Good Corporate Governance
| Part | Item | Company Practice in 2023 | Source Information |
| A.1 | Basic Shareholder Rights | ||
| A.1.1 | Does the company pay (interim and final/annual) dividends in an equitable and timely manner; that is, all shareholders are treated equally and paid within 30 days after being (i) declared for interim dividends and (ii) approved by shareholders at general meetings for final dividends? In case the company has offered Scrip dividend, did the company paid the dividend within 60 days. |
PTBA pays dividends in an equitable and timely manner. All shareholders are treated equally and paid within 30 days after being declared and approved by shareholders at general meetings for final dividends. As disclosed in Summary of Minutes of the AGMS for Financial Year 2023, Schedule and Procedure of Cash Dividend Distribution, page 10 Date of AGMS: 8 May 2024 Date of cash Dividend Payment for Financial Year 2023 : 7 Juni 2024 PTBA has not offered Scrip dividend, therefore the company did not pay the Scrip dividend.
1. Summary of Minutes of an Annual General Meeting of Shareholders for 2023 Financial Year, Schedule and Procedure of Cash Dividend Distribution 2. IDX Website |
1. Summary of Minutes of an Annual General Meeting of Shareholders for 2023 Financial Year, Schedule and Procedure of Cash Dividend Distribution, page 10 https://www.ptba.co.id/uploads/ptba_pengumuman/20240510192448-2024-05-10ptba_pengumuman192445.pdf
2. IDX - Company Profile - Calendar (Listed companies > Company Profiles > PTBA > Calendar > June 2024) https://www.idx.co.id/en/listed-companies/company-profiles/PTBA |
| A.2 | Right to participate effectively in and vote in general shareholder meetings and should be informed of the rules, including voting procedures, that govern general shareholder meetings. | ||
| A.2.1 | Do shareholders have the opportunity, evidenced by an agenda item, to approve remuneration (fees, allowances, benefit-in-kind and other emoluments) or any increases in remuneration for the non-executive directors/commissioners? |
Shareholders have the opportunity evidenced by an agenda item, to approve remuneration (fees, allowances, benefit-in-kind and other emoluments) or any increases in remuneration for the non-executive directors/commissioners. In the Summary of Minutes of the AGMS for Financial Year 2023, includes agenda items related to the approval of remuneration or remuneration increases for the Board of Directors and Board of Commissioners. In the Summary of Minutes of the AGMS for Financial Year 2023, Third Agenda Item Meeting include the Determination of Remuneration (salary/ honorarium, facilities, and benefits) of 2024 and Bonus (tantiem) for the 2023 Fiscal Year for the Board of Directors and Board of Commissioners.
Resolutions 1. Granting the authority and power to PT Mineral Industri Indonesia (Persero) as the majority Series B Shareholder in the company with prior consultation with Series A Dwiwarna Shareholders to determine the following for the members of the Board of Commissioners: a. Tantiem/ Peerformance Incentive/ Special incentive for 2023 Financial Year and/or Long term incentive of the 2024-2026 Financial Year, in accordance with the applicable regulations; and b. Salary, benefit and facilities for the 2024 Financial Year.
The information is stated in: Summary of Minutes of an Annual General Meeting of Shareholders for 2023 Financial Year, 3rd Agenda |
Summary of Minutes of an Annual General Meeting of Shareholders for 2023 Financial Year, 3rd Agenda (Page 7) https://www.ptba.co.id/uploads/ptba_pengumuman/20240510192448-2024-05-10ptba_pengumuman192445.pdf |
| A.2.2 | Does the company provide non-controlling shareholders a right to nominate candidates for board of directors/commissioners? |
PTBA provides shareholders a right to nominate candidates for board of directors/commissioners. Series A Dwiwarna are shares that are specially owned by the Republic of Indonesia which grant the holder special rights namely: 2 . The right to nominate Candidates for Members of Board of Directors and Candidates for Members of Board of Commissioners; Shareholders has the opportunity, as evidenced by agenda items, to nominate candidates for board of directors/commissioners. Based on Announcement for the Annual General Meeting of Shareholders of PT Bukit Asam Tbk on May 8th 2024, The Shareholders may propose the Meeting agenda subject to the fulfilment of the requirement provisions of Article 16 of POJK No.15/1010 and Article 23 paragraph (6) of the company's Articles of Association. one of the agenda that Shareholders can propose is nominated candidate for Board of Directors/Commissioners to changes in the Composition of Company’s Management.
1.Announcement Annual General Meeting of Shareholders PT Bukit Asam Tbk for 2023 Financial Year - Point 3 2. Annual Report 2023 |
Annual Report 2023 (Page 141)
Announcement Annual General Meeting of Shareholders PT Bukit Asam Tbk for 2023 Financial Year - Page 2-3 - Poin 3 https://www.ptba.co.id/uploads/ptba_pengumuman/20240506102748-2024-05-06ptba_pengumuman102747.pdf |
| A.2.3 | Does the company allow shareholders to elect directors/commissioners individually? |
PTBA allows shareholders to elect directors/commissioners individually. Referring to the Summary of Minutes of an Annual General Meeting of Shareholders for 2023 Financial Year, dated 8 May 2024, Fifth Agenda, Changes in the Composition of Company’s Management, state: "there was no proposal in the changes of company's management " In the Summary of Minutes of an Annual General Meeting of Shareholders for 2022 Financial Year dated 15 June 2023 (7th agenda), the voters choose to approve, abstain or not approve the changes of management of the company (changes in 3 candidates nominated by Series A Dwiwarna shareholder).
1. Summary of Minutes of an Annual General Meeting of Shareholders for 2023 Financial Year 2. Summary of Minutes of an Annual General Meeting of Shareholders for 2022 Financial Year |
1. Summary of Minutes of an Annual General Meeting of Shareholders for 2023 Financial Year https://www.ptba.co.id/uploads/ptba_pengumuman/20240510192448-2024-05-10ptba_pengumuman192445.pdf
2. Summary of Minutes of an Annual General Meeting of Shareholders for 2022 Financial Year https://www.ptba.co.id/uploads/ptba_pengumuman/20240507104812-2024-05-07ptba_pengumuman104811.pdf |
| A.2.4 | Does the company disclose the voting procedures used before the start of meeting? |
PTBA discloses the voting procedures use before the meeting begins. As stated in the Invitation to the AGMS 2024, the electronic voting process takes place through the eASY.KSEI application using the E-Meeting Hall menu, and Live Broadcasting sub-menu. Shareholders or proxies who attend alone or are represented by their proxies but have not yet cast their votes on the agenda items of the Meeting as referred to in Note point 10 letter a number i-iv, the Shareholders have the opportunity to submit their vote during the voting period on The E- Meeting Hall screen through the EASY.KSEI application opened by the Company. When the electronic voting period per meeting agenda item begins, the system automatically runs the voting time by counting down to a maximum of 5 (five) minutes. During the electronic voting process, the status "Voting for agenda item no [] has started" will be seen in the 'General Meeting Flow Text' column. If the Shareholders or their proxies do not vote for certain agenda items of the Meeting until the status of the Meeting as shown in the 'General Meeting Flow Text' column changes to "Voting for agenda item no [] has ended", it will be considered as voting to Abstain for the agenda item of the meeting concerned. Voting time during the electroning process is the standard time set in the easy.KSEI application. The company may determine the time policy for direct viewing electronically per agenda item of the meeting (with a maximum time of 5 minutes per agenda item of the meeting) and this will be stated in the rules of conduct for the meeting through the easy.KSEI application.
Invitation to the AGMS 2024 - Voting Process |
Invitation to the AGMS 2024 - Voting Process - Page 5 - Poin C. Voting Procedure https://www.ptba.co.id/uploads/ptba_pengumuman/20240416162758-2024-04-16ptba_pengumuman162748.pdf
Code of Conduct AGMS 2023 https://www.ptba.co.id/uploads/ptba_pengumuman/20240506102734-2024-05-06ptba_pengumuman102732.pdf
|
| A.2.5 | Do the minutes of the most recent AGM record that the shareholders were given the opportunity to ask questions and the questions raised by shareholders and answers given recorded? |
The minutes for the Company's last AGM includes a record of the questions raised by shareholders during the meeting, along with the responses provided. The Company's shareholders are given the opportunity to ask questions at the GMS using the procedures as stated in Invitation to the AGMS 2024. Chairman of the
meeting will provide
opportunities to
shareholders or
their proxies to
raise questions
and/or opinions in
relation with the
meeting Agenda
before resolutions
being taken.
Chairman of the
meeting will read
out and answer
questions/ respond
to each opinion one
by one. If
necessary, the
chairman of the
meeting may let
members of the board
of commissioners,
members of the board
of directors,
executive officers
of the company or
the supporting
professional of the
meeting answer or
respond to questions
and/or opinions. The information is stated in: 1. The Minutes of an Annual General Meeting of Shareholders for 2023 Financial Year 2. Invitation Annual General Meeting of Shareholders PT Bukit Asam Tbk for 2023 Financial Year 3. Code of Conduct AGMS for 2023 Financial Year https://www.ptba.co.id/uploads/ptba_pengumuman/20240416162832-2024-04-16ptba_pengumuman162828.pdf |
1) The Minutes of an Annual General Meeting of Shareholders for 2023 Financial Year https://www.ptba.co.id/uploads/ptba_pengumuman/20240723135348-2024-07-23ptba_pengumuman135344.pdf
2) Invitation Annual General Meeting of Shareholders PT Bukit Asam Tbk for 2023 Financial Year - Page 4-5 - Poin b. Process for submitting questions and/or opinions electronically https://www.ptba.co.id/uploads/ptba_pengumuman/20240416162758-2024-04-16ptba_pengumuman162748.pdf
3. Code of Conduct AGMS for 2023 Financial Year https://www.ptba.co.id/uploads/ptba_pengumuman/20240416162832-2024-04-16ptba_pengumuman162828.pdf
|
| A.2.6 | Does the company disclose the voting results including approving, dissenting, and abstaining votes for all resolutions/each agenda item for the most recent AGM? |
PTBA discloses the voting results including approving, dissenting, and abstaining votes for all resolutions/each agenda item for the most recent AGM. Summary of Minutes of Annual General Meeting of shareholder for 2023 Financial Year 2023, discloses the vosting result for each of Agenda, for example: - Result of the vote in the 1st Agenda: Approved: 9,281,357,233 or 99,6295266% Abstain: 25,554,019 or 0,2743063% Not Approved: 8,958,800 or 0,0961671%
The information is stated in: Summary of Minutes of an Annual General Meeting of Shareholders for 2023 Financial Year |
Summary of Minutes of an Annual General Meeting of Shareholders for 2023 Financial Year https://www.ptba.co.id/uploads/ptba_pengumuman/20240510192448-2024-05-10ptba_pengumuman192446.pdf |
| A.2.7 | Does the company disclose the list of board members who attended the most recent AGM? |
PTBA discloses the list of board members who attended the most recent AGM. According to the table on AGM attendance all member of Board of Directors (including the President Director) and Board of Commissioners including the member of Committees under Board of Commissioners were present.
The information is stated in: Summary of Minutes of an Annual General Meeting of Shareholders for 2023 Financial Year page 1-2, dated 10 May 2024. |
Summary of Minutes of an Annual General Meeting of Shareholders for 2023 Financial Year page 1-2, dated 10 May 2024. https://www.ptba.co.id/uploads/ptba_pengumuman/20240510192448-2024-05-10ptba_pengumuman192446.pdf |
| A.2.8 | Does the company disclose that all board members and the CEO (if he is not a board member) attended the most recent AGM? |
PTBA discloses that all board members including CEO attended the most recent AGM. The meeting was attended by all member of Board of Directors (including the President Director) and Board of Commissioners including the member of Committees under Board of Commissioners.
The information is stated in: Summary of Minutes of an Annual General Meeting of Shareholders for 2023 Financial Year page 1-2, dated 10 May 2024. |
Summary of Minutes of an Annual General Meeting of Shareholders for 2023 Financial Year page 1-2, dated 10 May 2024. https://www.ptba.co.id/uploads/ptba_pengumuman/20240510192448-2024-05-10ptba_pengumuman192446.pdf |
| A.2.9 | Does the company allow voting in absentia? |
PTBA allows shareholders voting in absentia. The company allows shareholders voting in absentia in the GMS by providing the proxy, both via easy.KSEI or by filling out power of attorney form which available on the Company's website. According to the code of conduct AGM of shareholders for 2023 financial year dated 16 April 2024, point 4(d), it is stated that the meeting will be held physically and electronically or by granting a power of attorney electronically through the eASY.KSEI facility in https://akses.ksei.co.id link or by granting a power of attorney in writing to an independent party appointed by the company.
The information is stated in: 1. Invitation to the AGMS 2023 2. Code of Conduct AGMS for 2023 Financial Year |
1. Invitation to the AGMS FY 2023 https://www.ptba.co.id/uploads/ptba_pengumuman/20240416162758-2024-04-16ptba_pengumuman162748.pdf
2.Code of Conduct AGMS for 2023 Financial Year https://www.ptba.co.id/uploads/ptba_pengumuman/20240416162832-2024-04-16ptba_pengumuman162828.pdf
|
| A.2.10 | Did the company vote by poll (as opposed to by show of hands) for all resolutions at the most recent AGM? |
PTBA conducts vote by poll for all resolutions at the most recent AGM. The resolution was taken by way of deliberation through voting with a poll vote mechanism (wheraby the resolutions were counted based on the total shares reference owned by the shareholders who physically attend the meeting and/or present electronically through access KSEI).
The information is stated in: Summary of Minutes of an Annual General Meeting of Shareholders for 2023 Financial Year |
Summary of Minutes of an Annual General Meeting of Shareholders for 2023 Financial Year, page 3 https://www.ptba.co.id/uploads/ptba_pengumuman/20240510192448-2024-05-10ptba_pengumuman192446.pdf |
| A.2.11 | Does the company disclose that it has appointed an independent party (scrutineers/inspectors) to count and/or validate the votes at the AGM? |
PTBA discloses that it has appointed an independent party to count and/ or validate the votes at the AGM. PTBA has appointed PT Datindo Entrycom and Notary Jose Dima Satria, S.H., M.Kn to assist in the voting calculation and validate voting calculation at the meeting.
The information is stated in: Summary of Minutes of an Annual General Meeting of Shareholders for 2023 Financial Year |
Summary of Minutes of an Annual General Meeting of Shareholders for 2023 Financial Year, page 3 https://www.ptba.co.id/uploads/ptba_pengumuman/20240510192448-2024-05-10ptba_pengumuman192446.pdf |
| A.2.12 | Does the company make publicly available by the next working day the result of the votes taken during the most recent AGM/EGM for all resolutions? |
PTBA makes publicly available by the next working day the result of the votes taken during AGMS for all resolutions in the company websites and in IDX Website. AGMS 2023 was conducted on 8 May 2024 and the results was published on 10 May 2024 (next working day, due to 9 May is public Holiday)
The information is stated in: 1.https://www.ptba.co.id/uploads/ptba_pengumuman/20240510192448-2024-05-10ptba_pengumuman192445.pdf 2. Exchange Website https://www.idx.co.id/StaticData/NewsAndAnnouncement/ANNOUNCEMENTSTOCK/From_EREP/202405/1dd7595903_e77ea6db86.pdf |
1. Summary of Minutes of AGMS for 2023 Financial Year https://www.ptba.co.id/hubungan-investor/rapat-umum-pemegang-saham
2. Exchange Website
|
| A.2.13 | Does the company provide at least 21 days notice for all AGMs and EGMs? |
PTBA provides at least 21 days notice for all AGM and EGM. At the 2023 Annual GMS, the Company provides notification before 21 days AGMS 2023 2023 AGMS Notice Date = 16 April 2024 2023 AGMS Date = 8 May 2024 PTBA has not held an Extraordinary General Meeting of Shareholders (EGMS) in the first half of 2024 (January to June).
The information is stated in: 1. Invitation to the AGMS 2024 2. Exchange Website |
1.Invitation Annual General Meeting of Shareholders PT Bukit Asam Tbk for 2023 Financial year https://www.ptba.co.id/uploads/ptba_pengumuman/20240416162758-2024-04-16ptba_pengumuman162748.pdf
2.Exchange Website https://www.idx.co.id/StaticData/NewsAndAnnouncement/ANNOUNCEMENTSTOCK/From_EREP/202404/945bc89479_822065ec63.pdf |
| A.2.14 | Does the company provide the rationale and explanation for each agenda item which require shareholders’ approval in the notice of AGM/circulars and/or the accompanying statement? |
PTBA provides the rationale and explanation for each agenda item which require shareholders’ approval in the notice of AGM. There are 5 agenda item which include 5 rationale and explanation on Invitation Annual General Meeting of Shareholders PT Bukit Asam Tbk for 2023 Financial year.
The information is stated in: Invitation Annual General Meeting of Shareholders PT Bukit Asam Tbk for 2023 Financial year |
Invitation Annual General Meeting of Shareholders PT Bukit Asam Tbk for 2023 Financial year, page 2 https://www.ptba.co.id/uploads/ptba_pengumuman/20240416162758-2024-04-16ptba_pengumuman162748.pdf |
| A.2.15 | Does the company give the opportunity for shareholders to place item/s on the agenda of general meetings and/or to request for general meetings subject to a certain percentage? |
PTBA gives the opportunity for shareholders to place item/s on the agenda of general meetings and/or to request for general meetings subject to a certain percentage. The shareholders may propose the meeting agenda subject to the fulfillment of the requirements and provisions of article 16 of POJK No. 15/2020 and article 23 paragraph (6) of the company’s Articles of Association. The proposal should be made in writing by the shareholders and appropriately received by the Board of Directors of the Company no later than 7 (seven) days prior to the Meeting Invitation, which is on Friday, 5 April 2024.
The information is stated in: 1. Announcement AGMS 2023 2. Company's Articles of Association |
1. Announcement of the AGMS 2023 - Point 3 - Page 1 of 2 https://www.ptba.co.id/uploads/ptba_pengumuman/20240506102748-2024-05-06ptba_pengumuman102747.pdf
2. Company's Articles of Association
|
| A.3 | Markets for corporate control should be allowed to function in an efficient and transparent manner. | ||
| A.3.1 | In cases of mergers, acquisitions and/or takeovers requiring shareholders' approval, does the board of directors/commissioners of the company appoint an independent party to evaluate the fairness of the transaction price? |
PTBA did not conduct mergers, acquisitions and/or takeovers during the period as evidenced from the Annual Report 2023. PTBA appoints an independent party to evaluate the fairness of the transaction price. In 2023, there were no material related to investment, expansion, business merger/consolidation, acquisition, and debt/capital restructuring carried out by Bukit Asam. The Company always uses third party services to assess the fairness of investment transactions, expansion, divestment, business mergers/consolidations, acquisitions, and debt/ capital restructuring, which are carried out in accordance with applicable provisions in the capital market sector. In 2023, there were no material related to investment, expansion, business merger/consolidation, acquisition, and debt/capital restructuring carried out by PTBA. However, for divestment in 2023, there were 2 (two) divestments of associated entities owned by PTBA through PT Internasional Prima Coal (PT IPC). The information regarding the divestment of associated entities owned by PTBA through PT IPC is as below.
The information is stated in: Annual Report 2023 |
Annual Report 2023 (Page 241) |
| A.4 | The exercise of ownership rights by all shareholders, including institutional investors, should be facilitated. | ||
| A.4.1 | Does the company disclose its practices to encourage shareholders to engage with the company beyond general meetings? |
PTBA discloses its practices to encourage shareholders to engage with the company beyond general meetings. Establishing relationships with Shareholders is one of the important issues for the Company. PTBA always provides the latest information periodically to shareholders, apart from the information conveyed at the General Meeting of Shareholders. Throughout 2023, PTBA Investor Relations activities and interactions with investors, analysts and capital market players include: 1. 4 (four) times analyst meetings 2. Discuss via teleconference, one on one meeting, group discussion, and also actively continue to communicate with shareholders either via WhatsApp, telephone, or email. 3. The 2023 Public Expose on November 27, 2023, was held online via video conference call in collaboration with the Indonesian Stock Exchange. In this public expose, company management explained the company’s operational and financial performance as well as the company’s future development strategy. 4. Site visits to PTBA work units with the involvement of existing shareholders, potential investors, analysts and the public (general public). 5. Info memo 4 (four) times.
The information is stated in: Annual Report 2023 |
Annual Report 2023 (Page 452) |
| A.5 | Shares and voting rights | ||
| A.5.1 | Where the company has more than one class of shares, does the company publicise the voting rights attached to each class of shares (e.g. through the company website / reports/ the stock exchange/ the regulator's website)? |
PTBA has more than one class of shares, namely Series A Dwiwarna Shares and Series B Shares. The voting rights attached to each class of shares as stated in the Company's Articles of Association and the Company's Annual Report for Financial Year 2023.
The information is stated in: 1. Company Articles of Association 2. Annual Report 2023 |
1. Annual Report 2023 (Page 141)
2. Company's Articles of Asssociaton
|
| A.6 | Notice of AGM | ||
| A.6.1 | Does each of the resolutions at the most recent annual general meeting deal with only one item, i.e., there is no bundling of several items into the same resolution? |
Resolutions at the most recent annual general meeting deals with only one item and there is no bundling of several items into the same resolution. In the 2024 AGM, every resolution only contain 1 (one) item, there's no bundling items as stated in Invitation AGMS, 5 agendas have each resolution and are not considered as bundling.
The information is stated in: Invitation Annual General Meeting of Shareholders PT Bukit Asam Tbk for 2023 Financial year |
Invitation Annual General Meeting of Shareholders PT Bukit Asam Tbk for 2023 Financial year https://www.ptba.co.id/uploads/ptba_pengumuman/20240416162758-2024-04-16ptba_pengumuman162748.pdf |
| A.6.2 | Are the company's notice of the most recent AGM/circulars fully translated into English and published on the same date as the local-language version? |
PTBA publishes the notice of its most recent AGM in both English and the local language on the same date. PTBA publishes translated versions of the most recent AGM documents in bilingual on its website on April 1, 2024.
The information is stated in: 1. Invitation to the AGMS 2. Indonesian Stock Exchange's integrated online report |
1. Announcement AGMS 2023 https://www.ptba.co.id/uploads/ptba_pengumuman/20240401110050-2024-04-01ptba_pengumuman110038.pdf
2. IDX website |
| Does the notice of AGM/circulars have the following details: | |||
| A.6.3 | Are the profiles of directors/commissioners ( at least age, academic qualification, date of first appointment, experience, and directorships in other listed companies) in seeking election/re-election included? |
Profiles of directors/commissioners in seeking election/re-election disclosed on Annual Report. As stated on 2023 Bukit Asam Annual Report, PTBA have disclosed information in regards to age, academic qualifications, date of first appointment, experience, and directorships in other issuers for each Director and Board of Commissioners. Referring to the summary of minutes of an AGMS 2023 (5th Agenda) Changes in the Composition of Company’s Management, state: "there was no proposal in the changes of company's management "
The information is stated in: 1. Annual Report 2023 2. Summary of minutes of an AGMS 2023 |
1. Annual Report 2023
2. Summary of Minutes of an Annual General Meeting of Shareholders for 2023 Financial Year https://www.ptba.co.id/uploads/ptba_pengumuman/20240510192448-2024-05-10ptba_pengumuman192446.pdf |
| A.6.4 | Are the auditors seeking appointment/re-appointment clearly identified? |
Auditors seeking appointed/reappointed are cleary identified. As stated in the Invitation of Annual GMS for the 2023 financial year fourth agenda. The Summary of Minutes of the Annual General Meeting of Shareholders for the 2023 Financial Year, specifically the 4th agenda item, confirms the approval of appointing a public accounting firm (the AGMS grant the authority to the Board of Commisioners to appoint Public Accountant Firm and Public Accountant with prior approval from Series A Dwiwarna Shareholders) to audit the company's financial statements and the micro and small enterprises funding program for the same year (For Financial Year 2024).
The information is stated in: 1. Invitation Annual General Meeting of Shareholders - 4th Agenda - Page 2 2. Summary of Minutes of the Annual General Meeting of Shareholders for the 2023 Financial Year - 4th Agenda - Page 4 |
1. Invitation Annual General Meeting of Shareholders https://www.ptba.co.id/uploads/ptba_pengumuman/20240416162758-2024-04-16ptba_pengumuman162748.pdf
2. Summary of Minutes of the Annual General Meeting of Shareholders for the 2023 Financial Year - 4th Agenda - Page 4 https://www.ptba.co.id/uploads/ptba_pengumuman/20240507104812-2024-05-07ptba_pengumuman104811.pdf |
| A.6.5 | Were the proxy documents made easily available? |
Proxy form (form of Power attorney) is easily available. As shown on the company's website, PTBA uploads proxy form on the same day with announcement of AGM on April 16, 2024.
The information is stated in: Form of Power Attorney GMS PT Bukit Asam Tbk for 2023 Financial Year |
Form of Power Attorney GMS PT Bukit Asam Tbk for 2023 Financial Year https://www.ptba.co.id/uploads/ptba_pengumuman/20240416162904-2024-04-16ptba_pengumuman162900.pdf |
| A.7 | Insider trading and abusive self-dealing should be prohibited. | ||
| A.7.1 | Are the directors / commissioners required to report their dealings in company shares within 3 business days? |
The director/commissioners required to report their dealings in company shares within 3 business days. Members of the Board of Directors and members of the Board of Commissioners are obliged to report ownership of Company shares, including any changes in ownership of Company shares either directly or indirectly, to the Financial Services Authority (OJK). This obligation is regulated in Financial Services Authority Regulation Number 11/POJK.04/2017 concerning Ownership Reports or Any Changes in Ownership of Public Company Shares
The information is stated in: Annual Report 2023 |
Annual Report 2023 (Page 522) |
| A.8 | Insider trading and abusive self-dealing should be prohibited. | ||
| A.8.1 | Does the company have a policy requiring a committee of independent directors/commissioners to review material RPTs to determine whether they are in the best interests of the company and shareholders? |
PTBA has a policy that requires a committee to review RPT materials to determine whether the RPT is in the best interests of the company and shareholders. The company has a policy on material transactions that contain conflicts of interest and/or transactions with affiliates/related parties. Material transactions containing conflicts of interest and/or transactions with affiliated/related parties, carried out by the Company, always consider the precautionary principle in accordance with generally accepted business practices and complying with OJK Regulation No. 42/POJK.04/2020 concerning Affiliate Transactions and Conflict of Interest Transactions, as well as PSAK No. 7 concerning Disclosures of Related Parties. The review mechanism for material transactions containing conflicts of interest and/or transactions with affiliated/ related parties is carried out through an audit process by the Audit Committee, with the results reported to the Board of Commissioners.
The information is stated in: Annual Report 2023 |
Annual Report Page
242 |
| A.8.2 | Does the company have a policy requiring board members (directors/commissioners) to abstain from participating in the board discussion on a particular agenda when they are conflicted? |
PTBA has policy requiring board members (directors/commissioners) to abstain from participating in the board discussion on a particular agenda when they are conflicted In order to avoid potential conflicts of interest, the Company has Conflict of Interest Guidelines which were approved based on the Joint Decree of the Board of Commissioners and Directors of PT Bukit Asam Tbk No. 14/SK/PTBA-DEKOM/ IX/2020 and No. 404/0100/2020 concerning the Application of Good Corporate Governance Principles and Practices for Company Conflict of Interest Policies. Conflict of Interest is a situation/condition that allows PTBA Personnel to take advantage of their position and authority within the Company for personal, family or group interests, so they cannot carry out their mandated tasks objectively and have implications for the Company’s performance and image in the long term. PTBA personnel are obliged to avoid all forms of potential conflicts of interest that could be detrimental to the Company, by freeing themselves from the situation by reporting it to the management or those responsible for handling conflicts of interest.
The information is stated in: Annual Report 2023 |
Annual Report 2023 (Page 546) |
| A.8.3 | Does the company have policies on loans to directors and commissioners either forbidding this practice or ensuring that they are being conducted at arm's length basis and at market rates? |
PTBA has policies on loans to directors and commissioners that they are being conducted at arm's length basis and at market rates. The company have policies on loans to directors as stated on Article of Association article (12) Paragraph (7) : j) receiving medium/long term loans and providing medium/long term loans with a certain value determined by the Board of Commissioners complying with the provisions in the Capital market sector.
The information is stated in: Article of Association |
Article of Association Article 12 Paragraph (7) (Page 78,80)
|
| A.9 | Protecting minority shareholders from abusive actions | ||
| A.9.1 | Does the company disclose that RPTs are conducted in such a way to ensure that they are fair and at arms' length? |
PTBA discloses that RPTs are conducted in such a way to ensure that they are fair and at arms' length. The Company, through the Board of Commissioners and the Audit Committee, has also carried out a review to ensure that material transactions containing conflicts of interest and/or transactions with affiliated/related parties, are carried out in accordance with generally accepted business practices and meet the principles of fair transactions (arms-length principle), and implemented in compliance with applicable regulations.
The information is stated in: Annual Report 2023 |
Annual Report 2023 (Page 242) |
| A.9.2 | In case of related party transactions requiring shareholders' approval, is the decision made by disinterested shareholders? |
PTBA discloses that related party transaction has been approved by shareholders. Throughout 2023, there was 1 (one) affiliated transaction conducted by PTBA and has been reported to OJK, which is related to the signing of the Second Amendment to the Shareholders Support Agreement for the Sumsel-8 CFPP Project. The signing was carried out on April 7, 2023, involving PTBA and China Huadian Hongkong Company Limited (CHDHK) as the shareholder of PT Huadian Bukit Asam Power (PT HBAP), The Export Import Exim Bank of China (CEXIM) and PT HBAP itself. Shareholders Support Agreement is a form of support from the shareholders of PT HBAP to provide support to the project company (PT HBAP), in the event of certain conditions. For the signing, PTBA has submitted an affiliated transaction report to OJK on April 11, 2023 in accordance with PTBA Letter No. T/112/111000/KS.03/ IV/2023 Regarding Affiliated Transactions.
The information is stated in: Annual Report 2023 |
Annual Report 2023 (Page 243) |
| Part | Item | Company Practice in 2023 | Source Information |
| B.1 | Sustainability-related disclosure should be consistent, comparable and reliable, and include retrospective and forward-looking material information that a reasonable investor would consider important in making an investment or voting decision | ||
| Material Sustainability-related information should be specified | |||
| B.1.1 | Does the company identify/report ESG topics that are material to the organization’s strategy? |
PTBA identifies ESG topics that are material to the organization’s strategy. The list of material topics for the Company’s 2023 Sustainability Report amounts to 27 topics, in full as follows: 1. Biodiversity and Conservation 2. Water and Air 3. Decarbonization 4. Responsible Production Activities 5. Operation Excellence: 6. Automation, Digitization, and Research 7. Quality and Responsible Products: 8. Customer Satisfaction 9. Management of Supply and Contractors 10. Occupational Health and Safety (OHS) 11. Recruitment, Inclusion, and Diversity 12. Training and Development 13. Labor Rights (Non-discrimination and Equal Opportunity) 14. Community Development Program 15. Human Rights 16. Relations with Stakeholders 17. Economic Impact 18. Financial Performance & Business Expansion 19. Financial Performance & Business Expansion 20. Leadership and Decision Making 21. Transparency and Accountability 22. Business Ethics & Compliance 23. Risk management Climate change triggered by global warming poses a challenge to all business sectors and industries. The coal mining sector is also affected by the impacts of climate change. One of the impacts of climate change is its influence on rainfall levels.The high rainfall in Indonesia recently has become one of the factors hindering the mining process, especially coal mining conducted by PTBA, particularly during the rainy seasons.
The information is stated in: Sustainability Report 2023 |
1. Sustainability Report (Page 97)
2. Sustainability Report (Page 164) |
| B.1.2 | Does the company identify climate change as an issue? |
PTBA identifies climate change as an issue. PTBA's operations in the coal mining sector have positive and negative impacts on the environment and social for the surrounding communities around the company. To determine these impacts, PTBA has implemented mapping and assessment of possible impacts, including mitigation steps.The mapping was conducted by PTBA involving internal and external stakeholders, especially communities in the Company’s Ring I area.
The information is stated in: Sustainability Report 2023 |
Sustainability Report (Page 257-258) |
| B.1.3 | Does the company adopt an internationally recognized reporting framework or standard for sustainability (i.e. GRI, Integrated Reporting, SASB, IFRS Sustainability Disclosure Standards)? |
PTBA adopts internationally recognized reporting frameworks or standards for sustainability such as GRI, SASB, and TCFD. The value of stakeholder expectations is assessed from the number of national and international standards that examine every issue that arises, including POJK 51/2017 on the Implementation of Sustainable Finance for Financial Services Institutions, Issuers and Public Companies, Global Reporting Initiatives (GRI), International Council on Mining & Metal (ICMM) Performance Expectations, ISO 26000 Social Responsibility Guidelines, Sustainable Accounting Standard Board (SASB) Metrics for Mining & Metals, and Task-Force on Climate Related Financial Disclosures (TCFD).
The information is stated in: Sustainability Report 2023 |
Sustainability Report 2023 (Page 95-96) |
| If a company publicly sets a sustainability-related goal or target, the disclosure framework should provide that reliable metrics are regularly disclosed in an easily accessible form | |||
| B.1.4 | Does the company disclose quantitative sustainability target? |
PTBA discloses quantitative sustainability target on the environmental aspect. As regards the government's commitment, the Board of Commissioners appreciates PTBA's earnestness in supporting the government's efforts to realize the NDC target. Moreover, apart from moving and acting alone, PTBA also opens up opportunities to synergize and establish strategic partnerships with various parties. With these numerous efforts, PTBA will be able to make a maximum contribution to the acceleration of Net Zero Emission (NZE) achievement by 2060 or sooner, in energy transition acceleration as targeted by Indonesian Government. PTBA's implementation and support towards achieving the NDC and NZE targets, are the Company's real effort to realize its vision to become a world- class energy company that cares about the environment.
The information is stated in: Sustainability Report 2023 |
Sustainability Report (Page 74) |
| B.1.5 | Does the company disclose sustainability-related performance progress in relation to its previously set targets? |
PTBA discloses sustainability-related performance progress.
Due to various efforts, PTBA recorded a total emission reduction of up to 16.29% from Business As Usual (BAU) in 2023.
The information is stated in: Sustainability Report 2023 |
Sustainability Report (Page 164) |
| B.1.6 | Does the company confirm that its Sustainability Report / Reporting is reviewed and /or approved by the Board or Board Committee? |
PTBA reveals that the 2023 Sustainability Report has been approved by the Board of Directors and Board of Commissioners. This report has been reviewed and authorized by management; therefore, the management is fully liable for the information in this report.
The information is stated in: Sustainability Report 2023 |
Sustainability Report (Page 21) |
| B.2 | Corporate governance frameworks should allow for dialogue between a company, its shareholders and stakeholders to exchange views on sustainability matters | ||
| B.2.1 | Does the company engage internal stakeholders to exchange views and gather feedback on sustainability matters that are material to the business of the company? |
PTBA engages internal stakeholders to exchange views and gather feedback on sustainability matters that are material to the business of the company. PTBA’s success in running a business is a reflection of the Company’s success in fulfilling its responsibilities and involving stakeholders, both internal and external, including customer, government policy maker and supplier. A complete description of stakeholder involvement is presented in the table and can be found in Sustainability Report 2023 page 274.
The information is stated in: Sustainability Report 2023 |
Sustainability Report (Page 273-275) |
| B.2.2 | Does the company engage external stakeholders to exchange views and gather feedback on sustainability matters that are material to the business of the company? |
PTBA engages external stakeholders to exchange views and gather feedback on sustainability matters that are material to the business of the company. PTBA’s success in running a business is a reflection of the Company’s success in fulfilling its responsibilities and involving stakeholders, both internal and external, including customer, government policy maker and supplier. A complete description of stakeholder involvement is presented in the table and can be found in Sustainability Report 2023 page 274.
The information is stated in: Sustainability Report 2023 |
Sustainability Report (Page 273-275) |
| B.3 | The corporate governance framework should ensure that boards adequately consider material sustainability risks and opportunities when fulfilling their key functions in reviewing, monitoring and guiding governance practices, disclosure, strategy, risk management and internal control systems, including with respect to climate-related physical and transition risks | ||
| Boards should assess whether the company’s capital structure is compatible with its strategic goals and its associated risk appetite to ensure it is resilient to different scenarios | |||
| B.3.1 | Does the company disclose that the board reviews on an annual basis that the company's capital and debt structure is compatible with its strategic goals and its associated risk appetite? |
PTBA discloses that the capital and debt structure is compatible with its strategic goals and its associated risk appetite. Management policy on capital structure is applied to protect the Company’s ability to maintain business continuity, so as to provide returns and benefits for shareholders and other stakeholders. In addition, the Company also maintains an optimal capital structure to reduce capital costs. The Company and its business groups always monitor capital based on the debt to capital ratio. This ratio is calculated by dividing total debt by total capital. While debt is the total liability in the consolidated statement of financial position, capital consists of all equity components as amounted to in the consolidated financial position. The Company determines an optimal capital structure policy in order to maximize the value of the Company. The Board of Commissioners, assisted by the Audit Committee and Risk Monitoring Committee, must provide opinions and approval for the Company Work Plan and Budget (WP&B) and other work plans prepared by the Board of Directors
The information is stated in: Annual Report 2023 |
1. Annual Report 2023, page 230 2. Annual Report 2023, page 230 3. Annual Report 2023, page 319 |
| B.4 | The corporate governance framework should recognise the rights of stakeholders established by law or through mutual agreements and encourage active co-operation between corporations and stakeholders in creating wealth, jobs, and the sustainability of financially sound enterprises. | ||
| Does the company disclose a policy and practices that address : | |||
| B.4.1 | The existence and scope of the company's efforts to address customers' welfare? |
PTBA discloses a policy and practices in regards to the existence and scope of company's efforts that address customers' welfare. To find out and measure customer satisfaction, as well as obtain opinions and feedback, the Company has a Customer Satisfaction Procedure and conducts regular Customer Satisfaction Survey. PTBA upholds ethical relationships with stakeholders, especially customers, by ensuring the quality of products and services according to agreed contracts. Apart from that, the Company also provides and manages communication media with potential customers and customers in the form of telephone, fax, short message service (SMS), website, and others, making it easier for customers to submit complaints and input so that PTBA can follow up immediately according to applicable standard operational procedures.
The information is stated in: Sustainability Report 2023 |
Sustainability Report (Page 199) |
| B.4.2 | Supplier/contractor selection procedures? |
PTBA discloses a policy and practices in regards to supplier/contractor selection procedure. The Supplier is a strategic partner for PTBA in carrying out its business. To obtain quality and reliable suppliers, both for goods and services, the Company sets strict requirements and selections, including environmental criteria, such as impacts related to water management, energy, emissions, environmental compliance, and so on. The selection needs to be carried out so that the Company can prevent and mitigate negative environmental impacts in the supply chain. This policy is adopted because PTBA potentially involves environmental impacts, either through company activities or as a result of business relationships with suppliers.
The information is stated in: Sustainability Report 2023 |
Sustainability Report (Page 179-180) |
| B.4.3 | The company's efforts to ensure that its value chain is environmentally friendly or is consistent with promoting sustainable development? |
PTBA discloses a policy and practices in regards to the company's efforts to ensure that its value chain is environmentally friendly or is consistent with promoting sustainable development. In line with its commitment to environmental aspects, PTBA has also encouraged a rating of the company's emissions (carbon) disclosure policy. In 2023, the Company has been assessed by the Carbon Disclosure Project (CDP), which is an independent international non-profit organization that plays a role in Carbon Disclosure. Based on the assessment from the CDP, the company received a “B” rating, an increase compared to previous year's achievements with an average "C" rating, the highest achievement of similar industries in its class. Apart from that, the Company also received the 11th Gold of PROPER for environmental performance in 2023 which was submitted on December 21, 2023 by the Minister of Environment and Forestry.
The information is stated in: Sustainability Report 2023 |
Sustainability Report (Page 330) |
| B.4.4 | The company's efforts to interact with the communities in which they operate? |
PTBA discloses a policy and practices in regards to the company's efforts to interact with the communities in which they operate. PTBA has a Social and Environmental Responsibility (CSR) Policy/ Development and Empowerment Community (PPM), which contains a commitment to encourage community development through the implementation of a Social and Environmental Responsibility Program (CSR) or Corporate Social Responsibility (CSR) as a fulfillment of responsibility to the community, as well as an effort to maximize the positive impact of the Company’s existence and operations. PTBA is committed to ensuring that its business operations have the greatest positive impact on the society, while minimizing any negative impacts that may arise.
The information is stated in: 1.Sustainability Report 2023 2.Company's Website |
1. Sustainability Report (Page 256 and 258) For Detail CSR Program, refer to sheet "CSR Program"
2. Company's Website https://www.ptba.co.id/esg/kinerja-sosial/komunitas-lokal
|
| B.4.5 | The company's anti-corruption programmes and procedures? |
PTBA discloses a policy and practices in regards to the company's anti-corruption programmes and procedures. The Company implements its commitment to anti-corruption regulations by not giving or receiving gifts and gratuities that are expected to affect independence in PTBA's decision making process, as well as being contrary to the sound code of conducts and/or contrary to applicable law. This commitment is strengthened in several policies that apply at PTBA such as the Joint Decree of the Board of Commissioners and Board of Directors of PTBA No: 10/SK/PTBA-DEKOM/IX/2020 and Number: 400/0100/2020 concerning the Implementation of Good Corporate Governance Principles and Practices for Anti-Gratification at PT Bukit Asam Tbk and Gratification Control Guidelines No. BAMSM:UPG:01. Pursuant with this, since 2020, PTBA has adopted ISO 37001:2016 Anti-Bribery Management System (SMAP) certification. Even for SMAP itself, PTBA has its own guidelines which are contained in the Guidelines of Anti-Bribery System of Bukit Asam No. BASMAP.01. Apart from socializing anti-corruption policies and procedures, PTBA also provides opportunities for the Board of Commissioners, Board of Directors and employees to take part in anti-corruption training. The anti-corruption training attended by the Board of Commissioners, Board of Directors and employees during the reporting year can be found in Sustainability Report, page 360.
The information is stated in: Sustainability Report 2023 |
1. Sustainability Report (Page 359)
2. Sustainability Report (Page 360) |
| B.4.6 | How creditors' rights are safeguarded? |
PTBA discloses a policy and practices in regards how creditors' rights are safeguarded. The Company is committed to fulfilling creditors’ rights by making loan principal and interest payments on time. For this reason, the Company manages liquidity and monitors the due date for principal and interest payments on loans.
The information is stated in: Annual Report 2023 |
Annual Report (Page 225) |
| B.4.7 | Does the company have a separate report/section that discusses its efforts on environment/economy and social issues? |
PTBA has a separate
report/section that
discusses its
efforts on
environment/economy
and social
issues. The information is stated in: 1. Sustainability Report 2023 2. Social and Environmental Responsibility Report 3. Annual Report 2023 |
1. Sustainability Report: Chapter 6 "Environment & Climate Change"; Chapter 9 "Society" and Chapter 10 "Economic Development"
2. Social and Environmental Responsibility Report Page 54 "Implementation of Environmental and Social Responsibility Activities in PTBA"
3. Annual Report Page 550 "Corporate Social Responsibility" https://www.ptba.co.id/uploads/ptba_laporan_tahunan/20240416183127-2024-04-16ptba_laporan_tahunan183105.pdf |
| B.5 | Where stakeholder interests are protected by law, stakeholders should have the opportunity to obtain effective redress for violation of their rights. | ||
| B.5.1 | Does the company provide contact details via the company's website or Annual Report which stakeholders (e.g. customers, suppliers, general public etc.) can use to voice their concerns and/or complaints for possible violation of their rights? |
PTBA provides contact details via the company's website which stakeholders can use to voice their concerns and/or complaints for possible violation of their rights. E -mail: [email protected] Telephone: +62 21 527 4635
The information is published in: 1. Company's website - https://www.ptba.co.id/tata-kelola/mekanisme-pengaduan 2. Annual Report 2023 |
1. Company website https://www.ptba.co.id/tata-kelola/mekanisme-pengaduan 2. Annual Report (Page 68) |
| B.6 | Mechanisms for employee participation should be permitted to develop. | ||
| B.6.1 | Does the company explicitly disclose the policies and practices on health, safety and welfare for its employees? |
PTBA explicitly discloses the policies and practices on health, safety and welfare for its employees. PTBA has a committed safety system policy that contains guidelines for communication with external stakeholders. Through these policies and guidelines, PTBA has succeeded in achieving zero fatality and maximizing OHS handling. Since July 2010, PTBA has integrated all operational systems related to OHS management aspects into the Bukit Asam Management System (BAMS). In addition, OHS in PTBA refers to the following provisions including (i) Mining Safety Management System (SMKP), (ii) OHS Management System (SMK3) which has been accredited by an independent body based on Government Regulation of the Republic of Indonesia No. 50 of 2012 concerning the Implementation of SMK3, and (iii) ISO 45001:2018 as contained in the ISO 45001:2018 OHS Management System certification with a validity period until 2024 which is the 3rd certification obtained by PTBA.
The information is stated in: Sustainability Report 2023 |
1. Sustainability Report (Page 212) |
| B.6.2 | Does the company explicitly disclose the policies and practices on training and development programmes for its employees? |
PTBA explicitly discloses the policies and practices on training and development programmes for its employees. PTBA regularly organizes education and training programs for Human capital (HC) to increase their capacity and competence. The program is open to all employees regardless of gender, race, religion and others. In organizing education and training programs, PTBA refers to the Annual Training Plan which is prepared based on the Training Need Analysis (TNA) to meet the needs and demands of the profession/certification. During the reporting year, PTBA held education and training as many as 396 development program which were participated in by all of the employees. The program is organized internally and externally, namely by sending employee delegations or establishing cooperation in providing education and training with third parties. PTBA also provides the table of Education and Training and Average Employee Training Hours for 2023.
The information is stated in: Sustainability Report 2023 |
1. Sustainability Report (Page 242) |
| B.6.3 | Does the company have a reward/compensation policy that accounts for the performance of the company beyond short-term financial measures? |
PTBA has a reward/compensation policy that accounts for the performance of the company beyond short-term financial measures. The Company realizes that employee training is important to fulfill technical and regulatory requirements. One of them is the Professional and Certification Program, which is the Company’s long-term investment in improving employee’s performances in the future. This program has been tailored to the annual Training Plan which is created based on each employee’s Individual Development Plan. The Company invests to human capital by granted scholarship for the employees, this aims to enrich the quality of PTBA’s human capital. The employees who got scholarship from the company and have graduated are required to work at the Company in accordance with the duration mentioned in the contract.
The information is stated in: Annual Report 2023 |
1. Annual Report (Page 121) 2. Annual Report (Page 515) |
| B.7 | Stakeholders including individual employee and their representative bodies, should be able to freely communicate their concerns about illegal or unethical practices to the board and their rights should not be compromised for doing this. | ||
| B.7.1 | Does the company have a whistle blowing policy which includes procedures for complaints by employees and other stakeholders concerning alleged illegal and unethical behaviour and provide contact details via the company's website or annual report |
PTBA has a whistle blowing policy which includes procedures for complaints by employees and other stakeholders concerning alleged illegal and unethical behaviour and provide contact details via the company's website and annual report. The Company determines WBS through Joint Decree of the Board of Commissioners and Directors No. 06/DEKOM/ VIII/2020 and No. 395/0100/2020 dated August 31, 2020, concerning Ratification of the Violation Reporting System Guidelines. Violation reports can be submitted to the Company through the channel provided, namely: Website : http://www.ptba.co.id Email : [email protected] Telephone : +62 21 527 4635
The mechanism for violation reports submissions is as follows: 1. The reporter submits a written or oral report (as initial information). 2. Written reports can be submitted via electronic mail (e-mail) and oral reports can be submitted via telephone. 3. The reporter provides information regarding personal data. Anonymous reporting will not be followed up. 4. The reporter must provide initial indications that can be accounted for, including the problem being reported, the parties involved, the location of the incident, the time of the incident, the brief story, whether there is evidence, whether this case has ever been reported to other institutions/parties, and whether this case has ever been reported. or happened before.
The information is stated in: 1. Company's website - https://www.ptba.co.id/ 2. Annual Report 2023 |
1. Annual Report (Page 529) 2. Annual Report (Page 530) 3. Company website https://www.ptba.co.id/tata-kelola/sistem-pelaporan-pelanggaran |
| B.7.2 | Does the company have a policy or procedures to protect an employee/person who reveals alleged illegal/unethical behaviour from retaliation? |
PTBA discloses the policy to protect the confidentiality and/or privacy of employee/person who reveals alleged illegal/unethical behavior from retaliation. The mechanism for submitting complaints and handling complaints is implemented in accordance with the Joint Decree of the Board of Commissioners and Directors of PT Bukit Asam Tbk No.06/DEKOM/VIII/2020 and No. 395/0100/2020 concerning Guidelines for the Violation Reporting System (Whistleblowing System) of PT Bukit Asam Tbk. The Guidelines for Reporting Violations regulate the main issues regarding the reporting mechanism, including: 1. Information and methods for reporting violations via WBS; 2. Reporting Management; 3. Whistleblower Protection; 4. Follow up on the Report including the sanctions rules applied.
In managing Violation Complaint Reports submitted to the Company, PTBA provides protection for whistleblowers, in the form of: 1. Confidentiality of the whistleblower identity (name, address, telephone number, facsimile, email, work unit); 2. Protection against countermeasures from the reported party or institution; 3. Protection from pressure, postponement of promotion/ position, dismissal, lawsuits, property, to physical actions; 4. The protection does not only apply to the whistleblower but can be extended to the whistleblower family member.
The information is stated in: Annual Report 2023 |
1. Annual Report (Page 530) 2. Annual Report (Page 532) |
