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Page 1
                                                                 Tel : +62-21 5795 7300                       Tanubrata Sutanto Fahmi Bambang & Rekan
                                                                 Fax : +62-21 5795 7301                       Certified Public Accountant
                                                                 www.bdo.co.id                                Licence No. 622/KM.1/2016

                                                                                                              Head Office
                                                                                                              Prudential Tower, 17th Floor
                                                                                                              Jl. Jend. Sudirman Kav. 79
                                                                                                              Jakarta 12910 - Indonesia




Jakarta, 5 Februari 2024                                                            Jakarta, 5 February 2024

No. 008/KAP-TCWG/ATM/SM/II-2024                                                     No. 008/KAP-TCWG/ATM/SM/II-2024

Kepada Yth,
                                                                                    The Board of Director, Comissioners and Audit
Dewan Direksi, Komisaris dan Komite Audit                                           Committee
PT Atmindo Tbk                                                                      PT Atmindo Tbk
Jl. Sei Belumai Km 2.4 No. 30-38                                                    Jl. Sei Belumai Km 2.4 No. 30-38
Desa Dagang Kelambir                                                                Desa Dagang Kelambir
Tanjung Morawa, Sumatera Utara 20362                                                Tanjung Morawa, Sumatera Utara 20362

Penilaian  sendiri  terhadap    pemenuhan                                           Self-assessment on compliance with restriction
pembatasan penggunaan jasa audit dan masa                                           on the period of audit services and cooling off
jeda

Sehubungan dengan penunjukan KAP Tanubrata                                          In connection with the appointment of KAP
Sutanto Fahmi Bambang & Rekan untuk mengaudit                                       Tanubrata Sutanto Fahmi Bambang & Partners to
laporan keuangan PT Atmindo Tbk untuk tahun                                         audit the financial statements of PT Atmindo Tbk
yang berakhir pada 31 Januari 2024, dengan ini                                      for the year ended 31 January 2024, we confirm
menyatakan bahwa:                                                                   that:

Akuntan Publik (AP) yang bertindak sebagai rekan                                    Public Accountant (AP) who is responsible as the
perikatan, AP yang bertindak sebagai penanggung                                     engagement partner, AP who is responsible as
jawab penelaahan pengendalian mutu perikatan                                        engagement quality review and other key audit
dan rekan perikatan audit lainnya memenuhi                                          partner comply with the restriction on the period
ketentuan pembatasan penggunaan jasa audit dan                                      of audit services and cooling off as required by
masa jeda sesuai POJK 9 Tahun 2023 tentang                                          POJK 9 Year 2023 regarding the use of AP and KAP
Penggunaan Jasa AP dan KAP dalam Kegiatan Jasa                                      services in Financial Services Activities, Code of
Keuangan, Kode Etik Profesi Akuntan Publik dan PP                                   Ethics for Public Accountants and PP No. 20 Year
No. 20 Tahun 2015 tentang Praktik Akuntan Publik.                                   2015 regarding the Accountant Public Practices.

Pertimbangan     yang     menyebabkan       kami                                    The considerations that led us to conclude that
menyimpulkan bahwa AP dan/atau personil KAP                                         the AP and/or KAP personnel mentioned above
dimaksud memenuhi pembatasan penggunaan jasa                                        complied with the restrictions on the use of audit
audit dan masa jeda dapat dilihat pada Lampiran.                                    services and the cooling off period can be seen in
                                                                                    the Appendix.

                                                            Hormat kami/Best regards,




                                                               Sury Musu, CPA
                                                     Rekan Perikatan/Engagement Partner




TANUBRATA SUTANTO FAHMI BAMBANG & REKAN
Tanubrata Sutanto Fahmi Bambang & Rekan (Certified Public Accountant), an Indonesian partnership, is a member of BDO International Limited, a UK
company limited by guarantee, and forms part of the international BDO network of independent member firms.
Page 2
                      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) years.
(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
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             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

Entity No. Position in the             Name of Company                 Parent, Subsidiary, or     Significant Component/           Type of Entities                 Industry                       2023           2023            2023            2023         Have you complied with   Have you complied with Have you complied with                       Conclusion              Signature           Name                  Position
            Engagement                                                     Single Entity         Not Significant Component                                                                                                                                           KEPAP 2021           POJK No. 9 of 2023       PP No. 20 of 2015
                                                                                                                                                                                                  Audit          Review           AUP          Other NAS                                     Art 7 and Art 8             Art 11                                                        `
    1            EP          PT Atmindo Tbk                          Single Entity              Significant Component        Listed Entity                Manufacturing                         Sury Musu                                                     Yes, the EP for 2023 has Yes, the EP for 2023 has Yes, the EP for 2023 has             EP in 2023 has fulfilled all                     Sury Musu          Engagement Partner
                                                                                                                                                                                                                                                              complied with KEPAP 2021 complied with POJK 9     complied with PP NO 20                rotation requirements

    1           EQCR         PT Atmindo Tbk                          Single Entity              Significant Component        Listed Entity                Manufacturing                      Nanda Priyatna                                                   Yes, the EQR for 2023 has Yes, the EQR for 2023 has        Yes, the EQR for 2023        EQR in 2023 has fulfilled                 Nanda Priyatna Harahap   Engagement Quality
                                                                                                                                                                                                Harahap                                                       complied with KEPAP 2021 complied with POJK 9              has complied with PP NO     all rotation requirements                                                 Review
                                                                                                                                                                                                                                                                                                                         20
                             Assessment for KEPAP                                                                                                                                                Tahun 2                                                      Yes, the EQR for 2023 has
                                                                                                                                                                                                                                                              complied with KEPAP 2021
                             Assessment for POJK                                                                                                                                                 Tahun 2                                                                                    Yes, the EQR for 2023 has
                                                                                                                                                                                                                                                                                            complied with POJK 9
                             Assessment for PP                                                                                                                                                   Tahun 2                                                                                                                 Yes, the EQR for 2023
                                                                                                                                                                                                                                                                                                                         has complied with PP NO
                                                                                                                                                                                                                                                                                                                         20

    1            MIC         PT Atmindo Tbk                          Single Entity              Significant Component        Listed Entity                Manufacturing                        Rizal Sitinjak                                                 Yes, the MIC for 2023 has Yes, the MIC for 2023 has        Yes, the MIC for 2023 has    MIC in 2023 has fulfilled                     Rizal Sitinjak       Manager In Charge
                                                                                                                                                                                                                                                              complied with KEPAP 2021 complied with POJK 9              complied with PP NO 20      all rotation requirements

                             Assessment for KEPAP                                                                                                                                                Tahun 2                                                        Yes, the MIC for 2023 has
                                                                                                                                                                                                                                                               complied with KEPAP 2021
                             Assessment for POJK                                                                                                                                                 Tahun 2                                                                                     Yes, the MIC for 2023 has
                                                                                                                                                                                                                                                                                               complied with POJK 9
                             Assessment for PP                                                                                                                                                   Tahun 2                                                                                                                 Yes, the MIC for 2023 has
                                                                                                                                                                                                                                                                                                                          complied with PP NO 20

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Names mentioned 12 people and organisations named in the text · linked when the evidence is strong

unresolved org Tanubrata Sutanto Fahmi Bambang & Rekan p.1 ×4
unresolved org Atmindo Tbk p.1 ×14
unresolved org Tanubrata p.1
unresolved org Sutanto Fahmi Bambang & Rekan p.1
unresolved org Sutanto Fahmi Bambang p.1
unresolved org Tanubrata Sutanto Fahmi Bambang & Partners p.1
unresolved org Penggunaan Jasa AP p.1
unresolved person Sury Musu · Rekan Perikatan/Engagement Partner p.1
unresolved org Engagement Partner TANUBRATA SUTANTO FAHMI BAMBANG & REKAN p.1
unresolved org BDO International Limited p.1
unresolved org Financial Services Authority p.2
unresolved org PT ABC p.3

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