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Asset transaction Needs review AADI

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     INFORMATION DISCLOSURE TO THE SHAREHOLDERS ON AN
              AFFILIATED-PARTY TRANSACTION OF
       PT ADARO ANDALAN INDONESIA TBK (“THE COMPANY”)
This information disclosure to the shareholders on the affiliated-party transaction (hereinafter referred
to as “Information Disclosure”) was prepared to inform the Company’s shareholders on the signing
of amendment IV to the Loan Agreement between the Company and PT Pari Coal (“PC”), a limited-
liability company on which the Company has direct and indirect control.

This transaction fulfills the definition of affiliated-party transaction as set forth in Indonesian Financial
Services Authority’s Regulation number 42/POJK.04/2020 on Affiliated-Party Transactions and Conflict
of Interest Transactions (“POJK 42/2020”).

  THE COMPANY’S BOARD OF DIRECTORS AND BOARD OF COMMISSIONERS, EITHER
  SEVERALLY OR JOINTLY, ARE FULLY RESPONSIBLE FOR THE ACCURACY OF THE
  INFORMATION DISCLOSURE AND THE AMENDMENT AND/OR ADDITION TO THE
  INFORMATION DISCLOSURE, IF ANY.

  THE COMPANY’S BOARD OF DIRECTORS AND BOARD OF COMMISSIONERS HEREBY
  DECLARE THAT THE INFORMATION AS DISCLOSED IN THIS INFORMATION DISCLOSURE
  IS COMPLETE, AND AFTER A DUE AND CAREFUL EXAMINATION, EMPHASIZE THAT THE
  INFORMATION STATED IN THIS INFORMATION DISCLOSURE IS TRUE, AND THAT THERE
  ARE NO RELEVANT AND MATERIAL FACTS OMITTED OR ELIMINATED IN SUCH A WAY
  THAT CAUSE THE INFORMATION PROVIDED HEREIN TO BE UNTRUE AND/OR
  MISLEADING.

  THE COMPANY’S BOARD OF DIRECTORS AND BOARD OF COMMISSIONERS DECLARE
  THAT THIS AFFILIATED-PARTY TRANSACTION DOES NOT CONTAIN ANY CONFLICT OF
  INTEREST.




                                  PT Adaro Andalan Indonesia Tbk

                                       Business activities:
  Holding-company activities (for subsidiaries operating in coal mining, mining services, management
        consultancy, water resources management, power generation, and specialized freight
 transportation), other management consultancy activities, in addition to operating in the sectors of oil
                palm plantation, and rubber and other latex-producing crops plantation.


                                             Head office:
                                      Cyber 2 Tower Lantai 26
                               Jl. H.R. Rasuna Said Blok X-5, No.13
                                      Jakarta 12950 – Indonesia
                                 Email: corsec@adaroindonesia.com
                                   Website: www.adaroindonesia.com

                        This information is issued in Jakarta on July 2nd, 2025.


                                                   1
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                                          DEFINITION


Affiliation:                    defined as set forth by article 1 of Law number 8 of 1995 on the
                                Capital Market as amended by Law number 4 of 2023 on the
                                Development and Strengthening of the Financial Sector or POJK
                                42/2020.

Amendment IV to the Loan        defined as explained in the Introduction section of this
Agreement:                      Information Disclosure.

US$:                            United States dollar.

Director(s):                    (a) member(s) of the Company’s Board of Directors holding such
                                position on the issuance date of this Information Disclosure.

Commissioner(s):                (a) member(s) of the Company’s Board of Commissioners
                                holding such position on the issuance date of this Information
                                Disclosure.

Appraiser’s Report:             defined as explained in the Introduction section of this
                                Information Disclosure.

Independent Appraiser:          the Office of Public Appraisal Services of Desmar, Susanto,
                                Salman dan Rekan (DSS Partners), an independent appraiser
                                registered with the FSA, which has been appointed by the
                                Company to appraise the fair value and/or fairness of the
                                transaction as explained in this Information Disclosure.

Loan Agreement:                 defined as explained in the Introduction section of this
                                Information Disclosure.

Company:                        PT Adaro Andalan Indonesia Tbk, a publicly-listed company duly
                                established and organized under the law of the Republic of
                                Indonesia and domiciled in Jakarta, Indonesia.

Controlled Company:             as defined by POJK 42/2020.

SOFR:                           Secured Overnight Financing Rate.

Affiliated-Party Transaction:   as defined by POJK 42/2020.

POJK 42/2020:                   FSA’s Regulation number 42/POJK.04/2020 on Affiliated-Party
                                Transactions and Conflict of Interest Transactions.




                                               2
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I.    INTRODUCTION

      On July 18th, 2018, the Company and PC executed an Affiliated-Party Transaction by signing the
      Loan Agreement as amended with Amendment I to the Loan Agreement on March 17th, 2019,
      Amendment II to the Loan Agreement on August 25th, 2023, and Amendment III to the Loan
      Agreement on December 18th, 2024 (“Loan Agreement”).

      Subsequently, the Company and PC agreed to amend a number of terms of the Loan Agreement
      that has been effective as of June 30th, 2025, among others concerning (i) the increase of the
      loan amount up to US$26,000,000 (twenty-six million United States dollars) and (ii) the reduction
      in the interest rate on the loan to Term SOFR + 1.90% per annum, which stated and addressed
      in the amendment IV to the Loan Agreement (“Amendment IV to the Loan Agreement”).

      Pursuant to article 4 point 1 of POJK 42/2020, the execution of the Affiliated-Party Transaction
      must use an appraiser service to determine the fair value of the object of the Affiliated-Transaction
      and/or the fairness of the transaction, and needs to be published to the public. In order to fulfill
      the provision of POJK 42/2020, the Company’s Board of Directors issued this Information
      Disclosure to convey information to the Company’s shareholders on such Affiliated-Party
      Transaction.

      The Appraiser’s Report used a reference is the report of the Office of Public Appraisal Services of
      Desmar, Susanto, Salman dan Rekan number 00043/2.0142-00/BS/02/0177/1/VI/2025 of June
      25th, 2025 on the Fairness Opinion on the transaction of Amendment IV to the Loan Agreement
      (“Appraiser’s Report”). The Appraiser’s Report gives a fair opinion on the transaction of
      Amendment IV to the Loan Agreement.

      This Affiliated-Party Transaction has been through the procedure as set forth in article 3 of POJK
      42/2020 and executed in accordance with the generally applicable business practices.

      This Affiliated-Party Transaction is neither a conflict-of-interest transaction as stipulated in POJK
      42/2020 nor a material transaction as stipulated in the Indonesian Financial Services Authority
      Regulation number 17/POJK.04/2020 on Material Transactions and Changes to Business Activities
      (“POJK 17/2020”) because the total value of this transaction is less than 20% (twenty percent) of
      the Company’s total equity value as stated in the Company’s Financial Statements of December
      31, 2024 audited by Public Accounting Firm Rintis, Jumadi, Rianto & Rekan, which amounts to
      US$3,363,482 (in thousand of United States dollars).

II.   BRIEF DESCRIPTION ON THE TRANSACTION AND THE EFFECT OF THE TRANSACTION TO
      THE COMPANY’S FINANCIAL CONDITION

      A. DESCRIPTION OF THE TRANSACTION

         i. Rationale, Background, and Benefits of the Transaction

            The background and rationale of the transaction of Amendment IV to the Loan Agreement
            are the transaction shall serve as one of the Company’s strategies to capture the investment
            opportunity for developing its business. The Company strives to maximize its financial
            potential and extensive network to capitalize on sound investment opportunities that will
            generate healthy returns for the shareholders. The Company has conducted a review on its
            own risk profile and its tolerance level against the fluctuations of the investment to be made.
            The Company always ensures to conduct risk review and good investment diversification, in
            addition to monitoring and balancing the investment portfolio. This transaction will provide
            stronger support to PC’s business development. Therefore, the Company expects this
            transaction to bring positive values to both parties, support the Company’s business
            development objectives, and maximize rate of return more effectively and efficiently.

                                                    3
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ii. Brief Description on the Transaction

   The Company and PC signed the Amendment IV to the Loan Agreement effective as of June
   30th, 2025, with the following details:

                  Remarks              Before Amendment IV           Amendment IV to the
                                            to the Loan               Loan Agreement
                                            Agreement
           Loan amount                 US$20,000.000                Up to US$26,000,000
           Interest rate               SOFR + 2.40% per             SOFR + 1.90% per
                                       annum                        annum

iii. Parties to the Transaction

   1. The Company

      Brief history

      The Company was established based on a notarial deed of December 1st, 2004 made
      before Ir. Rusli, S.H., a Notary in Bekasi. The deed was approved by the Minister of Law
      and Human Rights of the Republic of Indonesia by Decree number C-31123
      HT01.01.TH.2004 of December 23rd, 2004. The deed was announced in the State
      Gazette of the Republic of Indonesia number 52 of July 1st, 2005 and the Supplement to
      State Gazette number 6922. The Company’s articles of association have been amended
      several times. By the amendment to the Company’s articles of association based on the
      Notarial Deed number 100 made before Humberg Lie, S.H., S.E., M.Kn., a Notary in North
      Jakarta, of July 31st, 2024, the Company’s name has been changed from PT Alam Tri
      Abadi to PT Adaro Andalan Indonesia. Such amendment to the articles of association has
      been approved by the Minister of Law of the Republic of Indonesia by the decree number
      AHU-0046973.AH.01.02.TAHUN 2024 of July 31st, 2024.

      Based on Notarial Deed number 1 of September 3rd, 2024 made before Humberg Lie,
      S.H., S.E., M.Kn., Notary in North Jakarta, which was approved by the Minister of Law
      and Human Rights with Decree number AHU0055647.AH.01.02.TAHUN 2024 of
      September 3rd, 2024, and notified to the Minister of Law and Human Rights as confirmed
      with the Receipt of Notification on the Amendment to the Articles of Association number
      AHU-AH.01.03-0188887 of September 3rd, 2024, there was an amendment to the
      Company's articles of association concerning the change of the Company's status from
      a private company to a public company. Therefore, the Company's name was changed
      from PT Adaro Andalan Indonesia to PT Adaro Andalan Indonesia Tbk, effectively as of
      the effective date of the Registration Statement of the Financial Services Authority and
      the implementation of the public offering as required by the provision of article 25 point
      (1) b of Law number 40 of 2007 on Limited-liability Company as amended with the
      Government Regulation in lieu of Law no. 2 of 2022 on Job Creation as enacted into a
      law based on Law no. 6 of 2023 on the Enactment of Government Regulation in lieu of
      Law of the Republic of Indonesia No. 2 of 2022 concerning Job Creation into Law to issue
      the Company's new shares of maximum 778,689,200 shares through an initial share
      offering to the public, the implementation of stock split and the change of the composition
      of the Company' Board of Commissioners and Board of Directors.

      The latest amendment of the Company’s articles of association is based on the Deed of
      the Statement of Shareholders’ Resolutions number 14 of May 8th, 2025 made before
      Humberg Lie, S.H., S.E., M.Kn., a Notary in North Jakarta. The notification on the
      amendment to the articles of association has been received by the Minister of Law of the
      Republic of Indonesia as confirmed with the Receipt of the Notification on the Amendment
                                        4
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  to the Company’s Articles of Association number AHU-AH.01.03-0126591 of May 8th,
  2025.

  The Company’s business activities are holding-company activities (for subsidiaries
  operating in coal mining, mining services, management consultancy, water resources
  management, power generation, and specialized freight transportation), other
  management consultancy activities, in addition to operating in the sectors of oil palm
  plantation, and rubber and other latex-producing crops plantation.

  Management and supervision

  The compositions of the Company’s Board of Directors and Board of Commissioners on
  the date of this Information Disclosure are as stated in Deed number 1 of September 3rd,
  2024 made before Humberg Lie, S.H., S.E., M.Kn., a notary in North Jakarta, which has
  been notified to the Minister of Law and Human Rights of the Republic of Indonesia as
  follows:

  Board of Commissioners

  President Commissioner:          Budi Bowoleksono
  Commissioner:                    Primus Dorimulu

  Board of Directors

  President Director:              Julius Aslan
  Director:                        Priyadi
  Director:                        Lie Luckman
  Director:                        Susanti

2. PC

  Brief history

  PC is the Company’s Controlled Company. PC was established based on the Deed
  number 1 of December 1st, 1998 made before Sutjipto, S.H., Notary in Jakarta. The deed
  of establishment was approved by the Minister of Justice of the Republic of Indonesia by
  Decree number C2-27874 HT.01.01.Th.98 of December 14th, 1998. PC’s articles of
  association have been amended several times with the latest amendment based on the
  Deed number 27 of October 11th, 2024 made before Humberg Lie, S.H., S.E., M.Kn.,
  Notary in North Jakarta, concerning the amendment on the Board of Directors’ meetings.
  The amendment to the articles of association has been approved by the Minister of Law
  and Human Rights of the Republic of Indonesia by the Decree number AHU-AH.01.03-
  0201335 of October 15th, 2024.

  PC conducts business activities in the coal mining sector.

  Management and supervision

  The compositions of the Company’s Board of Directors and Board of Commissioners as
  stated in the Deed number 47 of April 22nd, 2024 made before Humberg Lie, S.H., S.E.,
  M.Kn., a notary in North Jakarta, are as follows:

  Board of Commissioners

  President Commissioner:          Budi Santoso Simin
  Commissioner:                    Hendri Tamrin
                                    5
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        Commissioner:                     Heri Gunawan

        Board of Directors

        President Director:               A.H. Bramantya Putra
        Director:                         R. Giri M. Natakusumah
        Director:                         Esther Suzanna Pakpahan


B. NATURE OF THE AFFILIATION OF THE PARTIES CONDUCTING THE TRANSACTION
   WITH THE COMPANY

  There is an affiliated-party relationship as stipulated by POJK 42/2020 between the Company
  and PC, which is under the direct and indirect control of the Company.


C. EFFECTS OF THE TRANSACTION ON THE COMPANY’S FINANCIAL CONDITION (PRO
   FORMA)

                                                                             thousand US$
       Balance Sheet          Audited December          Transaction       Pro forma December
                                  31st, 2024                                    31st, 2024
   Current assets                        2,214,052                    -                2,214,052
   Non current assets                    3,778,606                    -                3,778,606
   Total assets                          5,992,658                    -                5,992,658
   Short-term liabilities                  872,699                    -                  872,699
   Long-term liabilities                 1,756,477                    -                1,756,477
   Total liabilities                     2,629,176                    -                2,629,176
   Equity                                3,363,482                    -                3,363,482
   Total liabilities and                 5,992,658                    -                5,992,658
   equity

                                                                            thousand US$
       Profit & Loss               Audited              Transaction           Pro forma
                              December 31st, 2024                         December 31st, 2024
   Revenue                              5,319,582                     -              5,319,582
   Cost of revenue                    (3,853,631)                     -            (3,853,631)
   Gross profit                         1,465,951                     -              1,465,951
   Operating income                     1,481,217                     -              1,481,217
   Net income                           1,326,736                     -              1,326,736


D. EXPLANATION, CONSIDERATION AND RATIONALE FOR EXECUTING THE
   TRANSACTION IN COMPARISON WITH THE CONDITION IF A SIMILAR TRANSACTION IS
   EXECUTED WITH A NON-AFFILIATED PARTY

  The Company executed this transaction with PC because it viewed that this step will provide
  for PC’s financing needs efficiently. The Company has acquired thorough understanding on
  PC’s financial condition and operational requirements, so that the loan can be used properly
  and according to the objective. Should this transaction be made with an unaffiliated party, the
  Company must exercise stricter selection process and risk assessment.

  By providing loans to subsidiaries, the Company can maintain transparency, manage credit
  risk better, and support business growth of the group in a measurable and integrated manner.

                                           6
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       The documents associated with the transaction of Amendment IV to the Loan Agreement have
       been prepared to incorporate the same terms and conditions as those incorporated in
       transactions made with an unaffiliated party, thus the terms and conditions of the Affiliated-Party
       Transaction have been made on an arm’s length basis.

III.   SUMMARY OF THE APPRAISER’S REPORT

       Pursuant to article 4 of POJK 42/2020, publicly-listed companies intending to execute an
       Affiliated-Party Transaction must use an appraiser’s service to determine the fair value of the
       object of the Affiliated-Party Transaction and/or the fairness of the transaction.

       To ensure the fairness of the intended Transaction, the Company appointed an Independent
       Appraiser based on the quotation no. 0004/2.0142-00/PP-B/DSS-01/0177/V/2025 of June 12th,
       2025, which has been approved by the Company.

       The following is the summary of the fairness opinion as presented in the Appraiser’s Report on
       this transaction of Amendment IV to the Loan Agreement number 00043/2.0142-
       00/BS/02/0177/1/VI/2025 of June 25th, 2025:

       i.     Identity of the Parties to the Transaction

              The Company is the assignor. The parties to the transaction are the Company and PC.

       ii.    Object of the Analysis for the Fairness Opinion

              The object of the analysis for the fairness opinion herein is the planned transaction of
              Amendment IV to the Loan Agreement.

       iii.   Purpose and Objective of the Fairness Opinion

              The purpose and objective of this fairness opinion is to fulfill the provisions of POJK
              42/2020.

       iv.    Assumptions and Limiting Conditions

              1. This fairness opinion is a non-disclaimer opinion.
              2. All of the data, statements and information received by the Independent Appraiser
                 from the management and the data and information available in the public domain, in
                 particular those concerning the economic and industry data, are deemed accurate and
                 obtained from the sources of credible accuracy.
              3. The Independent Appraiser has reviewed the documents used in the process of
                 rendering the fairness opinion.
              4. The Appraiser’s Report is compiled to fulfill the capital market purposes and the
                 Financial Services Authority’s provisions and not for tax or other purposes other than
                 the capital market purposes.
              5. In conducting the analysis, the Independent Appraiser made a number of assumptions
                 and depended on the accuracy, reliability and completeness of all financial information
                 and other information provided by the Company or publicly available, which in principle
                 was true, complete and not misleading, and the Independent Appraiser is not
                 responsible for conducting an independent examination on such information. The
                 Independent Appraiser also relied on the warranty of the Company’s management that
                 they were not aware of any fact that may cause the information provided for the
                 Independent Appraiser become incomplete or misleading.
              6. The Independent Appraiser assumes that from the issuance date of this fairness
                 opinion until the execution date of the planned corporate action, there will be no
                 changes that may have material effects on the assumptions used in compiling this
                                                  7
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                   fairness opinion. The Independent Appraiser is not responsible for reaffirming or
                   completing or updating the opinion due to the changes to the assumptions and
                   conditions or events occurring after the date of the Appraiser’s Report.
               7. All disputes in the forms of criminal or civil cases (in or out of court) associated with
                   the appraisal object is not under the Independent Appraiser’s responsibility.
               8. Changes made by the Government or private parties concerning the condition of the
                   appraisal object, on this matter the market condition, etc., are not within the
                   Appraiser’s responsibility.
               9. This Appraiser’s Report shall serve as part of the information used for decision making,
                   however it is neither binding nor able to be used as the basis of a decision which may
                   lead to legal implications, because this Appraiser’s Report was prepared merely based
                   on the area of discipline and capability of the Independent Appraiser.
               10. The amounts were stated in United States dollar currency and/or equivalents on the
                   request of the assignor.
               11. This Appraiser’s Report is invalid in the absence of the signature of the licensed
                   appraiser and the official corporate seal of the Independent Appraiser.
               12. This Appraiser’s Report was prepared and intended only for the assignor, in
                   accordance with the purpose and objective as disclosed in the appraisal report. All
                   materials included in this appraisal report in parts or in its entirety including those
                   related with the references, opinion, names and professional affiliations of the
                   appraiser are not to be published without the written consent from the Independent
                   Appraiser.

         v.    Approaches and Appraisal Method

               In compiling this Appraiser’s Report on the planned transaction of Amendment IV to the
               Loan Agreement, the Independent Appraiser has conducted an analysis through the
               approaches and appraisal procedure on the transaction of Amendment IV to the Loan
               Agreement, which include the following:
               a. Analysis on the planned transaction of Amendment IV to the Loan Agreement.
               b. Qualitative and quantitative analyses on the planned transaction of Amendment IV to
                   the Loan Agreement.
               c. Analyses on the fairness of the planned transaction of Amendment IV to the Loan
                   Agreement.

         vi.   Fairness Opinion on Transaction

               Based on the study and analysis conducted on all associated aspects for determining the
               positive impacts of the planned transaction of Amendment IV to the Loan Agreement
               either qualitatively or quantitatively, the Independent Appraiser is of the opinion that the
               planned transaction of Amendment IV to the Loan Agreement is fair.


IV.   BOARD OF DIRECTORS’ STATEMENT

      The Company’s Board of Directors declares that this transaction of Amendment IV to the Loan
      Agreement has been made with sufficient procedure and ensures that the transaction has been
      executed in accordance with the generally applicable business practices, i. e. the procedure to
      compare it with the terms and conditions of a transaction made between parties who do not have
      an Affiliated relationship and made by fulfilling the arm’s-length principle.

V.    BOARD OF COMMISSIONERS’ & BOARD OF DIRECTORS’ STATEMENT

      The Company’s Board of Commissioners and Board of Directors hereby declare that this
      transaction of Amendment IV to the Loan Agreement is an Affiliated-Party Transaction that does
      not contain any conflict of interest.
                                               8
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      The Company’s Board of Commissioners and Board of Directors hereby declare that they have
      carefully reviewed the information available regarding the transaction of Amendment IV to the Loan
      Agreement as explained in this Information Disclosure, and all material information regarding this
      transaction of Amendment IV to the Loan Agreement has been disclosed in this Information
      Disclosure and the material information is true and not misleading. Subsequently, the Company’s
      Board of Commissioners and Board of Directors hereby declare that they hold full responsibility on
      the accuracy of all information provided in this Information Disclosure.

VI.   ADDITIONAL INFORMATION

      The Company’s shareholders wishing to receive further information on the Affiliated-Party
      Transaction as explained in this Information Disclosure can contact:


                                PT Adaro Andalan Indonesia Tbk
                                      Cyber 2 Tower Lantai 26
                               Jl. H.R. Rasuna Said Blok X-5, No.13
                                     Jakarta 12950 – Indonesia
                       Telephone: (021) 2553 3065 Facsimile: (021) 2553 3066
                                     www.adaroindonesia.com

                               for the attention of: Corporate Secretary
                                 Email: corsec@adaroindonesia.com


* This Information Disclosure is made in both Indonesian dan English language. In case of discrepancies
  between the Indonesian and English version, the Indonesian version shall prevail.




                                                  9

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Names mentioned 20 people and organisations named in the text · linked when the evidence is strong

linked org ADARO ANDALAN INDONESIA TBK p.1 ×17
linked org PT Pari Coal p.1
linked org PT Alam Tri Abadi p.4
linked person Budi Bowoleksono p.5
linked person Primus Dorimulu p.5
linked person Julius Aslan p.5
linked person Lie Luckman p.5
possible person Ir. Rusli · Notaris p.4 ×2
possible person Budi Santoso p.5
possible person Heri Gunawan p.6
unresolved org Financial Services Authority p.1 ×4
unresolved org Salman dan Rekan p.2 ×2
unresolved org Rianto & Rekan p.3
unresolved org Minister of Law and Human Rights p.4 ×5
unresolved person Humberg Lie · Notaris p.4 ×9
unresolved org PT Adaro Andalan Indonesia. Such p.4
unresolved org Minister of Law p.4 ×2
unresolved person Sutjipto · Notaris p.5
unresolved org Minister of Justice p.5
unresolved person H. Bramantya Putra p.6

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