Testing the Public Officials’ Integrity in the Moonlighting of State-Owned Company Commissioner

Conflict of interest is related to fraud and corruption, whose sources include the following, (a) concurrent positions or moonlighting, (b) public sector non-cooling off work/business activities post-employment, (c) work and personal business interests of family, friends, and associates, (d) affiliate relationship of community groups, organizations, and political aspirations. Therefore, this study aimed (1) to develop a catalogue of laws and regulations implicitly and explicitly prohibiting state officials or government employees from implementing moonlighting. It indicated the explicit prohibition of moonlighting against interfering with the conditions causing conflicts of interest. It also aimed (2) to examine the moonlighting of SOE commissioners through state officials. In this analysis, SOE was selected as the sample due to being simultaneously regulated by various policies prohibiting conflicts of interest and moonlighting. The sample was also exchange-listed because of the obligation to disclose information in the Capital Market Law as an Annual Report, where the profiles of the Commissioner members were often showcased. The results showed that moonlighting was unacceptable by public officials as commissioner members, regarding the compiled catalogue.


INTRODUCTION
A business organization is mostly challenged by corruption and fraud, which often originates from the government, State-owned Enterprise, as well as private, non-profit, and other companies, at 48.5%, 31.8%, 15.1%, 2.9%, and 1.7%, respectively (ACFE Indonesia Chapter, 2020). This analysis theoretically showed an agentprincipal problem in state organizations and SOE, indicating the difference between the interests of the manager (agent) and the organization owner (principal). From this context, a conflict of interest form emphasizes moonlighting. In the public service sector, a total of 397 moonlighting public officials are reportedly observed as SOE commissioners,with 254,112, and 31 of them originating from ministries, nonministerial institutions, and academics, respectively (Ombudsman Republik Indonesia, 2020). Regarding Business Competition Supervisory Com-mission (2021), numerous moonlighting analyses were explored between SOE Directors/ Commissioners and the non-SOE companies within various sectors, such as (i) finance, insurance, and investment (31 Directors/Commissioners), (ii) mining (12 Directors/Commissioners), and construction (19 Directors/Commissioners).
Based on Table 1, inflated outputs were observed because of the various definitions of State-owned Enterprise. The SOE holding program is a privatization program that changes the legal entity into mere Persero (Limited Liability) Companies. As quoted from idxchannel.com, the SOE Minister's statement, "We have succeeded in reducing the number of companies from 142 to 41", confirmed that this program encompassed the privatization of SOE. This confirmation is subsequently supported by the 101 non-SOE Persero Companies claiming to be State-owned enterprises. Since other parties have replaced state ownership, the prefix/suffix "Persero" is then lost, with the SOE Law becoming unreferenced to the articles of association and corporate governance. For example, Perkebunan Nusantara (PTPN), Gas Negara, Kimia Farma, Bukit Asam, Aneka Tambang, Timah, and Indofarma are merely Limited Liability Companies and not SOE.
Although various apologia is reportedly postulated, the public officials performing commissioner moonlighting still obtain time from their original institutions. In this case, the State-owned Enterprise often finance part-time jobs massively, due to being filled with the officials acting as commissioners. The moonlighting of ministry or non-ministry officials and academics subsequently emphasize an affiliation relationship, where the concerned commissioners commonly work in favour of the SOE. Under these conditions, the loyalty of these public actors is mostly ranked and authorized, with one of them prioritized over others. This provided priority focuses on the duties at the original institution or university or SOE. From this description, a potential is observed for information seepage, through the original organization (as regulator) to the State-owned Enterprise (as industry operator), or vice versa. Moreover, the moonlighting-based SOE requires a special favourable regulation, indicating that the affected commissioners are likely to propose organizational regulationmaking procedures. This explains that moonlighting is capable of distorting fair business competition, which promotes the ICC (Indonesia Competition Commission) to explore the company issue.
This study aims to develop inventory of laws and regulations explicitly and implicitly prohibiting moonlighting. The analysis is carried out through the conflicts of interest prohibition within the framework of stufenbautheorie, adopted by Indonesia as stated in Law Number 12/2011 on Legislation Establishment. In Article 7 paragraph (2), the principle of lex superiori derogat legi inferiori stated that "The legal force of laws and regulations is appropriate to the hierarchy, as referenced in pg. (1)". This derogation norm is the most effective method used to avoid interpretative differences, due to its explicitness in providing solutions through the valid legal force between 2 or more conflicting standards (Nurfaqih Irfani, 2020).

LITERATURE REVIEW AND HYPO-THESIS
The business form was initially similar to "Ma 'n Pa' Grocery", regarding the consideration of both owners and managers. However, many problems have reportedly originated since the adoption of the corporation form, which separates ownership from management. Regarding this issue, Ambrose Bierce, a journalist, published The Devil's Dictionary in 1906. This publication emphasized the satirical expressions and definitions of common words, to capture and expose social phenomena within American society in the early 20th century. In this dictionary, CORPORATION was defined as an ingenious device for obtaining individual profit without personal responsibility.
Twenty-five years after Ambrose Bierce's publication, a "journal war" was observed in 1932 between Adolf Augustus Berle Jr. and Edwin Merrick Dodd, which prioritized shareholders and stakeholders, respectively. These scholars subsequently reconciled after a while, through a common wedge that the business owner (shareholder) often provided authority to the organizational management. Since the management and employee commonly cheat and steal, a supervisory institution was then developed to sit with managers at one table known as the Board of Directors. In this development, the supervisors and managers were referenced as nonexecutive and executive directors. From this description, the supervisors need to carry out daily supervision because the managers frequently work and cheat regularly. Therefore, supervision is considered a full-time job and not part-time work. According to Jensen and Meckling (1976), the intersection of Berle and Dodd's opinions was rewritten and titled "Agency Theory", where a company's owner and manager were referenced as the principal and agent, respectively. The relationship between these parties was also filled with agent-principal problems, leading to various agency costs.
The occurrence observed in the early 20th century (l'histoire se répète) was then repeated in the early 21st century regarding corporate scandals, such as Enron, WorldCom, etc. During this period, an intertwined scientific taxonomy was emphasized, where securities and corporate law with financial recording and reporting techniques were observed. This led to the provision of a functional name, known as corporate governance.
Based on the trust provided by the GMS organ and not the interests of individual shareholders, the Board of Commissioners and Directors carried out their respective duties. In this process, both organs need to be bonafide in performing their duties for organizational benefits only. Regarding Law Number 40/2007 on Limited Liability Companies, fiduciary duties were commonly attached to each of the directors and commissioners, as regulated in Articles 97 and 114, paragraph 2, respectively. Table 2, the difference between the two Limited Liability Companies organs emphasized the prudential principles used by the board of commissioner members to implement fiduciary duties.

Based on
Article 114 paragraph (5) of the Company Law also stipulated the conditions guiding the Board of Commissioners against the liability of losses. This stipulation is similar to that of paragraph (3) and useful "when it is able to prove" the following, (a) Appropriate supervision in good faith and prudence for only organizational benefits, based on the set purposes and objectives, (b) No direct or indirect personal interest in the management of the Board of Directors causing the loss, and (c) Adequate Based on Caliph Umar bin Abdul Azis (682-720 AD) that turned off the oil lamp every time personal matters were assessed, the patterns by which conflicts of interest need to be avoided were adequately explained. This was due to the observation of the issue as a form of corruption often performed without the knowledge of the actor. It is also considered a norm that includes the use of state or company facilities (office supplies, telephone, internet, and car) and working time for personal purposes. Furthermore, conflicts of interest have reportedly caused bias in decision-making processes (Moore, Tanlu and Bazerman, 2010), and have affected thinking procedures (cognitive) through two patterns, namely conscious and subconscious (self-interest). This issue is declared as "human nature" when a moral dilemma is observed, indicating that individuals prioritized personal interests over common or organizational goals. Although these moral selections are not developed in sterile conditions, they are still part of social interaction, leading to the emergence of "collusion" and "nepotism". In this case, decisions commonly depend on social motives, such as showing loyalty, maintaining trust, and returning favours (Moore and Loewenstein, 2004).
From these descriptions, conflict of interest is a significant issue that affects ethics by distorting decision-making processes and generating destructive organizational consequences. This issue is mostly observed in various types, with Cossin and Lu (2017) categorizing it into 4 tiers, where the occurrence of moonlighting was ranked as a tier-I conflict. Regarding this explanation, tier-I conflicts of interest are the actual or potential issues found between the board members (directors and commissioners in civil law) and the corporate organization. This simple concept indicates that directors should not capitalize on the personal interests attached to their organizational positions. As the primary decision-makers in the organization, the board members only need to act in the interest of the company owners. Subsequently, the key conflicts of interest include setting salaries and benefits, misusing company assets, selfdealing, insider information and trading, as well as neglecting board work. Directors and board members are also expected to always act ethically, promptly disclose material facts/potential issues, and perform appropriate corrective action. In this case, the organizational organs that fail to dedicate their efforts, commitment, and time to their work, often constitute a conflict between themselves and the company. For example, the moonlighting performance of directors or commissioners in several companies to gain personal benefits from remuneration and compensation packages is a conflict of interest form.
In tier-I, conflicts of interest are commonly inherent within individual actors, leading to the immediate portrayal of their integrities. The embodiment of a member's integrity also falls within the domain of "official ethics", both in the private (corporate organizations) and public (government/public service organizations) spheres. One of the key principles of public service is the subordination of private interests under governmental goals. In this case, the failure to perform is a major cause of most unethical behavior in the public sector. Furthermore, conflicts of interest often occur in situations where public officials have personal or other goals, such as influencing the impartial and objective performance of their organizational duties. Public ethics also reflects the standards or norms determining the good-bad and right-wrong values of the individual policy actors' behaviours, actions, and decisions. These actors are mostly the state administrators to exponents of corporate organs. In Indonesia, a state organizer actor is bound by the General Principles of Good Governance (GPGG). This principle is used as a reference during the implementation of authority for government officials, regarding issuing a one-time decision (einmalig beschikking) and developing a continuous regulation (dauerhaftig regeling) within the public administration (Soeprapto, 2007).
Individual actors of state administrators are defined in several policies, including Law Number 28/1999 on Clean and Free Administration from Corruption, Collusion, and Nepotism. In the general provisions of this Law, State Administrators are the Officials that carry out executive, legislative, or judicial functions. Their main roles and duties are also related to the administration of the state, concerning the appropriate provisions of applicable laws and regulations. As explained in Article 2, State Officials emphasized the following, (1) Highest State Institution, (2) High State Institutions, (3) Ministers, (4) Governors, (5) Judges, (6) Individuals applicable by laws and regulations, and (7) Other officials with appropriate strategic functions. In this context, the phrase "other officials with appropriate strategic functions", prioritized the organizational organs whose duties and authority in carrying out state administration were prone to practices of corruption, collusion, and nepotism. These officials included the following, (1) Directors, Commissioners, and other structural organs at State and Regional-Owned Enterprises, (2)

Head of Bank Indonesia and National Banking Restructuring Agency, (3) Heads of State Universities, (4) Echelon 1 and equivalent officials in the civil, military, and Indonesian Police, (5) Prosecutors, (6) Investigators, (7) Court clerks, and (8) Project leaders and treasurers.
According to Law Number 37 of 2008 on the Indonesia Ombudsman, public services were organized by state and government officials, including those coordinated by SOE, ROE, and private entities. They were commonly assigned to organize specific public services, with some or all sourced from the State and Regional Budgets. Law Number 14/2008 on Public Information Disclosure also indicated that Public Institutions were executive, legislative, judicial, and other sources, whose main functions and duties prioritized the administration of the state. In this case, part or all of its funds originated from the State/ Regional Revenue and Expenditure Budget, public donations, or abroad.
From these aforementioned laws, a "Public Official is a person that occupies a specific position in government and nongovernment institutions, whose functions emphasized the administration of the state. In addition, the fund source originates from the State and Regional Budgets". Regarding the treasury of policies at the level of the Law, a prohibition of moonlighting was explicitly (per se) and implicitly observed through the conflicts of interest restriction after inventory performances. Subsequently, this observation was carried out through affiliate relationships in general policy, such as government administration, public services, and limited liability companies. The moonlighting prohibition was also observed through the associations in specific laws, including State civil apparatus, Indonesian Armed Forces and Police, Lecturers, SOE, and capital markets.
Based on Table 3, besides the aforementioned legal materials, the prohibition against moonlighting is also contained in the hierarchy of the laws one level lower than the government or high state institution regulations, for example, a. In Indonesia, "integrity" is a popular term since the signing of the Pact was declared mandatory for officials, civil servants, and state apparatus, through the Regulation of the Minister for Administrative and Bureaucratic Reform Number 49 of 2011. This prioritizes the General Guidelines for Integrity Pacts within Ministries/Agencies and Local Governments. It is also accompanied by a 7-point Pact format, which includes (1) playing a proactive role in preventing corruption, collusion, and nepotism, as well as not involving oneself in disgraceful acts, (2) not directly or indirectly asking for or obtaining gifts in the form of bribes, presents, assistance, or other forms, (3) being transparent, honest, objective, and accountable in task performances, (4) avoiding conflicts of interest in carrying out tasks, and (5) setting an example in compliance with the policies of task performance.
Law Number 14 of 2005 concerning Teachers and Lecturers has also provided guarantees for the adequacy of professorship income, leading to the support for the implementation of moonlighting and conflicts of interest. Based on the Regulation of the Finance Minister Number 164/PMK.05/2010, a professor is expected to obtain professional and honorary allowances of 1 and 2 times the basic salary, respectively. In this case, a mistake is immediately claimed and categorized when a professor implements moonlighting, due to violating public ethics through greed. This is in line with Gebhard Kirchgässner (2014), where "moneygrubbing" or "money-seeking" was easily found in the academic community, whose currency is reputation. From this context, the behaviour of several leading economists during the financial crisis was responsible for the greedy attitude. In this case, they often risked their reputation as independent scientists by obtaining large sums of money from the industry in exchange for writing supportive scientific papers for them. This was in line with A Report on Harvard's Enron Entanglements, as quoted by da Silveira (2013). Therefore, moonlighting is unable to be carried out with a Lecturer Workload of at least 12 to 16 credits per semester, except by stealing time or manipulating efficiency forms.
Besides integrity being easily emphasized, its meaning is also very easy to reduce. In this case, many definitions are observed for the term, including those available on Merriam-Webster as follows, 1: company adherence to a code of specifically moral or artistic values (INCORRUPTIBILITY), 2: an unimpaired condition (SOUNDNESS), and 3: the quality or state of being complete or undivided (COMPLETENESS).
In one of the seminal, Jensen, Erhard, and Zaafron (2009) attempted to convey the idea that integrity was a positive model, regarding the combination of three normative phenomena, such as morality, ethics, and legality. It was also known as a positive model due to its describing behavioural patterns, with other scholars referencing it as an approach capable of being empirically tested. Subsequently, morality, ethics, and legality were considered normative phenomena, regarding their emergence from the standards determining desired or undesired behavior.
A year after the publication of the Minister of State Apparatus Empowerment and Bureaucratic Reform Regulation Number 49 of 2011, No. 37/2012 of the same policy was issued, concerning General Guidelines for Handling Conflicts of Interest. This regulation explained that 11 forms of conflict of interest commonly encountered included the following, (1) the use of office/agency assets for personal gain, (2) the use of office/agency confidential information for private benefits, (3) moonlighting that causes the utilization of one position for the benefit of another, (4) granting special access to specific parties in the auction for goods and services procurement, and (5) moonlighting or outside employment asides from the main job. In this case, moonlighting or outside employment was the main source of the conflicts of interest, due to its frequent recurrence. This regulation has reportedly not considered the United Nations Convention Against Corruption (2004), which includes postemployment work/business activities in the public sector, without going through cooling-off periods.
Since integrity is defined as the quality/ state of being complete or undivided, moonlighting is then an unclean (mala per se) behavior that should be prohibited (mala prohibita). For example, a director general of a ministry or a professor doubling as a company commissioner often tend to encounter difficulties when answering questions emphasizing the SOE or institution they are employed with. In this case, the affected person is declared not to have met the completeness criteria irrespective of the answers provided.

METHODS
This doctrinal legal analysis was only aimed at written regulations or other legitimate materials (Soekanto & Mamudji, 2004), and began with an inventory of positive laws, principles, and constitutional philosophy (Wiradipradja, 2016). In this analysis, an authoritative primary material containing legislation, official records, and policy decisions obtained from the National Legal Documentation and Information Network was used (https://jdihn.go.id/). The publication of the Annual Report (https:// idx.co.id/perusahaan-tercatat/laporankeuangan-dan-tahunan/) accountable to the GMS available on the Indonesia Stock Exchange's website was also included in the primary data. Meanwhile, the secondary material included textbooks, legal journals, and related Ministry websites. After the collection of these materials, all the laws and regulations regarding the concerned legal issues were reviewed using a statute approach (Marzuki, 2014).
The consideration of the analytical focus was the moonlighting of the commissioners at public SOE, which contained the word "persero" (company) in its name. Besides, the state was also the majority shareholder and subject to the SOE Law. Since public state-owned enterprise differed from other business organizations, it was then simultaneously bound to various Laws (Appendix 1) and Government Regulations. In this analysis, two sample choices were observed, namely (1) the public SOE companies that are the constituent components of the IDXBUMN20 index, and (2) the stock information data available on https:// bumn.go.id/investor/stock. From this context, option (1) was completely ruled out because of the naming inconsistency, by including 2 public SOE and "grandchildren" of SOE. Based on the legal fact that "SOE was only bound by Law Number 40 of 2007 concerning Limited Liability Companies", screening was subsequently carried out to determine the appropriate state-owned enterprise. This process emphasized 14 SOE, with the rest being the limited liability companies only subject to the Company Law.
An examination was also carried out on the 2020 Annual Report of the 14 public SOE. In this survey, the results obtained were subsequently confirmed by the data available on the website of each ministerial or non-ministerial state institution. This was to ensure whether the members of the commissioners were Public Officials or not. Based on Table 4, the names of the members were re-screened with the data available on the Higher Education Database, specifically the academics, through the website, https://pddikti. kemdikbud.go.id/.

RESULTS AND DISCUSSION
Based on the results (Figure 1), 63 moonlighting activities were conducted at the 14 public SOE companies with 105 members of the board of commissioners. This indicated that a total of 30, 23, and 10 of these activities were carried out by the Ministry, Non-Ministry, and Nonstate civil apparatus, respectively. In this case, 13 of the 63 moonlighting was also performed by professors/lecturers.
Regarding the observations on the 2020 Annual Report of the 14 public SOE, a systematic failure was found to understand the term "affiliated relationship". For example, a person was described as the Inspector General of the Ministry of Public Works and Public Housing, as well as other position column. However, the description in the affiliation column was filled with "Has no association with other members of the Board of Commissioners, Directors, or Major/Controlling Shareholders". Since Law Number 17 of 2003 stipulated that SOE assets were part of state finances, every Public Official and Special Staff of the Minister automatically obtained According to the results, the term, "Ministerial Special Staff", was described.
To determine the appropriate description of this term, a reference was used in the form of Presidential Regulation Number 68 of 2019, concerning the Organization of State Ministries. In this regulation, the special staff were not directly appointed by the Minister, although they were nominated by the President. When the President declared approval, the relevant Minister was then permitted to issue a Decree of Appointment. From these results, the basic difference between the concerned Ministerial organs proved that the Expert Staff was an organic position, one unit with the institutional organization of the ministry. It was also a state civil apparatus with an Admiral Middle High Leadership Position. Meanwhile, the Special Staff was not included in the Admiral or Primary High Leadership Position varieties. Even when they were not included in the High Leadership Position, the financial rights and other facilities still showcased maximum equivalents to the Admiral group and were paid from the State Budget. In this case, a Ministerial Special Staff was described as any individual not bound by Law Number 5 of 2014 concerning the State Civil Apparatus. This included those paid through the State Budget despite not carrying out the oath of a federation civil apparatus. Subsequently, new nomenclatures, namely "Ministerial Expert and Assistance Team", as well as "Professional Advisors", did not have references to regulatory provisions.
Moonlighting was found by the state internal supervisory apparatus, regarding Article 49 of Government Regulation Number 60/2008 concerning the Internal Control System. This included the echelon 1 officials of supervisory agencies, namely 1 inspector general of the Ministry of Public Works and Housing, as well as 2 echelons 1a staff of the BPKP (FDSA). Moonlighting by Ministry and Non-Ministry state civil apparatus was also entirely carried out by echelon 1 or officials one level below the Minister, namely (1) Director, Secretary, and Inspector General, (2) Main Secretary of the Agency, (3) Deputy Minister, and (4) Deputy Agency. Meanwhile, the activity by non-state civil apparatus, Ministerial Special Staff, and academics were intertwined with up to 3 or 4 varieties. For example, a professor concurrently implemented the positions of Study Program Director and Head of the Center at a university, and also served as an Expert Advisor in a non-ministerial agency. In this case, the performances of the professor in teaching, supervising, analyzing, and carrying out all assigned duties at every position held were unimaginable. Another moonlighting also claimed to be a professor, although the name was not found in the Higher Education Database.
According to Government Regulation Number 45 of 2005, moonlighting in an SOE was understandable when companies were observed as Perusahaan Umum (Perum) entity, regarding the stipulation in Article 49. This stipulation was subsequently a form of the prohibition against moonlighting, as a public official under the technical ministries and Ministy of Finance (echelon 1) in the SOE companies. From this context, all the public officials nominated and elected by the Attorney of SOE Shareholders to become members of the Board of Commissioners in the state-owned enterprise did not abide by the Government Regulation Number 45 of 2005.
The Deputy Minister of SOE was also found to be a commissioner of Bank Rakyat Indonesia. Commissioner of public SOE also caused difficult experiences for company auditors, as well as the regulators and supervisors of the industrial sector. This was because the regulated, supervised and inspected parties were the companies where the shareholders' power of attorney depended on the organ of the board of commissioners (Appendix 2).
Based on the results, 2 FDSA leaders met the criteria for Article 4 of Presidential Regulation Number 192/2014, namely commissioners at Krakatau Steel and Pembangunan Perumahan. Meanwhile, the main duties of the FSDA were the implementation of audits, reviews, evaluations, monitoring, and other supervisory activities on the planning, implementation, and accountability of state/regional. Their duties also emphasized revenue and state/regional financial expenditure accountabilities, as well as national development. Subsequently, they prioritized other activities, whose finances were wholly or partly funded by the state/ regional budget and subsidies, including the business entities where various interests of the Central and Regional Governments were embedded. This Presidential policy was also a derivative and technical guidance from Government Regulation Number 60/2008, concerning the Internal Control System. In addition, Article 49 of this Regulation explicitly stated that the government's internal control apparatus included the FDSA (Appendix 2).
According to the perspective of morals, ethics, and the General Principles of Good Governance, moonlighting was prohibited. This activity was explicitly prohibited through 7 laws and regulations in the policy hierarchy, namely (1)  In this explanation, "The prohibition of moonlighting aimed to optimize the implementation of tasks and achieve organizational performance". Regarding Article 98 of this Government Regulation, functional officials were also prohibited from performing moonlighting with Administrative or High Leadership Positions. However, restrictions were not implemented for the positions whose competence and field of duties were similar and inseparable from FP (Functional Positions).
The results also showed that 2 former FSA officials were found at Bank Rakyat Indonesia (BBRI) and Bank Mandiri (BMRI). Despite this observation, no prohibition was still legally stipulated for former FSA officials to work anywhere after leaving the organization. This included becoming a commissioner of a Public Company, which was likely to be carried out after observing a cooling-off period, as stated in Article 12 of the United Nations Convention Against Corruption in the following verbatim: preventing conflicts of interest by imposing restrictions, as appropriate and for a reasonable period of time, on the professional activities of former public officials or on the employment of public officials by the private sector after their resignation or retirement, where such activities or employment relate directly to the functions held or supervised by those public officials during their tenure. Based on this stipulation, the prevention of conflicts of interest should be performed by appropriately imposing restrictions on the professional activities of former public officials after their resignation or retirement. This convention had been ratified as Law Number 7 of 2006 concerning the Ratification of the United Nations Convention Against Corruption 2003 as a regulation. In this case, the stipulation explicitly prohibited all forms of moonlighting by public officials, even for those that had retired, until the coolingoff period was over.

CONCLUSION
According to the results, weaknesses were observed in the following, (1) the internal control and supervision (inspectorate) functions within each ministry/nonministerial institution, (2) the low supervision function by the FDSA in the originating agencies, and (3)  concerning Government Administration, which had become a powerful rule by not enforcing regulations against position trap actors. This was slightly similar to the State Civil Apparatus Commission, which did not carry out its main functions, including the implementation of basic norms, codes of ethics and behavior. Besides, it also had functions as the implementation of the merit system in policy and management within government agencies. Based on these results, the state was harmed by the moonlighting of public officials as commissioners, which were paid remuneration. Performance and honorary allowances were also very expensive for the size of the main job partly performed due to the subsequent services as a commissioner. Moreover, Public SOE was disadvantaged in paying honorariums, allowances, facilities, and bonuses for the part-time job of the commissioners and vice versa. The climate of healthy business competition was also disrupted by the officials regulating the industry with their interests as commissioners in Public SOE. In response to these disruptions, moonlighting was prohibited. At the same time, this prohibition was a form of the conflict-of-interest arrangement selected by the state, through the laws that explicitly and implicitly restricted moonlighting. In this case, the moonlighting of the public officials issued in the 14 Public SOE showed a lack of integrity caused by ignorance or incompetence. From this context, ignorance is an insubordination jointly carried out by the following, (1) the attorney power of Public SOE Shareholders that nominated and elected public officials to become commissioners, (2) the concerned public officials willing to be nominated and elected, and (3)  These laws prohibit affiliation, inside information, and insiders. In this case, affiliate is defined as follows: a. The family relations due to second-degree horizontal and vertical marriage and heredity, b. The relationship between the Party and the employees, directors, or commissioners, c. The relationship between two companies, where one or more members of the same Board of Directors or Commissioners are observed, d. The direct or indirect relationship between the companies and the authoritative Party, e. The relationship between two companies directly or indirectly controlled by the same Party, f. The relationship between the companies and major shareholders 2 Law Number 40 of 2007 concerning Limited Liability Companies No verse or article prohibits moonlighting, although every sentence or word "interest" that is an Amar (command), is always accompanied by "company". Meanwhile, "interest", as a prohibition in all sentences, is always followed by the word "personal". Every word, "conflict of interest", is stated in the prohibition sentence. This shows that the prohibition substance of the company organs is inputted into a conflict of interest situation, such as prioritizing personal interests over organizational goals.

Law Number 5 of 2014 concerning State Civil Apparatus
The law does not regulate the permissibility or prohibition of moonlighting, although state civil servants need to adhere to a code of ethics or behavior. These ethics include safeguarding against conflicts of interest when carrying out duties. They also emphasize the appropriate use of internal information, tasks, status, power, and position, to obtain or seek profit for oneself or others.

Law Number 30 of 201concerning Government Administration
In this Law, conflict of interest is defined as the condition of a Government Official, which has a personal interest to benefit themselves or other people in the use of authority. This condition subsequently affects the neutrality and quality of the Decisions or Actions performed. In Article 43, the background of the conflict of interest indicates the following, (a) a personal or business interest, (b) relationships with relatives and family, (c) association with the representatives of the involved parties, (d) a relationship with the organ working and obtaining a salary from the party involved, (e) association with other parties prohibited by the provisions of laws and regulations. In this Law, moonlighting is prohibited based on the control of the market for specific goods or services. This often leads to monopolistic practices or unfair business competition. As regulated in Article 26, a company director or commissioner is prohibited from concurrently serving another enterprise when the following features are observed for both organizations, Present in the same relevant market, Possess a close relationship in the field and type of business, Collectively control the market share of specific goods or services, leading to monopolistic practices and unfair business competition. This law explains that lecturers are professional educators. In this case, a professional is defined as a job or activity that became a source of income for a person. This activity often requires the expertise, skills, or abilities to meet specific quality standards and education. In carrying out professional duties, lecturers are required to earn income above the minimum living needs and social welfare guarantees. These requirements include basic salary, attached allowances, professional, functional, special, and honorary incentives, as well as additional related benefits. The phrase, "an income above the minimum living needs", also emphasizes the monetary values sufficient to reasonably meet the needs of teachers and their families, including clothing, food, shelter, health, education, recreation, and old age security.
Source: Data Processed