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Asset transaction Needs review MAPA

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Page 1
              DISCLOSURE OF INFORMATION TO SHAREHOLDERS OF
                           PT MAP AKTIF ADIPERKASA TBK
                          (“DISCLOSURE OF INFORMATION”)
  In compliance with the Financial Services Authority Regulation No. 42/POJK.04/2020
    concerning Affiliate Transaction and Transaction with Conflict of Interest (“POJK
                                       42/2020”).



THE INFORMATION AS CONTAINED IN THIS DISCLOSURE OF INFORMATION IS OF UTMOST
       IMPORTANCE AND THEREFORE, MUST BE READ AND CONSIDERED BY THE
                             SHAREHOLDERS OF
                PT MAP AKTIF ADIPERKASA TBK (the “Company”)




                                  Main Business Activities:
                                 Engaged in general trading,
         including retail trade, and act as an agent or distributor for other parties

                          Domiciled in Central Jakarta, Indonesia

                                         Head Office:
                               Sahid Sudirman Center, Lt. 26
                                 Jl. Jend. Sudirman Kav. 86
                                 Jakarta 10220, Indonesia
                                 Phone: +62 21 8064 8488
                                Website: www.mapactive.id
                               Email: corpsec@mapactive.id

THE BOARD OF DIRECTORS AND BOARD OF COMMISSIONERS OF THE COMPANY, EITHER
INDIVIDUALLY OR JOINTLY, ARE RESPONSIBLE FOR THE ACCURACY AND COMPLETENESS
OF THE INFORMATION AND AFTER CAREFUL EXAMINATION, AFFIRM THAT THE
INFORMATION CONTAINED IN THE DISCLOSURE OF INFORMATION IS CORRECT AND
THERE IS NO IMPORTANT MATERIAL AND RELEVANT MATERIALS THAT IS NOT
DISCLOSED OR OMITED IN THE DISCLOSURE OF INFORMATION SO THAT THE
INFORMATION PROVIDED IN THE DISCLOSURE OF INFORMATION BECOMES INCORRECT
AND/OR MISLEADING.


                  This Disclosure of Information is published in Jakarta
                                      on 3 July 2023
Page 2
                                     I.     PRELIMINARY

On 26 June 2023, the Company and PT Mitra Adiperkasa Tbk., domiciled in Central Jakarta
(hereinafter referred to as “MAPI”) has executed the Amendment and Restatement of
Management Service Agreement.

The Company is a Controlled Company of MAPI whereby MAPI owns 68.843% shares in the
Company.

In accordance with the prevailing regulations, specifically provision of Article 4 POJK 42/2021,
the Board of Director of the Company hereby announce this Disclosure of Information for the
purpose to provide elaboration, consideration, and reasons for the conduct of the Transaction
(as defined below) to the Shareholders of the Company in compliance with POJK 42/2021
specifically the provisions in Article 4.


                            II. DESCRIPTION OF THE TRANSACTION

A. Transaction, Object and Transaction Value
   a. Name and Date of the Transaction: The delivery of management service as stipulated
      under the Amendment and Restatement of Management Service Agreement dated 26
      June 2023.

   b. Object of Transaction: Amendment to the Management Service Agreement relating to
      the delivery of services by MAPI to the Company in the daily administration and
      operational activities of the Company that is in the area of information and technology,
      corporate, finance and accounting, human resources, corporate secretary, legal
      administration, supply chain, general affair and licensing, sustainability, advertising and
      promotion, corporate treasury, corporate communication, procurement, academy,
      internal audit and compliance (hereinafter the “Transaction”)

   c. The Transaction value for year 2023 is estimated at Rp.115,200,000,000 (One Hundred
      Fifteen Billion Two Hundred Million Rupiah) per year, excluding VAT. The value of the
      annual service fee for the subsequent years shall be calculated based on the actual total
      costs (such amount shall be rounded up) relating to the delivery of the services to be
      provided by MAPI in the relevant year. The total costs of the services shall be calculated
      based on basis calculation relevant for each of the services (among others time spent to
      provide the service, number of employees, processed licenses, etc). The calculation shall
      be performed on 31 August of preceding year or at any other time as mutually agreed
      between the parties. The value of the services in the current year may be increased, as
      mutually agreed between the Company and MAPI by taking into consideration the
      expansion and development of the Company’s businesses.

   d. Term: 1 July 2023 until 31 December 2023, and shall be automatically extended for
      successive periods of one (1) year, unless earlier terminated by either party.
Page 3
B. Information Regarding the Parties Conducting Transactions
   1. PT Map Aktif Adiperkasa Tbk.
       a.      Brief History
       The Company is domiciled in Central Jakarta, it was incorporated based on Deed of
       Establishment No. 40 dated 11 March 2015, made before Hannywati Gunawan, SH,
       Notary in Jakarta. The Deed of Establishment of the Company has been ratified by
       Minister of Laws and Human Rights of the Republic of Indonesia based on Decree No.
       AHU‐0011719.AH.01.01. TAHUN 2015 dated 13 March 2015.

       The Articles of Association of the Company has been amended from time to time latest
       as stipulated in the Deed of Restatement of GMS’ Resolution No. 108, dated 18 August
       2021 made before Hannywati Gunawan, S.H., Notary in Jakarta. Such deed has been
       published in the State Gazette of the Republic of Indonesia dated 19 November 2021
       No.93, Supplement No. 36227.

       b.    Purposes, Objectives and Business Activities
             Based on Article 3 of the Company's Articles of Association, the purposes and
             objectives of the Company are to do business in the fields of:
             a. Wholesale and retail trade;
             b. Transportation and warehousing; and
             c. Professional, scientific and technical activities.

             To achieve the above purposes and objectives, the Company may carry out the
             following business activities:

             Main Business Activities

              a. Running a business in the field of wholesale trade, excluding cars and
                 motorcycles as well as retail trade, excluding cars and motorcycles;
              b. Act as agents, suppliers, franchisees and/or distributors of other agencies
                 and companies, both from within and from abroad.

             Supporting Business Activities

              a. To conduct importing and exporting, across islands/regions as well as
                 locally, for any goods that can be traded, either for own calculations, or for
                 calculations of other people, or legal entities on the basis of commission;
              b. To conduct business in the textile (factory) industry for any material that
                 can be produced in the country, including apparel, shoes and handicrafts;
              c. To conduct business in the transportation sector using motorized vehicles,
                 either to transport passengers and to transport goods;
              d. Carry out accounting activities and management consulting activities, in the
                 field of providing services and consulting in general, including management
                 consulting services, production, accounting methods and procedures as well
                 as human resource development (except for travel services and consultants
                 in the fields of law and taxation).

       C.    Capital Structure and Share Ownership
             As at the date of this Disclosure of Information, capital structure and
             shareholders    composition   of    the   Company     is    based    on
Page 4
             Company’s Shareholders Register as per 31 May 2023 issued by PT Datindo
             Entrycom, as Securities Administration Bureau of the Company, that is as follow:

                                                               Nominal amount
                                              Number of
                   Description                                     @Rp100              (%)
                                               Shares
                                                                     (Rp)

        Authorised Capital                   5,000,000,000        500,000,000,000

        Issued and Paid Up Capital:

        PT Mitra Adiperkasa Tbk.              1,962,299,080         196,229,908,000    68.843

        Public                                 888,100,920           88,810,092,000    31.157

        Total Issued and Paid Up Capital      2,850,400,000         285,040,000,000    100.00



      d.     Management and Supervisory

             On the date of the Disclosure of Information, the composition of the Board of
             Directors and Board of Commissioners of the Company are as follow:

             Board of Directors

             President Director       : Nicholas Jones
             Director                 : Handaka Santosa
             Director                 : Sjeniwati Gusman
             Director                 : Miquel Rodrigo Staal

             Board of Commissioners

             President Commissioner      : Virendra Prakash Sharma
             Vice President Commissioner : Susiana Latif
             Independent Commissioner    : Hendry Hasiholan Batubara

      e.         Address
                 The Company is having its address at Sahid Sudirman Center, 26th Floor, Jl.
                 Jenderal Sudirman Kav. 86, Jakarta Pusat, Jakarta 10220.

2. PT Mitra Adiperkasa Tbk.

 a. Brief history
    MAPI was incorporated based on Deed of Establishment No.105 dated 23 January 1995
    made before Julia Mensana, SH, Notary in Jakarta. The Deed of Establishment of MAPI
    has been ratified by Minister of Justice of the Republic of Indonesia based on Decree No.
    C2-9243.HT.01.01.TH.95. dated 31 July 1995.

     The Articles of Association of MAPI has been amended from time to time latest as stipu-
     lated in the Deed of Restatement of GMS’ Resolution No.114 dated 19 August 2021 made
     before Hannywati Gunawan, SH, Notary in Jakarta. Such deed has been published in the
Page 5
     State Gazette of the Republic of Indonesia dated 19 November 2021 No.93, Supplement
     No. 36228.

b. Purposes, Objectives and Business Activities
   Based on Article 3 of MAPI’ Articles of Association, the purposes and objectives of MAPI
   are to do business in the fields of:
   a. Wholesale and retail trade
   b. Transportation and warehousing; and
   c. Professional, scientific and technical activities; and
   d. Education

     To achieve the above purposes and objectives, MAPI may carry out the following
     business activities:

     Main Business Activities
     a. Running a business in the field of wholesale trade, excluding cars and motorcycles as
        well as retail trade, excluding cars and motorcycles;
     b. Act as agents, suppliers, franchisees and/or distributors of other agencies and com-
        panies, both from within and from abroad.

     Supporting Business Activities:

     a. To conduct importing and exporting, across islands/regions as well as locally, for any
        goods that can be traded, either for own calculations, or for calculations of other peo-
        ple, or legal entities on the basis of commission;
     b. To conduct business in the textile (factory) industry for any material that can be pro-
        duced in the country, including apparel, shoes and handicrafts;
     c. To conduct business in the transportation sector using motorized vehicles, either to
        transport passengers and to transport goods;
     d. Carry out accounting activities and management consulting activities, in the field of
        providing services and consulting in general, including management consulting ser-
        vices, production, accounting methods and procedures as well as human resource de-
        velopment (except for travel services and consultants in the fields of law and taxa-
        tion).
     e. to conduct education activities.

c.     Capital Structure and Share Ownership
       As at the date of this Disclosure of Information, capital structure and shareholders
       composition of the Company is based on MAPI’s Shareholders Register as per 31 May
       2023 issued by PT Datindo Entrycom, as Securities Administration Bureau of the MAPI,
       that is as follows:

                                                                     Nominal amount
                                                 Number of
                    Description                                          @Rp100             (%)
                                                  Shares
                                                                           (Rp)
         Authorised Capital                    40.000.000.000       2.000.000.000.000,00

         Issued and Paid Up Capital:
         1. PT Satya Mulia Gema Gemilang         8.466.000.000         423.300.000.000,00     51
         2. Public                               8.134.000.000         406.700.000.000,00     49
         Total Issued and Paid Up Capital       16.600.000.000         830.000.000.000,00    100
Page 6
       d.     Management and Supervisory

              On the date of the Disclosure of Information, the composition of the Board of
              Directors and Board of Commissioners of MAPI are as follow:

              Board of Director
              Presiden Director                    : Herman Bernhard Leopold Mantiri
              Vice President Director              : Virendra Prakash Sharma
              Director                             : Susiana Latif
              Director                             : Sean Gustav Standish Hughes
              Director                             : Handaka Santosa
              Director                             : Sjeniwati Gusman

              Board of Commissioners
              President Commissioner (independent)      : Sri Indrastuti Hadiputranto
              Vice President Commissioner (independent) : GBPH Prabukusumo, S.Psi.
              Commissioner                              : Johanes Ridwan

       e. Address
          MAPI is having its address at Sahid Sudirman Center, 29th Floor, Jl. Jenderal
          Sudirman Kav. 86, Jakarta Pusat, Jakarta 10220.

C. Affiliate Relationship
   a. The Company is a Controlled Company of MAPI whereby MAPI owns 68.843% shares
       in the Company.
   b. Several Directors of the Company also hold a position as Director of MAPI.

                          III.   SUMMARY OF APPRAISAL’ REPORT


A. Independent Party Appointed relating to the Transaction
The Company has appointed a Public Appraisal Service Office (KJPP) Kusnanto & rekan (“KR”)
as official Public Appraisal Service Office based on the Decree of the Minister of Finance No.
2.19.0162 dated 15th July 2019 and registered as a capital market supporting professional
service office at the Financial Services Authority (hereinafter referred to as “OJK”) with a
Capital Market Supporting Professional Registration Certificate from OJK No. No. STTD.PB-
01/PJ-1/PM.223/2023 (business appraiser), to provide a fairness opinion over the
Transaction based on assignment letter KR/230512-001 dated 12 May 2023 which has been
approved by the management of the Company.

B. Opinion of Independent Appraisal

   Summary of Fairness Opinion Report
   Summary of Fairness Opinion Report No. 00076/2.0162-00/BS/02/0153/1/VI/2023
   dated 26 June 2023 composed by KR is as follow:

       •    Parties involved in the Transaction
            Parties involved in the Transaction is Company and MAPI.

       •    Fairness Opinion Object
            The object of the transaction in the Fairness Opinion over the Transaction is a
            transaction whereas the Company intends to amend Management Service
Page 7
    Agreement and Term Sheet by making amendments as stipulated in the
    Amendment and Restatement of Management Service Agreement.

•   Purpose and Objective of the Fairness Opinion
    The purpose and objective of the fairness opinion of the Transaction is to provide
    an illustration regarding the fairness of the Transaction to comply with POJK
    42/2021.

•   Main Assumptions and Limiting Conditions
    Analysis of Fairness Opinion over Transaction is prepared using the data and
    information as mentioned above, such data and information has been reviewed by
    KR. When analyzing the Transaction, KR has relied upon the accuracy, reliability,
    and completeness of all financial information, information regarding the legal
    status of the Company and other information provided by the Company or which is
    publicly available and KR shall not be liable as to the correctness of such
    information. All changes to the data and information shall affect the final result of
    KR opinion materially. KR has also relied upon the Company management’s
    representations that they have not known any facts which resulting the
    information provided to KR becoming incomplete or misleading. Therefore, KR
    shall not be responsible for the changes in the conclusion of KR Fairness Opinion
    due to such data and information changes.

    Projection to the consolidated financial statement of the Company before and after
    the Transaction has been composed by the management of the Company. KR has
    reviewed the projection to the consolidated financial statement and such
    projection to the consolidated financial statement has reflected the condition of
    operation and performance of the Company. In general, no significant adjustment
    shall be made by KR over the performance target of the Company.

    KR did not inspect the fixed assets or facility of the Company. In addition, KR also
    did not opine on the tax impact of the Transaction. The service provided by KR to
    the Company relating to the Transaction is just to provide the Fairness Opinion
    over the Transaction but not to provide the accounting, audit or taxation services.
    KR did not examine the validity of the Transaction from legal and tax impact
    perspectives. The Fairness Opinion over the Transaction was only be reviewed
    from the economic and financial point of view. Report on the Fairness Opinion of
    the Transaction is a non-disclaimer opinion and is a publicly available opinion
    except if it contains a confidential information, which may affect the operation of
    the Company. Further, KR has obtained information on the legal status of the
    Company based on the Articles of Association of the Company.

    KR works which are related to the Transaction shall not constitute and cannot be
    interpreted as constituting in any way, as a review or audit, or implementation of
    certain procedures over financial information. Such works shall not be intended to
    expose the weak point of the internal control, mistake or deviation in the financial
    statement, or legal violation. In addition, KR is not authorised and was not in the
    position to obtain and analyse other existing/might existed transactions except for
    the Transaction, as well as the impact of such transactions toward the Transaction.
Page 8
    This Fairness Opinion was made based on market and economic condition, general
    business and financial condition, as well as Government regulations relevant to the
    Transaction as of the date of the issuance of this Fairness Opinion.

    In preparing the Fairness Opinion, KR used few assumptions, such as the
    fulfillment of all conditions and obligations of the Company and all parties involved
    in the Transaction. The Transaction will be conducted as explained based on the
    term and accuracy of information regarding the Transaction as disclosed by the
    management of the Company.

    This Fairness Opinion shall be viewed in a whole and the partial utilization of the
    analysis and information without considering other information and analysis in a
    whole as a unity might cause misleading view and conclusion over the underlying
    process of the Fairness Opinion. The preparation of this Fairness Opinion is a
    complicated process and might not be done without a complete analysis.

    KR also assume that from the date of the issuance of Fairness Opinion until the date
    of the Transaction no change has been occurred which may materially affect the
    assumptions used in the preparation of this Fairness Opinion. KR shall not be
    responsible to asserts or complete, update our opinion due to changes to the
    assumption and condition, and circumstances occurring after the date of this
    report. The calculation and analysis in order to provide the Fairness Opinion has
    been done correctly and KR is responsible for the Fairness Opinion Report.

    The conclusion of this Fairness Opinion shall be valid to the extent no change which
    materially impact the Transaction. Such changes include, but not limited to, change
    to the internal and external condition of the Company, that is market and economy
    condition, general business condition, trade and finance, regulations in Indonesia
    and other relevant regulations after the issuance date of this Fairness Opinion
    Report. If after the issuance date of this Fairness Opinion Report there has
    occurred the abovementioned changes, thus this Fairness Opinion over the
    Transaction might differ.

    The analysis of Fairness Opinion over the Transaction is done in an uncertain
    condition, including but not limited to, a high level of uncertainty due to Covid-19
    pandemic. The prudential principle shall be required in the utilization of this
    Fairness Opinion Report specifically relating to the change occurring from the date
    of the appraisal until the date of the utilization of Fairness Opinion Report. Change
    of assumption and condition as well as circumstances occurring after the date of
    this report will materially affect the conclusion of the Fairness Opinion.

•   Methodology and Procedure of Fairness Opinion
    In the evaluation of this Fairness Opinion over the Transaction, KR has conducted
    the analysis using the methodology and procedure of Fairness Opinion over
    Transaction based on:
    I. Analysis of Transaction;
    II. Qualitative and Quantitative Analysis of Transaction; and
    III. Analysis on Fairness of the Transaction.
Page 9
     •    Fairness Opinion Conclusion
           Based on scope of the works, assumptions, data, and information obtained from the
           management of the Company which are used in the preparation of this report, review
           over financial impact of the Transaction as disclosed in the Fairness Opinion report,
           KR is of the opinion that the Transaction is fair.

     IV. EXPLANATION, CONSIDERATION, AND REASONS FOR THE TRANSACTION PLAN
            COMPARED TO THE IMPLEMENTATION OF OTHER TYPES OF TRANSACTIONS
            WITH NON-AFFILIATED PARTY

     A.   Purpose of the Transaction

          The purpose and benefit for the Company from the implementation of the Transaction
          are among others the administration and operation activities of the Company can be
          done well, based on standard quality as determined to be implemented by the
          companies within MAPI business group. In addition, the benefit of the Transaction is
          the creation of synergy in the implementation of policies related to the performance of
          administration and operation activities, between the Company and MAPI as parent
          company.

B.        Consideration for the Transaction with Affiliated Party
          The consideration of Transaction conducted with affiliated party in comparison with
          non-affiliated party are:
          1. Creation of synergy in the implementation of policies related to the performance of
             administration and operation activities, between the Company and MAPI as parent
             company.
          2. To limit the disclosure of Company’s confidential information and data to third
             party.

                           V. STATEMENT OF BOARD OF DIRECTORS

This Transaction has gone through an adequate procedure to ensure that the Transaction is
conducted based on generally accepted business practice by taking into account arms-length
principle.

           VI. STATEMENT OF BOARD OF DIRECTORS AND BOARD OF COMMISSIONERS
This affiliated transaction:
1. does not constitute a conflict-of-interest transaction; and
2. all material information has been disclosed and such information is not misleading.

                                VII. ADDITIONAL INFORMATION
Shareholders of the Company who require further information regarding the Transaction as
disclosed in this Disclosure of Information, may contact:
                                    PT Map Aktif Adiperkasa Tbk.
                                          Corporate Secretary
                                     Sahid Sudirman Center, Lt. 26
                                       Jl. Jend. Sudirman Kav. 86
                                       Jakarta 10220, Indonesia
                                       Phone: +62 21 8064 8488
                                      Website: www.mapactive.id
                                     Email: corpsec@mapactive.id

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