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Page 1
    INFORMATION DISCLOSURE REGARDING THE PLAN TO EXPAND BUSINESS
                             ACTIVITIES

 THIS INFORMATION DISCLOSURE IS SUBMITTED BY THE COMPANY IN ORDER TO
 COMPLY WITH THE PROVISIONS OF THE FINANCIAL SERVICES AUTHORITY
 REGULATION ("POJK") NO. 17 OF 2020 CONCERNING MATERIAL TRANSACTIONS AND
 CHANGES IN BUSINESS ACTIVITIES AND THE CENTRAL STATISTICS AGENCY
 REGULATION NO. 7 OF 2025 CONCERNING THE STANDARD CLASSIFICATION OF
 INDONESIAN BUSINESS FIELDS ("KBLI").
 THE INFORMATION AS CONTAINED IN THIS INFORMATION DISCLOSURE IS
 IMPORTANT FOR THE PUBLIC TO READ AND NOTE.
 IF YOU EXPERIENCE DIFFICULTY UNDERSTANDING THE INFORMATION AS CONTAINED
 IN THIS INFORMATION DISCLOSURE, YOU SHOULD CONSULT WITH A LEGAL ADVISOR,
 PUBLIC ACCOUNTANT, FINANCIAL ADVISOR OR OTHER PROFESSIONAL.




                        PT BENTENG API TECHNIC TBK ("Perseroan")
                                 Head Office in Surabaya

                                      Business Activities:
  Engaged in manufacturing and trading of Refractory products (Fire-Resistant Materials) and Heat-
                      Resistant Insulation, including Construction Services

                                          Head Office:
                                     Jl. Kebraon II No. 103 A,
                                  Karangpilang, Surabaya, 60222.
                                      Jawa Timur - Indonesia

                                    Phone: +62 (31)-7672269
                              Fax: +62 (31) 7662336/ (31) 7671475
                               Email: sekretariat@bentengapi.com
                              Website: https://www.bentengapi.com


THE BOARD OF DIRECTORS AND THE BOARD OF COMMISSIONERS OF THE COMPANY,
WHETHER INDIVIDUALLY OR JOINTLY, ARE FULLY RESPONSIBLE FOR THE ACCURACY AND
COMPLETENESS OF THE INFORMATION DISCLOSED IN THIS INFORMATION DISCLOSURE
AND, HAVING CONDUCTED DUE AND CAREFUL REVIEW, CONFIRM THAT THERE ARE NO
MATERIAL FACTS THAT HAVE NOT BEEN DISCLOSED OR HAVE BEEN OMITTED IN THIS
INFORMATION DISCLOSURE THAT WOULD CAUSE THE INFORMATION PROVIDED HEREIN
TO BE INCORRECT AND/OR MISLEADING.


                     This Information Disclosure was published on 05 May 2026
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                                       I. INTRODUCTION
     This Information Disclosure to Shareholders (the “Information Disclosure”) contains
     information regarding the Company’s plan relating to its business activities, namely the addition
     of new business activities, which must first obtain approval from the General Meeting of
     Shareholders (the “GMS”) of the Company, as referred to in Article 22 paragraph 1 item (a) of
     POJK 17/2020, which includes the Indonesian Standard Industrial Classification (“KBLI”):
       1) KBLI 38221 – Processing and Disposal of Hazardous Waste or Hazardous Garbage Other
           Than Radioactive Waste (supporting);
       2) KBLI 78200 – Temporary Manpower Supply Activities and Provision of Other Human
           Resources (supporting);
       3) KBLI 43211 – Electrical Network Installation (supporting);
       4) KBLI 28151 - Industry of Ovens, Fireplaces, and Similar Furnaces that Do Not Use Electric
           Current (supporting);
       5) KBLI 41013 - Conventional Construction of Industrial Buildings;
       6) KBLI 42992 - Construction of Mining Civil Buildings;
       7) KBLI 64210 - Holding Company Activities.

     (hereinafter referred to as the “Addition of Business Activities”).

     This Information Disclosure forms the basis for consideration by the Company’s shareholders in
     granting approval for the plan to change the Company’s business activities, in this case the
     addition of business activities, which will be proposed by the Company to the GMS.

     In connection with the above, the Company’s Board of Directors will announce this Information
     Disclosure through the Company’s website and the Indonesia Stock Exchange (“IDX”) website,
     with the aim of providing further information to the Company’s shareholders regarding the
     planned Change of Business Activities.


                              II. INFORMATION ABOUT COMPANY


I.       General Information about the Company

         The Company is a limited liability company established under Deed of Establishment No. 02
         dated 09 September 2004, drawn up before Tutty Mulianingsih, S.H., Notary in the City of
         Surabaya, and published in the State Gazette No. 096 dated 02 December 2022,
         Supplement to the State Gazette No. 041603.

         The Company is domiciled in Surabaya with its address at Jl. Kebraon II No. 103 A,
         Karangpilang, Surabaya 60222. The Company’s shares are listed on the IDX with the share
         code “BATR”.

         The Company’s Articles of Association have been amended several times, with the latest
         amendment based on the Deed of Statement of Shareholders’ Resolutions of PT Benteng
         Api Technic Tbk No. 13 dated 22 May 2025, drawn up before Dr. Susanti, S.H., M. Kn.,
         Notary in the City of Surabaya. Notice of the latest amendment to the Articles of Association
         has been received by the Ministry of Law and Human Rights of the Republic of Indonesia
         based on Letter No. AHU-AH.01.03-0138904 dated 22 May 2025.
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 II.       Capital Structure and Share Ownership of the Company

           The Company’s capital structure, shareholder composition, and share ownership based on
           the Company’s Shareholder Register as of 30 April 2026 issued by PT Sinartama Gunita,
           as the Company’s Securities Administration Bureau, are as follows:



                                                        Nominal Value of Rp 20,- (twenty Rupiah)
                                                                       per Share
                 Description
                                                   Number of          Total Nominal        Percentage
                                                    Shares                (Rp)                (%)
Shares owned by the Board of
Directors and the Board of
Commissioners:
1. Ridwan                                           1.332.440.000         26.648.800.000           44,05
2. Sugeng Suryadi                                     130.798.200          2.615.964.000            4,32

Shares with Ownership of 5% or
More:

1.     Ekadana Prayoga Suryadi                        426.802.400          8.536.048.000           14,11
2.     Bayu Haekal Suryadi                            426.802.400          8.536.048.000           14,11

Shares with Ownership of Less than
5%:

1.Public                                              708.194.353         14.163.887.060           23,41

Total Issued and Fully Paid-up Capital            3.025.037.353         60.500.747.060          100,00


 III.      Composition of the Company’s Board of Commissioners and Board of Directors

           As of the date of this Information Disclosure, the composition of the members of the
           Company’s Board of Commissioners and Board of Directors, based on the Deed of Circular
           Shareholders’ Resolution in lieu of an Extraordinary General Meeting of Shareholders of PT
           Benteng Api Technic No. 60 dated 30 May 2024, drawn up before Leolin Jayayanti, S.H., M.
           Kn., Notary in Jakarta, which has obtained Approval from the Minister of Law and Human
           Rights of the Republic of Indonesia No. AHU-0031442.AH.01.02. year 2024 dated 30 May
           2024 and has received Acceptance of Notification of Amendment to the Articles of
           Association from the Minister of Law and Human Rights of the Republic of Indonesia No.
           AHU-AH.01.03-0125421 dated 30 May 2024, is as follows:

           Board of Commissioners
           President Commissioner: Sugeng Suryadi
           Independent Commissioner: M. Rusli Ananda, ST.

           Board of Directors
           President Director: Ridwan
           Director: Aswin Asmantono, SE.
           Director: Agus Hari Pramudianto

 IV.       Purpose, Objectives, and Business Activities of the Company

           Business Activities Based on the Articles of Association and KBLI
           Based on Article 3 paragraph 1 of the Company’s Articles of Association, the Company’s
           purpose and objectives are to conduct business activities in the fields of Wholesale Trade,
Page 4
          Manufacturing, Construction, Wastewater Management and Recycling Waste Management,
          and Rental Activities and Leasing Without Option Rights.

          Furthermore, Article 3 paragraph 2 of the Company’s Articles of Association states that to
          achieve such purpose and objectives, the Company may carry out the following main
          business activities:
          a. Wholesale Trade:
            (i) Wholesale Trade of Roof Tiles, Bricks, Floor Tiles, and Similar Products Made from
                 Clay, Lime, Cement, or Glass (46633);
            (ii) Wholesale Trade of Cement, Lime, Sand, and Stone (46634);
          b. Manufacturing:
            (i) Manufacture of Fire-Resistant Bricks, Mortar, Cement, and Similar Products (23911);
            (ii) Manufacture of Other Fire-Resistant Products Made from Clay/Other Ceramics
                 (23919);
          c. Construction:
            (i) Other Special Construction Activities n.e.c. (43909);
            (ii) Oil and Gas Installation (43223);

          Article 3 paragraph 3 of the Company’s Articles of Association states that to achieve such
          purpose and objectives and to support the Company’s Main Business Activities, the
          Company may carry out the following supporting business activities:
          a. Construction:
            (i) Construction of Oil and Natural Gas Civil Buildings (42915);
          b. Wastewater Management and Recycling Waste Management:
            (i) Material Recovery of Non-Metal Goods (38302);
          c. Rental Activities and Leasing Without Option Rights:
            (i) Rental Activities and Leasing Without Option Rights of Industrial Machinery and
                 Equipment (77391).

          The KBLI codes above are in accordance with KBLI 2020 issued by Statistics Indonesia
          (BPS) through Regulation of the Head of BPS Number 2 of 2020, and the Company has
          carried out all main and supporting business activities as referred to in the Company’s
          Articles of Association.

V.        Summary of the Company’s Key Financial Data

          Profit (Loss) Overview

          Description           2021           2022           2023           2024            2025
                             Audited (Rp) Audited (Rp) Audited (Rp) Audited (Rp) Audited (Rp)
     Revenue                   81.378.094    131.344.566    138.149.489    107.361.317    145.381.385
     Cost of Revenue         (52.958.365)   (97.650.978)   (94.883.678)   (74.777.641)   (108.954.623)
     Profit (Loss) Before
     Income Tax                 4.803.779     14.852.465     15.087.793     11.703.810     16.636.837
     Profit (Loss) for the
     Year                       3.300.569     12.347.002     14.118.295      9.986.472     13.467.524
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     Financial Position Overview

                                2021                2022              2023             2024            2025
      Description
                             Audited (Rp) Audited (Rp) Audited (Rp) Audited (Rp) Audited (Rp)
Current Assets                 105.646.239      91.138.927           89.420.008      120.705.128     128.870.502
Non-Current Assets              21.425.553      24.382.698           26.485.852       90.293.850      91.529.170
Total Assets                   127.071.793     115.521.625          115.905.860      210.998.978     220.399.672

Current Liabilities             68.538.141      22.886.104           15.016.960       32.474.557      34.624.061
Non-Current Liabilities          6.843.379      28.186.053           24.799.001       27.895.873      29.516.342
Total Liabilities               75.381.521      51.072.157           39.815.961       60.370.430      64.140.403
Equity                          51.690.272      64.449.468           76.089.899      150.628.548     156.259.268
Liabilities and Equity         127.071.793     115.521.625          115.905.860      210.998.978     220.399.672

     Financial Ratios

                                                       2022             2023                           2025
          Description                  2021                                             2024
                                  Audited (Rp)        Audited          Audited       Audited (Rp)     Audited
                                                       (Rp)             (Rp)                           (Rp)
LIQUIDITY RATIOS
Current Ratio                          154,14%         398,23%          595,46%         371,69%        372,20%
Cash Ratio                              33,70%             77,09%       146,11%           92,97%       100,37%
Quick Ratio                             87,97%         398,23%          336,13%         162,05%        177,02%
ACTIVITY RATIOS
Trade Receivables Turnover:
Third Parties                           112,58              56,14            63,11          54,42         44,80
Related Parties                              0,27            1,22             1,38            0,39         0,08
Other Receivables Turnover:
Third Parties                                0             132,90           0,07            2,52           0,86
Inventory Turnover                      312,59                  0         149,81          332,30         226,39
Trade Payables Turnover:
Third Parties                            38,49              32,73            39,48          50,10         44,33
Pihak Berelasi                                  -            0,04             0,15            0,89         4,46
Other Payables Turnover:
Third Parties                            11,40               2,00             2,10            1,60         1,42
SOLVENCY RATIOS
Total Debt to Equity Ratio             145,83%             79,24%        52,33%           40,08%        41,05%
Total Debt to Assets Ratio              59,32%             44,21%        34,35%           28,61%        29,10%
PROFITABILITY RATIOS
Net Profit Margin                       4,06%              9,40%         10,22%            9,30%         9,26%
Return on Assets                        2,60%              10,69%        12,18%            4,73%         6,11%
Return on Equity                        6,39%              19,16%        18,55%            6,63%         8,62%


     III. SUMMARY OF THE FEASIBILITY STUDY OF CHANGES IN BUSINESS ACTIVITIES


The Company has appointed the Public Appraisal Firm Guntur, Eki, Andri & Rekan (“GEAR”),
with Business License No. 2.13.0116 based on the Decree of the Minister of Finance
562/KM.1/2013 dated 14 August 2013, registered as a Capital Market Supporting Profession
with the OJK under Certificate of Registration (STTD) No. STTD.PB-51/PM.223/2021 dated 04
May 2021 as an independent appraiser, and requested GEAR to provide a feasibility study
opinion (“Report”) on the Company’s Change of Business Activities.
Page 6
In preparing this Report, GEAR acted independently without any conflict of interest, and GEAR
is not affiliated with the Company or any parties affiliated with the Company. Y&R also has no
interest or personal benefit in relation to this engagement.

The following is a summary of the Company’s Report regarding the Change of Business Activities
No. 00027/2.0116-06/BS/04/0511/1/IV/2026 dated 24 April 2026. The Report refers to the
Engagement Proposal Letter No. JKT.066/PN.BV.GEAR/2026 dated 24 July 2026 and has been
amended through an addendum to Proposal Letter No. JKT.068/PN.BV.GEAR/2026 dated 09
April 2026, with the purpose of conducting a Study on the Addition of Business Activities of PT
Benteng Api Technic Tbk.

Status of the Public Appraiser

    Name of Public Appraiser        : Dwi Hari Prasetiyo, ST., MM., M.Ec.Dev. MAPPI (Cert)
    Public Appraiser License No.    : B-01.18.00511
    STTD No.                        : STTD.PB-51/PM.223/2021
    License Classification          : Business Appraiser (B)
    No. MAPPI                       : 14-S-05089

Purpose and Objective of the Valuation

The purpose of this engagement is to conduct a Study on the Addition of Business Activities of
PT Benteng Api Technic Tbk, which is required to comply with the Financial Services Authority
Regulation ("POJK").

This engagement is carried out with reference to Financial Services Authority Regulation No.
17/POJK.04/2020 ("POJK 17") regarding “Material Transactions and Changes in Business
Activities”, Financial Services Authority Regulation No. 35/POJK.04/2020 regarding Valuation
and Presentation of Business Valuation Reports in the Capital Market ("POJK 35”), Financial
Services Authority Circular Letter No. 17/SEOJK.04/2020 ("SEOJK 17") regarding Guidelines for
Valuation and Presentation of Business Valuation Reports in the Capital Market, and the
Indonesian Valuation Standards ("SPI") 7th Edition of 2018.

Feasibility Study Object

 The object of the Feasibility Study in this engagement is the addition of business activities
 under the Indonesian Standard Industrial Classification (KBLI), namely:
 1) KBLI 38221 – Processing and Disposal of Hazardous Waste or Hazardous Garbage Other
    Than Radioactive Waste (supporting);
 2) KBLI 78200 – Temporary Manpower Supply Activities and Provision of Other Human
    Resources (supporting);
 3) KBLI 43211 – Electrical Network Installation (supporting);
 4) KBLI 28151 - Industry of Ovens, Fireplaces, and Similar Furnaces that Do Not Use Electric
    Current (supporting);
 5) KBLI 41013 - Conventional Construction of Industrial Buildings;
 6) KBLI 42992 - Construction of Mining Civil Buildings;
 7) KBLI 64210 - Holding Company Activities.

Feasibility Study Date (Cut Off Date) and Report Validity Period

The Feasibility Study Date is 31 December 2025, and this date was determined based on
considerations of the interests and objectives of the valuation.

Based on Financial Services Authority Regulation No. 35/POJK.04/2020 (“POJK 35”) dated 25
May 2020 regarding Valuation and Presentation of Business Valuation Reports in the Capital
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 Market, the validity period of a valuation report is 6 (six) months from the effective date of the
 valuation (cut off date) in the valuation report.

 Taking the foregoing into consideration, the validity period of the Feasibility Study Report is 6
 (six) months from the effective date of the valuation (cut off date) in the Feasibility Study
 Report.

 Appraiser Independence

 In preparing this Feasibility Study report, GEAR acted independently without any conflict of
 interest and is not affiliated with BATR or any parties affiliated with BATR. GEAR also has no
 interest or personal benefit, nor may it disadvantage any party, in relation to this engagement.
 The professional fees received are not influenced in any way by the results of the feasibility
 study produced.

 Appraiser’s Responsibility

 To the best of GEAR’s knowledge and belief as an appraiser, GEAR states that all calculations
 and analyses made in preparing the Feasibility Study have been carried out correctly, and
 GEAR is responsible for the Feasibility Study that is issued.

 Approach and Analysis Methods Used

 In preparing this Feasibility Study report, GEAR conducted analyses through feasibility study
 approaches and procedures covering, among others, the following:

  Data Collection
  a. Collection of primary data from the Company related to the expansion plan for the addition
     of business activities, including the Company’s identity data, licensing, financial aspects,
     business plan, and other related data.
  b. Collection of secondary data from relevant and accountable sources.
  c. Collection of data from discussions on aspects that affect feasibility with the Company.

  Analysis Process
   a. Market analysis reviewing market conditions, market share, market potential, business
      competitors, and marketing strategy for the planned addition of business activities.
   b. Technical analysis reviewing the Company’s business processes for the planned addition
      of business activities, the products and services provided by the Company, capacity,
      production processes, availability of resources, and sustainability plans.
   c. Business model analysis reviewing the Company’s current business model, analysis of the
      addition of business activities, analysis of competitive advantages, competitors’ ability to
      replicate products, ability to create value, risk analysis, and SWOT analysis.
   d. Management model aspect analysis reviewing human resources, employee composition,
      intellectual property management, risk management, management capacity and
      capability, and the suitability of organizational and management structures.
   e. Financial analysis reviewing economic feasibility parameters, investment cost plan,
      funding sources, assumptions, financial projections before and after the addition of
      business activities, financial ratio analysis, operating cost analysis, raw material cost
      analysis, break-even analysis, profitability analysis, incremental analysis, investment
      return analysis, sensitivity analysis, and feasibility analysis of the addition of business
      activities.

Feasibility Study Engagement Standards

The analyses, opinions, and conclusions prepared by the appraiser, as well as the preparation of
this report, have been prepared in compliance with POJK 17, POJK 35, SEOJK 17, and SPI 7th
Edition of 2018.
Page 8
Scope and Depth of Investigation

The Feasibility Study was conducted through an investigation that included collecting data and
information from BATR’s management, aimed at obtaining the supporting documents required
for the analysis, and subsequently verified through interviews via conference call or virtual
meeting.

The Appraiser did not conduct the following activities or analyses:
1. No due diligence of the financial statements was performed, and any review of financial
   statement information was carried out only to the extent necessary for reasonableness
   analysis;
2. No due diligence of legal aspects, including the legal documents of the object of the
   reasonableness analysis, was performed;
3. Impact analysis for parties related to the Addition of Business Activities;
4. Other transactions besides those mentioned in the object of this feasibility study analysis.

Based on the investigation performed, it is known that BATR is currently still conducting its
operations in the fields of Wholesale Trade, Manufacturing, Construction, and Wastewater
Management and Recycling Waste Management.

In this engagement, we have conducted investigations to obtain adequate assurance, including
interviews with BATR or its representatives and other relevant parties.

The following parties were interviewed:

           Interviewee                            Position                   Company
 Aswin Asmantono                       Director & Corporate Secretary         BATR
 Citra Baby Safitri                    Assistant Corporate Secretary          BATR
 Muksim Adi Chandra                         Accounting Manager                BATR

Data and Information on the Business Expansion Plan

   Several relevant and reliable sources of information, without requiring verification, include
   the following:
  1) Historical financial statement data;
  2) Investment data and other supporting documents provided by BATR’s management;
  3) Economic data obtained from Damodaran research and other relevant sources;
  4) Economic data, both macro and micro, obtained from relevant institutions such as Bank
      Indonesia and others.

     Experts and Experts’ Work Products

       In preparing this Feasibility Study Report on the Addition of Business Activities, GEAR did
       not use any external expert analysis reports.

     Assumptions and Limiting Conditions

      Assumptions

      Several assumptions used in preparing this Feasibility Study include:
      1) The Feasibility Study Report is a non-disclaimer opinion.
      2) The business appraiser has reviewed the documents used in the Feasibility Study
          process.
      3) In preparing this report, GEAR relies on the accuracy and completeness of information
          provided by BATR and/or data obtained from publicly available information and other
          information and research considered relevant.
Page 9
4) The assignor represents that all material information relating to this Feasibility Study
    engagement has been fully disclosed to GEAR and that there has been no omission of
    important facts.
5) GEAR used financial projections provided by BATR and adjusted them to reflect the
    reasonableness of the projections in light of achievability ( fiduciary duty).
6) The resulting Feasibility Study Report is publicly available, except for confidential
    information that could affect BATR’s operations.
7) GEAR is responsible for the Feasibility Study Report and the conclusions produced.
8) GEAR obtained information regarding the legal status of the feasibility study object
    from the assignor.
9) This Feasibility Study Report is intended to meet capital market needs and comply with
    OJK regulations, and is not intended for tax purposes.
10) This feasibility study is prepared based on market and economic conditions, general
    business and financial conditions, and applicable government regulations related to the
    planned transaction as of the publication date of this feasibility study.
11) In preparing this Feasibility Study Report, we used assumptions such as the fulfillment
    of all conditions and obligations by BATR and all parties involved in the Addition of
    Business Activities, as well as the accuracy of information regarding the Addition of
    Business Activities disclosed by BATR’s management.
12) This feasibility study must be viewed as an integral whole, and using only part of the
    analysis and information without considering the other analyses and information as a
    whole may result in misleading views and conclusions regarding the underlying
    feasibility study process. Preparing a feasibility study is a complex process and may not
    be carried out through incomplete analysis.
13) We also assume that from the issuance date of this feasibility study until the occurrence
    of the Addition of Business Activities, there will be no changes that materially affect the
    assumptions used. We are not responsible for reaffirming or supplementing/updating
    our opinion due to changes in assumptions and conditions, or events that occur after
    the date of this report.

  Limiting Conditions

1) GEAR did not perform due diligence procedures on the entity or the parties conducting
   the transaction.

2) In performing the analysis, GEAR assumes and relies on the accuracy, reliability, and
   completeness of all financial information and other information provided to us by BATR
   or publicly available, which are inherently true, complete, and not misleading, and
   GEAR is not responsible for conducting independent verification of such information.
   GEAR also relies on management’s assurance that they are not aware of facts that
   would render the information provided to GEAR incomplete or misleading.
3) This feasibility study analysis of the Addition of Business Activities was prepared using
   the data and information disclosed above. Any changes to such data and information
   may materially affect our final opinion. Accordingly, we are not responsible for any
   change in our feasibility study conclusion due to changes in such data and information.
4) GEAR does not provide an opinion on the tax impact of this Addition of Business
   Activities. The services we provide to BATR in connection with this Addition of Business
   Activities are limited to providing a feasibility study of the planned Addition of Business
   Activities and are not accounting, audit, or tax services. GEAR does not examine the
   legal validity of the Addition of Business Activities from a legal standpoint, nor the tax
   implications thereof.
5) The work performed by GEAR in connection with this Addition of Business Activities is
   not, and cannot be construed in any form as, a review, audit, or the performance of
   certain procedures on financial information. Such work is also not intended to uncover
   weaknesses in internal controls, errors, or irregularities in financial statements, or
   violations of law. In addition, GEAR has neither the authority nor the position to obtain
   and analyze other transactions beyond the existing Addition of Business Activities and
Page 10
    that may be available to BATR, as well as the impact of such transactions on this
    Addition of Business Activities.

Publication Approval Requirements

This Feasibility Study Report and its attachments are intended solely for the Assignor and
the intended users of the Feasibility Study Report as set out in the scope of this
engagement. Any use of this Report outside the scope specified herein must obtain prior
written approval from GEAR and the assignor.

Material Events after the Feasibility Study Date (Subsequent Events) and
Report Date

Up to the date of this Feasibility Study Report, we have not obtained information regarding
material events that could have a material impact. Subsequent events are events occurring
after the report date, i.e., the issuance date of the Feasibility Study Report. The appraiser
is not obliged to make changes or adjustments to the Feasibility Study results set forth in
the Detailed Feasibility Study Report that has been issued and delivered to the Assignor.
However, if new substantive information arises, GEAR may issue a revision to the Feasibility
Study Report.

Confirmation that the Feasibility Study Report Was Prepared Based on
Financial Services Authority Regulations

The analyses, opinions, and conclusions, as well as the Feasibility Study Report, have been
prepared by the Appraiser in compliance with POJK 17, POJK 35, and SEOJK 17.

Confirmation that the Feasibility Study Report Was Prepared Based on SPI

The analyses, opinions, and conclusions prepared by the appraiser, as well as the Feasibility
Study Report, have been prepared in compliance with the Indonesian Appraiser Code of
Ethics (“KEPI”) and the Indonesian Valuation Standards (“SPI”) 7th Edition of 2018, as
established by the Indonesian Society of Appraisers (“MAPPI”).

Feasibility Analysis

Market Aspect

 Based on industry conditions, market share, and market potential across various relevant
 business lines, it can be concluded that the Company’s market aspect is in a promising
 and sustainable condition. The Company’s target industries include hazardous waste
 management, human resources provision, electrical installation, the oven and furnace
 industry, industrial building construction, and mining civil construction, all of which show
 positive growth trends driven by increased industrial activity, government policy, and the
 transition toward a sustainable economy.

 In the Processing and Disposal of Hazardous Waste or Hazardous Garbage Other Than
 Radioactive Waste sector, the market shows growth in line with tighter environmental
 regulations, implementation of circular economy principles, and increasing volumes of
 industrial waste. Nationally, there remains a gap between waste generation and
 management capacity, which creates broad market opportunities. The Company’s
 position, which is integrated with industrial and construction activities, provides an
 advantage in obtaining contract-based market share and recurring demand, while also
 supporting environmental compliance. These conditions make the waste management
 segment one of the stable market pillars.
Page 11
In the temporary manpower supply and provision of other human resources sector, market
growth is driven by the need for operational efficiency, labor flexibility, and increasing
complexity of labor regulations. The shift of the BPO industry toward knowledge-based
and performance-oriented services aligns with the nature of industrial and construction
project needs. With experience in industrial and site-based projects, the Company has a
specific and relatively strong market position compared to general manpower providers.
This opens opportunities to increase market share through integrated services that provide
added value to the Company.

In the electrical network installation sector, market prospects are supported by increasing
demand for electrical infrastructure in industrial facilities, power plants, smelters,
refineries, and new industrial estates. Every development and revitalization of industrial
facilities requires reliable and safe electrical installation systems that comply with technical
standards and electricity-sector regulations. The Company’s licensing and readiness to
meet IUJPTL requirements provide a strategic advantage in participating in industrial and
energy project tenders. With the Company’s background in installations for high-
temperature industrial equipment and high-risk environments, electrical installation
services can be positioned as an integral part of integrated industrial project solutions,
thereby increasing the chances of winning contracts and strengthening the Company’s
revenue contribution.

The oven, fireplace, and furnace industry has good market prospects along with growth
in industries requiring high-temperature heating processes, such as cement, steel,
petrochemicals, fertilizers, metal casting, and mineral processing. Demand for industrial
furnaces and ovens comes not only from new facility development, but also from
revamping, rejuvenation, and energy-efficiency improvements in existing facilities. The
Company’s core competencies in refractory and heat-resistant insulation provide a
competitive advantage in this segment, because furnace design and performance depend
heavily on material quality and thermal process understanding.

In conventional industrial building construction and mining civil construction, market
opportunities are influenced by the acceleration of industrial estate development,
downstream mining projects, and the development of energy and mineral supporting
facilities. The construction of smelters, processing facilities, industrial warehouses, and
mining infrastructure requires contractors that understand safety standards, structural
resilience, and integration with industrial process systems. The Company’s experience in
special construction work, industrial installation, and manpower supply support provides
an advantage in handling projects. This segment also opens synergy opportunities with
other business lines of the Company, such as supplying refractory materials, equipment
installation, and waste management, thereby creating integrated business patterns and
strengthening long-term revenue sustainability.

In addition, holding company activities provide strategic added value in market
management and the Company’s business development. Through its holding function, the
Company can coordinate various interrelated business lines, ranging from industrial
equipment manufacturing, construction services, installations, and manpower supply to
industrial waste management. A holding structure enables operational synergies among
business entities, optimal resource utilization, and stronger bargaining power in securing
large-scale industrial projects. Moreover, the holding structure provides flexibility in
investment development, business portfolio management, and expansion strategy into
industrial sectors linked to the Company’s core competencies.

Overall, the Company’s market aspect shows alignment between industry trends, market
needs, and the Company’s core competencies. Related market diversification reduces
dependence on a single business segment, increases resilience to industry cycles, and
creates cross-line business opportunities. Considering industry market conditions, market
share, market potential, target market, and marketing strategy to be implemented by the
Page 12
Company, the addition of business activities by BATR is, from the market aspect, feasible.

Technical Aspect

From an operational capacity standpoint, the Company has set realistic production targets
and activity capacities that align with its operational capabilities. For hazardous waste (B3)
management activities, the Company plans a capacity to utilize up to 1,000 tons per year
of used refractory waste, supported by adequate storage and processing facilities. For
manufacturing of industrial ovens and furnaces, production capacity is adjusted to project
needs with an estimated potential turnover of around Rp15 billion per year, while in
construction and installation the Company targets a measurable number of projects with
measurable contract values each year.

From an operational process standpoint, each business activity has a clear and structured
workflow, from planning, preparation, and implementation through to final inspection.
These operational processes are supported by the implementation of standard operating
procedures (SOPs), quality control systems, and occupational health and safety
management systems (K3) consistently applied in project execution. This indicates that
the Company’s business activities have adequate technical foundations and operating
systems to support effective and safe execution.

In terms of resource availability, the Company has relatively adequate human resources
distributed across various operational projects and supported by experts with technical
certifications in occupational safety, equipment operation, and industrial project
management. In addition, the Company has a supplier network supporting raw material
and production equipment needs, particularly for industrial oven and furnace
manufacturing. This resource availability indicates the Company’s operational readiness to
carry out the planned business activities.

In addition, in terms of compliance with licensing and technical standards, the Company
has identified the various licenses required for each business activity, such as IUJPTL for
electrical network installation activities and the Business Entity Certificate (SBU) for
construction services. The Company has also prepared steps to meet these requirements,
including providing certified experts and strengthening operational management systems.

With respect to operational sustainability, the Company has integrated sustainability
principles covering environmental, occupational safety, social, and corporate governance
aspects into all business activities. This is reflected in responsible waste management
practices, implementation of K3 management systems, enhancement of workforce
competencies, and a commitment to applying Good Corporate Governance (GCG)
principles. This approach shows that the Company’s business activities are not only
oriented toward business growth, but also consider long-term operational sustainability.

Furthermore, in line with the addition of the Company’s function as a holding company,
the Company is technically ready to perform the management and control role over
subsidiaries through strengthening managerial functions, performance oversight, and
operational coordination among entities. The existing organizational structure and human
resource competencies are considered adequate to support the holding function without
requiring additional manpower.

This holding role also enables increased synergies among entities within the business
group, optimized resource utilization, and stronger integrated control and strategic
planning systems. Accordingly, the holding function not only supports operational
efficiency, but also strengthens the sustainability and overall business development
direction of the Company.
Page 13
Considering the planned operational capacity, readiness of production processes, and the
human resource support owned by the Company, all planned business activities have an
adequate technical basis for implementation. Each business line is supported by clear
operational flows, implementation of SOPs, quality control systems, and K3 management
systems that support safe, efficient, and professional execution. Therefore, the addition
of business activities by BATR is, from the technical aspect, feasible.

Business Model Aspect

Based on the Company’s overall main business activities, supporting businesses, and the
plan to add new KBLI codes, the Company’s (BATR’s) business model can be concluded
as an integrated business model that combines manufacturing, trading, construction
services, installations, and supporting industrial services. The Company acts not only as a
producer and distributor of refractory products and construction materials, but also as an
end-to-end industrial solution provider, ranging from material supply and execution of
installation and special construction work, to operational support in the energy, industrial,
and mining sectors.

The Company’s main business activities in wholesale trade of construction materials and
manufacturing of fire-resistant goods form the foundation of its value chain. Through
control over production and distribution, the Company gains strong control over quality,
costs, and product availability. This is reinforced by special construction and oil and gas
installation activities that reflect a project-based business pattern. This model enables the
Company to increase revenue per customer through an end-to-end solution approach,
while strengthening long-term relationships with industrial customers.

The addition of new business activities—such as processing and disposal of hazardous
waste other than radioactive waste, temporary manpower supply and provision of other
human resources, electrical network installation, the oven/fireplace/furnace industry for
non-electric furnaces, conventional industrial building construction, and mining civil
construction—expands the Company’s business model to become more comprehensive
and adaptive. This diversification reflects a shift from being merely a product provider to
becoming an industrial strategic partner capable of meeting customers’ technical,
regulatory, and operational needs in an integrated manner. Besides opening new market
opportunities, this pattern also increases business resilience against demand fluctuations
in certain sectors.

In addition, with the holding company activities KBLI, the Company has the capability to
manage and coordinate various business lines within an integrated business structure. The
holding function enables optimization of investment management, synergies among
business units, and stronger strategic coordination in business development. This
structure provides flexibility for the Company to expand business activities through the
development of new business units and strategic partnerships, while also improving
operational efficiency and decision-making effectiveness in managing the business group.

From a competitive advantage perspective, the Company’s business model is supported
by long experience, specific technical capabilities, compliance with quality, safety, and
environmental standards, and skilled human resources. Entry barriers in the form of
certification requirements, special licensing, and technical competence make the
Company’s business model relatively difficult for competitors to replicate in full. A
marketing approach based on repeat orders and value added through knowledge sharing
further strengthens customer loyalty and business model sustainability.

Overall, BATR’s business model demonstrates diversified yet integrated characteristics,
with a focus on creating long-term value. Although business expansion does not
significantly increase operational complexity, adequate risk management, strengthening
of corporate governance, and continuous human resource development remain key factors
Page 14
in maintaining the Company’s business continuity and sustainability.

Considering the business model to be implemented by BATR’s management in terms of
business segments, competitive advantages, competitors’ ability to replicate products,
value creation ability, business risks, and SWOT analysis in the plan to add business
activities, the plan to add business activities is, from the business model aspect, feasible.

Management Model Aspect

The success of company management is strongly influenced by the quality of human
resources and professional management, so that operations can run effectively,
productivity increases, and corporate objectives can be achieved properly.

Based on BATR’s employee composition data, the workforce is recorded at 159 employees,
dominated by male employees at 85% compared to female employees at 15%. Most
employees are at the Staff & Non-Staff level or entry-level positions, with education
dominated by diploma-level and bachelor’s degree (S1). In terms of age, the majority of
employees are in the productive age ranges of 31–40 and 41–50. Overall, this human
resource structure indicates that the Company has sufficient manpower to support its
operational activities.

Based on the organizational capacity, human resources, and operational experience,
BATR’s management is considered to have adequate capability to support the proposed
plan to add business activities across the submitted sectors. The Company has also
prepared a human resource strengthening strategy, including expert certification plans
and optimization of existing manpower, so that overall it is considered capable of
supporting the development and operation of business activities in the future.

BATR’s organizational and group structure is considered to be clearly and integrally
designed to support effective coordination, decision-making, and operational control. With
a structured division of duties and authorities and continuous evaluation, the Company
has an adequate organizational foundation to support achievement of objectives and
business development in the future.

Considering the management model to be implemented by BATR’s management in terms
of human resources, risk management, management capacity and capability, and
organizational structure suitability in the plan to add business activities, the plan to add
business activities is, from the management model aspect, feasible.

Financial Aspect

With regard to the plan to add business activities for Processing and Disposal of Hazardous
Waste or Hazardous Garbage Other Than Radioactive Waste (KBLI 38221), Temporary
Manpower Supply Activities and Provision of Other Human Resources (KBLI 78200),
Electrical Network Installation (KBLI 43211), Conventional Construction of Industrial
Buildings (KBLI 41013), Construction of Mining Civil Buildings (KBLI 42992), and Holding
Company Activities (KBLI 64210), the Company will not make additional investment, as
the addition of these KBLI codes is intended to fulfill business licensing legality and to
support the Company’s participation in project tenders. In addition, specifically for KBLI
41013 and KBLI 42992, the Company already has adequate human resources to carry out
such business activities.

The investment is only made for the addition of the business activity for the Industry of
Ovens, Fireplaces, and Similar Furnaces that Do Not Use Electric Current (KBLI 28151),
amounting to Rp231,431,301 (two hundred thirty-one million four hundred thirty-one
thousand three hundred one rupiah), sourced from the Company’s cash.
Page 15
The assumptions used in preparing the financial projections before and after the addition
of business activities reflect BATR’s business development efforts. The addition of business
activities will result in changes to BATR’s financials. The projection period runs through
2030, or an explicit projection period of 5 years, considering that BATR’s management has
prepared a 5-year business plan and assumes the Company will be in a stable growth
condition thereafter. Therefore, to reflect BATR’s going concern, a terminal value is applied
using the income capitalization/Gordon model method. With respect to the achievability
analysis of the financial projections, the Appraiser held discussions with BATR’s
management and determined that the projections used are reasonable and have been
adjusted by the Appraiser.

The feasibility of this Addition of Business Activities is calculated based on the anticipated
future economic benefits, measured as the difference between Free Cash Flow to Firm
(FCFF) with the addition of business activities and FCFF without the addition of business
activities. This difference is then compared with the economic sacrifice, resulting in Free
Cash Flow to Incremental. Based on the feasibility analysis of the addition of business
activities, considering the assumptions applied, the following results were obtained:
  • Net Present Value (NPV)             : Rp6.835.038 Ribu
  • Internal Rate of Return (IRR)       : 20,59%
  • Profitability Index (PI)            : 29,53
  • Payback Period (PP)                 : 3 Years 5 Months

BATR’s NPV with the addition of business activities is Rp6,835,038 thousand. This result
concludes that the investment in adding business activities is feasible using the NPV
parameter because the resulting NPV is positive.

An IRR of 20.59% indicates that adding business activities by BATR is feasible because
the IRR is higher than the discount rate.

Overall Return on Investment (ROI) is the rate of profit generated from an investment
over a certain period of time, generally expressed as a percentage (%). In the feasibility
study context, ROI is used to measure the extent to which an investment provides a
financial return. The average ROI for the addition of business activities during the 2026–
2030 projection period is 2,953%.

Sensitivity analysis aims to test a project’s sensitivity to various influencing factors. The
sensitivity analysis results show that changes in the investment value for BATR’s business
expansion project indicate strong financial feasibility and remain in the feasible category
even with investment cost fluctuations of up to ±20%. The results show that this addition
of business activities is resilient to the risk of rising investment costs, with all financial
parameters remaining positive. Therefore, the financial risk due to changes in investment
value is relatively low, making this project feasible and safe to realize from a financial
perspective.

Based on the evaluation and financial analysis, as well as other projections, provided that
the established assumptions can be met, the plan to add business activities for Processing
and Disposal of Hazardous Waste or Hazardous Garbage Other Than Radioactive Waste
(KBLI 38221), Temporary Manpower Supply Activities and Provision of Other Human
Resources (KBLI 78200), Electrical Network Installation (KBLI 43211), the Industry of
Ovens, Fireplaces, and Similar Furnaces that Do Not Use Electric Current (KBLI 28151),
Conventional Construction of Industrial Buildings (KBLI 41013), Construction of Mining
Civil Buildings (KBLI 42992), and Holding Company Activities (KBLI 64210) is, from the
financial aspect, feasible.
Page 16
     Conclusion

     Based on the conclusions of the aspects above, BATR’s plan to add business activities is
     Feasible.

IV. AVAILABILITY OF RESOURCES IN CONNECTION WITH PLANNING TO CHANGE
                         BUSINESS ACTIVITIES

KBLI 38221 – Processing and Disposal of Hazardous Waste or Hazardous Garbage
Other Than Radioactive Waste

At present, the Company does not yet have experts who specifically handle the Processing and
Disposal of Hazardous Waste or Hazardous Garbage Other Than Radioactive Waste activities for
B3 Waste. However, the Company has planned to enhance human resource competencies by
targeting that in 2026 it will enroll 2 (two) employees to obtain certification as a person in
charge of B3 waste operations and a person in charge of controlling B3 waste pollution.

From an operational standpoint, the waste received by the Company comes from residual
materials that are no longer used by the user, which will then undergo further treatment and
processing to be reused as raw materials for BATR products. This approach reflects efforts to
improve resource efficiency while applying sustainable waste management principles.

KBLI 78200 – Temporary Manpower Supply Activities and Provision of Other Human
Resources

The Company currently has a total workforce of around 250 people distributed across all work
areas (projects under BATR), with a composition of 74 experts. The availability of these human
resources is considered adequate to support the implementation of this business activity,
particularly in manpower supply and the management of human resource functions.

KBLI 43211 – Electrical Network Installation

The Company currently has a total workforce of around 250 people distributed across all work
areas (projects under BATR), with 7 experts in the electrical field. The certification of these
experts has been prepared by the Company as part of fulfilling the requirements for obtaining
IUJPTL. The availability of these human resources is considered adequate to support the
implementation of electrical installation business activities.

In carrying out this business activity, the Company does not depend on suppliers, given the
service-based nature of the business; therefore, operations are supported primarily by the
competencies and readiness of its workforce.

KBLI 28151 – Industry of Ovens, Fireplaces, and Similar Furnaces that Do Not Use
Electric Current

The Company currently has approximately 10 personnel, and this number will certainly increase
as this KBLI becomes active and the market continues to grow.
Page 17
Suppliers for this KBLI business:
                                                                      Type of Goods
 No.                            Name
                                                                          /Project
  1    PT. Anugerah Binajaya Steel                                Steel and Stainless Steel
  2    PT. Global Spex Mandiri .                                  Equipment
  3    PT. Sarana Metal Jayatama                                  Steel and Stainless Steel
  4    PT. Berkat Prima Lancar Langgeng                           Steel and Stainless Steel
  5    PT. Karya Usaha Anugerah Tekhnik                           Steel and Stainless Steel
  6    PT. Yunika Trijaya Sentosa                                 Equipment
  7    PT. Timur Jaya Indosteel                                   Mild Steel (MS)

KBLI 41013 – Conventional Construction of Industrial Buildings

The Company currently has a total workforce of around 250 people distributed across all work
areas (projects under BATR). However, the Company does not yet have dedicated experts who
meet the requirements for a Business Entity Certificate (SBU) with sub-classification BG003. In
connection with this plan to add business activities, the Company will process the relevant SBU,
including fulfilling the required expert resources.

In carrying out this business activity, the Company does not depend on suppliers, given the
service-based nature of the business; therefore, operations rely primarily on the competence of
its human resources.

KBLI 42992 – Construction of Mining Civil Buildings

The Company currently has a total workforce of around 250 people distributed across all work
areas (projects under BATR), with 3 (three) experts. The certification of these experts has been
prepared by the Company to support the process of obtaining a Business Entity Certificate (SBU)
with sub-classification BS014.

In carrying out this business activity, the Company does not depend on suppliers, given the
service-based nature of the business; therefore, operations are supported primarily by the
competencies and readiness of its workforce.

KBLI 64210 – Holding Company Activities

To support the implementation of holding company activities, the Company does not plan to
add human resources through new recruitment. The Company will optimize its existing
workforce, particularly in managerial, finance, and operational control functions, which are
considered competent and adequate to carry out the holding role.

Technically, the holding function carried out by the Company will focus more on strategic
management, performance oversight of subsidiaries, and decision-making at the corporate level,
so it does not require significant additional operational manpower. The existing organizational
structure is considered sufficient to accommodate these needs, with potential adjustments to
functions and division of tasks to improve coordination effectiveness among entities.

By utilizing available resources, the Company is expected to improve operational efficiency while
strengthening synergies among entities within the business group. The Company’s role as a
holding company is also expected to improve the quality of control, strategic planning, and
optimization of subsidiary performance, thereby driving more focused and sustainable business
growth overall without significantly increasing labor costs.
Page 18
 V. EXPLANATION, CONSIDERATIONS AND REASONS FOR CHANGES TO BUSINESS
                                           ACTIVITIES

As a company with experience, capability, and a reputation in the manufacturing and trading of
Refractory products (Fire-Resistant Materials) and Heat-Resistant Insulation along with
Construction Services, PT Benteng Api Technic Tbk is consistently committed to developing
products and services sustainably in line with the Company’s motto, “Increasingly Excellent and
Trustworthy.” In line with its mission, the Company continuously develops and produces superior
and effective products at competitive prices. Expanding the scope of business into construction,
installation, treatment and management of B3 waste, manpower supply, and holding company
activities is a strategic step aligned with the Company’s growth direction.

By expanding the scope of work in construction, installation, treatment and management of B3
waste, manpower supply, and holding company activities, the Company seeks to provide more
integrated and comprehensive solutions for customers. This allows the Company not only to
handle trading and manufacturing work but also to be directly involved in on-site work, enabling
end-to-end construction services from upstream to downstream. This strategy will increase
competitiveness, expand market opportunities, and strengthen the Company’s position in the
national and international construction industry.

Through this business diversification, the Company believes it can provide significant added
value, maintain the quality of work, ensure timely execution, and deliver the best services
according to customers’ expected standards. Accordingly, this step is also a tangible
manifestation of the Company’s commitment to consistently realizing its mission while expanding
business sectors for long-term sustainability.

Products generated from the addition of business activities are as follows:

KBLI 38221 – Processing and Disposal of Hazardous Waste or Hazardous Garbage
Other Than Radioactive Waste

The Company does not produce any products under this KBLI, because this business activity is
a requirement for obtaining technical considerations for B3 waste for the Company’s operational
needs.

KBLI 78200 – Temporary Manpower Supply Activities and Provision of Other Human
Resources

Manpower supply services for insulation work such as furnace construction, kiln construction,
and building roofs and walls that require fire-resistant materials.

KBLI 43211 – Electrical Network Installation

The addition of the Electrical Network Installation KBLI is carried out as a strategic step to obtain
an IUJPTL license, so that the Company has the legal capacity to participate in electricity-related
projects and can support refractory work requirements without using a subcontract scheme.

KBLI 28151 – Industry of Ovens, Fireplaces, and Similar Furnaces that Do Not Use
Electric Current

Products produced under this KBLI are as follows:
a.   Furnace Manufacturing
b.   Anchor Manufacturing
Page 19
   KBLI 41013 – Conventional Construction of Industrial Buildings

   The construction services to be carried out by the Company are as follows:
   a.   Warehouse Building Construction
   b.   Factory building construction for industries in any sector

   KBLI 42992 – Construction of Mining Civil Buildings

   The construction service to be carried out by the Company is mining civil construction services;
   at present, services that can be provided include construction of processing plant buildings for
   mining output.

   KBLI 64210 – Holding Company Activities
   The Company does not produce new products or services from this addition of business
   activities; the addition of KBLI 64210 is intended to support the Company’s operations. As the
   Company has subsidiaries, the holding function carried out by the Company will focus on
   strategic management, performance oversight of subsidiaries, and decision-making at the
   corporate level.


       VI. THE EFFECT OF CHANGES IN BUSINESS ACTIVITIES ON THE FINANCIAL
                               CONDITION OF PUBLIC COMPANIES

   The assumptions used in preparing the financial projections before and after the addition of
   business activities reflect BATR’s business development efforts. The addition of business
   activities will result in changes to BATR’s financials. The financial projection period runs through
   2030, or an explicit projection period of 5 years, considering that BATR’s management has
   prepared a 5-year business plan with the assumption that the Company will be in a stable growth
   condition thereafter. Therefore, to reflect BATR’s going concern, a terminal value is applied
   using the income capitalization/Gordon model method. With respect to the achievability analysis
   of the financial projections, the Appraiser discussed with BATR’s management and concluded
   that the projections used are reasonable and have been adjusted by the Appraiser. The
   assumptions are as follows:

    Figure 81. Assumptions Before the Addition of Business Activities
                             Des              Des            Des                 Des              Des
     Description
                            2026             2027           2028                2029             2030
Inflation                      2,90%            2,50%           2,50%              2,50%            2,50%
Days                               365             365              366               365              365

Sales and Operating
                           153.000.000      156.060.000     159.181.200      162.364.824      165.612.120
Revenue
Sales Growth                                      2,00%            2,00%            2,00%           2,00%

                                          (107.681.400      (109.835.028    (112.031.729     (114.272.363
Cost of Revenue          (105.570.000)
                                                )                      )               )                )
% of Sales                         69%            69%               69%             69%              69%


General and
Administrative            (22.950.000)     (23.409.000)     (23.877.180)     (24.354.724)     (24.841.818)
Expenses
% of Sales                      15,00%          15,00%           15,00%           15,00%           15,00%


Selling Expenses           (7.650.000)      (7.803.000)      (7.959.060)      (8.118.241)
                                                                                               (8.280.606)
Page 20
                             Des              Des              Des            Des          Des
    Description
                            2026             2027             2028           2029         2030
% of Sales                     5,00%            5,00%            5,00%          5,00%        5,00%

Turnover
Trade Receivables
  Third Parties                  49,61            49,61           49,61         49,61          49,61
  Related Parties                 0,67             0,67            0,67          0,67           0,67
Other Receivables
  Third Parties                   1,15            1,15             1,15          1,15          1,15
Inventory                       226,84          226,84           226,84        226,84        226,84
Prepaid Advances                  8,00            8,00             8,00          8,00          8,00
Trade Payables
  Third Parties                  44,64            44,64           44,64         44,64          44,64
  Related Parties                 2,68             2,68            2,68          2,68           2,68
Other Payables
  Third Parties                   1,78             1,78            1,78          1,78              1,78
Accrued Expenses                  3,90             3,90            3,90          3,90              3,90

   Assumptions – Assumptions before the addition of business activities:
     1. The inflation rate in 2026 is assumed to be 2.90%, and in 2027–2030 it is assumed to
        remain the same each year at 2.50%.
     2. The number of days for the 2026–2030 period is 365 days.
     3. Revenue for the period ending December 2026 is recorded at Rp153,000,000 thousand,
        and is assumed to increase by 2% per year. Accordingly, revenue for the period ending
        December 2027 is Rp156,060,000 thousand and becomes Rp165,612,120 thousand in
        2030.
     4. The percentage of cost of revenue to sales is 69% for the 2026–2030 period. Accordingly,
        cost of sales for the period ending December 2026 is Rp105,570,000 thousand and
        becomes Rp114,272,363 thousand in 2030.
     5. The percentage of general and administrative expenses to sales is 15% for the 2026–
        2030 period. Accordingly, general and administrative expenses for the period ending
        December 2026 are Rp22,950,000 thousand and become Rp24,841,818 thousand in 2030.
     6. The percentage of selling expenses to sales is 5% for the 2026–2030 period. Accordingly,
        selling expenses for the period ending December 2026 are Rp7,650,000 thousand and
        become Rp8,280,606 thousand in 2030.
     7. Several parameters related to working capital turnover are assumed as follows:
       • Trade receivables turnover for 2026–2030 is assumed at 49.61 days for third parties
           and 0.67 days for related parties.
       • Other receivables turnover for 2026–2030 is assumed at 1.15 days for third parties.
       • Inventory turnover for 2026–2030 is assumed at 226.84 days.
       • Prepaid advances turnover for 2026–2030 is assumed at 8.00 days.
       • Trade payables turnover for 2026–2030 is assumed at 44.64 days for third parties and
           2.68 days for related parties.
       • Other payables turnover for 2026–2030 is assumed at 1.78 days for third parties.
       • Accrued expenses turnover for 2026–2030 is assumed at 3.90 days.

    Figure 82. Assumptions After the Addition of Business Activities
                            Des              Des              Des             Des           Des
     Description
                           2026             2027             2028            2029          2030
Inflation                      2,90%            2,50%             2,50%         2,50%         2,50%
Days                              365              365               366           365           365

Sales                    165.000.000      181.500.000      199.650.000     219.615.000   241.576.500
Sales Growth                                     10%              10%             10%           10%
Page 21
                           Des           Des           Des           Des           Des
    Description
                          2026          2027          2028          2029          2030
Cost of Sales         (113.850.000) (125.235.000) (137.758.500) (151.534.350) (166.687.785)
% of Sales                     69%           69%           69%           69%           69%

General and
Administrative         (24.750.000)    (27.225.000)    (29.947.500)   (32.942.250)    (36.236.475)
Expenses
% of Sales                  15,00%          15,00%         15,00%          15,00%          15,00%

Selling Expenses        (8.250.000)     (9.075.000)     (9.982.500)   (10.980.750)    (12.078.825)
% of Sales                   5,00%           5,00%           5,00%          5,00%           5,00%

Turnover
Trade Receivables
  Third Parties               49,61           49,61           49,61          49,61           49,61
  Related Parties              0,67            0,67            0,67           0,67            0,67
Other Receivables
  Third Parties                1,15            1,15           1,15            1,15            1,15
Inventory                    226,84          226,84         226,84          226,84          226,84
Prepaid Advances               8,00            8,00           8,00            8,00            8,00
Trade Payables
  Third Parties               44,64           44,64           44,64          44,64           44,64
  Related Parties              2,68            2,68            2,68           2,68            2,68
Other Payables
  Third Parties                1,78            1,78            1,78            1,78              1,78
Accrued Expenses               3,90            3,90            3,90            3,90              3,90

   Assumptions – Assumptions after the addition of business activities:
   1. The inflation rate in 2026 is assumed to be 2.90%, and in 2027–2030 it is assumed to
       remain the same each year at 2.50%.
   2. The number of days for the 2026–2030 period is 365 days.
   3. Revenue growth is assumed to increase by 10% per year. Accordingly, revenue for the
       period ending December 2026 is Rp165,000,000 thousand and becomes Rp241,576,500
       thousand in 2030.
   4. The percentage of cost of revenue to sales is 69% for the 2026–2030 period. Accordingly,
       cost of sales for the period ending December 2026 is Rp113,850,000 thousand and becomes
       Rp166,687,785 thousand in 2030.
   5. The percentage of general and administrative expenses to sales is 15% for the 2026–2030
       period. Accordingly, general and administrative expenses for the period ending December
       2026 are Rp24,750,000 thousand and become Rp36,236,475 thousand in 2030.
   6. The percentage of selling expenses to sales is 5% for the 2026–2030 period. Accordingly,
       selling expenses for the period ending December 2026 are Rp8,250,000 thousand and
       become Rp12,078,825 thousand in 2030.
   7. Several parameters related to working capital turnover are assumed as follows:
        • Trade receivables turnover for 2026–2030 is assumed at 49.61 days for third parties
             and 0.67 days for related parties.
        • Other receivables turnover for 2026–2030 is assumed at 1.15 days for third parties.
        • Inventory turnover for 2026–2030 is assumed at 226.84 days.
        • Prepaid advances turnover for 2026–2030 is assumed at 8.00 days.
        • Trade payables turnover for 2026–2030 is assumed at 44.64 days for third parties and
             2.68 days for related parties.
        • Other payables turnover for 2026–2030 is assumed at 1.78 days for third parties.
        • Accrued expenses turnover for 2026–2030 is assumed at 3.90 days.
Page 22
             VII OTHER MATERIAL MATTERS RELATED TO NEW BUSINESS
                         ACTIVITIES. PERUBAHAN KEGIATAN USAHA
1.   In relation to the Change of Business Activities, in addition to shareholder approval through
     the GMS, the Company requires licensing processed through OSS administered by the
     Ministry of Investment and Downstreaming/Investment Coordinating Board (BKPM).
2.   The Company does not require approval from other parties, including the Company’s
     creditors, for the Company’s Change of Business Activities plan.
3.   The Change of Business Activities plan will become effective after the Company:
        a. obtains GMS approval to amend Article 3 of the Company’s Articles of Association and
           obtains approval from the Ministry of Law and Human Rights; and
        b. obtains the relevant licenses from the competent authorities to carry out the new
           business activities (to the extent so required under applicable regulations).
4.   The Change of Business Activities will be proposed at the GMS to be held on 11 June 2026
     at the Auditorium Room, East Java Representative Office of the Indonesia Stock Exchange,
     Jl. Kusuma Bangsa No. 19, Ketabang, Kec. Genteng, Surabaya, East Java 60272, with both
     online and physical mechanisms. The GMS invitation will be issued by the Company on 20
     May 2026.
5.   The agenda items of the GMS related to the Change of Business Activities are as follows:
        a. Approval of the adjustment to the 2025 Indonesian Standard Industrial Classification
           (“KBLI”) in the Company’s Articles of Association in connection with Statistics
           Indonesia (BPS) Regulation No. 7 of 2025 on the Indonesian Standard Industrial
           Classification;
        b. Approval of amendments to the Company’s Articles of Association related to the
           Addition of Business Activities as reflected in the 2025 Indonesian Standard Industrial
           Classification (“KBLI”), including, among others:
            • KBLI 38221 – Processing and Disposal of Hazardous Waste or Hazardous Garbage
                Other Than Radioactive Waste (supporting);
            • KBLI 78200 – Temporary Manpower Supply Activities and Provision of Other
                Human Resources (supporting);
            • KBLI 43211 – Electrical Network Installation (supporting);
            • KBLI 28151 – Industry of Ovens, Fireplaces, and Similar Furnaces that Do Not
                Use Electric Current (supporting);
            • KBLI 41013 – Conventional Construction of Industrial Buildings;
            • KBLI 42992 – Construction of Mining Civil Buildings;
            • KBLI 64210 – Holding Company Activities.

     The following are the important dates in connection with the Company’s GMS:
       a. Announcement of the GMS through the Company’s website, IDX, and PT Kustodian
           Sentral Efek Indonesia (KSEI) website on 05 May 2026;
       b. Publication of the Information Disclosure regarding the Change of Business Activities
           through the Company’s website and IDX website on 05 May 2026;
       c. Shareholders Record Date (DPS) on 19 May 2026;
       d. GMS invitation through the Company’s website, IDX, and KSEI website on 20 May
           2026;
       e. Planned GMS date on 11 June 2026; and
       f. Planned announcement of the GMS minutes summary through the Company’s
           website, IDX, and KSEI website on 13 June 2026.
Page 23
Based on Article 23 of the Company's Articles of Association and Article 42 of OJK Regulation
Number 15 of 2020, the General Meeting of Shareholders concerning the Change of
Business Activities must satisfy the following attendance quorum and resolution
requirements:

  a. The General Meeting of Shareholders may be held if it is attended by shareholders
     representing at least 2/3 (two-thirds) of the total shares with valid voting rights;
  b. Resolutions of the General Meeting of Shareholders as referred to in item (a) are valid
     if approved by more than 2/3 (two-thirds) of the total shares with voting rights present
     at the General Meeting of Shareholders;
  c. If the quorum referred to in item (a) is not achieved, a second General Meeting of
     Shareholders may be held, provided that the second General Meeting of Shareholders
     is valid and entitled to adopt resolutions if it is attended by shareholders representing
     at least 3/5 (three-fifths) of the total shares with valid voting rights;
  d. Resolutions of the second General Meeting of Shareholders are valid if approved by
     more than 1/2 (one-half) of the total shares with voting rights present at the General
     Meeting of Shareholders; and
  e. If the attendance quorum at the second General Meeting of Shareholders as referred
     to in item (c) is not achieved, a third General Meeting of Shareholders may be held,
     provided that the third General Meeting of Shareholders is valid and entitled to adopt
     resolutions if it is attended by shareholders of shares with valid voting rights in an
     attendance quorum and decision quorum determined by the Financial Services
     Authority (OJK) upon the Company’s application.


                          VIII. ADDITIONAL INFORMATION

            Shareholders who require additional information may contact:


                            PT BENTENG API TECHNIC TBK
                         Jl. Kebraon II No. 103 A, Karangpilang,
                        Surabaya, 60222, Jawa Timur, Indonesia
                                Phone: +62 (31)-7672269
                         Fax: +62 (31) 7662336/ (31) 7671475
                            Email: sekretariat@bentengapi.com
                         Website: https://www.bentengapi.com

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Names mentioned 28 people and organisations named in the text · linked when the evidence is strong

linked org BENTENG API TECHNIC TBK p.1 ×19
linked org Ekadana Prayoga Suryadi p.3
linked — Bayu Haekal Suryadi p.3
linked person Sugeng Suryadi · President Commissioner p.3 ×3
possible person Dr. Susanti p.2 ×2
possible person Ridwan · President Director p.3 ×2
unresolved org FINANCIAL SERVICES AUTHORITY p.1 ×8
unresolved org Indonesia Stock Exchange p.2 ×2
unresolved person Tutty Mulianingsih · Notaris p.2
unresolved org Ministry of Law and Human Rights p.2 ×2
unresolved person Leolin Jayayanti p.3
unresolved org Minister of Law and Human Rights p.3 ×2
unresolved person M. Rusli Ananda · Commissioner p.3
unresolved person Aswin Asmantono · Director p.3
unresolved person Agus Hari Pramudianto · Director p.3
unresolved org Andri & Rekan p.5
unresolved org Minister of Finance p.5
unresolved person BATR · Corporate Secretary p.8 ×2
unresolved org Bank Indonesia p.8
unresolved org PT. Anugerah Binajaya Steel p.17
unresolved org PT. Global Spex Mandiri p.17
unresolved org PT. Sarana Metal Jayatama p.17
unresolved org PT. Berkat Prima Lancar Langgeng p.17
unresolved org PT. Karya Usaha Anugerah Tekhnik p.17
unresolved org PT. Yunika Trijaya Sentosa p.17
unresolved org PT. Timur Jaya Indosteel p.17
unresolved org Ministry of Investment and Downstreaming p.22
unresolved org PT Kustodian Sentral Efek Indonesia p.22

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