Financial Services Authority Circular Number 16/SEOJK.05/2020 Concerning Business Plans of Pawnshop Companies

To:
The Board of Directors of Pawnshop Companies at their place.

COPY

CIRCULAR LETTER OF THE FINANCIAL SERVICES AUTHORITY REPUBLIC OF INDONESIA NUMBER 16/SEOJK.05/2020

CONCERNING

BUSINESS PLANS OF PAWNSHOP COMPANIES

In connection with the mandate of Article 7 paragraph (3), Article 14 paragraph (5), Article 15 paragraph (5), and Article 19 of the Financial Services Authority Regulation Number 24/POJK.05/2019 concerning Business Plans of Non-Bank Financial Service Institutions (State Gazette of the Republic of Indonesia Year 2019 Number 175, Supplement to the State Gazette of the Republic of Indonesia Number 6392), it is necessary to regulate the scope of business plans, the format and structure of business plan realization reports, the format and structure of business plan supervision reports, and the procedures for submitting business plans, adjusting business plans, changing business plans, reporting business plan realization, and reporting business plan supervision for pawnshop companies in the Financial Services Authority Circular Letter as follows:

I. GENERAL PROVISIONS

In this Financial Services Authority Circular Letter, the following terms are defined as:

1. Pawnshop Business is all business concerning the provision of loans secured by movable goods, safekeeping services, appraisal services, and/or other services, including those conducted based on Sharia principles.

2. Pawnshop Company is a private pawnshop company and a government pawnshop company that is regulated and supervised by the Financial Services Authority.

3. Private Pawnshop Company is a legal entity conducting Pawnshop Business.

4. Government Pawnshop Company is PT Pegadaian (Persero) as referred to in the Staatsblad Year 1928 Number 88 concerning Pandhuis Reglement and Government Regulation Number 51 of 2011 concerning the Change of Legal Entity Form of the State-Owned Enterprise (Perum) Pegadaian into a State-Owned Limited Liability Company (Persero).

5. Sharia Principle is Islamic law provisions based on fatwas and/or Sharia compliance statements from the National Sharia Council of the Indonesian Ulema Council.

6. Sharia Business Unit, hereinafter abbreviated as UUS, is a working unit of the headquarters of the Government Pawnshop Company that functions as the parent office of offices conducting Pawnshop Business activities based on Sharia Principles.

7. Pawn (Gadai) is a right obtained by the Pawnshop Company over a movable good, which is handed over to it by the customer or their proxy, as collateral for their loan, and which grants the Pawnshop Company the authority to take repayment of the loan from that good ahead of other creditors, with the exception of costs for auctioning or selling the good and costs for preserving the good incurred after the good is handed over as collateral, which costs must be prioritized.

8. Board of Directors:
   a. for Pawnshop Companies in the form of a limited liability company, is the Board of Directors as referred to in Law Number 40 of 2007 concerning Limited Liability Companies; or b. for Pawnshop Companies in the form of a cooperative legal entity, is the Management as referred to in Law Number 25 of 1992 concerning Cooperatives.

9. Board of Commissioners:
   a. for Pawnshop Companies in the form of a limited liability company, is the Board of Commissioners as referred to in Law Number 40 of 2007 concerning Limited Liability Companies; or b. for Pawnshop Companies in the form of a cooperative legal entity, is the Supervisors as referred to in Law Number 25 of 1992 concerning Cooperatives.

10. Business Plan is a written document describing the development plan and business activities of the Pawnshop Company over a certain period, as well as strategies to realize such plans according to established targets and timeframes.

11. Business Plan Realization Report is a report compiled by the Board of Directors regarding the realization of the Business Plan up to a certain period.

12. Business Plan Supervision Report is a report from the Board of Commissioners regarding the results of supervision concerning the implementation of the Business Plan up to a certain period.

II. SCOPE OF BUSINESS PLAN

1. The Scope of the Business Plan must at least include:
   a. executive summary; b. evaluation of the implementation of the previous period's Business Plan;
   c. vision, mission, and business strategy;
   d. policies and management plans, including:

   1. business activity plans;
   2. plans for developing or expanding business activities;
   3. capital plans;
   4. funding plans;
   5. plans for developing and/or changing office networks or distribution channels;
   6. plans for organizational development, human resources, and/or information technology; and
   7. plans for activities to increase financial literacy and inclusion;
      e. projected financial statements along with the assumptions used; f. projected ratios and specific items; and g. other information.

2. The executive summary as referred to in item 1 letter a contains a brief explanation of the main points of the Business Plan presented concisely to enable a comprehensive understanding of the Business Plan, which includes among others:
   a. strategic plans and steps to be taken by the Pawnshop Company in the short term (1-year period), medium term (3-year period), and long term (5-year period); b. key financial indicators; and
   c. description of short-term targets (1-year period).

3. The executive summary as referred to in item 2 is compiled according to Format 1 as contained in the Appendix, which is an integral part of this Financial Services Authority Circular Letter.

4. The evaluation of the implementation of the previous period's Business Plan as referred to in item 1 letter b contains explanations regarding:
   a. main points of the realization of the previous period's Business Plan; b. obstacles and problems faced in the previous period; and
   c. measures taken to overcome such obstacles and problems.

5. The evaluation of the implementation of the previous period's Business Plan as referred to in item 4 is compiled according to Format 2 as contained in the Appendix, which is an integral part of this Financial Services Authority Circular Letter.

6. The vision, mission, and business strategy as referred to in item 1 letter c contains explanations regarding:
   a. vision, which is the goal the Pawnshop Company wants to achieve in the long term; b. mission, which is the method used in the short or medium term to achieve the goal;
   c. business strategy, which is the strategy and policy direction of the Pawnshop Company in facing business competition and social dynamics in the future, which must at least include:

   1. analysis of the Pawnshop Company's position in facing business competition, including information regarding the Pawnshop Company's position within the same business group or industry, including information regarding problems and obstacles faced by the Pawnshop Company;
   2. policy direction of the Pawnshop Company, including general information on policies established by management for the development of Pawnshop Business in the future; and
   3. business development strategy, which among others contains information regarding:
      a. strategic steps to achieve the established business goals of the Pawnshop Company; b. explanation regarding organizational development and information system technology strategies; and
      c. strategies to anticipate changes in external conditions.

7. In compiling the analysis of the Pawnshop Company's position in facing business competition as referred to in item 6 letter c item 1), the Pawnshop Company may use relevant strategic planning analysis methods.

8. The vision, mission, and business strategy as referred to in item 6 is compiled according to Format 3 as contained in the Appendix, which is an integral part of this Financial Services Authority Circular Letter.

9. The business activity plan as referred to in item 1 letter d item 1) contains explanations regarding the Pawnshop Business activity plans which must at least include:
   a. plans for disbursing loans secured based on Pawn law; b. plans for disbursing loans secured based on fidusia;
   c. plans for providing safekeeping services for valuable goods;
   d. plans for providing appraisal services; e. plans for other activities not related to Pawnshop Business that generate fee-based income, provided they do not conflict with financial services legislation; and f. plans for other business activities with the approval of the Financial Services Authority.

10. The business activity plan as referred to in item 9 is compiled according to Format 4 as contained in the Appendix, which is an integral part of this Financial Services Authority Circular Letter.

11. The plan for developing or expanding business activities as referred to in item 1 letter d item 2) must at least include:
    a. plans for implementing other activities not related to Pawnshop Business that generate fee-based income, provided they do not conflict with financial services legislation; b. plans for using contracts (akad) that have not been used before, which must first obtain approval from the Financial Services Authority; and
    c. plans for implementing other business activities with the approval of the Financial Services Authority.

12. The plan for developing or expanding business activities as referred to in item 11 is compiled according to Format 5 as contained in the Appendix, which is an integral part of this Financial Services Authority Circular Letter.

13. The capital plan as referred to in item 1 letter d item 3) must at least include:
    a. capital projections; and b. plans for capital changes.

14. The capital plan as referred to in item 13 is compiled according to Format 6 as contained in the Appendix, which is an integral part of this Financial Services Authority Circular Letter.

15. The funding plan as referred to in item 1 letter d item 4) must at least include:
    a. funding plans based on funding sources; and b. funding plans based on funding contracts, for Sharia pawnshop companies, Government Pawnshop Companies possessing a UUS, and Private Pawnshop Companies conducting some business activities based on Sharia Principles.

16. The funding plan as referred to in item 15 is compiled according to Format 7 as contained in the Appendix, which is an integral part of this Financial Services Authority Circular Letter.

17. The plan for developing and/or changing office networks or distribution channels as referred to in item 1 letter d item 5) must at least include:
    a. plans for opening service units (outlets); b. plans for changing the address of the headquarters and/or service units (outlets); and
    c. plans for closing service units (outlets).

18. The plan for developing and/or changing office networks or distribution channels as referred to in item 17 is compiled according to Format 8 as contained in the Appendix, which is an integral part of this Financial Services Authority Circular Letter.

19. The plan for organizational, human resources, and/or information technology development as referred to in item 1 letter d item 6) must at least include:
    a. organizational development plans, among others:

    1. plans for forming work units/divisions;
    2. plans for changing work units/divisions; and
    3. plans for forming committees;
       b. human resources development plans, among others:
    4. plans for fulfilling human resources:
       a) recruitment plans; b) plans for appointment and dismissal of employees; c) plans for using consultants and/or advisors; and d) plans for using contract workers;
    5. human resources education and training plans:
       a) plans for human resources education and training needs; and b) plans for human resources education and training costs/budgets;
    6. plans for utilizing outsourced labor; and
       c. information technology development plans, which are plans for fundamental development and procurement of information technology, including information regarding development and maintenance costs, among others:
    7. significant changes to the configuration of core information technology or applications of the Pawnshop Company;
    8. procurement of new core applications;
    9. cooperation with information technology service providers; and
    10. other fundamental information technology development and procurement that can add and/or increase the Pawnshop Company's risk.

20. The plan for organizational, human resources, and/or information technology development as referred to in item 19 is compiled according to Format 9 as contained in the Appendix, which is an integral part of this Financial Services Authority Circular Letter.

21. The plan for activities to increase financial literacy and inclusion for Pawnshop Companies as referred to in item 1 letter d item 7) is compiled according to the format regulated in the Financial Services Authority Circular Letter concerning the implementation of activities to increase financial literacy in the financial services sector and the Financial Services Authority Circular Letter concerning the implementation of activities to increase financial inclusion in the financial services sector.

22. The projected financial statements along with the assumptions used as referred to in item 1 letter e must at least contain:
    a. assumptions used in compiling the financial projections, including:

    1. macro assumptions, including gross domestic product growth assumptions, interest rate levels, gold prices, and USD exchange rates; and
    2. micro assumptions, including the growth of Pawn business activities and the growth of fidusia business activities; and
       b. information regarding the financial condition of the Pawnshop Company, including:
    3. projected balance sheets;
    4. projected comprehensive income statements; and
    5. projected cash flow statements.

23. The projected financial statements along with the assumptions used as referred to in item 22 is compiled according to Format 10 as contained in the Appendix, which is an integral part of this Financial Services Authority Circular Letter.

24. The projected ratios and specific items as referred to in item 1 letter f is compiled according to Format 11 as contained in the Appendix, which is an integral part of this Financial Services Authority Circular Letter.

25. The Business Plan containing:
    a. key financial indicators in the executive summary as referred to in item 2 letter b; b. business activity plans as referred to in item 9;
    c. capital plans as referred to in item 13;
    d. funding plans as referred to in item 15; e. projected financial statements along with the assumptions used as referred to in item 22; and f. projected ratios and specific items as referred to in item 24; is presented:

    1. for actual positions at the end of September of the Business Plan preparation year;
    2. for projections at the end of December of the Business Plan preparation year;
    3. for projections for the next 1 (one) year presented semi-annually; and
    4. in Indonesian Rupiah.

26. Other information as referred to in item 1 letter g must at least include information that needs to be submitted because it affects Pawnshop Business activities, but is not included in the scope of the Business Plan as referred to in item 1 letters a through f, among others:
    a. plans for merger, consolidation, and/or separation; b. plans for conducting some business activities based on Sharia Principles or discontinuing some business activities based on Sharia Principles; and
    c. plans for changing business activities so that it is no longer a Pawnshop Company.

27. The plan for merger, consolidation, and/or separation as referred to in item 26 letter a is compiled according to Format 12 as contained in the Appendix, which is an integral part of this Financial Services Authority Circular Letter.

28. The plan for conducting some business activities based on Sharia Principles or discontinuing some business activities based on Sharia Principles as referred to in item 26 letter b is compiled according to Format 13 as contained in the Appendix, which is an integral part of this Financial Services Authority Circular Letter.

29. The plan for changing business activities so that it is no longer a Pawnshop Company as referred to in item 26 letter c is compiled according to Format 14 as contained in the Appendix, which is an integral part of this Financial Services Authority Circular Letter.

30. The description of the scope of the Business Plan including:
    a. business activity plans as referred to in item 1 letter d item 1); b. plans for developing or expanding business activities as referred to in item 1 letter d item 2);
    c. capital plans as referred to in item 1 letter d item 3);
    d. funding plans as referred to in item 1 letter d item 4); e. plans for developing and/or changing office networks or distribution channels as referred to in item 1 letter d item 5); f. plans for organizational, human resources, and/or information technology development as referred to in item 1 letter d item 6); g. plans for merger, consolidation, and/or separation as referred to in item 26 letter a; h. plans for conducting some business activities based on Sharia Principles or discontinuing business activities based on Sharia Principles as referred to in item 26 letter b; and
    i. plans for changing business activities so that it is no longer a Pawnshop Company as referred to in item 26 letter c;
    also contains descriptions regarding:
    a. reasons or considerations used in compiling the aforementioned plans; and b. the Pawnshop Company's strategy to realize the aforementioned plans.

31. For Government Pawnshop Companies possessing a UUS, the Business Plan must contain information regarding the Business Plan for business activities conducted based on Sharia Principles, which is an integral part of the Business Plan.

32. For Private Pawnshop Companies conducting some business activities based on Sharia Principles, the Business Plan must contain information regarding the Business Plan for the conduct of some business activities based on Sharia Principles, which is an integral part of the Business Plan.

33. In the event there is other information that needs to be submitted by the Pawnshop Company in the Business Plan, but its format is not regulated in this Financial Services Authority Circular Letter, the format for submitting such information is compiled based on the Pawnshop Company's needs.

III. FORMAT AND STRUCTURE OF BUSINESS PLAN REALIZATION REPORTS AND BUSINESS PLAN SUPERVISION REPORTS

1. The Business Plan Realization Report includes:
   a. explanations regarding the achievement of the Business Plan, namely the comparison between the plan and the realization of the Business Plan; b. explanations regarding deviations in the realization of the Business Plan, namely explanations regarding the causes and obstacles of deviations between the plan and the realization of the Business Plan;
   c. follow-up actions on the achievement of the Business Plan, namely follow-up efforts that have been and will be taken to improve the realization achievement of the Business Plan;
   d. financial ratios and specific items; and e. other information, which among others contains information that needs to be submitted because it affects the realization of the Business Plan, but has not yet been included in the scope of the Business Plan Realization Report as referred to in letters a through d.

2. For Government Pawnshop Companies possessing a UUS, the Business Plan Realization Report must also contain a specific realization report for the UUS, which is an integral part of the Business Plan Realization Report.

3. For Private Pawnshop Companies conducting some business activities based on Sharia Principles, the Business Plan Realization Report must also contain a specific realization report for the conduct of some business activities based on Sharia Principles, which is an integral part of the Business Plan Realization Report.

4. The Business Plan Realization Report must be signed by members of the Board of Directors.

5. The Business Plan Realization Report is compiled according to Format 15 as contained in the Appendix, which is an integral part of this Financial Services Authority Circular Letter.

6. The Business Plan Supervision Report must at least include the Board of Commissioners' assessment regarding:
   a. the realization of the Business Plan both quantitatively and qualitatively; b. factors affecting the performance of the Pawnshop Company; and
   c. efforts to improve the performance of the Pawnshop Company.

7. For Pawnshop Companies possessing a UUS, the Business Plan Supervision Report must also contain a specific supervision report for the UUS, which is an integral part of the Business Plan Supervision Report.

8. For Private Pawnshop Companies conducting some business activities based on Sharia Principles, the Business Plan Supervision Report must also contain a specific supervision report for the conduct of some business activities based on Sharia Principles, which is an integral part of the Business Plan Supervision Report.

9. The Business Plan Supervision Report must be signed by members of the Board of Commissioners.

10. The Business Plan Supervision Report is compiled according to Format 16 as contained in the Appendix, which is an integral part of this Financial Services Authority Circular Letter.

IV. PROCEDURES FOR SUBMISSION OF BUSINESS PLANS, ADJUSTMENT OF BUSINESS PLANS, CHANGES TO BUSINESS PLANS, BUSINESS PLAN REALIZATION REPORTS, AND BUSINESS PLAN SUPERVISION REPORTS

1. Pawnshop Companies must submit Business Plans, adjustments to Business Plans, changes to Business Plans, Business Plan Realization Reports, and Business Plan Supervision Reports

Business to the Financial Services Authority (OJK) online through the OJK data communication network system.

2. Pawnshop Companies must ensure that the Business Plan submitted online as referred to in item 1 is correct and identical to the printed (hardcopy) Business Plan document.

3. In the event that the OJK data communication network system as referred to in item 1 is not yet available or experiences technical difficulties, the submission of the Business Plan, adjustment of the Business Plan, change of the Business Plan, Business Plan Realization Report, and Business Plan Supervision Report to the Financial Services Authority is conducted offline through the following methods:
   a. submitted directly; or b. sent via a courier service company.

4. In the event of technical difficulties as referred to in item 3, the Financial Services Authority announces this through the OJK website.

5. The submission of documents offline as referred to in item 3 must be submitted in electronic data (softcopy) format using media such as a compact disc (CD) or other electronic data storage media.

6. The submission of reports as referred to in item 5 must be accompanied by a printed (hardcopy) cover letter signed by the Board of Directors.

7. The submission of the cover letter and the Business Plan, adjustment of the Business Plan, change of the Business Plan, Business Plan Realization Report, and Business Plan Supervision Report offline as referred to in item 3 is addressed to:
   a. for Government Pawnshop Companies and Private Pawnshop Companies:

Executive Head of Insurance, Pension Funds, Financing Institutions, and Other Financial Services Supervision Financial Services Authority u.p. Director of Special Financial Institution Supervision Wisma Mulia 2 Building, 15th Floor Jalan Jenderal Gatot Subroto Kav. 40 Jakarta 12710; and b. for Sharia Pawnshop Companies, Private Pawnshop Companies conducting part of their business activities based on Sharia Principles, and Government Pawnshop Companies having a Sharia Business Unit (UUS):

Executive Head of Insurance, Pension Funds, Financing Institutions, and Other Financial Services Supervision Financial Services Authority u.p. Director of Sharia Special Financial Institution Supervision (IKNB Syariah) Wisma Mulia 2 Building, 15th Floor Jalan Jenderal Gatot Subroto Kav. 40 Jakarta 12710.

8. In the event of a change in the address of the Financial Services Authority's office for report submission as referred to in item 7, the Financial Services Authority provides notification regarding the address change via letter or announcement.

9. Pawnshop Companies are deemed to have submitted the Business Plan, adjustment of the Business Plan, change of the Business Plan, Business Plan Realization Report, and Business Plan Supervision Report with the following provisions:
   a. for online submission through the OJK data communication network system, proven by a receipt from the OJK data communication network system; or b. for offline submission, proven by a receipt from the Financial Services Authority.

This copy is consistent with the original
Legal Director 1
Legal Department signed
Mufli Asmawidjaja

V. CLOSING
The provisions in this Financial Services Authority Circular shall take effect from the date of establishment. Established in Jakarta on August 7, 2020 EXECUTIVE HEAD OF INSURANCE, PENSION FUNDS, FINANCING INSTITUTIONS, AND OTHER FINANCIAL SERVICES SUPERVISION FINANCIAL SERVICES AUTHORITY REPUBLIC OF INDONESIA, signed RISWINANDI

APPENDIX
FINANCIAL SERVICES AUTHORITY CIRCULAR LETTER
REPUBLIC OF INDONESIA
NUMBER 16 /SEOJK.05/2020
REGARDING
BUSINESS PLAN OF PAWNSHOP COMPANIES

TABLE OF CONTENTS
BUSINESS PLAN FORMAT OF PAWNSHOP COMPANIES
Format 1: Executive Summary 2
Format 2: Evaluation of Previous Period Business Plan Implementation Format 3: Vision, Mission, and Business Strategy 6 Format 4: Business Activity Plan 7 Format 5: Business Activity Development or Expansion Plan Format 6: Capital Plan 15 Format 7: Financing Plan 17 Format 8: Office Network or Distribution Channel Development and/or Change Plan Format 9: Organization, Human Resources, and/or Information Technology Development Plan Format 10: Financial Report Projections and Assumptions Used Format 11: Projection of Ratios and Specific Items 39 Format 12: Merger, Consolidation, and/or Separation Plan Format 13: Plan to Conduct Part of Business Activities Based on Sharia Principles or Cease Part of Business Activities Based on Sharia Principles Format 14: Plan to Change Business Activities so that the Entity is No Longer a Pawnshop Company Format 15: Business Plan Realization Report 46 Format 16: Business Plan Supervision Report 47

Format 1: Executive Summary

1. Strategic plans and steps to be taken by the Pawnshop Company
   a. Short-term (1-year) period strategic plans and steps

1. ..........
2. ..........
3. etc.
   b. Medium-term (3-year) period strategic plans and steps
4. ..........
5. ..........
6. etc.
   c. Long-term (5-year) period strategic plans and steps
7. ..........
8. ..........
9. etc.

2. Key Financial Indicators
   a. Key financial indicator format for Pawnshop Companies No. Financial Indicator Actual Sep X-1 Projection Dec X-1 Jun X Dec X
3. Debt to Asset Ratio 1)
4. Debt to Equity Ratio 2)
5. Profitability
   a. Return on Asset

3. b. Return on Equity 4)
   c. Operating Expenses
   against Operating Income

4. Liquidity
   a. Current Ratio 5) b. Cash Ratio 6)
   Notes:
   X-1: Year of report preparation.
   X: Year of Business Plan position.

1. Debt to Asset Ratio = total liabilities / total assets
2. Debt to Equity Ratio = total liabilities / total equity
3. Return on Asset = net profit / total assets
4. Return on Equity = net profit / total equity
5. Current Ratio = current liabilities / current assets
6. Cash Ratio = current liabilities / cash and cash equivalents
   b. Description of the Pawnshop Company's financial condition (description of the Pawnshop Company's financial condition along with projections reflected in key financial indicators)

3. Description of short-term (1-year) period targets 1)
   a. ...........................................................................................................
   b. ...........................................................................................................
   c. etc.
   Notes:

1. includes, among others, sales revenue, loan balance amount, number of consumers, and number of pledged goods.

Format 2: Evaluation of Previous Period Business Plan Implementation (to be filled with an explanation regarding the main points of the previous period's business plan realization, constraints and problems faced, and actions taken to overcome such constraints and problems)

Format 3: Vision, Mission, and Business Strategy

1. Vision of the Pawnshop Company
   ....................................................................................................................
   ....................................................................................................................
2. Mission of the Pawnshop Company
   ....................................................................................................................
   ....................................................................................................................
3. Business Strategy
   a. Analysis of the Pawnshop Company's position in facing business competition
   ...........................................................................................................
   ...........................................................................................................
   b. Policy direction of the Pawnshop Company
   ...........................................................................................................
   ...........................................................................................................
   c. Business development strategy
   ...........................................................................................................
   ...........................................................................................................

Format 4: Business Activity Plan

1. Business activity plan based on activity type
   a. Table of Pawnshop Company business activity plan Type of Use Actual Sep X-1 Projection Dec X-1 Jun X Dec X A. Plan for disbursing loans with pledge guarantees based on pledge law. B. Plan for disbursing loans with fiduciary guarantees based on fiduciary law.
   C. Plan for providing safekeeping services for valuable goods.
   D. Plan for providing appraisal services.
   E. Plan for other activities not related to Pawnshop Business that provide commission-based income (fee based income) F. Plan for other business activities with the approval of the Financial Services Authority Notes:
   X-1: Year of report preparation
   X: Year of Business Plan position

2. Reasons/considerations
   for business activities)

3. Strategy
   (to be filled with strategies to realize the business activity plan)

Format 5: Business Activity Development or Expansion Plan

1. Plan for implementing other activities not related to Pawnshop Business that provide commission-based income (fee based income) as long as they do not conflict with financial services laws and regulations.
   a. Table of other activities not related to Pawnshop Business that provide commission-based income (fee based income) as long as they do not conflict with financial services laws and regulations. No. Type of Business Activity 1) General Description of Business Activity 2) Time of Implementation of Business Activity Objective of Business Activity 3) Relevance of Business Activity with Business Strategy of the Company 2) Risks of Implementation of Business Activity 2) Risk Mitigation for Implementation of Business Activity 2) For the Company For the Debtor 1. 2. Notes:

1. Types of other business activities that have received approval from the Financial Services Authority (example: as a mutual fund sales agent in the context of fee based) refer to the Financial Services Authority Regulation regarding Pawnshop Business.

1. Development of conventional/Sharia pawnshop business products; and/or
2. Cooperation in the context of business acquisition

2. More detailed explanations/descriptions can be attached in separate sheets.
3. Can be filled with government assignment details, Development of conventional/Sharia pawnshop business products; and/or Cooperation in the context of business acquisition.

implementation of other activities not related to Pawnshop Business that provide commission-based income (fee based income) as long as they do not conflict with financial services laws and regulations)
c. Strategy
(to be filled with strategies to realize the implementation of other activities not related to Pawnshop Business that provide commission-based income (fee based income) as long as they do not conflict with financial services laws and regulations)

2. Plan for using previously unused agreements that must first obtain approval from the Financial Services Authority.
   a. Table of plans for using previously unused agreements that must first obtain approval from the Financial Services Authority. No. Type of Business Activity 1) General Description of Business Activity 2) Time of Implementation of Business Activity Objective of Business Activity Relevance of Business Activity with Business Strategy of the Company 2) Risks of Implementation of Business Activity 2) Risk Mitigation for Implementation of Business Activity 2) For the Company For the Debtor 1. 2. 3. 4. Etc. Notes:

1. Types of business activities include:
   a. Plan for implementing new Pawnshop Business activities; and b. plan for using other agreements that must first obtain approval from the Financial Services Authority;
2. More detailed explanations/descriptions can be attached in separate sheets.

use of previously unused agreements that must first obtain approval from the Financial Services Authority)
c. Strategy
(to be filled with strategies to realize the plan for using agreements that have not been used previously that must first obtain approval from the Financial Services Authority)

3. Plan for implementing other business activities with the approval of the Financial Services Authority.
   a. Table of plans for other business activities with the approval of the Financial Services Authority.
   No.
   Type of
   Business Activity 1)
   General Description of Business Activity 2)
   Time of Implementation of Business Activity
   Objective of Business Activity
   Relevance of Business Activity with Business Strategy of the Company 2) Risks of Implementation of Business Activity 2) Risk Mitigation for Implementation of Business Activity 2) For the Company For the Debtor 1. 2. 3. 4. Etc. Notes:

1. Types of other business activities referred to are not yet regulated in the Financial Services Authority Regulation regarding Pawnshop Business
2. More detailed explanations/descriptions can be attached in separate sheets.

implementation of other business activities based on approval from the Financial Services Authority)
c. Strategy
(to be filled with strategies to realize the plan for implementing other business activities based on approval from the Financial Services Authority)

Format 6: Capital Plan

1. Capital projection
   Notes*) Actual
   Sept X-1 Projection
   Dec X-1 Jun X Dec X
   Initial paid-in capital
   Existing shareholders
2. ...
3. etc.
   New shareholders
4. ...
5. etc.
   Total paid-in capital
   Retained earnings 1)
   Total Equity
   Notes:
   X-1: Year of report preparation.
   X: Year of Business Plan position.

1. the stated nominal value is the accumulated nominal value.
   *) For legal entity cooperatives, the terminology used adjusts accordingly

2. Plan for Capital Change
   a. Description regarding the plan for capital change (to be filled with the plan for capital change, accompanied by the plan for nominal amounts and the plan for the timing of capital change implementation) change of capital implementation)

c. Strategy
(to be filled with strategies to realize the plan for capital change implementation)

Format 7: Financing Plan

1. Financing plan based on funding sources
   a. Table of financing plan based on funding sources for Pawnshop Companies Type of Funding Actual Sep X-1 Projection Dec X-1 Jun X Dec X A. New funding receipts:
2. Loans from government institutions
3. Loans from state-owned enterprises or
   local government-owned enterprises
4. Loans from banks
5. Waqf and/or donations
6. Others*)
   Total New Funding Receipts
   B. Balance of funding receipts
   (outstanding):
7. Loans from government institutions
8. Loans from state-owned enterprises or
   local government-owned enterprises
9. Loans from banks
10. Waqf and/or donations
11. Others
    Total balance of funding receipts (outstanding) Notes:
    *) : others: for example, deposits from private loans to banking institutions X-1: Year of report preparation X: Year of Business Plan position

b. Table of financing plan based on funding sources for Sharia Pawnshop Companies, Government Pawnshop Companies having a Sharia Business Unit (UUS), and Private Pawnshop Companies conducting part of their business activities based on Sharia Principles. Type of Funding Actual Sep X-1 Projection Dec X-1 Jun X Dec X A. New funding receipts:

1. Funding from government institutions
2. Funding from state-owned enterprises or
   local government-owned enterprises
3. Funding from banks
4. Waqf and/or donations
5. Others
   Total new funding receipts
   B. Balance of funding receipts (outstanding)
6. Funding from government institutions
7. Funding from state-owned enterprises or
   local government-owned enterprises
8. Funding from banks
9. Waqf and/or donations
10. Others
    Total balance of funding receipts (outstanding)

c. Reasons/Considerations
for financing based on funding sources) d. Strategy (to be filled with strategies to realize the financing plan based on funding sources)

2. Financing Plan based on Financing Agreements for Sharia pawnshop companies, Government Pawnshop Companies
   having a Sharia Business Unit (UUS), and Private Pawnshop Companies conducting part of their business activities based on Sharia Principles. a. financing plan based on financing agreements Type of Funding Actual Sep X-1 Projection Dec X-1 Jun X Dec X A. New funding receipts:
3. Mudharabah Agreement
4. Mudharabah Musytarakah Agreement
5. Musyarakah Agreement
6. Ijarah Agreement
7. Qardh Agreement
8. Other Financing Agreements
   B. Balance of funding receipts (outstanding):
9. Mudharabah Agreement
10. Mudharabah Musytarakah Agreement
11. Musyarakah Agreement
12. Ijarah Agreement
13. Qardh Agreement
14. Other Financing Agreements

financing based on agreements)
c. Strategy
(to be filled with strategies to realize the financing plan based on agreements)

Format 8: Office Network or Distribution Channel Development and/or Change Plan a. Table of office network or distribution channel development and/or change plan Description Number of outlets Time of Implementation 1) Estimated Investment/ Cost 2) Location 3) Notes 4) Opening of service units (outlets) Change of Address of head office and/or service units (outlets) Closing of service units (outlets) Notes:

1. To be filled with the month of the planned implementation time.
2. To be filled with all costs required for the opening of service units (outlets) and additional operational costs resulting from the opening of new service units (outlets). Example: costs consist of:
   a) initial capital (licensing costs, rental or purchase location costs, human resource provision costs, fixed asset purchase costs, etc.) at the time of opening the service unit (outlet). b) working capital needed for the operation of the service unit (outlet) for a certain period until the said outlet can meet its own needs as established by the pawnshop company (overhead costs of the service unit (outlet), employee salaries, etc.).
3. For locations within the DKI Jakarta region, at least the name of the province DKI Jakarta must be stated.
   For locations outside the DKI Jakarta region, at least the name of the Regency/City must be included.
4. Detailed notes can be attached in separate sheets.

development and/or change of office network or distribution channels)
c. Strategy
(to be filled with strategies to realize the plan for development and/or change of office network or distribution channels)

Format 9: Organization, Human Resources, and/or Information Technology Development Plan

1. Organization Development Plan
   a. Description regarding the plan for organization development:
   (to be filled with an explanation regarding the plan for organization development, including plans for the formation of work units/divisions, plans for changing work units/divisions, and plans for forming committees, adjusted to the size and complexity of the Pawnshop Company's business) development of organization)
   c. Strategy
   (to be filled with strategies to realize the plan for organization development)

2. Human Resources Development Plan
   a. Plan for fulfilling human resources

1. Description regarding the plan for fulfilling human resources
   (to be filled with an explanation regarding the plan for recruitment, appointment and dismissal of employees, use of consultants and/or advisors, and use of contract employees of the Pawnshop Company)
2. Reasons/considerations
   for fulfilling human resources)
3. Strategy
   (to be filled with strategies to realize the plan for fulfilling human resources)

b. Plan for education and training of human resources

1. Table of education and training needs plan and costs/budget for education and training of human resources
   No. Material
   Training 1) Method of Training 2)
   Model of Training 3)
   Estimated Time of Training 4)
   Duration of Training 5) Location
   Speaker/
   Institution of Training
   Number of employees participating
   Cost of Training

Notes:

1. Example: appraiser certification, risk management, marketing, etc.

2. To be filled with online or offline

3. To be filled with in-house training or out-house training

4. To be filled with the month of training implementation, e.g., March 2020

5. To be filled with the duration of training, e.g., 3 days
   .

6. Reasons/considerations
   for education and training of human resources)

7. Strategy
   (to be filled with strategies to realize the plan for education and training of human resources)

c. Plan for Utilization of Outsourced Labor

1. Table of Plan for Utilization of Outsourced Labor
   No. Field of
   Work
   Reasons for Utilization of Outsourced
   Labor
   Number of
   Outsourced
   Labor
   Name of
   Provider Company of Outsourced
   Labor
   (if any)
   Duration of
   Agreement with
   Outsourced Labor
   Company

2. Reasons/considerations
   for utilization of outsourced labor)
3. Strategy
   (to be filled with strategies to realize the plan for utilization of outsourced labor)

3. Information Technology Development Plan
   a. Description regarding the plan for development and procurement of fundamental information technology, including information regarding the costs of development and maintenance of information technology (To be filled with the plan for development and procurement of fundamental information technology, including: significant changes to the configuration of core information technology or applications, procurement of new core applications, cooperation with information technology service providers, and development and procurement of other fundamental information technology that can add and/or increase the risks of the Pawnshop Company. Additionally, information regarding estimated costs for information technology development must be filled in.)

Example: Application Development
No. Name of Application Description
Type of
Development
(New /
Change)
Developer
(inhouse / IT
Service Provider)
Third Party
Information Technology
Service Provider (IT SP)
Time of
Planned
Implementation
Estimated Cost of Development Notes
(1) (2) (3) (4) (5) (6) (7) (8) (9)
1.
2.
Notes:
(1) Serial number.
(2) Name of Application/infrastructure to be developed.
(3) Detailed explanation of the Application/infrastructure to be developed.
(4) Type of Development: new or change/development of existing applications.
(5) In-house developer = conducted by the internal company, or IT SP = by Information Technology Service Provider/Vendor (6) Name of IT SP Third Party (7) To be filled with Quarter I/II/III/IV (8) To be filled with estimated development costs for 1 year

b. Reasons and Considerations for development and procurement of fundamental information technology)
c. Strategy
(to be filled with strategies to realize the plan for development and procurement of fundamental information technology)

Format 10: Financial Report Projections and Assumptions Used

1. Assumptions used
   Assumptions
   Actual
   Sept X-1 Projection
   Dec X-1 Jun X Dec X
   Macro Assumptions 1)
   :
2. Gross domestic product growth
3. Interest rate levels
4. Gold prices
5. USD exchange rate
6. Others, detailed per
   type of assumption 2)
   Micro Assumptions:
7. Growth of pledge business activities
8. Growth of fiduciary business activities
9. Others, detailed per
   type of assumption
   Notes:
   X-1: Year of report preparation.
   X: Year of business plan position.

1. in the event that semi-annual assumptions are not available, annual assumptions can be used and may be accompanied by an explanation regarding the source institution that serves as the basis for the macro assumptions used.
2. other macro assumptions, such as Gold Price Projections related to the value of pledged goods for Pledge products and standard appraisal of metals.

2. Information regarding the financial condition of the Pawnshop Company

a. Projection of the financial position report of the Pawnshop Company in the form of a limited liability company, including those conducting business activities based on Sharia Principles.

Account Name	Actual Sept X-1	Projection Des X-1	Projection June X	Projection Des X
A. ASSETS
1. Current Assets
a. cash and cash equivalents
b. investments/Sharia investments
c. loans granted/Sharia loans granted
d. accrued income/Accrued Sharia income
e. other current assets
Total Current Assets
2. Non-Current Assets
a. fixed assets
b. investments in other companies
c. other non-current assets
Total Non-Current Assets
TOTAL ASSETS
B. LIABILITIES
1. Current Liabilities
a. loans received/Sharia loans received
b. other current liabilities
Total Current Liabilities
2. Non-Current Liabilities
a. loans received/Sharia loans received
b. other non-current liabilities
c. customer surplus funds
Total Non-Current Liabilities
TOTAL LIABILITIES
C. EQUITY
1. Paid-in Capital
2. Reserves
3. Profit/(Loss) Balance
4. Other Equity
TOTAL EQUITY
TOTAL LIABILITIES AND EQUITY

b. Projection of the financial position report of the Pawnshop Company in the form of a cooperative, including those conducting business activities based on Sharia Principles.

Account Name	Actual Sept X-1	Projection Des X-1	Projection June X	Projection Des X
A. ASSETS
1. Current Assets
a. cash and cash equivalents
b. investments/Sharia investments
c. loans granted/Sharia loans granted
d. other current assets
Total Current Assets
2. Non-Current Assets
a. fixed assets
b. investments in other companies
c. other non-current assets
Total Non-Current Assets
TOTAL ASSETS
B. LIABILITIES
1. Current Liabilities
a. loans received/Sharia loans received
b. voluntary deposits
c. customer surplus funds
d. other current liabilities
Total Current Liabilities
2. Non-Current Liabilities
a. loans received/Sharia loans received
b. other non-current liabilities
Total Non-Current Liabilities
TOTAL LIABILITIES
C. EQUITY
1. Basic Deposits
2. Mandatory Deposits
3. Reserves
4. Surplus Result of Business for Current Year
5. Other Equity
TOTAL EQUITY
TOTAL LIABILITIES AND EQUITY

3. Projection of Comprehensive Income Statement

a. Projection of the comprehensive income statement of the Pawnshop Company in the form of a Limited Liability Company, including those conducting business activities based on Sharia Principles.

Account Name	Actual Sept X-1	Projection Des X-1	Projection June X	Projection Des X
A. REVENUE
1. Operating Revenue
a. loan interest income/service remuneration
b. administrative income
c. service income
d. other operating income
Total Operating Revenue
2. Non-Operating Revenue
a. deposit interest/service remuneration
b. other non-operating income
Total Non-Operating Revenue
TOTAL REVENUE
B. EXPENSES
1. Operating Expenses
2. Non-Operating Expenses
TOTAL EXPENSES
C. PROFIT/(LOSS) BEFORE TAX
D. INCOME TAX
E. PROFIT/(LOSS) FOR THE PERIOD

b. Projection of the comprehensive income statement of the Pawnshop Company in the form of a Cooperative, including those conducting business activities based on Sharia Principles.

Account Name	Actual Sept X-1	Projection Des X-1	Projection June X	Projection Des X
A. REVENUE
1. Operating Revenue
a. loan interest/service remuneration
b. administrative income
c. service income
d. other operating income
Total Operating Revenue
2. Non-Operating Revenue
a. Deposit Interest/Service Remuneration
b. Other Non-Operating Income
Total Non-Operating Revenue
TOTAL REVENUE
B. EXPENSES
3. Operating Expenses
4. Non-Operating Expenses
TOTAL EXPENSES
C. SURPLUS RESULT OF BUSINESS BEFORE TAX
D. INCOME TAX
E. SURPLUS RESULT OF BUSINESS FOR THE PERIOD

4. Projection of Cash Flow Statement

Description	Actual Sept X-1	Projection Des X-1	Projection June X	Projection Des X
A. CASH FLOWS FROM OPERATING ACTIVITIES
1. cash receipts from operating activities
2. cash payments for operating activities
Total Cash Flows From Operating Activities
B. CASH FLOWS FROM INVESTING ACTIVITIES
1. cash receipts from investing activities
2. cash payments for investing activities
Total Cash Flows From Investing Activities
C. CASH FLOWS FROM FINANCING ACTIVITIES
1. cash receipts from financing activities:
2. cash payments for financing activities
Total Cash Flows From Financing Activities
Net Increase/(Decrease) in Cash and Cash Equivalents
Beginning Balance of Cash and Cash Equivalents
Ending Balance of Cash and Cash Equivalents

Format 11: Projection of Financial Ratios and Specific Items

Ratio and Specific Items	Actual Sept X-1	Projection Des X-1	Projection June X	Projection Des X
1. Liquidity
a. Cash Ratio 1)
b. Current Ratio 2)
2. ROA 3)
3. ROE 4)
4. BOPO
5. Loans/Funding Disbursed (OSL)

Notes:
X-1 is the year of report preparation.
X is the year of the business plan position.

1. Cash Ratio = current liabilities / cash and cash equivalents
2. Current Ratio = current liabilities / current assets
3. Return on Asset = net profit / total assets
4. Return on Equity = net profit / total equity

Format 12: Plan for Merger, Consolidation, and/or Separation

1. Merger Plan
   a. Information regarding the merger plan:
   Pawnshop Company merging into:

1. ....
2. ....
3. ....
   Pawnshop Company receiving the merger: ....
   b. Reasons and Considerations
   (to be filled with reasons/considerations for the merger)
   c. Strategy
   (to be filled with the merger strategy)

2. Consolidation Plan
   a. Information regarding the consolidation plan:
   Pawnshop Company consolidating into:

1. ....
2. ....
3. ....
   Pawnshop Company after consolidation: ....
   b. Reasons, Considerations, and Objectives
   (to be filled with reasons, considerations, and objectives for consolidation)
   c. Strategy and Implementation Steps
   (to be filled with the strategy and implementation steps for consolidation)

3. Separation Plan
   a. Information regarding the separation plan:
   Pawnshop Company separating from: ....
   Pawnshop Company resulting from separation:

1. ...
2. ...
3. etc.
   b. Reasons and Considerations
   (to be filled with reasons/considerations for separation)
   c. Strategy
   (to be filled with the separation strategy)

Format 13: Plan for Conducting Partial Business Activities Based on Sharia Principles or Cessation of Partial Business Activities Based on Sharia Principles

1. Plan for conducting partial business activities based on Sharia Principles
   a. Information regarding the plan for conducting partial business activities based on Sharia Principles:
   ………………………………………………………………………………………....
   b. Reasons and Considerations
   (to be filled with reasons and considerations for conducting partial business activities based on Sharia Principles)
   c. Strategy
   (to be filled with the strategy for conducting partial business activities based on Sharia Principles)

2. Plan for cessation of partial business activities based on Sharia Principles
   a. Information regarding the plan for cessation of partial business activities based on Sharia Principles
   ………………………………………………………………………………………....
   b. Reasons and Considerations
   (to be filled with reasons and considerations for cessation of partial business activities based on Sharia Principles)
   c. Strategy
   (to be filled with the strategy for cessation of partial business activities based on Sharia Principles)

Format 14: Plan for Change of Business Activities So That It Is No Longer a Pawnshop Company

a. Description of the plan to change business activities so that it is no longer a Pawnshop Company (to be filled with an explanation regarding the plan to change business activities so that it is no longer a Pawnshop Company) b. Reasons and considerations (to be filled with reasons and considerations for changing business activities so that it is no longer a Pawnshop Company)
c. Strategy
(to be filled with the strategy for changing business activities so that it is no longer a Pawnshop Company)

Format 15: Business Plan Realization Report

a. Filled with an explanation regarding the achievement of the Business Plan, including the achievement of the Business Plan and the comparison of the plan and its realization, which must at least include:

1. realization of the business activities plan as referred to in Format 4;
2. realization of the plan for business development or expansion as referred to in Format 5;
3. realization of the capital plan as referred to in Format 6;
4. realization of the financing plan as referred to in Format 7;
5. realization of the plan for office network or distribution channel development and/or changes as referred to in Format 8;
6. realization of the plan for organizational development, human resources, and/or information technology as referred to in Format 9; and
7. realization of the financial statement projections along with the assumptions used as referred to in Format 10.
   b. Filled with an explanation regarding deviations in the Business Plan realization related to the scope of realization in letter a, such as causes and obstacles faced.
   c. Filled with follow-up efforts that have been and will be carried out to improve the realization achievement of the Business Plan.
   d. Filled with financial ratios and specific items, including an explanation regarding the realization of financial ratios and specific items as referred to in Format 11. e. Filled with an explanation regarding other achievements in the Business Plan and the comparison of the plan and its realization, which must at least include:
8. realization of the merger, consolidation, and/or separation plan as referred to in Format 12;
9. realization of the plan for conducting partial business activities based on Sharia Principles or cessation of business activities based on Sharia Principles as referred to in Format 13; and
10. realization of the plan to change business activities so that it is no longer a Pawnshop Company as referred to in Format 14.

Known by:
Board of Directors: (signature and full name)
Board of Directors: (signature and full name)
..etc. ..etc.

This copy is in accordance with the original
Legal Director 1
Legal Department signed
Mufli Asmawidjaja

Format 16: Business Plan Supervision Report

The Board of Commissioners' assessment of the implementation of the Business Plan consists of an assessment of:
a. quantitative and qualitative aspects of the Business Plan realization; b. factors affecting the performance of the Pawnshop Company; and
c. efforts to improve the performance of the Pawnshop Company, if according to their assessment there is a decline in the performance of the Pawnshop Company.

Approved by:
Board of Commissioners: (signature and full name) Board of Commissioners: (signature and full name) etc... etc...

Established in Jakarta on August 7, 2020
HEAD OF EXECUTIVE SUPERVISOR FOR
INSURANCE, PENSION FUNDS,
FINANCING INSTITUTIONS, AND
OTHER FINANCIAL SERVICE INSTITUTIONS
FINANCIAL SERVICES AUTHORITY
REPUBLIC OF INDONESIA, signed
RISWINANDI