KEMITRAAN believed that good communication, honest and open among the employees at all levels in the whole organization will increase organizational performance and for that reason the employees are encouraged to increase the awareness of malpractice/fraud at work without fear of a retaliatory action as KEMITRAAN will defend the sources.

Based on this policy, if an employee convey her/his concern and on the basis of good intention, although later on s/he was found responsible for a mistake, s/he would not risk losing their job or have to pay a compensation as a result.

Since the responsibility for investigation of fraud corruption, money laundering, financing of terrorism and other forms of misconduct lies with the Internal Audit Department as outlined in the Internal Audit Charter, it is necessary to develop terms of reference which outlined the responsibility and task of the Independent Investigation Committee.


The ad-hoc To provide independent and objective investigation to resolve any cases involving ethic, fraud, corruption, money laundering and financing of terrorism.

Key Responsibility and Authority

  1. Investigate the alleged malpractice/fraud, corruption, money laundering and financing of terrorism if an employee is reporting of a malpractice/fraud, at work;
  2. Conduct investigation no later than one week since the issue is expressed.
  3. The Ad-Hoc Independent Investigation Committee is expected to conclude the case within one month. The time frame can be extended if the Ad-Hoc Committee has not completed the task.
  4. Reporting the result of the investigation to relevant parties.
  5. The Committee has the authority to collect relevant information, talking to the informants/witnesses, collecting documents and other relevant information related to the case to ensure timely conclusion of the investigation
  6. The Committee will be dissolved or terminated once the task has been concluded.
  7. Ad-hoc Membership Requirement
  8. The ad-hoc team will be led by the Internal Auditor or an appointed senior staff along with one head of a unit as a member and the head of HR unit. The selected ad-hoc members is required to declare the potential conflict of interest in relation to the case being investigated.


In conducting the investigation, the Ad-Hoc investigation committee will maintain the confidentiality of the assignment throughout the duration of the assignment. The Committee shall only report the result of the investigation to the relevant party/authority.

This terms of reference is prepared to guide the Ad-Hoc team in conducting the investigation in accountable and responsible manners.

Kemitraan Bagi Pembaruan Tata Kelola Pemerintahan
Jl. Taman Margasatwa No. 26C, Ragunan

Pasar Minggu, Jakarta Selatan 12550
Telephone: +62-21-2278-0580
Fax: +62-21-781-2325
Email: complaint.handling@kemitraan.or.id
Website: www.kemitraan.or.id