A Compliance-Based Evaluation of ESG Policy: The Case of PGN Saka

Arkananta Buwana, Dr. Nurhadi Susanto, S.H., M.Hum.

2025 | Skripsi | ILMU ADMINISTRASI NEGARA (MANAJEMEN DAN KEBIJAKAN PUBLIK)

State-owned enterprises (SOEs) have been positioned as key drivers in advancing Indonesia’s sustainability agenda, yet the effectiveness of their Environmental, Social, and Governance (ESG) implementation remains underexamined. This research evaluates the implementation of Pertamina’s ESG policies within PGN Saka Energi Indonesia as a representative subsidiary, employing Compliance Theory to move beyond ratings-based assessments and capture the behavioral dimensions of implementation. The analysis incorporates surface-level compliance, reflected in adherence to Indonesian regulatory frameworks such as POJK No. 51/2017 and Ministry of SOEs directives, as well as internal ESG scoring through Pertamina’s APQA instrument. Findings show that PGN Saka achieves moderately high surface-level compliance, driven largely by the presence of structured instruments, formal procedures, and external certifications. However, a deeper assessment of compliance types reveals that the organization is situated predominantly at the habitual stage rather than the normative maturity expected for fully effective ESG implementation. High habitual compliance is enabled by a dense ecosystem of instruments, yet the same density constrains progression toward normative commitment due to overlap, fragmentation, and administrative burden across multiple authorities. The study identifies four key adjustments needed to advance normative compliance: calibrating the volume and overlap of instruments, ensuring leader-driven and ESG-framed socialization, strengthening recognition-based motivation, and addressing uncontrollable factors such as indicator visibility and leadership stability. These insights highlight both the progress and structural constraints of ESG implementation within SOEs, underscoring the need for more coherent, value-oriented governance to achieve sustainable and long-term ESG maturity.

State-owned enterprises (SOEs) have been positioned as key drivers in advancing Indonesia’s sustainability agenda, yet the effectiveness of their Environmental, Social, and Governance (ESG) implementation remains underexamined. This research evaluates the implementation of Pertamina’s ESG policies within PGN Saka Energi Indonesia as a representative subsidiary, employing Compliance Theory to move beyond ratings-based assessments and capture the behavioral dimensions of implementation. The analysis incorporates surface-level compliance, reflected in adherence to Indonesian regulatory frameworks such as POJK No. 51/2017 and Ministry of SOEs directives, as well as internal ESG scoring through Pertamina’s APQA instrument. Findings show that PGN Saka achieves moderately high surface-level compliance, driven largely by the presence of structured instruments, formal procedures, and external certifications. However, a deeper assessment of compliance types reveals that the organization is situated predominantly at the habitual stage rather than the normative maturity expected for fully effective ESG implementation. High habitual compliance is enabled by a dense ecosystem of instruments, yet the same density constrains progression toward normative commitment due to overlap, fragmentation, and administrative burden across multiple authorities. The study identifies four key adjustments needed to advance normative compliance: calibrating the volume and overlap of instruments, ensuring leader-driven and ESG-framed socialization, strengthening recognition-based motivation, and addressing uncontrollable factors such as indicator visibility and leadership stability. These insights highlight both the progress and structural constraints of ESG implementation within SOEs, underscoring the need for more coherent, value-oriented governance to achieve sustainable and long-term ESG maturity.

Kata Kunci : ESG implementation, compliance theory, normative compliance, habitual compliance, principal–agent, state-owned enterprises, Pertamina, PGN Saka, Indonesia, sustainability governance