Indonesian Seafood SMETA/SEDEX Audits: 2025 Essential Guide

A practical, Indonesia-specific evidence checklist for SMETA 2- and 4-pillar audits in seafood processing. Exactly which documents auditors sample, how many months to prepare, Indonesian document names (BPJS, UMK, PKWT), vessel-level proofs, and the most common gaps we see on the shop floor.

If you run an Indonesian seafood plant and want a clean SMETA outcome in 2025, you don’t need theory. You need an evidence pack that mirrors what auditors actually sample. Below is the exact, Indonesia-specific documentation we prepare for audits at our own facilities and partners. We’ve learned this from years of working with Sedex auditors who dig into wages, hours, and third-party labor in seafood.

The three buckets of evidence auditors always test

People and labor. Contracts, age proofs, BPJS, working hours, overtime, agency labor, grievance mechanisms.
Wages and hours. Time, payroll, attendance, overtime approvals, piece-rate conversions, leave, deductions.
Site and management. Permits, environmental monitoring, waste, utilities, business ethics (for 4-pillar), and on-site conditions like dorms/canteens.

Focus your prep here. The rest flows from these.

What documents do SMETA auditors check in Indonesian seafood factories?

In our experience, auditors sample a core set across HR, payroll, HSE, and environment. Here’s the short list with Indonesian document names where relevant.

HR and contracts

Master employee list by category: PKWTT (permanent), PKWT (fixed-term), harian lepas/daily, magang/interns, outsourcing/agency.
Contracts: PKWTT, PKWT with job role, duration, renewal history. Addenda for wage changes or reassignments.
KTP copies or other legal age proof, and onboarding list with start dates.
Company regulations or peraturan perusahaan and/or collective agreement (PKB) if applicable.
Grievance mechanism SOP, hotline/posters, complaint logs, resolution records in Bahasa Indonesia.

Wages, time, and benefits

Attendance/time records: biometric logs or timesheets, overtime approval forms, shift rosters, weekly rest day allocation.
Payroll registers: gross wage, UMK compliance, overtime calculation, allowances, BPJS deductions and employer contributions, proof of payment (bank transfer files or signed payslips).
UMK evidence: SK Gubernur for current UMK/UMP (2025 set under PP 51/2023), internal wage matrix per grade.
Leave records: annual, sick, maternity/paternity, and holiday rosters.
BPJS Ketenagakerjaan and BPJS Kesehatan: registration, monthly payment receipts, participant lists, JKK/JKM claims history, accident log.

Agency and recruitment

Agreements with labor agencies: Perjanjian Penyediaan Jasa Pekerja/Buruh or Pemborongan Pekerjaan. Agency license from Disnaker and NIB/OSS printout.
Worker deployment lists from agency, matching site timekeeping.
No worker-paid fees policy and proofs (more below).

Health, safety, and welfare

HIRADC/HAZOP or risk assessments, induction and refresher training records, fire drills, PPE issuance logs.
Medical checks for cold-room or chemical exposure roles. Accident/near-miss investigation forms.
Dormitory and canteen inspections, water potability test results, kitchen hygiene checklist.

Site, environment, and business ethics (4-pillar)

NIB/OSS profile, location permit, IMB/SLF if applicable.
Environmental approvals: SPPL for low risk or UKL/UPL/AMDAL for larger operations. Technical approvals for wastewater, and lab results vs permit limits.
Hazardous waste: contracts with licensed collectors and processor, Manifest Limbah B3, waste inventory and storage inspection logs.
Refrigeration and ammonia systems: leak checks, maintenance logs, emergency response drills.
Energy and water usage trend, 12 months minimum. Waste segregation and recycling records.
Business ethics: anti-bribery policy, conflict-of-interest declaration, gifts/hospitality register, training logs.

Traceability touchpoints

Supplier approval list, receiving logs, COAs, product labels that tie to batch lots. For lines like Grouper Fillet (IQF) or Yellowfin Saku (Sushi Grade), ensure batch-to-supplier matching is quick. Auditors often spot-check this alongside labor sampling.

Practical takeaway: put all of the above in one shared, read-only folder by topic, with the last 12 months on top. Auditors appreciate fast retrieval.

How many months of time, payroll, and attendance records are required?

We prepare 12 months. Auditors typically sample 3–6 months, but they will want:

The last closed payroll month.
A peak season month (e.g., tuna, squid, or snapper surge).
A low season month for contrast.

Make sure three data streams reconcile: biometric time, overtime approvals, and payroll calculation. If you use piece rates on trimming or filleting, show the conversion to hourly equivalent and top-ups to meet UMK each pay period. Keep signed overtime consent forms and weekly rest day proof.

Do we need fishing vessel crew documents if we only process?

Short answer. Usually not, unless you own or control vessels. But. Buyers and auditors increasingly ask how you screen upstream labor risks. If you’re strictly a processor buying landed fish, prepare:

Supplier due diligence: signed code of conduct, risk assessment, and annual re-approval.
Supplier vessel list for sensitive species or markets. For tuna items like Yellowfin Saku (Sushi Grade) or Yellowfin Steak, keep accessible the landing site, vessel ID, and valid licenses (SIPI/SIKPI) via your supplier.
If you own or charter vessels, or operate a vertically integrated line, be ready with crew contracts, wage slips, hours-of-rest logs, and proof of ILO C188 alignment. Include insurance/accident coverage and provisioning records.

Practical takeaway: even processors benefit from a vessel list per supplier for high-risk fisheries. It shows credible due diligence without overreaching.

Which BPJS documents should we prepare and how recent should they be?

Auditors ask for current-month confirmation and a history trail. We compile:

BPJS Ketenagakerjaan and Kesehatan registration letters and company IDs.
Participant list matching payroll headcount, updated monthly.
The last 3–6 months of BPJS payment receipts and SIPP/VA proof of transfers.
JKK/JKM claim records and work accident logs with corrective actions.
Inclusion timing. Evidence that PKWT, PKWTT, and agency workers (if under your payroll) are enrolled from day one as required by contract.

A common gap is mismatch between payroll and BPJS participant totals. Reconcile headcount monthly.

How can we prove workers did not pay recruitment fees to agents?

Here’s what actually convinces auditors:

Policy and flowchart in Bahasa and English stating workers pay zero fees. Include a reimbursement mechanism if a fee is discovered later.
Signed worker declarations during onboarding that no fees were paid. Keep translations.
Vendor file for each agency: license, invoice structure, and proof that the company pays all legitimate costs (medical checks, admin, transport) directly. No salary deductions.
Worker interview corroboration. Train HR not to coach. If any fees surface, show same-day reimbursement evidence and CAPA.

We also keep a quarterly check. Random interviews with new hires and a quick receipt scan. It’s saved us more than once.

What environmental permits are commonly requested in a 4-pillar SMETA for seafood?

Wastewater treatment and safety controls at a seafood plant: a technician in PPE takes a water sample from an aeration tank while yellow drums sit on containment pallets near a secure storage area; refrigeration condensers and insulated pipes are visible in the background.

Environmental approvals. SPPL or UKL-UPL/AMDAL depending on capacity and risk. Keep the approval letter and any monitoring commitments.
Wastewater. Permit or technical approval for discharge, design of your IPAL, and 3–6 recent lab results within limits. Keep calibration and chain-of-custody records.
Hazardous waste (Limbah B3). Contract with a licensed collector/processor, manifest records, inventory and temporary storage inspection logs.
Refrigeration and cold storage. Ammonia system inspection, leak log, emergency drill records, and training for responders.
Energy, water, waste. 12 months of consumption data, reduction targets, and actions. Simple is fine if credible.
Ethics. Anti-bribery policy, training, and gifts register. Auditors will ask who can approve payments and how conflicts are declared.

Tip. Put your last internal environmental audit and CAPA on top. It shows control and momentum.

Will auditors interview agency and daily workers, and what records must we show?

Yes. They will deliberately interview agency, PKWT, and daily workers. Have ready:

Worker lists by employment type and department. No supervisors in selection.
Contracts that match actual job duties and hours.
Pay parity evidence. Same base pay and benefits for agency vs direct in the same role.
Time and pay records that align to interviews. No cash-in-hand exceptions.
Return-of-ID policy. Workers hold their own documents, confirmed by interview and SOP.

If you use daily workers regularly, keep rotation logic and days worked per month. Chronic full-time patterns without proper contracts trigger non-conformities.

Two non-obvious checks that avoid most wage/hour findings

Triangulate schedules. Production plan, time clock extracts, and overtime approvals should tell the same story. We run a weekly three-way spot check. It takes 20 minutes and prevents audit-day surprises.
Pay-day audit. Randomly pick five workers across roles and rebuild their pay from the ground up. Hours, OT rates (1.5x first hour, 2x next), allowances, BPJS, take-home. If you can reconcile in 10 minutes per worker, you’re ready.

The five most common gaps we see in Indonesian seafood plants

UMK misalignment after the annual update. Keep the 2025 SK Gubernur printed and your wage matrix adjusted on the effective date.
Agency file thin on licenses. Get Disnaker approval copies and keep them current.
BPJS headcount mismatch with payroll. Reconcile monthly and keep the email trail.
Piece-rate conversions undocumented. Add a simple SOP and a calculator sheet.
Environmental sampling gaps. Missed one quarter of wastewater tests or no B3 manifest signatures. Build a calendar and assign backups.

Quick pre-audit run-through you can do this week

Update the Sedex SAQ and attach current permits, wage matrix, and BPJS proofs.
Print three months of time, payroll, OT forms. Choose low, peak, and last month.
Reconcile BPJS participants to payroll headcount. Fix gaps now.
Re-verify agency license and zero-fee documentation. Do two fresh new-hire interviews.
Walk dorms and canteen with a checklist. Photograph fixes before-and-after.

If you want a facility-specific evidence pack mapped to your UMK, seasonality, and agency model, Contact us on whatsapp. We can also align traceability sampling to your priority lines, whether that’s Grouper Bites (Portion Cut) for retail or Yellowfin Saku (Sushi Grade) for sushi channels. If you’re exploring new items, you can also View our products.

What’s interesting is how fast audit expectations have shifted in the last six months. There’s tighter scrutiny on recruitment fees, agency licenses, and credible wastewater monitoring. The facilities that fare best keep it simple. One source of truth per topic, monthly reconciliations, and a short narrative for every anomaly. That’s the playbook we use, and it works.