Codes of conduct

PTBA Code of Conduct is stated in the Code of Conduct and Business Ethics document signed by the Board of Directors and Board of Commissioners. These Guidelines are based on International Standards (United Nations Global Compact, ILO Foundation Conventions), company values, principles of business ethics and work ethics as a framework for implementing responsible business. The PTBA Code of Conduct applies to all employees, directors and commissioners. As complement to the Code of Conduct and Business Ethics, there are a number of internal policies that all employees must comply, in the form of company policies, management agreements and trade unions as stated in the Collective Labor Agreement. Implemented since 2009 and was last updated in 2018, this Code of Conduct is also applied as the basis for partnering or doing business in global markets where laws and regulations, working conditions, environmental standards and varying business ethics demand comprehensive strategies related to responsible business, business ethics, and risk management. This Code of Conduct is a minimum behavior requirement to be implemented by the entire value chains, whether PTBA as a buyer or seller.

Human Rights

PTBA has implemented the principles related to human rights, labor rights, environment, and anti-corruption since 2009. As commitment manifestation to implement these principles, PTBA plans to join as a member of the UN Global Compact in early 2021. PTBA supports and respects human rights and in its business process strives to ensure no involvement in human rights violations, such as discrimination for persons with disabilities, human trafficking, child labor, sex discrimination or abuses and slavery. PTBA also gives rights to Indigenous People around the company's operational areas through CSR programs. In evaluating company business partners, PTBA considers Occupational Health and Safety (HSE), Employment and Community Development as important aspects of the Company's Business Partners.


In June 2020 PTBA obtained the ISO 37001:2016 Certificate for Anti-Bribery Management System (SMAP) after an Audit process by the British Standard Institution (BSI). In addition, as a form of commitment to implementing the Anti-Bribery Management System (SMAP), 8 targets were set, including zero bribery cases, increasing awareness of all employees of the SMAP, and reporting of official assets to State Agencies (Corruption Eradication Commission). For SMAP implementation consistency, regular monitoring or evaluation is carried out and is reported annually through the Management Review Meetings mechanism. The company has zero-tolerance approach to bribery and corruption; the Anti-Bribery Management System Guidelines (SMAP) apply to all employees, directors and commissioners. The guidelines also apply to the Company, Subsidiaries and Affiliated Companies. In addition, PTBA has 7 derivative policies of Corporate Governance Policy in an effort to implement good governance practices, namely:

  • Holding Interaction Policy with Controlled Companies and Affiliated Companies
  • Conflict of Interest Policy
  • Insider Trading Policy
  • Goods and Services Procurement Policy
  • Risk Management Policy
  • Anti-Gratification Policy
  • Legal Compliance Policy

Ethics and Compliance

As a form of the company's commitment to implementing good corporate governance and to support the Board of Directors in ensuring Ethics, Compliance and Risk Management, several boards in BOD level has established. The functions of ethics, compliance and risk management are a collaboration of several Work Units with their respective functions, namely:

  1. Company Management System and GCG
    ● Reviewing company policies
    ● Evaluating company goals and performance
    ● Evaluating the implementation of corporate governance
  2. Corporate Secretary
    ● Publishing information disclosure and reporting to government agencies
    ● Ensuring compliance with the capital market
  3. Risk Management
    ● Identify the risk of corruption
    ● Analyzing the company's business risk
  4. Internal Audit Unit
    ● Monitoring and reporting related to ethics and compliance
    ● Investigate the substance of the reported violations

Whistleblower Channel

In 2020, PTBA updates the Guidelines and Whistleblowing System referring to the General Guidelines for GCG by the National Committee on Governance and fulfill the requirements of the ISO 37001:2016 Clause. All Employees, Business Partners and related Stakeholders can report serious or suspicious violations committed by PTBA personnel. The new Whistleblowing System Guidelines accommodate anonymous reporting and to maintain objectivity or independence, third parties may be involved to carry out investigations. The Guidelines and Whistleblowing System are updated to improve and facilitate the investigation process and to ensure the confidentiality of the complainant's personal data. If the violation is proven, disciplinary action is taken from of a warning letter to dismissal. PTBA has established a whistleblower protection mechanism to reduce concerns for the sincere complainants.

Evaluation of Business Partners

The evaluation or feasibility process of business partners with aims to ensure business partners, current and potential partners comply with regulations, is an important part of PTBA's ambition to become a responsible company. To qualify as PTBA customers or suppliers, all business partners must carry out business processes in accordance with the requirements set by PTBA and must meet a responsible business perspective. If there is a risk of non-compliance with applicable requirements, a more in-depth review of the business partner will be conducted. If the results still deviate from the prerequisites, there will be consequences such as imposing sanctions, cancellation of transactions, rejection of products or services.

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