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20251210_OPMS_Tanggapan atas Permintaan Penjelasan Bursa_32012226_lamp2.pdf

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Page 1 OCR 0.942
OPMS

Surabaya, December 10, 2025

No 1058.CS.0PMS.2025
Subject 1 Response to Reguest for Clarification
To:

Head of Corporate Assessment Division 3
Financial Services Authority (OJK)
Jakarta

Dear Sir/Madam,

In response to letter No. S-13806/BEI.PP3/12-2025 dated December 5, 2025, regarding the
Reguest for Clarification, we hereby submit our responses as follows:

1. Regarding the plan to add a new business activity, namely large-scale trading of food and
beverages, please clarify:

a. In relation to the plan to add a new business activity, is there any plan for a change of
control?

Response:
No, the Company has no plans for any change of control.

b. WIII the Company change its business activities considering the significant revenue
decline since the period ending March 31, 2025?

Response:
The Company has obtained approval from OJK and shareholders for the addition of the
new business activity through the EGMS held on December 1, 2025.

Cc. Target timeline for recording revenue from the new business activity and addition of
experts.

Response:

The Company will add experts, and revenue from the new business activity will be
recognized in the Company's A4 2025 financial statements and reported no later than
March 31, 2026.

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OPMS

d.

Has the Company entered into agreements with consumers related to the new
business activity? If yes, please clarify whether there is any affiliation with the
Company.

Response:
The Company has no agreements with consumers related to the new business
activity and there is no affiliation between the Company and consumers.

The Company has stated that it owns a warehouse facility on Jl. Raya Suramadu,
please clarify its ownership status. If the warehouse is owned by the Company,
please explain when and from what source of funds it was acguired.

Response:

The warehouse facility is owned by the Company based on Building Use Rights
Certificate No. 1401 dated January 4, 2021. The source of funds for acguiring the
warehouse came from the Company's cash.

2. There was a significant increase in inventory as of September 30, 2025 please ciarify:

a. Nature of recognition of the newly recognized merchandise inventory in September

2025.

Response:

Inventory is recognized as an asset in the balance sheet when the Company obtains
ownership rights. Inventory is valued at the lower of cost or net realizable value. Cost
includes all expenses incurred to bring the inventory to its present condition and
location, determined using the weighted-average method.

The significant increase in merchandise inventory as of September 30, 2025 was
due to inventory purchases made to conduct market evaluation during July-
September 2025.

Source of funds used for inventory purchases.

Response:
The source of funds used for inventory purchases was the Company's cash.

Background of the significant decrease in processed scrap inventory while revenue
for the period ending September 30, 2025 also significantly declined.

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OPMS

M1 emupamutik eeemuna

Response:

The decrease was due to sales of processed iron scrap inventory, while the
Company faced supply chain disruptions and difficulties obtaining scrap metal raw
materials, resulting in reduced processed scrap inventory. This matter has also been
conveyed during the 2025 Public Expose.

3. Based on Notes to Financial Statements (CALK) 10 on fixed assets, there was a
reduction of Rp1.5 billion (3696) in factory eguipment. Please clarify:

a. Background of the reduction in factory eguipment assets.

Response:

The reduction occurred because the Company sold two crane units due to the
current unavailability of ship plate raw materials, resulting in no plate-cutting activities
reguiring heavy eguipment. Moreover, the assets, located near coastal areas, had
begun reguiring high maintenance costs.

b. Was the reduction in factory eguipment related to the addition of the new business
activity?

Response:

No, the reduction in factory eguipment is unrelated to the new business activity. It
occurred because the Company has not been able to obtain ship plate raw materials,
resulting in no cutting activities reguiring heavy eguipment, and the assets were
already incurring high maintenance costs.

Cc. Use of funds from the sale of fixed assets.
Response:
Funds from the sale of fixed assets were used to strengthen the Company's cash

position, and the proceeds were placed in deposits.

4. Regarding the right-of-use asset amounting to Rp130 million as of September 30, 2025,
please clarify:

a. Relationship between the Company and the lessor.

Response:
The relationship between the Company and the lessor is purely business-related.

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OPMS

b. Source of funds used for building rental, as this is not reflected in the cash flow
statement as of September 30, 2025.

Response:

The source of funds for building rental was the Company's cash. This information
has been reported in the Company's cash flow statement (page 5).

ARUS KAS UNTUK AKTIVITAS

CASH FLOVrS FOR

PENDANAAN PANCING ACTNTTY
Pembayaran pokok Repaymanta Of penopa
Mapitas sewa (05412782) (02517401 jagsa sariines

Cc. Detailed explanation regarding the purpose of the building rental.

Response:

The rented building is used as the Company's main office, consistent with the
Company profile listed on the Stock Exchange.

5. Regarding CALK 20 - retained earnings, please clarify the measures taken to reduce
accumulated deficits, considering the Company is still recording net losses.

Response:

One measure taken is adding 16 new business lines in the Consumer Goods sector,
which was approved by shareholders in the EGMS on December 1, 2025. This step is
expected to help improve the Company's profitability going forward.

6. Based on CALK 21 regarding net sales, please clarify:

a. Background of the significant decrease in revenue for the period ending September

30, 2025 compared to September 30, 2024, noting that the decline has occurred
since March 31, 2025.

Response:

The decline was caused by shifting economic dynamics in ship usage. Shipping
companies that previously invested in new ships now prefer to refurbish existing
ships to reduce operational costs and anticipate regulatory changes.

Other issues identified include:

 Non-uniform Regional Regulations
Some regional governments impose layered levies or permits for scrap
transportation, disrupting distribution across regions. Technical regulations on

metal waste transportation overlap with hazardous waste (B3) rules, causing
confusion among businesses.

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OPMS

" Lack of National Policies on Circular Economy for Metals
There is no national policy or incentive structure supporting the return of metal
products to the steel industry. Unlike plastic or paper, metals are not yet a focus
Of circular economy regulations.

Despite these challenges, the Company remains optimistic that the ship-plate
cutting business will recover, although more effort is needed to secure stable
sources of plate raw materials.

b. Explanation of affiliation between the Company and PT Tritama Jaya Bersama and
Mr. Mochmad Saddam.

Response:
There is no affiliation between the Company and PT Tritama Jaya Bersama or Mr.
Mochmad Saddam.

C. Information regarding long-term contracts with customers and measures to ensure
sustainable revenue from the scrap metal sales segment.

Response:

The Company currently has no long-term contracts with customers. Moving forward,
the Company will focus more on the new Fast Moving Consumer Goods (FMCG)
business lines rather than scrap metal sales. However, the Company will still
optimize its supply chain to secure a stable scrap metal supply to support revenue
from that segment.

d. Strategies undertaken to increase future revenue.

Response:

One measure taken to increase revenue is adding 16 new FMCG business lines.
This expansion enables the Company to pursue partnerships with new principals.
With a distribution network focused on Madura and East Java, the Company has
opportunities to strengthen regional food supply chains.

7. Regarding the cash flow statement, please clarify:
a. In operating cash flows for 2025, there is a sub-account “receipts from (payments to)

others" amounting to Rp5 billion, which increased significantly. Please clarify the
nature and details of this sub-account.

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OPMS

MOnammmanuttu kanan

Response:

The amount represents a refund of a down payment for a used ship auction, as the
Company did not win the auction.

b. Background on the cash proceeds from the sale of fixed assets amounting to Rp315
million, given the fixed asset reduction of Rp1.5 billion.

Response:

Acguisition cost of the assets sold: Rp1,503,000,000, Accumulated depreciation:
Rp1,069,427,083, Net book value: Rp433,572,917. The Company sold the assets
below book value at Rp315,315,315, as reflected in the cash flow statement.

Thus, we hereby convey this information. Thank you.

Rubbyanto Handaja Kusuma

Director

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File

File Open PDF
Source IDX
Size1.78 MB
Published10 Dec 2025
Pages6
Characters9,099
Text sourceOCR
OCR confidence0.928

Names mentioned 4 people and organisations named in the text · linked when the evidence is strong

unresolved org Financial Services Authority p.1
unresolved org PT Tritama Jaya Bersama p.5 ×2
unresolved person Mochmad Saddam. Response p.5
unresolved person Mochmad Saddam. C. Information p.5

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