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It further clarifies that the appointment of online training platforms as program partners and
              third-party training institutions is not a “procurement of goods and services”, but “still takes into
              account the purpose, principles and ethics of the state procurement of goods and services”.

              The new regulation is not retroactive, and stipulates that all decisions taken by the program
              management under the previous Perpres are “legitimate, as long as they were taken with good
              intentions”. The program’s Job Creation Committee is then required to evaluate the decisions.

              The provision is applicable to the appointment of partnering platforms and third-party training
              institutions, among other things.

              Perpres No. 76 also restructures and expands the Job Creation Committee that oversees the
              program, which originally consisted of six members led by the coordinating economic minister
              and the presidential chief of staff.

              The new committee has 12 members comprising the state secretary and six ministers: the home,
              finance, education, manpower, industry and national development planning ministers. The five
              remaining committee members are the Cabinet secretary, the attorney general, the National
              Police  chief,  as  well  as  the  heads  of  the  Development  Finance  Comptroller  (BPKP)  and  the
              National Procurement Agency (LKPP).

              The preemployment card program had drawn widespread public criticism over the apparent lack
              of transparency since it was launched on March 20, with an aim to provide a safety net to
              workers affected by the health crisis. The two key criticisms were that the appointment of online
              partners through a nontransparent process left it open to conflicts of interest, and that it did not
              comply with the prevailing regulation on the procurement of goods and services.

              “We welcome suggestions from all parties, including [top] institutions like the KPK, and we have
              received  many  inputs  from  the  public,  including  the  [people]  who  are  eligible  for  the
              preemployment card,” program director Denni Purbasari said on June 22.

              Earlier in June, the Corruption Eradication Commission (KPK) uncovered irregularities in the
              program, including a potential for conflicts of interest and a risk of mistargeting.

              The KPK found potential conflicts of interest in at least 250 courses provided by third-party
              institutions  that  had  ties  to  partnering  platforms.  For  instance,  partnering  platform  Pintaria
              offered  199  courses,  one-third  of  which  was  provided  by  its  parent  education  technology
              company HarukaEdu.

              By the end of June, the program was offering 3,805 courses through eight partnering platforms,
              including e-commerce giants Tokopedia and Bukalapak.

              “It should not be like this because it weakens the [course] curation,” KPK corruption prevention
              deputy Pahala Nainggolan said on June 19.

              Denni said at the time that the program management had issued a public call for expressions
              of  interest.  Nineteen  firms  had  responded  the call,  said  the preemployment  card  program’s
              director.

              The  preemployment  card  was  one  of  Jokowi’s  reelection  campaign  promises  and  originally
              designed as an upskilling and reskilling program. As the global health crisis started impacting
              the economy and led to job losses when companies downsized in response, the government
              redesigned it into an incentivized training program as part of its COVID-19 safety net strategy.




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