SDG 8.2.8 Employment Practice: Appeal Process on Employee Rights and Pay
Universitas Islam Internasional Indonesia
Universitas Islam Internasional Indonesia (UIII), a legal-entity state university (PTN-BH) governed by Government Regulation No. 23 of 2019, gives every employee, whether a lecturer or administrative staff member, civil servant or non-civil servant, permanent or on contract, a process to question and appeal decisions on their employment rights and pay. The rights themselves are set by Rector’s Regulation No. 4 of 2025 on the UIII Personnel System and Rector’s Regulation No. 5 of 2025 on Salaries and Other Income, and the process to appeal them runs from the work unit to the Rector and, where needed, to external bodies established by Indonesian law.
Table 1 summarises the routes. Employees may raise any concern about pay, allowances, performance appraisal, sanctions or other employment rights with the leadership; submit a written objection to the Directorate of Organisation, Personnel and Law; file a formal objection and appeal against a decision of the University under the Law on Government Administration; and, if the matter remains unresolved, take it to the Manpower Office, the Industrial Relations Court or, for civil servants, the Civil Service Appeals Board. Complaints about discrimination, harassment or abuse of authority are handled through the codes of ethics and the designated complaint units, which protect complainants’ confidentiality and prohibit retaliation.
Table 1. Routes of appeal for UIII employees on employment rights and pay.
| Stage | Route | Matters covered | Basis |
|---|---|---|---|
| 1. Within the University | Raise the matter with the direct superior or the leadership of the work unit; every employee has the right to give advice and raise concerns with the leadership | Any employment matter | Rector’s Regulation No. 4/2025, Art. 6(f), 7(g), 8(c), 9(e) |
| 2. Personnel review | Written objection to the Directorate of Organisation, Personnel and Law (OKH), which checks the record and corrects payment where due | Pay, allowances, overtime, performance appraisal, personnel records | Rector’s Regulations No. 4/2025 (Art. 65–68) and No. 5/2025 |
| 3. Objection and administrative appeal | Objection to the official who issued the decision within 21 working days; appeal to the superior official within 10 working days of the response | Written decisions on pay, sanctions, appointment or dismissal | Law No. 30/2014 on Government Administration, Art. 75–78; Rector’s Regulation No. 4/2025, Art. 69–72 |
| 4. External bodies | Bipartite negotiation, mediation by the Depok City Manpower Office and the Industrial Relations Court (non-civil-servant employees); administrative appeal to the Civil Service Appeals Board (civil servants); State Administrative Court | Rights disputes and dismissal; disciplinary decisions | Law No. 2/2004; Government Regulation No. 94/2021; Presidential Regulation No. 79/2021; Law No. 30/2014 |
| Ethics, discrimination and harassment | Written complaint to the work unit or to the Disability Services Unit, the Counseling and Mental Health Services Unit or the Task Force for the Prevention and Handling of Sexual Violence; ad hoc Code of Ethics Council | Discrimination, harassment, bullying, abuse of authority, retaliation | Codes of ethics (2023); Rector’s Circular No. 1c/2025; Rector’s Regulation No. 12/2025 |
1. Employment Rights That Can Be Appealed
Instrument: Rector’s Regulation No. 4 of 2025 on the UIII Personnel System
Applies to: Permanent lecturers, permanent administrative staff and non-permanent employees, civil servants (PNS) and non-civil servants (PNPNS)
Rector’s Regulation No. 4 of 2025 sets the rights and duties of every category of employee, together with performance contracts (Art. 65), performance appraisal (Art. 66–67), income (Art. 68) and sanctions and dismissal (Art. 69–72). Rector’s Regulation No. 5 of 2025 sets the salary, allowances and other income of each category, and Rector’s Regulation No. 13 of 2021 the payment of overtime. The rights that employees can appeal therefore include:
1. Salary, allowances and other income, paid according to grade, position, job class and performance under the published schedules;
2. Overtime pay and overtime meal allowance for work outside working hours;
3. Health and employment social security through BPJS Kesehatan and BPJS Ketenagakerjaan;
4. Leave, rest time and opportunities for professional development;
5. A fair performance appraisal, which must be objective, measurable, accountable, participatory and transparent (Art. 66–67), and on which performance allowance and career progression depend;
6. Due process before any sanction or dismissal (Art. 69–72).
SDGs Relevance: Decent Work and Economic Growth (8.5, 8.8), Peace, Justice and Strong Institutions (16.3, 16.6)
2. Internal Appeal Process
2.1. Raising a concern with the leadership
Rector’s Regulation No. 4 of 2025 gives every permanent lecturer, permanent staff member and non-permanent employee the right to give advice and raise concerns with the leadership for the improvement of the work unit and the University (Art. 6(f), 7(g), 8(c) and 9(e)). Employees use this right to raise disagreements about pay, allowances, workload, appraisal or sanctions with their direct superior or the head of their unit, who is expected to resolve them at that level where possible.
2.2. Written objection to the Directorate of Organisation, Personnel and Law
The Directorate of Organisation, Personnel and Law (OKH), under the University Secretary, administers personnel and payroll matters. An employee who finds that a payslip does not match the applicable schedules, the employee’s grade, position or performance contract, or that an allowance or overtime has not been paid, submits a written objection to the Directorate with supporting documents. The Directorate checks the payroll and personnel records and, where the objection is upheld, corrects the payment.
2.3. Performance contracts and appraisal
Each employee signs a performance contract agreed with the direct superior (Art. 65), and appraisal must be objective, measurable, accountable, participatory and transparent (Art. 66–67). Because performance allowance and career progression depend on appraisal, an employee who considers an appraisal unfair may ask the superior to review it and, if still dissatisfied, take it to the next level of the hierarchy and to the Directorate of Organisation, Personnel and Law.
2.4. Sanctions and dismissal
Sanctions and dismissal follow the procedure in Articles 69–72 of Rector’s Regulation No. 4 of 2025, under which an employee whose appraisal falls below the required standard is evaluated in stages before a final decision of the Rector, giving the employee the opportunity to respond.
SDGs Relevance: Decent Work and Economic Growth (8.8), Peace, Justice and Strong Institutions (16.6)
3. Formal Objection and Appeal Against University Decisions
As a state university, UIII issues personnel decisions as decisions of a state official, which are subject to Law No. 30 of 2014 on Government Administration. Any employee whose interests are affected by a written decision, such as a decision on pay, sanctions, appointment or dismissal, may file an objection (keberatan) with the official who issued it within 21 working days of the decision being announced; the official must respond within 10 working days. If the employee is not satisfied with the response, they may file an administrative appeal (banding) with the official’s superior within 10 working days (Art. 75–78). For employees who are civil servants, objections and appeals against disciplinary decisions follow Government Regulation No. 94 of 2021 on Civil Servant Discipline and Presidential Regulation No. 79 of 2021 on Administrative Remedies and the Civil Service Appeals Board.
4. External Dispute Resolution
Where an internal or administrative appeal does not resolve the matter, Indonesian law gives employees further routes (Table 2).
Table 2. External routes for disputes on employment rights and pay.
| Instrument | Route |
|---|---|
| Law No. 2 of 2004 on the Settlement of Industrial Relations Disputes | Rights disputes, including on pay, and disputes over termination must first be negotiated bipartitely between the employee and the employer; if no agreement is reached within 30 working days, the employee may seek mediation by the Depok City Manpower Office, conciliation or arbitration, and then the Industrial Relations Court |
| Government Regulation No. 36 of 2021 on Wages, as amended by Government Regulation No. 51 of 2023 | Protects wages from unlawful deductions and late payment and entitles workers to claim them |
| Law No. 13 of 2003 on Manpower, as amended by Law No. 6 of 2023 | Rights to working time, leave, occupational safety and health and freedom of association, enforceable through labour inspection and the dispute procedure |
| Government Regulation No. 94 of 2021; Presidential Regulation No. 79 of 2021 | Administrative appeal of civil servants against disciplinary decisions to the Civil Service Appeals Board (BPASN) |
| Law No. 30 of 2014; Law No. 5 of 1986 on the State Administrative Court | Judicial review of administrative decisions after the objection and appeal stages |
5. Confidentiality and Protection from Retaliation
UIII’s codes of ethics and anti-discrimination instruments protect employees who raise a complaint or appeal:
1. Confidentiality. The unit receiving a complaint must examine it and protect the confidentiality of the complainant and the information provided (Rector’s Regulation No. 3 of 2023, Art. 11(5)).
2. No retaliation. The code of ethics for administrative staff prohibits arbitrary or retaliatory treatment and abuse of authority, and the codes for the University and for lecturers prohibit threats, intimidation and bullying; superiors may not penalise an employee through appraisal, promotion or dismissal for having appealed.
3. Independent handling. Alleged ethical violations are examined by an ad hoc Code of Ethics Council formed by the Rector with an odd number of at least five members, and sanctions apply to anyone proven to have violated the codes.
4. Designated complaint units. Rector’s Circular No. 1c/Rek/UIII/SE.01/1/2025 names the Disability Services Unit, the Counseling and Mental Health Services Unit and the Task Force for the Prevention and Handling of Sexual Violence as units that receive complaints, provide assistance and follow up cases, and Rector’s Regulation No. 12 of 2025 protects victims and witnesses of sexual violence.
SDGs Relevance: Decent Work and Economic Growth (8.8), Peace, Justice and Strong Institutions (16.3, 16.b)
6. Public Evidence
Rector’s Regulation No. 3 of 2023 on the Code of Ethics for Administrative Staff: https://jdih.uiii.ac.id/detail/129
Rector’s Regulation No. 5 of 2023 on the UIII Code of Ethics: https://jdih.uiii.ac.id/detail/127
Academic Senate Regulation No. 1 of 2023 on the Lecturer Code of Ethics: https://jdih.uiii.ac.id/detail/87
Rector’s Regulation No. 13 of 2021 on overtime pay: https://jdih.uiii.ac.id/detail/113
Rector’s Circular No. 1c/Rek/UIII/SE.01/1/2025: https://jdih.uiii.ac.id/detail/474
Rector’s Regulations No. 4 and No. 5 of 2025: https://jdih.uiii.ac.id/
References
[1] Universitas Islam Internasional Indonesia. Rector’s Regulation No. 4 of 2025 on the UIII Personnel System.
[2] Universitas Islam Internasional Indonesia. Rector’s Regulation No. 5 of 2025 on Salaries and Other Income for UIII Employees. 6 January 2025.
[3] Universitas Islam Internasional Indonesia. Rector’s Regulation No. 13 of 2021 on Overtime Pay and Overtime Meal Allowance. 1 September 2021.
[4] Universitas Islam Internasional Indonesia. Rector’s Regulation No. 3 of 2023 on the Code of Ethics for Administrative Staff; Rector’s Regulation No. 5 of 2023 on the UIII Code of Ethics; Academic Senate Regulation No. 1 of 2023 on the Lecturer Code of Ethics.
[5] Universitas Islam Internasional Indonesia. Rector’s Circular No. 1c/Rek/UIII/SE.01/1/2025; Rector’s Regulation No. 12 of 2025 on the Prevention and Handling of Sexual Violence.
[6] Government of Indonesia. Law No. 30 of 2014 on Government Administration; Law No. 5 of 1986 on the State Administrative Court, as amended.
[7] Government of Indonesia. Law No. 2 of 2004 on the Settlement of Industrial Relations Disputes; Law No. 13 of 2003 on Manpower, as amended by Law No. 6 of 2023.
[8] Government of Indonesia. Government Regulation No. 36 of 2021 on Wages, as amended by Government Regulation No. 51 of 2023.
[9] Government of Indonesia. Government Regulation No. 94 of 2021 on Civil Servant Discipline; Presidential Regulation No. 79 of 2021 on Administrative Remedies and the Civil Service Appeals Board.
[10] Government of Indonesia. Government Regulation No. 23 of 2019 on the Statute of Universitas Islam Internasional Indonesia.