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20260505_SWID_Informasi Transaksi Afiliasi_32077564_lamp3.pdf

Asset transaction Needs review SWID

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Page 1
                                 DEFINITIONS AND ABBREVIATIONS
Affiliate                :   a. family relationship due to marriage or lineage up to the second degree, both
                                horizontally and vertically;
                             b. relationship between a party and the employees, directors, or commissioners
                                of such party;
                             c. relationship between 2 (two) companies where there is 1 (one) or more
                                members of the board of directors or board of commissioners in common;
                             d. relationship between a company and a party that, directly or indirectly,
                                controls or is controlled by the company;
                             e. relationship between 2 (two) companies that are controlled, directly or
                                indirectly, by the same party; or
                             f. relationship between a company and its major shareholder.
Affiliated Transaction   :   Any activity and/or transaction carried out by a public company or a controlled
                             company with an Affiliate of the public company or an Affiliate of members of
                             the board of directors, members of the board of commissioners, major
                             shareholders, or the Controller, including any activity and/or transaction carried
                             out by a public company or a controlled company for the benefit of an Affiliate
                             of the public company or an Affiliate of members of the board of directors,
                             members of the board of commissioners, major shareholders, or the Controller.
Conflict of Interest     :   A difference between the economic interests of a public company and the
                             personal economic interests of members of the board of directors, members of
                             the board of commissioners, major shareholders, or the Controller that may
                             harm the public company.
POJK 42/2020             :   Financial Services Authority Regulation Number 42/POJK.04/2020 concerning
                             Affiliated Transactions and Conflict of Interest Transactions.
Company                  :   PT Saraswanti Indoland Development Tbk (“SWID”)
PT SU                    :   PT Saraswanti Utama




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                                               INTRODUCTION


This Disclosure of Information is made in connection with the transaction of receiving loan funds directly from
PT SU to the Company, which has become effective on May, 4 2026. This transaction constitutes an Affiliated
Transaction as regulated under POJK 42/2020.

To avoid any doubt, after careful examination and supported by the fairness of the transaction, in relation to the
fulfillment of POJK 42/2020, hereby:

    a.   the Board of Directors and the Board of Commissioners declare that this loan transaction constitutes an
         Affiliated Transaction that does not contain a Conflict of Interest;
    b.   the Board of Directors and the Board of Commissioners declare that all material information has been
         disclosed in this Disclosure of Information and that such information is not misleading; and
    c.   the Board of Directors of the Company declare that this Affiliated Transaction has undergone adequate
         procedures and ensures that the Affiliated Transaction is carried out in accordance with generally
         accepted business practices.

In connection with the matters as mentioned above, the Board of Directors of the Company announces this
Disclosure of Information to comply with the provisions of POJK 42/2020.




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                                        DESCRIPTION OF THE AFFILIATED
                                                TRANSACTION
I.    TRANSACTION DATE
      The transaction was carried out on Monday, May 4, 2026.

II.   TRANSACTION OBJECT
      The object of the transaction is the receipt of loan funds obtained directly from an affiliated party.

III. TRANSACTION VALUE
     Based on the Loan Agreement No. 001/SWID/V/2026 signed on May 4, 2026 between the Company and
     PT Saraswanti Utama, the value of this affiliated transaction amounts to Rp20,000,000,000 (Twenty Billion
     Rupiah).

IV. PARTIES CONDUCTING THE AFFILIATED TRANSACTION
    The parties conducting the affiliated transaction are the Company and PT Saraswanti Utama. The following
    is a brief description of the Company and PT Saraswanti Utama.

      Company
      Brief History
      The Company is a property developer that has been operating since 2010. The Company is a subsidiary of
      the Saraswanti Group or PT SU, focusing on property development, particularly high-rise buildings, which
      include apartments, condotels, and convention facilities (convention halls).

      The Company was established under the name PT Saraswanti Indoland Development based on Deed of
      Establishment No. 01 dated August 2, 2010, drawn up before Ismaryani, S.H., M.Kn. in Sidoarjo Regency,
      which has been approved by the Minister of Justice of the Republic of Indonesia based on Decree No. AHU-
      41610.AH.01.01 dated August 24, 2010.

      Since its establishment, the Articles of Association have been amended several times, including when the
      Company conducted its Initial Public Offering in 2022, as stated in the Statement of Shareholders
      Resolutions No. 15 dated February 24, 2022, which has obtained the Receipt of Notification of Amendment
      to Articles of Association No. AHU-AH.01.03.-0125744 dated February 24, 2022 and the Notification Letter
      of Changes in Company Data No. AHU-AH.01.03-0125752 dated February 24, 2022. Most recently, the
      Company’s Articles of Association have been amended as set forth in the Deed of Statement of Resolutions
      of the Annual General Meeting of Shareholders of the Company, drawn up before Notary Lucky Suryo
      Wicaksono, S.H., M.Kn., M.H. in Sleman Regency, dated July 3, 2025 No. 03, and has obtained the Receipt
      of Notification of Changes in Company Data dated June 16, 2025 No. AHU-AH.01.09.0298857.

      Capital Structure and Shareholding Composition
                                                                  Par Value Rp20/share
                Description
                                          Number of Shares          Total Nominal (Rp)           Percentage (%)
        Authorized Capital                 20,180,000,000             403,600,000,000
        Issued and Fully Paid
        Capital:
        1. PT Saraswanti Utama              3,420,338,983              68,406,779,660                 63.52%
        2. Bogat Agus Riyono                 855,084,746               17,101,694,920                 15.88%
        3. Public                           1,109,595,472              22,191,909,440                  20.6%
        Total Issued and Fully Paid
                                            5,395,019,201              107,700,384,020                 100%
        Capital
        Shares in Treasury
                                            14,794,980,799             295,899,615,980
        (Portfolio)




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Management and Supervision

The composition of the Board of Directors and the Board of Commissioners of the Company is most recently
based on Deed No. 03 dated 3 July 2025, drawn up before Notary Lucky Suryo Wicaksono, S.H., M.Kn.,
M.H., a Notary in Surabaya, and has obtained the Receipt of Notification of Changes in Company Data from
the Ministry of Law and Human Rights of the Republic of Indonesia dated 16 June 2025 No. AHU-
AH.01.09.0298857, as follows:

       Board of Commissioners
       President Commissioner         : Noegroho Hari Hardono
       Commissioner                   : Ir. Yahya Taufik
       Independent Commissioner       : Roossusetyo

       Board of Directors
       President Director             : Bogat Agus Riyono
       Director                       : Gentina Ratna Octanti
       Director                       : Samsul Hadi
       Director                       : Muhammad Alfian Ramadhan



PT Saraswanti Utama

Brief History

The Company was established under the name PT Saraswanti Utama based on Deed of Establishment No.
22 dated January 17, 2013, drawn up before Ismaryani, S.H., M.Kn. in Sidoarjo Regency, which has been
approved by the Minister of Law and Human Rights of the Republic of Indonesia based on Decree No.
AHU-07137.AH.01.01 dated February 19, 2013.

Since its establishment, the Articles of Association have been amended several times. Most recently, the
Company’s Articles of Association have been amended as set forth in the Minutes of the General Meeting
of Shareholders, drawn up before Notary Mudjiharto, S.H., M.Kn. in Surabaya, dated January 29, 2025 No.
07, and has obtained the Receipt of Decision of the Minister of Law and Human Rights of the Republic of
Indonesia based on Decree No. AHU-0004842.AH.01.02.

Capital Structure and Shareholding Composition

                                                 Par Value Rp50,000/share
       Description
                             Number of Shares      Total Nominal (Rp)     Percentage (%)
 Authorized Capital          1,000,000,000,000          20,000,000
 Issued and Fully Paid
 Capital:
     1. Noegroho Hari         133,522,500,000            2,670,450                46.85%
          Hardono
     2. Ir. Yahya Taufik       73,387,500,000            1,467,750                25.75%
     3. Andreas Adhi           35,340,000,000             706,800                 12.40%
          Harsanto
     4. Agnes                  42,750,000,000             855,000                   15%
          Martaulina Dwi
          Saraswanti
          Haloho
 Total Issued and Fully       285,000,000,000              5,700                   100%
 Paid Capital
 Shares in Treasury           715,000,000,000           14,300,000
 (Portfolio)




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      Management and Supervision
      The composition of the Board of Directors and the Board of Commissioners of the Company is most recently
      based on Deed No. 07 dated January 29, 2026, drawn up before Notary Mudjiharto, S.H., M.Kn., a Notary
      in Surabaya, and has obtained the Receipt of Notification of Changes in Company Data from the Ministry
      of Law and Human Rights of the Republic of Indonesia dated January 29, 2026 No. AHU-
      0004842.AH.01.02, as follows:

              Board of Commissioners
              President Commissioners          : Drs. Edison D. Haloho
              Commissioner I                   : Agnes Martaulina Dwi Saraswanti H
              Commissioner II                  : Annie Susilowati
              Commissioner III                 : Wardiyono

              Board of Directors
              President Director               : Noegroho Hari Hardono
              Director I                       : Ir. Yahya Taufik
              Director II                      : Andreas Adhi Harsanto
              Director III                     : Samsul Hadi


V.    NATURE OF AFFILIATED RELATIONSHIP
      The Company, as the recipient of the loan, is a subsidiary of PT SU. PT SU is also the Company’s major
      shareholder with an ownership percentage of 63.52%.

      Based on the relationship described above, in accordance with POJK 42/2020 Article 1 letter f: relationship
      between a Company and its major shareholder.

      This Affiliated Transaction is not required to use an Appraiser to determine the fair value of the object of the
      Affiliated Transaction and/or the fairness of the transaction as it constitutes a business activity carried out in
      generating operating revenue and is conducted on a routine, recurring, and/or continuous basis as referred
      to in POJK 42/2020 Article 8.

VI.   DESCRIPTION, CONSIDERATIONS, AND REASONS FOR THE AFFILIATED TRANSACTION
      In order to meet funding needs to support business activities, one of the Company’s strategies is to obtain
      loans from affiliates. Such loans are used to support the Company’s operations, including but not limited to
      financing operational activities, project development, and fulfilling working capital requirements.

      The Company requires immediate bridging financing from shareholders to carry out the Company’s
      project development in the near term. This funding is intended to support the acceleration of the
      construction of The Royal Alana Yogyakarta Hotel, which is expected to generate recurring income in the
      future, thereby providing better assurance of the Company’s business sustainability.

      Considering that customer advances received by the Company are collected in stages and the process of
      credit disbursement and/or addition of working capital facilities from banks requires a considerable
      amount of time, immediate bridging financing from shareholders is necessary to promptly proceed with
      the Company’s project development.

      The bridging financing from shareholders bears an interest rate of 7% per annum. This interest cost is
      considered lower than the banking interest rate of 8%. The Company believes that such funding provides
      optimal economic benefits compared to alternative sources of financing. In its implementation, the
      Company continues to observe the arm’s length principle and ensures that the transaction does not harm
      the Company or its minority shareholders.




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                                        ADDITIONAL INFORMATION


Shareholders of the Company who require more detailed information regarding this Disclosure of Information are
encouraged to contact us during the Company’s business days and working hours at:



                                 PT Saraswanti Indoland Development Tbk
                    Jl. Palagan Tentara Pelajar KM 7, Sleman, Daerah Istimewa Yogyakarta
                                     E-mail: corsec.swid@saraswanti.com
                                        Website: saraswantiproperty.com




                                           Main Business Activities:

  Star-rated hotel, real estate development owned, leased or sold, venue rental for MICE activities and special
                                                     events




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Names mentioned 22 people and organisations named in the text · linked when the evidence is strong

linked org PT Saraswanti Utama p.1 ×11
linked person Bogat Agus Riyono p.3 ×2
linked person Noegroho Hari Hardono p.4 ×2
linked person Gentina Ratna Octanti p.4
linked person Samsul Hadi p.4 ×2
linked person Muhammad Alfian Ramadhan p.4
linked — Agnes Martaulina Dwi p.5
linked person Andreas Adhi Harsanto p.5
unresolved org Financial Services Authority p.1
unresolved org PT SU p.1 ×5
unresolved org PT Saraswanti Utama. Company Brief History p.3
unresolved person Ismaryani p.3 ×2
unresolved org Minister of Justice p.3
unresolved person Notary Lucky Suryo Wicaksono · Notaris p.3 ×2
unresolved org Ministry of Law and Human Rights p.4
unresolved person Ir. Yahya Taufik Independent p.4
unresolved org PT Saraswanti Utama Brief History p.4
unresolved org Minister of Law and Human Rights p.4 ×2
unresolved person Notary Mudjiharto · Notaris p.4 ×2
unresolved person Drs. Edison D. Haloho Commissioner I p.5
unresolved person Ir. Yahya Taufik Director II p.5 ×4

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