*Corresponding Author

P-ISSN: 1412-1212
E-ISSN: 2541-2388

65

The Winners, 23(1), March 2022, 65-71
DOI: 10.21512/tw.v23i1.7293

Corporate Governance Principles
in Sovereign Wealth Fund: The Case of Indonesia 

Sovereign Wealth Fund

Suwinto Johan*

Management Study, Faculty of Business, President University
Jababeka Education Park, Jl. Ki Hajar Dewantara , RT 2/RW 4, Mekarmukti, North Cikarang, Bekasi 17530, Indonesia

Faculty of Law, Universitas Tarumanagara
Jl. Letjen S. Parman No. 1 Jakarta 11440, Indonesia

suwintojohan@gmail.com  

Received: 14th April 2021/ Revised: 07th June 2021/ Accepted: 21st June 2021

How to Cite: Johan, S. (2022). Corporate governance principles in sovereign wealth fund: The case of
Indonesia sovereign wealth fund. The Winners, 23(1), 65-71. https://doi.org/10.21512/tw.v23i1.7293

Abstract - The research aimed to determine the 
application of corporate governance principles for the 
Indonesian Sovereign Wealth Fund (ISWF) consisting  
of  the Supervisory Board and the Board of Directors 
which had different functions. The research applied 
a normative juridical research method. The research 
concludes that the government needs to review the 
implementation of the principles of institutional 
corporate governance in the ISWF. The principles of 
corporate governance need to be rearranged, mainly 
the functions and powers of the Supervisory Board 
and the definition of the authority of the Board of 
Directors. It is considered that the research has its 
particular limitation as the discussion is based only on 
two laws and one corporate governance manual. It is 
suggested that further research have more development 
by comparing corporate governance in other countries.

Keywords: corporate governance, corporate 
governance principles, Indonesia Sovereign Wealth 
Fund (ISWF)

I. INTRODUCTION

Every country aims to achieve economic 
progress since it will increase the national income 
and improve the welfare of its people. Based on the 
Law of the Republic of Indonesia No. 11 of 2020 
on Job Creation (UU Cipta Kerja), the Indonesian 
government established the ISWF. which aims to 
increase and optimize asset value in the long-term 
to support sustainable development (Pratama, 2020). 
ISWF will finance Indonesia’s development through 
innovation and breakthroughs, such as investment 
partners, so investors will have confidence in the 

business environment in Indonesia (“Tarik investor, 
pemerintah bentuk”, 2021). ISWF has the duty and 
authority to allocate funds in financial instruments, 
perform asset management activities, collaborate with 
other parties, trust fund entities, determine potential 
investment partners, provide and receive loans, and 
administer assets (Prakoso, 2020).

Many countries in the world already have a 
Sovereign Wealth Fund (SWF), such as Norway, the 
United Arab Emirates, India, Singapore, and China. 
SWF countries in the world manage USD 7,1 trillion 
in funds (“Berkaca pada raksasa”, 2021). The creation 
of SWF has generated several debates, particularly 
regarding the initial capital investment in Nigeria 
(Mmaduabuchi, 2020).

Indonesian citizens have already known about 
GIC and Temasek from Singapore and Khazanah 
from Malaysia, which have invested in Indonesia. 
Temasek once owned shares in several banks and 
telecommunication companies. Khazanah has shares 
in several banks and telecommunication companies in 
Indonesia. 

Malaysia has an investment institution called 
1 Malaysia Development Berhad (1MDB). It a 
government fund management company launched in 
2009 which aimed to build the Malaysian economy. 
1MDB transferred as much as USD 4,5 billion 
to accounts of companies unrelated to 1MDB 
investments. The funds were corrupted. The former 
Prime Minister (PM) of Malaysia, Najib Razak, was 
charged with receiving USD 1 billion. Najib Razak 
was found guilty in the trial of the 1MDB corruption 
case (Iswara, 2020).

The government injected an authorized capital 
of IDR 15 trillion in ISWF. President Joko Widodo 
appointed the ISWF Supervisory Board (Farisa, 2021). 



66 The Winners, Vol. 23 No. 1 March 2022, 65-71

He also announced the ISWF Board of Directors on 
February 16, 2021 (Nugraheny, 2021). The Board of 
Trustees has the function and authority to oversee the 
ISWF Board of Directors.

Research on the corporate governance of 
institutions established by the government is still 
rare. The ISWF is an institution that was only formed 
in 2021. It is a new institution for Indonesia where 
corporate governance is very important. ISWF 
manages a large amount of funds with an initial capital 
of IDR 15 trillion. In addition, ISWF requires trust 
from partner investors in Indonesia.

Corporate governance has an influence on the 
performance of Islamic banking in Indonesia. The 
board of directors has a direct impact on the financial 
performance (Eksandy, 2018). Corporate governance 
has an effect on company value (Sarafina & Saifi, 
2017). The number of independent commissioners 
in a company is one of the variables in determining 
corporate governance. The corporate governance 
variables have a positive influence on financial stress 
(Fathonah, 2017). Corporate governance has an impact 
on the company’s financial performance (Paniagua, 
Rivelles, & Sapena, 2018). Furthermore, corporate 
governance has an effect on the capital structure 
including the amount of debt used by the company 
(Kieschnick & Moussawi, 2018).

The institutional ownership, directors, and 
audit committee have no influence on agency costs 
(Ayunitha et al., 2020). Institutional ownership has a 
negative impact on the level of corporate governance 
(Al-Sartawi et al., 2019). Moreover, the independent 
commissioner and the audit committee have no effect 
(Eksandy, 2018).  

For stakeholders, corporate governance has 
a very strong influence in providing positive signals 
to the market and reducing information asymmetry. 
Corporate governance also ensures objective signals 
from different shareholders (Bae, Masud, & Kim, 
2018). The financial safety net and too-big-to-fail 
guarantees in thinking about corporate governance 
reforms at the bank (Anginer, et al., 2018). Mutlu 
et al. (2018) find a relationship between corporate 
performance and good corporate governance in China 
as corporate sustainability continues to improve and 
enhance the principles of good corporate governance 
(Choi et al., 2020).

The Minister of Finance, Sri Mulyani, as the 
Chairperson of the Supervisory Board of the ISWF, 
wants to ensure that the supervisory function can 
be performed effectively. President Joko Widodo 
reminded ISWF not to repeat the 1MDB incident. 
Indonesia must prove that it has good corporate 
governance.

The research aims to investigate three research 
problems: 1) The application of corporate governance 
principles in the ISWF compared to the Limited 
Liability Company Law; 2) Function and authority 
of the ISWF board compared to the Limited Liability 
Company Law; 3) The difference in the implementation 
of corporate governance in the function of entities in 

the ISWF and limited liability companies.

II. METHODS

The research applies a normative juridical 
method. It studied the laws and regulations in effect in 
Indonesia. The research uses primary and secondary 
data. The primary data is information regarding the 
formation of the ISWF. Meanwhile, the secondary 
data is the applicable laws and regulations, namely the 
Law of the Republic of Indonesia No. 11 of 2020 on 
Job Creation, the Law of the Republic of Indonesia 
No. 40 of 2007 on Limited Liability Companies 
and Indonesia Corporate Governance Manual (2nd 
edition) (IFC, 2018).

The research begins by obtaining materials 
related to legal matters with the identification and 
inventory of materials related to the research topic. 
The material inventory consists of primary legal 
materials, secondary legal materials, and tertiary legal 
materials. The primary legal materials consist of the 
laws and regulations in Indonesia. The secondary 
legal materials are items that explained the primary 
legal materials, such as books, reports, and others. 
The tertiary legal materials are legal items that served 
as secondary guidance, such as information on the 
Internet as additional information and data related to 
the research topics. The tertiary legal materials include 
news regarding government policies in establishing 
the ISWF (Johan & Ariawan, 2020; Lie et al., 2019).

III. RESULTS AND DISCUSSIONS

Based on Article 165 of the Law of the Republic 
of Indonesia No. 11 of 2020 on Job Creation, the 
ISWF consists of two boards, namely the Supervisory 
Board and the Board of Directors. The Supervisory 
Board consists of five people, two of which are 
ministers, namely the Minister of Financial Affairs as 
the chairperson and a member and the minister who 
governs the affairs related to state-owned enterprises 
as a member. Besides the two ministers, there are also 
three professionals on the board.

The members of the Supervisory Board are 
appointed and terminated by the President. The 
President forms a selection committee to elect 
members of the Supervisory Board. The President is 
obliged to conduct consultations with the House of 
Representatives.

Fellow members of the Supervisory Board may 
not have family ties within the second generation with 
fellow members of the Supervisory Board and the 
Board of Directors. Members of the Supervisory Board 
are appointed with a term of five years, which can only 
be reappointed for one term of office. Fellow members 
of the Board of Directors are also not allowed to have 
family ties within the second generation with fellow 
members of the Supervisory Board and the Board of 



67Corporate Governance Principles.... (Suwinto Johan)

Directors. The Board of Directors is appointed for a 
term of 5 years and may only be reappointed once.

Based on the Law of the Republic of Indonesia 
No. 40 of 2007 on Limited Liability Companies (PT 
Law), a limited liability company has three entities, 
namely the General Meeting of Shareholders, the 
Board of Commissioners, and the Board of Directors. 
The Board of Directors is obliged to submit an annual 
report to the General Meeting of Shareholders (GMS), 
which is reviewed by the Board of Commissioners. 
Annual reports include financial reports, activity 
reports, reports on the implementation of social and 
environmental responsibility, reports on supervisory 
duties by the Board of Commissioners, and salaries 
and allowances for members of the Board of Directors 
and the Board of Commissioners. The annual report is 
approved by the GMS.

All corporate governance matters of a limited 
liability company, especially the financial institutions 
in accordance with the laws and regulations in 
Indonesia has been included in the Indonesia 
Corporate Governance Manual (2nd edition) (IFC, 
2018). The regulations regarding good corporate 
governance, especially financial institutions, have 
been fully explained. The research discusses the ISWF 
and limited liability companies in general, not only 
financial institutions. ISWF is a special investment 
institution for the Indonesian government and is 
not under the supervision of the Financial Services 
Authority.

In the event that the Board of Directors consists 
of two or more members of the Board of Directors, 
the division of duties and authority for management 
shall be determined based on the resolution of the 
GMS. In the event that the GMS is not stipulated, the 
duties and authorities shall be determined based on the 
decision of the Board of Directors. Members of the 
Board of Directors are appointed by the GMS and can 
be reappointed. 

The salaries and allowances of the members of 
the Board of Directors are determined based on the 
resolution of the GMS. Authority can be delegated to 
the Board of Commissioners. Members of the Board 
of Directors are required to report the shares owned 
by the respective members of the Board of Directors 
and/or their family members in the company. The 
Board of Directors is obliged to request the approval 
of the GMS to transfer the assets of the company, in 
making a guarantee for the debt of the company’s 
assets. The Board of Directors is not authorized to 
apply for bankruptcy on its own. The members of 
the Board of Directors can be dismissed based on the 
resolution of the GMS. The Board of Commissioners 
can temporarily suspend the Board of Directors.

The Board of Commissioners consists of more 
than one member as a panel. Each member of the Board 
of Commissioners cannot act individually as it should 
be based on a decision by the Board of Commissioners. 
Members of the Board of Commissioners are appointed 
by the GMS. The Board of Commissioners can be 
reappointed after a certain period of an appointment 

has ended. The salary or honorarium and allowances 
for the Board of Commissioners is determined by the 
GMS.

The Supervisory Board has the authority to: 
1) approve the work plan and budget proposed by 
the Board of Directors, 2) conduct performance 
evaluations, 3) receive and evaluate the accountability 
report of the Board of Directors, 4) submit the 
accountability report of the Supervisory Board and the 
Board of Directors to the President, 5) determine and 
appoint the Advisory Board, 6) appoint and dismiss 
the Board of Directors, 7) determine the remuneration 
of the Board of Trustees and the Board of Directors, 8) 
propose an increase and/or reduction in ISWF capital 
to the President, 9) approve the ISWF financial report, 
10) suspend members of the Board of Directors and 
appoint a temporary replacement for the Board of 
Directors, and 11) approve the appointment of the 
Institute’s auditors.

The Board of Directors has the authority to: 
1) formulate and determine institutional policies, 2) 
implement policies and operational management of 
the Institute, 3) compile and propose remuneration for 
the Supervisory Board and Board of Directors to the 
Supervisory Board, 4) compile and propose along with 
the main performance indicators to the Supervisory 
Board, 5) compile the ISWF organizational structure 
and personnel management, and 6) represent ISWF 
inside and outside the court. The appointment of each 
member of the Board of Directors is determined by the 
Board of Directors.

Based on Article 92 of the Limited Liability 
Company Law, the Board of Directors carries out the 
management of the company for the benefit of the 
company in accordance with the aims and objectives. 
The Board of Commissioners supervises management 
policies and the course of management in general and 
provides advice to the Board of Directors.

The ISWF entities consist of a Board of 
Trustees and a Board of Directors. This is different 
from the entities of a limited liability company as 
regulated in the Law of the Republic of Indonesia 
No. 40 of 2007. By considering the ISWF structure, 
it can be concluded that the ISWF structure tends to 
be a single-board system. However, the supervisory 
and implementation functions are separated. This 
is different from the structure of a limited liability 
company in general, of which the separation between 
supervision and implementation is very clear. 

The single-board system is mostly run on the 
common law system. A single-board system also allows 
faster decision execution compared to a dual-board 
system. The dual-board system will require approval 
from shareholders in making important decisions. 
A description of the structure in ISWF is provided 
in Figure 1. The President appoints the Supervisory 
Board and the Supervisory Board appoints the Board of 
Directors. The Board of Directors  reflects in a single-
board system. In contrast, the term Board of Directors 
is not known in the limited liability company.

Based on the Limited Liability Company 



68 The Winners, Vol. 23 No. 1 March 2022, 65-71

Law on the Board of Commissioners, the Board of 
Commissioners is referred to as the assembly. All 
the decisions of the Board of Commissioners are 
made jointly. Each commissioner member should act 
based on the decision of the Board of Commissioners. 
Conversely, the Board of Directors and the Board 
of Trustees of the ISWF are not described as a form 
of an assembly. Thus, the regulation regarding 
the responsibilities of the Board of Directors and 
the Board of Commissioners needs to be further 
regulated. Directors in the Limited Liability Company 
Law recognize joint responsibility if the directors 
are proven to have contributed to an incident. The 
coordination path for the entities of a limited liability 
company is described in Figure 2.

The concept of a Board of Commissioners 
as an assembly is the similar to the structure of the 
House of Representatives (Dewan Perwakilan Rakyat/
DPR). The function of the Board of Commissioners in 
a limited liability company also resembles that of the 
DPR in the Indonesian government system. Indonesia 
adopt the dual-board management system. Therefore, 

the supervisory function belongs to a board.
In addition, the Indonesian Sovereign Wealth 

Fund (ISWF) and a limited liability company have 
similarities in terms of appointing supervisory bodies. 
ISWF has a Supervisory Board and a limited liability 
company has a Board of Commissioners. The two 
entities are appointed by the shareholders. ISWF 
has the Indonesian government as shareholders, and 
a limited liability company has shareholders who 
appoint them through the GMS.

The supervisory and the executive boards have 
the same requirements. A person who is appointed as 
a member of the supervisory and executive boards 
must never be convicted of a crime. In addition, the 
person should not have been a manager of a bankrupt 
company or one that experienced bankruptcy.

The Supervisory Board of the ISWF has the 
power to suspend the Board of Directors. The Board 
of Commissioners at a limited liability company has 
the authority to temporarily suspend the Board of 
Directors. The two councils have the same authority 
over the Executive Board. An explanation of the 

Figure 1 Organizational Structure of the Indonesian Sovereign Wealth Fund
(Source: Research Results)

Figure 2 Organizational Structure of a Limited Liability Company
(Source: Research Result)



69Corporate Governance Principles.... (Suwinto Johan)

similarities between ISWF and a limited liability 
company is described in Table 1.

Apart from having similarities, ISWF and a 
limited liability company (PT) have differences. ISWF 
has two entities, while a limited liability company 
has three entities. ISWF has a separate supervisory 
function between the Supervisory Board and the 
Board of Directors. ISWF does not have shareholders 
and the highest entity in a limited liability company 
is the GMS. Supervision of the ISWF is fully carried 
out by the Supervisory Board, which reports to the 
President’s office holders. 

The appointment of the Board of Directors at 
the ISWF is made by the Supervisory Board. The 
Supervisory Board is appointed by the President. 
Meanwhile, the Board of Directors at a limited 
liability company is appointed by the GMS. The 
Board of Directors is responsible to the GMS and 
the Supervisory Board. This is what differentiates 
these two entities in the implementation of corporate 
governance.

The Board of Directors in a limited liability 
company is an individual responsibility, not in the 
form of a board. The Board of Directors in ISWF is 
a form of assembly. Based on the definition in the 
Limited Liability Company Law, a board is a panel and 
all decisions are made by the board, not individuals. 
Whereas in the Job Creation Law, the definition of 
the assembly is not explained. It also differentiates 
institutional governance.

The number of members of the Supervisory 
Board and Board of Directors at the ISWF is determined 
by an odd number. The number of commissioners 
and directors is not determined and does not specify 
an odd or even number. An odd number will make 
it easier to make decisions since the potential risk 
of having a balanced opinion can be avoided. The 
authority of each member of the Board of Directors 
is determined by the Board. Meanwhile, the GMS at a 
limited liability company determines the authority of 
the Board of Directors. The GMS can delegate to the 
directors in deciding it. In general, the main director 
determines the division of powers of other directors.

ISWF has corporate governance which requires 
that there are no family ties within the second 

generation between fellow board members, the Board 
of Directors, and the Supervisory Board. However, 
the ISWF authorizes the Supervisory Board to 
determine remuneration. A limited liability company 
has a different remuneration system, where the GMS 
determines the remuneration of the Board of Directors 
and the Supervisory Board. The determination of 
remuneration by the Supervisory Board allows 
conflicts of interest to arise. A conflict of interest will 
result in an agency cost (Ayunitha et al., 2020). 

ISWF has good corporate governance in limiting 
the tenure of the members of the Supervisory Board 
and the Board of Directors. Each member may only 
serve for two terms. Conversely, the board members 
of a limited liability company are not limited to the 
number of terms of office. However, there are some 
state-owned enterprises (SOEs) that limit the tenure of 
the directors, one of which is Bank Mandiri.

ISWF has a unique status since it can only be 
dissolved by law. Laws can only be issued by the 
House of Representative and the President. This is 
different from a limited liability company, which can 
only be dissolved by the GMS or a court decision.

The Board of Directors at the ISWF has 
an obligation to report to the Supervisory Board. 
Meanwhile, the directors of a limited liability company 
are obliged to submit annual reports to the GMS, which 
must be reviewed by the Board of Commissioners. 

In the Limited Liability Company Law, 
directors are required to report share ownership in 
the company. Conversely, the Supervisory Board 
and Board of Directors at ISWF do not regulate 
the obligation to report share ownership. As good 
corporate governance, the Board of Directors and the 
Supervisory Board should report share ownership in 
subsidiaries or investments by ISWF. This is in order 
to have good institutional governance.

The Supervisory Board has the power to 
terminate the Board of Directors at ISWF. The Board 
of Commissioners does not have the authority to stop 
a director at a limited liability company. The Board of 
Commissioners may only be terminated temporarily. 
Permanent termination is executed by the GMS. This 
shows the existence of good corporate governance 
with the decision to appoint and terminate by the 

Table 1 Similarities between ISWF and a Limited Liability Company

No. Details Indonesian Sovereign Wealth Fund and a Limited Liability 
Company

1. Supervisory and Operational Boards Supervisory Board/ Board of Commissioners
2. Appointment of the Supervisory Board/ Board of 

Commissioners
Majority shareowner through the GMS or the President

3. Requirements for the Board of Directors/ 
the Board of Directors and the Board of 
Commissioners/ the Board of Trustees

Never been convicted or involved in bankruptcy

4. Temporarily suspend the Board of Directors/ 
Executives

Board of Commissioners/ Board of Trustees

Source: Research Results



70 The Winners, Vol. 23 No. 1 March 2022, 65-71

highest entity at a limited liability company. Table 2 
provides more comparisons of the Job Creation Law 
in ISWF and the Limited Liability Company Law.

The transfer of wealth to ISWF is not regulated 
in the Job Creation Law. Directors at a limited liability 
company have the obligation to seek approval from 
the GMS in the transfer of assets if it is more than 
50% of the company’s total assets. Every business in 
development needs funding. To obtain the funding, 
the business will transfer wealth as a guarantee of 
funding. ISWF does not regulate this, so it will remain 
in a gray area.

IV. CONCLUSIONS

 The government established the ISWF in 2021. 
It is an initiative to accelerate development, which 
has two boards, namely a Supervisory Board and a 
Board of Directors. Corporate governance in ISWF is 
different from a limited liability company. The ISWF 
boards have broader powers than the authority of the 
Board of Commissioners and Directors of a limited 

liability company. The Indonesian government needs 
to reorganize corporate governance in ISWF to attract 
investors to invest in Indonesia. The research provides 
an overview of the corporate governance structure at 
ISWF. The research provides input on the development 
of corporate governance in Indonesia. The research 
has limitations as the discussion is only based on two 
laws and one corporate governance manual. Further 
research can be developed by comparing corporate 
governance in other countries. 

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Source: Research Results



71Corporate Governance Principles.... (Suwinto Johan)

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