ACGS Part C - Disclosure and Transparency
The ASEAN Corporate Governance Scorecard measures corporate governance against ASEAN regional best practice standards.
Table of Disclosure and Transparency
| Part | Corporate Governance Standards | Implementation |
|---|---|---|
| C.1 | Transparent Ownership Structure | |
| C.1.1 | Does the information on shareholdings reveal the identity of beneficial owners holding 5% or more? | The identity of the ultimate shareholders and shareholders holding 5% or more is disclosed. |
| C.1.2 | Does the company disclose the direct and indirect (deemed) shareholdings of major and/or substantial shareholders? | Direct and indirect shareholdings of major/substantial shareholders are disclosed. |
| C.1.3 | Does the company disclose the direct and indirect (deemed) shareholdings of directors/commissioners? | Direct and indirect shareholdings of Directors and Commissioners are disclosed. |
| C.1.4 | Does the company disclose the direct and indirect (deemed) shareholdings of senior management? | Direct and indirect shareholdings of senior management are disclosed. |
| C.1.5 | Does the company disclose details of the parent/holding company, subsidiaries, associates, joint ventures and SPEs/SPVs? | Details of the corporate group (subsidiaries, associates, joint ventures, SPE/SPV) are disclosed. |
| C.2 | Quality of Annual Report | |
| Does the company's Annual Report disclose the following items: | ||
| C.2.1 | Corporate objectives disclosed? | Corporate objectives are disclosed in the Annual Report. |
| C.2.2 | Financial performance indicators disclosed? | Financial performance indicators are disclosed. |
| C.2.3 | Non-financial performance indicators disclosed? | Non-financial performance indicators are disclosed. |
| C.2.4 | Dividend policy disclosed? | Dividend distribution is disclosed, but the 2024 dividend-policy determination letter is not yet referenced. |
| C.2.5 | Biographical details (at least age, academic qualifications, date of first appointment, relevant experience, other directorships of listed companies) of all directors/commissioners disclosed? | Complete biographical details of all Directors/Commissioners are disclosed. |
| Corporate Governance Confirmation Statement | ||
| C.2.6 | Does the Annual Report contain a statement confirming full compliance with the code of corporate governance, and where there is non-compliance, identify and explain the reasons for each such issue (apply/comply-or-explain)? | The Annual Report includes a statement of compliance with the Corporate Governance Guidelines and explains reasons for non-compliance (PUGKI 'apply or explain' / OJK Regulation 21 'comply or explain'). |
| C.3 | Remuneration of Members of the Board and Key Executives | |
| C.3.1 | Is there disclosure of the fee structure for non-executive directors/commissioners? | The fee structure for Directors is disclosed. |
| C.3.2 | Does the company publicly disclose the details of remuneration of each non-executive director/commissioner? | Details of the remuneration of each Commissioner are not yet publicly disclosed. |
| C.3.3 | Does the company disclose its remuneration policy/practices (short- and long-term incentives, performance measures) for executive directors and the CEO? | Short-term remuneration policy/practices for Directors and the President Director are disclosed; long-term remuneration policy/practices are not yet disclosed. |
| C.3.4 | Does the company publicly disclose the details of remuneration of each executive director and the CEO? | Details of the remuneration of each Director and the President Director are not yet publicly disclosed. |
| C.4 | Disclosure of related party transactions (RPT) | |
| C.4.1 | Does the company disclose its policy covering the review and approval of material/significant RPTs? | The policy on review and approval of material/significant RPTs is disclosed. |
| C.4.2 | Does the company disclose the name, relationship, nature and value of each material RPT? | The name, relationship, nature and value of each material RPT are disclosed. |
| C.5 | Directors and Commissioners Dealings in Shares of the Company | |
| C.5.1 | Does the company disclose trading in the company's shares by insiders? | The company is not a listed company (no trading in its shares). |
| C.6 | External Auditor and Auditor Report | |
| Where the same audit firm is engaged for both audit and non-audit services | ||
| C.6.1 | Are the audit and non-audit fees disclosed? | The 2024 audit fee to KAP Rintis, Jumadi, Rianto & Rekan (PwC Indonesia) is disclosed. |
| C.6.2 | Do the non-audit fees exceed the audit fees? | The 2024 non-audit fee paid to the same audit firm did not exceed the 2024 audit fee. |
| C.7 | Medium of Communications | |
| Does the company use the following modes of communication? | ||
| C.7.1 | Quarterly reporting used? | Used: Quarterly Management Reports I-IV and unaudited Annual Report for FY2025. |
| C.7.2 | Company website used? | Used as a communication medium. |
| C.7.3 | Analyst's briefing used? | Used as a communication medium. |
| C.7.4 | Media briefings/press conferences used? | Used as a communication medium. |
| C.8 | Timely Filing/Release of Annual/Financial Reports | |
| C.8.1 | Is the audited annual financial report released within 120 days of the financial year end? | Not yet met. The audited financial statements as of 31 December 2024 were issued on 23 May 2025. |
| C.8.2 | Is the annual report released within 120 days of the financial year end? | Not yet met. The Annual Report was signed by all Commissioners and Directors in June 2025. |
| C.8.3 | Is the true and fair representation of the annual financial statements affirmed by the board of directors/commissioners and/or relevant officers? | The true-and-fair representation of the Annual Financial Statements has been affirmed by management and/or relevant officers. |
| C.9 | Company Website | |
| Does the company have a website disclosing up-to-date information on the following: | ||
| C.9.1 | Financial statements/reports (latest quarterly) disclosed on the website? | The website has not yet disclosed quarterly financial statement information. |
| C.9.2 | Materials provided in briefings to analysts and media disclosed on the website? | Analyst and media briefing materials are disclosed. |
| C.9.3 | Downloadable annual reports available? | Annual reports are downloadable. |
| C.9.4 | Notice of AGM and/or EGM disclosed on the website? | AGM/EGM notices are disclosed. |
| C.9.5 | Minutes of AGM and/or EGM disclosed on the website? | Summaries of AGM/EGM minutes are disclosed. |
| C.9.6 | Company's constitution (bylaws, memorandum and articles of association) disclosed on the website? | The website does not yet disclose the Articles of Association. |
| C.10 | Investor Relations | |
| C.10.1 | Does the company disclose the contact details (telephone, fax, email) of the officer responsible for investor relations? | Contact details of the investor relations officer are disclosed through the Annual Report. |
