20241023_AMIN_Perubahan Profesi Penunjang_31748721_lamp6.pdf

                Tanubrata Sutanto Fahmi Bambang & Rekan
                Certified Public Accountants

Partners Rotation Requirements under Local Regulations
Code of Ethics for the Public Accountant Profession (KEPAP)
P540.5: Subject to paragraphs P540.7 through P540.9, concerning audits of entities with public accountability, individuals are prohibited from acting in any of the following roles, or a combination thereof, for a cumulative period exceeding 7 (seven) years
("Active" period):
(a) Engagement partner;
(b) Individuals appointed as responsible for the quality control review of the engagement; or
(c) Other lead engagement partner roles.
After the active period, individuals must undergo a cooling-off period in accordance with the provisions in paragraphs P540.11 through P540.19.

P540.11: If an individual acts as an engagement partner for 7 (seven) cumulative years, the cooling-off period is 5 (five) consecutive years.

P540.12: When an individual has been appointed as responsible for the quality control review of the engagement and has acted in that capacity for 7 (seven) cumulative years, the cooling-off period is 3 (three) consecutive years.

P540.13: If an individual has acted as a lead auditor other than in the capacities specified in paragraphs P540.11 and P540.12 for 7 (seven) cumulative years, the cooling-off period shall be 2 (two) consecutive years.

P540.14 If an individual acts in a combination of roles as the lead engagement partner and as the engagement quality control reviewer for a cumulative 4 (four) years or more, then the cooling-off period will be 5 (five) consecutive years.

P540.15 Subject to paragraph P540.16(a), if an individual serves in a combination of roles as the lead engagement partner and as the lead engagement partner responsible for the quality control review of the engagement
for four cumulative years or more, then the cooling-off period shall be 3 (three) consecutive years.

P540.16 If an individual has served in a combination of roles as an engagement partner and in a role as an engagement quality control reviewer for four cumulative years or more during the active period, then the cooling-off period shall be:
(a) As an exception to paragraph P540.15, five consecutive years when the individual has been an engagement partner for three years or more; or
(b) Three consecutive years in other combinations.

P540.17 If an individual serves in any combination as the lead engagement partner other than those discussed in paragraphs P540.14 to P540.16, then the cooling-off period shall be 2 (two) consecutive years.




POJK 9 of 2023 - The use of Partner Audit Services and Public Accounting Firms

Article 7
(1) Entities such as commercial banks, issuers, and public companies are obligated to restrict the utilization of audit services for annual historical financial information from the same Audit Partner ("AP") for a cumulative period of 7 (seven)
(2) The entities specified in paragraph (1) may only reengage audit services for annual historical financial information from the same AP after a cooling-off period based on the type of AP's role in the engagement:
   a. If the AP serves as an Engagement Partner, the cooling-off period shall be 5 (five) consecutive reporting years;
   b. If the AP takes on the responsibility for the quality control review of the engagement, the cooling-off period shall be 3 (three) consecutive reporting years; and
   c. For other lead engagement partners, the cooling-off period shall be 2 (two) consecutive reporting years.
(3) The cumulative calculation referred to in paragraph (1) is accumulation from the 2017 fiscal year.
(4) Beyond adhering to paragraphs (1), (2), and (3), the entities referenced in paragraph (1) ensure that the AP has complied with the constraints on the utilization of audit services and the cooling-off period, as stipulated in the ethical code
of the Association of Public Accountant Professions and the prevailing regulations pertaining to the practice of public accountants.

Article 8
(1) Entities other than those indicated in Article 7 paragraph (1) are required to limit the utilization of audit services for annual historical financial information from the same AP to a maximum period of 5 (five) consecutive reporting years.
(2) The restriction on the utilization of audit services mentioned in paragraph (1) also applies to Audit Partners who are associated entities and personnel of Public Accountant Offices ("KAP"), positioned one (1) level below the AP assigned in
providing audit services.
(3) Entities referred to in paragraph (1) may be assigned to provide audit services for annual historical financial information from the same AP after a cooling-off period of 2 (two) consecutive reporting years.

Article 9
(1) The Party requests that the KAP carry out and provide the results of its own assessment regarding compliance with the restrictions on using audit services and the cooling-off period as intended in Article 7 and Article 8.
(2) The results of the self-assessment provided by KAP as intended in paragraph (1) for the Party:
   a. Commercial banks, issuers, and public companies must be accompanied by information on the assignment period that the AP acting has undertaken as Engagement partner, AP who acts as the person responsible for reviewing engagement
   quality control and other audit engagement partners; and
   b. Other than commercial banks, issuers, and public companies must be accompanied by information on the assignment period that has been undertaken by the AP and/or associated parties and KAP personnel with positions 1 (one) level
   below the AP who are involved in providing audit services, as well as the considerations that caused the KAP to conclude that the AP and/or KAP personnel in question comply with the restrictions on the use of audit services and the cooling
   off period.
(3) Calculation of limits on the use of audit services for annual historical financial information from the same AP by a Party as intended in Article 7 paragraph (1) and Article 8 paragraph (1) is applied from the time the AP provides audit services
to a Party, including:
   a. the period of providing services before the Party obtains a permit or is registered as an entity regulated and supervised by the Services AuthorityFinance; and
   b. period of service provision by AP before being registered with the Financial Services Authority.
(4) Parties who violate the provisions as intended in:
   a. Article 7 paragraph (1), Article 8 paragraph (1), and/or paragraph (2); or
   b. Article 7 paragraph (2) and/or Article 8 paragraph (3), is declared as not fulfilling the obligations regarding reports and assignments as intended in Article 2 paragraph (2) and is subject to sanctions in accordance with the provisions of laws
   and regulations in the financial services sector.



PP No. 20 of 2015 - Public Accountant Practice

Article 10
(1) Public Accountants provide assurance services, which include:
   a. Audit of historical financial information;
   b. Review services of historical financial information; and
   c. Other assurance services.
(2) In addition to the assurance services referred to in paragraph (1), Public Accountants may provide other services related to accounting, finance, and management.
(3) The provision of services as mentioned in paragraphs (1) and (2) is carried out in accordance with the provisions of the Legislation.

Article 11
(1) The provision of audit services for historical financial information as referred to in Article 10 paragraph (1) point a to an entity by a Public Accountant is limited to a maximum of 5 (five) consecutive reporting years.
(2) The entities referred to in paragraph (1) consist of:
   a. Industries in the Capital Market sector;
   b. Commercial banks;
   c. Pension funds;
   d. Insurance/reinsurance companies; or
   e. State-Owned Enterprises.
(3) The limitation on the provision of audit services for historical financial information as stipulated in paragraphs (1) and (2) also applies to Public Accountants who are Associated Parties.
(4) Public Accountants can re-engage in providing audit services for historical financial information to entities referred to in paragraph (1) after a consecutive 2 (two) reporting-year period of not providing such services.


Applicability of prevailing local regulations:
Type of Entities                                          KEPAP 2021                      POJK No. 9 of 2023 Art 7 and 8                  PP No.20 of 2015 Art 11

Listed Entity                                                  Yes                                        Yes                                        Yes
Banking                                                        Yes                                        Yes                                        Yes
Insurance and Re-insurance                                     Yes                                        Yes                                        Yes
Pension Fund                                                    -                                         Yes                                        Yes
Multifinance                                                    -                                         Yes                                        Yes
Stated - Owned Enterprise (BUMN)                                -                                          -                                         Yes

             Tanubrata Sutanto Fahmi Bambang & Rekan
             Certified Public Accountants


Workdone

Instructions:
            This document serves to fulfill the self assessment compliance to audit usage restrictions based on POJK No. 9 Articles 7 and 8 of 2023, Code of Ethics for Public Accountants (KEPAP) 2021, and PP No. 20 of 2015.
            1. The Engagement Team needs to perform self assessment compliance for the entities subject to POJK 9 /2023 Article 9. For group client need assessment for all entities under the group as required by KEPAP paragraph 540.19.
           2. Engagement team need to identify profile of each entities under the group: parent, subsidiary or single entity; significant or not significant; type of entities (see Row 70 of "Summary of Local Regulations); and industry
           3. The Engagement Team is required to fill in columns D to BB.
           4. The Engagement Team needs to confirm compliance with POJK No. 9 of 2023, KEPAP 2021, and PP No. 20 of 2015 in columns BD to BK.
           5. Regarding Other Key Audit Partners (OKAP), an individual can be considered an OKAP when their EP sign on significant component company, that should be required with the regulation based on the definition of the "Rekan Audit Utama" on Code of Ethics for Public Accountants (KEPAP) 2021. For further explanations, refer to tab sheet "EXAMPLE"
           * If there are company and subsidiaries that should required with the regulation, the Engagement Team can add them below without altering the sequence numbers we have provided in column B

Notes:
           When PT ABC is a parent entity with PT A and PT B as subsidiaries, the circumstances are different:
           PT A is a "Low Risk" client but is categorized as a "Significant Component", so the EP in PT A = OKAP
           PT B is a "Low Risk" client but categorized as a "Not Significant Component", so the EP at PT B ≠ OKAP

Example 1: Single Entity (Bank, Listed and Public Company - POJK 9/2023 Article 9 (2) a)                                                                                                                                                                            Assessment for appointment of audit fiscal year 2024
Entity No. Position in the             Name of Company              Parent, Subsidiary, or    Significant Component/         Type of Entities                                Industry                        2023             2024           2025   2026   Have you complied with Have you complied with       Have you complied                Conclusion            Signature           Name                  Position
            Engagement                                                   Single Entity      Not Significant Component                                                                                                                                           KEPAP 2021           POJK No. 9 of 2023         with PP No. 20 of
     1            EP        PT Atmindo Tbk                         Single Entity           Significant Component      Listed Entity                               Manufacturing                            Sury Musu        Sury Musu                      Yes, the EP for 2024 has Yes, the EP for 2024 has   Yes, the EP for 2024 has    EP in 2024 has fulfilled                     Sury Musu          Engagement Partner
                                                                                                                                                                                                                                                           complied with KEPAP 2021 complied with POJK 9       complied with PP NO 20     all rotation requirements

    1           EQCR        PT Atmindo Tbk                              Single Entity             Significant Component            Listed Entity                  Manufacturing                         Nanda Priyatna Nanda Priyatna                      Yes, the EQR for 2024 has Yes, the EQR for 2024 has Yes, the EQR for 2024      EQR in 2024 has fulfilled               Nanda Priyatna Harahap   Engagement Quality
                                                                                                                                                                                                           Harahap        Harahap                          complied with KEPAP 2021 complied with POJK 9       has complied with PP NO           all rotation                                                    Review
                                                                                                                                                                                                                                                                                                               20                              requirements
    1            MIC        PT Atmindo Tbk                              Single Entity             Significant Component            Listed Entity                  Manufacturing                           Rizal Sitinjak   Rizal Sitinjak                  Yes, the MIC for 2024 has Yes, the MIC for 2024 has Yes, the MIC for 2024      MIC in 2024 has fulfilled                    Rizal Sitinjak      Manager In Charge
                                                                                                                                                                                                                                                           complied with KEPAP 2021 complied with POJK 9       has complied with PP NO          all rotation
                                                                                                                                                                                                                                                                                                               20                              requirements