengthen the trust placed in the company by stakeholders (i.e. employees, customers, business partners, vendors/suppliers and community). 

In order to maintain the integrity of APP Sinar Mas and avert possible damaging situations, APP Sinar Mas focuses on identifying violations. Stakeholders who are aware of compliance risks are encouraged to report the situation to an appropriate contact within the company, such as a supervisor, the Human Resources Department or the Ethics & Compliance Department. 

In addition, APP Sinar Mas offers its stakeholders a secure whistleblower portal for providing information on possible compliance violations. This whistleblower portal allows safe and confidential sharing of such information at any time and from anywhere. 

Everyone is welcome to submit their concerns/reports in good faith. To raise it, please pay attention to the following requirement: 


i. Content of the Disclosure

You should include as many of the following details as you have in your disclosure: 

  • the nature of the conduct that concerns you; 
  • the details of the person you think engaged or is engaging in any relevant conduct/behavior; 
  • when and where the conduct occurred (i.e., dates and times); 
  • details of anyone else aware of or involved in the conduct; 
  • details of anyone else who might be able to verify your disclosure; 
  • whether you have done anything in response to the conduct/behavior; 
  • whether you have any concerns about possibly being victimized, and if so by whom; and 
  • any supporting information (i.e., documents, file notes, emails, photographs) 

ii. Anonymity and Confidentiality

If you want to make an anonymous disclosure or restrict your disclosure to only certain people, we will respect that request.


  • You have the right to remain anonymous and do not need to identify yourself at any time during the investigation process.
  • APP Sinar Mas protects your identity.
  • At no time will APP Sinar Mas force you to reveal your identity.
  • You can refuse to answer questions you feel could reveal your identity.
  • If you choose to reveal your identity at any time, we will document who will have access to that information.

You can choose to identify yourself, but this is your choice and at no point do you need to do this, nor will you be forced to provide your identity.

There are some limited situations where APP Sinar Mas may not be able to comply fully with your request as a Reporter to remain anonymous. For example, where:

  • we are compelled by law to do so (for example, where APP Sinar Mas receives a valid subpoena);
  • there is an immediate and substantial risk to the health or wellbeing of you or another person (for example, where a disclosure suggests you might engage in self-harm or harm others);
  • we need to engage external legal counsel in order to obtain legal advice;
  • we use a specialist external investigator;
  • we consider we are obligated to make a disclosure to a regulator or the police under legislation (for example, where a felony has been reported we may be required to report it to the police); or
  • there is an imminent risk of serious harm or danger to public health or safety, or to the financial system, if the information is not acted on immediately.

Whilst we will still make best endeavors to investigate the disclosure, there may be some practical limitations in doing so if you do not agree to share your disclosure or identity.

iii. Retaliation Prohibited

We prohibit all forms of retaliation against you as a direct result of being a Reporter or a witness in an investigation. Retaliation is negative action against you because of your participation as a Reporter or witness, such as:

  • termination of employment (unless unrelated and in the ordinary course of business);
  • disciplinary action;
  • performance management (unless irrelevant and in the ordinary course of business);
  • harassment or bullying;
  • personal or financial disadvantage; or
  • unlawful discrimination

If you feel that you have been or will be retaliated against, you should escalate this immediately to the Corporate Risk & Integrity (CRI). CRI will investigate the retaliation and take the action they feel is appropriate to address any valid concern.

We have the discretion to grant a Reporter who has not engaged in serious or unlawful conduct, immunity from company disciplinary action relating to matters that come to light as a result of their disclosure. We may raise with you matters that arise in the ordinary course of your employment or engagement (e.g. individual performance or misconduct issues) and which are separate from the matter disclosed. 

All personal information you provide is entirely voluntary. If you must identify yourself, the only information that you will be required to provide is your name. 

The personal information that you provide will only be used: (1) to resolve your inquiry; (2) with all identifying information removed and in an aggregate form, for statistical and reporting purposes; (3) in the case of the sale or transfer of some or all of the assets of APP Sinar Mas, to transition to a new owner; and (4) as may be required by law. 

Legal Notice

In jurisdictions where use of this site is restricted by local law or regulation, use of this site is voluntary and constitutes your consent to the collection, reporting and processing of the information you provide, with confidentiality maintained.

By submitting a report, you understand and agree with the requirement stated above. 

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