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20260410_RATU_Rencana Transaksi Material Dengan Persetujuan RUPS_32069963_lamp4.pdf

Asset transaction Needs review RATU

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            DISCLOSURE OF INFORMATION TO SHAREHOLDERS
            PT RAHARJA ENERGI CEPU TBK (THE “COMPANY”)

This Disclosure of Information is provided by the Company in order to comply with Financial
Services Authority Regulation No. 17/POJK.04/2020 on Material Transactions and Changes
in Business Activities in conjunction with Financial Services Authority Regulation No.
31/POJK.04/2015 on Disclosure of Material Information or Facts by Issuers or Public
Companies (including its amendments).




                            PT Raharja Energi Cepu Tbk

                                  Business Activities:
     Engaging in holding company activities, other management consulting activities,
                    crude petroleum mining, and natural gas mining.

                                       Head Office:
                          Office Park Thamrin Residences A01-05
                    Jl. Thamrin Boulevard, Kebon Melati, Tanah Abang
                           Central Jakarta, DKI Jakarta, 10220
                                         Indonesia

                                Telephone: (021) 23579812
                                Facsimile: (021) 23579812
                                  Email: corsec@rec.co.id
                                  Website: www.rec.co.id


 If you encounter any difficulty in understanding the information set out in this Disclosure
 of Information or are uncertain in making a decision, you are advised to consult with your
 securities broker, investment manager, legal advisor, public accountant, or other
 professional advisor.


 The Board of Directors and the Board of Commissioners of the Company, individually and
 jointly, are fully responsible for the completeness and accuracy of all material information
 or facts contained in this Disclosure of Information and affirm that the information
 presented herein is true and that there are no undisclosed material facts that could render
 such material information inaccurate and/or misleading.



         This Disclosure of Information is issued in Jakarta on 31 March 2026




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                             DEFINITIONS AND TERMS


“Affiliate”              :   Means:
                              a. a familial relationship by marriage or descent up to the
                                 second degree, either horizontally or vertically;
                              b. relationship between a party and its employees, directors,
                                 or commissioners;
                              c. a relationship between two companies having one or more
                                 members of the same board of directors or board of
                                 commissioners;
                              d. a relationship between a company and a party that
                                 directly or indirectly controls or is controlled by such
                                 company;
                              e. a relationship between two companies that are directly or
                                 indirectly controlled by the same party; or
                              f. a relationship between a company and its major
                                 shareholders.

“Conflict of Interest”   :   A situation where there is a divergence between the economic
                             interests of a public company and the personal economic
                             interests of members of the Board of Directors, members of
                             the Board of Commissioners, major shareholders, or
                             controlling parties, which may be detrimental to the public
                             company.

“Indonesia Stock         :   A stock exchange as referred to in Law No. 8 of 1995 on Capital
Exchange” or “IDX”           Markets (as amended), in this case operated by PT Bursa Efek
                             Indonesia domiciled in Jakarta.

“Board of                :   The corporate organ responsible for general and/or specific
Commissioners”               supervision in accordance with the articles of association and
                             for providing advice to the Board of Directors.

“Board of Directors”     :   The corporate organ vested with full authority and
                             responsibility for managing the company for the benefit of the
                             company in accordance with its purposes and objectives, as
                             well as representing the company both within and outside the
                             court in accordance with the articles of association.

“Guarantee to            :   A corporate guarantee and cash deficit guarantee provided by
Creditors”                   the Company to secure the obligations of PT REM in
                             connection with the planned financing facility for the
                             Acquisition Transaction by PT REM.

“Corporate Guarantee     :   A corporate guarantee provided by the Company to secure the
to Seller”                   obligations of PT REM in connection with the Acquisition
                             Transaction by PT REM as stipulated under the Share Sale
                             and Purchase Agreement.

“Disclosure of           :   This disclosure of information provided to the Company’s
Information”                 shareholders for the purpose of complying with POJK No.
                             17/2020.




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“KJPP FDI&R”             :   Ferdinand, Danar, Ichsan & Rekan Public Appraisal Services
                             Office (FDI&R), acting as an Appraiser duly licensed based on
                             the Decree of the Minister of Finance No. 2.22.0176 KMK
                             460/KM.1/2022 dated 21 April 2022 and registered as a
                             capital market supporting professional services firm with the
                             OJK pursuant to the Certificate of Registration of Capital
                             Market Supporting Professionals No. STTD.PB-47/PJ-
                             1/PM.021/2024.

“Company’s               :   The Company’s Interim Consolidated Financial Statements
Consolidated Financial       for the period ended 30 November 2025, which have been
Statements”                  audited by Public Accounting Firm Paul Hadiwinata, Hidajat,
                             Arsono, Retno, Palilingan & Rekan as set forth in Report No.
                             PHHARP-AL/039/RD/AD/2026 dated 16 March 2026, with
                             an unqualified opinion in all material respects.

“Fairness Opinion        :   Fairness     Opinion      Report      No.     00063/2.0176-
Report dated 30 March        00/BS/02/0213/1/III/2026 dated 30 March 2026, issued by
2026”                        KJPP FDI&R to provide an opinion on the fairness of the
                             Acquisition Transaction Series and the provision of Guarantee
                             to Creditors, for the purpose of complying with POJK No.
                             17/2020.

“MOL”                    :   The Minister of Law of the Republic of Indonesia, formerly
                             known as the Minister of Law and Human Rights of the
                             Republic of Indonesia (“MOLHR”).

“Financial Services      :   An independent authority whose functions, duties, and
Authority”, “FSA” or         powers include regulation, supervision, examination, and
“OJK”                        investigation in the capital markets, insurance, pension
                             funds, financing institutions, and other financial services
                             sectors, as referred to in Law No. 21 of 2011 on the Financial
                             Services Authority, as amended.

“Shareholders”           :   Parties that hold beneficial interests in the Company’s shares,
                             whether in scrip form or in collective custody, which are
                             deposited and administered in securities accounts with the
                             Indonesian Central Securities Depository, and are recorded in
                             the Company’s Register of Shareholders maintained by the
                             Share Registrar appointed by the Company.

“Controller”             :   A party that, directly or indirectly:
                             a. owns more than 50% (fifty percent) of the total issued and
                                fully paid-up shares with voting rights in a company; or
                             b. has the ability to determine, directly or indirectly and by
                                any means, the management and/or policies of a
                                company.

“Appraiser”              :   An individual who, by virtue of their expertise, carries out
                             valuation activities in the capital market.

“Novation Agreement”     :   The Novation Agreement dated 24 December 2025, entered
                             into and executed by and among PT REM as the New Lender,
                             SMS Offshore Overseas Limited as the Original Lender, SMS
                             Development Limited as the Borrower, and Cosimo Borrelli of
                             Kroll HK Limited as the receiver of SMS Offshore Overseas
                             Limited (each as defined in the Novation Agreement), the
                             execution of which has been disclosed by the Company to its


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                           Shareholders through a disclosure of material information
                           dated 24 December 2025.

                           This Novation Agreement was entered into in connection with
                           the transfer (novation) of all rights, interests, and obligations
                           of SMS Offshore Overseas Limited to PT REM, under a
                           shareholder loan agreement dated 24 December 2025 between
                           SMS Offshore Overseas Limited and SMS Development
                           Limited.

“Company”              :   PT Raharja Energi Cepu Tbk, a public company domiciled in
                           South Jakarta, whose shares are listed on the Indonesia Stock
                           Exchange, and established under the laws of the Republic of
                           Indonesia.

“Controlled Company”   :   A company that is directly or indirectly controlled by a public
                           company as defined under POJK No. 42/2020.

“POJK No. 15/2020”     :   OJK Regulation No. 15/POJK.04/2020 on the Planning and
                           Implementation of General Meetings of Shareholders of Public
                           Companies.

“POJK No. 17/2020”     :   OJK Regulation No. 17/POJK.04/2020 on                   Material
                           Transactions and Changes in Business Activities.

“POJK No. 42/2020”     :   OJK Regulation No. 42/POJK.04/2020 on Affiliated
                           Transactions and Conflict of Interest Transactions.

“Share Sale and        :   The Share Sale and Purchase Agreement dated 25 December
Purchase Agreement”        2025, entered into and executed by and among SMS Offshore
or “SSPA”                  Overseas Limited as the Seller, Cosimo Borrelli of Kroll HK
                           Limited as the Sales Agent, PT REM as the Purchaser, the
                           Company as the Purchaser’s Guarantor, and OCP Asia Fund
                           IV and OCP Asia Fund V as the New Lenders (each as defined
                           in the SSPA), the execution of which has been disclosed by the
                           Company to its Shareholders through a disclosure of material
                           information dated 25 December 2025.

                           The SSPA was entered into in connection with the acquisition
                           of 100% (one hundred percent) of the shares in SMS
                           Development Limited by PT REM.

“PT REI”               :   PT Raharja Energi Indonesia, a limited liability company
                           domiciled in Central Jakarta, established under the laws of
                           the Republic of Indonesia, of which 99% (ninety-nine percent)
                           of its shares are owned by the Company. Accordingly, PT REI
                           is a Controlled Company of the Company.

“PT REM”               :   PT Raharja Energi Madura, a limited liability company
                           domiciled in South Jakarta, established under the laws of the
                           Republic of Indonesia, of which 51% (fifty-one percent) of its
                           shares are owned by PT REI. Accordingly, PT REM is an
                           indirectly Controlled Company of the Company through PT
                           REI.

“Rp” or “Rupiah”       :   Indonesian Rupiah, being the lawful currency of the Republic
                           of Indonesia.

“GMS”                  :   General Meeting of Shareholders of the Company.

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 “EGMS”                       :   Extraordinary    General Meeting    of Shareholders of the
                                  Company.

 “Affiliated Transaction”     :   Any activity and/or transaction conducted by a public
                                  company or its controlled company with an Affiliate of such
                                  public company or an Affiliate of members of the Board of
                                  Directors, Board of Commissioners, major shareholders, or
                                  controllers, including any activity and/or transaction
                                  conducted by a public company or its controlled company for
                                  the benefit of such Affiliates.

 “Acquisition                 :   The acquisition of 100% (one hundred percent) of the shares
 Transaction by PT                in SMS Development Limited by PT REM, carried out through
 REM”                             (i) the Novation Agreement and (ii) the Share Sale and
                                  Purchase Agreement.

 “Material Transaction”       :   Any transaction carried out by a public company or its
                                  controlled company that meets the value threshold as
                                  stipulated under POJK No. 17/2020.

 “Company Law”                :   Law No. 40 of 2007 concerning Limited Liability Companies,
                                  as amended.

 “USD”                        :   United States Dollar, being the lawful currency of the United
                                  States of America.



                                      INTRODUCTION


The information set out in this Disclosure of Information has been prepared to comply with
POJK No. 17/2020 in connection with several Material Transactions to be carried out by (i)
PT REM, a Controlled Company of the Company; and (ii) the Company.

The Material Transaction to be undertaken by PT REM is the Acquisition Transaction by
PT REM, while the Material Transactions to be undertaken by the Company consist of
(i) the provision of a Corporate Guarantee to the Seller; and (ii) the provision of a
Guarantee to Creditors.

The Acquisition Transaction by PT REM and the provision of the Corporate Guarantee to the
Seller are hereinafter collectively referred to as the “Acquisition Transaction Series.”

The Board of Directors and the Board of Commissioners of the Company, individually and
jointly, state that the Acquisition Transaction Series and the provision of the Guarantee to
Creditors constitute Material Transactions, as the value of such transactions exceeds 20%
(twenty percent) of the Company’s equity as of 30 November 2025, as reflected in the
Company’s Consolidated Financial Statements.

Considering the relationship between the Company and PT REM as a Controlled Company,
the Material Transactions in the form of the provision of the Corporate Guarantee to the Seller
and the Guarantee to Creditors constitute Affiliated Transactions as defined under POJK No.
42/2020. However, such transactions do not constitute Conflict of Interest Transactions.
Furthermore, pursuant to Article 33 letter (a) of POJK No. 17/2020 and Article 24 paragraph
(1) of POJK No. 42/2020, where a Material Transaction also constitutes an Affiliated
Transaction, the Company is only required to comply with POJK No. 17/2020. Accordingly,
this Disclosure of Information is provided in compliance with POJK No. 17/2020.



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Pursuant to Article 11 letter (c) of POJK No. 17/2020, the Material Transaction in the form
of the provision of the Guarantee to Creditors is exempt from the requirement to appoint an
Appraiser and to obtain prior approval from the Shareholders. Nevertheless, as part of the
implementation of good corporate governance, compliance with Article 12 paragraph (8) of
the Articles of Association of the Company, and taking into account Article 102 of the
Company Law, the Company has obtained a fairness opinion in respect of such transaction
based on the Fairness Opinion Report dated 30 March 2026, and such transaction will still
be submitted for approval by the Shareholders at the EGMS to be held on 7 May 2026 (“EGMS
7 May 2026”).

Meanwhile, the Acquisition Transaction by PT REM and the Corporate Guarantee to the Seller
are not subject to such exemption. Therefore, in accordance with Article 6 paragraph (1)
letters (a) and (d) of POJK No. 17/2020, the Company has obtained a fairness opinion and
approval for such transactions will be sought at the EGMS 7 May 2026.

In connection with the EGMS 7 May 2026, the Company has announced the plan to convene
the EGMS on 31 March 2026 through the Company’s website, the PT Kustodian Sentral Efek
Indonesia’s website (eASY.KSEI), and the IDX website, in accordance with POJK No. 15/2020.

In compliance with POJK No. 17/2020, this Disclosure of Information is made available
through the Company’s website and the IDX website.


                     DESCRIPTION OF MATERIAL TRANSACTIONS


A. OBJECT AND VALUE OF MATERIAL TRANSACTIONS
   In connection with the implementation of the Acquisition Transaction Series and the
   provision of the Guarantee to Creditors, the relevant parties have entered into the
   Novation Agreement, the SSPA, and a supplemental letter dated 17 March 2026, which
   principally contain the following terms:
    a.   Novation Agreement

         Parties to the             :    1. PT REM as the New Lender;
         Transaction
                                         2. SMS Offshore Overseas       Limited   as the
                                            Original Lender;
                                         3. SMS Development Limited as the Borrower;
                                            and
                                         4. Cosimo Borrelli of Kroll HK Limited as
                                            receiver of SMS Offshore Overseas Limited,

                                        (each as defined in the Novation Agreement).

         Value and Object of        :   The object of the novation is a shareholder loan
         Novation                       agreement amounting to USD 59,208,570 (the
                                        “Loan Agreement”).

                                        Such loan was previously granted by SMS
                                        Offshore Overseas Limited to SMS Development
                                        Limited.

                                        The amount represents the transfer price payable
                                        by the new lender to the original lender.
         Novation Mechanism         :   The novation mechanism is as follows:




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                              1. PT REM shall pay USD 59,208,570 to SMS
                                 Offshore Overseas Limited no later than two
                                 business days after the fulfillment of the
                                 conditions precedent under the SSPA; and
                              2. Upon such payment, all rights, interests, and
                                 obligations of SMS Offshore Overseas Limited
                                 as creditor under the Loan Agreement shall be
                                 transferred to PT REM (the “Effective Time”).
     Scope of Agreement   :   The Novation Agreement governs the transfer
                              (novation) of all rights, interests, and obligations
                              of SMS Offshore Overseas Limited under the Loan
                              Agreement to PT REM, effective as of the Effective
                              Time.

                              Key terms of the Loan Agreement include:
                              a. Principal Amount
                                   USD 59,208,570
                              b. Maturity
                                   The loan does not have a fixed term and shall
                                   become due upon demand for payment by the
                                   lender.
                              c. Interest Rate
                                   The loan bears interest at a rate of 0% (zero
                                   percent) per annum or such other interest rate
                                   as may be determined by the lender.
                              d. Repayment Schedule
                                   Repayment of the loan shall be made upon
                                   written demand by the lender, in accordance
                                   with the payment mechanism as stipulated in
                                   the Loan Agreement, including but not limited
                                   to cash payment or other mechanisms as may
                                   be agreed by the parties.
                              e. Collateral

                                   None.

                              f.   Prohibited Actions by the Debtor

                                   None.

     Governing Law        :   English Law

     Dispute Resolution   :   Any dispute shall be resolved through arbitration
                              at the Singapore International Arbitration Centre
                              (SIAC), with the seat of arbitration in Singapore
                              and conducted in the English language.



b.   SSPA

     Parties to the       :    1. SMS Offshore Overseas Limited as the Seller;
     Transaction


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                             2. Cosimo Borrelli of Kroll HK Limited as the
                                Sales Agent;
                             3. PT REM as the Purchaser;
                             4. the Company as the Purchaser’s Guarantor;
                                and
                             5. OCP Asia Fund IV and OCP Asia Fund V, each
                                as the New Lenders,


                             (each as defined in the SSPA)
Scope of the Agreement   :   The SSPA governs the acquisition of 100% (one
                             hundred percent) of the shares held by SMS
                             Offshore Overseas Limited in SMS Development
                             Limited by PT REM, including the transfer of all
                             rights and interests attached to such shares to PT
                             REM.

                             SMS Development Limited is an investment
                             company holding shares in Husky-CNOOC
                             Madura Limited (“HCML”), which engages in the
                             exploration and production of crude oil and
                             natural gas in the Madura Strait, Indonesia,
                             pursuant to a production sharing contract (PSC)
                             between HCML and SKK Migas (“PSC”).

                             In addition, the SSPA also provides for the
                             granting of a corporate guarantee by the Company
                             in respect of PT REM’s obligations in connection
                             with the implementation of the transaction in
                             accordance with the provisions of the SSPA.
Transaction Value and    :   The transaction value consists of:
Payment Mechanism
                             a) Base transaction price
                                USD 62,510,594
                             b) Initial deposit
                                PT REM is required to pay a deposit of USD
                                12,500,000 upon the execution of the SSPA on
                                25 December 2025.
                             c) Contingent payment
                                SMS Development Limited             may    receive
                                additional payments of:
                                       USD 16.5 million, if the PSC extension is
                                        obtained; and
                                       an additional USD 3 million if the PSC
                                        extension is obtained before 30 June 2027.
Conditions Precedent     :   The transaction may only be completed upon the
                             fulfillment of, among others, the following
                             conditions:
                             1. approval of the Company’s GMS on the
                                Material Transaction in accordance with OJK
                                regulations;



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                                   2. settlement of certain loans held by SMS
                                      Development Limited;
                                   3. SMS Offshore Overseas Limited no longer
                                      having the status of creditor of SMS
                                      Development Limited; and
                                   4. where required, approval from independent
                                      shareholders in accordance with OJK
                                      regulations on Affiliated Transactions.
                                  If such conditions are not fulfilled within a
                                  maximum period of six months from the date of
                                  execution, the SSPA may be terminated.
     Governing Law            :   English Law

     Dispute Resolution       :   Any dispute shall be resolved through arbitration
                                  at the Singapore International Arbitration Centre
                                  (SIAC), with the seat of arbitration in Singapore
                                  and conducted in the English language.


c.   Supplemental letter dated 17 March 2026

     Parties to the           :   1. the Company; and
     Transaction
                                  2. PT Petro Indo Pasifik (“PT PIP”).

     Scope of the Agreement   :   The supplemental letter dated 17 March 2026 sets
                                  out the agreement between the Company and PT
                                  PIP in relation to the proposed acquisition of a
                                  bank financing facility for the Acquisition
                                  Transaction, whereby the obligations arising from
                                  the Guarantee to Creditors in respect of such
                                  facility shall be borne proportionally, with 51%
                                  (fifty-one percent) by the Company and 49% (forty-
                                  nine percent) by PT PIP.

                                  If either party makes payment in respect of any
                                  creditor claim arising from the default of PT REM,
                                  the other party shall reimburse such payment in
                                  accordance with its respective proportion on an
                                  unconditional and irrevocable basis no later than
                                  3 (three) business days prior to the due date of
                                  such claim, and such obligation shall remain fully
                                  effective and shall not be reduced or discharged
                                  under any circumstances, including any right of
                                  the paying party to claim reimbursement for
                                  penalties or additional interest arising from the
                                  other party’s delay in payment.

                                  Accordingly, the risks that may arise for the
                                  Company in connection with the execution of this
                                  supplemental letter include the obligation to
                                  comply with all terms and conditions under the
                                  financing agreement, as well as the potential
                                  claims for payment by creditors in relation to
                                  obligations arising from the provision of
                                  guarantees to creditors.




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                                          As of the date of this Disclosure of Information, the
                                          guarantee terms and the guaranteed amount have
                                          not yet been determined.
       Governing Law                 :    Laws of the Republic of Indonesia


B. PARTIES UNDERTAKING THE MATERIAL TRANSACTION

  1. PT REM

     Brief History
     PT REM is a limited liability company established and governed under the laws of the
     Republic of Indonesia based on Deed No. 9 dated 5 December 2025, made before
     Muhammad Hanafi, S.H., Notary in Jakarta. The deed of establishment has been
     approved by the MOL pursuant to Decree No. AHU-0107173.AH.01.01.TAHUN 2025
     dated 12 December 2025 (the “Deed No. 9/2025” or the “Articles of Association of
     PT REM”).

     Based on the Articles of Association of PT REM, the purposes and objectives of PT
     REM are to engage in holding company activities and other management consulting
     activities.

     Capital Structure and Shareholding Composition
     Based on Deed No. 9/2025, the shareholding structure of PT REM is as follows:

                              Number of        Par Value per       Total Nominal Value
         Description                            Share (Rp)                                  %
                               Shares                                      (Rp)
      Authorized Capital
                               500,000              1,000,000       500,000,000,000
      Issued and Paid-up Capital
      PT REI                   127,500                              127,500,000,000        51%
                                                    1,000,000
      PT PIP                   122,500                              122,500,000,000        49%
      Total                    250,000                              250,000,000,000       100%


     Management and Supervision
     Based on Deed No. 9/2025, the composition of the Board of Commissioners and the
     Board of Directors of PT REM is as follows:
     Board of Commissioners
         Commissioner                : Sumantri

     Board of Directors
         Director                    : Adrian Hartadi


     Address and Contact Information of PT REM
      Address     : Graha Iskandarsyah Lt. 9, Jl. Iskandarsyah Raya No. 66,
                     Desa/Kelurahan Melawai, Kec. Kebayoran Baru, Kota Adm.
                     Jakarta Selatan, Provinsi DKI Jakarta, 12160
      Telephone   : (021) 23579812
      Facsimile   : (021) 23579812
      Email       : raharjaenergimadura@gmail.com

   2. Company

     Brief History
     The Company is a public limited liability company established and governed under
     the laws of the Republic of Indonesia based on Deed No. 7 dated 16 October 2006,


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made before Ny. Indah Setyaningsih, S.H., Notary in Jakarta. The deed of
establishment was approved by the MOLHR pursuant to Decree No. W7-
06263.HT.01.01.TH 2007 dated 7 June 2007.

The Company’s Articles of Association have been amended from time to time, with the
latest amendment set forth in Deed No. 18 dated 20 September 2024, made before
Rini Yulianti, S.H., Notary in East Jakarta. Such amendment has been approved by
the MOLHR pursuant to Decree No. AHU-0059751.AH.01.02.TAHUN 2024 dated 20
September 2024 and has been duly notified as evidenced by Receipt of Notification of
Amendment to the Articles of Association No. AHU-AH.01.03-0193996 dated 20
September 2024 and Receipt of Notification of Amendment to Company Data No. AHU-
AH.01.09-0254185 dated 20 September 2024.

(collectively referred to as the “Articles of Association of the Company”).

Based on Article 3 of the Articles of Association of the Company, the purposes and
objectives of the Company are to engage in holding company activities, mining, other
management consulting activities, crude oil mining, and natural gas mining.

To achieve such purposes and objectives, the Company may conduct the following
business activities:
 1. Main business activities
    i. Holding company activities (KBLI 64200)
    ii. Other management consulting activities (KBLI 70209)

2. Supporting business activities
   i. Crude oil mining (KBLI 06100)
   ii. Natural gas mining (KBLI 06201)

Capital Structure and Shareholding Composition
Based on the Company’s Register of Shareholders prepared by the Share Registrar,
PT Ficomindo Buana Registrar, the shareholding structure of the Company as of 27
February 2026 is as follows:

                         Number of       Par Value per    Total Nominal Value
     Description                          Share (Rp)                              %
                          Shares                                  (Rp)
 Authorized Capital
                       10,000,000,000         10            100,000,000,000
 Issued and Paid-up Capital
 PT Rukun Raharja
                       1,867,121,000                        18,671,210,000      68.77%
 Tbk
 Alexandra    Sinta
                              50,000                              500,000       0.00%
 Wahjudewanti                                 10
 Adrian Hartadi               3,600                                36,000       0.00%
 Public                 847,879,200                             8,478,792,000   31.23%
 Total                 2,715,053,800                        27,150,538,000      100%


Management and Supervision
Based on the Deed of Statement of Resolutions of the Company’s Meeting No. 35 dated
30 April 2025, made before Rini Yulianti, S.H., Notary in East Jakarta, which has
been duly notified to the MOL through the Receipt of Notification of Amendment to
Company Data No. AHU-AH.01.09-0221474 dated 5 May 2025 and registered in the
Company Register No. AHU-0097145.AH.01.11.Tahun 2025 dated 5 May 2025, the
composition of the Board of Commissioners and the Board of Directors of the
Company is as follows:
Board of Commissioners
  President Commissioner                : Orias Petrus Moedak


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       Commissioner                       : Merly
       Independent Commissioner           : Taufik Ahmad

     Board of Directors
       President Director                 : Sumantri
       Director                           : Alexandra Sinta Wahjudewanti
       Director                           : Adrian Hartadi

     Address and Contact Information of the Company
      Address     : Office Park Thamrin Residences A01-05, Jl. Thamrin Boulevard,
                     Kebon Melati, Tanah Abang, Jakarta Pusat, DKI Jakarta, 10220,
                     Indonesia
      Telephone   : (021) 23579812
      Facsimile   : (021) 23579812
      Email       : corsec@rec.co.id

C. INFORMATION REGARDING THE PARTY WHOSE SHARES ARE THE OBJECT OF THE
   TRANSACTION

  1. SMS Development Limited

     Brief History
     SMS Development Limited (“SMSD”) was established on 20 September 2010 under
     the laws of the British Virgin Islands (BVI) as a BVI Business Company. Upon its
     establishment, the Company was domiciled at Portcullis Chambers, 4th Floor, Ellen
     Skelton Building, 3076 Sir Francis Drake Highway, Road Town, Tortola, British Virgin
     Islands VG1110.

     On 14 October 2010, SMSD completed the acquisition of a 20% shareholding interest
     in Husky-CNOOC Madura Limited (HCML), acquired from Husky Oil Madura
     Partnership and CNOOC Southeast Asia Limited, which became effective on 13
     January 2011. Since then, the principal activity of SMSD has been as a shareholder
     of HCML.

     Operationally, SMSD is an investment company holding equity participation in HCML,
     which is engaged in the exploration and production of crude oil and natural gas in the
     Madura Strait, Indonesia, pursuant to a Production Sharing Contract (“PSC”) between
     HCML and SKK Migas. As of 31 December 2020, HCML held a 100% participating
     interest in the Madura Strait PSC working area.

     The original PSC, with a term of 30 years, expired on 20 October 2012. Subsequently,
     an extension of the PSC (the “Extended PSC”) was signed on 28 October 2010 for a
     period of 20 years until 2032, unless further extended. The PSC extension also
     included amendments, among others, to the Madura Strait working area, production
     entitlements, First Tranche Petroleum, Investment Credit, Domestic Market
     Obligation, and recoverable operating costs.

     SMSD is a holding/investment company whose business activities are focused on the
     ownership and management of equity investments in other entities. SMSD does not
     conduct direct operational activities but derives economic benefits from its
     investments.

     The principal business activities of SMSD include:
      • Holding equity investments, particularly a 20% interest in HCML;
      • Managing investments and monitoring the performance of investee entities; and
      • Managing administrative and financing matters related to such investment
         activities.

     Capital Structure and Shareholding Composition

                                           12
Page 13
Based on management information and the certificate of incumbency of SMSD, the
shareholding composition of SMSD as of 30 November 2025 is as follows:

          Description              Number of Shares             Total Nominal Value (USD)        %

 SMS Offshore Overseas Limited           100                              100                   100%
 Total                                   100                              100                   100%


Management and Supervision
Based on management information and the certificate of incumbency of SMSD, the
composition of the Board of Directors of SMSD as of 30 November 2025 is as follows:

Board of Directors
  Director                         : Cosimo Borrelli
  Director                         : Benjamin John Crilly

Key Financial Highlights
The following summary of SMSD’s financial data is derived from the consolidated
financial statements of SMSD as of 30 November 2025, which have been audited by
KAP Purwanto, Susanti and Surja as reflected in their report No.
00109/2.1505/AU.1/02/1726-1/0/III/2026 dated 5 March 2026 (the “SMSD
Consolidated Financial Statements”).

Statement of Financial Position

                                      30 November                           31 December
         Description
                                      2025 (Audited)                       2024 (Unaudited)
 Total Assets                                    98,691,981                             123,285,248
 Total Liabilities                               65,821,018                              95,165,458
 Total Equity                                    32,870,963                              28,119,790

The following provides an explanation of the financial position of SMSD as of 30
November 2025 as compared to its financial position as of 31 December 2024:

Total Assets
Total assets of SMSD decreased by 19.9% to 98,691,981 as of 30 November 2025 from
123,285,248 as of 31 December 2024. This decrease was primarily attributable to a
reduction in the Company’s assets during the period, mainly due to a decline in
investment in associates from 109,460,212 as of 31 December 2024 to 84,439,399 as
of 30 November 2025.

Total Liabilities
Total liabilities of SMSD decreased by 30.8% to 65,821,018 as of 30 November 2025
from 95,165,458 as of 31 December 2024. This decrease was mainly due to a
reduction in DCA and DPP payable to CNOOC Southeast Asia Ltd. and Husky Oil
Madura.

Total Equity
Total equity of SMSD increased by 16.9% to 32,870,963 as of 30 November 2025 from
28,119,790 as of 31 December 2024. This increase was primarily attributable to
higher retained earnings.

Statement of Profit or Loss and Other Comprehensive Income

                                               30 November                    30 November
              Description
                                               2025 (Audited)                2024 (Unaudited)
 Net Revenue                                                     -                               -
 Cost of Revenue                                                 -                               -
 Share of Profit from Associates                         5,341,811                      18,700,171
 Interest Income                                           427,574                         128,395


                                           13
Page 14
      Finance Costs                                    (10,986)                   (127,835)
      Interest Expenses                               (910,198)                 (2,491,377)
      Other Expenses                                       (28)                          (8)
      Profit for the Period/Year                     4,751,173                 16,209,346

     The following provides an explanation of the statement of profit or loss and other
     comprehensive income of SMSD for the period ended 30 November 2025 as compared
     to the corresponding period ended 30 November 2024:

     Net Revenue
     SMSD did not record any direct revenue for the eleven-month period ended 30
     November 2025 or for the same period in 2024, as SMSD is an investment company
     with no direct operating revenue.

     Share of Profit from Associates
     Share of profit from associates decreased by 71.4% to 5,341,811 for the eleven-month
     period ended 30 November 2025 from 18,700,171 for the same period in 2024. This
     decrease reflects lower profit contribution from SMSD’s associate, relating to its 20%
     ownership in HCML.

     Interest Income
     Interest income increased by 233.0% to 427,574 for the eleven-month period ended
     30 November 2025 from 128,395 for the same period in 2024. This increase was
     mainly driven by higher interest income from short-term deposits of 426,628
     compared to 128,085 in the same period of 2024, as well as current account interest
     of 946 compared to 310 in the same period of 2024.

     Finance Costs
     Finance costs remained relatively stable at 107,986 for the eleven-month period ended
     30 November 2025 compared to 127,835 for the same period in 2024, representing a
     decrease of 15.5%.

     Interest Expenses
     Interest expenses decreased significantly by 63.5% to 910,198 for the eleven-month
     period ended 30 November 2025 from 2,491,377 for the same period in 2024. This
     decrease was mainly due to lower interest expenses on DCA from 2,021,139 to
     738,401, and a reduction in interest expenses on DPP from 470,238 to 171,797,
     reflecting reduced borrowings or repayment of interest-bearing obligations during the
     period.

     Profit for the Period
     Profit for the period decreased by 70.7% to 4,751,173 for the eleven-month period
     ended 30 November 2025 from 16,209,346 for the same period in 2024. This decrease
     was mainly due to the decline in share of profit from associates amounting to
     13,358,360, which could not be fully offset by the increase in interest income and the
     reduction in interest expenses during the period.

D. NATURE OF THE AFFILIATED RELATIONSHIP BETWEEN THE COMPANY AND PT
   REM

  The nature of the affiliated relationship between the Company and PT REM is as follows:
  1. PT REM is an indirect subsidiary of the Company.
  2. Pursuant to Article 1 point 1 letter d of POJK No. 42/2020, PT REM is an affiliate of
     the Company as the Company indirectly controls PT REM.
  3. The transaction between the Company and PT REM constitutes an Affiliated
     Transaction for the Company as referred to in POJK No. 42/2020.




                                           14
Page 15
 RATIONALE, CONSIDERATIONS, AND PURPOSE OF THE MATERIAL TRANSACTIONS
        AND THEIR IMPACT ON THE COMPANY’S FINANCIAL CONDITION

The implementation of the Acquisition Transaction Series and the provision of Collateral to
Creditors have been carried out by considering the potential economic benefits and added
value that may be obtained by the Company in the future. This transaction forms part of the
Company’s efforts to develop its business activities, which is expected to strengthen the
Company’s business position and support the sustainable growth of its operations.

Specifically, the Acquisition Transaction Series is based on strategic and financial
considerations, including the expansion of the upstream asset portfolio through the
acquisition of SMSD, which provides an indirect ownership of 20% in HCML as the holder of
100% participating interest in the Madura Strait PSC. This is expected to significantly expand
the Company’s reserves base and oil and gas production. In addition, this Acquisition
Transaction Series is expected to create added value for Shareholders through the
contribution of equity income from an associate entity, which as of November 2025 amounted
to USD 5,259,853 for the eleven-month period.

This transaction is also in line with the Company’s strategy to optimize its exposure in the
upstream oil and gas sector and to create operational synergies. From a financial perspective,
the Company has sufficient financial capability to execute this transaction, supported by a
strong cash position and loan facilities from banks/other financial institutions. Furthermore,
the existence of a contingent payment reflects the Company’s confidence in the prospects for
the extension of the Madura Strait PSC in the future.

To provide a more comprehensive overview of the financial impact of the implementation of
the Acquisition Transaction Series on the Company, the following presents the Company’s
and its subsidiaries’ Proforma Consolidated Financial Information prepared as of November
30, 2025 (“Proforma Consolidated Financial Information”).

Basis for Preparation of Proforma Consolidated Financial Information
The proforma has been prepared under the assumption that the following transactions had
occurred as of 30 November 2025:

 No.    Description of Proforma Adjustments
        Consolidated Financial Statements of SMSD, including the recognition of cash of USD
 (a)    14.241 million, investment in an associate of USD 84.439 million, and third-party
        liabilities of USD 6.612 million.
        Recognition of planned loan facilities from banks and/or other financial institutions
 (b)
        amounting to USD 100,000,000 as long-term financial liabilities.
        Recognition of goodwill amounting to USD 29,639,037, calculated as the difference
 (c)    between the consideration transferred (USD 62,510,000) and SMSD’s equity as of 30
        November 2025 (USD 32,870,963).
        Profit or loss adjustments arising from foreign exchange differences and
 (d)
        intercompany eliminations related to ownership in the associate entity..

Proforma Consolidated Statement of Financial Position (30 November 2025)

                  Description                  Historical (USD)           Proforma (USD)

 ASSETS

 Cash and banks                                           28,206,595               28,093,345

 Trade and other receivables                               6,174,715                6,154,828

 Advances and prepaid expenses                             1,628,676                1,628,676




                                              15
Page 16
 Other current assets                                                679,087                    679,087

 Total Current Assets                                             36,688,231               36,555,936

 Long-term investments                                             6,020,450                6,020,450

 Investment in Associate Entities                                  7,457,121               91,896,520

 Goodwill                                                                 —                29,639,037

 Fixed assets & oil and gas properties – net                      19,739,767               19,739,767

 Other non-current assets                                             64,795                     64,795

 Total Non-Current Assets                                         33,282,133              147,360,569

 TOTAL ASSETS                                                     69,970,364              183,916,505

 LIABILITIES

 Other payables to third parties                                          —                 6,612,448

 Taxes payable                                                     2,562,072                2,562,072

 Bank loans – current portion                                      5,389,752                5,389,752

 Other current liabilities                                         1,683,629                1,683,629

 Total Current Liabilities                                         9,635,453               16,247,901

 Bank loans – non-current portion                                  8,123,427              108,123,427

 Shareholder loans                                                 1,516,433                1,516,433

 Other non-current liabilities                                       161,401                    161,401

 Total Non-Current Liabilities                                     9,801,261              109,801,261

 TOTAL LIABILITIES                                                19,436,714              126,049,162

 EQUITY

 Share capital                                                     2,484,844                2,484,844

 Additional paid-in capital                                       12,920,505               12,920,505

 Retained earnings                                                34,828,358               34,751,717
 Equity Attributable to Owners of the Parent
                                                                  50,233,707               50,157,066
 Entity
 Non-controlling interests                                           299,943                7,710,277

 TOTAL EQUITY                                                     50,533,650               57,867,343

 TOTAL LIABILITIES AND EQUITY                                     69,970,364              183,916,505


Proforma Consolidated Statement of Profit or Loss (11 Months Ended 30 November
2025)

             Description                       Historical (USD)                Proforma (USD)

 Net Revenue                                                46,446,207                     46,446,207

 Cost of Revenue                                           (22,461,664)                   (22,461,664)

 Gross Profit                                               23,984,543                    23,984,543
 General and Administrative
                                                            (1,275,334)                    (1,275,334)
 Expenses
 Finance Costs / Interest Expense                           (1,281,772)                    (1,281,772)



                                                     16
Page 17
 Gain/(Loss) on Foreign Exchange –
                                                                  (443,673)                                (551,228)
 Net
 Share of Profit of Associates                                   5,259,853                                5,259,853

 Other Income/(Expenses) – Net                                     335,035                                  339,763

 Profit Before Income Tax                                      26,579,652                               26,475,825

 Income Tax Expense                                           (10,085,865)                             (10,085,865)

 PROFIT FOR THE PERIOD                                         16,493,787                               16,389,960
 Attributable to Owners of the
                                                                16,366,500                              16,313,548
 Parent
 Attributable to Non-controlling
                                                                   127,287                                   76,412
 Interests
 Other Comprehensive Income – Net                                   (3,898)                                  (3,898)
 TOTAL COMPREHENSIVE
                                                               16,489,889                               16,386,062
 INCOME


Analysis of the Impact of the Acquisition Transaction Series on Key Financial
Statement Items
1. Assets — Significant Changes
The Acquisition Transaction Series has a significant impact on the Company’s asset
structure, particularly as follows:

    Asset Item          Historical vs Proforma (USD)                           Impact Analysis
                                                            Largest increase, reflecting the consolidation of
 Investment in            7,457,121 → 91,896,520            SMSD’s investment in HCML (USD 84.4 million),
 Associates             (+1,132%, +USD 84.4 million)        representing the fair value of a 20% ownership
                                                            interest in HCML.
                                                            Goodwill of USD 29.6 million represents the difference
                                                            between the purchase consideration (USD 62.5
                                 — → 29,639,037             million) and SMSD’s equity (USD 32.9 million).
 Goodwill
                                     (new)
                                                            This reflects the strategic value of access to the
                                                            Madura Strait PSC.
                                                            Slight decrease due to intercompany elimination
                         28,206,595 → 28,093,345
 Cash and bank                                              adjustments. The Group’s historical cash position
                             (-USD 0.1 million)
                                                            remains strong.
                                                            The increase is primarily driven by investment in
                         69,970,364 → 183,916,505
 Total Assets                                               associates (USD 84.4 million) and goodwill (USD 29.6
                         (+163%, USD 113.9 million)
                                                            million).



2. Liabilities — Significant Changes
The Company’s liabilities increased significantly as a result of the planned acquisition
financing from banks and/or other financial institutions:

  Liability Item        Historical vs Proforma (USD)                           Impact Analysis

                                                            Arising from the consolidation of SMSD liabilities.
 Other payables                  — → 6,612,448              Classified as current liabilities and expected to be
 to third parties                   (new)                   settled shortly after closing.

                                                            Reflects planned loan facilities from banks and/or
 Long-term bank          8,123,427 → 108,123,427            other financial institutions amounting to USD 100
 loans                  (+1,231%, +USD 100 million)         million. Interest expenses will increase and need to be
                                                            managed through strong operating cash flows.
                                                            Significant increase, with 94.1% of the total increase
                        19,436,714 → 126,049,162            attributable to bank/financing loans of USD 100
 Total Liabilities
                        (+548%, +USD 106.6 million)         million.



                                                       17
Page 18
3. Equity — Changes
Despite the significant increase in liabilities, the Company’s equity shows positive growth:

   Equity Item          Historical vs Proforma (USD)                             Impact Analysis

 Equity                                                       Relatively unchanged, with minor adjustments due to
 attributable to         50,233,707 → 50,157,066              intercompany foreign exchange elimination (USD 76.6
 owners of the               (-USD 0.08 million)              million).
 parent
                                                              Significant increase reflecting the recognition of non-
 Non-controlling           299,943 → 7,710,277                controlling interest (49%) in PT REM in the proforma
 interests                   (+USD 7.4 million)               consolidation.
                                                              Net increase mainly driven by the recognition of non-
                         50,533,650 → 57,867,343              controlling interests. Equity remains positive and
 Total Equity
                         (+14.5%, +USD 7.3 million)           sufficient to support operations.


All of the above financial information is derived from the Proforma Consolidated Financial Information compiled by an
independent practitioner and presented in accordance with the applicable Financial Accounting Standards.


                   SUMMARY OF THE APPRAISER’S REPORT ON THE FAIRNESS
                                  OF THE TRANSACTION

A. Identity of the Appraiser
    KJPP FDI&R has been appointed by the Company pursuant to engagement letter No.
    019/FDI/SPK/REC/III/2026 dated 26 March 2026 to provide a fairness opinion on the
    Acquisition Transaction Series and the provision of the Guarantee to Creditors.

B. Summary of the Fairness Opinion Report
    The following is a summary of the Fairness Opinion Report dated 30 March 2026.

    1. Object of the Valuation
         The object of the valuation is the Acquisition Transaction Series and the provision of
         the Guarantee to Creditors.

    2. Purpose of the Valuation
         The purpose of the preparation of the Fairness Opinion Report is to provide an opinion
         on the fairness of the Acquisition Transaction Series and the provision of the
         Guarantee to Creditors in order to comply with POJK No. 17/2020.

    3. Assumptions and Limiting Conditions
         In conducting its analysis and as a basis for providing its fairness opinion on the
         Acquisition Transaction Series and the provision of the Guarantee to Creditors, KJPP
         FDI&R has relied on information and data provided by the management of the
         Company and has assumed that such information and data are true, complete, and
         reliable. KJPP FDI&R has also assumed that the Company will continue to operate on
         a going concern basis and that there will be no material changes in the economic,
         market, or operational conditions of the Company from the date of the report up to
         the date of the fairness opinion.

         KJPP FDI&R has not conducted any audit or detailed verification of the information
         and data received, whether in oral or written form. Accordingly, KJPP FDI&R does not
         provide any assurance and shall not be held responsible if, at any time, the
         information and data provided by the management of the Company are found to be
         incomplete, inaccurate, or misleading.


                                                         18
Page 19
       KJPP FDI&R has not conducted any review of legal aspects or due diligence on
       financial aspects. Accordingly, KJPP FDI&R assumes that the object being valued is
       free from any legal issues, and that its ownership rights are valid and marketable.
       KJPP FDI&R also assumes that the object presented is indeed the object referred to
       in the fairness opinion. Furthermore, KJPP FDI&R assumes that all relevant parties
       have complied and will comply with all applicable laws and regulations in connection
       with the implementation of the transaction.

       The Fairness Opinion Report dated 30 March 2026 must be used in its entirety and
       cannot be separated, and its use is limited solely for the purpose of this fairness
       opinion. Accordingly, KJPP FDI&R shall be released from any claims and liabilities
       arising from the use of the Fairness Opinion Report dated 30 March 2026 for purposes
       other than those intended in the preparation of this fairness opinion.

   4. Valuation Approaches and Methods
        In providing its fairness opinion on the Acquisition Transaction Series and the
       provision of the Guarantee to Creditors, KJPP FDI&R has conducted a fairness
       analysis through the following:
       a. transaction analysis;
       b. qualitative and quantitative analysis; and
       c. fairness analysis of the transaction.

   5. Fairness Opinion on the Material Transaction
       Based on the information and data obtained from the management of the Company
       and used in its analysis, KJPP FDI&R is of the opinion that the Acquisition
       Transaction Series and the provision of the Guarantee to Creditors are fair.

       STATEMENT OF THE BOARD OF COMMISSIONERS AND THE BOARD OF
                       DIRECTORS OF THE COMPANY

The Board of Directors of the Company states that the Material Transactions in the form of
the provision of the Corporate Guarantee to the Seller and the Guarantee to Creditors in
support of the Acquisition Transaction by PT REM constitute an Affiliated Transaction as
referred to in POJK No. 42/2020. Referring to Article 33 letter (a) of POJK No. 17/2020 and
Article 24 paragraph (1) of POJK No. 42/2020, where a Material Transaction also constitutes
an Affiliated Transaction, the Company is only required to comply with the provisions set out
in POJK No. 17/2020.
The Board of Commissioners and the Board of Directors of the Company, individually and
jointly, state that:
1. the Acquisition Transaction Series and the provision of the Guarantee to Creditors do
   not constitute a Conflict of Interest Transaction as referred to in POJK No. 42/2020; and
2. all material information relating to the Acquisition Transaction Series and the provision
   of the Guarantee to Creditors has been disclosed and such information is not misleading.

                               ADDITIONAL INFORMATION

Shareholders of the Company who require further information regarding this Disclosure of
Information may contact the Company during business days and hours at:
                                       Head Office:
                          Office Park Thamrin Residences A01-05
                    Jl. Thamrin Boulevard, Kebon Melati, Tanah Abang
                           Central Jakarta, DKI Jakarta, 10220
                                         Indonesia

                                             19
Page 20
 Telephone: (021) 23579812
 Facsimile: (021) 23579812
   Email: corsec@rec.co.id
   Website: www.rec.co.id


PT Raharja Energi Cepu Tbk




         Sumantri
     President Director




             20

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Pages20
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OCR confidence—

Names mentioned 40 people and organisations named in the text · linked when the evidence is strong

linked org RAHARJA ENERGI CEPU TBK p.1 ×11
linked person Adrian Hartadi p.10 ×3
linked org PT Rukun Raharja p.11
linked person Alexandra | Sinta p.11 ×2
linked person Orias Petrus Moedak p.11
linked person Taufik Ahmad p.12
possible org PT Bursa Efek Indonesia p.2
possible org Purwanto p.13
unresolved org Financial Services Authority p.1 ×3
unresolved org PT REM p.2 ×40
unresolved org KJPP FDI p.3 ×14
unresolved org Ichsan & Rekan p.3
unresolved org Minister of Finance p.3
unresolved org Palilingan & Rekan p.3
unresolved org Minister of Law p.3
unresolved org Minister of Law and Human Rights p.3
unresolved org SMS Offshore Overseas Limited p.3 ×13
unresolved org SMS Development Limited p.3 ×10
unresolved org Kroll HK Limited p.3 ×4
unresolved org Indonesia Stock Exchange p.4
unresolved org Overseas Limited p.4
unresolved org PT REI p.4 ×4
unresolved org PT Raharja Energi Indonesia p.4
unresolved org PT Raharja Energi Madura p.4
unresolved org PT REI. Accordingly p.4
unresolved org PT Kustodian Sentral Efek Indonesia p.6
unresolved org PT Kustodian Sentral Efek Indonesia’s p.6
unresolved org PT REM. SMS Development Limited p.8
unresolved org Husky-CNOOC Madura Limited p.8 ×2
unresolved org PT REM’s p.8
unresolved org PT Petro Indo Pasifik p.9
unresolved org PT PIP p.9 ×3
unresolved org PT PIP. If p.9
unresolved org PT REM Brief History p.10
unresolved person Muhammad Hanafi · Notaris p.10
unresolved person Indah Setyaningsih · Notaris p.11
unresolved person Rini Yulianti · Notaris p.11 ×3
unresolved org PT Ficomindo Buana Registrar p.11
unresolved org SMS Development Limited Brief History SMS Development Limited p.12
unresolved org CNOOC Southeast Asia Limited p.12 ×2

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