Dear Investors of PT. Indo Tambangraya Megah Tbk.

We wish you and your family all the best in this difficult pandemic situation.

On the occasion of the World celebrates river day on September 26 every year, we are writing to you, a group of Indonesian environmental and social justice organizations, to address an urgent and important matter regarding your investment at PT. Indo Tambangraya Megah Tbk. (ITMG), in this case specifically related to its subsidiaries PT. Indominco Mandiri (PT IMM).

Indominco Mandiri is one of the eight subsidiaries of PT. Indo Tambangraya Megah Tbk. who is the holder of a Coal Mining Exploitation Work Contract (PKP2B) since 11 November 1988 with concession area of 24,121 ha. The contract period is valid until 2028 in Kutai Kartanegara Regency, Bontang City and East Kutai Regency, East Kalimantan Province, Indonesia.

Indominco Mandiri has brought destruction to the nature of East Kalimantan for three decades now. They get the privilege to be exempted from the regulation that prohibit open-pit mining in protected forest areas, and therefore bring destruction upon it. Adding on to the obvious, recent investigation (water sampling and testing of PT IMM’s settling pond, Palakan River and Palakan River’s estuary) of JATAM East Kalimantan has concluded that::

  • PT IMM’s wastewater disposal activities have violated the obligation to comply with surface water quality standards.
  • There are environmental crimes done by PT IMM in the form of violations of wastewater quality standards, environmental pollution, and destruction of the Palakan River.
  • As a result of PT IMM mining in the upstream area, every year residents of 3 Santan Villages and residents of Bontang City experienced flooding in residential areas and fields.
  • As a result of the tailings being dumped into Santan River, indigenous biota of Santan River went extinct, two of them were the Kepah shells and Biawan fish.
  • The crocodiles’ natural habitat continues to be pressured. From 1998 to 2010, 11 residents of 3 Santan Villages had crossed paths with and were killed by the crocodiles. Nowadays, the risk becomes higher as the river ecosystem is increasingly ruined by the poisoning of the Santan River.
  • As a result of forest clearing and mining in the upstream area of Bontang River and Santan River, residents in these 2 areas experience clean water concerns throughout the year.
  • Until the end of the PKP2B permit in 2028, there would be as many as 53 holes within an area of 2,823.73 ha which was equivalent to an area 32 times larger than the Palaran Football Stadium and Sports Center.
  • The mine pits that were not reclaimed were “written-off” and will become a source of raw water for the residents of Bontang City. There was 1 giant mining hole measuring 369 ha, equivalent to more than 4 x the area of the Palaran Main Stadium Complex (SUP complex: 88 ha) given to the residents of Santan and Bontang City.

It is strongly indicated that the violations and pollution has been happening for a long time and not only at the time of sampling, and has had negative impacts on people and the ecosystem who depend on the health of the Rivers.

Therefore, on World River Day, 26 September, where the world commemorates every year, we hope you will evaluate your involvement and investment contribution in coal mining companies, one of which is PT IMM, which must be held responsible for the destruction and pollution of our rivers in Kalimantan. East, Indonesia.

Rivers for our people are extraordinary ecosystems, part of the living space and economic resources of dependent communities, even rivers are an identity and store history for indigenous and local communities in East Kalimantan, that’s why respect for rivers is so high and sacred.

Given that, we are writing to urge you to evaluate your investment policy at PT. ITMG who’s affiliated with the violation, environmental destruction, and pollutions carried out by its subsidiaries, PT IMM. Even more important, to evaluate your investment policy in the coal industry, and start shifting as soon as possible to the solution, to support a just-transition that is equitable for all in Indonesia and beyond. We request you to pay extra cautions to the following facts that we have explained in the attached report.

We would appreciate your immediate attention to this matter. Should you need any further information about the letter and the report, please do not hesitate to contact Merah Johansyah, National Coordinator of JATAM Indonesia at We thank you in advance.

Yours sincerely,

Komunitas Tani Muda Santan, JATAM East Kalimantan, JATAM National Secretariat, #BersihkanIndonesia

Letter for Investors

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