Compliance Function

PT Indocement Tunggal Prakarsa Tbk., (“the Company”) is a subsidiary of the HeidelbergCement Group. We are always committed to comply with all applicable laws and regulations in carrying out our business activity.

As a globally active company, we are moreover committed to implementing all the important values for the Company. This commitment is realized by implementing a comprehensive and consistent GCG at all levels of the organization, one of which is by adopting the best standards that apply in Indonesia and internationally, including:

  • Universal Declaration of Human Rights
  • The Eight core labor standards of the International Labor Organization (ILO)
  • OECD Guidelines for Multinational Enterprises
  • United Nations Guiding Principles for Business and Human Rights ("Protect, Respect and Remedy"-Framework)

We expect our employees and business partners to adhere to al guidelines. Guidelines owned by the Company include:

Policy/Guideline Content Target Group

1. Compliance Policy
(Updated 2021)

This policy outlines the HeidelbergCement compliance programme:

  • Responsibilities (general and specific compliance management)
  • Compliance in joint entities
  • Contents and tools
  • Sanctions in case of non-compliance
Upper management
2. Code of Business Conduct
(Updated 2021)

The Code of Business Conduct sets the ethical and legal standards
for day-to-day business activities in terms of:

  • Compliance with applicable laws and internal policies
  • Antitrust law
  • Health and safety
  • Environmental and sustainability issues
  • Human rights
  • Plenty of more compliance topics

Emphasis is laid on the responsibility of all employees to uphold
these standards and the fact that violations are not tolerated

All employees

3. Anti-Corruption Guideline
(Updated 2021)

This document provides guidance in situations which could bear corruption risks, such as:

  • Giving or receiving gifts or hospitality to or from business partners
  • Gifts or hospitality with respect to representatives of public authorities
  • Conflicts of interest
  • Corporate citizenship activities
  • Cooperation with agents and advisors
  • Merger and Acquisition projects

Risk-mitigating measures include

  • Personnel-rotation
  • Two-person integrity and segregation of duties
  • Adequate documentation
  • Information and training of employees exposed to corruption risks
  • All employees and focus on Management
  • Employees involved in procurement, i.e. purchasing employees as well as engineers (e.g. by determination of specifications)
  • Employees of specialist departments that use external service providers (e.g. attorneys, accountants, auditors, consultants, etc.)
  • Employees of departments responsible for obtaining governmental permits of all kinds and other approvals
  • Sales employees
  • Employees involved in corporate acquisitions
  • Employees involved in Corporate Citizenship activities (sponsorships, donations, etc.) that accompany HC CAPEX projects.
4. Competition Law Guidline
(Updated 2021)

This guideline gives an overview over the following topics:

  • Responsibilities in terms of competition law
  • Competition law infringements relevant to our business and their legal consequences
  • Rules of conduct in order to avoid competition law violations
  • Instructions for conduct in the event of competition law
  • investigations
  • Reporting on competition law incidents
  • Implementation of and minimum requirements for national
  • Competition law guidelines
  • Mitigation measures, such as:
    • Adequate documentation,
    • Yearly risk assessment,
    • Information and training of employees exposed to
  • Competition law risks
  • Specific Grey Cement/Cementitious compliance rules for EEA Countries
  • Upper management
  • Sales managers and officers
  • Purchasing managers and officers
  • Managers and employees involved in procurement
  • Merger and Acquisition projects
  • All other
5. Compliance Incident Reporting and Case Management Guideline
Updated 2021)

This document provides guidance on:

  • The types of incidents to be reported as compliance incidents
  • The various reporting channels
  • How a compliance incident should be reported
  • How the investigation process is organized (responsibilities, timing, documentation, communication, etc.)
  • Which persons need to be informed within the organization in case of reported compliance incidents
  • Securing data if severe compliance violations are suspected
  • Responsible persons for remedial measures in case of proven
  • Misbehaviour
  • The investigation principles
All employees
6. Trade Sanctions Policy
(Updated 2020)

This policy provides:

  • An overview of national and international trade sanctions
  • The types of EU and U.S. trade sanctions and their scope of applicability
  • Details on the responsibilities on Group and local level
  • Upper Management
  • Sales managers and officers
  • Purchasing managers and officers
  • HR managers and officers
  • Managers and employees involved in procurement and
  • Merger and Acquisition projects 
  • All employees charged with screening of business
  • Partners for trade sanctions compliance
7. Human Right Position
(Updated 2020)

This policy specifies:

  • HC’s commitment to a list of different human rights documents
  • The application of human rights in our relationship with our
    • Employees,
    • Suppliers and customers
    • Surrounding of location (corporate citizenship)
All employees
8. Anti-Money Laundering Policy
(Updated 2020)

This policy specifies HC’s

  • Obligations to prevent money laundering
  • Regulations for cash payments
  • Approach to money laundering risk management
  • Treasury/staff involved in financial transactions
  • Master data requester (purchasing, sales)
  • Master data administration
  • All employees involved in selection of business
  • Partners and business transactions