Scope of this policy
This policy applies to PT Acala Genesa Sumberdaya, trading as ACALA (“ACALA”), and to every engagement delivered under the MinexCoal name: licence supply, implementation, data migration, training and retained support. It binds our employees, and our contractors while working on our engagements.
It sits alongside our Data Protection & Compliance page, which covers information security and privacy in detail, and our Terms & Conditions.
Who this page is written for. Procurement and vendor-onboarding teams asked to evidence supplier ESG credentials. If your questionnaire needs something this page does not cover, ask us rather than assuming the answer.
Where we sit in the coal value chain
We will not pretend to be something we are not. We supply software and expertise to companies that mine coal and other stratified deposits. We do not own, operate, finance or hold equity in any mine. We do not extract, transport, wash or sell coal.
What that means in practice is that our direct environmental footprint is small — an office, some travel, a laptop fleet — and our real leverage sits somewhere else entirely: in the quality of the plans our clients are able to make. A mine plan built on a model nobody can rebuild is not only a commercial risk. It is the reason waste gets moved twice, pits get cut wider than the economics justify, and rehabilitation gets designed after the fact instead of before it.
That is the part of the value chain we can genuinely affect, and it is what most of this policy is about.
Environmental
Our own operations
- ACALA operates an environmental management system certified to ISO 14001:2015. Certificate details are available on request.
- Delivery is remote by default. We travel to site for commissioning, hands-on training and model reviews where being in the room genuinely changes the outcome, and we say so honestly when it does not.
- We do not print project deliverables. Models, procedures and reports are handed over digitally unless a client's own records policy requires otherwise.
Through the work we deliver
These are the levers a mine planning practice actually holds. We commit to raising them in scope discussions rather than waiting to be asked:
- Rehabilitation designed early, not retrofitted. Spoil regrade and landform design are taught as part of the mine planning cycle, not as a closure afterthought. A dump built to a landform that was designed at the start does not need to be rehandled to meet a closure commitment at the end.
- Waste moved once. Pit optimisation, dump scheduling and haul route selection exist to stop material being placed where it has to be moved again. Every avoided rehandle is diesel not burned.
- Models that hold. An unreliable resource model is mined conservatively, which means more ground disturbed for the same tonnage. Accuracy is an environmental control, not only a commercial one.
- Water and drainage in the landform. Drainage strings and the rehabilitation limit belong in the design file, where they can be checked, rather than in someone's memory.
Governance
- Corporate form. ACALA is a limited liability company established under Law No. 40 of 2007 on Limited Liability Companies (Undang-Undang Perseroan Terbatas), which sets the framework for our governance, shareholding and reporting obligations. NIB 0212010200653.
- Quality management. ACALA operates a quality management system certified to ISO 9001:2015. Certificate details are available on request.
- Anti-bribery and anti-corruption. We do not offer, pay, solicit or accept bribes, kickbacks or facilitation payments, in cash or in kind, to win or retain work. This applies to public officials and to private counterparties equally, and to anyone acting on our behalf.
- Conflict of interest in licence scoping. We supply licences and we also advise on how many you need. We manage that tension by reporting seat utilisation as we measure it, including when the honest finding is that you should buy fewer seats. Where we advise on scope we act on your instructions; where we supply a licence we act as the vendor's partner, and we identify which capacity applies.
- Software licence compliance. We do not install, use or supply unlicensed software, and we will not work around a client's licence limits. If an engagement cannot be delivered within the licences held, we say so and quote the shortfall.
- Data protection. Client mine data is among the most commercially sensitive material a company holds. Controls, sub-processors, retention and breach response are set out in full on our Data Protection & Compliance page.
- Fair dealing. Scope, assumptions and limitations are written into every proposal. We do not bid work we are not competent to deliver, and we decline engagements where an honest result cannot be defended.
- Raising concerns. Anyone — our staff, a contractor, or a client's employee — may raise a concern about conduct on one of our engagements to legal@minexcoal.com. Concerns raised in good faith will not be held against the person who raised them.
How this shows up in the work
A policy that changes nothing about the deliverable is decoration. These are the specific places this one bites:
- Reclamation and landform design is one of the eighteen disciplines in our training curriculum, taught in sequence with the rest of the mine planning cycle rather than bolted on at the end.
- Pit optimisation is taught with the safe slope constraint treated as a boundary, and with the run log read honestly when the optimiser fails.
- Truck cycle time and haulage selection are taught as fuel and cost per tonne, which are the same number viewed from two directions.
- Every implementation ends in written procedures, because an undocumented model is an environmental and commercial liability in equal measure.
- Licence audits report what we find, including the findings that reduce our own invoice.
What we do not claim
This section exists on purpose. An ESG page for a supplier to the coal sector is worth nothing if it is silent about its own limits.
- We do not claim that better mine planning software reduces absolute emissions. Emissions are driven overwhelmingly by how much coal is produced and burned, and that is not a decision we make or influence.
- We have not set a science-based emissions target and we do not purchase offsets. We would rather report nothing than report a number we cannot substantiate.
- We do not publish a carbon footprint for our own operations at this time. If you need one for your supply chain reporting, ask and we will tell you honestly what we can and cannot evidence.
- We hold no ESG rating and no membership of a sustainability reporting framework beyond the ISO certifications named above.
- We are not a mine operator. Nothing in this policy commits our clients to anything, and no statement here should be read as an assurance about any client's operations.
Review, reporting & contact
This policy is owned by the ACALA management team and reviewed at least annually, and sooner if our scope of work, certifications or applicable regulation change materially.
Questions, due-diligence questionnaires and requests for certificate copies: legal@minexcoal.com. Concerns about conduct on an engagement may be raised at the same address.
Applicable Indonesian frameworks we work within include the mineral and coal mining law and its implementing regulations on good mining practice and post-mining, and the environmental protection and management law. Where a client operates under additional standards — a lender's requirements, a listing rule, or a parent company code — we work to those as well when they form part of the engagement.
Social
Capability stays with your people
Our central social commitment is also our commercial model: we work to make ourselves unnecessary. Every engagement ends with written procedures, scripted workflows and trained people. We train on your own project data so the competence is real, and we deliberately train more than one person so the model does not sit inside a single head.
For an Indonesian operation that means the capability stays in Indonesia, with your team, rather than being rented back from a consultant every year.
Safety in what we teach
Our people and our conduct