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20231228_ANTM_Transaksi Material Tanpa Persetujuan RUPS_31563057_lamp4.pdf

Asset transaction Needs review ANTM

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Page 1
    THE DISCLOSURE OF INFORMATION TO SHAREHOLDERS REGARDING
      MATERIAL TRANSACTIONS AND AFFILIATED TRANSACTIONS OF
              PT ANEKA TAMBANG TBK (THE “COMPANY”)

This Information Disclosure to the Company’s Shareholders (as defined below) is intended to provide explanation
to the public regarding the SDA-HKCBL Divestment Transaction by the Company with HKCBL and FHT
Divestment Transaction between the Company and IMC as the Controlled Company, which is part of the
Transaction Series within the framework of cooperation related to the EV Battery Project (as defined below).

The SDA-HKCBL Divestment Transaction and FHT Divestment Transaction is part of the series of Material
Transactions as defined in the Financial Services Authority Regulation Number 17/POJK.04/2020 on Material
Transactions and Alteration in Business Activities (“POJK 17/2020”).


 THE INFORMATION PROVIDED IN THIS INFORMATION DISCLOSURE IS IMPORTANT AND SHOULD
            BE READ AND DULY NOTED BY THE COMPANY’S SHAREHOLDERS.


  IF YOU ENCOUNTER DIFFICULTIES IN UNDERSTANDING THE INFORMATION PROVIDED IN THIS
 DISCLOSURE, IT IS ADVISABLE TO SEEK ADVICE FROM LEGAL CONSULTANT, CERTIFIED PUBLIC
              ACCOUNTANT, FINANCIAL ADVISOR, OR OTHER PROFESSIONALS.


  THE BOARD OF COMMISSIONERS AND BOARD OF DIRECTORS OF THE COMPANY AFFIRM THAT
  ALL MATERIAL INFORMATION OR FACTS CONTAINED IN THIS INFORMATION DISCLOSURE ARE
                     COMPLETE, ACCURATE, AND NOT MISLEADING.

THE BOARD OF COMMISSIONERS AND BOARD OF DIRECTORS OF THE COMPANY ALSO DECLARE
  THAT THIS MATERIAL TRANSACTION AND AFFILIATED TRANSACTION DO NOT CONTAIN ANY
                              CONFLICT OF INTEREST.




                                          PT ANEKA TAMBANG TBK

                                              Business Activities
 Engaged in the mining of various types of mineral resources, and involved in industrial, trading, transportation,
 and related services associated with the mining of various types of mineral resources, as well as optimizing the
   utilization of resources owned by the Company to produce high-quality goods and/or services with strong
  competitiveness to obtain/seek profits to enhance the Company's value while adhering to the principles of a
                                           Limited Liability Company.

                                         Domiciled in Jakarta, Indonesia.

                                                  Head Office
                                       Gedung Aneka Tambang Tower A
                Jl. Letjen T.B. Simatupang No. 1, Lingkar Selatan, Tanjung Barat, Jakarta 12530
                                          Telephone: (021) 789 1234
                                          E-mail: corsec@antam.com
                                        Website: https://www.antam.com

               This Information Disclosure is issued in Jakarta on the date of 28 December 2023
Page 2
                              DEFINITION AND ABBREVATIONS

“Affiliated         :   Any activity and/or transaction conducted by a Publicly-Listed Company
Transaction”            or a Controlled Company with Affiliates of the Publicly-Listed Company
                        or Affiliates of members of board of directors, members of board of
                        commissioners, major shareholders, or controllers, including any activity
                        and/or transaction conducted by the Publicly-Listed Company or
                        Controlled Company for the benefit of Affiliates of a Publicly-Listed
                        Company or Affiliates of members of board of directors, members of
                        board of commissioners, major shareholders, or controllers.

“Affiliation”       :   Parties as referred to in Article 1 paragraph (1) POJK 42/2020, namely:

                        a.   family relationships by marriage up to the second degree, both
                             horizontally and vertically;
                        b.   relationships between a party and employees, directors, or
                             commissioners of that party;
                        c.   relationships between 2 (two) companies in which there are 1 (one)
                             or more common members of the board of directors or board of
                             commissioners;
                        d.   relationships between a company and a party, whether directly or
                             indirectly controlled by or controlling that company;
                        e.   relationships between 2 (two) controlled companies, whether directly
                             or indirectly, by the same party; or
                        f.   relationships between the company and major shareholders.

“Appraiser”         :   An individual who, through their expertise, engages in appraisal activities
                        within the capital market field.

“ARI”               :   PT ANTAM Resourcindo, a limited liability company established under
                        the laws of the Republic of Indonesia, having its registered address at
                        Jalan Letjen T.B. Simatupang No. 1, ANTAM Office Park Tower B, 11th
                        Floor, South Jakarta.

“ASX”                   Australian Securities Exchange.

“Battery Cells      :   The joint venture company to be established under the laws of the
JVCO”                   Republic of Indonesia with share ownership by IBC and SGCBL.

“Battery Cells      :   The project to be undertaken by Battery Cells JVCO to conduct
Project”                development, construction, and operation of a lithium-ion battery factory
                        in accordance with the Masterplan agreed upon by the Company and
                        SGCBL.

“Battery            :   Battery Material JVCO, Battery Cells JVCO, and Battery Recycling JVCO
Manufacturing           collectively referred.
JVCOs”

“Battery Material   :   The joint venture company to be established under the laws of the
JVCO”                   Republic of Indonesia with share ownership by IBC and HKCBL.

“Battery Material   :   The project to be undertaken by Battery Material JVCO to produce



                                                                                         Page 1 of 35
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Project”                     battery materials in accordance with the Masterplan agreed upon by the
                             Company and HKCBL.

“Battery Recycling       :   The joint venture company to be established under the laws of the
JVCO”                        Republic of Indonesia with share ownership by IBC and HKCBL.

“Battery Recycling       :   The project to be undertaken by Battery Recycling JVCO to recycle
Project”                     batteries.

“CBL”                    :   Ningbo Contemporary Brunp Lygend Co., Ltd., is a joint venture
                             established by and between (i) Ningbo Brunp Contemporary Amperex
                             Co., Ltd.; (ii) Xiamen Ruiting Investment Co., Ltd.; and (iii) Ningbo
                             Lygend New Energy Co., Ltd., incorporated under the laws of the
                             People's Republic of China, with its registered address at Room 618,
                             Office Building 5, Meishan Avenue Business Center, Beilun District,
                             Ningbo, China.

“Conflict of Interest”   :   The distinction between the economic interests of a Publicly-Listed
                             Company and the personal economic interests of its directors, board of
                             commissioners, major shareholders, or controllers that could be
                             detrimental to the Publicly-Listed Company as referred to in POJK
                             42/2020.

“Conflict of Interest    :   Transactions conducted by a Publicly-Listed Company or a Controlled
Transaction”                 Company with any party, whether with Affiliates or parties other than
                             Affiliates, that contain a Conflict of Interest as referred to in POJK
                             42/2020.

“Controlled              :   Company controlled either directly or indirectly by a Publicly-Listed
Company”                     Company.

“Company”                :   PT Aneka Tambang Tbk or abbreviated as PT ANTAM Tbk, a Publicly-
                             Listed Company established under the laws of the Republic of Indonesia,
                             with its registered address at Jalan Letjen TB. Simatupang No. 1,
                             Jakarta, Indonesia.

”Company’s               :   The parties holding beneficial ownership of the Company's shares,
Shareholders”                whether in the form of certificates or in collective custody held and
                             administered in securities accounts at the Indonesian Central Securities
                             Depository, recorded in the Shareholders Register managed by the
                             Securities Administration Bureau appointed by the Company.

“CP”                         Conditions precedent.

“CSPA FHT”               :   Conditional Sale and Purchase of Shares Agreement between the
                             Company, IMC, and HKCBL signed on 4 May 2023.

“CSPA SDA”               :   Conditional Share Purchase Agreement between the Company and
                             HKCBL signed on 16 January 2023.

“EV Battery Project”     :   The cooperation between the Company, IBC, and CBL in the end-to-end
                             electric vehicle battery ecosystem development project in Indonesia by



                                                                                            Page 2 of 35
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                        integrating the mining industry, smelters, precursors, cathodes, battery
                        cells, and battery recycling.

“FHT”               :   PT Feni Haltim, a limited liability company established under the laws of
                        the Republic of Indonesia, having its registered address at Jalan Letjen
                        TB. Simatupang No. 1, Jakarta, Indonesia.

“FHT JVCO”          :   The joint venture company established by the Company and HKCBL by
                        repurposing the Company's existing subsidiary, namely FHT, to carry out
                        the FHT Project.

“FHT Project”       :   The project to be undertaken by FHT JVCO involves repurposing and
                        developing the operations currently conducted by FHT, which consist of
                        development, construction, ownership, financing, operation and
                        maintenance of industrial estates as well as 8 (eight) RKEF lines and
                        facilities related to the sale of nickel products, including the development
                        of additional RKEF lines.

“Framework          :   The Framework Agreement signed by the Company, IBC, and CBL on
Agreement”              14 April 2022.

“GAAP”              :   Generally Accepted Accounting Principles.

“GR 12/1969”        :   Government Regulation Number 12 of 1969 on State-Owned Enterprises
                        as revoked by Government Regulation Number 12 of 1998.

“GR 26/1974”        :   Government Regulation Number 26 of 1974 on the Transfer of the Form
                        of the State-Owned Company Aneka Tambang into a State-Owned
                        Enterprise (Persero).

“GR 47/2017”        :   Government Regulation Number 47 of 2017 on the Additional State
                        Capital Participation of the Republic of Indonesia into the Share Capital
                        of the State-Owned Enterprise (Persero) PT Indonesia Asahan
                        Aluminium.

“GR 45/2022”        :   Government Regulation Number 45 of 2022 concerning the Reduction of
                        the State Capital Participation of the Republic of Indonesia in the State-
                        Owned Enterprise (Persero) PT Indonesia Asahan Aluminium.

“GR 46/2022”        :   Government Regulation Number 46 of 2022 on the State Capital
                        Participation of the Republic of Indonesia for the Establishment of a
                        State-Owned Enterprise (Persero) in the Mining Sector.

“HKCBL”             :   HongKong CBL Limited, a limited liability company established under the
                        laws of Hong Kong, with its registered address at Level 54, Hopewell
                        Centre, 183 Queen’s Road East, Hong Kong.

“HPAL Facilities”   :   Hydrometallurgical Project.

“HPAL JVCO”         :   The joint venture company to be established under the laws of the
                        Republic of Indonesia with share ownership by the Company and
                        HKCBL.



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“HPAL Project”        :   The project to be undertaken by HPAL JVCO involves the construction of
                          HPAL Facilities to produce Mixed Hydroxide Precipitate on the land
                          owned by FHT.

“IBC”                 :   PT Industri Baterai Indonesia, a limited liability company established
                          under the laws of the Republic of Indonesia, with its registered address
                          at Jl. Medan Merdeka Timur No. 11-13, Jakarta 10110, Indonesia.

“IMC”                 :   PT International Mineral Capital, a limited liability company established
                          under the laws of the Republic of Indonesia, with its registered address
                          at Gedung Aneka Tambang, Jl. Letjen T.B. Simatupang No. 1, South
                          Jakarta.

“JVA”                 :   Joint Venture Agreement.

“JVA HPAL”            :   JVA between the Company and HKCBL regarding the HPAL JVCO for
                          the HPAL Project.

“JVCOs”               :   The joint venture companies formed and established in connection with
                          the EV Battery Project, namely Mining JVCO, FHT JVCO, HPAL JVCO,
                          Battery Material JVCO, Battery Cells JVCO, and Battery Recycling
                          JVCO.

“Law 9/1969”          :   Law Number 9 of 1969 on the Enactment of Government Regulation
                          Replacement Law Number 1 of 1969.

“Material             :   Any transaction conducted by a Publicly-Listed Company or a Controlled
Transaction”              Company that meets the value thresholds as regulated in POJK 17/2020.

“MIND ID”             :   PT Mineral Industri Indonesia (Persero), a state-owned enterprise in the
                          form of limited liability company, established under the laws of the
                          Republic of Indonesia, with its registered address at The Energy Building
                          16th Floor, SCBD Lot 11A, Jl. Jend. Sudirman Kav. 52-53, Jakarta,
                          Indonesia.

“Mining JVCO”         :   The joint venture company established by the Company and HKCBL by
                          repurposing the Company's existing subsidiary, namely SDA.

“Mining Project”      :   The project to be undertaken by Mining JVCO to mine the saprolite ore
                          and limonite ore which will be utilized by the other sub-projects in EV
                          Battery Project.

“MoLHR”               :   Minister of Law and Human Rights of the Republic of Indonesia.

“OJK or Financial     :   Financial Services Authority or Otoritas Jasa Keuangan (OJK) is an
Services Authority”       independent institution as referred to in Law Number 21 of 2011 on the
                          Financial Services Authority as amended by Law Number 4 of 2023 on
                          the Development and Strengthening of the Financial Sector (“Law
                          21/2011”), whose duties and authorities encompass the regulation and
                          supervision of financial services activities in the banking sector, capital
                          markets, insurance, pension funds, financing institutions, and other
                          financial institutions. As of 31 December 2012, OJK is the institution that



                                                                                           Page 4 of 35
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                           replaced and assumed the rights and obligations to perform regulatory
                           and supervisory functions from the Capital Market and Financial
                           Institutions Supervisory Agency (Badan Pengawas Pasar Modal dan
                           Lembaga Keuangan) in accordance with the provisions of Article 55 of
                           Law 21/2011.

“POJK 17/2020”         :   Financial Services Authority Regulation Number 17/POJK.04/2020 of
                           2020 on Material Transactions and Alteration Business Activities.

“POJK 42/2020”         :   Financial Services Authority Regulation Number 42/POJK.04/2020 of
                           2020 on Affiliated Transactions and Conflict of Interest Transactions.

“Presidential          :   Presidential Instruction Number 11 of 1973 on the Guidelines for the
Instruction 11/1973”       Working Relationship between the Minister of Technical Affairs and the
                           Minister of Finance as Representatives of the State as the Shareholder
                           of State-Owned Enterprises (SOEs).

“Publicly-Listed       :   An issuer that has conducted a public offering of equity securities or a
Company”                   public company.

“RKEF”                 :   Rotary Kiln Electric Furnace.

“Rupiah or Rp”         :   Reference to Rupiah or Rp is a reference to the lawful currency of the
                           Republic of Indonesia.

“SDA”                  :   PT Sumberdaya Arindo, a limited liability company established under the
                           laws of the Republic of Indonesia, with its registered address at Jalan
                           Letjen TB. Simatupang No. 1, Jakarta, Indonesia.

“SGCBL”                :   CBL International Development Pte. Ltd, a limited liability company
                           established under the laws of Singapore, with its registered address at
                           987 Serangoon Road, Singapore, 328147.

“SHA FHT”              :   Shareholders Agreement in respect of FHT between the Company and
                           HKCBL dated 4 May 2023, including all additional instruments,
                           supplements, and accompanying documentation.

“SHA SDA”              :   Shareholders Agreement in respect of SDA between the Company and
                           HKCBL dated 16 January 2023, including all additional instruments,
                           supplements, and accompanying documentation.

“Transaction Series”       The series of transactions to be carried out by the Company as outlined
                           in the Introduction section of this Information Disclosure.

“USD”                  :   Reference to the United States Dollar or USD is a reference to the lawful
                           currency of the United States of America.

“WHO”                  :   World Health Organization.




                                                                                          Page 5 of 35
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                                           INTRODUCTION

In order to comply with the provision of POJK 17/2020, the Company's Board of Directors announces
this Information Disclosure to provide information to the Company's Shareholders that:

1.    The Company has sold 49% (forty nine percent) of its shares ownership in SDA to HKCBL
      ("SDA-HKCBL Divestment Transaction"); and
2.    The Company has sold 10% (ten percent) of its shares ownership in FHT to HKCBL ("FHT-
      ANTAM Divestment Transaction") and IMC has sold 50% (fifty percent) of its shares
      ownership in FHT to HKCBL ("FHT-IMC Divestment Transaction") (hereinafter collectively
      referred to as the "FHT Divestment Transaction"),

which are the transactions of the Transaction Series in order to implement the EV Battery Project.

The Transaction Series is a series of Material Transactions as referred to in POJK 17/2020 due to the
interdependence and continuity between a transaction and other transactions for considerations as
described below. Further, the Transaction Series is not a Conflict of Interest Transaction as referred
to in POJK 42/2020.

In Transaction Series, there are Non-Exempted Transaction Series from the obligation to comply with
Article 6 of POJK 17/2020 and there are Exempted Transaction Series from part of the provisions of
Article 6 of POJK 17/2020. Meanwhile, the SDA-HKCBL Divestment Transaction and FHT Divestment
Transaction are the part of Non-Exempted Transaction Series from the obligation to implement the
provisions of Article 6 POJK 17/2020

Following the execution of SDA-HKCBL Divestment Transaction and FHT Divestment Transaction as
disclosed in this Information Disclosure, the Company will subsequently conduct other transactions
within the Transaction Series as further explained in the Description of the Transaction section of this
Information Disclosure.

The Company's Board of Directors announces this Information Disclosure through the Company's
website and the Indonesia Stock Exchange website with the intention of providing comprehensive
information and insights to the Company's Shareholders regarding the SDA-HKCBL Divestment
Transaction and FHT Divestment Transaction, as well as the Transaction Series as a whole.
Additionally, the Company has submitted the supporting documents for this Information Disclosure to
the OJK in accordance with the provisions of POJK 17/2020.

                       EXPLANATION, CONSIDERATIONS, AND REASONS
                         FOR CONDUCTING MATERIAL TRANSACTION

On 14 April 2022, the Company has signed a Framework Agreement with CBL and IBC to develop
the EV Battery Project which will be executed by JVCOs established by the Company, CBL, and/or
IBC. In establishing these JVCOs, there are transactions within the Transaction Series that must be
conducted by the Company and its Controlled Companies as well as non-Controlled Companies. In
regards to that, the establishment of JVCOs has been followed up by the Company and HKCBL, a
subsidiary of CBL, by signing several preliminary agreements related to the Transaction Series which
are a continuation of the Framework Agreement, among others for the:

1.    SDA-HKCBL Divestment Transaction by CSPA SDA on 14 January 2023 as disclosed to the
      public on 16 January 2023;
2.    FHT Divestment Transaction by CSPA FHT on 4 May 2023 as disclosed to the public on 8 May
      2023; and



                                                                                            Page 6 of 35
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3.    HPAL JVCO Investment Transaction by JVA HPAL on 22 December 2023 as disclosed to the
      public on 27 December 2023.

In addition, the completion of the SDA-ANTAM Divestment Transaction on 20 December 2023 is a CP
to the CSPA SDA in the context of the completion of the SDA-HKCBL Divestment Transaction as
disclosed to the public on 22 December 2023.

Specifically, (i) the SDA-HKCBL Divestment Transaction is carried out to form SDA into a Mining
JVCO which will carry out the Mining Project; and (ii) the FHT Divestment Transaction is carried out to
form FHT into a FHT JVCO which will carry out the FHT Project. The Mining Project and FHT Project
are several sub-projects of the EV Battery Project.

The Transaction Series is carried out to realize the EV Battery Project, which is a national strategic
project based on the Coordinating Minister for Economic Affairs Number 7 of 2021 Regulation on the
Amendment of the List of National Strategic Projects as lastly amended by the Coordinating Minister
for Economic Affairs Regulation Number 8 of 2023. This Transaction Series is important to be carried
out in order to fulfill the Government of Indonesia’s mandate and expectation to develop the electric
vehicle battery industry in Indonesia, to bring a positive multiplier effect towards the national
economy.

Furthermore, Company’s participation in the EV Battery Project is essential for Company's long-term
growth. Through the EV Battery Project, the Company which enabling the Company to understand
and master key technologies of nickel ore processing and refining, as well as making the raw material
of batteries and electric vehicle batteries. This not only strengthens the Company's position in the
mining industry, but also grows the Company’s competitive advantages in the electric vehicle battery
industry. The Company sees significant added value potential from the EV Battery Project, both in
terms of financial and non-financial growth, that will encourage growth and strengthen the Company’s
position in the market and enhance a positive image among stakeholders and the general public,
particularly the Company's Shareholders.

Based on the explanations, considerations, and reasons mentioned above, the Company believes
that participation in the EV Battery Project through the execution of the Transaction Series will bring a
multiplier effect to the Company and the broader community, marking a milestone for the Company in
its efforts towards the development of the ongoing EV Battery Project. Therefore, the completion of
the SDA-ANTAM Divestment Transaction, the SDA-HKCBL Divestment Transaction, and the FHT
Divestment Transaction is necessary for the entire Transaction Series to proceed according to the
plan.

                               DESCRIPTION OF THE TRANSACTION

A.    Scope of the Transaction Series and Its Relation to the SDA-ANTAM Divestment
      Transaction

      The EV Battery Project is a collaboration between the Company, IBC, and CBL concerning the
      end-to-end development of an electric vehicle battery ecosystem in Indonesia which involves
      the integration of mining industry, smelters, precursors, cathodes, battery cells, and battery
      recycling, consisting of several sub-projects as follows:

      1.     Mining Project through Mining JVCO;
      2.     FHT Project through FHT JVCO;
      3.     HPAL Project through HPAL JVCO;
      4.     Battery Material Project through Battery Material JVCO;



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5.    Battery Cells Project through Battery Cells JVCO; and
6.    Battery Recycling Project through Battery Recycling JVCO.

The establishment of the above JVCOs is executed through the sale and purchase of shares in
the Company's existing subsidiaries and the subscription of shares in newly established joint
venture companies. Subsequently, the JVCOs will be owned by the Company, IBC, and CBL
through HKCBL and SGCBL in accordance with the shareholder structure as follows:


No.          JVCO on Related Sub-Project                            Shareholders
1.                     Mining JVCO                               ANTAM and HKCBL
2.                      FHT JVCO                                 ANTAM and HKCBL
3.                     HPAL JVCO                                 ANTAM and HKCBL
4.                Battery Material JVCO                            IBC and HKCBL
5.                 Battery Cells JVCO                              IBC and SGCBL
6.               Battery Recycling JVCO                            IBC and HKCBL

For the purpose of the EV Battery Project, the Company directly engages in the establishment
and formation of the JVCOs, with the involvement of the Company’s Controlled Companies,
particularly in:

1.    Mining JVCO as the party to undertake the Mining Project, in which Mining JVCO is
      established through the SDA-HKCBL Divestment Transaction, preceded by the SDA-
      ANTAM Transaction;
2.    FHT JVCO as the party to undertake the FHT Project, in which FHT JVCO is established
      through the FHT Divestment Transaction consisting of the FHT-IMC Divestment
      Transaction and FHT-ANTAM Divestment Transaction; and
3.    HPAL JVCO as the party to undertake the HPAL Project, in which HPAL JVCO is
      established through the HPAL JVCO Investment Transaction.

Moreover, the Company is indirectly involved in the establishment of Battery Manufacturing
JVCOs, through IBC, which is an associated entity of the Company that is not a Controlled
Company as the Company only holds 25% (twenty-five percent) of ownership in IBC. In this
regard, IBC will establish the Battery Manufacturing JVCOs jointly with HKCBL and SGCBL (as
relevant). The Company’s participation in the Battery Manufacturing JVCOs Investment
Transaction involves an increase in equity participation in IBC, proportional to its shareholding.

Based on the above explanations, the following Transaction Series will be executed by the
Company and/or Controlled Companies, as well as non-Controlled Companies, in connection
with the establishment of JVCOs for the implementation of the EV Battery Project:

1.    SDA-HKCBL Divestment Transaction, preceded by the SDA-ANTAM Divestment
      Transaction;
2.    FHT Divestment Transaction, consisting of the FHT-ANTAM Divestment Transaction and
      FHT-IMC Divestment Transactions;
3.    HPAL JVCO Investment Transaction; and
4.    Battery Manufacturing JVCOs Investment Transaction.

Transaction Series constitutes a series of Material Transactions as defined under POJK
17/2020 due to the interdependency and continuity among transactions, as follows:



                                                                                      Page 8 of 35
Page 10
     1.    CSPA SDA stipulates that the completion of the SDA-HKCBL Divestment Transaction
           depends on the fulfillment of CP, where one of the CPs for the completion of SDA-
           HKCBL Divestment Transaction is the completion of the SDA-ANTAM Divestment
           Transaction.
     2.    CSPA SDA also specifies that the completion of the SDA-HKCBL Divestment
           Transaction depends on the signing of the JVA of HPAL JVCO, FHT JVCO, and Battery
           Manufacturing JVCOs.
     3.    CSPA FHT stipulates that the completion of the SDA-HKCBL Divestment Transaction is
           a condition subsequent to the FHT Divestment Transaction.
     4.    The establishment of the HPAL JVCO depends on the completion of the SDA-HKCBL
           Divestment Transaction and the FHT Divestment Transaction.
     5.    The establishment of Battery Manufacturing JVCOs by IBC is depending on the increase
           in equity participation of the Company in IBC through the Battery Manufacturing JVCO
           Investment Transaction.

B.   Materiality of Transaction Series

     In the Transaction Series, there are Non-Exempted Transaction Series from the obligation to
     implement the provisions of Article 6 of POJK 17/2020 and there are Exempted Transaction
     Series that are exempted from the obligation to comply with some provisions of Article 6 of
     POJK 17/2020, as explained below:

     1.    Non-Exempted Transaction Series

           The transactions within the Transaction Series that are not exempted from the obligation
           to comply with the provisions of Article 6 of POJK 17/2020 are: (i) SDA-HKCBL
           Divestment Transaction; (ii) FHT Divestment Transaction; and (iii) HPAL JVCO
           Investment Transaction (the "Non-Exempted Transaction Series").

     2.    Exempted Transaction Series

           The transactions within the Transaction Series that are exempted from the obligation to
           comply with some provisions of Article 6 of POJK 17/2020 are: (i) SDA-ANTAM
           Divestment Transaction; and (ii) Battery Manufacturing JVCOs Investment Transaction
           (the "Exempted Transaction Series"). The reasons for these exemptions are as follows:

           a.    SDA-ANTAM Divestment Transaction

                 SDA-ANTAM Divestment Transaction is an Affiliated Transaction because it is
                 conducted between the Company as a Publicly-Listed Company and ARI as a
                 Controlled Company of the Company which has an Affiliated relationship as
                 defined in Article 1 paragraph (1) letter (d) of POJK 42/2020. However, in
                 accordance with Article 24 paragraph (1) of POJK 42/2020, in cases where the
                 value of Affiliated Transaction meets the criteria of a Material Transaction as
                 referred to in POJK 17/2020, the Publicly-Listed Company is only obligated to
                 comply with POJK 17/2020. Considering that the SDA-ANTAM Divestment
                 Transaction is part of a Transaction Series that overall qualified as Material
                 Transactions, the Company is only obliged to comply with POJK 17/2020.

                 Furthermore, Article 11 letter (a) of POJK 17/2020 stipulates that a Publicly-Listed
                 Company is not obligated to use an Appraiser if it conducts a Material Transaction



                                                                                         Page 9 of 35
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            with a Controlled Company in which it holds at least 99% (ninety-nine percent) of
            the Controlled Company's paid-up capital or transactions conducted between
            Controlled Companies in which at least 99% (ninety-nine percent) of the shares
            are owned by the Publicly-Listed Company itself.

            Based on the above provisions, the Company is not obligated to use an Appraiser
            to carry out the SDA-ANTAM Divestment Transaction because this transaction is
            conducted between the Company as a Publicly-Listed Company and ARI as a
            Controlled Company, where the Company holds 99,98% (ninety-nine point nine
            eight percent) shares in ARI. The SDA-ANTAM Divestment Transaction was
            completed on 20 December 2023.

      b.    Battery Manufacturing JVCOs Investment Transaction

            As previously explained, the Company currently holds 25% (twenty-five
            percent) share ownership in IBC since 2021. The Battery Manufacturing
            JVCOs Investment Transaction is a transaction of increasing capital
            participation by the Company to IBC proportionally to maintain the Company's
            share ownership in IBC. This additional capital participation will be carried out
            by all the shareholders of IBC and will be used by IBC to contribute capital in
            the establishment of the Battery Manufacturing JVCOs alongside HKCBL and
            SGCBL (as relevant).

            Based on Article 11 (d) of POJK 17/2020, a Publicly-Listed Company is not
            obligated to use an Appraiser if it conducts a Material Transaction involving
            additional capital participation to maintain its ownership percentage after the
            said participation for a minimum period of 1 (one) year. Accordingly, in
            compliance with the provisions of Article 11 letter (d) of POJK 17/2020, the
            Company is not obliged to use an Appraiser to carry out the proportional
            additional capital participation in IBC in the Battery Manufacturing JVCOs
            Investment Transaction.

Considering the aforementioned explanation that the Company is not required to use an
Appraiser in executing the Exempted Transaction Series, the Company does not calculate the
Exempted Transaction Series in assessing the materiality of the Transaction Series. Therefore,
the materiality of the Material Transaction to be conducted by the Company solely takes into
account the Non-Exempted Transaction Series. In relation to this, the Company has obtained:

1.    A Fairness Opinion Report on the Transaction Series based on the Fairness Opinion
      Report on Series of Transaction Plan Number 00499/2.0059-02/BS/02/0242/1/XI/2023
      dated November 20, 2023, prepared by Suwendho Rinaldy and Partners Public
      Appraisal Office (“Fairness Opinion Report”);
2.    An Assessment Report for the SDA-HKCBL Divestment Transaction based on the
      Assessment Report for 49% Ownership of PT Sumberdaya Arindo Number
      00068/2.0095-00/BS/02/0273/1/X/2023 dated October 26, 2023, prepared by Ruky,
      Safrudin & Partners Public Appraisal Office (“SDA Assessment Report”);
3.    An Assessment Report for the FHT Divestment Transaction based on the Assessment
      Report for PT Feni Haltim Shares Number 00477/2.0059-02/BS/02/0242/1/X/2023 dated
      October 26, 2023, prepared by Suwendho Rinaldy and Partners Public Appraisal Office
      (“FHT Assessment Report”); and
4.    Feasibility Study Report for the HPAL JVCO Investment Transaction based on the
      Feasibility Study Report for the HPAL JVCO Investment Transaction Plan Number


                                                                                 Page 10 of 35
Page 12
             231117.001/SRR-JK/LP-S/ANTM/OR dated November 17, 2023, prepared by Suwendho
             Rinaldy and Partners Public Appraisal Office (“HPAL Feasibility Study Report”).

       Based on the Fairness Opinion Report, the value of the Transaction Series amounts to 29,73%
       (twenty-nine point seventy-three percent) of the Company's equity based on the Company's
       Financial Statements as of 30 June 2023.

       In connection with the explanation provided, below is the illustration related to the entire
       Transaction Series:




            Exempted Transaction Series that have been carried out by the Company
            Non-Exempted Transaction Series that have been carried out by the Company
            Non-Exempted Transaction Series to be carried out by the Company
            Exempted Transaction Series to be carried out by the Company

C.     Scope, Object, and Value of Transaction Series

       After the execution of SDA-HKCBL Divestment Transaction and FHT Divestment Transaction
       as disclosed in this Information Disclosure, the Company will subsequently proceed to carry out
       other transactions that are part of the Transaction Series, namely HPAL JVCO Investment
       Transaction and Battery Manufacturing JVCOs Investment Transaction.

C.1.   Completed Transaction in the Transaction Series

       This Information Disclosure is intended to explain the completion of the SDA-HKCBL
       Divestment Transaction between the Company and HKCBL and the FHT Divestment
       Transaction between the Company, IMC, and HKCBL. As previously disclosed on 22
       December 2023 by the Company, the SDA-ANTAM Divestment Transaction between the
       Company and ARI has also completed on 20 December 2023.

       1.    SDA-HKCBL Divestment Transaction

             SDA-HKCBL Divestment Transaction is the sale of a portion of the Company's shares in
             SDA to HKCBL. In SDA-HKCBL Divestment Transaction, the object of the transaction is
             39,755,625 (thirty-nine million seven hundred fifty-five thousand six hundred twenty-five)
             shares with a nominal value of Rp100,000.00 (one hundred thousand Rupiah) or
             equivalent to 49% (forty-nine percent) of the Company's ownership in SDA that will be
             transferred by the Company to HKCBL ("SDA-HKCBL Shares").

             The shares ownership structure in SDA before and after the SDA-HKCBL Divestment
             Transaction is outlined below:




                                                                                          Page 11 of 35
Page 13
       Shareholders         Shares                  Nominal Value             Percentage
      Before the SDA-HKCBL Divestment Transaction
      Company           81.133.930         Rp8.113.393.000.000,00             100%
      After the SDA-HKCBL Divestment Transaction
      Company           41.378.305         Rp4.137.830.500.000,00             51%
      HKCBL             39.755.625         Rp3.975.562.500.000,00             49%

     The Parties in Transaction
     The Parties involved in the SDA-HKCBL Divestment Transaction are the Company as
     the seller of the SDA-HKCBL Shares and HKCBL as the purchaser of the SDA-HKCBL
     Shares.

     Transaction Value
     The value of the SDA-HKCBL Divestment Transaction, or the purchase price of the SDA-
     HKCBL Shares to be paid in cash by HKCBL to the Company, amounts to USD
     416,500,000.00 (four hundred sixteen million five hundred thousand United States
     Dollars). The Company also has a contingent right to receive payment if there are
     additional reserves in the SDA mining area within a period of 36 (thirty six) months from
     the date of completion of the Divestment Transaction SDA-HKCBL. However, the final
     value of the contingent consideration that the Company may receive will be known when
     the 36 (thirty six) months period has ended.

     Related Agreements
     The completion of the SDA-HKCBL Divestment Transaction is evidenced by the signing
     of Deed of Sale and Purchase of Shares No. 274 between the Company and HKCBL
     made before Notary Nabila Mazaya Putri, Bachelor of Laws, Master of Notary, as
     substitute of Jose Dima Satria, Bachelor of Laws, Master of Notary on 28 December
     2023.

2.   FHT Divestment Transaction

     Scope and Object of Transaction
     FHT Divestment Transaction constitutes the partial sale of 10% (ten percent) of the
     Company's shares in FHT to HKCBL and the sale of IMC's entire 50% (fifty percent)
     shares in FHT to HKCBL. The FHT Divestment Transaction is intended to form FHT into
     FHT JVCO, which is the entity that will implement the FHT Project.

     In the FHT Divestment Transaction, the object of the transaction is:

     (i)    12,290,021 (twelve million two hundred ninety thousand twenty-one) shares with a
            total nominal value of Rp122,900,212,000.00 (one hundred twenty-two billion nine
            hundred million two hundred twelve thousand Rupiah), equivalent to 10% (ten
            percent) ownership of the Company in FHT, for FHT-ANTAM Divestment
            Transaction; and
     (ii)   61,450,106 (sixty-one million four hundred fifty thousand one hundred six) shares
            with a total nominal value of Rp614,501,060,000.00 (six hundred fourteen billion
            five hundred one million sixty thousand Rupiah), equivalent to 50% (fifty percent)
            ownership of IMC in FHT, for FHT-IMC Divestment Transaction,




                                                                                 Page 12 of 35
Page 14
     hereinafter collectively be referred to as the "Ownership of Shares in FHT". Below is
     the shares ownership structure in FHT before and after the FHT Divestment Transaction:

            Shareholders         Cumulative             Nominal Value          Percentage
      Before the FHT Divestment Transaction
      Company                 61.450.106           Rp614.501.060.000,00        50%
      IMC                     61.450.106           Rp614.501.060.000,00        50%
      After the FHT Divestment Transaction
      Company                 49.160.085           Rp491.600.850.000,00        40%
      HKCBL                   73.740.127           Rp737.401.270.000,00        60%

     Referring to the shareholding structure in FHT above, following the execution of the
     Divestment Transaction FHT: (i) FHT will no longer be consolidated into the Company's
     financial statements as a subsidiary in accordance with the provisions of GAAP 65 on
     Consolidated Financial Statements; and (ii) FHT will no longer be considered a
     Controlled Company of the Company under capital market regulations.

     Parties Involved in the Transaction
     The parties involved in the FHT Divestment Transaction are (i) the Company and IMC as
     the sellers of the Ownership of Shares in FHT; (ii) and HKCBL as the purchaser of the
     Ownership of Shares in FHT.

     Transaction Value
     The value of the FHT Divestment Transaction, or the value of the purchase of the
     Ownership of Shares in FHT to be paid by HKCBL, amounts to Rp781,200,000,000.00
     (seven hundred eighty-one billion two hundred million Rupiah), divided into:

     (i)     Rp130,200,000,000.00 (one hundred thirty billion two hundred million Rupiah) for
             the 10% (ten percent) ownership of the Company's shares in FHT in the
             Divestment Transaction FHT-ANTAM; and
     (ii)    Rp651,000,000,000.00 (six hundred fifty-one billion Rupiah) for the 50% (fifty
             percent) ownership of IMC's shares in FHT in the Divestment Transaction FHT
             IMC-HKCBL.

     Related Agreements
     The completion of the FHT Divestment Transaction is evidenced by the signing of (i)
     Deed of Sale and Purchase of Shares No. 272 between the Company and HKCBL made
     before Notary Nabila Mazaya Putri, Bachelor of Laws, Master of Notary, as substitute of
     Jose Dima Satria, Bachelor of Laws, Master of Notary on 28 December 2023; and (ii)
     Deed of Sale and Purchase of Shares No. 271 between IMC and HKCBL made before
     Notary Nabila Mazaya Putri, Bachelor of Laws, Master of Notary, as substitute of Jose
     Dima Satria, Bachelor of Laws, Master of Notary on 28 December 2023.

3.   SDA-ANTAM Divestment Transaction

     Scope and Object of Transaction
     The SDA-ANTAM Divestment Transaction is the sale of all share rights owned by ARI in
     SDA to the Company ("SDA-ANTAM Divestment Transaction"). The SDA-ANTAM




                                                                                Page 13 of 35
Page 15
            Divestment Transaction is one of the CPs in the SDA CSPA and therefore must be
            completed prior to the completion of the SDA-HKCBL Divestment Transaction.

            Within the SDA-ANTAM Divestment Transaction, the object of the transaction involves
            1.350 (one thousand three hundred fifty) shares, each with a nominal value of
            Rp100,000.00 (one hundred thousand Indonesian Rupiah) or equivalent to 0,02% (zero
            point zero two percent) ownership of ARI in SDA, which will be transferred from ARI to
            the Company ("SDA-ARI Shares"). Below is the shares ownership structure in SDA
            before and after the SDA-ANTAM Divestment Transaction, but prior to the execution of
            SDA-HKCBL Divestment Transaction:

             Shareholders            Shares                Nominal Value              Precentage
            Before the SDA-ANTAM Divestment Transaction
            Company          81.132.580           Rp8.113.258.000.000,00              99,98%
            ARI              1.350                Rp135.000.000,00                    0,02%
            After the SDA-ANTAM Divestment Transaction
            Company          81.133.930           Rp8.113.393.000.000,00              100%

            Parties Involved in the SDA-ANTAM Divestment Transaction
            The parties involved in the SDA-ANTAM Divestment Transaction are (i) ARI as the seller
            of the SDA-ARI Shares, and (ii) the Company as the purchaser of the SDA-ARI Shares.

            Transaction Value
            The value of the SDA-ANTAM Divestment Transaction or the value of the purchase of
            shares in SDA that will be paid by the Company to ARI is Rp199,000,000.00 (one
            hundred and ninety-nine million Rupiah).

            Related Agreements
            The completion of the SDA-ANTAM Divestment Transaction is evidenced by the signing
            of Share Purchase Deed No. 03 executed before Notary Lolani Kurniati Irdham-Idroes,
            Bachelor of Laws, Lex Legibus Magister, by the Company and ARI on 20 December
            2023

C.2.   Subsequent Transaction in the Transaction Series

       1.   HPAL JVCO Investment Transaction

            The Scope of the Transaction
            HPAL JVCO is a new entity that will be formed to implement the HPAL Project. HPAL
            JVCO will be established through capital injection by the Company and HKCBL with a
            share ownership composition of 30% (thirty percent) by the Company and 70% (seventy
            percent) by HKCBL, in which the establishment of HPAL JVCO is based on the JVA
            HPAL that has been signed by the Company and HKCBL dated 22 December 2023
            ("HPAL JVCO Investment Transaction").

            Parties Involved in the Transaction
            The involved parties in the HPAL JVCO Investment Transaction are (i) the Company;
            and (ii) HKCBL, both acting as founders and prospective shareholders of HPAL JVCO.




                                                                                     Page 14 of 35
Page 16
     Transaction Object
     The transaction object in the HPAL JVCO Investment Transaction is the capital to be
     paid by the Company for the establishment of HPAL JVCO. Below are further
     explanations regarding the establishment of HPAL JVCO:

      The Establishment Timeline      5 (five) business days after the effective date of the
      of HPAL JVCO                    HPAL JVA, where the effective date of the HPAL JVA
                                      is the date when all CP stipulated in the HPAL JVA
                                      have been fulfilled or waived by the Company and
                                      HKCBL. One of these CPs is HKCBL becoming a
                                      shareholder in SDA and FHT.
      Business Activities             Engaged in the development, construction,
                                      ownership, financing, operation, and maintenance of
                                      HPAL Facilities for the production and sale of Mixed
                                      Hydroxide Precipitate.
      Capital Structure
      Authorized Capital              Rp10.000.000.000,00
      Paid-up Capital                 Rp10.000.000.000,00
      Shareholders Structure
      Company                         Rp3.000.000.000,00                             30%
      HKCBL                           Rp7.000.000.000,00                             70%

     Transaction Value
     The value of the Investment Transaction in HPAL JVCO for the initial capital injection by
     Company into HPAL JVCO is Rp3,000,000,000.00 (three billion Rupiah), equivalent to a
     30% (thirty percent) shares ownership in HPAL JVCO.

     Related Agreements
     The Company and HKCBL have entered into the HPAL JVA in relation to the HPAL
     JVCO Investment Transaction on 22 December 2023 as disclosed on 27 December
     2023 and the completion of the HPAL JVCO Investment Transaction is subject to the
     fulfilment of the CP by the Company and HKCBL.

2.   Battery Manufacturing JVCOs Investment Transaction

     Scope of the Transaction
     Within the EV Battery Project, there are sub-projects where the Company does not
     directly engage in collaboration with CBL but rather through IBC, a subsidiary of the
     Company. These sub-projects consist of the Battery Material Project, Battery Cells
     Project, and Battery Recycling Project. The implementation of the sub-projects is carried
     out by establishing Battery Materials JVCO, Battery Cells JVCO, and Battery Recycling
     JVCO (collectively referred to as "Battery Manufacturing JVCOs")..

     The establishment of Battery Manufacturing JVCOs will be carried out by way of the
     capital injection by IBC together with HKCBL and SGCBL (as relevant) into the new joint
     venture companies, with the share ownership compositions in each Battery
     Manufacturing JVCO as follows:




                                                                                 Page 15 of 35
Page 17
                         Battery Material          Battery Cells           Battery Recycling
    Shareholders
                              JVCO                    JVCO                       JVCO

          IBC                   30%                     30%                       40%
       HKCBL                    70%                       -                       60%
       SGCBL                      -                     70%                         -

Below are further explanations of the establishment plan of the Battery Manufacturing
JVCOs:


                     Battery Material           Battery Cells              Battery Recycling
    Aspect
                          JVCO                     JVCO                          JVCO

 Related         Battery Material JVA       Battery Cells JVA          Battery Recycling
 Agreement       between IBC and            between IBC and            JVA between IBC
                 HKCBL on 14                SGCBL on 21                and HKCBL on 14
                 November 2023.             November 2023.             November 2023.
 Time of         After the fulfillment of   After the fulfillment of   After the fulfillment of
 Establishment   all CPs based on the       all CPs based on the       all CPs based on the
                 JVA Battery Material.      JVA Battery Cells.         JVA Battery
                                                                       Recycling.
 Business        ▪    The                   ▪   The                    ▪     The
 Activities           development,              development,                 development,
                      construction,             construction,                construction,
                      operation, and            operation, and               operation, and
                      maintenance of a          maintenance of a             maintenance of a
                      battery material          battery cell plant.          battery recycling
                      plant.                ▪   Sales, both                  plant.
                 ▪    Sales, both               domestically in        ▪     Sales, both
                      domestically in           Indonesia and                within Indonesia
                      Indonesia and             internationally, of          and
                      internationally, of       electric motorized           internationally, of
                      battery materials         vehicles and                 recycled battery
                      for the production        energy storage               products.
                      of Li-ion                 system.
                      batteries.
 Capital         Rp10.000.000.000,-         Rp10.000.000.000,-         Rp10.000.000.000,-
 Structure
 Shareholding    Rp3.000.000.000,-          Rp3.000.000.000,-          Rp4.000.000.000,-
 of IBC
 Shareholding    Rp7.000.000.000,-          Rp7.000.000.000,-          Rp6.000.000.000,-
 of CBL
 through
 HKCBL/
 SGCBL

Furthermore, IBC requires additional capital to make capital injections into Battery
Manufacturing JVCOs for the establishment of Battery Manufacturing JVCOs in



                                                                                   Page 16 of 35
Page 18
           accordance with the aforementioned ownership composition. In line with this, IBC will
           raise funds from its shareholders through a capital increase. Hence, as a shareholder,
           the Company will contribute additional capital to IBC to maintain its ownership
           percentage in IBC ("Battery Manufacturing JVCOs Investment Transaction").
           Currently, the Company holds 4,895,100 (four million eight hundred ninety-five thousand
           one hundred) shares or equivalent to 25% (twenty-five percent) ownership in IBC since
           2021.

           Parties Involved in the Transaction
           The parties involved in the Investment Transaction in Battery Manufacturing JVCOs are
           (i) the Company and (ii) IBC.

           Object and Transaction Value
           The object of the transaction in the Battery Manufacturing JVCOs Investment
           Transaction is the additional capital to be injected by the Company into IBC with a value
           to be determined later.

D.   Parties Carrying Out the Transaction Series

     The parties to the SDA-HKCBL Divestment Transaction and the FHT Divestment Transaction
     are as follows.

1.   Company

     General Explanation
     The Company was formerly a State-Owned Enterprise, established under the name
     "Perusahaan Negara (PN) Aneka Tambang" in the Republic of Indonesia on 5 July 1968, based
     on Government Regulation No. 22 of 1968 as a result of the merger of the General Leadership
     Body of State-Owned Mining Companies, the State-Owned Company for Bauxite Mining in
     Indonesia, the State-Owned Company for Tjikotok Gold Mining, the State-Owned Company for
     Precious Metals, PT Nikel Indonesia, the South Kalimantan Diamond Mining Project, and
     former Bapetamb Projects. This establishment was announced in the Supplement to the State
     Gazette of the Republic of Indonesia No. 36 of 1968 on 5 July 1968.

     On 14 June 1974, based on GR 26/1974, the Company's form was changed from a State-
     Owned Company to a Limited Liability Company (Persero) and since then became known as
     "Perusahaan Perseroan (Persero) PT Aneka Tambang." The Company's name was later
     changed to "PT Aneka Tambang (Persero)" based on Notarial Deed No. 320 dated 30
     December 1974, made before Warda Sungkar Alurmei, S.H., as a replacement for Abdul Latief,
     a Notary in Jakarta, through Deed of Amendment No. 55 dated 14 March 1975, made before
     Abdul Latief, a Notary in Jakarta, to comply with the provisions stipulated in Law 9/1969, GR
     12/1969, GR 26/1974, Presidential Instruction 11/1973, and Minister of Finance Decree No.
     1768 of 1974. These deeds received approval from the MoLHR in Decree No. Y.A. 5/170/4
     dated 21 May 1975, were registered in the register book at the South Jakarta District Court
     under No. 1736 and No. 1737 dated 27 May 1975, and were announced in the State Gazette
     No. 312, Supplement to the State Gazette No. 52 dated 1 July 1975.

     In 1997, the Company conducted its initial public offering to the public with 430,769,000 (four
     hundred thirty million seven hundred sixty-nine thousand) shares at a nominal value of
     Rp1,000.00 (one thousand Rupiah) per share at an offering price of Rp1,400.00 (one thousand
     four hundred Rupiah) per share. Consequently, since 27 November 1997, all Company shares
     have been listed on the Jakarta and Surabaya Stock Exchanges (now Indonesia Stock



                                                                                       Page 17 of 35
Page 19
Exchange). Subsequently, the Company's name was changed to Perusahaan Perseroan
(Persero) PT Aneka Tambang Tbk, abbreviated as PT Aneka Tambang (Persero) Tbk based
on the Declaration Deed of the Extraordinary General Meeting of Shareholders of Perusahaan
Perseroan (Persero) PT Aneka Tambang Tbk No. 48 dated 15 September 1997. In 1999, the
Company also listed its shares in the form of Chess Depository Interests on the ASX as a
Foreign-Exempt Listing and later upgraded its listing status to ASX Listing in 2002.

Furthermore, in 2017, following the establishment of the Mining Industry Holding by the
Government of the Republic of Indonesia, there was a transfer of ownership of Series B shares
in the Company by 65% (sixty-five percent) in accordance with GR 47/2017. Pursuant to GR
47/2017, the ownership of the Republic of Indonesia over 15,619,999,999 (fifteen billion six
hundred nineteen million nine hundred ninety-nine thousand nine hundred ninety-nine) Series B
shares in the Company was transferred to Perusahaan Perseroan (Persero) PT Indonesia
Asahan Aluminium ("Inalum") as an additional State capital participation in Inalum ("Holding
Transaction").

The Holding Transaction did not result in a change in control within the Company as the
Republic of Indonesia retained control through indirect share ownership in the Company.
Subsequently, through ownership of Series A shares in the Company, the Republic of
Indonesia retained specific rights not granted to the holders of Series B shares in accordance
with the provisions in the Company's Articles of Association.

As a result of the Holding Transaction, Inalum became the direct holder of 65% (sixty-five
percent) of Series B shares in the Company, while the public holds 35% (thirty-five percent) of
Series B shares in the Company, whereas Dwiwarna Series A shares in the Company are still
owned by the Republic of Indonesia. Therefore, the Company’s status, initially a Persero (state-
owned enterprise), changed to a Limited Liability Company (Non-Persero) as stated in the
Deed No. 89 dated 29 November 2017, executed before Jose Dima Satria S.H., M.Kn., a
Notary in South Jakarta, and obtained approval from the MoLHR through Decree No. AHU-
0026147.AH.01.02. Year 2017 dated 13 December 2017, and acknowledgment notification
from the MoLHR through Letter No. AHU-AH.01.03-0200027 dated 13 December 2017.

In accordance with (i) GR 47/2017; (ii) Minister of Finance Decree No. 887/KMK.06/2017; and
(iii) Agreement on the Transfer of the Republic of Indonesia's Rights to Shares in the Company
and in the context of Additional State Capital Participation of the Republic of Indonesia in the
Share Capital of Inalum dated 27 November 2017, the total issued and fully paid-up shares in
the Company amounted to Rp2,403,076,472,500.00 (two trillion four hundred three billion
seventy-six million four hundred seventy-two thousand five hundred Rupiah) or 24,030,764,725
(twenty-four billion thirty million seven hundred sixty-four thousand seven hundred twenty-five)
shares, consisting of one Dwiwarna Series A share and 24,030,764,724 (twenty-four billion
thirty million seven hundred sixty-four thousand seven hundred twenty-four) Ordinary Series B
shares.

In December 2022, the Indonesian Government issued GR 45/2022 regarding the reduction of
state capital participation in Inalum and GR 46/2022 regarding state capital participation for the
establishment of a state-owned limited liability company (Persero) in the mining sector. In line
with the implementation of GR 45/2022, Inalum returned ownership of 15,619,999,999 (fifteen
billion six hundred nineteen million nine hundred ninety-nine thousand nine hundred ninety-
nine) Series B shares in the Company to the Government of the Republic of Indonesia for the
purpose of reducing state capital participation.




                                                                                     Page 18 of 35
Page 20
Subsequently, in compliance with the implementation of GR 46/2022, concurrently with the
effective reduction of state capital participation, the Government of the Republic of Indonesia
transferred its ownership of 15,619,999,999 (fifteen billion six hundred nineteen million nine
hundred ninety-nine thousand nine hundred ninety-nine) Series B shares in the Company to
MIND ID as a state capital injection for the establishment of MIND ID. MIND ID is a state-owned
enterprise in which all shares are owned by the Government of the Republic of Indonesia.
Commencing from 21 March 2023, the Company remains indirectly controlled by the
Government of the Republic of Indonesia and is directly controlled by MIND ID.

Furthermore, the Company's Articles of Association have undergone several amendments. The
most recent change was formalized in the Deed Statement of the Meeting Resolution on the
Amendment of the Articles of Association of PT Aneka Tambang Tbk No. 51 dated 11 July
2023, which was made before Jose Dima Satria, S.H., M.Kn., a Notary in South Jakarta and
the notification of this alteration was received by the MoLHR through Letter No. AHU-AH.01.03-
0094322 dated 20 July 2023 concerning the Receipt of Notification of Amendment to the
Articles of Association of PT Aneka Tambang Tbk (“Company's Articles of Association”).

Business Activities
Based on Article 3, Paragraph (1) of the Company's Articles of Association, the purpose and
objectives of the Company are to engage in mining activities involving various types of mineral
resources, and to operate in industries, trade, transportation, and services associated with the
mining of these various types of mineral resources. Additionally, the aim includes optimizing the
utilization of the Company's resources to produce high-quality goods and/or services with
strong competitiveness, pursuing profits to enhance the Company's value by adhering to the
principles of a Limited Liability Company. To achieve these purposes and objectives, the
Company may undertake the following main business activities:

a.    engaging in mining activities involving various mineral resources, including but not limited
      to: (i) bauxite ore mining; (ii) nickel ore mining; and (iii) gold and silver mining;

b.    operating in industries associated with the mining of various mineral resources,
      encompassing, but not limited to: (i) production of base metals; (ii) production of precious
      base metals; (iii) clay brick/ceramic manufacturing industry; (iv) tile manufacturing from
      clay/ceramics;

c.    conducting trade activities related to various mineral resources, including
      processed/refined mineral commodities, both in physical and non-physical trading
      (including hedging), such as: (i) wholesale trade of jewelry and watches; (ii) wholesale
      trade of metals and metal ores; (iii) wholesale trade of tiles, bricks, roof tiles, and similar
      products made from clay, limestone, cement, or glass; (iv) wholesale trade of cement,
      limestone, sand, and stones; (v) other business support service activities; (vi)
      warehousing and storage services; (vii) retail trade through various media for various
      goods;

d.    operating transportation services for both its own purposes and other parties related to
      the mining of various mineral resources, including: (i) motorized transport for specialized
      goods; (ii) railway transport for goods; (iii) domestic maritime transport for specialized
      goods; (iv) port services activities; (v) river and lake transport for specialized goods; (vi)
      river and lake port services activities;

e.    providing services associated with the mining of various mineral resources (excluding
      legal and tax consultancy services), including: (i) other support activities for mining and



                                                                                       Page 19 of 35
Page 21
         quarrying; (ii) laboratory testing services; (iii) other management consultancy activities;
         (iv) engineering activities and associated technical consultancy; (v) activities in the field
         of education, not limited to private technical education, other private education, and
         educational support activities; (vi) other technical analysis and testing; (vii) technical
         installation inspection services; (viii) industrial process commissioning, quality assurance,
         and quality control services.

Furthermore, as per Article 3 paragraph (3) of the Company's Articles of Association, the
Company may also engage in supportive/complementary activities aimed at optimizing the
utilization of owned resources, including but not limited to:

a.       optimization activities and utilization of assets, whether it be land, buildings, or other
         asset forms, including but not limited to real estate owned or leased;
b.       industrial estates;
c.       plantation, agriculture, and forestry, encompassing all economic/business activities,
         including food crop farming, plantations, horticulture, forest harvesting, and this category
         also includes support services for each of these economic activities;
d.       properties, including (i) star-rated hotels; (ii) hotel apartments; (iii) owned or leased real
         estate; (iv) health center activities; (v) private hospital activities; (vi) private clinic
         activities;
e.       optimization and utilization of owned resources, including but not limited to power plants
         and energy, not restricted to electricity generation activities;
f.       waste management, encompassing all activities related to wastewater, garbage,
         hazardous and toxic waste management, including collection, transportation, storage,
         and utilization; including but not limited to (i) collection of non-hazardous wastewater; (ii)
         collection of hazardous wastewater; (iii) treatment and disposal of non-hazardous
         wastewater; (iv) treatment and disposal of hazardous wastewater; (v) collection of non-
         hazardous waste and garbage; (vi) collection of hazardous waste; (vii) treatment and
         disposal of non-hazardous waste and garbage; (viii) treatment and disposal of hazardous
         waste; (ix) recovery of metal material goods; (x) recovery of non-metal material goods;
g.       tourist areas;
h.       privately managed museums;
i.       information and communication, including but not limited to (i) private radio broadcasting;
         (ii) telecommunications activities for self-use; (iii) cableless telecommunications activities
         in compliance with applicable laws and regulations;
j.       provision of clean water and distribution of clean water for industrial activities, including:
         (i) collection, purification, and distribution of drinking water; (ii) collection and distribution
         of raw water;
k.       land preparation, sand excavation, and other building constructions;
l.       operation of storage and warehousing facilities for (i) oil and natural gas storage; and (ii)
         hazardous and toxic waste storage activities.

Capital Structure and Shareholders Composition of the Company
In accordance with Article 4 of the Company's Articles of Association and the Report of
Securities Administration Bureau (PT Datindo Entrycom) as of 30 November 2023, the capital
structure of the Company as of the Information Disclosure Date is as follows:

                                  Number of          Total Nominal Value (Nominal Value
         Explanation                                                                                  %
                                   Shares              Rp100.00 per Share Certificate)
     Authorized Capital
     Class A Shares           1                      Rp100,00                                     -



                                                                                             Page 20 of 35
Page 22
                                 Number of         Total Nominal Value (Nominal Value
           Explanation                                                                        %
                                  Shares             Rp100.00 per Share Certificate)
      Class B Shares         24.030.764.724     Rp2.403.076.472.400,00                    -
      Total Authorized       24.030.764.725     Rp2.403.076.472.500,00                    -
      Capital
      Paid-up Capital
      Class A Shares
      The Government of      1                  Rp100,00                                  0
      Indonesia
      Class B Shares
      MIND ID                15.619.999.999     Rp1.561.999.999.900,00                    65
      Other shareholders     8.410.764.725      Rp841.076.472.500,00                      35
      with ownership below
      5%
      Total Issued and       24.030.764.725     Rp2.403.076.472.500,00                    100
      Paid-up Capital

     The Board of Directors and Board of Commissioners of the Company
     Based on the Company's Articles of Association, the composition of Board of Directors and
     Board of Commissioners as of the date of this Information Disclosure are as follows:

     Director
     President Director                        :     Nicolas D. Kanter
     Director of Operation and Production      :     Hartono
     Director of Business Development          :     I Dewa Bagus Sugata Wirantaya
     Director of Finance and Risk Management   :     Elisabeth RT Siahaan
     Director of Human Resources               :     Achmad Ardianto

     Board of Commissioner
     President of Commissioner cum             :     F.X. Sutijastoto
     Independent Commissioner
     Independent Commissioner                  :     Gumilar Rusliwa Somantri
     Independent Commissioner                  :     Anang Sri Kusuwardono
     Commissioner                              :     Bambang Sunarwibowo
     Commissioner                              :     Dilo Seno Widagdo

2.   IMC

     General Explanation
     IMC was established under the Deed of Establishment of the Limited Liability Company PT
     International Mineral Capital No. 16 dated 3 March 2011, which was made before Bambang
     Dharmawan, S.H., who at that time replaced Buntario Tigris Darmawa, S.H., S.E., M.H., a
     Notary in Central Jakarta, and received approval from the MoLHR through Decree No. AHU-
     11868.AH.01.01.Year 2011 dated 8 March 2011.

     The Articles of Association of IMC have undergone several amendments, last amended
     through the Deed of Statement of Decision outside the Extraordinary General Meeting of
     Shareholders of PT International Mineral Capital No. 01 dated 21 May 2021, which was made


                                                                                     Page 21 of 35
Page 23
     before Zulfiah Tenri Abeng, S.H., M.Hum., M.Kn., a Notary in Bogor Regency, and have
     obtained approval from the MoLHR through Letter No. AHU-0031937.AH.01.02.TAHUN 2021
     ("IMC's Articles of Association").

     Business Activities
     Based on Article 3 of IMC's Articles of Association, the purpose and objective of IMC are to
     engage in business activities in the field of trading services. To achieve these goals and
     objectives, IMC may conduct business activities as follows:

     a.    engaging in service-related businesses, including but not limited to: (i) trusts, financing,
           and similar financial entities; (ii) venture capital; (iii) holding company activities; (iv) other
           management consulting activities; and (v) other business support service activities;
     b.    engaging in trading businesses, including but not limited to wholesale trading of metals
           and metal ores.

     Capital Structure and Shareholders Composition of IMC
     Based on Article 4 of IMC's Articles of Association, IMC's capital structure as at the date of this
     Information Disclosure is as follows:

                                  Number of          Total Nominal Value (Nominal Value
          Explanation                                                                                 %
                                   Shares            Rp10.000,00 per Share Certificate).
     Authorized Capital        85.000.000            Rp850.000.000.000,00                         -
     Issued and Paid Up Capital
     Company                   61.532.082            Rp615.320.820.000,00                         99,20
     PT Indonesia Coal
                               493.038               Rp4.930.380.000,00                           0,080
     Resources
     Total Issued and          62.025.120            Rp620.251.200.000,00                         100,00
     Paid Up Capital
     Treasury Stocks           22.974.880            Rp229.748.800.000,00                         -

     The Board of Directors and Board of Commissioners of MC

     Based on the Deed of Resolution Outside the Meeting of Shareholders in lieu of the
     Extraordinary General Meeting of Shareholders of PT International Mineral Capital No. 04
     dated 18 July 2022, which was made before Zulfiah Tenri Abeng, Bachelor of Laws, Master of
     Humanities, Master of Notary, a Notary in Bogor Regency, the composition of the Board of
     Directors and Board of Commissioners of IMC as of the date of this Information Disclosure is as
     follows:

     Director            :   Handi Sutanto
     Commissioner        :   Sufen Triantio

3.   HKCBL

     General Explanation
     HKCBL is a limited liability company established under the laws of Hong Kong on 25 January
     2021.




                                                                                               Page 22 of 35
Page 24
      Business Activities
      The purpose and objective of HKCBL is to become an international investment platform,
      HKCBL's planned investment projects include mine development, non-ferrous smelting, battery
      manufacturing and other new energy battery production. To achieve these aims and objectives,
      HKCBL may carry out business activities as follows:

      a.     sales of non-ferrous metals and high-performance alloying materials;
      b.     development of new material technologies; and
      c.     trade in goods and technology/management, mergers and acquisitions of global mineral
             and resource projects and trade channels for related products.

      Capital Structure and Shareholders Composition of HKCBL

              Name of
                                  Total Number             Total Amount Paid-up                  %
           Shareholder(s)
       Ningbo Contemporary
       Brunp Lygend Co.,             990,013                   USD 990,013.00                 100%
       Ltd.

      The Board of Directors and Board of Commissioners of HKCBL
      According to the Company Registry dated 4 January 2023, the composition of the Board of
      Directors and Board of Commissioners of HKCBL as of the date of this Information Disclosure
      is as follows:

      Director
      Director                                      :   Tang Honghui
      Director                                      :   Chi Peng

                              SUMMARY OF APPRAISER’S REPORT

In accordance with the explanation provided in the previous section, the SDA-ANTAM Divestment
Transaction is a part of the Exempted Transaction Series, therefore it does not use an Appraiser and
it will not be considered in assessing the materiality of the Transaction Series, thus this section will
elaborate the part of the Transaction Series that constitutes the Non-Exempted Transaction Series. In
relation to the Non-Exempted Transaction Series, the Company has appointed and assigned KJPP
Ruky, Safrudin & Rekan (“RSR”) and KJPP Suwendho Rinaldy & Rekan (“SRR”) to provide an
assessment and fairness opinion of the Non-Exempted Transaction Series within the Transaction
Series, with detail as follows:

1.    RSR as an Appraiser for SDA-HKCBL Divestment Transaction;
2.    SRR as an Appraiser for FHT Divestment Transaction;
3.    SRR as an Appraiser for HPAL JVCO Investment Transaction; and
4.    SRR as an Appraiser for providing the fairness opinion on the entire Transaction Series.

A.    Summary of the SDA-HKCBL Divestment Transaction Assessment Report based on the
      SDA Assessment Report

      1.     Transacting Parties

             The parties involved in the SDA-HKCBL Divestment Transaction are the Company as the
             seller and HKCBL as the buyer.




                                                                                           Page 23 of 35
Page 25
2.   Object of Assessment

     Object of assessment is SDA-HKCBL Shares, the 49% (forty-nine percent) of non-
     control shares in SDA.

3.   Purposes and Objectives of the Assessment

     The purpose of the assessment is to estimate the market value of 49% (forty-nine
     percent) of shares in SDA related to the SDA-HKCBL Divestment Transaction in order to
     comply with OJK regulations on the capital market, and not for the taxation, banking, and
     any other type of transaction plans. Further, the objective of the assessment is to assess
     the shares for the purpose of transaction of the Publicly-Listed Company.

4.   Assumption and Limiting Conditions

     Assumption

     a.    The SDA Assessment Report is non-disclaimer opinion in nature, RSR has
           reviewed the documents used in the assessment process, data, and information
           obtained from the Company’s management and/or SDA as well as other reliable
           sources which the accuracy can be trusted.
     b.    The SDA Assessment Report is prepared upon the adjusted financial projection as
           approved by the Company’s management, reflecting the fairness of the financial
           projection with its achievability (fiduciary duty).
     c.    RSR is responsible for conducting the assessment and according to RSR’s
           opinion, the adjusted financial projections are reasonable. However, RSR is not
           responsible for the accomplishment.
     d.    RSR is responsible for assessment’s opinion and conclusion of final value.
     e.    The SDA Assessment Report is open to the public, except for information that is
           confidential and could affect the Company’s operations.
     f.    RSR has also obtained information on the legal status of the assessed object from
           SDA.

     Depth Level of the Investigation
     In carrying out the assignment, there are no limits or restrictions in conducting the
     inspection reviews, calculations, and analyses. RSR has conducted interviews with the
     Company's management and SDA through video conference, but RSR did not conduct
     on-site inspections of SDA's operations.

     Limiting Conditions

     a.    The assessment is prepared based on the principles of integrity of information and
           data. In preparing SDA Assessment Report, RSR relies on information and data
           as prepared by the Company’s management and/or SDA, which in essence, is
           deemed to be true, complete, reliable, and not misleading in the context of
           fairness.
     b.    With the transfer of mining business licenses from the Company to SDA and the
           transfer of SDA’s mining services business to another subsidiary of the Company,
           the assessment of 49% (forty-nine percent) of SDA shares indirectly constitutes an
           assessment of the mining business transferred from the Company.
     c.    The aforementioned transfer obliges SDA to restate its financial statements, and
           RSR understands that SDA has fulfilled this obligation in accordance with GAAP



                                                                                  Page 24 of 35
Page 26
     38 provisions where SDA has restated its financial statement in such a way that
     the transfer of the nickel mining business transaction is deemed effective from 1
     January 2021, which is the beginning of the statement period.
d.   Based on the above conditions, SDA does not have audited financial statements
     for the period ending on 31 December 2018 – 31 December 2021, which have
     reflected the restatement of the business related to the transferred mining
     business permit. Therefore, in conducting historical analysis, RSR relies on
     working papers prepared by the Company and SDA for the periods ending on 31
     December 2020 and 31 December 2021.
e.   RSR’s assessment is also based on the number of mineral reserves contained in
     The Reporting of Exploration Results, Mineral Resources, and Ore Reserves as at
     30 September 2022 prepared by PT Mining One Indonesia in January 2023.
f.   RSR has not conducted a detailed audit or due diligence on the explanations or
     data provided by the management of the Company and SDA either orally or in
     writing, and as such RSR cannot guarantee or be responsible for the accuracy and
     completeness of such information or explanation.
g.   As a basis for RSR to conduct analyses in the assessment, RSR uses the data as
     listed in the data and information sources section as material for review,
     calculation and analysis.
h.   Any changes to such data may materially affect the results of RSR's assessment.
     Therefore, RSR cannot accept responsibility for possible differences in
     conclusions due to changes in such data.
i.   This assessment is prepared only by considering the Company's point of view and
     does not consider the point of view of other stakeholders and other aspects.
j.   RSR assignments are not undertaken for the purpose of disclosing internal control
     weaknesses, errors or fraud in the financial statements, any form of tax implication
     or violation of the law.
k.   The denomination of this share valuation is expressed in Rupiah. This is based on
     the understanding that SDA's financial statements are presented in Rupiah. The
     review, calculation, and analysis are based on the data and information provided
     by the management of the Company and/or SDA as stated in the source of data
     and information.
l.   The assessment was prepared by considering market and economic conditions,
     general business and financial conditions, and government regulations as of the
     date of this assessment.
m.   WHO has officially announced that the COVID-19 pandemic is a global pandemic
     and has spread almost all over the world including Indonesia. This was announced
     on 11 March 2020, as reported on the official WHO website through a press
     conference at WHO headquarters in Geneva.
n.   On 30 December 2022, the Government officially revoked the restrictions on
     community activities in all parts of Indonesia and on 21 June 2023, the
     Government decided to revoke the pandemic status and entered the endemic
     period.
o.   The COVID-19 pandemic has indirectly affected the global and Indonesian
     economy and has the potential to affect the companies’ business operations in
     Indonesia.
p.   The resolution of the COVID-19 pandemic will depend on the effectiveness of
     policies or regulations issued by the Government of the Republic of Indonesia and
     the level of public discipline in implementing these policies. Similarly, Indonesia's
     economic growth after the COVID-19 pandemic depends on the macro-economic
     policies proposed by the Government of the Republic of Indonesia.




                                                                            Page 25 of 35
Page 27
     q.    This assessment is only made against the assessment objectives as outlined
           above.
     r.    RSR considers that since the date of issuance of the assessment report, there
           have been no changes that materially affect the assumptions used in the SDA
           Assessment Report as a result of changes in some or all of the information and
           documents provided to RSR by the management of the Company and/or SDA.
     s.    RSR stated that RSR's assignment did not include analyzing transactions outside
           the assessment objectives that may be available to the Company and the effect of
           such transactions on the assessment objectives, nor was it an analysis of the most
           probable and optimal use of the assessment objectives.
     t.    RSR would like to emphasize that the results of RSR's analysis and review are
           specifically limited to the commercial and financial aspects of the transaction. RSR
           did not conduct research on the legal validity of the SDA-HKCBL Divestment
           Transaction and the tax implications of the SDA-HKCBL Divestment Transaction,
           as these were beyond the scope of RSR's assignment.
     u.    RSR also relies on the representation letter from the Company on the assignment
           of RSR to prepare the share valuation report, that the Company, either directly or
           through the Company's consultants, has disclosed all important and relevant
           information in relation to the share valuation and to the best of the Company's
           management's knowledge there are no undisclosed material factors that may be
           misleading.

5.   Approaches and Methods

     Based on the results of the analysis conducted, SDA has good business prospects,
     where the income factor is one of the main value drivers of the company. Therefore, the
     assessment is carried out using the income approach as the main assessment approach.
     Considering that the main driver of a mining company comes from its assets such as
     exploration assets, mining business licenses, and equipment supporting mining activities,
     therefore RSR applies the asset approach as the second assessment approach.

     RSR did not apply the market approach in the assessment on the basis that the historical
     financial performance of SDA up to the valuation date does not reflect the future
     business potential of SDA and therefore not appropriate to be used in the assessment.

     The above assessment approaches and methods are those that RSR considers most
     appropriate for application in this assignment.

6.   Conclusion

     The market value of 49% (forty-nine percent) of SDA shares as of 30 June 2023 is
     Rp5,876,366,000,000.00 (rounded) (five trillion eight hundred seventy-six billion three
     hundred sixty-six million Rupiah) or equivalent to USD391,079,887.00 (three hundred
     ninety-one million seventy-nine thousand eight hundred eighty-seven United States
     Dollars) (Bank Indonesia mid exchange rate as of 27 June 2023 in the amount of USD1
     = Rp15,026.00).




                                                                                  Page 26 of 35
Page 28
B.   Summary of the FHT Divestment Transaction Assessment Report based on FHT
     Assessment Report

     1.   Transacting Parties

          The parties to the FHT Divestment Transaction are the Company and IMC as sellers of
          the Ownership of Shares in FHT; and (ii) and HKCBL as purchasers of the Ownership of
          Shares in FHT.

     2.   Object of Assessment

          The object of assessment is Ownership of Shares in FHT, the 60% (sixty percent) of
          shares in FHT that are controlling in nature and 40% (forty percent) non-controlling
          shares in FHT.

     3.   Purposes and Objective of Assessment

          The purpose of the assessment of the FHT Divestment Transaction is to provide
          information which will then be used as a reference by the Company in the context of
          implementing the Transactions Series. The objective of the assessment of the FHT
          Divestment Transaction is to provide an opinion on the market value, on June 30 2023,
          of the Share Ownership in FHT and 40% (forty percent) of non-controlling FHT shares,
          expressed in Rupiah.

     4.   Assumptions dan Limitations

          a.    The FHT Assessment Report is a non-disclaimer opinion.
          b.    SRR has reviewed the documents used in the assessment process.
          c.    The data and information obtained comes from sources whose accuracy can be
                trusted.
          d.    SRR uses adjusted financial projections that reflect the fairness of the financial
                projections made by the Company's management with the ability to achieve them
                (fiduciary duty).
          e.    SRR is responsible for the implementation of assessments and the fairness of
                financial projections.
          f.    The FHT Assessment Report is open to the public unless there is confidential
                information that could affect the Company's operations.
          g.    SRR is responsible for the FHT Assessment Report and final value conclusions.
          h.    SRR has obtained information on the legal status of FHT shares from the
                Company.

     5.   Approaches and Methods

          The assessment approach used in the valuation of Ownership of Shares in FHT and the
          40% (forty percent) of non-controlling shares in FHT is the income approach using the
          discounted cash flow method and the market based approach using the comparative
          method of listed companies on the stock exchange (guideline publicly traded company
          method).




                                                                                     Page 27 of 35
Page 29
     6.   Conclusion of Value

          Based on the analysis of all data and information that SRR has received and taking into
          account all relevant factors affecting the valuation, therefore in SRR's opinion, the market
          value of 60% (sixty percent) shares in FHT as at 30 June 2023 is Rp779,230,000,000.00
          (seven hundred seventy nine billion two hundred thirty million Rupiah) and the market
          value of 40% (forty percent) of shares in FHT as at 30 June 2023 is
          Rp318,180,000,000.00 (three hundred eighteen billion one hundred eighty million
          Rupiah).

C.   Summary of HPAL JVCO Investment Transaction Feasibility Study Report based on
     HPAL Feasibility Study Report

     1.   Transacting Parties

          The parties to the HPAL JVCO Investment Transaction are (i) the Company; and (ii)
          HKCBL, both of which act as the founder and prospective shareholder of HPAL JVCO.

     2.   Object of the Feasibility Study

          The object of the feasibility study is the feasibility of HPAL JVCO Transaction as a
          company to be established by the Company and HKCBL.

     3.   Purposes and Objectives of the Feasibility Study

          The purpose of the feasibility study is to provide an opinion of the feasibility of the HPAL
          JVCO Investment Transaction in terms of market analysis, technical analysis, business
          pattern analysis, management model analysis, and financial analysis. The objective of
          the preparation of the feasibility study is to provide an overview of the feasibility of the
          HPAL JVCO Investment Transaction and to fulfil the provisions of POJK 17/2020.

     4.   Assumption and Limiting Conditions

          a.    The HPAL Feasibility Study Report is a non-disclaimer opinion report in nature.
          b.    SRR has reviewed the documents used in the feasibility study process.
          c.    The data and information obtained comes from sources that can be trusted for
                accuracy.
          d.    SRR uses adjusted financial projections that reflect the fairness of the financial
                projections made by the Company's management with the ability to achieve them
                (fiduciary duty).
          e.    SRR is responsible for the preparation of the HPAL Feasibility Study Report and
                the fairness of the financial projections.
          f.    The HPAL Feasibility Study Report is open to the public unless there is
                confidential information, which may affect the Company's operations.
          g.    SRR is responsible for the HPAL Feasibility Study Report and the feasibility study
                conclusions.
          h.    SRR has obtained information on legal status of the HPAL JVCO Investment
                Transaction from the Company.




                                                                                        Page 28 of 35
Page 30
     7.   Approaches and Methods

          The feasibility analysis in this feasibility study uses the discounted cash flow method with
          reference to the investment criteria of net present value ("NPV"), internal rate of return
          ("IRR"), payback period ("PP"), discounted payback period ("DPP"), and profitability
          index (or benefit/cost ratio). Based on these investment criteria, the HPAL JVCO
          Investment Transaction can be said to be feasible or profitable if it results in an NPV
          greater than zero, an IRR greater than the discount rate, a PP and DPP shorter than the
          projection period, and a profitability index greater than 1x (one time).

     5.   Conclusion

          Based on the results of the analysis of all data and information that SRR has received
          and taking into account all relevant factors that influence the feasibility analysis, therefore
          in SRR's opinion the HPAL JVCO Investment Transaction is financially feasible. This can
          be seen from the following investment criteria values:

                                                                     Investment Criteria
          No.                Description                              (in thousand USD)
                                                                Project                 Equity
           1.   NPV                                             682.816                355.294

           2.   IRR                                             15,23%                  19,34%

           3.   PP                                             11 years            9 years 6 months

           4.   DPP                                       13 years 8 months       13 years 5 months

           5.   Profitability index/benefit-cost ratio            1,54                   1,31


D.   Summary of Fairness Opinion Report on Transactions Series based on Fairness Opinion
     Report

     1.   Transacting Parties

          The parties to the Transaction Series are the Company, ARI, IMC, IBC and HKCBL.

     2.   Object of Fairness Opinion

          The object of the fairness opinion is the Transaction Series, which is divided into:

          a.    Non-Exempted Transactions Series:
                (i)   SDA-HKCBL Divestment Transaction;
                (ii)  FHT Divestment Transaction; and
                (iii) HPAL JVCO Investment Transaction.

          b.    Exempted Transaction Series:
                (i)  SDA-ANTAM Divestment Transaction; and
                (ii) Battery Manufacturing JVCOs Investment Transaction.




                                                                                           Page 29 of 35
Page 31
3.   Purposes and Objective of the Fairness Opinion

     The purpose of the preparation of the Fairness Opinion Report is to fulfil POJK 17/2020.
     The objective of the preparation of the Fairness Opinion Report is to provide an overview
     of the fairness of the Transaction Series.

4.   Assumptions and Limiting Conditions

     a.    Fairness Opinion Report is a non-disclaimer opinion report in nature.
     b.    SRR has reviewed the documents used in the process of preparing the Fairness
           Opinion Report.
     c.    The data and information obtained comes from sources that can be trusted for
           accuracy.
     d.    The analysis in the preparation of the Fairness Opinion Report is carried out by
           using adjusted financial projections that reflect the fairness of financial projections
           made by the Company's management with its ability to achieve (fiduciary duty).
     e.    SRR is responsible for the implementation of the preparation of the Fairness
           Opinion Report and the fairness of financial projections.
     f.    The Fairness Opinion Report is a report that is open to the public unless there is
           confidential information which may affect the Company's operation.
     g.    SRR is responsible for the Fairness Opinion Report and the conclusion of the
           Fairness Opinion Report.
     h.    SRR has obtained information on the terms and conditions of the agreements
           related to the Transaction Series from the Company.

5.   Approaches and Methods

     There are several assessment approaches used in the assessment of Transaction
     Series, as follows:

     a.    Qualitative and Quantitative Analysis

           Analysis conducted by conducting a review of the mining industry which will
           provide an overview of the development of the mining industry's performance,
           conducting an analysis of the Company's operational activities and business
           prospects, the reasons for conducting the Transaction Series, the advantages
           and disadvantages of the Transaction Series and conducting an analysis of
           the Company's historical financial performance based on the Company's
           consolidated financial statements for the years ended 31 December 2018-
           2022 which have been audited and for the 6 (six) months period ended 30
           June 2023 which have been reviewed by the auditor.

           Based on the projection of the Company's financial position report without the
           Transaction Series and with the Transaction Series, it appears that with the
           Transaction Series there will be an increase in the current ratio, quick ratio, return
           on assets ("ROA"), and return on equity ("ROE") of the Company. Based on the
           projection of the Company's profit (loss) statement without the Transaction Series
           and with the Transaction Series, it appears that with the Transaction Series there
           will be an increase in the Company's operating profit margin and net profit margin.

           Furthermore, SRR also analyzed the proforma report and incremental analysis of
           the Transaction Series, where after the Transaction Series became effective,



                                                                                    Page 30 of 35
Page 32
          based on the Company's proforma financial statements, there was an increase in
          current ratio, ROA, ROE, and net profit margin.

     b.   Analysis on the Fairness of the Transaction Series

          Based on the fairness analysis of the Transaction Series that has been carried out,
          including the price fairness analysis and the analysis of the impact of the
          Transaction Series, the result is obtained that the Transaction Series are
          reasonable because:

          i)     The SDA-HKCBL Divestment Transaction price is 6.50% (six point five
                 percent) higher than the market value of 49% (forty nine percent) SDA’s
                 shares;
          ii)    The FHT Divestment Transaction Price is 0.25% (zero point two five percent)
                 higher than the market value of 60% (sixty) of FHT’s shares; and
          iii)   The HPAL JVCO Investment Transaction is feasible with net present value
                 (NPV) greater than zero, internal rate of return (IRR) greater than the
                 discount rate, payback period (PP) and discounted payback period (DPP)
                 shorter than the projection period, and profitability index greater than 1x (one
                 time).

          Furthermore, from the analysis of the impact of the Transaction Series, it is
          concluded that the Transaction Series will be able to provide benefits to the
          Company’s Shareholders.

6.   Conclusion

     Based on the fairness analysis of the transaction that has been carried out on the
     Transaction Series, SRR is of the opinion that the Transaction Series is fair.


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                                                                                   Page 31 of 35
Page 33
      IMPACT OF THE TRANSACTION PLAN ON THE COMPANY'S FINANCIAL CONDITION

The following is the proforma balance sheet report of the Company before and after the Transaction
Series:

                                                               Adjustment
                                           Before the                                  After the
                Description               Transaction       FHT           SDA         Transaction
                                             Series      Divestment    Divestment        Series
                                                            60%           49%


Assets
Current Assets


Cash and Cash Equivalent                     6,581,605      781,200      6,258,329      13,621,134
Receivables, Net                             2,089,390             -              -      2,089,390
Supplies, Net                                2,934,689             -              -      2,934,689
Other Receivables, Net                         364,990             -              -        364,990
Prepaid Taxes                                  536,480             -              -        536,480
Prepaid Costs                                  120,351             -              -        120,351
Other Current Financial Assets                 836,113             -              -        836,113
Other Current Assets                           342,073             -              -        342,073
Assets Held for Sale                           506,060     (506,060)              -                 -


Total Current Assets                        14,311,751      275,140      6,258,329      20,845,220


Non-Current Assets
Restricted Cash Usage                          246,021             -              -        246,021
Investment on Association Entities, Net      2,308,080      318,185               -      2,626,265
Fixed Assets, Net                           16,257,643             -              -     16,257,643
Mining Properties, Net                         647,803             -              -        647,803
Exploration and Evaluation Assets net          550,739             -              -        550,739
Intangible Assets, Net                          28,273             -              -         28,273
Prepaid Taxes                                  723,401             -              -        723,401
Goodwill                                        68,336             -              -         68,336
Deferred Tax Assets                            220,266             -     (106,888)         113,378
Other Non-Current Assets                     1,006,353             -        485,856      1,492,209


Total Non-Current Assets                    22,056,915      318,185         378,968     22,754,067


Total Assets                                36,368,666      593,325      6,637,297      43,599,287


Liabilities and Equities


Short-Term Liabilities
Account Payable                              1,018,408             -              -      1,018,408
Accrual Expenses                             1,674,280             -              -      1,674,280




                                                                                        Page 32 of 35
Page 34
                                                                   Adjustment
                                               Before the                                  After the
                 Description                  Transaction       FHT           SDA         Transaction
                                                 Series      Divestment    Divestment        Series
                                                                60%           49%
Short-Term Employee’s Liabilities                  367,764             -              -        367,764
Prepaid Customers                                  710,684             -              -        710,684
Tax Payable                                        428,346        9,636         502,225        940,207
Rent Liabilities, Short-Term Part                   85,308             -              -         85,308
Short-Term Bank Payable                            901,560             -              -        901,560
Short-Term Investment Payable                      643,977             -              -        643,977


Short-Term Provision                             1,089,638             -              -      1,089,638
Dividend Payable                                 1,862,894             -              -      1,862,894
Other Payable                                      483,362             -              -        483,362
Liabilities related to Assets Held for Sale          5,957       (5,957)              -                 -



Total Short-Term Liabilities                     9,272,178        3,679         502,225      9,778,082


Long-Term Liabilities
Rent Liabilities, Net of Short-Term                 74,987             -              -         74,987


Investment Loan, Net of Short-Term               1,323,447             -              -      1,323,447


Provisions, Net of Short-Term                      896,990             -              -        896,990


Provision for Post-Employment Benefits           1,122,296             -              -      1,122,296
Other Long-Term Liabilities                          2,682             -              -          2,682


Total Long-Term Liabilities                      3,420,402            -               -      3,420,402


Total Liabilities                               12,692,580        3,679         502,225     13,198,484


Equities


Shares Capital                                   2,403,076             -              -      2,403,076
Agio Shares                                      3,934,833             -     5,820,475       9,755,308
Foreign    Exchange      Difference      on      1,185,116             -              -      1,185,116
Elaboration of Financial Statements
Surplus on Revaluation of Fixed Assets           3,014,627      (51,725)              -      2,962,902
Profit Balance
- Designated Use                                   480,615             -              -        480,615
- Undesignated Use                              12,657,801      641,371               -     13,299,172
Non-Controlling Interest                                18             -        314,597        314,615


Total Equities                                  23,676,086      589,646      6,135,071      30,400,804




                                                                                            Page 33 of 35
Page 35
                                                                 Adjustment
                                          Before the                                    After the
                Description              Transaction          FHT           SDA        Transaction
                                            Series         Divestment    Divestment       Series
                                                              60%           49%
Total Liabilities and Equities             36,368,666         593,325      6,637,297     43,599,288


The following is the Company's proforma financial profit and loss statement before and after the
Transaction Series:

                                                                 Adjustment
                                          Before the                                    After the
                Description              Transaction          FHT           SDA        Transaction
                                            Series         Divestment    Divestment       Series
                                                              60%           49%


Sales                                      21,661,112                -             -     21,661,112

Cost of Goods Sold                        (17,420,301)               -             -    (17,420,301)


Gross Profits                                4,240,811               -             -      4,240,811


Business Expenses                          (1,914,556)               -             -     (1,914,556)


Business Profits                             2,326,255               -             -      2,326,255


Other Operating Income (Expense)
Share of Profit of Associate Entities         569,830                -             -        569,830

Profits on Disposal of Subsidiary                      -      599,282              -        599,282
Financial Income                               64,270                -             -         64,270
Financial Expenses                            (39,097)               -             -        (39,097)
Profits on Foreign Exchange, Net             (318,809)               -             -      (318,809)
Other Profits, Net                           (140,086)               -             -      (140,086)

Other Operating Income (Expense)                       -             -             -                 -



Total Other Operating Income (Expense)        136,108         599,282              -        735,390



Profit Before Income Tax                     2,462,363        599,282              -      3,061,645



Income Tax Benefit (Expense)                 (572,606)         (9,636)             -      (582,242)



Ongoing Period Profits                       1,889,757        589,646              -      2,479,403




                                                                                         Page 34 of 35
Page 36
      STATEMENT OF THE COMPANY'S BOARD OF COMMISSIONERS AND DIRECTORS

The Board of Commissioners and the Board of Directors of the Company both individually and
collectively declare that:

1.    All information or material facts related to the Transaction Series have been disclosed in this
      Information Disclosure and such information is not misleading.
2.    The Transaction Series are Material Transactions as referred to in POJK 17/2020 because the
      value of the transaction reaches 29.73% (twenty-nine point seven three percent) of the
      Company's equity based on the Company's Financial Statements as of 30 June 2023 reviewed
      by the Tanudiredja, Wibisana, Rintis & Rekan Public Accounting Firm.
3.    In particular, the SDA-ANTAM Divestment Transaction and the Battery Manufacturing JVCOs
      Investment Transaction are also Affiliated Transactions as referred to in POJK 42/2020.
4.    This Transaction Series is not a Conflict of Interest Transaction as referred to in POJK 42/2020.

                                   ADDITIONAL INFORMATION

If you need further information regarding the matters disclosed in the Information Disclosure, you can
contact the Company at the address:

                                      PT Aneka Tambang Tbk
                                       Corporate Secretary

                                 Gedung Aneka Tambang Tower A
          Jl. Letjen T.B. Simatupang No. 1, Lingkar Selatan, Tanjung Barat, Jakarta 12530
                                    Telephone: (021) 789 1234
                                    E-mail: corsec@antam.com
                                  Website: https://www.antam.com




                                                                                          Page 35 of 35

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