Internal policies

Child protection policy


Center for Indonesian Policy Studies (CIPS) has zero-tolerance approach to child exploitation or abuse. According to Indonesian Law, we are responsible to prevent any activities that may lead to child abuse and exploitation. Therefore, this child protection policy was made as an activity or initiative to protect children from any form of harm and to demonstrates a commitment to safeguarding children and to makes clear to all what is required in relation to child protection. It helps to create a safe and positive environment for children and to show that the organization is taking its duty and responsibility of care seriously.


This policy applies to:

  • a full-time, part-time or casual staff member;

  • temporary or agency employee;

  • an intern;

  • a volunteer;

  • an external individual engaged in CIPS activities;

  • a contractor, sub-contractor or service provider.

The word ‘abuse’ in this policy refers to:

  • physical abuse: the use of physical force against a child that results in harm to the child. Physically abusive behavior includes shoving, hitting, slapping, shaking, throwing, punching, kicking, biting, burning, strangling and poisoning;

  • neglect: the failure by a parent or caregiver to provide a child with the conditions that are culturally accepted as being essential for their physical and emotional development and wellbeing;

  • emotional abuse: refers to a parent or caregiver’s inappropriate verbal or symbolic acts toward a child, or a pattern of failure over time to provide a child with adequate non-physical nurture and emotional availability. Such acts have a high probability of damaging a child’s self-esteem or social competence;

  • sexual abuse: the use of a child for sexual gratification by an adult or significantly older child or adolescent;

  • ill treatment: disciplining or correcting a child in an unreasonable and seriously inappropriate or improper manner; making excessive and/or degrading demands of a child; hostile use of force towards a child; and/or a pattern of hostile or unreasonable and seriously inappropriate degrading comments or behavior towards a child.

Child exploitation includes:

  • committing or coercing another person to commit an act of abuse against a child;

  • possessing, controlling, producing, distributing, obtaining or transmitting child exploitation material

  • according to Indonesian Law no. 13/2003 article 68 on manpower, employers are not allowed to employ children below 18 years old. Within a specific terms and condition, there is an exemption to employ children between 13 – 15 years old.

sexual harrasment policy

CIPS is committed to provide a safe environment for all its employee free from discrimination on any ground and from harassment at work including sexual harassment. CIPS applies a zero-tolerance policy to any form of sexual harassment in the workplace, treats all incidents seriously and promptly investigates all allegations of sexual harassment. Any person found to have sexually harassed another will face disciplinary action, up to and including termination of employment.

All complaints of sexual harassment will be taken seriously and treated with respect and in confidence. 

What Qualifies as Sexual Harassment?

Sexual harassment is any unwelcome sexual conduct, request for engaging in sexual act, verbal or physical gestures of a sexual nature, or behavior that is sexual in nature, which makes another person feel humiliated and/or intimidated, and that action interferes with work, and creates an intimidating, hostile or disrespectful work environment.

Sexual harassment is:

  1. inappropriate sexual behavior;

  2. request for sexual favors; 

  3. verbal or physical statements or gestures describing sexual acts, and;

  4. unwanted sexual acts.


  1. the victim has declared the behavior undesirable;

  2. the victim feels insulted, intimidated and/or pressured by the act;

  3. the harasser could have reasonably anticipated and understood that the victim will feel intimidated, humiliated, insulted and/or pressured by the act.

Behaviors that qualify as sexual harassment are:

  1. Physical – Any unwanted physical contact, ranging from inappropriate touching to sexual assault and rape;

  2. Verbal – unwanted and intimidating comments and questions about appearance, lifestyle, sexual orientation, as well as sex-related jokes or insults, either in direct or in telecommunication;

  3. Non-verbal – staring, whistling, sexually suggestive gestures, unwelcome display of sexually explicit material including pictures, magazines, videos or objects;


Acts of sexual harassment in the workplace have been regulated by the Indonesian government under the Criminal Code of the Republic of Indonesia Article 294 (2), Indonesian Labor Law No. 13/2003 concerning manpower article 86 (1), and the guideline for prevention of sexual harassment in work environment by the International Labor Organization (ILO).

To Whom This Applies

 Anyone can be a victim of sexual harassment, regardless of their sex and the sex of the harasser. CIPS recognizes that sexual harassment may occur between people of the same sex. CIPS also recognizes that sexual harassment is a manifestation of power and may occur between different hierarchical levels in the organization. This policy applies to all CIPS members, including:

  • full time and part-time staff;

  • senior fellows, visiting fellows, associate researchers;

  • trainees and temporary employees ;

  • interns;

  • volunteers;

  • external individuals engaged in CIPS activities;

  • contractors, sub-contractors or service providers.

CIPS prohibits all forms of sexual harassment whether taking place in CIPS office premises or outside, including social events, business trips, training sessions, conferences or any other outside activities by CIPS.





Fraud and corruption prevention policy


Definition of Corruption

In accordance with Indonesian Law on Eradication of the Criminal Act of Corruption no.31/1999, penal code of the Republic of Indonesia article 372, article 378, article 209, article 368, and other related laws regarding corruption, CIPS defines act of corruption includes anyone who:

  • Illegally commits an act to enrich oneself or another person or other entities to the detriment of the finances and assets of CIPS and its donors and grantors;

  • Illegally enriching oneself or another person or other entities, with abusing the authority, opportunity or facilities given to him related to his post or position, to the detriment of the finances and assets of CIPS and its donors and grantors;

  • Giving or promising something to someone with the intention to persuade the recipient to do or not to do something, which is contrary to the recipient’s authority or obligation, known as bribery;

  • With deliberate intent and unlawfully appropriates property which wholly or partially belongs to another and which he has in his possession otherwise than by a crime, known as embezzlement;

  • With intent to unlawfully benefit himself or another, either by assuming a false name or a false capacity, or by crafty artifices, or by a web of fictions, induces someone to deliver any property or to negotiate a loan or to annul a debt, known as fraud;

  • With intent to unlawfully benefit himself or another, by force or threat someone either to deliver a good belongs to that person or to a third party, known as extortion;

  • Receives any offer, payment and/or gift to encourage him/her to do or not to do something in relation to his/her position or obligation, known as gratifications.



Statement of Attitude to Fraud and Corruption 

CIPS requires all staff at all times to act honestly and with integrity and to safeguard the institute’s resources for which they are responsible CIPS is committed to protecting all revenue, expenditure and assets from any attempt to gain illegal financial or other benefits.


Perpetrators of Fraud and Corruption

Any fraud or corruption committed against CIPS is a major concern to us. Consequently, any case will be thoroughly investigated and appropriate disciplinary action will be taken against anyone who is found guilty of corrupt conduct. This may include referral to the Police and other authorized personnel. 

CIPS endeavors to make its staff, interns, volunteers, contractors, suppliers and donors aware of its statement of attitude to fraud and corruption by:

  • inform the document to any new member

  • placing it on the CIPS website.

  • referring to key attributes of the strategy in CIPS’ publications including the annual report.

  • providing a summary in training sessions.

  • regular Fraud and Corruption awareness activities


Code of Conduct

All CIPS members are subject to the provisions and requirements of the CIPS’ Code of Conduct. The Code of Conduct assists in preventing fraud and corruption within CIPS and the following statement is incorporated in the Code of Conduct to that effect:

All members of CIPS are expected to perform their duties with efficiency, fairness, impartiality, integrity, honesty, and compassion. This code aims to clarify for all staff the conduct expected in the performance of their duties and to provide them with a guide to solving ethical issues. To this end we expect every member to conduct the activities of CIPS with the utmost integrity, honesty, accuracy and fairness. We need to examine our actions in accordance with this standard and where this generates concerns we should raise them in the appropriate manner and resolve them before proceeding.

data protection policy

Personal Data


CIPS takes employee’s privacy seriously and makes all efforts to protect employee’s personal information from misuse, interference and loss; and from unauthorized access, modification or disclosure. Personal data is classified as confidential and it must be respected by all CIPS members. All personal information about CIPS employees collected by CIPS, such as personal contact details (ID, photograph, salary details, etc) will be used for contract and work purposes only. 

CIPS personnel need to respect and apply these basic principles while processing personal data: Fair processing, purpose specification, accuracy, respect, confidentiality and security. 



This policy applies to all personal data held by CIPS in relation to persons of concern to CIPS. Data which will be protected under this policy includes:

  • Biographical data (biodata) such as name, sex, marital status, date and place of birth, country of origin, country of asylum, occupation, religion, and ethnicity;

  • Scanned ID;

  • Scanned NPWP;

  • Photograph;

  • Fingerprint;

  • Salary details;

  • Performance review;

  • Bank account details;

  • Personal address;


This policy applies whether the processing takes place within CIPS office or transferring personal data to other parties. The policy continues to apply even after persons are no longer CIPS staff members. Employment history details will be kept for work purposes and will not be shared with anybody or any institution.


Use and disclose personal information

Personal information will only be used and disclosed for the purpose for which it was collected. Any requests for information about personal data must have approval from the data subject. Information collected from all CIPS member will be used and disclosed to other organization or other parties within the following condition:


  • you have consented to use or disclosure for a secondary purpose;

  • it is requested by the law enforcement agency or court. Transfers may concern a person subject to an investigation for an allegedly committed crime, or in relation the victim(s) of or witness(es) to a crime.

FUNDraising policy


Since the existence of the Center for Indonesian Policy Studies (CIPS) relies on financial support from local and international communities, public trust is vital to our mission. The key to gaining and maintaining public trust is transparency and accountability on how our business is conducted and how donations are handled. 

As CIPS fundraising develops and grows, it is important that our income stream is guided by clear policies and procedures with regard to the criteria that determine whether donations to CIPS should be accepted or refused. Having a Fundraising Policy enables CIPS to express our values, ethos and defined reasons (practical, legal and ethical factors) to be taken into account while making decisions on donations. The policy has been developed to specify guiding principles that influence and determine these decisions and actions of CIPS with respect to fundraising. The CIPS team and the Executive Director should always be able to explain their decision making to the Board of Directors and donors and will henceforth use this Fundraising Policy as a guide.

What Constitutes a Donation?

A donation is considered as any act by which the owner or manager of funds or other tangible items transfers the title and possession of the same, from her/himself on their own behalf or on behalf of a donating organization/institution they legally represent, to support research, events, communication, advocacy campaigns, the general operations, a strategic financial reserve or a trust fund for the sustainable growth of CIPS. Donations include, among others, individual donations, online donations, monthly or recurring donations, planned gifts, corporate grants, matching gifts, in-kind donations, unrestricted donations and restricted grants by private foundations, corporate foundations and government-funded agencies. A donation is never perfected until it has been accepted. The acceptance is requisite to make the donation complete. 

Ethical Guidelines

This policy recognises the critical importance of ethical conduct in fundraising activities in order to safeguard the status of the organisation as a registered non-profit and ensure CIPS stands up to scrutiny by all its stakeholders and the public.

Ethical considerations include:

1. It is permissible to accept funds from companies, their Corporate Social Responsibility programs or foundations as long as CIPS does not endorse any products and/or services of donors or sponsors.


2. We accept donations in cash or kind from organisations and individuals that help us in our mission to advocate for public policies that empower Indonesians, especially from low-income households, to lead free, prosperous and peaceful lives. 

3. We do not accept donations in cash or kind from tobacco companies. The rejection of funding from other business sectors depends on the decision by the board of directors and the formal revision of this fundraising policy. Funding from business units of companies involved in the tobacco industry is possible only if, in the opinion of the executive director: 

  • the primary business of the donor unit is unrelated to the production, manufacture, distribution, promotion or marketing of tobacco or tobacco products, and 

  • acceptance of the funding cannot be construed to support the tobacco industry.

4. Funding from foundations established and primarily funded by the tobacco industry will not be accepted unless in exceptional cases approved by the board of directors.

5. We will not use any unethical or unlawful techniques to solicit funds or sell products and services.

6. Donations will not be accepted if they are deemed (to the best of our knowledge) to have originated from unethical or unlawful activities.


7. We will not engage in any activities that involve discriminatory practices against any individual or group based on gender, religious or political affiliation, citizenship, age, race or ethnicity, a record of offences, disability, income or family status.


8. No valuable consideration or other privileges will be bestowed on a donor who could have the ability to exercise, directly or indirectly, control or significant influence over CIPS mission and goals.


9. Cash donations up to a maximum of IDR 5 million only will be accepted. Donations exceeding this amount will be accepted by cheque, e-payment, online or direct bank transfers, or in kind.


10. All CIPS activities will be aligned with our Child Protection Policy, Sexual Harassment Policy, Fraud and Corruption Prevention Policy and Data Protection Policy.


11. We will not outsource fundraising to external professionals if fees are a significant portion of the anticipated funds raised.



Guiding Fundraising Policies

1. Accepting a Gift: CIPS accepts financial support from, and works in partnership with individuals, companies and grant-making organisations on the following conditions:

  • If it aligns with CIPS’ vision, mission and strategic objectives.

  • If it complies with fiscal and charity regulations of the Indonesian government. 

  • If anticipated results will be in the best interest of our organisation and our beneficiaries.

  • If we are satisfied that neither the independence nor the integrity of CIPS would be compromised by accepting such support.

  • If we are satisfied that any publicity that results from accepting such support will be beneficial to the organisation.


2. Declining a Gift: CIPS  must refuse opportunities where:

  • The gift derives from any illegal activities such as (but not limited to) tax evasion, fraud or money laundering and where it is otherwise required to do so by specific, prevailing legislation.

  • The source of the gift, or its ethical origin is unclear, and/or could undermine CIPS' reputation as an independent and non-partisan think tank were it to be accepted, regardless of value.

  • The gift comes from an individual or organisation which is in direct conflict with CIPS’ vision of a free and prosperous Indonesia.

  • It is believed that the cost to CIPS of accepting a donation/opportunity will be greater than the value of the donation/opportunity itself.

  • The donation is made with the intention of influencing CIPS with an explicit or implicit exchange for favours or benefits. 

  • The donation, through either its magnitude or nature, will influence CIPS to abandon its mission and objectives.

  • It is considered that the opportunity may, in the opinion of CIPS, bring the organisation into disrepute or involve it in controversy or publicity which would do meaningful damage to its reputation.

  • It does not clearly comply with specific prevailing legislation.



Specific Fundraising Protocols

1. For all corporate grants, CIPS will enter into a written agreement with all corporate partners. This agreement will set out clearly the nature of the partnership and the obligations of each party.

2. Donations come with risk if they were made from a source that is unexpected, i.e. when a donor comes to us without being approached by us first. This is more likely to happen as the Center’s fundraising activities reach new audiences and our work becomes more widely known.

  • The decision to accept a truly anonymous donation, where CIPS only deals with an intermediary who will not identify the donor, even to the CIPS Board of Directors, will be made on the following conditions:

    • The intermediary is a trusted/credible third party who can guarantee the integrity and origin of the funding source.

    • The donation in such cases will not amount to more than USD 10,000 in a year.

  • A donation by a donor who wishes for their name to remain anonymous to all but the Board of Directors should be dealt with, as far as possible, in the same way as other donations.

3. Where CIPS offers to name a building, scholarship or any other aspect of its activities in recognition of a particular donor, the duration of such naming opportunity should be agreed upon between the donor and the Center. In addition, CIPS reserves the right to withdraw such named recognition in the future, where it transpires that the source of the funding is suspicious or arose in whole or part from any activity listed under the rules regarding declining donations above.

4. The Executive Director will ensure that the Board of Directors is made aware of any potentially suspicious donations and any significant and potentially contentious issues. The Board will review such cases and will pass a board resolution on the way forward.

5. If CIPS is asked to refund a donation made in error or due to an agreement on the return of underutilised funds, then it must ensure that it complies with relevant regulation and practices in Indonesia and the transaction must be authorised in writing by the Executive Director and the Board of Directors.


Donor Privacy Policy

Any information supplied to CIPS by donors will be used solely to fulfil their donation and shall not be shared for any reason unless permission is granted by the donor to share such information.

  • All requests to remain anonymous shall be honoured. In case other policies in CIPS demand the disclosure of the donor’s name, the donor will be informed prior to the donation and needs to agree in writing before the donation.  

  • CIPS does not sell or share donor lists. 

  • Donors who supply CIPS with their postal address, email address or telephone number may be contacted as per agreed timelines and purpose.

  • All donors have the option of being included on mailing lists which grant CIPS permission to contact them. Donors may request to be permanently removed from the mailing lists by contacting us via email, phone or postal mail. All requests to be removed from the mailing list shall be honoured by CIPS.

  • Only the Executive Director, the Board of Directors, the Heads of Departments in CIPS and specific personnel in charge of fundraising and donor communication will have access to all donor information.