Indonesia Financial Services Authority (OJK) herewith announces the results of the Formal Investigation in the case of violations of Capital Market regulations by PT Narada Aset Manajemen. 

Considering the role and involvement of each Persons in the violations and in order to create deterrence effect for financial services industry players, on December 8, 2023 OJK imposes administrative sanctions and/or Written Orders as follows:

1. OJK imposes PT Narada Aset Manajemen (PT NAM) penalty of Rp4.600.000.000,00 (four billion six hundred million rupiah) and a Written Orders as follows:
   a. settle redemption debt payments for the Reksa Dana Narada Saham Indonesia (RD NSI), the Reksa Dana Narada Campuran I (RD NC I), the Reksa Dana Narada Saham Indonesia II (RD NSI II), and the Reksa Dana Narada Saham Berkah Syariah Sharia (RD NSBS);
   
   
   b. settle debt payments to Securities Companies arising from purchase transactions for the benefit of Mutual Funds;
   
   
   c. settle debt payments for bilateral and individual fund management agreements/fund management contracts that have matured and have not been extended; 
   
   
   d. terminate bilateral and individual fund management agreements/fund management contracts that are carried out not in accordance with the provisions; And
   
   
   e. settle the dissolution/liquidation of RD NSI, RD NC 1, RD NS II, and RD NSBS. 
   
   
   Furthermore, the Written Orders as intended in letters a to e above is implemented with the following conditions:
   a. That the obligations of Written Orders letters d and e are carried out after payment of points a, b, and c above.
   
   
   b. That the process of fulfilling the Written Order above is carried out within a period of 6 (six) months. 
   In the process of fulfilling all the Written Orders above, PT NAM is obliged to continue reporting the progress of fulfillment to OJK. 
   
   
2. The Administrative Sanctions in the form of penalties and Written Orders were imposed because PT NAM was proven to have committed the following violations: 
   a. Provisions of Article 4 POJK Number 24/POJK.04/2014 are due to PT NAM because PT NAM does not have an Standard Operational Procedure (SOP) for the implementation of the Investment Manager function, namely the Research Function SOP, Trading SOP, Securities Transaction Settlement SOP, and Risk Management and Internal Audit Compliance SOP. Furthermore, PT NAM only made adjustments to the SOP on July 10, 2020; 
   
   
   b. The provisions of Article 14 paragraph (1) and Article 15 POJK Number 33/POJK.04/2019 juncto Article 8 paragraph (2) POJK Number 23/POJK.04/2016 because PT NAM has a composition of Securities issued by 1 (one) the party is more than 20% (twenty percent) NAV on RD NSBS and does not make adjustments in accordance with the provisions; 
   
   
   c. The provisions of Article 6 paragraph (1) letter d juncto with Article 7 paragraph (2) and Article 8 paragraph (2) POJK Number 23/POJK.04/2016 as amended and regulated are the same in POJK Number 2/POJK.04/2020 because PT NAM related to ownership of Securities issued by 1 Party of more than 10% (ten percent) NAV in RD NSI, RD NC I and RD NSI II and not making adjustments in accordance with applicable regulations; 
   
   
   d. The provisions of Article 45 letter d juncto with Article 48 POJK Number 23/POJK.04/2016 as amended and regulated the same in POJK Number 2/POJK.04/2020 regarding the nondissolution of the Reksa Dana Narada Milenesia Cash Fund (RD NMCF) because RD NMCF owns NAV is less than 10 billion Rupiah and does not carry out dissolution in accordance with the provisions; 
   
   
   e. The provisions of Article 27 paragraph (1) UUPM junctis Article 18, Article 25, Article 28 and Article 33 POJK 43/POJK.04/2015 as revoked and re-regulated in Article 23 paragraph (1), Article 31, Article 36 and Article 42 POJK 17/POJK.04/2022 regarding cross transactions between PT NAM Mutual Funds at prices outside the stock exchange price range, causing losses to one of the Mutual Funds and the provision of Article 17 paragraph (1) UUPM Junctis Article 18, Article 25, and Article 28 POJK 43/POJK.04/2015 as revoked and re-regulated in Article 23 paragraph (1), Article 31, and Article 36 POJK 17/POJK.04/2022. 
   
   
   f. The provisions of Article 14 paragraph (2) letter g juncto Article 57 POJK Number 33/POJK.04/2019 regarding PT NAM's investment management in RD NSBS in FORZ and LAND shares/stocks which are the shares no longer listed on the Sharia Securities List (DES) and subsequently PT NAM is not selling the FORZ and LAND shares in question no later than 10 (ten) working days after the shares are no longer listed in the DES.
   
   
   g. The provisions of Article 24 UUPM and Article 27 UUPM junctis Article 2 paragraph (1), Article 6 paragraph (1) letter p, and Article 6 paragraph (1) letter o POJK Number 23/POJK.04/2016 as amended and reregulated in POJK Number 2/POJK.04/2020 regarding failure to pay instructions for purchasing shares for Mutual Funds where PT NAM does not have sufficient cash funds to purchase the Securities in question so payment for the purchase instructions is made with borrowed funds 13 (thirteen) The Securities Company which is the broker for PT NAM.   
   
   
   h. The provisions of Article 20 paragraph (2) UUPM junctis Article 21, Article 23 paragraph (1) and paragraph (2), and Article 24 POJK Number 23/POJK.04/2016 as amended and re-regulated in POJK Number 2/POJK.04/ 2020 related to non-purchase and payment of Participation Units of RD NSI, RD NSI II RD NC I, and RD NSBS to customers/participation unit holders beyond 7 (seven) trading days after the redemption instruction was received by the Investment Manager.  
   
   
   i. The provisions of Article 25 number 1 UUPM and Article 38 number 1 POJK Number 23/POJK.04/2016 as amended and regulated the same in POJK Number 2/POJK.04/2020 due to the storage of several Mutual Fund Securities which are managed in Securities Accounts not in the name of Mutual Funds Funds in several Securities Companies. This is because these Securities/stocks are used as collateral to Securities Companies in the context of resolving PT NAM's default transactions.  
   
   
   j. The provisions of Article 34 paragraph (1) letter b POJK Number 43/POJK.04/2015 as revoked and reregulated in Article 43 paragraph (1) letter b POJK Number 17/POJK.04/2022 regarding cross securities transactions between Mutual Fund Accounts managed by PT NAM with Made Adi Wibawa (President Commissioner PT NAM) through a nominee account.  
   
   
   k. Provisions of Article 6 paragraph (1) letter c juncto Article 7 paragraph (2) and Article 8 paragraph (2) POJK Number 23/POJK.04/2016 as amended and re-regulated in POJK Number 2/POJK.04/2020 regarding Securities ownership greater than 5% (five percent) of the Issuer's paid-up capital in RD NSI and does not make adjustments to the composition of the Securities in accordance with applicable regulations.  
   
   
   l. The provisions of Article 37 paragraph (2) and Article 44 paragraph (1) POJK Number 43/POJK.04/2015 as revoked and reregulated in Article 58 paragraph (2) letter a and Article 68 paragraph (1) POJK Number 17/POJK.04/2022 regarding the failure to convey material facts in disclosing the composition of Securities in Fund Fact Sheet (FFS) on RD NSI, RD NSI II, RD NC I, and RD NSBS, thus giving a wrong picture and could mislead customers or prospective customers in understanding investment products.  
   
   
   m. The provisions of Article 37 paragraph (2) letter a and Article 44 paragraph (1) and paragraph (2) POJK Number 43/POJK.04/2015 as revoked and reregulated in Article 58 paragraph (2) letter a and Article 68 paragraph (1) POJK Number 17/POJK.04/2022 junctis Article 31 UUPM and Article 2 Paragraph (1) POJK Number 45/POJK.04/2016 relating to the marketing and sale of Mutual Funds by promising certain returns within a certain period to customers/potential customers.  
   
   
   n. Provisions of Article 17 paragraph (1) junctis Article 20 paragraph (1), Article 27 paragraph (1), and Article 44 paragraph (1) POJK Number 12/POJK.01/2017 as amended in POJK Number 23/POJK.01/2019 regarding PT NAM is not identifying and classifying Participation Unit Holder (PUP) customers in Mutual Fund account opening form (FPR) based on whether or not there is a beneficial owner of the account. Because of this, PT NAM cannot confirm and monitor transactions carried out by the PT NAM Mutual Fund PUP account.  
   
   
   o. The provisions of Article 2 of Regulation Number V.D.5 which have been revoked and are re-regulated in Article 4 paragraph (1) POJK Number 52/POJK.04/2020 juncto the provisions of Number 2 of Regulation Number VIII.G.17 and Article 2 POJK Number 1/POJK.04 /2020 which has been revoked and are re-regulated in Article 2 paragraph (1) POJK Number 20/POJK.04/2021 regarding PT NAM does not include one of the Company's bank accounts in the calculation and reporting of Net Adjusted Working Capital (MKBD) and is not recorded in the  Chart of Accounts of the Financial Report (off balance sheet) in accordance with the provisions for preparing Securities Company Financial Reports. 
   
   
   p. The provisions of Article 7 paragraph (2) juncto Article 17 paragraph (1) POJK Number 21/POJK.04/2017 regarding PT NAM not carrying out Discretionary Fund (KPD) management in good faith and with full responsibility for the selection of Securities that become the KPD's portfolio so that PT NAM cannot carry out settlement of KPD Customer rights in accordance with KPD agreements that have expired (failure to pay back the KPD).  
   
   
   q. The provisions of Article 18 POJK Number: 43/POJK.04/2015 as revoked and re-regulated in Article 23 paragraph (1) POJK Number 17/POJK.04/2022 regarding PT NAM is not making and implementing any investment policies and carrying out transactions for the benefit of customers based on rational reasons, PT NAM only chose and transacted on TGRA and FORZ Securities as its KPD portfolio and sold TGRA and FORZ Securities at a lower selling price than the buying price on the same day.  
   
   
   r. The provisions of Article 10 and Article 19 POJK Number 21/POJK.04/2017 relate to PT NAM not depositing customer KPD funds with a Custodian Bank, but instead depositing them with an affiliate of PT NAM, namely PT Narada Adikara Indonesia. Apart from that, PT NAM did not report PT NAM's KPD to the OJK in accordance with the provisions.
   
   
3. To Mr. Garry Hart Hizkia as National Retail Sales of PT NAM is subject to Administrative Sanctions in the form of a Penalty of Rp75.000.000,00 (seventyfive million rupiah) and Written Order in the form of a prohibition on becoming a shareholder, management and/or employee in a Financial Services Institution (LJK) in the Capital Market Sector for 3 years because he was proven as the party that caused PT NAM to commit the violation as referred to in number 2 letter m above. 
   
   
4. To Mr. Rudy Rudolf as the National Retail Sales of PT NAM is subject to Administrative Sanctions in the form of a Penalty of Rp75.000.000,00 (seventy five million rupiah) and Written Order in the form of a prohibition on becoming a shareholder, management, and/or employee in an LJK in the Capital Market sector for 3 years because he was proven as the party that caused PT NAM to commit the violation as referred to in number 2 letter m above.
   
   
5. To Ms. Nyoman Anie Puspitasari as Chief Marketing Officer of PT NAM is subject to Administrative Sanctions in the form of a Penalty of Rp155.000.000,00 (one hundred and fifty-five million rupiah) and Written Order in the form of a prohibition on becoming a shareholder, management and/or employee in an LJK in the Capital Market sector for 3 years because she was proven as the party that caused PT NAM to commit the violation as referred to in numbers 2 letters m and n above.
   
   
6. To Ms. Rany Dian Febiyani as Head Dealer of PT NAM is subject to Administrative Sanctions in the form of a Penalty of Rp60,000,000.00 (sixty million rupiah) and Written Order in the form of a prohibition on becoming a shareholder, management, and/or employee in an LJK in the Capital Market sector for 3 years because she was proven as the party causing PT NAM to commit the violation as referred to in number 2 letter j above.
   
   
7. To Mr. Dimay Vito as President Director of PT Narada Adikara Indonesia (NAI) and PT NAM IT & Research Employees are subject to Administrative Sanctions in the form of a Penalty of Rp635.000.000,00 (six hundred and thirty-five million rupiah) and Written Order in the form of a prohibition on becoming a shareholder, management and /or employees at LJK in the Capital Market sector for 3 years because he was proven as the party that caused PT NAM to commit violations as referred to in numbers 2 letters b, c, f, g, h, j, k, l and r above
   
   
8. To Mr. Bhisma Waskita Jati as Finance Director of PT NAI and Head of HRD PT NAM is subject to Administrative Sanctions in the form of a Penalty of Rp220.000.000,00 (two hundred and twenty million rupiah) and Written Order in the form of a prohibition on becoming a shareholder, management and/ or an employee at an LJK in the Capital Markets sector for 3 years because he was proven as the party that caused PT NAM to commit the violations as referred to in number 2 letters j, n, and r above.
    
9. To Mr. Arif Kurniawan as Research Analyst at PT NAM is subject to Administrative Sanctions in the form of a Penalty of Rp140.000.000,00 (one hundred and forty million rupiah) as well as Revocation of his Broker-Dealer Representative License, and Written Order in the form of a prohibition on becoming a shareholder, management and/ or an employee at an LJK in the Capital Markets sector for 3 years because he was proven as the party that caused PT NAM to commit the violation as referred to in number 2 letter j and n above.
   
   
10. To Mr. Indra Prasetiya as the Trade Function Coordinator of PT NAM is subject to Administrative Sanctions in the form of a Penalty of Rp60.000.000,00 (sixty million rupiah), as well as Revocation of his Broker-Dealer Representative License, and Written Order in the form of a prohibition on becoming a shareholder, management and/or employee in an LJK in the Capital Markets sector for 3 years because he was proven as the party causing PT NAM to commit the violation as referred to in number 2 letter j above.
    
    
11. To Mr. I Ketut Mahendra as Fund Manager of PT NAM was subject to Administrative Sanctions in the form of a Penalty of Rp60.000.000,00 (sixty million rupiah) and Written Order in the form of a prohibition on becoming a shareholder, management and/or employee in an LJK in the Capital Markets sector for 3 years because he was proven as the party causing PT NAM to commit the violation as referred to in number 2 letter j above.
    
    
12. To Mr. Made Adi Wibawa as the President Commissioner of PT NAM is subject to Administrative Sanctions in the form of a Penalty of Rp1.200.000.000,00 (one billion and two hundred million rupiah) and Written Order in the form of a prohibition on becoming a shareholder, management and/or employee in LJK in the Capital Market sector for 5 years because he was proven as the party that caused PT NAM to commit the violations as referred to in numbers 2 letters b, c, f, g, h, j, k, m, n, p, q and r above.