: +62 (21) 798-4292

Tetra Pak Building, Ground Floor +62 (21) 798-4293

Jl. Buncit Raya Kav. 100 : concord@concord-consulting.com
Jakarta 12510 Indonesia
: www.concord-consulting.com

Threat Assessment & Risk

Analysis (TARA)
LUWU REGENCY

Prepared for:

PT Masmindo Dwi Area Report Date: September 2020

Gedung Graha Mitra
Floor 4, Room 401
Jl. Jend. Gatot Subroto Kav. 21 Proposal Reference CNCRD-JL-2481
Jakarta 12930, Indonesia Number:

Point of Contact:
Adrian Rollke
Country Manager STATEMENT OF CONFIDENTIALITY
This proposal document, and any report and/or
deliverable(s) generated hereunder, has been prepared
Prepared by: for the benefit of the Client only including its directors,
officers and employees. This document is not to be
Jan Lepeltak disseminated to a third party or reproduced without the
Concord Consulting Indonesia
Tetra Pak Building, Ground Floor express written permission of PT Concord Consulting
Jl. Buncit Raya Kav. 100 Indonesia.
Jakarta 12510 Indonesia
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distribution on a business basis only. No third party dissemination without written approval of management.

DISCLAIMER
This report contains sensitive information prepared by Concord (the Provider) at the request of PT
Masmindo Dwi Area (the Client). The information provided in this report has been done so in good faith and
is based on information obtained from multiple sources in Luwu Regency and other South Sulawesi-based
primary sources. Secondary information sources include comprehensive internet and media including social
media searches and corroborative information to support where possible primary source information. The
Provider makes no assertion that the information contained in this report is intended to provide legal advice
or interpretation. Furthermore, this report does not constitute an audit, review or examination of financial
statements or a review that detects fraud or illegal acts. The Provider will not be responsible for the
consequences of decisions made by the Client based on the information contained in this report to include
liability for alleged dated, speculative or unverified information subsequently determined to be inaccurate.

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CONTENTS
DISCLAIMER ............................................................................................................................................. 2
CONTENTS ............................................................................................................................................... 3
EXECUTIVE SUMMARY ............................................................................................................................. 7
MAIN FINDINGS ....................................................................................................................................... 7
CONCLUSION ........................................................................................................................................... 9
RECOMMENDATIONS ............................................................................................................................... 10
INTRODUCTION ..................................................................................................................................... 11
BACKGROUND ....................................................................................................................................... 11
OBJECTIVES ........................................................................................................................................... 11
DELIVERABLES ....................................................................................................................................... 13
SCOPE.................................................................................................................................................. 14
THREAT ASSESSMENT METHODOLOGY ......................................................................................................... 14
Stage One: Direction ................................................................................................................................. 14
Stage Two: Collection ................................................................................................................................ 14
Stage Three: Information Analysis ............................................................................................................ 14
Stage Four: Drafting of Report .................................................................................................................. 14
KEY FINDINGS ........................................................................................................................................ 14
LAND OWNERSHIP .................................................................................................................................. 14
Perceptions of Gold Exportation: .............................................................................................................. 16
Outside Influence Affecting Ring One Villagers: ....................................................................................... 16
Sentiments in Ring Two: ............................................................................................................................ 17
Belopa Land Prices..................................................................................................................................... 18
ENVIRONMENTAL AND ANTI-MINING SENTIMENTS ......................................................................................... 18
Masamba Disaster ..................................................................................................................................... 19
Latimojong and Bajo Districts .................................................................................................................... 20
Agricultural Economy ................................................................................................................................ 21
Negative Sentiments in Belopa ................................................................................................................. 21
Negative Sentiments in Palopo ................................................................................................................. 22
POLITICAL ............................................................................................................................................. 22
Luwu Regency............................................................................................................................................ 23
Luwu Regent Mattayang ........................................................................................................................... 24
Bureaucratic Apparatus ............................................................................................................................. 26
Deputy Regent Syukur Bijak ...................................................................................................................... 27
Mattayang’s sons....................................................................................................................................... 27
Pancasila Youth or Pemuda Pancasila ....................................................................................................... 28
Luwu DPRD ................................................................................................................................................ 28
Local Media ............................................................................................................................................... 29
Former Regent Andy Mudzakkar............................................................................................................... 30
Wider Luwu Area ....................................................................................................................................... 30
South Sulawesi Provincial Politics ............................................................................................................. 31
CORRUPTION, EXTORTION AND COERCION.................................................................................................... 31
Luwu Regency............................................................................................................................................ 32
ILLEGAL NARCOTICS ................................................................................................................................ 35

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INCIDENTS OF THEFT................................................................................................................................ 37
Theft .......................................................................................................................................................... 37
TERRORISM, EXTREMISM AND RADICALISM .................................................................................................. 39
Poso - Central Sulawesi ............................................................................................................................. 41
Terrorist Incidents in the Wider Region .................................................................................................... 42
Laskar Jundullah ........................................................................................................................................ 44
Extremism and Radical Groups.................................................................................................................. 45
ILLEGAL MINING..................................................................................................................................... 45
Modus Operandi........................................................................................................................................ 46
Network Structure ..................................................................................................................................... 47
Security Backing ........................................................................................................................................ 47
Social and Economic Impact ...................................................................................................................... 47
Environmental Impact ............................................................................................................................... 48
Illegal Mining Cases in Sulawesi ................................................................................................................ 48
SOCIAL THREATS .................................................................................................................................... 50
Luwu Local Culture .................................................................................................................................... 51
Resistance to Outsiders ............................................................................................................................. 52
Community Conflicts ................................................................................................................................. 53
Main Source of Income in Luwu Regency ................................................................................................. 53
LOCAL ORGANIZATIONS ........................................................................................................................... 54
NATURAL DISASTERS ............................................................................................................................... 55
Earthquakes ............................................................................................................................................... 55
INFRASTRUCTURE ................................................................................................................................... 56
South Sulawesi Province............................................................................................................................ 56
CRIME TRENDS ...................................................................................................................................... 56
HEALTH ISSUES ...................................................................................................................................... 57
Coronavirus ............................................................................................................................................... 57
Bird Flu....................................................................................................................................................... 58
Dengue Fever ............................................................................................................................................ 58
Measles and Rubella.................................................................................................................................. 58
Rabies ........................................................................................................................................................ 58
Tuberculosis............................................................................................................................................... 58
HIV/AIDS .................................................................................................................................................... 59
Anthrax ...................................................................................................................................................... 59
RISK ASSESSMENT .................................................................................................................................. 59
CONSEQUENCE SCORE ............................................................................................................................. 59
LIKELIHOOD SCORE ................................................................................................................................. 60
VULNERABILITY SCORE ............................................................................................................................. 60
CONSEQUENCE AND MANAGEMENT IMPLICATIONS ......................................................................................... 60
BASIC IMPACT LIKELIHOOD MATRIX ............................................................................................................ 61
BASIC VULNERABILITY AND CONSEQUENCE MATRIX ........................................................................................ 61
RISK ANALYSIS TABLE .............................................................................................................................. 62
ANALYSIS ............................................................................................................................................. 73
CONCLUSION ......................................................................................................................................... 74
RECOMMENDATIONS ............................................................................................................................. 74
SECURITY ACTION MANAGEMENT PLAN RECOMMENDATIONS (SAMP) ............................................................... 74

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Client management establishes and maintains a security management department ............................. 74

Client maintains a process of continual review of security capacity and capability ................................. 74
Interim-Security Manager ......................................................................................................................... 75
Client improves current information collection ........................................................................................ 75
Client develops an investigative capability ............................................................................................... 75
Client establishes a MoU with the South Sulawesi Police (Polda Sulsel) .................................................. 76
Client registers the mine site into a National Vital Object ........................................................................ 76
Client ensures suitable security training ................................................................................................... 76
LAND OWNERSHIP - DELAYS IN LAND ACQUISITION AND COMPENSATION ............................................................ 76
Continue improving socialization of the Client’s historical development of the project.......................... 76
Client improves current information collection, collation and analytical capability/capacity ................. 77
Undertake further continued investigation .............................................................................................. 77
Client maintains detailed records ............................................................................................................. 77
Client establishes a targeted Social Media Engagement Plan................................................................... 77
ENVIRONMENTAL ALLEGATIONS ................................................................................................................. 77
Client establishes additional village-based information ........................................................................... 78
Client develops and implements mine site visits ...................................................................................... 78
Client initiates a Corporate Communication Plan ..................................................................................... 78
Client develops an active Media Communication Plan ............................................................................. 78
Client establishes an environmental monitoring capability ...................................................................... 78
Client maintains or has access to an in-depth investigations capability ................................................... 78
POLITICAL/CORRUPTION/EXTORTION/COERCION/FRAUD ................................................................................ 79
Client uses its information collection capability ....................................................................................... 79
Client always conducts thorough Due Diligence ....................................................................................... 79
Client utilizes an advisory and compliance monitoring capability ............................................................ 79
Client establishes a proactive good governance and business ethics program ........................................ 80
ILLEGAL NARCOTICS ................................................................................................................................ 80
Client immediately implements a Narcotics Prevention and Detection Plan and Policy .......................... 80
Client uses its information collection capability ....................................................................................... 80
Client maintains a professional competent Security management footprint........................................... 81
THEFT .................................................................................................................................................. 81
Compartmentalizes the project area ........................................................................................................ 81
Conduct strict access control .................................................................................................................... 81
Same gender search and inspection procedures ...................................................................................... 81
Security officer rotations ........................................................................................................................... 81
Conduct regular security audits ................................................................................................................ 81
Closely monitor fuel distribution and consumption ................................................................................. 81
Install overt and covert GPS monitoring devices ...................................................................................... 81
Install security ID recognition systems ...................................................................................................... 81
Conduct in-depth pre-employment background checks........................................................................... 81
Regularly announce the Ethics Hotline ..................................................................................................... 81
Provide sufficient and effective security personnel .................................................................................. 81
Use fixed CCTV zoom-in areas of the facility with high net worth ............................................................ 82
Use separate guard forces......................................................................................................................... 82
Gold Room Recommendations.................................................................................................................. 82
Command and Control Centre .................................................................................................................. 84
TERRORISM, EXTREMISM AND RADICALISM .................................................................................................. 84
The Client maintains a robust security management posture as part of the SAMP ................................. 84
The Client ensures that SMP contractor personnel receive adequate training ........................................ 84
The Client’s Security Department maintains relationships with security agencies .................................. 84

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The Client uses its information collection capability................................................................................. 84

ILLEGAL MINING..................................................................................................................................... 84
The Client uses its information collection capability................................................................................. 85
SOCIAL ISSUES ....................................................................................................................................... 85
The Client conducts regular and thorough induction training .................................................................. 85
The Client implements a selection and recruitment program .................................................................. 85
The Client implements a local procurement program .............................................................................. 85
GENERAL THREATS.................................................................................................................................. 85
Natural Disaster ......................................................................................................................................... 85
Infrastructure ............................................................................................................................................ 86
Health ........................................................................................................................................................ 86

ANNEX A: STAKEHOLDER MAPPING

ANNEX B: OVERVIEW OF REGISTERED ORGANISATIONS IN LUWU REGENCY

ANNEX C: OVERVIEW OF SOUTH SULAWESI SECURITY INCIDENTS

ANNEX D: OVERVIEW OF REGISTERED ORGANIZATIONS IN LUWU REGENCY

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EXECUTIVE SUMMARY
Concord Consulting conducted a Threat Assessment and Risk Analysis (TARA) for the Client on its Awak Mas
Mining Project in Latimojong District in Luwu Regency from 21 July to 5 August 2020. Field inquiries and
further research and risk analysis were conducted onsite and in Jakarta, respectively.

Following the Client’s request, the TARA was conducted covertly focusing on external threats to the Client.
Information on identified threats and levels of risk collected during the TARA were further analysed and
assessed prior to the final risk analysis and threat prioritization.

Main Findings

Delays to Land Compensation

The client needs to be abreast of the continuous changing and evolutionary dynamics involved among and
between the landowners and stakeholders. These stakeholders promote their own agendas which generate
conflict that will disrupt and delay the land acquisition process. Furthermore, the client needs to improve its
image with local residents, community leaders and activists as perceptions of the company over recent years
have become negative.

Issues in Ring One include internal family disputes over land prices and Belopa’s land price increases used as
a reference for the Client land acquisition process. Issues in Ring Two and the wider area include social
jealousy where villagers may allege that the Client is denying them adequate compensation and/or business
and employment opportunities. Residents of Ring Two and Bajo District may conduct road blockades,
protests, and/or demonstrations due to their exclusion in the land acquisition process. They are likely to
demand compensation for increased use of their infrastructure by the Client and its contractors.

Environmental Allegations
The Client has previously been targeted with unsubstantiated allegations of polluting the Songgang River,
the main water source for the Belopa area. Socio-political leaders and/or environmental groups in Luwu
Regency continue to allege these claims. The July 2020 Masamba flash flood disaster, which has been
blamed on mining and palm oil activities, has further strengthened the perception that the Client is
responsible for impending adverse environmental conditions impacting the local environment including
landslides, deforestation and water contamination.

Political/ Corruption/Coercion/Fraud
Political elites with business interests in the wider Luwu area will likely use the Client as a political
commodity to question the Client’s presence and the socio-economic benefit of the mining project. The 2023
Luwu Regent Election increases the risk of the mining project being targeted by potential student or other
issue motivated stakeholders conducting protests and/or demonstrations and restricting access through
road blockades.

The Governor, Regent, and Luwu DPRD members will support the Client’s project. However, the client needs
be aware that there is a deep undercurrent of adverse sentiment. Political support may change if
environmental, economic and nationalist issues arise.

While the Client is reliant on the Indonesian government’s security apparatus for its overall security, local or
regional elements in the military or police may pressure the Client and/or its contractors to pay for security
services. There have been many past occurrences where a company’s refusal to pay resulted in the sudden
emergence of logistical, operational and/or security issues.

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Illegal Narcotics
Local sources identified that crystal meth (sabu-sabu) is widely available in Palopo, only ninety minutes’ drive
from Belopa. Drug trafficking networks smuggle drugs from North Kalimantan through Parepare to Palopo.
South-Sulawesi crime groups and networks traffic illegal narcotics to Latimojong and Bajo Districts, Belopa
and Palopo and Luwu Regency. When the Belopa Port becomes operational, there will likely be an increase
in drug-trafficking and consumption. Increased economic activity will lead to more demand for illegal
narcotics. The Client and contractor’s workforce, like other mining operations in Sulawesi, have large
disposable incomes compared to local residents with little to spend in the local communities. It is likely that
some employees will try drugs. Drug addiction is an ever present issue within the mining sector and will
likely impact the Client’s security and possibly affecting its operation and reputation.

Theft
General crime rates including theft are at medium levels in Luwu Regency; this includes the Client’s project
area. The presence of a gold mining operation will trigger the interest of criminal elements in other parts of
Sulawesi, as well as from local residents tempted to steal gold or other high value assets and can potentially
include Client and contractor employees. The predominant focus of anti-theft measures should be on the
gold. Many other high value items and material are also attractive targets of theft.

Theft can be a crime of opportunity or part of well organized criminal networks. There is a need for
integrated security countermeasures that deter, detect, delay and provide rapid response in a layered and
concentric configuration. This can be enhanced with supporting crime prevention through appropriate
environmental design (CPTED) considerations. Attaining suitable assets to establish robust and capable
security countermeasures in South Sulawesi will be challenging and will require considered commitment
from Client management.

Terrorism, Extremism and Radicalization

Direct terrorist threat in Luwu Regency remains low, even though there are significant threats of violence
from terrorism and extremism in the wider area of Sulawesi. There is still a need for the Client to
continuously monitor terrorist, extremist and radicalised developments. Potential infiltration or influence
(radicalisation) of the Client/contractor workforce remains a realistic consideration. Also an operating gold
mine, including the presence of expatriates, may be considered a potential target of opportunity, especially
as a national vital object. Regular liaison with INP and TNI contacts, the development of a robust security
management capability and Information Collection & Action Capability that includes a counter-
extremism/radicalisation strategy are necessary.

Illegal Mining
Incidents of illegal mining support entrenched security and social issues in Sulawesi. However, there are no
current incidents of illegal mining occurring in Luwu Regency. Limited Community Mining is occurring in the
Bajo and Latimojong Districts. Once the Client’s mining operations commence, it is likely that a number of
Illegal miners from other areas in Sulawesi will be attracted to the area, lured by the promise of economic
benefit.

According to the Client, illegal mining will likely be limited and sporadic, considering the technical difficulties
in extracting gold in quantities large enough to make it viable. However, the threat of damage to the
environment and pollution from the expected limited number of illegal miners presents potential
environmental, community and reputational.

Social Issues
There is a risk that while the presence of the mine will generate economic opportunity for the poorly
developed skill sets of local residents; increased criminal activity, alleged environmental damage, negative

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impact on local economy, etc. can be exploited by issue motivated stakeholders including but not limited to
social activists, political opportunists and economic commercial competitors to manipulate and influence
local communities to discredit the Client. Furthermore, claims of unequal job or local business opportunities,
which force local residents into a lower socio-economic class and a dependence on government aid, could be
used to attack the company’s reputation and weaken political relationships with the Luwu Regency
administration. The influx of outsiders and the potential for them to develop intimate relations with local
women may also present community tension.

Other Risk Areas

Infrastructure and logistics are key challenges in the development and construction of the Client’s gold
mining project. The physical visit to the mine site determined that landslides, resulting from heavy rains,
have blocked access roads resulting in disruption of mining operations and the logistics support and
infrastructure.

Natural Disasters
Landslides remain a significant concern to the Client’s workforce, property and overall business operations.
Residents of Luwu Regency are aware of this risk following the Masamba disaster. Poor Infrastructure makes
response efforts difficult. The Client must develop a strong monitoring and response capability to the risk of
landslides and flooding. This includes the capacity and capability to assist the local community.

Infrastructure
The provincial and regional governments are aware that infrastructure improvement is a key issue in
Sulawesi. However, funding and graft issues remain obstacles for successfully developing infrastructure
projects. The need for infrastructure improvement is a key element in the interaction between various levels
of government and the Client and between the Client and the community. However, the client will need to
address attempts by unscrupulous administration officials and local resident collusion in attempts to
embezzle project funds and land compensation payments.

Conclusion

The Client faces major challenges from the community. According to a feasibility study in 1996, the
communities were very supportive of the mine. However, in recent years opinions have turned to distrust.
Local communities share wide-spread misconceptions that the mine has already extracted gold and will be
responsible for future adverse incidents affecting their livelihood. The surrounding communities’ negative
sentiment has been intensified by the Masamba disaster where media, environmental groups and regional
political entities have misdirected blame to large business operations. Continuing local community may
delay the land acquisition process jeopardizing mining operations and potentially the entire project.

Political coercion is a challenge that the Client faces. There is an expectation from political stakeholders to
receive financial benefit. South Sulewesi, according to the February 2019 Indonesia Corruption Watch (ICW)
report, ranked 3rd out of 47 provinces for cases of corruption within local administrations. These cases
involve regional government abuse of local or state budget, procurement projects corruption, permits
obtained illegally for infrastructure projects or bribery.

Although Concord Consulting has not observed any coordinated efforts to impede Client operations, the risk
of community issues escalating could potentially jeopardize mining operations, if not properly managed.

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Recommendations

1. Establish a Robust Security Management Capability

The Client needs to implement a highly effective, professional security management capability able to
counter numerous adversaries/threats from issue-motivated stakeholders minimizing the impact of
environmental allegations, political and other entity coercion, corruption, fraud, theft, illegal narcotics,
terrorism, illegal mining, de-escalation of social issues and disaster response, etc.

The Client Security Management Action Plan (SAMP) is the initial element in establishing this goal. The
overall security management capability must include policy, procedures, processes and systems
implementation and compliance, supported by highly trained and competent physical security manpower.
Security manpower must be integrated with the required technical support systems and command and
control functions to develop a truly robust security management system. Physical security design elements,
such as layered concentric security-in-depth and crime prevention through environmental design must
support an established security capability demonstrating the capacity to deter, deny, detect and respond to
threats targeting the Client and its operation.

The protection of key assets needs to be achieved through committed Client management oversight either
through an in-house security management department or utilizing third party providers. The Client requires
assistance to recruit, train and mentor to develop the Client’s Security Management Department.
Furthermore, the Client needs assistance implementing recommendations highlighted in this document. Key
performance indicators (KPIs) are essential for the Client to hold the Security Manpower Provider
accountable for competency, gauge its effectiveness and efficiency and highlight training requirements.

Security management must be supported by established relationships with third party security agencies;
including Police, TNI, disaster management agency, local community administrations and regional
government. To ensure successful a security management capability, a reliable Information Collection and
Action Capability (ICAC) and a proficient investigations capability must be developed and actively engaged.

2. Implement an Information Collection and Action Capability (ICAC).

This recommendation is critical for the success of this project. The ICAC enables the Client to make timely
and informed management decisions. The system, while maintaining security and discretion protecting the
Client, will provide a clear and accurate picture of the threats and associated risks from local and regional
stakeholders include but are not limited to the following:
 Communities  Criminal elements  Media
 Government  NGOs  Social, cultural & religious leaders
 Police  Environmental groups  Other issue-motivated stakeholders
 Military  Commercial business entities  (e.g., disgruntled/former employees, opportunists)

In addition to timely and accurate intelligence, the ICAC provides the Client management Action
Management Plans including counter-narratives, media campaigns, public relations lobbying, establishing
NGOs etc., to counter adversaries. The ICAC is critical for the Client to complete the land acquisition and
compensation process, managing environmental allegations, understanding the political environment,
combating corruption, extortion, coercion, fraud, illegal narcotics, theft, terrorism/extremism/ radicalization,
illegal mining and community social issues.

3. Establish a Highly Competent Investigations Capability.

Investigations are essential to support the Client’s SAMP and the security management functions.
Mandatory quality due diligence investigations and background checks are required prior to employment of
and individual or engagement with a commercial partner. Effective investigations limit potential fiscal loss
and reputational damage to the Client in instances of fraud, theft, coercion and corruption.

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INTRODUCTION
Background

A proposal was developed for a Threat Assessment and Risk Analysis Project for PT Dwi Masmindo Area (the
Client), based on the Client’s email dated 5 May 2020 and discussions during the video conference on 12
June 2020. The Client provided a specific Scope of Work on 1 July 2020. During a subsequent meeting
between the Client and the Provider on 16 July 2020, the Client directed that the TARA, including its field
investigations and inquiries should be conducted covertly.

The Scope of Work centred on the Client’s Awak Mas Site in Luwu Regency, South Sulawesi Province. The
area of focus included the immediate surroundings of Belopa, (capital of Luwu Regency), the neighbouring
city of Palopo, and the village centres of Rante Balla, Bone Posi and Kadundung in Latimojong District in
Luwu Regency.

The TARA Scope of Work is as follows:

Phase 1: Review and field work

 Review all threats and associated risks identified in the previous DFS as listed, including any
subsequent changes in conditions.

 Additional identification of threats and associated risks not listed in the previous DFS.

 Undertake a regional site visit, meeting GOI and non-GOI key stakeholders to gauge the following:
- Validity of threats and security issues identified in the previous DFS
- Highlight any subsequent changes in conditions since the writing of the previous DFS
- Include additional identified threats and associated risks not previously highlighted in the DFS.
- Field Information Collection in Luwu Regency including Palopo; Balopa and the three villages of
Rante Bella, Bone Posi and Kadundung; visiting community leaders, police, military and other key
stakeholders and ascertaining and updating changes to the initial risk/threat assessment.

Phase 2: Risk and Threat Assessment

 Conduct a risk and threat assessment of the physical facilities as identified in Phase 1.

Phase 3: Deliverables

 Threat & Security Risk Assessment Report; Due 15 August 2020

- Incorporation the results from Phase 1 and 2.

Objectives

The threat assessment focus was to identify threats and associated risk levels in the Client operating
environment. The TARA scope of work is centred on the Client’s Awak Mas Site in Luwu Regency, South
Sulawesi Province. This includes the immediate surroundings of Belopa (capital of Luwu Regency), the
neighbouring city of Palopo and the village centres of Rante Balla, Bone Posi and Kadundung in Latimojong
District in Luwu Regency.

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The Client’s gold mine site is considered a high-level, attractive target. The potential financial rewards
derived from theft, fraud, extortion and illegal mining are substantial and will draw interest from numerous
criminal elements at varying levels.

Furthermore, numerous stakeholders including political, government, security agencies, local communities,
commercial, social/cultural/religious, environmental and NGOs, etc. at all levels will influence security
considerations and impact the Client’s project in various forms.

The TARA Scope of Work comprises of focused information collection at a local micro and grassroots level,
executed through a process of field information collection comprising of stakeholder mapping, identification
of economic and business opportunity and identification of general threats. This will include but not be
limited to the following:

1. Stake Holder Mapping: Mapping includes a risk analysis of each grouping to identify current, developing or
potential threats that might emerge under 1) current conditions, 2) during the project phase and 3) when
the mine site is operational and functioning. Groupings will include but not be limited to the following:
 Government  Labour-related organizations
 Social  NGOs and environmental groups
 Police  Media
 Military  Prominent figures (informal and formal)
 Religious groups and organizations  Influential business groups and or individuals within
 Community–based special interest groups the Client’s wider operating environment
 Social mass organizations (also referred to  Criminal groups and elements, illegal mining
as ‘Ormas’) perpetrators

2. Economic/Business Opportunity: In order to assess whether control strategies that depend on community
support remain valid, it is of critical importance that issues, sentiments and developments within the three
villages are identified to assess the level of community support and developing issues and/or trends related
to these control strategies. Issues reviewed are as follows:
 Obtain information relevant to the business landscape and the potential for economic development.

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 Identify “Key Stakeholders” and or strategic individuals within areas of interest.

 Assess the threat posed by entrenched interests, issue motivated groups and or individuals opposed
to new development, attempts to extort or coerce the Client and or their personnel or any identified
ongoing disputes, conflicts, trends or issues of interest.
 In-depth research into issues, threats and risks related to the three village communities including but
not limited to the following:
- Land ownership
- Concerns over employment
- Income disparity between mine site workers and local villagers/community members
- Community demands for local-local contracts
- Increased drug use including drug trafficking networks targeting mine site workers with
relatively high incomes
- Impact of mine workers separated from their families
- Personal relationship issues impacted by the interaction between newcomers and community
members

If sentiments and the level of support change, effectiveness of the listed control strategies and the overall
security of the Client’s business operation will be negatively impacted and other control strategies will need
to be developed.

3. General Threats: The risk level of identified threats is assessed employing a risk analysis methodology
based on asset criticality of current physical assets and assets that still need to be developed at the mine
site. During Stage One, the Client needs to review and confirm approval of the findings and
recommendations highlighted in the TARA to complete the Security Access and Management Plan.
 Crime statistics and trends  Recent threat issues
 Terrorism  Social, economic, cultural, religious or environmental issues
 Extortion affecting or potentially affecting future Client development
 Corruption opportunities
 Illegal Mining  Infrastructure, transportation and communication issues posing
 Natural Disaster obstacles, threats and risks

Deliverables

The deliverables encompass a review and analysis of the likely security factors that affect the operations
and profitability at the Client’s mining site in Luwu Regency. These factors consist of threats, risks and the
likely impact on the Client including but not limited to the following:

 Identification of all threats potentially impacting the Client’s operations, profitability, reputation and the
security of its personnel, property and assets and information.
 Assessment of the land ownership situation for the area stakeholder mapping.
 Risk Identification Matrix
 Vulnerability and Consequence Matrix
 Consequence and Management Implications
 Impact Likelihood Matrix
 Mitigation Determination Worksheet (Counter Measures) will be determined

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Scope

The proposed Scope of Work encompasses a review and analysis of the likely factors that affect operations
and profitability at the Luwu site, the risk and likely impact of these factors to the Client.

Threat Assessment Methodology

The TARA was completed in four stages as follows:

Stage One: Direction

Concord Consulting reviewed and assessed the TARA requirements by determining the resources needed
and the scope the assessment would require. The direction stage includes determining all stakeholders who
could provide information that would impact the Threat Assessment.

Stage Two: Collection

Based on the collection strategy developed by Concord Consulting Indonesia, staff members were allocated
tasks in Luwu Regency to satisfy the collection requirements. The collection stage entailed interviews with
primary sources, individuals with direct access to primary sources and data, and collection of overt media
information pertinent to the issues.

Stage Three: Information Analysis

The collected information was collated, evaluated and analysed that highlighted potential likely adversaries
and the impact of developing a complex project in Luwu Regency, South Sulawesi Province.

Stage Four: Drafting of Report

The assessed information has been presented in the following report to answer the specific Client questions.
Further observations on identified issues during the Threat Assessment process and their impact on the
project have also been highlighted.

KEY FINDINGS
Land Ownership

The commencement of the Client’s mining operation depends on successfully acquiring land from the three
surrounding villages located in Ring One. Any delays or obstacles will have an immediate detrimental impact
on the mining project, its operation and the financial resources of the Client. External groups and individuals
are persuading local villagers from Ring One to demand larger payments or refrain from selling their land to
the Client which may jeopardise the mining project.

Issue-motivated stakeholders (negative actors) are strengthening their level of influence by circulating false
perceptions among the villages as follows:

• The client has not been truthful towards local communities

• The client has secretly exported gold from the area for decades
• The client in 2012 conducted land surveys to estimate ownership and compensation. However, there
has been no follow-up from the company.

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Land prices and Client land acquisition have recently gained interest and attention. Sources stated that
people, who originate from the three villages of Ring One and Latimojong District after working in
Kalimantan, have returned to their villages to advise villagers on the Client land acquisition process. These
returning villagers see economic opportunity and financial benefit of being included in this process.
Stakeholders are advising villagers to demand higher compensation for their land due to increasing land
prices in Belopa City.

Initially villagers in Ring One were supportive of the current compensation promised by the Client. Pressure
from community leaders of other villages in Latimojong District and stakeholder influence and can quickly
change this position. The following factors may contribute:

1. The need to “seize the opportunity” and receive substantial financial benefit from the Client

2. Social pressure from Ring Two community leaders stating that villagers in Ring One are stupid to
accept the client’s current offer. Villagers in Ring One may be humiliated for hastily accepting the
client’s offer and may be persuaded to become more difficult and “opportunistic” leading to new
negotiations

3. Changing mindsets against the traditional dependence on agriculture and self-reliance in Ring One
villages. The younger generation supports an urbanized culture: more financial opportunity, a better
lifestyle and formal employment with a company rather than working as farmers. Their influence on
their parents and older villagers may contribute to demands for higher compensation

4. There are people originating from Latimojong District working as migrant workers in other parts of
Indonesia, predominantly in Kalimantan. Their outside work experience has made them savvier and
more confident. They will likely influence other villagers for higher compensation from the Client.
There have been reports of a family dispute in one of the villages, most likely in Rante Balla Village in
Ring One, where a returning family member (who is a migrant worker) argued with other family
members (who never left the village) about land compensation.

5. Members of the wider Latimojong and Bajo District are insisting that they are selling Luwu’s
customary or cultural heritage ‘adat’ land which not only affect secular land owners but also the
greater community. Since they are selling heritage land to a foreign company, they feel that the
Client must pay a considerable premium.

6. Political and business-linked individuals in Luwu Regency who act as negotiators or advisors for
villagers in Ring One can delay the land compensation process, driven by personal financial interests,
land speculation and political opportunity.

In early August local community members in Rante Balla Village wanted land compensation payment of IDR
100,000 per square meter. They also stated that compensation for seven-year old clove trees should be at
least IDR 15 million per tree. Local residents still felt that IDR 15 million per tree was low, as older clove
trees produced more cloves and were more valuable to local farmers.

In Rante Balla Village local sources claimed that many residents of Latimojong District are wary of the Client.
Villagers allegedly believed that the Client had previously conducted land measurements and surveys in 2012
including land on top of Latimojong Mountain. According to sources, the Client had informed locals that it
would conduct compensation payments for the land. However, until now nothing had progressed. When the
Client commenced the land measurements and surveys in 2020, local residents did not have a great
expectation from the company due to their experience in 2012.

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It was identified that many Ring One villagers have accepted the mining project and associated land
compensation as a “fait accompli”, as the central government has already granted licenses and permits to
the Client. The villager’s position is that they “will go along as long as they receive fair compensation.”
Inquiries with residents of Desa Rante Balla in late July 2020 indicated that, “the Client valued their land at
IDR 50,000 per square meter.” However, several sources indicated that villagers view fair compensation at
“over IDR 100,000 per square meter.”

Various local sources in Rante Balla Village said that “they don’t really need the mining company because
their self-reliance on agriculture has been financially rewarding: their children are able to go to college and
they are able to make pilgrimages to Mecca.”

Perceptions of Gold Exportation:

Because the villagers are not aware of the true history of the company including the addition of new
investors in recent years and the entry into new phases of the mining project, many village communities are
suspicious of the Client. There is a well-established misconception that the Client has been in exploration for
forty years. Unsubstantiated rumours are circulating in Latimojong and Bajo Districts and even Belopa City
that the Client has been mining and exporting gold. These misperceptions have created distrust in the Client
amongst many community members which is negatively impacting community relations with the company.

Covert interviews with many residents confirmed that this negative sentiment is well-entrenched within
local communities in the client’s wider operating environment. Local sources
in Rante Balla Village explained that “they feel they have been fooled by the
company claiming it had been in the exploration phase for forty years.” These
sources questioned how the client was financially able to fund mining
exploration for forty years without any result. They stated that it made no
sense, and they suspected that the client had already secretly transported
gold abroad. According to the sources, community members witnessed large
quantities of wooden boxes being transported from the project and
concluded that the boxes contained of gold.

Sources confirmed that the Client explained that the boxes were used to
transport rock samples needed to assess gold content. They claimed that
“the rocks had been taken away repeatedly and the wooden boxes were
returned empty to Latimojong District,” which makes them question the Clients’ explanation. The sources
were dubious about the large sample quantities required to determine the gold content, and therefore
presumed that gold was already exported.

Outside Influence Affecting Ring One Villagers:

The Lambanan Balla Village Head, Burharuddin SE, is one of the most vocal community leaders in Ring Two
who publicly raised concerns and objections about the alleged secret transport of gold and the land
compensation amounts, respectively. Burharuddin has a Bachelor’s Degree in Economics and is politically
connected to the previous regent, Andy Mudzakkar which gives him influence in both Bajo and Latimojong
Districts.

Burharuddin has publicly announced that villagers of Ring One “are stupid even if they accept an offer of IDR
500,000 per square meter” of land, ten times the initial Client offer. His reasoned that the price of land in
Belopa is already between IDR 700,000 to IDR 1 million per square meter. He further stated that the land in
the mining area managed by the client is more valuable compared to the land in Belopa due to the gold
content. Burharuddin has already expressed his opinions in various community meetings. He is eager to
continue expressing his views, concerns and objections and peddling influence regarding land compensation

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between the company and the land owners from Ring One villages, despite not living in Ring One or owning
any land there.

Burharuddin claimed that in the past he and Luwu former Regent Andi Mudzakkar brought a 30 centimetre
diameter rock from the village to a geological laboratory in Bandung, West Java to assess the rock’s content.
Allegedly, the rock contained gold, the size of an A-2 battery, and some diamond content.

During a Ring One public meeting with the client in early July 2020, Burharuddin advised the other Village
Heads to not sell their land to the Client for the offered price again arguing that the price should be higher as
it was clear the land contained gold and was more valuable. Burharuddin stated that he joined the Ring One
meeting because he was convinced his village would be the next mining location, and he did not want the
land price to be the same as the price offered at the Desa Rante Balla Village.

Burharuddin has publically repeated this negative narrative opposing the Client’s current price offering for
land acquisition across the wider area. His influence on other villagers especially in Ring One poses a
significant threat, which may result in delaying or prolonging the Client’s land acquisition process. The main
consequence is that landowners in Ring One will renege on selling their land at the initially agreed price and
delay the land compensation process to push for higher prices.

The client cannot dismiss the seriousness of the unsubstantiated rumours and misperceptions of the local
villagers. The client needs to proactively address these suspicions and fully communicate the historical
chronology of the project to the surrounding villages. The Client counter-narrative needs to become the
established in the wider area of Latimojong and Bajo Districts.

Sentiments in Ring Two:

Prevalent sentiments identified among residents in Ring Two and how they would impact opinions of Ring
One villagers and the overall land compensation process require Client consideration.

Interviews conducted in late July and early August 2020 with various community residents included villagers
from Desa Buntu Sarek in Ring Two. Residents were aware of the ongoing land and trees negotiations with
Ring One villages. They were aware of the Ring One villagers’ concerns over customary ‘adat’ land, and had
heard rumors of internal family disputes in Ring One concerning land negotiations. Ring Two villagers have
been informed that the exact compensation price offered by the Client would be announced in August 2020.

The Client needs to be aware of potential roadblocks, demonstrations, protests etc., conducted by villagers
in Ring Two in Bajo District based on social jealousy and being excluded from the land compensation
process. Their argument is that the client and their contractors still had to move through the villages in Ring
Two and that the company needs to pay compensation. Furthermore, a widely shared sentiment by villagers
in Ring Two is the environmental impact associated with the mining project.

A local police source in Luwu Regency stated that he did not expect problems as the land sought by the
Client was not being cultivated by local residents. However, based on interviews with local residents in both
Ring One and Ring Two, residents in Latimojong and Bajo Districts have no clear understanding of what kind
of land will be acquired by the client.

The police source expected that problems would start if the client wanted to acquire farm land that was
being cultivated by local residents which would impact the incomes of local farmers. The source mentioned
this could trigger widespread protests and demonstrations against the client from many sides, including
farming communities in Ring One.

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The police source had identified the following key threats that could negatively impact the Client if protests
and demonstrations occurred:

 Protest demonstrations in front of government offices in Belopa

 Road blockades aimed at denying access to the client’s mine site
 Spreading negative narratives in regional and social media
 Seeking political support in the regional and nationally
 Seeking support from regional, national and international NGOs

The police source emphasized the importance of maintaining continuous dialogue with community
stakeholders, including government officials, customary ‘adat’ leaders and other community leaders. The
source did not recommend the Client develop a strong show of force or aggressive security posture such as a
heavy presence of TNI or Police personnel at site.

Belopa Land Prices

Many residents, including community leaders, in Bajo and Latimojong Districts make comparisons with land
prices in Luwu’s capital Belopa to assess the value of land that the Client seeks. The two main points
identified in this comparison are:

1. In recent years land prices in Belopa have increased significantly

2. The value of land at the client’s project site should also follow the trend of increasing land prices,
taking into account the value of the lands mineral deposits.

Inquiries in Belopa indicated that land prices within the city have reached between IDR 1 million to IDR 2
million per square meter depending on its location. Interviews with Belopa-based project developers
indicated that if the land is located in close proximity to the main road, the Trans-Sulawesi Road, also known
as Jalan Poros, land will be more expensive.

For areas outside Belopa city including Kamanri District and Sengga sub-district, the price is lower. However,
sources indicated that land owners in these prefecture areas are already trying to value their land at the
same price as in Belopa City. The sharp increase in land prices over the past five years was confirmed by local
Chinese Indonesian businessman in Belopa.

The businessman said that the easiest way to buy land in the Belopa area is to register the land under a local
person. He explained that in the Luwu tradition, proceeds from land sale are equally divided amongst
children. Family disputes arising due to unfair distribution amongst siblings (e.g., if one sibling has previous
debts that is larger his/her portion of the sale price) may affect the land acquisition process for companies.
A common land disputes amongst family members occurs when one of the children previously deposited the
land certificate with a bank to obtain a loan. These family disputes will increase the sales price and/or delay
land acquisition for companies.

Environmental and Anti-Mining Sentiments

A significant threat from socio-political leaders and/or environmental groups in Luwu Regency exists. There
are allegations that the client is polluting the Songgang River in Latimojong District and therefore polluting
the main water catchment area for Luwu Regency’s capital Belopa, and Latimojong and Bajo Districts.

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Allegations can negatively influence communities and their attitudes toward the client in Latimojong and
Bajo Districts. Environmental groups, activist networks and political figures may publicly raise concern
through online social media comments, NGO reports and media gatherings, including protests and
demonstrations about the environmental impact of the Client’s project.

In the past, environmental groups and regional political leaders have already targeted the Client with
unsubstantiated allegations of polluting the river. Environmental concerns at various community levels in
Luwu Regency are as follows:

1. The main catchment area of the Songgang River used as the water source by the regional PDAM
water company providing water to the entire city of Belopa is located in relative close proximity to
the client’s project.

2. The Masamba Disaster in neighbouring North Luwu Regency has regionally triggered much concern
regarding natural disasters and the role of commercial companies, including those active in mining.

3. The villages in Latimojong and Bajo Districts strongly depend on agriculture, including coffee and
cloves. Any environmental pollution can have an immediate detrimental impact on their livelihoods.

4. The occurrence of landslides in the area of the Client’s project, including those near the access road
to the site, has gained attention from local residents and has raised questions whether the Client’s
presence has played a role in these landslides.

Observations of mining activities as well as landslides near the main access road can be manipulated by issue
motivated stakeholders into an incorrect but persistent narrative that the client’s presence has resulted in
an increase of landslides and environmental degradation in the area.

The association between commercial activities and/or mining activities and the Masamba disaster has been
developing into a widely shared perception among inhabitants of Luwu Regency and Palopo that commercial
mining activities can have a disastrous impact on the local environment and can lead to natural disasters
such as what occurred in Masamba.

The relative proximity between Belopa and Palopo, poses a significant risk of a spill over effect in which
activist campaigns in the local area of Latimojong and Bajo Districts and Belopa will escalate and involve
political forces and student groups in Palopo.

Masamba Disaster
The National Disaster Mitigation Agency (BNPB) reported that heavy rainfall resulted in the Masamba,
Rongkong and Mely rivers overflowing. Flooding resulted in 35 fatalities and left 4,930 flood affected families
across six districts, Masamba, Sabbang, Baebunta, South Baebunta, Malangke and West Malangke. 3-5
meters of mud buried hundreds of houses and public facilities rendering many uninhabitable.

Many regional political groups, environmental organizations and regional media in the wider Luwu area have
alleged that the flash floods in Masamba, North Luwu Regency on 13 July 2020 and the massive impact on
the wider city of Masamba to palm oil and mining companies. There is a growing sentiment and widely
shared perception among inhabitants of Palopo and Luwu Regency that commercial palm oil and mining
activities cause deforestation and landslides. Residents believe commercial mining activities have a
disastrous impact on the local environment leading to natural disasters, as occurred in Masamba, especially
Latimojong and Bajo District where agriculture is the primary livelihood.

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Latimojong and Bajo Districts

Allegations of environmental pollution impacting water sources including the Songgang River are an
immediate threat, raising severe concerns among communities in the Latimojong and Bajo Districts. Growing
public concern, potentially will force the Luwu Regent to respond and investigate allegations, scrutinize the
client, project operations, and client activities. This may delay, hinder or stop Client operations and
debilitate relationships with community members and leaders and wider area stakeholders. Allegations of
water pollution will create a reputational issue for the client that ultimately will negatively impact the clients
business.

Interviews with residents in Ring One and Ring Two indicated that villagers have concerns about the
environmental impact caused by the Client mining operations. A village source in Desa Buntu Sarek in
Latimojong District stated that villagers widely fear that the Client’s presence could cause environmental
damage, water pollution and landslides.

A sand mining company operating previously active in Luwu Regency was operating in the Desa Pasamai
area, Belopa District. Local village residents blamed the company’s excavator for damaging their rice paddies
and informed the Luwu Regional Mining Department. Subsequently, the Department subsequently
scrutinized the company and its mining licenses. Department officials “determined” that the company owner
only had approval from the Pesamai Village Head and did not possess the correct licenses. After the Regional
Government stopped the company’s operation, the company left the areas.

It was established that the Regent, Basmin Mattayang had visited the area of the Client’s mine site after the
Masamba incident. The purpose of the visit was to see with his “own eyes” whether there was an increased
risk of landslides and potential flash floods and to gauge the risk of other potential environmental damage.

The Indonesian Agency for Meteorological, Climatological and Geophysics1 (BMKG), had sent a regional team
to inspect Mt Latimojong in Latimojong District in early August. Their role was to assess the risk of landslides
and flash floods.

Local environmental activists monitoring environmental developments in Latimojong and Bajo Districts are
as follows:

Baso Ubas Gandangsura: Born in Bonelemo in West Bajo District, Gandangsura earned a Bachelor of Law,
from Hassanudin University, Makassar studying from 1993 until 1994. He was politically active during his
studies, serving as Chairman of the Islamic Student Association HMI at Hassanudin University and Chairman
of the Muhammadiyah Student Association IPM Bonelemo.

His resume includes affiliations with several international NGOs and ultimately politics:
 2004-2007: Project Officer for a capacity-building project funded by the Japan International
Cooperation Agency (JICA) and National Development Planning Agency (Bappenas)
 Conflict Management on a Natural Resources Exploitation Project funded by an international NGO
 Centre for People and Forests (RECOFTC)
 UN Food and Agriculture Organization (FAO)
 German Aid Agency GTZ2
 Indonesian Forestry Ministry
 2007: Involved in Disaster Risk Assessment, Development and Finance Management Program
promoted by the British branch of human rights organization, Oxfam in 2007

1
Badan Meteorologi, Klimatologi, dan Geofisika or simply BMKG

2
Gesellschaft für Technische Zusammenarbeit or German Technical Cooperation Agency.

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 2009-2011: Program Coordinator for the Forestry Social Program, funded by Indonesian NGOs DID-
KONSTAN LINGKAR and Telapak.
 2011: Monitoring Coordinator for Forestry Management, Luwu Regency working in cooperation with
the Independent Network of Forestry Supervisory Organization.
 2012: Program Coordinator for the Water Supply Management Program in Luwu (the program
worked in cooperation with Indonesian NGOs Swadaya Lingkar and Telapak)
 2013: Mediator Team member for Conflict Resolution between the Karunsi customary community
and PT Vale
 2014: Legislator at the Luwu Regional House of Representatives as a Gerindra Party (chaired by
current Defence Minister, Prabowo Subianto) representative.

Rachmat K. Foxchy alias ‘Bang Ories’: Foxchy is a Luwu-based activist and media entrepreneur, owner and
manager of news website http://newstabloidsar.com. Foxchy is also the Executive Director of Luwu-based
NGO Pembela Arus Bawah. He is an opportunist, actively using his media website as a coercive instrument,
applying pressure to local officials for personal and fiscal benefit. His opportunism extends to his NGO
activities, joining any issue or cause where he can benefit, depending on the issue or situation. His public
influence, via his media connections, and his NGO activism is a powerful tool. He has a reputation of siding
with the party that provides the most personal gain. This can either be, local government, communities or
local organizations, or potentially with the client company, if he can benefit. Sources indicated that he has
made contact with company members in the past.

H. Kamal: Kamal is the largest coffee trader in the Latimojong and Bajo Districts. He purchases
approximately three tons of coffee from the local coffee farmers in the area. He has an extensive network
exerting considerable influence in the area. He is well-respected among local residents in the two districts,
and is known to be sensitive towards the environment and its impact on the coffee trade in the region.

Sultan D. Somme: As the Sampeang Village Head, Somme has publicly raised his concerns that the mining
project can cause environmental damage, mentioning drilling activities conducted by the client can trigger
landslides and pollute the Songgang River. He is also the chairman of the Muslim Brotherhood (PARMUSI).

Agricultural Economy
In Luwu Regency, agriculture is the most important economic sector providing the highest level of
employment for local residents. The agricultural sector is traditionally and culturally the most respected
sector. Key agricultural products in Luwu are:

 Coffee
 Cacao
 Cengke or cloves
 Rice

Luwu Regional Investment Board sources explained that agriculture was their preferred economic sector,
and that the Board and villagers in the mountainous Latimojong and Bajo District had concerns regarding the
mining sector’s potential impact on the environment.

Negative Sentiments in Belopa

In Belopa residents are aware of the environmental concerns that communities in Latimojong and Bajo
Districts have towards the client and its mining activities. Some do not directly share these concerns or
actively criticise the Client and its project. However, the recent Masamba disaster has made them more
aware of potential environmental concerns and associated risks.

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Interviews with local community activists based in Belopa established that information had circulated among
activists in Luwu Regency’s capital that the Client was possibly polluting the Songgang River. The activists
said this information circulated very quickly on social media and were immediately concerned because the
Songgang River is Belopa’s main water source.

The Luwu Regency has a vocal, active and educated environmental activist network that are very aware of
current events. The activists are alarmed by the potential risks associated with mining activities. Activist
sources stated, ‘local people already understand the problems.’ They further mentioned that the local
environmental network would definitely mobilise and act against the Client if there was clear indication of
the mining company polluting the river or damaging the environment.

Negative Sentiments in Palopo

Many Palopo students and journalists share negative sentiments towards the mining sector in general and
mining activities taking place in the wider Luwu area. The perception is that mining can damage the
environment and local economy making poor communities even poorer. The Masamba disaster has
strengthened this sentiment.

Among local journalists that covered the flash floods in Masamba, a story was circulated alleging that mining
in the mountainous Seko District in North Luwu Regency was responsible for the flash floods. The Seko
mining site is an isolated location. Because there is little information on what kind of mine it is, a conspiracy
theory is circulating among local journalists and activists that the mining activities in Seko District are related
to a geopolitical power struggle between China and the US to control the area.

These kinds of conspiracy theories fit into a wider nationalist narrative that foreign elements are attempting
to take over natural resources in Sulawesi and Indonesia as a whole. These sentiments are strongly
supported by conservative Islamic groups and student groups in South Sulawesi Province, including Palopo,
the second major city after Makassar with a large student population.

Students in South Sulawesi Province including Makassar and Palopo are renowned for being hot-headed and
easily provoked. Student protest demonstrations can often escalate into violent clashes with police, student,
and other groups.

The potential threat exists where large numbers of suitably motivated, well organised students will mount a
protest campaign against the client and their mining operations over environmental, underlying local and
nationalist issues.

Political

A significant threat is that political elite groups will use the Client as a political commodity by questioning the
socio-economic benefit of the mining project and the Client’s presence in the area. Indications suggest that
these are groups have vested political and business interests in Luwu Regency and the wider area of Luwu,
including Luwu’s political and business capital Palopo.

Their objective and focus directed towards the client is to either use political coercion to win a substantial
business contract or secure other financial benefit from the client and/or to gain electoral popularity.

Another possible objective may be to undermine the Client’s entire project with the aim to take over and
acquire the mining project, replacing the client with another business entity to exploit production at the gold
mine.

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Potential threats from political groups exist on multiple levels as highlighted below:

1. Regency Level: The current Regent Basmin Mattayang plays a dominant role in the relationship
between local and regional political elite’s and their relationship with the Client. However, the
previous Regent Andy Mudzakkar, who is now the political opposition, remains an important
political figure.

2. Regional Level: Political elites control the three regencies and one city municipality in the Luwu area.
These elites maintain long established political attitudes towards new companies and vested
interests in the wider area, including mining companies. Their attitude towards a company in general
is largely based on financial opportunity, political leverage, and addressing potential community
concerns. They may politicize community concerns to rally populist support increasing their
powerbase for regional elections in Luwu.

3. Provincial and National Level: The client company can draw the attention of political elites in the
following circumstances:

a. Environmental groups and NGOs are successful in drawing national attention for their
environmental concerns related to the Client’s project. Following the Masamba incident this
possibility has become a lot more viable.

b. Escalation of security incidents at the project site with allegations of human rights violations
triggering scrutiny from provincial and national authorities, legislators and rights groups.

c. Noncompliance issues where the Client is facing allegations that it has violated or failed to
comply with Indonesian government regulations. This will trigger scrutiny from relevant
departments at provincial or ministerial level, examples are:

 Ministry of Environment and Forestry receive reports that mining activities are triggering
landslides in the area, raising fears about deforestation and a potential natural disaster such
as the Masamba disaster.

 Ministry of Manpower and Provincial Manpower Agency receive reports of undocumented

foreign workers working at the Client’s mine site triggering an inspection and investigation.

 Ministry of Manpower and Provincial Manpower Agency receive reports that some of the
workers in or around the Client’s mine site are under aged, where it is unclear whether they
are part of the Client or contractor workforce or are workers employed by illegal mining
groups.

The Indonesian political environment is highly fluid and dynamic. In this environment continuous cross-
relationships and shifting connections exist between politicians at the regency, regional, provincial and
national levels. This is achieved through family connections, political party affiliations, business
relationships, and or through previous careers in government agencies such as INP or TNI.

Luwu Regency
In Luwu Regency, business and politics are closely entwined. Politicians own businesses and small business
owners aspire to become DPRD members hoping to benefit their commercial interests. Successful business
people often get involved in regional politics to obtain respect and status within their community. In Luwu’s
current political environment, the three most powerful, politically motivated stakeholders that the Client
may need to interact with are as follows:

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distribution on a business basis only. No third party dissemination without written approval of management.

1. Regent H. Basmin Mattayang

2. Deputy Regent Syukur Bijak

3. Former Regent Andy Mudzakkar

While more politically motivated stakeholders are involved, the current political landscape is roughly divided
between the Mattayang camp and the Mudzakkar camp, which also impacts the Client. Both Mudzakkar and
Mattayang could potentially run for South Sulawesi Governor during provincial elections in 2023 and will
likely play an influential role in the 2023 Luwu Regional election.

During field inquiries, sources stated that there was an alleged relationship between the Client and some of
these political stakeholders. In Ring Two, the current Sampeang Village Head, Sultan D. Somme, who
unsuccessfully ran as a Luwu Regional Legislator in 2009, and has been Village Head since approximately
2000, alleged that the Client had made a deal with Andi Mudzakkar while he was still Regent. This alleged
deal involved the Client’s promise to improve the infrastructure in exchange for Mudzakkar’s political
support. This alleged deal was beneficial for Mudzakkar.

However, the current regent H. Basmin Mattayang has allegedly inherited this deal, according to the source.
The primary difference is that he inherited the deal without the alleged benefits that his predecessor gained.
The Village Head described this as: “Orang lain yang menikmati madu, kita yang sekarang tinggal racun nya
saja,” or “others enjoyed the honey, we have been left the poison.” The poison relates to no progress in
developing local infrastructure and road access in Latimojong and Bajo Districts despite the community’s
expectation. The Village Head stated that this had upset many community members in Bajo District and
increased the risk of local residents blocking the access road to the Client’s mine site.

Luwu Regent Mattayang

On 27 July 2018 the Luwu Regional Election Commission announced that H. Basmin Mattayang and his
candidate for deputy regent Syukur Bijak had won the election beating their opponents Patahuddin and
Emmy Tallesang with 117,230 votes versus 76,206 votes. Mattayang was supported by a wide coalition of
parties consisting of the National Democrat Party (Nasdem), Indonesian Democratic Party of Struggle (PDI-P),
United Development Party (PPP), National Conscience Party (Hanura), Indonesian Justice and Unity Party
(PKPI), the Crescent Star Party (PBB) and the National Awakening Party (PKB).

Field inquiries indicate Mattayang’s ambivalence towards the Client and its mining project. There are
indications that the current regent is maintaining a balance between economic opportunity and benefits for
the regency and his political network, and environmental and social concerns many residents of Luwu
Regency have towards the Client’s mining project.

Key factors influencing Mattayang’s attitude towards the Client include the following:

 The level of short term economic benefit and business opportunities the project can provide for his
political camp, network, support base and constituents.
 The level of attention that is given to environmental concerns and the potential impact of the Client’s
project site, and whether local community groups and Luwu-based environmental activists will start a
campaign that will push environmental concerns onto Luwu Regency’s political agenda ahead of the
2013 Regional Election.
 The progress that is made by the Company and local government in improving local road access and
infrastructure in Bajo and Latimojong Districts.

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distribution on a business basis only. No third party dissemination without written approval of management.

 The relationship between the Client and local community members in both Ring One and Ring Two. If
there is a deterioration of ties between the community leading to potential protests or roadblocks,
there is likelihood that the regent will increasingly distance himself from the mining project.

Analysis of Mattayang’s political career and network has identified that the 62-year old is a seasoned
Sulawesi-based politician that is building a political dynasty for his family who are aiming to become one of
the most powerful groups in the Wider Luwu area and in South Sulawesi Province. His wife Hayana Hakim
was head of the Luwu Legislature from 2009 until 2014.

It is evident that if the Client and its activities become problematic for the political career of Mattayang and
his family, his attitude towards the Client will shift dramatically becoming an immediate and high threat for
the Client’s mining project.

Indications of Mattayang’s political dynasty are based on the following observations:

1. His continuous and successful ambition to become regent. When Luwu was established as new
regency, Mattayang became its first regent. However, he lost after just one term. He joined the 2018
regency election and won again. Field sources indicated that he may either run for election in 2024 or
may even potentially aim for the governorship of South Sulawesi Province, scheduled for the same
year.

2. Mattayang’s three sons are involved in regional politics and hold influential positions in socio-political
organizations in Luwu Regency. They are being prepared for their own political careers aimed at
further strengthening the family’s political position in South Sulawesi Province.

3. The political experience that Mattayang can rely on is based on his activeness in regional and
provincial politics since 1983 when he started to work as a staff member for the South Sulawesi
Provincial Government. He has an extensive network among various socio-political organizations and
can rely on vast experience in governing and managing the political process. His self-confidence as a
political leader is displayed by his modest appearance in daily meetings where he often does not use
any bodyguards or maintain a large entourage to draw attention.

Any expansion of political influence and power in Indonesia requires financial resources and that regional
politics and governance in South Sulawesi Province have traditionally been associated with corrupt practices.

During his first tenure as Luwu regent, Mattayang along with administration officials and dozens of
lawmakers were under police investigation in 2007 for their alleged involvement in the misappropriation of
IDR1 Billion of the local budget.3 Mattayang maintained his innocence, arguing that the money he disbursed
was allocated from the previous administration. On 5 February 2009, the Makassar District Court acquitted
Mattayang, former administration secretary Baso Gani, and 27 lawmakers in the case.

Regarding Mattayang’s business interests, the website of Luwu Regency states that he is a Director for the
company PT Tasi Celebes Internasional and a Commissioner in PT Ahkam Mega Putra.

PT Tasi Celebes Internasional was established in Makassar on 1 May 2003 by Mattayang and his family. The
company has three shareholders: Basmin Mattayang (50% shareholding), Mattayang’s wife, Hayarna Hakim
(40% shareholding) and Mattayang’s son, Andi Muhammad Arham Basmin (10% shareholding).

3
https://nasional.tempo.co/read/103992/polisi-periksa-bupati-luwu-sebagai-tersangka

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distribution on a business basis only. No third party dissemination without written approval of management.

The company is officially registered with the Ministry of Law and Human Rights. It provides a wide range of
business activities, including mining (nickel, coal, iron, marble and granite), oil and gas, transportation,
business consulting and distribution. The company had an authorized capital of IDR 100 Million, issued
capital of IDR 50 million and paid-up capital of IDR 25 million. PT Tasi Celebes Internasional is classified as a
small enterprise according to Law 20/2008 on Micro, Small and Medium Enterprise.

Inquiries into PT Ahkam Mega Putra did not produce any results, and it is likely that this company is no
longer active.
Sources from the Luwu Regional Investment Agency stated that Mattayang and his regional government
were aware that all licensing regulations for the Client’s mining project were being regulated and issued at a
national ministerial level. The Regional Government knows its hands are tied, and therefore Mattayang only
gets involved in a reactive manner concerning the Client’s mining operation. If there is an incident or
development related to the mine site, the Regional Government will be forced to act and respond by
conducting a field visit, investigation or another response.

In March 2019 during a visit to the Client’s operation, Mattayang threatened to shut down the mining
project if no mining activities occur in the area.4 His media statement exhibits sensitivity to the complaints of
residents in Latimojong and Bajo Districts that the company had been in the exploration phase for nearly 40
years.

If a situation arises where the regent has to scrutinize or apply pressure to the Client, the political means at
his disposal include the following:

1. Bureaucratic apparatus, more specifically, the different regional government agencies (Dinas) that
have a role in monitoring companies in the area can create various obstacles for the Client through
sudden inspection checks, audits and investigations. This includes the Regional Environmental
Agency, the Manpower Agency, the Regional Trade and Industrial Agency and the Regional Transport
Agency. Mattayang has personally appointed many of the heads of these agencies in 2019 and 2020;
he commands a high level of loyalty.

2. Deputy Regent Syukur Bijak allegedly maintains control over a large group of street-thugs and can
provide the political muscle for protests/demonstrations and road blockades to apply pressure and
coerce businesses.

3. The regent’s three sons maintain influential leadership appointments and positions in social-political
organisations in Luwu Regency. These organisations can quickly be mobilized to rally or put pressure
on opponents.

4. The regent’s political allies within the Luwu DPRD Legislature, including the DPRD Chairman who is a
close political confidante of the regent.

5. Local media, including the Regional government’s own television channel Pemda Luwu TV. Regent
Mattayang makes full use of the television channel with daily speeches and visits to villages
broadcasted on a continuous basis.

Bureaucratic Apparatus
Since his appointment in 2019, Mattayang has appointed loyalists to key positions within the regional
administration.5 Key appointments are as follows:

4
https://gosulsel.com/2019/03/25/bupati-luwu-warning-hentikan-aktifitas-perusahaan-tambang-emas-pt-masmindo-dwi-area-di-
latimojong/
5
https://tekape.co/lantik-pimpinan-tinggi-pratama-di-lingkup-pemkab-luwu-bupati-terapkan-prinsip-kerja/

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distribution on a business basis only. No third party dissemination without written approval of management.

 15 February 2019: Ir. H. Saiful Abdul Latief - Agency Head of the Luwu Regional Manpower Agency.
His previous position was Administrative Head of the Development and Procurement Service
department within the Luwu Regency Secretariat.

 30 December 2019: Drs. Husain Parewoi - Agency Head of the Regional Trade and Industry Agency.
His previous position was Secretary of the Regional Office for Women and Children Empowerment.6

 15 April 2020: Andi Pangerang appointed as Agency Head of the Regional Environmental Agency. He
previously was the Agency Head of the Regional Agricultural Agency.7

Regent Mattayang typifies most politicians and prefers to place people loyal to him. He ensured that none
of the current heads served under the previous regent Andy Mudzakkar. It is evident that Mattayang prefers
to manage the lucrative regional agencies of Investment and Transport directly. For the last 18 months,
those two agencies have only had temporary caretakers.8

Deputy Regent Syukur Bijak

Bijak is the current Luwu Deputy Regent. He previously held the position as Deputy Regent from 2009 to
2014 under Andy Mudzakkar. Access to this political muscle is likely one of the reasons that Mattayang
selected him as his running mate. In the wider Luwu area, Bijak has a reputation of being a belligerent
politician with alleged connections to regional thugs and criminal elements in South Sulawesi.

During previous South Sulawesi gubernatorial elections, he allegedly used a rock to damage the vehicle of
supporters of then Governor Syahrul Yasin Limpo and Agus Arifin Nu’mang. Bijak reportedly had a bad
relationship with Regent Andi Mudzakkar during his first term as Deputy Regent. On one occasion, he
intentionally crashed into Andi Mudzakkar’s vehicle.

Information from local sources indicated that Bijak allegedly was arrested over possession of Crystal
Methamphetamine also known Sabu-sabu. However, he was allegedly released because of his political
connections.

Bijak has a son, Muhammad Dhevy Bijak, who is a member of the Indonesian House of Representatives in
Jakarta representing the Democrat Party for the South Sulawesi9. Inquiries established that Muhammad
Dhevy Bijak is a Commissioner in a tin mining company named PT Bintang Utama Abadi. The company’s
registered address is Desa Harapan, Kec. Walenrang, Kabupaten Luwu. Jl. Poros Harapan Luwu 91951.

Mattayang’s sons
Information from various sources suggests that the Luwu Regent is actively preparing his sons for political
careers. His sons’ political positions are as follows:

 Arfan Basmin: Recently won a local election as the village head of Senga Selatan, which is an
important sub-district in Belopa District as the price of land in this area is among the highest in
Belopa.

https://palopopos.fajar.co.id/2019/05/02/basmin-saya-akan-ganti/
6
https://palopopos.fajar.co.id/2019/12/30/malam-malam-bupati-luwu-lantik-2-kadis-dan-6-kabid-dan-camat/,
http://teropongsulseljaya.com/2019/11/29/jabatan-kepala-dinas-perdagangan-dan-p3a-kab-luwu-di-perebutkan/
7
https://makassar.tribunnews.com/2020/04/15/basmin-mattayang-mutasi-kepala-dinas-di-tengah-wabah-virus-corona
https://palopopos.fajar.co.id/2020/04/16/6-pejabat-bergeser-4-pejabat-nonjob/
8
https://docplayer.info/42017026-Pangkat-gol-ruang-pembina-utama-eselon-ii-a-2-h-basir-s-sos-mp-pembina-utama-muda-iv-c-
pembina-utama.html
9
https://beritakotamakassar.fajar.co.id/berita/2018/08/09/putra-wakil-bupati-luwu-terpilih-devi-bijak-maju-caleg-dpr-ri-dapil-iii-
sulsel/, https://fraksidemokrat.org/anggota/page/2http://www.dpr.go.id/blog/profil/id/1830

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distribution on a business basis only. No third party dissemination without written approval of management.

 Arham Basmin: Head of the South Sulawesi provincial chapter of the national committee of
Indonesian youth KNPI, a Golkar party youth wing that prepares regional politicians for their political
careers.

 Andi Muhammad Ahkam Basmin: Current leader of the Luwu Regional branch of the powerful mass
organization, Pancasila Youth or Pemuda Pancasila (PP). This organization remains politically powerful
in Sulawesi. He was also an official in the Luwu Regency’ Manpower Agency.

As leader of Luwu Regional branch of PP, Andi Muhammad Ahkam Basmin has placed many of the family’s
key allies into the leadership structure of the mass organisation. The organisation’s deputy head is
Muhammad Iqbal Halwi, also the Head of Finance at the Luwu Regional Secretary Office. Another deputy
head, A Satti Latif, is the Secretary-General of the Luwu Satpol PP Public Order Agency10. This
interconnection between the regency and PP represents a significant power base and level of influence over
various public affairs in Luwu Regency.

Regent Mattayang and his family’s strong control over the Luwu branch of PP exhibits the family’s political
power. Regional politicians cannot ignore the organisation if they want to get elected or successfully govern.
Pemuda Pancasila is the only mass organisation present in Belopa and Luwu Regency, and therefore has a
monopoly in socio-political control or influence peddling in the area.

Pancasila Youth or Pemuda Pancasila

Pemuda Pancasila maintains an influential and well-established position within Luwu Regency many PP
members. At least one PP leader resides in Latimojong District. The PP regional leadership will use local
resident members for information collection on the Client’s activities and to instigate detrimental actions
against the Client as needed, including road blocks and protest demonstrations in Belopa.

Other social groups in Belopa don’t like to work with PP renowned for using its activities for financial gain. It
is highly likely that PP will use its political and social influence to try and win contracts from Client and its
contractors. If the Luwu PP leadership fails to win contracts and/or receive immediate benefit from the
Client at the start of operations, it will be a critical loss of face for the organization, especially as the
chairman is the son of the Regent.

In this situation, PP will likely initiate and undertake various adverse campaigns against the Client. This will
include political coercion through affiliation with the regent, protests, personal intimidation, media and
social campaigns to stir up local sentiment against the company and/or increase environmental activism or
scrutiny from the regional administration.

Luwu DPRD
Regent Mattayang’s strongest asset in the DPRD is the current chairman, Rusli Sunali, who will maintain his
position for the period 2019 - 2024. The former student activist was the campaign manager of candidate pair
Mattayang and Bijak during the 2018 Luwu Regional Election.

The 30-year old Sunali has been a DPRD member since 2009 and represents the moderate Islamic-based
United Development Party (PPP).11 He is the PPP Luwu branch chairman and is also a close associate of
Provincial House of Representatives Member Abdul Hafid Pasiangan, who is also the President Director and
Owner of the Client’s Security Manpower Provider PT Mitra Prata Milenia.

10
Polisi Pamong Praja is the Public Order Agency. Each regency or city municipality has this agency that acts as civilian guard
personnel focused on upholding public order and compliance with regional regulations and directives.
11
Partai Persatuan Pembangunan

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distribution on a business basis only. No third party dissemination without written approval of management.

When Sunali was a student, he was active in the Muslim-based organizations Himpunan Mahasiswa Islam or
Islamic Students Association and Ikatan Mahasiswa Muhammadiyah or the Muhammadiyah Student
Organization, which is closely affiliated to the moderate Muhammadiyah mass organization.

The Luwu DPRD is currently deliberating a new regional regulation on foreign investment in Luwu Regency.
This regulation will also outline the local-local requirement. The deliberation is expected to be completed in
September 2020.

The current leaders of the Luwu DPRD are drawn from different political parties, rather than from the Luwu
Regent’s political party, as follows:

Name Position Party

Rusli Sunali Chairman United Development Party
Mappatunru Deputy Chairman United Indonesia Party
Zulkifli Deputy Chairman Golkar

The Indonesian Democratic Party for Struggle (PDIP) lost its seats in the DPRD during the 2019 regional
legislative election. The current powerful political parties are Nasdem and Golkar, which are traditionally
strong in South Sulawesi due to its grassroots network and connections within local administrations.

Under the leadership of PPP Chairman Rusli Zunali, a close ally of Regent Mattayang, the United
Development Party has become the largest party in the Luwu DPRD during 2019-2024.

The Luwu DPRD comprises the following:

Political Party # of Lawmakers

National Awakening Party 2
Democratic Party 1
Golkar Party 3
Greater Indonesia Movement (Gerindra) 1
National Democrat Party (Nasdem) 5
National Mandate Party (PAN) 1
People's Conscience Party (Hanura) 2
Social Justice Party (PKS) 5
United Development Party (PPP) 10
United Indonesia Party (Perindo) 4
Indonesian Justice and Unity Party 2
Total 36

Local Media
Regent Mattayang makes full use of the regional television channel Pemdu Luwu TV. The channel broadcasts
mostly of Mattayang’s speeches and gatherings with local communities almost 24-hours a day. The regent
and his administration clearly make full use of this media source to strengthen their image in the community
and increase their popularity.

Mattayang used one speech broadcasted on 27 July to criticize the DPRD and political parties warning them
not to sow division among communities by politicizing them. This is clearly an example of how Mattayang
uses the regency’s television channel for his own political interests and strengthen his position.

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distribution on a business basis only. No third party dissemination without written approval of management.

The television channel can potentially be used by the regent to attack its opponents, which can include the
company. If the regent feels that he has limited influence over the company due to central government
policies and directions, he may potentially use the television channel to attack the Client. He will likely stir
local sentiment against the company fulfilling his own agenda while supporting his own political base. For
example, if there are allegations of environmental degradation or pollution, the Regent would be compelled
to conduct his own investigation and address local sentiment. He can use of the television channel to
publicising his commitment to investigate the case while promoting his agenda.

Former Regent Andy Mudzakkar

Mudzakkar was born in Palopo on 11 November 1964. He is the son of separatist leader Kahar Mudzakkar,
who still has considerable popularity in South Sulawesi Province. Kahar Mudzakkar’s children are all
politically active in South Sulawesi Province, and sometimes have competing political interests and inner-
family disputes.

Andy Mudzakkar was Luwu Regent from 2009 until 2019 and remains popular, including in Bajo and
Latimojong Districts. He started his political career in 1999 when he became Deputy Chairman of the Luwu
Regional House of Representatives. In 2002 he became Deputy Chairman, Palopo Regional House of
Representatives. He then switched back to the Luwu Regency becoming Deputy Chairman, Luwu Regional
House of Representatives from 2004 until 2009. In 2009 he successfully won the regency election by
defeating the incumbent Basmin Mattayang and became a two-term regent until 2019.

Mudzakkar has played an influential role in the local branch of the Golkar Party and was branch chairman
from 2010 until 2015. He has maintained an influential position since 2010 as the Chairman of the TNI and
Police Family Communication Forum (FKPPI) Luwu, an organization closely affiliated to TNI and INP.

Wider Luwu Area

Sources explained that Palopo is both the political and business centre of the wider Luwu area comprising
four municipalities:
 Luwu Regency  East Luwu Regency
 North Luwu Regency  Palopo City

Makassar and Palopo are the two most important political centres in South Sulawesi Province.

Luwu political elites and their supporters gather in Palopo to discuss strategies and commence preparation
for regency elections. Local sources affirmed that regional politics are conducted in an aggressive manner
where candidates are supported by political brokers who have the reputation of doing ‘whatever it takes’ to
get their candidate elected. Politicians, their brokers and allies often come together at Enzyme Café in
Palopo to discuss strategies, make political deals and expand their support base.

Being former administration officials with large collusive and nepotistic networks among the local
administrations, regional leaders still follow the traditional modus operandi. To win a political campaign a
candidate needs to normally invest billions of Rupiah.

Luwu Region includes the areas of Luwu Regency, Palopo City, Luwu Utara Regency and Luwu Timur
Regency. The local people understand that currently, the local government is in the process of forming the
Luwu Raya Province. Government regulations number 78/2007 on provincial formation states, that
formation of a province requires a region to comprise a minimum of five Regencies or Cities. Therefore the
formation of Luwu Raya Province is currently pending on the formation of the Central Luwu Regency. This is
to be achieved by changing Walenrang and Lamasi areas into several Districts and Sub-Districts.

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distribution on a business basis only. No third party dissemination without written approval of management.

It is also important to note that Palopo has four universities with an approximate student population of
10,000. The universities’ student organizations can potentially provide powerful political support with
student demonstrations and activism to support political campaigns against the Client. Student
organizations have a proven track record of conducting protest demonstrations.

The Luwu Regional Government is inexperienced in dealing with foreign investors and the regulations
applicable to foreign owned companies. Foreign investors need to use a personal and cautious approach to
assist local government staff with interpretation and application of regulations.

South Sulawesi Provincial Politics

Powerful families in South Sulawesi Province include the following:

 Kalla family: Jusuf Kalla, the former Vice President under the SBY administration and his extended
family, Mahmud Aksa and his son. Kalla owns the Haj Kalla group that owns many businesses in
cement, nickel mining, car dealerships and property. Aksa controls the Bosowa Group which has
many businesses including property, hotels, energy and media.

 Limpo family: The family is led by current Agricultural Minister, Yahsin Limpo. He was previously the
South Sulawesi Governor, while his brother was Luwu Regent. They also have an extensive business
network.

 Mudzakkar-family: The children of the national hero, Mudzakkar who fought against the Dutch and
then became a separatist leader include his son, Andy Mudzakkar who ran as a candidate for Vice
Governor and still is a powerful player in Luwu Regency. He has spoken out against the Client over
governmental concerns.

Corruption, Extortion and Coercion

There is a potential threat of unscrupulous government officials from the Luwu Regional Government
attempting to embezzle or steal funds allocated for the road improvement and expansion project. The Client
will undertake and fund the road project, while the Regional Government will arrange compensation and
payments to local villagers. If some of the funds are stolen by government officials, the Client will not only
face financial loss but likely suffer reputational damage by being associated with a project rife with graft and
corruption.

This threat must be placed in the context of rampant graft practices in government agencies in South
Sulawesi Province (and Indonesia in general). In February 2019 anti-graft watchdog Indonesia Corruption
Watch (ICW) released a report that detailed cases of corruption within local administrations. South Sulawesi
ranked third (East Java topped the list of provinces with the most cases, followed by the province of Central
Java). According to the ICW, cases in regional governments typically involved abuse of the local or state
budget, corruption in procurement projects, illegally obtained permits for infrastructure projects, or bribery
to secure promotions.

The provincial High Prosecutor’s Office formed a special unit (Satgassus) to curb rampant graft in South
Sulawesi Province in May 2018. The High Prosecutor’s Office said the establishment of the special unit was
urgent as the number of graft cases in the region had reached an alarming level. However, it is unlikely to
change firmly entrenched ‘business practices’ overnight in the province, or for that matter in the country.

Widespread corruption in Indonesia exists in the country’s judicial system and across the government and
commercial sectors. Bribes continue to influence prosecutions, convictions, and sentencing in countless civil

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distribution on a business basis only. No third party dissemination without written approval of management.

and criminal cases. Collusion and nepotism have also marred the country’s executive and legislative
branches, the three main pillars of the Indonesian state are involved in systemic corruption, a situation that
is a setback for the reform campaign.

According to Transparency International’s (TI) 2019 Corruption Perceptions Index (CPI), Indonesia’s record
remains poor with a score of 40, the same level as Trinidad, Tobago, Lesotho, Kuwait, Guyana, and Burkina
Faso. Although Indonesia remained a promising emerging economy, TI deemed that corruption is coupled
with repression of civil society and weak oversight institutions. The independence and effectiveness of
Indonesia’s anti-corruption commission, the KPK, has been thwarted by government, and Indonesia faces
the risk of scaring off investors and slowing economic progress. The survey ranked Indonesia in fourth place
in South East Asia behind Singapore, Brunei, and Malaysia.

Makassar was ranked second on a list of the most-corrupt cities in Indonesia, according to the Corruption
Perception Index (CPI) released by NGO Transparency International Indonesia (TII) on 22 November 2019.
Medan scored the worst on the CPI with 37.4 points, followed by Makassar (53.4), Bandung in West Java
(57.9), Semarang in Central Java (58.9), Surabaya in East Java (61.4), Manado in North Sulawesi (62.8) and
Padang in West Sumatra (63.1). The survey, conducted from June to August 2019, involved 1,200 business
people from the manufacturing, service, trade, construction and finance sectors in 12 major cities across the
country. The cities included on the list were chosen due to their high contribution to gross domestic product
values on the national level.

The most phenomenal corruption case was the investigation into the e-KTP corruption case, which
eventually put the speaker of the House of Representatives (DPR), one of the most powerful politicians in
Indonesia, Setya Novanto, in jail in 2018. The state is believed to have suffered losses of IDR 2.3 trillion in
this massive corruption case.

Luwu Regency
Business sources based in Belopa explained that when they start a new company, they use their family
connections in the local administration to accelerate the licensing process. They stated that this common
practice significantly reduces commencement times their businesses are operational. These family
relationships used to support local businesses are also used to act against other companies or individuals
whose interests may pose a threat to their own interests.

Several instances of this type of public/private corruption in Luwu Regency are as follows:

1. During his first tenure as Luwu regent, Mattayang along with administration officials and dozens of
lawmakers were under police investigation in 2007 for their alleged involvement in the misappropriation
of Rp1 billion from the local budget. Mattayang maintained his innocence, arguing that the money he
disbursed was allocated from the previous administration. On February 5, 2009, the Makassar District
Court acquitted Mattayang, former administration secretary Baso Gani, and 27 lawmakers in the case.

2. On 26 September 2019, the former head of the Luwu Regency Social Affairs Agency, Mursyid Dufrie and
the former head of the agency’s department managing poverty reduction, Asmawi Alwi became suspects
in an embezzlement case involving IDR 120 Million from a local microcredit program. This case is still
ongoing12.

3. In November 2019 local media reported that an anti-corruption unit from Polres Luwu were
investigating a corruption case relating to the 2015 regional budget. The corruption allegedly involved
procurement fraud during the allocation of a new pumping system by the Regional Agency for

12
https://regional.kompas.com/read/2020/06/10/18130951/2-tersangka-korupsi-dana-kube-dititipkan-di-tahanan-polres-luwu

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Plantations and Horticulture. The project value was IDR 1.4 Billion and was divided into thirteen project
components.13

4. Local residents in South Larompong District, Luwu Regency reported their suspicions to police
concerning corruption during a road improvement project. The project budget was IDR 87 Million and
was funded by the 2018 Village Budget. However, the quality of the work was inferior failing to improve
road conditions. The road was again in need of repair in 2020. Some of the villagers raised questions
about the role of the Village Head in the road improvement project.14

Corruption poses a significant challenge in the Client area as local village rely on village funds to build their
infrastructure. According to sources, local officials embezzled social funds provided by the central
government in 2017 to help alleviate poverty in Luwu Regency.

It is common for local bureaucrats to be involved in business ventures taking place in their administrative
area. Luwu Regency is no exception. Private businesses are required to adhere to the local ‘liaison
procedures’15, generally set by the regional leaders, when tendering for large or small projects. While this
requirement is not justifiable by any legislation or regulation, failure to follow ‘local procedures’ will result in
companies encountering difficulties in obtaining contracts for project work in the Regency. As previously
mentioned, there are strong family links between business, politics and government. It is common for
Belopa residents to use their family connections in the local administration to accelerate the licensing
process when starting their companies.

The highest threat to the Client during construction phase is that unscrupulous government officials from
the Luwu Regional Government may attempt to embezzle or steal funds allocated for the road improvement
and expansion project. The Client has an agreement with the Luwu Regional government to conduct a road
expansion/construction project for the main access road up the mountain to the mine site in Latimojong
District. Many business owners have family members in the regional government who facilitate corruptive
practices that are part of a well-entrenched culture of nepotism, collusion and often corruption.

The following are potential threats to the Client’s planned infrastructure project:

 Fraud and Corruption by corrupt regional officials during land compensation payment process for the
road improvement project or during the land acquisition process:

1. Listing fictitious residents as compensation claimants to embezzle funds. The Client will be
exposed to possible allegations of involvement or association with corruption in a government
project through its partnership with the Luwu Regency Administration.

2. Manipulating, marking-up or forging compensation figures and documents for claimants, then
embezzling a percentage of the compensation payments.

3. Collusion with claimants to increase the amount of compensation demands, including the
potential demanding compensation, direct from the company.

4. Collusion with local residents to incite protests against the company, forcing the company to
negotiate where corrupt officials act as negotiators and arbitrators to mediate and appease
protesting residents. These officials will request payment either directly from the company or
will share any company settlement as a partial commission with colluding residents. In some

13
https://koranseruya.com/polisi-endus-korupsi-rp14-miliar-di-luwu-ini-dugaan-kasusnya.html
14
https://kabar.news/lapor-polisi-warga-desa-salusana-luwu-curiga-ada-korupsi-pembangunan-jalan
15
A local government term for corrupt payments to officials.

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cases, they will take a service fee from the company and share the commission from the
settlement with the colluding residents.

 Fraud and Corruption threats directed to Client subcontractors during the tendering process for the road
expansion project:

1. Regional officials will provide a list of local contractors for the Client’s consideration and then
pressure the Client to choose specific contractors to execute the project. These contractors are
linked to the official by possibly being owned by 1) family members or close personal/business
associates or 2) directly owned by the officials but registered under different names (family or
close personal/business associates). Potential pressure applied to the Client include the
following:

a. Only local contractors are accepted by community members to conduct work in the
respective villages.

b. Companies from outside the region lack required local licenses.

c. Outsider companies do not benefit the local economies

Government officials will claim that the Client will face criticism from Luwu Regency residents for
not being supportive or providing economic opportunity to local business.

2. Requests and demands that regional officials take part in the company’s tendering committee
and contractor selection process or for regional officials appoint representatives to take part in
the Client’s tendering committee.

3. Demands from regional officials that they participate in developing the Scope of Work and
Technical and Regulatory tender requirements. The aim is to develop requirements that exclude
contractors from outside of the regency and/or contractors that are not owned by or affiliated
to these officials. These requirements can include manpower requirements from the Regional
Manpower Agency, licensing requirements from the Regional Investment Agency or company
operating licenses (SIUP) issued by the Regional Industry and Trade Agency.

4. Corrupt officials establishing contractor companies that do not have the required technical or
commercial experience or financial stability as Special Purpose Vehicles to win the road
expansion project. These companies then subcontract to associated local contractors, obtaining
funds by marking-up the project value and receiving kickbacks from their selected subcontractor.

5. Corrupt officials colluding with local and regional construction companies to manipulate the
tender process, agree on a manipulated bidding price and make under the table agreements
that determine the company winning the tender and subcontracted companies for the project.

6. Road improvement and construction project tender-selected-contractors or subcontractors

using cheap and low quality materials that do not meet the technical specifications of the Scope
of Work. Procurement, specification and invoice documentation are manipulated or forged to
embezzle funds that were allocated to purchase materials as per the contract and technical
specifications. Due to the low quality of the materials (i.e., cement), the road is of an inferior
quality that shortens its lifespan. Additional construction projects would be required so that the
process is repeated, in essence a guarantee of continuation work.

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Other Indonesian government institutions are not exempt from allegations of corruption, and it has been
alleged by a number of sources that rogue elements in the Police and Military are ‘turning a blind eye’ to
activities that circumvent the law.

Illegal Narcotics

Illegal Narcotics impacting the workforce of the Client or its contractors are likely to occur. This can result in
workplace accidents that impact the operation or the company relationship with the local communities.

Identified South-Sulawesi crime groups and drug networks are actively trafficking illegal narcotics from
Nunukan Regency in North Kalimantan, through Makassar and Parepare to Palopo, where the drugs are sold
or further distributed in the Luwu Area. Drug trafficking is part of a current pandemic of Crystal Meth that in
Indonesia is referred to as ‘Sabu-sabu.’ Police sources in Luwu Regency say that drug trafficking and abuse is
one of the biggest criminal problems in the region.

As the Client/contractor workforces increase, local and regional drug trafficking networks will target these
relatively well-paid workers. Drug trafficking has impacted some local officials, including allegations that the
current Deputy-Regent, Luwu Regency was involved in the consumption of Sabu-Sabu. Sources stated that
he has contacts to criminal networks and control over a network of local thugs.

Karaoke bars and cafes are still operating near Tempat Pelelangan Ikan harbour in Belopa. Furthermore, the
sale of local alcohol also known as ballo is common, as well as gambling. It is likely that illegal drug
distribution exists and prostitution occurs in buildings known as ‘rented houses’ for women working in the
nearby cafes. Once the Belopa port becomes fully operational, trafficking narcotics in larger quantities will
become easier since the vessels from Kalimantan can moor directly in Belopa.

Drug traffickers use an eastern route starting from Malaysia’s Serawak and Sabah States crossing the border
into Kalimantan, especially to Pontianak in West Kalimantan Province and to Nunukan Regency in North
Kalimantan Province. Many of the drugs coming into Indonesia via this route are trafficked to the Western
coastal cities of South Sulawesi Province, especially to Makassar, the capital of South Sulawesi Province and
an important business hub for Eastern Indonesia. The Eastern route comprises of two alternate options from
Malaysia to Kalimantan as follows:

a. North Kalimantan Route: Commencing from the Tawau area in Sabah State across the border into
Nunukan Regency, located in the province of North Kalimantan.

b. West Kalimantan Route: Commencing from Kuching in Serawak State through Tebedu District into
the Indonesian districts of Entikong or Sekayam in the province of West Kalimantan.

The drugs smuggled through Kalimantan are mainly distributed to the Eastern part of Indonesia, which
besides Sulawesi, includes the provinces of North Maluku, Maluku, West Papua and Papua. The drug
networks often involve trans-migrants from South Sulawesi who are living in Kalimantan to serve as drug
couriers. Many business networks in South Sulawesi own and/or operate vessels and have extensive
logistical networks that are exploited for drug smuggling.

Many crystal meth traffickers based in Malaysia’s Tawau District use the entry point of Tunon Taka on
Sebatik Island to traffic drugs hidden in other imported goods destined for Indonesia. For example, packages
shipped as cargo to conceal drugs with an address in Pare-Pare, South Sulawesi.

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Drug routes from Tawau, Malaysia through North Kalimantan Province to Eastern Indonesia

Drug routes from Kuching to Western Kalimantan

In the wider Luwu area, Palopo is the centre of local drug networks that distribute crystal meth to smaller
towns and villages through networks of smaller drug dealers. Palopo has a young population with many
university students who have access to crystal meth.

Nightclubs exist in Palopo as well. However many of them have closed in 2020 due to the COVID-19
pandemic. Following the closure of Marco Polo, a popular nightclub near the port of Palopo and several
other clubs and bars, crime has fallen in Palopo,16 including stabbings and fights between thugs or
intoxicated youths that frequented the clubs. The owner of Marco Polo, Benny Tenriolo, is a powerful and
well-connected local Chinese Indonesian businessman. He is also the chairman of the THM Palopo
Businessmen Association (Asosiasi Pengusaha THM Palopo).

16
https://palopopos.fajar.co.id/2017/10/10/wali-kota-panggil-pengusaha-thm/https://tekape.co/sabtu-malam-thm-di-
palopo-mulai-buka-lagi/

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Recent cases of crystal meth trafficking and arrests are as follows:

 25 December 2019: A police officer was arrested during raid in his boarding house in Tompotikka sub-
district, Wara district, Palopo, for possession of crystal methamphetamine. Five packages containing
small amounts of the narcotics were found at the brigadier-ranked officer's boarding house.

 30 April 2020: Polres Luwu Anti-Narcotics Unit arrested a 37-year old local resident in his house in
Mentang, Larompong Subdistrict, Larompong District over complaints that he was a drug dealer and
user of crystal meth. Local residents reported him to police as there were regular visitors and
transactions at his house. Police found ten bags of crystal meth under the suspect’s carpet in his
home. The suspect told police that he had received 0.56 gram of the drug from a person in Wajo
Regency, South Sulawesi Province. Prior to this arrest, Luwu Polres members had arrested a 26-year
old drug dealer17.

 28 June 2020: Palopo Police arrested a construction worker for possession of crystal meth. Police
confiscated 0.4 grams of the drug and a mobile phone. The arrest was made following information
from local residents.

 1 July 2020: Palopo Anti-Narcotics Unit arrested a 24-year old suspect for possession of crystal
meth.18 The suspect had hidden the drugs in his pants. Police seized 0.6 grams of the drug. The
suspect said he had purchased the drugs from a local drug dealer for IDR 400,000. The police unit
subsequently arrested the drug dealer and seized six bags of crystal meth weighing of 3.22 grams and
IDR 3.7 Million in cash.

 8 July 2020: Palopo branch of the Anti-Narcotics Agency BNN arrested two suspected drug dealers in
Palopo and seized crystal meth hidden in a tube of toothpaste.19 The drugs totaling 168.7 grams were
trafficked from Pekanbaru, Riau Province. The two suspects had purchased the drugs in Pekanbaru
for IDR 100 Million. One of the suspects had acted as a courier receiving the drugs as a post package
while the other suspect was the owner of the package.

BNN officials said that transporting drugs hidden in toothpaste tubes was a new method used by drug
trafficking networks operating between Riau and South Sulawesi Provinces.

Police said the two suspects were planning to distribute and sell the drugs to customers in Luwu Regency,
Palopo, North Luwu Regency, Toraja Regency and East Luwu Regency. The sale price was IDR 3 million per
gram with a total value of IDR 500 Million, according to BNN officials.

Incidents of Theft

Theft
The potential for criminal groups or individuals stealing gold from the mine site exists. This could be achieved
through unauthorized access and infiltration or through insider support and collusion with Client/contractor
employees who are complicit in the act.

In general, crime rates in Luwu Regency are low and have been decreasing. General security in Belopa has
reportedly seen an improvement since Polres Luwu conducted a crackdown on karaoke bars and cafes which

17
https://makassar.tribunnews.com/2020/05/01/sembunyi-10-saset-sabu-sabu-warga-larompong-luwu-diringkus-polisi.
18
https://makassar.tribunnews.com/2020/07/01/beli-sabu-rp-400-ribu-warga-palopo-diringkus-polisi
19
https://regional.kompas.com/read/2020/07/08/15525441/selundupkan-sabu-di-pasta-gigi-2-warga-kota-palopo-ditangkap

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has been further supported by pandemic social distancing laws. According to locals, this has significantly
increased the general feeling of safety and security, including businesses that operate in the area.
Local businessmen confirmed that crime is low in Belopa and in Luwu Regency in general. The security
situation has also improved since the Polres station was built in Belopa resulting in a stronger police
presence in the area. While mass organizations are active in Belopa, protection fees are not usually
demanded. Multiple sources have identified that crime levels including the level of theft is not extremely
high in Luwu Regency. However, it is important to note that the existence of a gold mining operation can
attract criminal elements from various areas of Sulawesi, and even outside Sulawesi as previously
highlighted. It is noted that every gold mine is a target. In relation to the Client’s mine site, potential targets
for theft include but are not limited to:
 Ore containing gold  Scrap metal
 Gold processed in the gold room  Laptops and IT equipment
 Fuel that is stored on site or in the Belopa facility  Petty cash in offices
 Electricity  Air-conditioning sets and other electronic
 Company or contractor vehicles equipment
 Construction materials kept on site or other locations  Food supplies
 Mining processing materials and chemicals, such as cyanide  ID Cards and badges
 Building and fabrication material  Operational consumables

The biggest concern is theft of gold from the mine site. The high risk of gold theft is highlighted below:

1. The high monetary value of gold.

2. Gold theft often involves individuals who have no prior track record or experience with theft or
criminal activities. However, the possibility of taking a piece of gold and selling it has led to many
attempts of stealing.
3. General attitudes among some residents in Luwu Regency are that the gold originates from ancestral
land on Indonesian soil, and community-members are entitled to take ownership of the gold.
Lay Down: The lay-down area presents a high threat level for theft. During construction phase, easy access
to attractive items and a lack of proper illumination, CCTV monitoring and strict access control, the risk of
theft increase significantly. Another area that is prone to theft or planning of theft is the parking facility near
the process plant. Insider support and collusion to plan gold theft cannot be dismissed. Company
employees have knowledge about the location of valuable materials, what security and protection measures
are implemented and how a location can be accessed without detection.

Some examples of random theft cases at mine sites in Indonesia include the following:

1. Located in a secured lay-down yard, a shipping container with tons of cyanide was broken into;
hundreds of kilograms of cyanide were stolen. The perpetrators likely received insider support
knowing exactly which container to target, how to gain access to the lay-down yard and how to
circumvent security.

2. Employees of a mining company stole mining materials from a secured storage area. The materials
were thrown into a rubbish bin located outside of the Process Plant near a perimeter fence. The thief
was able to get access to the storage area and assistant in getting the stolen items out of the mine
site. The materials were taken from the rubbish bin and sold on the local black market.

3. Air conditioner units being prematurely replaced with new air conditioners. The old air conditioner
units were secretly stored in an empty building in the larger area of the mine site and then sold on

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the local black market. The theft involved high volumes and developed into an organized theft and
embezzlement ring with significant financial loss to the mining company.

4. Theft of scrap metal from a scrap lay down area with insider support from the mining company. The
scale of theft of scrap metal increased over time, until it became a well-organized theft ring, stealing
the scrap metal on a routine basis to supply established customers.

5. Fuel stolen from a mine site by vehicle drivers who learned how to circumvent the security
monitoring and GPS systems and transfer fuel to external vehicles at prearranged locations at the
mine site. The amount of fuel stolen increased over time, triggering financial losses for the mining
company.

Gold Room: The gold room is a key target for thieves and often involves complicit insider personnel. The
potential returns of selling stolen gold from the gold room often pushes personnel with no criminal track
record to conduct or co-conspire to steal. This can include security personnel. This risk is especially
significant when security guards are sourced and recruited from the local community. Security personnel
recruited from the local community can be compromised by threats to their family and coerced to support
and assist in stealing gold. This may simply be a request to be deliberately lax in their security awareness.

Terrorism, Extremism and Radicalism

The threat of a terrorist attack targeting Client or contractor personnel, property or other assets in the Luwu
Regency using firearms improvised explosive devices (IEDs) or edged weapons is a realistic possibility.
However, this threat needs to be taken into consideration with reference to the likelihood of a terrorist
attack occurring in the Clients area of operations.

Consideration also needs to be given to other terrorist-related activities, including criminal activities linked
to the generating funds to support terror groups in Indonesia. This includes theft, prostitution, drug
trafficking, etc. A further consideration is the threat of terrorist or violent extremist and radical groups
infiltrating the Client/contractor’s workforce. The objective of these groups would include the radicalisation
of employees, which has resulted in workforce tensions between employees and employee groups that have
escalated into larger security incidents, disputes or conflicts. An example of this occurred in Chevron in
Dumai, Riau Province.

In the provincial context of South Sulawesi, terrorism is considered a possible emerging factor by
government authorities. The region of South Sulawesi represents a focal point for the growth of terrorist
groups to project their brand of Islamic extremism across the country and internationally. At the regional
level, porous borders make movement between areas of terrorist operation relatively easy. Vast expanses of
territory and low levels of government control have enabled terrorist organizations to establish highly
sophisticated training facilities that are still able to maintain a high level of mobility but are mainly focused in
the Poso area of Central Sulawesi Province.

While there is only one specific case of terrorist-associated violence in Luwu Regency, the deeply entrenched
nature of Islamic fundamentalism and specifically conservatism penetrates the region, making it a potential
attraction for radical Islam. Any increase or movement in Islamic radicalization, through alternative Islamic
organizations in Luwu Regency, potentially represents a very high risk factor for the Client’s mining project,
its employees (whether national or foreign) and future operations in the area.

The Indonesian National Police supported by the Indonesian Military have succeeded in ending the activities
of the MIT terrorist network of killed leader Santoso in July 2016. The Poso area of Central Sulawesi has

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remained a fertile ground for radical and extremist elements. The relative proximity to the Southern
Philippines has made Central Sulawesi an important transit-area for members of terrorist groups. The
province saw widespread religious violence concentrated in Poso Regency between 1998 and 2001 that
resulted in thousands of deaths on both sides. There were incidents of violence elsewhere in the province,
including in the capital, Palu.

The sectarian conflict between Christian and Muslim groups in Central Sulawesi has left behind many
weapons and explosives in Poso and other areas that are still accessible by extremist elements. Extremist
activity to include the burning of places of religious worship is still ongoing.

The violence has left a legacy of distrust among many communities and a level of support for radical terrorist
groups that continues to this day. Poso in Central Sulawesi Province is home to the Mujahedeen in Eastern
Indonesia (MIT), a militant group tied to the Islamic State of Iraq and Syria (ISIS), and Jamaah Ansharut
Daulah (JAD), a group held responsible for various bomb attacks in Jakarta and in Surabaya in recent years,
including the Surabaya church bombings on 13 May 2018.

Terrorism, however, is a rare incident in Belopa with the last recorded incident occurring in 2016, when anti-
terror police raided a residence in Belopa and arrested two alleged terrorist, Chandra and Adri. Chandra was
known to be a member of the Front Pembela Islam (FPI) mass organisation in Luwu Regency. He was
accused of hiding suspected terrorist Adri, from Poso, Central Sulawesi. Since then there has been no
recurring terrorism-related incidents. The local government has blacklisted the FPI mass organization.

In the 1950s a separatist conflict was fought between the Indonesian military and the Islamist separatist
Kahar Mudzakkar (the former Luwu Regent’s father) who wanted to establish an Islamic State in Sulawesi.
Some of the blood-letting and killings of non-Muslims by Mudzakkar’s supporters reportedly took place in
the Latimojong area, including Rante Balla Village. In South Sulawesi there still remains a level of admiration
and respect for Kahar Mudzakkar among many residents. However, the past bloodshed in the 1950s has not
triggered any religious tension in Luwu Regency, where inter-religious relations are relatively stable.

A list of registered organizations was obtained from the Luwu Regency administration’s Social Political
Department. Officials explained that there had been a certain amount of interest from the radical Islamic
Defenders Front (FPI) to start a branch in Luwu Regency. However, approval for their registration submission
has been postponed by the regional government who is concerned that FPI will adversely impact religious
harmony and tolerance in the Regency.

In April 2020 a conservative Islamic cleric from West Java Province wanted to visit Luwu Regency to give a
religious sermon. Local authorities rejected the visit request over concerns his teachings would negatively
impact the current local culture of religious tolerance.

There is a level of established religious tolerance in Belopa and Luwu. Belopa’s neighbouring district of Enrop
has many churches of different denominations. Signs of religious tension have not been observed thus far,
and several new churches are being constructed. The regional government is not discriminatory based on
religion by denying building licenses for churches, as often is the case in Java. However, further confirmation
is required.

There is an ethnically-based organization in Luwu Regency named Bola Asera that is closely monitored by the
government. The government has concerns that Bola Asera does not follow Indonesia’s official Unitary State
philosophy of NKRI. However, source checks have not identified any further information on this group at this
stage.

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Poso - Central Sulawesi

Mujahedin in Eastern Indonesia (MIT):
Three people were beheaded, allegedly by members of MIT, in separate areas of Parigi Moutong regency in
mid-September 2015. In May 2015 Police in Luwuk arrested a member of MIT that operated from the
neighbouring Poso area. The arrested person was a logistics officer for MIT leader Santoso and had received
military training from him. MIT was previously led by Santoso, alias Abu Wardah. Santoso, at one time the
most wanted militant in Indonesia, was killed by security forces in Poso on 18 July 2016. He had pledged
allegiance to the Islamic State of Iraq and Syria (ISIS) in 2014. The Tinombala operation began in October
2015 but was extended several times, as the MIT terrorists eluded the security forces in the jungles of Poso.

MIT was responsible for several attacks on police and soldiers in Central Sulawesi, including a suicide
bombing at a police station in Poso in 2013 and the murders of several police officers in 2012 and 2011.

Central Sulawesi Police have commented that sympathizers of terrorist groups, or even suspected terrorists,
could be in Poso and could act at any time. MIT is still seen as a threat as it operates under the leadership of
Ali Muhammad, alias Ali Kalora. A two-minute, 14-second video of the new MIT chief calling for his followers
to fight and not negotiate with the government was circulating online in May 2018. Kalora, who appeared in
the video standing between two men armed with M-16 assault rifles, said his followers relied on their
weapons to avoid capture. Central Sulawesi Police reported that a police raid on an MIT base on 19 August
2017 had forced members of the militant group to disperse with some traveling to Parigi Moutong regency.

Indications of a new group were revealed when security personnel intercepted a man named Samsuriyadi,
also known as Sham, a report said in early March 2017. He told security officers that several men from Toboli
in Parigi Moutong regency as well as Poso and Tolitoli regencies in Central Sulawesi, and Mamuju regency in
West Sulawesi, had weapons that could be used to conduct attacks.

Security forces are also concerned by the potential impact or influx of terrorists from the Southern
Philippines, including Marawi where Philippine security forces have cracked down on Islamist terrorists that
pledged allegiance to ISIS. Northern areas of Central Sulawesi Province, especially Tolitoli regency and Poso,
are in close proximity to the Jolo island group in the southern Philippines, a stronghold of the Abu Sayyaf
group, infamous for kidnapping-for-ransom operations. Police have also linked the arrest of nine alleged
terrorists in Central Sulawesi and an arrest in East Java to the southern Philippine-based Abu Sayyaf militant
group in March 2017. The Merdeka Regional Military Command (Kodam XIII) commander at that time, Maj.
Gen. Ganip Warsito, said on 7 March 2017 that the military had detected several people from the southern
Philippines entering the province. The statement came after arson attacks targeting two churches in Palu in
February 2017 and another church in Poso Regency in early March 2017. There were indications that the
three attacks were launched to incite religious-based violence in the province.

Security forces in 2016 and 2017 also identified ethnic Uighurs from China travelling to Central Sulawesi to
join Indonesian terrorists in the Poso area20. An ethnic Uighur from China, wanted for allegedly supporting
the MIT, was killed in a shootout with police in Kilo village, North Poso Pesisir district, Poso regency on 17
August 2016. Another man believed to be a wanted ethnic Uighur from China and member of MIT was shot
dead by police during a foiled attack in Poso regency on 24 April 2016. A homemade pipe bomb, a machete
and explosive powder were seized as evidence. Police believed him to be the fifth Uighur MIT member to be
killed. According to an MIT Uighur member who was arrested in 2016, Uighur militants took several flights to
reach the jihadist group in Poso. Central Sulawesi Police reported that the Uighurs flew from Xinjiang, a
region in far western China, to Riau via Thailand and Malaysia before traveling to Bogor in West Java, where
a person they met took them to Makassar in South Sulawesi. From Makassar they travelled to Palu in Central

20
Uighurs come from Xinjiang, a region Beijing said is home to extremist militants and separatists. The Indonesian government said it
has worked with China to stem the flow of Uighur militants.

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Sulawesi and onwards to Poso. The Indonesian police feared this network could assist in the return of battle-
hardened Indonesian ISIS fighters from Syria, who could then launch more calculated attacks.

July 2020: Ummu Syifa, the wife of the MIT terrorist group leader, Ali Kalora, and another man, identified
only as “YS” were arrested on the same day. The arrests took place in Kasiguncu village, Poso Pesisir district,
Central Sulawesi on 29 July 2020. They were arrested by the National Police’s counter-terrorism unit,
Detachment 88. “YS” is suspected of recruiting members for MIT and providing money and logistics for the
terrorist group.

The government is making a renewed push to neutralize the militant group after it killed several locals in
recent months. Around 150 soldiers from the Army's Strategic Reserve Command (Kostrad) arrived in Poso
regency on 15 August 2020 in response to the escalation of MIT-related violence.

August 2020: In a recent incident, a retired soldier was found murdered in East Lore district, Poso on 14
August 2020. Police said the 57-year-old man was found with deep slash wounds to his abdomen. His
motorcycle was allegedly stolen by MIT members. On 8 August 2020, two farmers were abducted with one
of the men later being murdered, by a group of men believed to be MIT members. On the same day, two
Poso Health Agency cars were intercepted by 10 alleged MIT members on the Trans-Sulawesi Highway,
located near Sangginora village, where the abduction of the farmers took place.

Several sources stated that the reduction of soldiers in the operation against MIT, Operation Tinombala
earlier this year could have indirectly been the catalyst for the escalation of MIT related terrorist activity in
recent months. The small group of militants had been largely dormant for much of the past year. However,
starting in February 2020 an escalation of violence, propaganda and fundraising by MIT members and their
associates elsewhere in the country has been observed.

August 2020: Eleven people were arrested in Bekasi, West Java by the police’s Detachment 88 counter-
terrorism unit. They had allegedly been sourcing money and logistics for the Poso-based MIT group. The
pursuit of MIT members has been ongoing since the commencement of the Tinombala operation on 10
January 2016. In the first year, the group’s founder, Santoso alias “Abu Wardah”, was shot dead. His
successor, Basri alias Bagong, was later apprehended and detained. IT is now led by Ali Kalora. Although the
terrorist group has been decimated, continuously harassed, and hunted by police and TNI personnel with a
focus to specifically destroy it, the organization remains resilient. Although, increasingly cornered, MIT still
manages to mark its presence with attacks on local security personnel and residents.

Operation Tinombala has already been extended about a dozen times. These extensions have included
relatively large deployments of police, Brimob and TNI personnel including the latest Strategic Command,
Kostrad deployment. Several sources highlighted suspicions that the operation mainly serves as an excuse
for expanding the mandate and budget of security forces, especially since MIT is currently believed to be less
than 20 members.

Terrorist Incidents in the Wider Region

Security forces are also concerned by the potential impact from an influx of terrorists from the Southern
Philippines. This includes Marawi where Philippine security forces have cracked down on Islamist terrorists
that have pledged allegiance to ISIS.

July 2019: The National Police on 23 July 2019 identified an Indonesian couple who allegedly carried out a
suicide bombing claimed by the Islamic State of Iraq and Syria (ISIS). The bombing was at a church in Jolo,
Philippines in January that left 22 dead. The bombers were Rullie Rian Zeke and Ulfah Handayani Saleh,
allegedly members of Jamaah Ansharut Daulah's (JAD) branch in Makassar, South Sulawesi. JAD is an
umbrella organization in Indonesia supporting ISIS. Zeke and Saleh were identified following the arrest of a

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suspected militant, Noviandri, in Padang, West Sumatra and another JAD suspect in East Kalimantan. Zeke
and Saleh allegedly entered the Philippines illegally after being deported from Turkey in 2017. They left
Indonesia to join ISIS in March 2016 with their three children. However, before they could reach Syria and
Iraq, they were arrested in Turkey in January 2017 and were deported back to Indonesia that same month.

In Indonesia, both the bombers went through a short rehabilitation program and were later released.
Rehabilitation was unsuccessful, as they later decided to pursue their cause in Mindanao taking their
children with them. The suicide bombers were reportedly assisted by another wanted Indonesian terrorist
identified as S, who is based in Afghanistan. Twenty-two people were killed as two bombs hit a church in Jolo
on the morning of January 27 as mass was being celebrated. This was followed by a second explosion in the
parking lot as security and first responders were at the scene. ISIS claimed responsibility for the attack via its
Amaq news agency. Philippine Interior Minister Eduardo Año said the suicide attack was carried out by an
Indonesian couple with the help of Abu Sayyaf militants. Abu Sayyaf is a militant organization notorious for
conducting kidnappings and extremist action and has pledged allegiance to ISIS.

August 2018: A suspected member of Mujahedeen in Eastern Indonesia (MIT) terrorist group was arrested in
Tomoni village, Tomoni district, East Luwu Regency on 13 August 2018. The arrest was part of a renewed
crackdown on the terrorist network near its base in Central Sulawesi Province. Sources stated the arrest was
made around 7:45 AM local time by Detachment 88 and was based on information obtained during earlier
arrests. The 34-year old suspect, identified as Ato, was allegedly linked to the network of the late terrorist
Santoso, at one time the most wanted militant in the country and who was killed by security forces in Poso,
Central Sulawesi on 18 July 18.

August 2018: Three alleged terrorists were arrested by the National Police’s counter-terrorism squad
Detachment 88 at a residence on Jl. Rappokalling Raya in Tallo district, Makassar, South Sulawesi. One of the
suspects was identified as Moh. Risal, 36, a local drinking water vendor. Sondani did not provide details
about the other suspects or their links to any terrorist organization.

August 2018: Two alleged terrorists were arrested in Tobenteng hamlet, Liliriattang village, Amali district,
Bone regency on 10 August 2018. The two were identified by the initials MU alias YD, 37, and BD, 28. Police
sources said the two were linked to a network that used to be involved with local terrorist, Suardi, who was
shot dead in 2013.

January 2018: A terrorism convict was transferred to the Gunungsari Penitentiary in Makassar after
assaulting a guard and quarrelling with other inmates at a prison in Takalar Regency in the same province.
Sources said the transfer of Ahmad Sutrisno, 25, was made late on 16 January under heavy security. The
transfer was meant to prevent further violence since prior to the transfer, Sutrisno was involved in two
disputes with other inmates.

Sutrisno had allegedly tried to radicalize and recruit inmates at the correctional facility. He had assaulted a
guard, Syufarman Radjab, after a jihadist-themed book was taken from him. He punched Radjab in the head
and arm before brandishing a bladed weapon, prompting other inmates to intervene. Sutrisno then ran out
of the cafeteria to cause more commotion, order was restored after he was isolated. Takalar Prison
authorities placed Sutrisno in isolation in September the previous year after he was involved in a quarrel
with inmates who were studying the Koran, who he accused of insulting the scripture. Enraged by the
accusation, prisoners mobbed Sutrisno, forcing wardens to place him in isolation.

Sutrisno was transferred to Takalar Prison from East Jakarta's Cipinang Penitentiary after being involved in
fights with inmates, leaving three of them dead due to stab wounds to their stomach, while he himself
suffered multiple bruises. Sutrisno is serving five years in jail for his role in the 2016 bombing and shooting

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attack near the Sarinah shopping center in Central Jakarta that left four civilians and attackers dead. The
attack was claimed by the Islamic State of Iraq and Syria (ISIS).

January 2018: Two police officers were injured in an attack using homemade explosives at a police office on
Jl. Sunu in Bontoala district, Makassar, early on 1 January 2018. Sources said a man threw three explosive
devices at the police office at around 3:30 AM. Bontoala Police chief Comm. Rapiuddin sustained injuries to
his arm and hand while one of his subordinates, 1st Brig. Yudiswan, suffered minor injuries to his leg in the
attack.

The attacker managed to flee through the police office's backyard that is connected to a mosque. Police later
found a backpack in the area that was allegedly left behind by the perpetrator containing two bottles filled
with fuel, a kitchen knife, pliers and an empty bottle. Police sources confirmed that the explosives were low
grade and homemade containing fireworks, fuel, bolts and screws. The National Police’s counter-terrorism
unit Detachment 88 launched an investigation, but the motive behind the attack has remained unknown.

October 2017: A man named Bakri was arrested for his alleged involvement in a 2012 assassination attempt
targeting Syahrul Yasin Limpo, then governor of South Sulawesi. The arrest was made in Towuti district, East
Luwu regency on 24 October 2017 at around 7:00 AM local time. An alleged accomplice, Awaludin, was
sentenced in late 2013 to nine years’ imprisonment for his involvement in the same plot.

Laskar Jundullah
In October 2000, Agus Dwikarna, an Indonesian militant linked to al Qaeda, helped establish the paramilitary
organization Laskar Jundullah, members of which participated in religious violence in South and Central
Sulawesi in the early 2000s. It is modelled after Laskar Jihad, another paramilitary organization formed
earlier in Java, but Laskar Jundullah drew its recruits from the island of Sulawesi. Laskar Jundullah gathered
about 2,000 recruits to central Sulawesi. Mostly using bats and machetes, they supported local Muslims in
violent conflicts with Christians near the town of Poso, Central Sulawesi between 1998 and 2005, resulting in
heavy casualties on both sides. Laskar Jundullah was seen as the military wing of the Preparatory Committee
for the Implementation of Islamic Law (KPPSI) in Makassar.

Although the KPPSI was formed to establish sharia law through peaceful
means, some members of KPPSI had ties to violent jihadist groups. KPPSI
members said that the group was a way of changing Indonesia into an
Islamist state through constitutional means. The Laskar Jundullah
recruits associated with DI would reportedly often go to the Hidayatullah
pesantren or Islamic boarding school in Balikpapan, East Kalimantan.
This boarding school is notorious for producing hard-liners and Islamist
militants, before proceeding to participate in the religious conflict in
KPPSI Congress in May 2014
Poso.

KPPSI was founded immediately after the regional autonomy laws were passed in 1999 with the aim of
trying to obtain special autonomy for the province of South Sulawesi, similar to that granted to Aceh, so that
the province could enforce Islamic law. Under the autonomy laws, religious matters remain under the
control of the central government, but since Aceh was allowed to adopt Islamic law under special autonomy
provisions, KPPSI demanded the same treatment for South Sulawesi.

While the activity of KPPSI has diminished in recent years, at its height it enjoyed support from tens of
thousands of members and regional branches across Makassar and at many pesantren (Islamic boarding
schools) in the region.

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A splinter cell of Laskar Jundullah led by Agung Abdul Hamid carried out a bombing of a McDonald's
restaurant in Makassar in December 2002. Dwikarna at the time also served as the head of the South
Sulawesi branch of the al Haramain Foundation, which funnelled money from the Middle East to terrorist
groups in Indonesia, including Jemaah Islamiyah. Laskar Jundullah reached its peak strength and influence
during the Poso conflict in Central Sulawesi between 1999 and 2002. Dwikarna was later convicted of
charges of illegal possession of explosives and involvement in bombings in Manila and Jakarta. Information
on Dwikarna’s activities at that time reportedly came from Omar al Faruq, al Qaeda’s main liaison with
militants in Indonesia in the 1990s and early 2000s.

According to leaked US diplomatic cables, the director of al Haramain’s Jakarta branch frequently disbursed
large amounts of cash to al Faruq to procure weapons, explosives and other items. Dwikarna served as the
head of the South Sulawesi branch of the al Haramain Foundation. Al Faruq was arrested in Bandung, West
Java in early 2002 and was later handed over to US authorities. He was killed by coalition forces in Iraq in
2006 after escaping from a detention centre in Afghanistan. After Dwikarna’s arrest, Laskar Jundullah
changed its name to Korps Pemuda Islam or the Islamic Youth Corps. It currently focuses on establishment of
sharia law in Sulawesi. Dwikarna disappeared in mid-2014 days after returning to Indonesia from the
Philippines, where he had been imprisoned since 2002 on charges of possessing illegal explosives. Dwikarna
returned in early January 2015 and spent a few days at his home in Makassar, South Sulawesi, but his
whereabouts have since been unknown. Dwikarna was serving a 17-year prison sentence when the
Philippines deported him to Indonesia. A Filipino court convicted Dwikarna in 2002 for trying to board a
flight to Bangkok from Manila with C-4 plastic explosives and bomb parts in his possession.

Extremism and Radical Groups

Central Sulawesi Province, especially Poso Regency, is home to various extremist and radical groups that
often have close ties to terrorist organizations. In 2016 the National Counter-Terrorism Agency (BNPT)
reported that least 19 Islamic boarding schools, or pesantren, including an unnamed one in Poso Regency,
exhibited signs of supporting terrorism and radicalism; some of the teachers at the schools were linked to
known terrorists.

The government said in October 2017 that it would launch a task force to prevent and counter Islamist
radicalization in Central Sulawesi Province and West Nusa Tenggara Province. Officials from security agencies
and regional administrations gathered in Mataram in Lombok, West Nusa Tenggara Province in October
2017 for a coordination meeting to discuss effective counter-radicalization and counter-terrorism measures.
The task force is focused on introducing comprehensive programs encompassing social, religious and
economic initiatives to prevent radicalization from spreading in both provinces.

Illegal Mining

Illegal mining results in the theft of gold and impacts levels of environmental damage and pollution. Illegal
mining increases tension between the Client and local residents, and increases affiliated crime in the area. In
the past few years illegal gold mining has spread throughout the country. Reportedly the state incurs losses
of over IDR 80 trillion (approximately USD 6.1 billion) annually. Former Deputy Environment Minister,
Masnellyarti Hilman said that based on data from the Energy and Mineral Resources Ministry in 2014, illegal
gold mining had occurred in 27 provinces, 80 regencies and two cities.

Illegal resource-extraction impacting the Client’s property and operations is a threat that focuses on illegal
gold mining groups entering the wider project area to explore for and exploit gold resources, often with the
collusion of local residents. Information reviewed has identified no current illegal gold mining activities in
Luwu Regency. However, it is highly likely that the client’s project once entering the production phase will
attract illegal mining groups active in other areas of Sulawesi and the country. This can escalate concerns

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and complaints from local communities where perceptions and opinions affect the Clients reputation and
operation. Environmental and social activists and political groups could argue that the Client’s presence and
mining activities are responsible for environmental damage, increased crime and negative social impact even
though, these issues are attributable to the illegal miners.

The Indonesian Peoples Mining Association (APRI), an organization focused on community mining, has
shown interest in conducting community mining activities in the area. Local sources identified that APRI has
become active in the Latimojong District area, having conducted a socialization program with local villagers.
The organization is focused on consulting with the local community on mining issues, influencing local
community opinions and gaining attention from local and national media. APRI has the capacity to influence
other national or international NGOs, demand meetings with government officials at the local, regional and
national level and has the capacity to organize protest demonstrations.

Field inquiries identified that currently there has been some traditional gold mining in local villages. Local
residents from Sampeang Village in West Bajo District were conducting artisanal small scale mining, panning
for gold in the Songgang River. Approximately 13 people from Desa Sampeang villager were using traditional
equipment: a piece of carpet, a shuffle, and a gold finding maze. The villagers explained that in one day they
could find two grams of gold. However, sometimes they don’t find anything. They said the capital required to
find gold at the river is approximately IDR 100,000 and the need for persistence and patience.

Desa Sampeang villagers conducting Gold Panning activities

Modus Operandi
In many areas of Sulawesi, illegal miners excavate ore in the mountains by digging small tunnels following
veins of gold. The tunnels are not supported and tend to be steep and curved as a consequence numerous
deaths occur from tunnels collapsing. Once removed from the tunnels, the ore is then placed in sacks and
carried to process plants located in the area. In many cases, the ore is transported by bullock and motorbike
along bush tracks to the processing plants. Full and empty sacks of ore are a common sight along the
roadway in areas where illegal mining is occurring.

Illegal miners often work in groups of 10 to 15 at a pit site. Miners pay for the ore to be crushed at a nearby
processing plant as well as paying the landowner (when involved). After the investor’s costs are deducted,
the remaining is distributed among the miners. The landowner is paid by receiving a percentage of the sacks
of ore mined. Ore is processed by crushing which takes about three to four hours. After the initial crushing,
mercury is added. The ore is crushed a second time in a tank called a “tong” for about 30 minutes. The

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processed ore is then flushed with water and filtered through cloth. Land owners at times are involved in
the mining themselves, while others rent their land to pit operators and investors who make most of the
money. The set-up cost for a pit mine operation is at least IDR 30 Million, which takes approximately three
months to return a profit.

Network Structure
Investors are the highest tier. They identify the locations, determine the potential financial return from the
illicit activity and provide seed funding to the operation. There are very few people at this level, and they
determine the organizers and operators from within their networks (i.e., a closed organization) where only
those on the inside are drawn into the workings of the illicit activity. Generally, financiers/investors of illegal
mining operations are well removed from the practical and physical aspects of the operation and therefore
difficult to identify and/or prosecute.

The appointed organizers are the second tier of the crime group mode, taking on the role of ensuring the
illegal mining activities are successfully implemented. This includes coordinating the work site, selecting
workers and taking in cash from all sources of the process.

The final tier is often referred to as “Hands On”, a literal description of the people that conduct all aspects of
the illicit activity and have the most exposure to law enforcement authorities. They are the miners,
assistants, process operators, drivers, etc. While the Hands On tier generate the most revenue for the crime
group, they receive only marginal returns for their efforts.

In terms of monetary return for each tier, it is inversely proportional to the aforementioned structure, with
investors receiving the bulk of the illicit funds, organizers receiving a percentage and the Hands On tier
obtaining significantly less.

Security Backing
Tacit approval or even involvement of local regional security forces including police or military has been
identified in many areas of Sulawesi and across the country. At times government officials are also involved.
Security sources have suggested the possibility of elements within the provincial police leadership being
involvement in illicit financial ventures associated with or that include illegal mining and illegal timber
export. However, this Threat Assessment has not established any information that can corroborate this
allegation from sources. In some instances in Sulawesi and other regions in Indonesia, local elements of the
police and military have conflicting agendas concerning the arrest of illegal miners and enforcing the law in
respect to illegal mining activities. Illegal mining and the level of support at times provided by competing
elements of the state security apparatus can have a significant impact on the security environment of an
area. This includes the capacity and/or commitment of security forces to assist companies manages the
security issues affiliated with illegal mining.

Social and Economic Impact

Several sources contend that illegal mining contributes to the destruction of local resident’s traditional
livelihood including agriculture and fishing. This is a result of adverse environmental conditions and
degradation, including pollution through the use of mercury and cyanide. Degradation of the environment
also occurs through increased erosion, the result of excessive pit mining operations. The consequences of
this illicit activity negatively impact local economies: introduction of illicit and illegal crime types to include
prostitution, human trafficking, drug-trafficking, and increased theft. The social impact on communities
includes social jealousy and conflict economics.

In some instances workers flock willingly to illegal mining sites, drawn by perceived rewards. In other
environments, where conditions are especially hazardous or undesirable, deception is prevalent in worker
recruitment.

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There is a strong link between illegal gold mining and sexual exploitation. Whenever there are large
migrations of men to an area, there is a high demand for sexual services that often facilitates sex trafficking.
Multiple sources have highlighted that there are a large number of cases where women and girls are
trafficked into illegal gold mining areas for sexual exploitation either through deception or being sold
including at times by family members into the sex trade.

Other affiliated criminal activities include supplying the high demand for narcotics in these areas where both
legitimate, ASM and illegal mining takes place. Similar to prostitution and sex-trafficking, the concentration
of large numbers of men with disposable funds, limited spending options and remote locations is an
exploitable opportunity for stakeholders in the drug trade.

Environmental Impact
Although several permits are required from several levels of government to own and operate an approved
cyanidation facility, there is no enforcement and tailings ponds are perched on the edges of streams. During
the rainy season, these ponds fill and overflow, discharging sediments, probably containing pollutant by-
products into fish-bearing streams, including mercury.

Clearly, there is a link between the use of mercury in the gold extraction process and the impact on
surrounding waterways. There are numerous accounts of the pollution of rivers, based on the uncontrolled
use of mercury that has been identified by Regents, Mayors and Governors alike.

The associated health issues arising from illegal mining in Indonesia are of major concern to all involved in
legitimate mining or associated activities. Where illegal or small scale mining occurs on established
concession sites, any related health incidents will be, in all likelihood, deflected back to the mining
leaseholder, with community expectations that the large scale mining operator will be held responsible for
the health outcomes of these informal or illegal miners.

Illegal Mining Cases in Sulawesi

North Sulawesi
Areas along the Tondano River in Minahasa Regency and the Dumoga River in Bolaang Mongondow regency
have suffered severe environmental damage due to illegal mining according to the North Sulawesi Forestry
Agency report in 2010. Data from the agency showed that 60% of the 788,692 hectares of forest in the
province was affected at that time. The region was the focus of a long-running battle between
environmentalists and the gold mining industry. After an extensive court battle, a probe by a panel of
experts in May 2010 found that miner PT Newmont Minahasa Raya did not harm the environment despite
years of dumping mine tailings into lower levels of Buyat Bay. The pursuit of the company by environmental
groups was perceived by the industry as a major threat that could stop the practice of disposing of mine
tailings into the sea. Furthermore senior mining executives and members of management were either jailed
or received home detention for extensive periods while the case was ongoing.

A journalist was injured in a violent protest against the closure of the Potolo illegal gold mining site in South
Tanoyan village, Lolayan district, Bolaang Mongondow regency on 17 March 2020. The victim was assaulted
by protesters angered by the provincial government decision to close the illegal site. Approximately 500
protesters rallied near the Potolo mine site when Bolaang North Sulawesi Police chief Ir. Gen. Royke Lumowa
arrived at the scene to shut down the illegal mining site.

A married couple was arrested for smuggling mercury to Talawaan Bajo village, Wori district, North
Minahasa regency. The couple were arrested on 23 May 2020, following a tip-off. At least 180 kg of mercury

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stored in six jerry cans were seized. Police sources said the suspects planned to sell the materials to illegal
mine sites in Tatelu Satu village, Dimembe district, also in North Minahasa, for Rp1.2 million per kilogram.

There are at least 130 illegal processing plants in the Talawaan area in North Sulawesi Province. While no
accurate figures have been kept regarding illegal miners in the area, it has been estimated that there may be
2,000+ illegal miners in the region. In order for the ore to be processed and the gold obtained, it is essential
that the processing plants have a supply of cyanide. Without cyanide the gold cannot be extracted. As a
consequence, there is a high demand for the product. Cyanide cannot be obtained commercially in North
Sulawesi; other methods to obtain supplies must be exploited. This includes illegally importing cyanide from
overseas or by purchasing cyanide from producers within Indonesia. In any case it is illegal for these
unlicensed and regulated processing plants to operate.

Central Sulawesi
Police sources indicated that four men were arrested for illegal gold mining activities in a conservation forest
in Poso, on 15 January 2020. The arrests followed raids near the Lore Lindu National Park on 12 and 13
January. The men arrested had nearly 40 sacks of gold bearing ore in their possession when arrested in
Kawatuna sub-district, Mantikulore district, Palu. These arrests came despite the shutdown in March 2016
of illegal mining sites in the national park. The 2,180-sq-km park, designated a UNESCO biosphere reserve in
1978, is home to dozens of rare species of animals indigenous to the Island of Sulawesi. Park spokesman
Irham Rangga Sasmita said patrols involving police and residents had been intensified to prevent a re-
emergence of illegal mining activities. Abdul Haris, director of environmental advocacy group, Indonesian
Forum for the Environment (Walhi), said the latest raids showed law enforcement remained weak and that
this underscored concerns that security officials are colluding with illegal miners.

The Energy and Mineral Resources Ministry will investigate a gold mine in Palu accused of contaminating the
environment with mercury and cyanide according to official sources. The Poboya gold mining block in
Poboya sub-district, Mantikulore district is managed by PT Citra Palu Minerals (CPM), a subsidiary of the
Bakrie Group's PT Bumi Resources Minerals, the country's largest thermal coal miner. The Bakrie Group is
owned by the family of Aburizal Bakrie, a former government minister and former chairman of the Golkar
Party. Energy and Mineral Resources Minister Ignasius Jonan told reporters he will immediately order
Mineral and Coal Director General Bambang Gatot Ariyono to investigate the matter ordering him to revoke
mining permits to those proven guilty of violations. The statement followed a report from Ahmad Ali, a
member of the House of Representatives’ (DPR) Commission VII, overseeing energy and mineral resources
and environmental affairs, during a working meeting with the ministry on 25 January 2020. Ali stated, due to
a lack of supervision, miners at the Poboya block have allegedly been polluting the environment with
materials including mercury and cyanide. Director General Ariyono after the 25 January meeting admitted
that the government struggles to curb illegal mining at the Poboya block, which has been ongoing since 2016
in an area of 70 hectares. Officials have repeatedly expelled illegal miners, but they keep returning.

The Network for Mining Advocacy (Jatam) has reported in addition to PT CPM, other companies are also
believed to have violated regulations in Poboya: PT Panca Logam Utama, PT Mahakam, PT Madas and PT
Indo Kimia Asia Sukses. The NGO accused the companies of building 42 cyanide ponds to soak and purify
gold on 14.5 ha of land in the sub-district. The mining sites are reportedly adjacent to seven watershed areas
utilized by the Palu Regional Water Company (PDAM) and are located around 2 km from residential areas.
Jatam national coordinator Merah Johansyah said the Palu Health Agency in 2014 reported that mercury
content in the water in the area was five times higher than the World Health Organization’s (WHO) safety
limit. However, the mining sites are still operating freely.

South Sulawesi
Four illegal miners were killed in a landslide at an abandoned limestone quarry in Caramming village,
Bontotiro district, Bulukumba Regency on 19 April 2020. Five people were digging when unstable soil

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collapsed burying them. One of the miners was rescued while the others were found dead at the scene.
Police said the victims came from Sinjai regency, also in the province, and did not have a permit to mine at
the location.

Southeast Sulawesi
Southeast Sulawesi has experienced a number of conflicts related to illegal mining. In 2019 local nickel
miner, PT Alam Mitra Indah Nugraha was accused of operating illegally at a mining site in Patikala village,
Tolala district, North Kolaka Regency. The company has been operating since 2018 and reportedly exported
over 10,000 metric tons of nickel ore in its first year. The company's operational legality is under scrutiny as
officials revealed that the firm did not have a special mining permit (IUP) to operate in Patikala. Police
sources confirmed that a probe has been launched over the alleged illegal mining activity. Southeast
Sulawesi Police sources denied that police are assisting the company. Southeast Sulawesi Governor Ali Mazi
called on the company to suspend operation pending an investigation into the operation's legality.

Waste from nickel mining companies polluting waters in South Konawe, Buton and Bombana has been a long
standing issue with reports of such incidents being made as early as 2010. In South Konawe, pollution
resulted in failed seaweed harvests in an area spanning 200 hectares. In Buton, pollution is worst in the
Talaga Raya district waters. In Bombana, West Kabaena is the most affected by pollution.

West Sulawesi
North Mamuju (now Pasangkayu) Regional House of Representatives (DPRD) lawmaker Yani Pepi Andriani
identified 15 illegal mining sites in North Mamuju Regency on 22 April 2016. The illegal mines were located
in several districts including Pasangkayu, Bambaira, Lariang and Tikke Raya.

Maluku
In another recent development, the Maluku government said it is planning to re-open the Mt. Botak mine in
Buru Regency after it was closed by the government in 2015. The closure was due to environmental damage
and rampant social conflict. Illegal mining operations at Mt. Botak reportedly involved non-compliant
companies and allegations of bribery implicating security and law enforcement officials. The number of
illegal miners at the mountain had reached more than 20,000 between 2012 and 2013 after gold deposits
were discovered three meters below the ground in 2011. According to reports, more than 1,000 people
were killed in clashes, robberies, murders and landslides at the site between November 2011 and February
2015.

Social Threats

Statistics from South Sulawesi Province mirror those countrywide and suggest the population at large is
troubled by a number of divisive issues confronting an emerging democracy. This includes the exceptional
growth of an innovative and far-reaching extractive-based industry, combined with a large under-educated
and unskilled populace. Security threats and challenges related to social, cultural and religious issues can
negatively impact the Client and their operation. Issues can be directly related to the Client’s mining project
or be an element of the wider social dynamic.

In Ring One and Two, social issues that may develop into protests can include the following:

 Lack of compensation and damaged infrastructure including damaged or closure to roads, other
infrastructure and local houses, allegedly caused by the Client or its contractor’s heavy vehicles
passing through villages.

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 Insufficient employment opportunities for local villagers, especially the younger generation eager to
work within a professional company rather than in the traditional agricultural sector.

 A lack of economic opportunity for small local business owners not included in contracts or projects
from the company. This develops local perceptions that only larger companies from Belopa, Palopo
or other locations in Indonesia receive economic benefit from opportunities to win Client contracts
triggering feelings of economic disparage and increased social jealousy among communities.

There are general expectations among the Luwu people that any new business coming into the area will also
provide increased local work opportunities, depending on the skillsets required.

The general expectation confirmed by local officials however, is that increased employment for locals will be
a reality, at times regardless of the skillsets of the local workforce. Local officials also added that while
increased business opportunity is a high priority the preservation of the environment is of vital importance
for the majority of people in Luwu. It is the reason why the agricultural sector is a priority for the local
Investment Agency.

A growing social problem in Belopa is, many local males work in the maritime sector and are leaving their
families behind for extended periods, disrupting families for up to a year in some instances. This often
impacts the family dynamic, where in some instances the husband has started a family elsewhere. The wife
is left to manage her own household and is not used to or resents her husband returning and wanting to
assume the position of head of the family.

The arrival of Client and contractor employees to the area may further impact social family structures, as
intimate relationships may develop between newly arrived workers and local female residents whose
husbands are away. This can create increased domestic disputes and security incidents that damage the
Client’s reputation in the area. Successful and peaceful assimilation between different people that make up
the local community largely depends on the willingness of incoming migrants to understand, embrace and
adapt to local custom and the local way of doing things.

Luwu Local Culture

Various sources in Luwu Regency indicate that community members in Luwu, including Bajo and Latimojong
Districts, are not business-minded and don’t have experience in management or employment in a company.
Although the importance of the coffee industry in these districts is significant, sources state it lacks business
experience, which is a predominant reason that there is no strong campaign to promote Luwu coffee, unlike
Toraja, where its coffee has become internationally renowned. Luwu coffee is still generally unknown.
Coffee farmers in Bajo and Latimojong are part of a system that provides average grade coffee in return for a
basic price. Wholesalers transport coffee to Makassar without any locally added value. There are some
government initiatives to process coffee locally as well as a private company attempting to supply specialty
coffee. However, these initiatives are limited.

The professional standard of the available workforce in Luwu is limited, impacted by low levels of education
and a lack of experience. A small percentage of people, however, have developed knowledge and experience
working in the tourism or service industry sector (hotels or cruise ships). With the main livelihood for many
local residents in the regency being coffee production, the methods used in growing coffee plants and bean
processing are performed through years of habit. There is no consideration for proven methods of
enhanced and improved coffee production and marketing. The majority of local people tend to limit
themselves in improving and thereby limit their earning capacity. They appear content maintaining the
current flow of income, considering it good enough.

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Local communities display and maintain strong close family connections. Local sources stated that the two
districts are part of one integrated community, predominantly involved in the local coffee industry. The local
culture is very community-focused. Individuals don’t want to conduct any activity that might be a threat or
potential threat to the local community and its culture. This has reduced the interest of local community
members starting different business projects or activities.

Villagers in Bajo and Latimojong place a lot of attention on their land and are very proud of their ancestral
connections to it. Villagers will cultivate rice, even if coffee, cacao or clove cultivation is more profitable.
Local residents feel that buying rice is for lazy people and that families should farm their own rice. Outsiders
conducting business in Luwu Regency have commented that it is extremely difficult to purchase land,
especially for foreign investors.

The social structure is different in Luwu’s capital Belopa, however. The population is mixed between Luwu
natives and many newcomers from Makassar, Toraja and other parts of South Sulawesi Province as well as
Javanese transmigrants. Furthermore, many young people in Luwu Regency don’t want to work as farmers
and would rather be employed in a company or have an office job wearing a suit and tie. Therefore, much
farm land will become unused, as the number of young people available to cultivate it reduces. This trend
highlights that many young residents of Belopa and other places in Luwu will have an expectation of being
employed in companies like MDA or its contractors.

Resistance to Outsiders
In the past communities and officials in Luwu Regency have shown resistance towards Chinese Indonesian
investors wanting to base themselves in Luwu. In general many communities in South Sulawesi Province
have a negative perception of Chinese Indonesian or Chinese business people and companies.

Sources highlighted one example of a young Chinese Indonesian businessman who wanted to move to
Belopa to start a construction business. However, officials told him that as a Chinese-Indonesian, he wasn’t
allowed to open a business in Belopa, even though he was a fourth-generation Indonesian citizen. He took
legal action and finally was allowed to operate his business using a community-based approach of working
with locals, not bossing them around, which Chinese Indonesians have a reputation for.

It was established that the perception of the community toward the Client is generally negative with many
mixed messages and understanding about company activities and goals.

Local officials at the Luwu Regional Investment Agency stated that they have had what a source described as
inadequate communication with the Client since regulations only require the company obtain permits from
the central government. As a result, local officials claimed they do not have an accurate understanding of the
Client’s presence, activities and the context of its operation. In terms of regulations, local government is not
yet fully prepared to accommodate new investors either, the result of a lack of regulations related to
workforce requirements and business licensing. However, sources advised that currently local government
is deliberating investment regulations that are expected to be concluded in the near future.

When mentioning the Client, Luwu officials as well as many Luwu community members immediately
highlighted that their understanding was that the company had existed between 30 to 40 years in the area
without any clear mining activity. Other widely shared perceptions of the Client in Luwu are as follows:

1. The Client has made false promises to the local community particularly about developing the
economy and the people.

2. The Client has been secretly taking gold and other mineral resources from the mountains to avoid
making required contributions to the local government and community.

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3. Locals feel that they have been fooled into welcoming a mining company on their land to start
activities without that company giving significant contributions in return.

The Luwu regional government plays a key role in facilitating communication and interaction with the local
communities in Luwu, which emphasizes the need for the Client to maintain a proactive role in developing
strong regional government engagement. This must be based on open and continual communication to
include the overall operational process and project history thereby avoiding claims of a lack of transparency
by the Client.

Community Conflicts
The economic downturn and social impact resulting from the COVID-19 pandemic have created a need for
the Client to develop and maintain good relationships with local government, key stakeholders and
communities prevent potential disputes or conflicts. Many mining area conflicts exist throughout Indonesia,
but the failure to manage the pandemic could damage relations with local communities further. However, if
managed properly, this may be an opportunity to improve relations with the communities.

The Indonesian NGO, Mining Advocacy Network (Jatam), warned on 4 August 2020 that social conflicts
among residents living near mining concessions have escalated amid the coronavirus pandemic. The NGO
conducted a survey from 18 May to 12 June 2020 with residents from 39 communities whose lives have
been affected by either state or private mining activities. Twenty-one communities were living near
operational mining areas: seven in closed mining areas, eight in mining areas that have yet to begin
operations and 3 in mining areas that have temporarily halted activities.

The survey’s results showed that the most frequent conflict was intimidation of residents, where 15
respondents reported such incidents. Other conflicts highlighted included 11 cases of land grabs, 10 cases
each for clashes and personal disputes, 9 criminal cases and 6 cases of economic decline.

In recent years, including 2020, communities in various parts of Indonesia have conducted active campaigns
against the presence of mining companies. In late March 2020, the East Java Provincial Government ordered
the closure of anti-gold mining posts and the dispersal of activists in Tumpang Pitu and the Salakan
Mountains in Banyuwangi Regency in a bid to mitigate the spread of the coronavirus. However, activists
condemned the move as the government still allowed the mine, owned by PT Bumi Suksesindo, to operate
despite the site posing COVID-19 health risks for the local community. The incident led to a clash between
groups in the area on 26 and 27 March 2020. At least 13 homes, 60 motorcycles and two cars were
damaged.

In a similar incident in July 2020, residents protesting against coal mining companies for damaging the
environment in West Merapi district, Lahat Regency, South Sumatra were allegedly frightened off by police
officers after they staged demonstrations.

The central government’s track record in dealing with mining disputes is often seen as being biased in favour
of companies and is marred by allegations of bribery and graft in the process of providing operational
permits. This could lead to heightened social tension among communities whose sources of income are
affected by mining activity. In addition, illegal mining operations remain rampant and the higher price of
gold could prompt more people to engage in the illegal and often dangerous practice of unsupervised
mining.

Main Source of Income in Luwu Regency

Farming in the agricultural sector is essential for the majority of Luwu people. Produce varies between high
value crops to crops developing higher production levels and economic returns and those crops that still

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need to be produced. The local community harvests rice, cloves, coffee and cacao. The market for differing
produce is influenced by fluctuations in demand and variations of crop quality.

Sources stated that coffee is a main source of income for the majority of people in Luwu, but the harvest
season lasts only between May and August each year. For the remainder of the year, a large portion of the
workforce is inactive due to relatively low skillsets of the majority of workers. This causes high
unemployment levels in the local community (Luwu Regency is ranked 4.66%, 9th among the 10 highest
unemployment areas in South Sulawesi Province according to 2019 government statistical data).

Other workers from Luwu Regency migrate outside of Luwu to find better employment opportunities in the
construction and maritime sectors finding work as construction workers or sailors, respectively.

There is a small local state-owned company in Boneposi village adding value to the local coffee industry by
processing coffee in the Luwu region. A company named Sisola Coffee is producing specialty coffee
managed by two American nationals residing in Bajo District in Luwu Regency.

Local Organizations

Currently there are 44 community organizations registered with the Luwu Regency Government. The list
comprises of 28 national organizations, nine regional organizations and 7 local organizations.

The following are registered local NGOs in Luwu Regency with an interest in mining issues:

Organization Key Personnel Established Address Scope Capability

1. PP-IPMIL Chairman: 5 Aug 1958 Tirowali Local -  Raise mining issues/activities through student
Pengurus Pusat Paisal Sub-District, Regional demonstrations in South Sulawesi
Ikatan Pelajar Secretary: Ponrang  Local and Regional media, South Sulawesi
Mahasiswa Indonesia Ahmad Syawal District  Influence political mass organizations (i.e.,
Luwu Treasurer: Pemuda Pancasila, other political party youth
(Central Leadership Annha Fabryan wings
Indonesian Students  Demand meetings with regional lawmakers.
Association)
2. FK-BPD Chairman: 12 Mar 2014 Jl. Andi Local-  Raise issues related to mining operation by
Forum Komunikasi Ridwan Mabbi Mukkulau Regional facilitating meetings between local community
Badan Secretary: no.24, and local government officials
Permusyawaratan Irham As’ad Lamunre  Gain attention from local and regional media in
Desa Treasurer: Sub-District, South Sulawesi
(Communication Sumarling Belopa  Influence local community opinions
Forum Of The Village Utara  Organize demonstrations in South Sulawesi
Community Agency) District  Demand meetings with regional lawmakers
3. APRI Chairman: 19 Sep 2014 Kampung Local-  Consult local community ref mining issues
Asosiasi Penambang Robby Tanduk Baru, Bajo National  Influence local community opinions
Rakyat Indonesia Langi Sub-District,  Gain local - national media attention
(Indonesian People’s Secretary: Bajo District  Influence national or international NGOs
Mining Association) Hamsah Hamid  Demand meetings with government officials at
Treasurer: local, regional and national level
Burharuddin  Organize demonstrations
4. AMAN Chairman: 23 Nov 2015 Jl. Karaeng Local -  Consult local community ref mining issues
Aliansi Masyarakat Muslim Andi Mate’ne no. National  Influence local community opinions
Adat Nusantara Yusuf 1,  Gain local - national media attention
(Indigenous Peoples Secretary: Larompong  Influence national or international NGOs
Alliance of the Asdar Azis Sub-District  Demand meetings with government officials at
Archipelago) Treasurer: local, regional and national level
Dharma Fidyasari  Organize demonstrations

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Natural Disasters

In Latimojong and Bajo Districts heavy rain can cause landslides that can block access roads and disrupt
mining operations and logistics support. Regular landslides block roads and bridges in the mountainous area.
Three excavators are available to remove landslide debris, including one excavator that belongs to the Client.

Environmental watchdog Friends of the Earth Indonesia (Walhi) in South Sulawesi on April 22, 2019 stated
that forest conditions in the province are worsening with 516,000 ha of land at a ‘critical level.’ Mining,
infrastructure projects and large agribusiness were blamed for increasing deforestation. Land degradation is
making the province more vulnerable to natural disasters such as landslides and flooding according to Walhi.

At least 21 people were killed following flash floods and landslides that devastated parts of Masamba in
North Luwu Regency in July 2020. The disaster left 4,930 houses buried in mud after three rivers in the
region burst their banks due to torrential rains, which began on 13 July. Nearly 1,600 people were taking
refuge in temporary shelters, according to data from the Regional Chapter of the National Search and Rescue
Agency (Basarnas). Hundreds of houses, government offices and public facilities were inundated with mud,
including those of the District Military Command (Koramil 1403-11) in Masamba District. It was reported that
in Baebunta and Sabbang districts, there was mud four meters deep which blocked road access in some
areas.

Two people were killed and three others were missing as flash floods and landslides struck parts of South
Sulawesi late on 12 June 2020 according to officials. Torrential rains caused the natural disaster that
destroyed dozens of houses and blocked main roads in Jeneponto and Bantaeng Regencies. Hundreds of
residents were forced to flee their homes.

North Luwu had been classified a flood-prone area since the 1800s and the North Luwu Regency is prone to
flooding easily affected every rainy season.

Earthquakes
A series of small earthquakes hit South Sulawesi in October 2018. No tsunami warning and no casualties
were reported. The Meteorology, Climatology and Geophysics Agency (BMKG) announced on 19 October
2018 that an earthquake hit Luwu Regency. The 3.4-magnitude quake hit the regency at 3:03 PM local time.
The epicenter of the quake was located 28 km Northwest of East Luwu, at a depth of 5 km.

A 4.0-magnitude quake occurred in Bulukumba Regency on 15 October 2018 at 5:20 PM and then at 6:20 PM
local time, according to the BMKG. The centre of the quakes was at coordinates 5.67 South latitude and
120.66 East longitude, at a depth of 10 km, 57 km Southeast of Bulukumba.

A magnitude 4.2 quake hit Wajo Regency at 9:03 AM local time on 9 October. The centre of the quake was
located at southeast Sidap regency. A 3.1 magnitude earthquake shook Sinjai regency on 1 October at 7:39
PM local time, BMKG said. The quake’s centre was 37 km northeast of Sinjai, are a depth of 38 km under the
ocean.

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Infrastructure

The infrastructure and its capacity are key elements of the Client’s mining development and construction
process. Infrastructure and road access are critical for the area, especially in Bajo and Latimojong Districts
and the villages. Already a major difference for coffee farmers is access to a cemented path rather than a
bush trail. This enables them to transport larger shipments of coffee by motorcycle rather than a bush trail
where they have to physically carry coffee for considerable distances.

Both South Sulawesi Province and Luwu Regency are focused on improving local infrastructure. The Client
has had discussions with the current Luwu Regent and has made arrangements with the previous Regent to
assist with the construction and improvement of the access road in Bajo and Latimojong Districts to the
Project Site.

The Belopa Port becoming operational will greatly improve infrastructure and logistics processes for
companies based in Luwu Regency. The development of an airplane connection between Toraja and Luwu
Regency is anticipated to boost local tourism and strengthen the connectivity of Luwu Regency’s Bua Airport.

South Sulawesi Province

In 2019, the government completed the construction of the 142 km Makassar-Pare-pare railway line in South
Sulawesi. A 104 km railroad connects Pangkajene Islands Regency with Garongkong Port in Barru Regency
linking several cement factories in Pangkajene Islands Regency, all in South Sulawesi and part of the Trans-
Sulawesi Railway Construction Project. The remaining 38 km of the railroad will begin construction in 2020,
connecting the Pangkajene Islands to the Southern part of Makassar and the Garongkong Port with Pare-
pare in the North of the Province.

In 2019, South Sulawesi Governor Nurdin Abdullah has said the government would also allocate IDR 80
billion to fund road construction to connect Malili with Bantilang District in East Luwu Regency. The road
would boost pepper production in Bantilang.

The Transportation Ministry has allocated IDR 500 billion to help fund the construction of the Buntu Kunik
Airport in Mengkendek District, Tana Toraja Regency. The development is expected to be completed within
two years, Transportation Minister Budi Karya Sumadi said while inspecting the site on 12 September 2020.

Crime Trends

South Sulawesi Province continues to experience high levels of communal violence. Motorcycle gang
violence is a major problem in Makassar, where the city government at one stage declared a state of
emergency due to the high incidence of violence. Universities in Makassar have a history of inter-faculty
brawls, in particular the Makassar State University (UNM), which is the scene of frequent brawls and violent
protests. This has prompted police to storm campuses on several occasions. Land disputes and
neighbourhood feuds also have a tendency to turn violent. General security in Belopa has reportedly seen an
improvement since Polres Luwu conducted a crackdown on karaoke bars and cafes. According to local
sources, police action has improved security and safety of people, including businesses operating in the area.

In recent months Polres Luwu has arrested many local street thugs for drug possession. However, in the
areas of Tempat Pelelangan Ikan harbour in Belopa, a number of karaoke bars and cafes are still operating.
The sale of local alcohol known as ‘Ballo’ is common along with gambling activities, illegal drug distribution
and prostitution. Local sources stated that boarding houses ‘Kost’ for women in the nearby cafes are being
used for prostitution.

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Other crime activities that are still a concern in the regency are as follows:

Crime Incident Description Hotspots Frequency

There have been a total of 40 sexual-related violations between January-June
2020 according to the local Women Empowerment and Children Protection
North Belopa,
Sexual Crimes Agency. This suggests that since 2017 there has been an increasing trend. The High
East Lamasi
most cases to date are underage marriages (25 cases), sexual violence (13
cases) and abandonment (2 cases).
There have been at least 10 drug related arrests by Polres Luwu between Ponrang,
Drugs January-June 2020. All arrests made involved crystal meth believed to be Larompong, Moderate
distributed from Palopo. North Belopa
Murder is a concern in Luwu regency, most incidents stem from disagreements Belopa, Bupon,
Murder Moderate
over personal issues. Walenrang
The level of theft is high in Luwu regency and is often perpetrated by groups Belopa, Suli,
Theft targeting high value items including bird nests and electronics such as mobile Bajo, High
phones, laptops, televisions, etc. Larompong
Illegal levies targeting truck drivers are still common in the area. There is a
Illegal Levies likelihood of illegal levies occurring that involve regency officials, however Larompong High
these cases are rarely reported.
Cases involving forgery of currency are common across South Sulawesi
Forgery Province, especially in major cities where notes amounting IDR 1 million are
Bua Rare
approximately sold for IDR 200,000. However in Luwu Regency the crime is not
as prevalent.

In neighbouring Wajo Regency, the provincial police's mobile detective unit (Resmob) arrested three people
during a raid for manufacturing and possessing homemade firearms. The raid followed information provided
by authorities at Sultan Hasanuddin International Airport concerning the delivery of a firearm to Jakarta
from Makassar, South Sulawesi on 17 February 2020. Police seized 43 homemade firearms, hundreds of
rounds of ammunition and two machines used to make the firearms. The suspects, who had been running
the illicit operation since 2014, face at least 10 years in prison.

Luwu Police are reportedly planning to improve the capacity of the Luwu Resort Police by establishing a
battalion of Brimob in Bua District, located just outside Palopo City. Luwu Police are also planning to add a
Water and Air Police Unit (Polairud) to the squad. In addition, the Luwu Regional Government intends to
build a prison in Balubu Sub-District, Belopa District.

In Palopo crime has decreased in 2020 following the closure of several clubs and bars including popular
nightclub, Marco Polo near the port of Palopo. Many violent crimes occurred in these bars, including
stabbings and fights between thugs or intoxicated young people frequenting these establishments. The
owner of Marco Polo is a powerful local Chinese Indonesian businessman, Benny Tenriolo who is also
chairman of the THM Palopo Businessmen Association (Asosiasi Pengusaha THM Palopo).21

Health Issues

Coronavirus
Governor Nurdin Abdullah on 10 June 2020 said the local administration is struggling to reduce coronavirus
infections after the relaxation of the expanded social distancing policy (PSBB) in the province. According to
data from Bonza – an online platform which monitors coronavirus transmission in Indonesia – South

21
https://palopopos.fajar.co.id/2017/10/10/wali-kota-panggil-pengusaha-thm/
https://tekape.co/sabtu-malam-thm-di-palopo-mulai-buka-lagi/

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Sulawesi is listed as the province with the highest transmission rate, at 1.59, far above the recommended
threshold of 1.0, according to World Health Organization (WHO) standards for relaxing restrictions. The
relaxed restrictions on public activity in Makassar, which is one of the province’s red zones for coronavirus
infections, has made it difficult for authorities to ensure the implementation of strict health protocols among
residents. The situation is also exacerbated by the inauguration of a new mayor, causing delays in policy
making.

The government at the central and regional levels is intensifying efforts to mitigate the spread of the
coronavirus outbreak. South Sulawesi has declared a health emergency for the coronavirus, suspending all
school activities and working trips for civil servants. In the province, the referral hospitals are Dr.
Wahidin Sudirohusodo Hospital in Tamalanrea district, Dr. Tadjuddin Chalid, MPH Hospital in Biringkanaya
district, Lakipadada Makale Hospital in North Makale district, Sinjai Regional Hospital in North Sinjai district,
Labuang Baji Regional Hospital in Mamajang district, Pelamonia Hospital in Ujung Pandang district, and
Andi Makkasau Parepare Hospital in West Bacukiki district.

Bird Flu
The Bird Flu virus is common in chickens and is easily spread to human. Cases occurred in the province in
2015. The government detected a sharp rise in avian influenza in July 2016, with an outbreak of 188 cases
detected in birds during the year. There were also concerns in 2017 about the spread of Bird Flu in the
province. Visitors should avoid wet markets and contact with live or dead poultry.

Dengue Fever
The province's Health Agency said on 1 February 2020 that dengue fever killed eight people and infected 658
others in January. Most of the cases were recorded in the Pangkajene Islands Regency and included three
fatalities and 157 infections.

Nine Regions in Gowa Regency were declared endemic areas for dengue fever in November 2019: Somba
Opu sub-district, Pallangga district, the districts of Bajeng and West Bajeng, Bontonompo district, South
Bontonompo district, Barombong sub-district, Bontomarannu district, and Pattalassang. All are categorized
as lowlands.

Measles and Rubella

Cases of measles and rubella are still reported. A single infection case of suspected rubella was reported in
Sengkang district, Wajo Regency, with a child suffering serious complications in August 2019. The infant was
reportedly treated at the La Madukelleng Hospital for Rubella symptoms including microcephaly, cloudy
corneas, deafness and heart problems. The case was classified as congenital Rubella, which can occur in an
infant whose mother has been infected with the virus during pregnancy.

Rabies
Rabies is present in the province. In July 2019 East Luwu regency was declared the third highest endemic
area in the province for rabies after Toraja and North Toraja regencies. The regency's health agency reported
East Tomoni district topped the list of areas with the highest number of rabies cases, followed by
Wasuponda, Wotu, Tomoni, Mangkutana and Burau districts. According to agency data, at least 1,883 dog
bites were recorded in the regency from 2016 to June 2019. No fatalities were recorded.

Tuberculosis
Tuberculosis is a communicable disease displaying an increasing trend in the province. Gowa Health Agency
recorded 428 cases of tuberculosis in the regency between January and March 2019, compared to 328 cases
in the same period in 2018. As many as 202 people in Pare-Pare contracted tuberculosis between January
and June of that year, more than half of the 336 cases reported throughout 2017. Pare-Pare Health Agency

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on 31 July 2019 predicted the figure would reach 400 by year-end. The agency has conducted more
counselling and investigations to detect the infection at an earlier stage.

HIV/AIDS
HIV/Aids is a continuing problem across Indonesia and Sulawesi is no exception, figures from 2015 up to
2018 have highlighted an increase. The Pinrang Health Agency recorded 7 fatalities and 22 infections of
HIV/AIDS between January and December 2018. Thirteen patients suffered from HIV while nine others
tested positive for AIDS in Pinrang Regency. The fatality rate increased from 2017, when 3 fatalities and 38
infections were recorded. The disease has spread to all districts in the regency, with Banyuputih, Bandar and
Gringsing districts having the highest numbers of cases.

A total of 60 people in Sidenreng Rappang Regency died from HIV/AIDS between 2006 and 2016. One
hundred forty-nine cases were recorded in the Regency during that period with sixty of those infected dying.
The remaining patients were treated with anti-retroviral (ARV) therapy.

The most cases recorded in the Regency occurred in 2015: 28 while 17 cases had been identified in the first
half of 2016. Those infected consisted of 105 males, 41 females and 3 children aged between 4 and 12 years
old. The increasing number of cases every year had led the commission to set up working groups to prevent
the disease spreading primarily through sexual transmission. At least 61 people in Pinrang Regency died
from HIV/AIDS up until November 2015. The fatalities were among 127 people infected with the disease in
the Regency.

Anthrax
Anthrax is an acute disease caused by the bacterium Bacillus anthracis. Most forms of the disease are lethal
affecting both humans and animals. No recent cases of Anthrax have been reported. The last reported cases
were in 2016. The case involved two people believed to be infected with anthrax who were hospitalized in
Malimpung village, Patampanua district, Pinrang regency, on 12 March 2016. The patients were admitted to
the hospital with high fever, headaches and other symptoms common with anthrax infections. Both patients
reported having direct contact with anthrax-infected cattle. Since the beginning of March 2016, prior to the
hospitalisation of the 2 patients, at least 43 cattle reportedly died from anthrax in Malimpung village

RISK ASSESSMENT
The following section consists of a methodological risk analysis as part of the TARA. This methodological
process includes an analysis of the consequence of the threat, likelihood of the threat, level of vulnerability,
and the resulting level of risk. Based on the analysis of the level of risk, management implications are
identified and mitigation strategies developed.

Threat and Risk Matrix PT Masmindo

Consequence Score

Consequence Rating Score Definition

Total loss of production and contractual obligations not being met, extensive
Catastrophic 3 economic impact, extensive reputational damage, socio-economic damage over a
large area, business damage affecting Group profitability.
Moderate loss of production but contractual obligations currently being met,
Significant 2 moderate economic impact, some reputational damage, moderate socio-economic
damage, potential for Group business damage if it continues.
Moderate 1 Minimal loss of production, minimal economic impact, minimal reputational damage,

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minimal socio-economic damage, no Group business damage.

Likelihood Score

Consequence Rating Score Definition

Likely events 4 Will undoubtedly happen/recur, possibly frequently
Credible 3 Will probably happen/recur, but it is not a persisting issue/ circumstances.
Serious likelihood 2 Might happen or recur occasionally.
Unlikely but possible 1 Do not expect it to happen/recur but it is possible it may do so

Vulnerability Score

Vulnerability Rating Score Definition

Good capability expected to counter the threat (e.g., detailed Security plan, effective
emergency communication systems, excellent restricted access to site including both
personnel and material from point of entrance and at the site, proactive personnel
Good Deterrence
1 reporting of suspicious activities, effective training and drills for personnel, intrusive
Capability
deterrence measures in place, effective coordination with emergency services, major
coordinated media and PR campaigns, full political support to affect the outcome and
a proactive legal ability to affect the outcome).
Fair capability to counter the threat (e.g., minimal Security plan, restricted access to
Fair Deterrence site by personnel and material from point of entrance and at the site, a minimal
2
Capability coordinated media campaign, ad-hoc political support to affect the outcome and
some legal ability to affect the outcome).
No capability to counter the threat (e.g., no Security plan, unrestricted access to site
No Deterrence by personnel and material from point of entrance and at the site, no coordinated
3
Capability media campaign, no political support to affect the outcome and no legal ability to
affect the outcome).

Consequence and Management Implications

SHADING MANAGEMENT IMPLICATIONS

CRITICAL RISKS (some or all of the following)
- immediate action & contingency planning is necessary
- if they cannot be managed, the business operations may be at risk.
- requires constant & careful management
SERIOUS RISKS (some or all of the following)
- senior management attention needed to fix and prevent the risks
- important to lessen the impact if the risk should occur
- likely to be unforeseen or discounted
- requires careful contingency planning
SIGNIFICANT RISKS (some or all of the following)
- will need to be integrated into the management system
- need to continue to assess and monitor these risks
- management responsibility must be specified
- some contingency planning required
ROUTINE RISKS (some or all of the following)
- routine risk management appropriate: some risks can be dismissed as irrelevant
- however, care needed not to overreact, nor to miss signal that there is a new type of risk
- requires some contingency planning

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Basic Impact Likelihood Matrix

CONSEQUENCE SCORE
Moderate Significant Catastrophic
MANAGEMENT SIGNIFICANCE

Unlikely but (1.1), (1.2), (1.3), (1.4), (1.5), (1.10), (1.13), (1.14), (1.15),
(2.1)
possible (1.7), (1.8), (1.11), (1.12), (2.3) (1.16), (1.17), (1.18), (2.2), (6.5)

(1.9), (1.11), (4.2), (4.4), (4.5),

Serious likelihood (4.3), (4.7), (6.3), (6.6), (6.7)
(4.6), (2.6), (6.4)
LIKELIHOOD AND

Credible (3.1), (5.1), (6.8)

Likely events (2.4), (4.1), (4.8) (1.6), (1.19), (2.5), (6.1), (6.2)

Basic Vulnerability and Consequence Matrix

CONSEQUENCE SCORE
Moderate Significant Catastrophic
Good Deterrence
Capability
(1.6), (1.13), (1.14), (1.15),
VULNERABILITY

(1.1), (1.2), (1.4), (1.5), (1.7),

Fair Deterrence (1.16), (1.17), (1.19), (2.6), (3.1),
(1.8), (1.12), (4.3), (4.7), (4.8),
Capability (4.2), (4.4), (4.5), (6.1), (6.2),
(6.3), (6.6), (6.7)
(6.4), (6.5), (6.8)
No Deterrence (1.9), (1.10), (1.11), (1.18), (2.2),
(1.3), (2.3), (2.4), (4.1) (2.1)
Capability (2.5), (4.6), (5.1)

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Risk Analysis Table

1. Political Threat
Risk
Adversary Action Risk Consequence Likelihood Vulnerability Mitigating Strategy
Score
South Governor South Sulawesi passes (1.1) Special taxes/levies are Moderate Unlikely 2 Fair  Conduct analysis of powers Provincial
Sulawesi provincial regulations detrimental to the introduced on Masmindo for but Deterrence Government has to introduce taxes/levies such as
Governor Masmindo project. Possible concerns using local government services possible Capability road usage taxes, lighting taxes and general cost-
include but are not limited to recovery taxes.
(1) Environment protection  After analysis, submit Financial Impact Statement
(2) Requirement for mandatory regional to Ministries of Energy & Mineral Resources and
offices and licenses Taxation. Seek mechanism for cost recovery.
(3) Road use (1.2) Concession site becomes Moderate Unlikely 2 Fair  Conduct analysis of areas used by PT Masmindo
(4) Local recruitment subject to additional regulations but Deterrence subject to local Regulations or Central
(5) Level of economic benefit for the possible Capability Government Regulations or are subject to both.
region  The criticality of each asset is then identified and
a Business Continuity Plan developed, in case of
closure, due to discriminatory local Regulations.
(1.3) Masmindo gold processing Moderate Unlikely 2 No  Audit is undertaken of all planned Development
facility creation, including road but Deterrence Applications, which are subject to local
route, applications are delayed possible Capability government approval.
 Develop Contingency Plans in case they continue
to delay.
 Commence a large Media/PR campaign designed
to influence and educate.
(1.4) Local government officials Moderate Unlikely 2 Fair  PT Masmindo staff/contractors are required to
conduct checks of all Masmindo but Deterrence carry ID, SIM and police vehicle registration at all
vehicles on public roads possible Capability times.
 Staff members are to use seat belts off site.
 Vehicles should be checked and all defects fixed
before they use public roads.
(1.5) Local government officials Moderate Unlikely 2 Fair  Expatriate staff should at all times carry KITAS,
conduct ID checks on all but Deterrence passport copy and if required, travel permit (Surat
Masmindo contractors on public possible Capability Jalan).
roads

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Risk
Adversary Action Risk Consequence Likelihood Vulnerability Mitigating Strategy
Score
Luwu Regent Luwu Regent passes regulations (1.6) Masmindo reputation is Significant Likely 6 Fair  Establish good relation with selected reputable
detrimental to Masmindo concerning its facing inaccurate accusations events Deterrence local, regional, national media outlets and
concession area and introduces other against the gold mining project Capability commence a large Media/PR campaign designed
discriminatory regulations. Possible to influence and educate.
concerns include but are not limited to (1.7) Local government denies Moderate Unlikely 2 Fair  Prepare a formal Letter of Complaint in advance
(A) Allegations of non-utilization of land access to selected area within the but Deterrence and any PT Masmindo employee stopped is
(B) Lack of realization of promised concession area possible Capability respectfully to give a copy to the authority
regional development funds present. There is to be no confrontation.
(C) Allegations of not undertaking  Prepare an Incident Report for the contracted
promised projects in Luwu Regency guarding company and PT Masmindo Security.
(D) Allegations that Masmindo is working  Once completed a formal protest is lodged with
with local miners who are violating the respective Administration or Department.
forest permit regulations. (1.8) Local authorities dismantle Moderate Unlikely 2 Fair  Undertake analysis to determine what power the
any works at project site/s but Deterrence respective authority has to undertake such action.
possible Capability  If the Department has the power then a flow
diagram should be prepared of the process time-
line e.g., notice periods etc.
 Prepare a Contingency Plan for each critical
incident identified in the flow diagram.
(1.9) Approval processes are Significant Serious 4 No  Undertake an audit of all planned Development /
delayed likelihood Deterrence Construction applications which are subject to
Capability local government approval.
 Develop Contingency Plans in case delay.
 Implement a broad-based media/PR campaign,
utilizing mass media, ComDev, ComRel and
provincial supporters to progress the issuance of
appropriate licenses.
(1.10) Harassment of Masmindo Significant Unlikely 3 No  Develop Information Collection Plan for
staff by sponsored but Deterrence Information Collection and Analysis teams
groups/criminals possible Capability operating in the vicinity of the concession site and
all aspects of company operational activities.
 Use this approach to develop a Threat Indices,
and once activated, staff from the security guard
contractor should contact all vehicles traveling

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Risk
Adversary Action Risk Consequence Likelihood Vulnerability Mitigating Strategy
Score
to/from the site/s.
 Establish a security post in potential vulnerable
locations and manned 24-7.
Rogue government officials embezzle or (1.11) PT Masmindo incurring Significant Serious 4 No  Develop Information Collection Plan.
steal funds allocated for road financial loss due to fraud. This likelihood Deterrence  Conduct Due Diligence checks on contractor
improvement and expansion project that will cause operational delays Capability companies and/or tender participants.
Client is undertaking and funding where impacting project. Reputation  Develop capability to conduct investigations.
the Regional Government is arranging damage by association with a  Develop and use Specific tender guidelines and
the compensation and payments to project marred by graft and road construction project milestones.
villagers. Client will not only incur corruption. Relations with local
financial loss but also suffer reputational community become negatively
damage by being associated with a impacted by fraud and
project marred by graft and corruption. corruption.
Ministry of Possible concerns include but are not (1.12) Ministry auditors go to Moderate Unlikely 2 Fair  Conduct analysis to determine powers Ministry
Energy and limited to Masmindo offices and examine but Deterrence has under legislation concerning such actions.
Mineral (1) Ministry officials initiate an audit of all admin, financial and gold possible Capability  Develop aide-memoire for staff use during audit.
Resources Masmindo interests and assets or other mining and gold processing  Aide-memoir should NOT be distributed until an
disruptive measures against Masmindo records official notice is received from the Department.
(Allegations of non-adherence to the (1.13) The Ministry applies Significant Unlikely 3 Fair  Identify and activate legal team with expertise in
provisions of the IUP/CoW). different interpretations of gold but Deterrence gold processing if any controversial
processing legislation / possible Capability interpretations be applied by Ministry.
Regulations / Rules  That team should vigorously dispute such
interpretations by utilizing all available means
within Indonesian Law.
(1.14) Directs staff in Luwu Significant Unlikely 3 Fair  Determine powers Ministry has under
Regency to monitor all gold but Deterrence legislation/Regulations concerning such actions.
processing activities on-site possible Capability  Develop aide-memoire for staff use during
during times of permit delays. inspection period.
 Aide-memoire should NOT be distributed until
official notice is received from the Department.
 For all normal staff, HSE requirements should
apply to Ministerial staffs that are sent to PT
Masmindo locations.
 Prepare corporate response if a public official

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Risk
Adversary Action Risk Consequence Likelihood Vulnerability Mitigating Strategy
Score
requests transport, meals and accommodation
assistance from the Company.
Attorney AGO initiates legal action against (1.15) Prosecutors investigate Significant Unlikely 3 Fair  PT Masmindo staff summoned as witnesses
General’s Masmindo (Allegations of environmental allegations into complaints from but Deterrence should attend with a legal representative from
Office damage/criminal conduct). the Regent, Luwu or Provincial possible Capability the Company and cooperate with the
Administration concerning investigator.
corruption, insulting public  PT Masmindo officer summoned as a suspect
officials, undertaking actions that should only attend after clarification is sought;
may have caused a financial loss he/she removes all personal and valuable
to the State and fraud. property and then attends with a legal
representative and in the case of an expat, with a
Consular Officer.
 If detained at a Police facility and not the AG’s
detention facility, they are to request detention
take place at MABES POLRI Jakarta or POLDA HQ.
 Meals or money for meals should be provided by
the company.
 Bail or city or home detention should be applied
for immediately by the employee’s lawyer.
Tax Ministry Tax Ministry initiates action against (1.16)Tax auditors go to the Significant Unlikely 3 Fair  Aide-memoire should be developed for staff to
Masmindo (Allegations of tax avoidance, Masmindo offices and examine but Deterrence use during such audits.
transfer pricing/data manipulation). all financial and administrative possible Capability  Aide-memoir should NOT be distributed until
records official notice is received from the Department of
Taxation.
INP INP initiates action against Masmindo (1.17)Police investigators Significant Unlikely 3 Fair  PT Masmindo staff summoned as witnesses
(allegations of criminal conduct). summon numerous staff of but Deterrence should attend with a legal representative and
Possible concerns include but are not Masmindo and initiate criminal possible Capability cooperate with the Police.
limited to dossiers  PT Masmindo officer, summoned as a suspect,
(1) Corruption should only attend after clarification is sought;
(2) Insulting Public Officials  He/she removes all personal and valuable
(3) Fraud property and then attends with a legal
(4) Environmental offences representative and in the case of an expat, with a
Consular Officer.
 If detained, they are to request detention take

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Risk
Adversary Action Risk Consequence Likelihood Vulnerability Mitigating Strategy
Score
place at MABES POLRI Jakarta or POLDA HQ.
 Meals or money for meals should be provided by
the company.
 Bail, city or home detention should be
immediately applied by the employee’s lawyer.
Members of DPRD members commence a negative (1.18) A campaign centered on Significant Unlikely 3 No  Develop media strategy centred on donations,
the Luwu campaign against PT Masmindo. This nationalism, CSR, environmental but Deterrence COMDEV, taxation and royalty payments, and
DPRD campaign would also be supported by concern or socio-economic possible Capability benefits to the Luwu Regency.
the Regent and a coalition of supporters. concern (employment/projects  Develop series of short documentaries on
for locals and critical assets is benefits for Indonesia, specifically Luwu Regency,
initiated, aiming at taking over of particularly those living within the site, by having
the interests of Masmindo in the PT Masmindo project in the Regency.
Luwu Regency
Village heads Village heads and community leaders (1.19) A campaign centred on Significant Likely 6 Fair  Develop community relation strategy centred on
and influence residents not to sell their land refusing land acquisition by PT events Deterrence establishing mutual relationship between PT
community or demand larger financial payments Masmindo is initiated, as well as Capability Masmindo and surrounding communities.
leaders from PT Masmindo. setting up road blockades.  Develop common understanding, respect and
appreciation of local values.
 Develop Information Collection Capability to
conduct further risk analysis and associated
Action Plans to mitigate risks.

2. Security Threat

Risk
Adversary Action Risk Consequence Likelihood Vulnerability Mitigating Strategy
Score
Terrorist Terrorists conducting a terrorist attack (2.1)Fatalities and delays in Catastrophic Unlikely 4 No  Develop information collection strategy centred
group/s with firearms or explosives against the logistical support causing further but Deterrence on identification of possible terrorist cell in area
Client employees, contractor employees delays in project development. possible Capability surrounding the project location.
or client property in Luwu Regency
causing fatalities or severe injuries.

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Risk
Adversary Action Risk Consequence Likelihood Vulnerability Mitigating Strategy
Score
Extremist and Terrorist or violent extremist and radical (2.2) PT Masmindo can be seen as Significant Unlikely 3 No  Develop information collection strategy centred
radical groups infiltrating the Client’s or providing means and support for but Deterrence on identification of possible extremist and
group/s contractor workforce and radicalizing extremist and radical groups. possible Capability radical groups conducting activities in area
employees resulting in tensions between surrounding the project location.
employees that can escalate into larger  Develop counter-extremism strategy to reduce
security incidents, disputes or conflicts. or prevent extremist influence on the workforce.
Rogue Rogue elements within TNI or Police (2.3) PT Masmindo is susceptible Moderate Unlikely 2 No  Cooperate with TNI and Police under formal
elements pressuring the Client and/or its to corrupt practices involving but Deterrence agreement with official TNI and Police
within TNI or contractors to provide payment for government officials, where possible Capability institutions.
Police security services or otherwise risking senior management is under
problems during operation or occurrence pressure to conduct illicit
of security incidents and disturbances. payments.
Criminal Criminal group/s targeting PT Masmindo (2.4) Loss of asset suffered by PT Moderate Likely 5 No  Conduct employee background check, improve
group/s assets for theft using unauthorized Masmindo, triggering financial events Deterrence facility security system, and improve quality of
access and infiltration or through insider losses and operational delays. Capability guarding staff performance.
support with a colluding client employee  Develop Information Collection and
or contractor employee. Investigative capability and liaison with INP and
TNI to share information.
 Improve security awareness among employees
 Develop internal ethic hotline system to receive
any inside information relating to possible breach
of company regulations.
Drug traffickers targeting Masmindo (2.5) Employees becoming Significant Likely 6 No  Conduct Drug Prevention and Screening
employees or contractor employees with addicted, causing workplace events Deterrence program.
Crystal Meth sales to become customers. accidents or conducting criminal Capability  Develop effective information collection
activities to finance their drug capability.
addiction, such as selling drugs to  Liaise closely with INP offices and BNN branches
other employees. to be vigilant against drug trafficking groups.
Illegal gold Illegal gold mining groups entering the (2.6) Illegal mining causing Significant Serious 4 Fair  Consistently audit HSE records to ensure that all
miner wider project area with the aim to negative regional impact that likelihood Deterrence government environmental and social impact
group/s explore and exploit gold resources in the can be blamed on PT Masmindo, Capability standards are being met and maintained.
wider area of the Client’s project site, such as environmental pollution,  Monitor any disposal sites for any human activity
often in collusion with local residents increased crime (prostitution, which could be construed as pollution or
narcotics, theft, attack, violence) pollution-related damage (e.g., damage to rivers,

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Risk
Adversary Action Risk Consequence Likelihood Vulnerability Mitigating Strategy
Score
and increased safety issues. road drainage, damaged irrigation systems, etc.)
 All such events be recorded and investigated by
Company to determine accuracy of allegations.
 Develop Information Collection and Investigative
capability.
 Liaise with INP and TNI to share information.

3. Natural Disaster Threat

Risk
Adversary Action Risk Consequence Likelihood Vulnerability Mitigating Strategy
Score
Natural (1) Landslides or flash floods resulting (3.1)Possible fatalities and delays Significant Credible 5 Fair  Developing Disaster Response Strategies and
disaster from incessant rain blocking access roads in logistical support causing Deterrence conduct regular training.
resulting in disruption of mining further delays in project Capability  Identify geographic risk areas for landslides.
operations and logistical support. development.  Develop Crisis Management Plan and Business
Continuity Plan.
(2) Potential earthquakes impacting the  Liaise with Basarnas Search and Rescue Agency
mining project and its employees and and other relevant agencies with disaster
other assets. response capability such as TNI and INP.

4. Private Enterprise Threat

Risk
Adversary Action Risk Consequence Likelihood Vulnerability Mitigating Strategy
Score
Undefined Undefined business group(s) initiates (4.1) Masmindo contractors are Moderate Likely 5 No  Contact contractors regularly to address issue.
business action against PT Masmindo (e.g., subject to commercial pressure events Deterrence All external approaches are to be recorded.
group(s) questioning the socio-economic benefit by the undefined business Capability  Response Plan be developed and actioned if
of the mining project and the company’s entities. required, particularly with PT Masmindo
presence in the area). The group uses contractors/sub-contractors
influence and power to bring pressure on (4.2) Undefined group/s pressure Significant Serious 4 Fair  Audit HSE records consistently to ensure that

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Risk
Adversary Action Risk Consequence Likelihood Vulnerability Mitigating Strategy
Score
Masmindo to abandon the concession the Environment-al Agency to likelihood Deterrence all government environmental standards are
site, so that it can be taken over by undertake a review of the gold Capability met and maintained.
another business entity. mining operation.  Monitor disposal sites for human activity which
could be construed as pollution or pollution-
related damage (e.g. damage to rivers, road
drainage, irrigation systems, etc.)
 Record and investigate all events to determine
accuracy of allegations.
(4.3) Undefined business entities Moderate Serious 3 Fair  Remind staff of confidentiality provisions
put pressure on individual staff likelihood Deterrence contained in PT Masmindo’s Ethics Policy and PT
(particularly at the local level) to Capability Masmindo Communication/Document Security
provide information detrimental Manuals.
to Masmindo interests.  Review computer access levels for access
controls on material classified or sensitive.
 Examine restricted records
 Investigate any access with no valid business
reason(s) and remove as necessary.
 Registers be implemented and held by Restricted
Records Registrar who will regularly audit and
provide findings to management.
 PT Masmindo Security Officer be specifically
tasked with investigating and reporting daily on
all after-hours access and recorded door alarms
at PT Masmindo Jakarta’s offices.
(4.4) Business entities put Significant Serious 4 Fair  Develop Project Influence Matrix and those
pressure on individual staff likelihood Deterrence officers that reach the highest level of the
within Masmindo to provide Capability respective companies and are deemed
active support for a takeover bid. susceptible to such pressure be monitored.
 Install capability to actively monitor specific IT
accounts from Jakarta, if not already installed.
This should randomly occur for all officers
identified and reports only go to one particular
officer in Jakarta and he/she should be subject to
audit by Masmindo Corporate Security.

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Risk
Adversary Action Risk Consequence Likelihood Vulnerability Mitigating Strategy
Score
(4.5) Undefined business entities Significant Serious 4 Fair  Maintain relationships with external contractors
seek to become a major likelihood Deterrence and business people.
stakeholder in the Masmindo Capability  Though there is no indication at this time of any
gold mining venture in Luwu intention to manipulate situations, the same
Regency. does not apply to staff members family/children
and the potential situation should be monitored.
 Develop information collection and investigative
capability, including conduct of Due Diligence.
(4.6) Business entities bring Significant Serious 4 No  Identify business entities with demonstrable
pressure on the Central likelihood Deterrence record of blocking gold processing interests, with
Government to influence future Capability political parties always seeking financial
gold mining industry donations, creating influence. Influence must be
development ideas weakened. Two areas where the business
recommended by Masmindo entities are vulnerable: reputation and financing.
 Action Strategy/Plan can be developed to
manage reputation, which supports any
potential demonstrators, environmental activists
and other concerned citizens to pay for
advertising space in newspapers, billboards and
TV. Two focus groups need to be reached: the
political elite and the special interest groups.
This can be maintained during the entire process
Indonesian Contractors/sub-contractors involved in (4.7) Indonesian parties initiate Moderate Serious 3 Fair  Action should be countered aggressively by
contractors/ initiation of civil action against PT action alleging that PT Masmindo likelihood Deterrence production of contracts, agreed undertakings,
sub- Masmindo consortium has taken actions Capability including responsibilities regarding quality,
contractors that caused them detrimental quantity and timeliness. Corporate legal should
effect be involved in any response.
PT Masmindo The influx of Client employees and (4.8) Domestic disputes involving Moderate Likely 5 Fair  Remind staff and contractors to follow company
company contractors from outside the locale will mine workers and local residents events Deterrence regulations contained in PT Masmindo’s Ethics
employees impact social family structures in the can escalate into security Capability Policy and Communication/Document Security
surrounding villages where mine workers incidents placing communities Manuals.
develop intimate relations with local against Masmindo.  Develop effective information collection
residents. capability.

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5. Media Threat

Risk
Adversary Action Risk Consequence Likelihood Vulnerability Mitigating Strategy
Score
Selected Selected media outlets are utilized to (5.1) Negative public perception Significant Credible 5 No  Develop media strategy centred on donations,
local/ mount a PR campaign against Masmindo on PT Masmindo as a result of Deterrence Community Development funding, taxation and
regional/ (Allegations with a resource nationalism negative PR campaign, which can Capability royalty payments.
national theme), leading to a coordinated and cause detrimental effect for PT  Consider developing a series of short
media outlets detrimental campaign. Possible concerns Masmindo reputation documentaries on PT Masmindo project in the
include but are not limited to campaign region benefitting Indonesia and Luwu Regency,
centred on: particularly those living within the site. Short
(1) Nationalism documentaries should be aired to mitigate
(2) Corruption negative media messages.
(3) CSR
(4) Labour rights
(5) Human rights abuse
(6) Environmental damage & exploitation

6. NGO and Special Interest Group Threat

Risk
Adversary Action Risk Consequence Likelihood Vulnerability Mitigating Strategy
Score
Selected NGOs initiate and maintain a campaign (6.1) Negative public perception Significant Likely 6 Fair  Audit HSE records to ensure that all government
local/ against PT Masmindo in various media on PT Masmindo as a result of events Deterrence environmental standards are met.
regional/ outlets including social media, possibly negative PR campaign, which can Capability  Monitor disposal site for human activity, which
national NGO based on unsubstantiated and erroneous cause detrimental effect for PT could be construed as pollution or pollution-
Group information/data. General allegations Masmindo reputation related damage (e.g., disruption or damage to
Environment may relate but are not limited to community irrigation systems, etc.). All such
al groups: (1) Environmental damage such as events are to be recorded.
(1) Local polluting the Songgang River and causing  Re-examine the CSR Plan.
youth groups landslides  Prepare an Outcomes Statement to counter
with like- (2) Labour exploitation respective claims.
minded (3) Illegal land occupation  Develop Counter Demonstration Plan.
‘concerned’ (4) General exploitation  Upon construction of processing facility, submit

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Risk
Adversary Action Risk Consequence Likelihood Vulnerability Mitigating Strategy
Score
citizens application to be listed as a National Vital Object,
initiate action affording a level (but not absolute) protection.
against PT (6.2) Road blocks and Significant Likely 6 Fair  Prior to any development activities, Community
Masmindo demonstrations are conducted events Deterrence Relations teams need to socialize upcoming
(2) Union against the development actions Capability activities and so that there are no surprises for
officials of PT Masmindo because of fears locals.
(3) Student of impact on local villagers  Use Police to control demonstrators
groups (6.3) A formal complaint is made Moderate Serious 3 Fair  Audit HR records to ensure that all government
(4) Selected to the ILO to investigate PT likelihood Deterrence requirements are met.
village Masmindo labour practices and Capability
communities particularly the use of contractors
(villages in and outsourcing
ring two area (6.4) People who believe they Significant Serious 4 Fair  As a preventative, Community Relations teams
and Bajo have been affected by pollution likelihood Deterrence need to engage locals in the project area prior to
District) or have had their traditional Capability applying new technologies or innovative science.
lifestyles affected detrimentally  Effective communications on future activities,
by the Masmindo operation will will likely result in greater acceptance where the
be approached for support project can move forward without issues.
(6.5) A formal complaint is made Significant Unlikely 3 Fair  Any such actions should be vigorously responded
to the Human Rights Commission but Deterrence with proper legal defense.
possible Capability
(6.6) Masmindo signage is Moderate Serious 3 Fair  Contracted security provider and PT Masmindo
vandalized at such places as Luwu likelihood Deterrence Security should make formal complaint to Police
and/or villages in the concession Capability
area
(6.7) An anti-Masmindo gold Moderate Serious 3 Fair  Contracted security provider and PT Masmindo
processing graffiti campaign is likelihood Deterrence Security should make formal complaint to Police
mounted against Company assets Capability
(6.8) A rolling strike program is Significant Credible 5 Fair  PT Masmindo management should effectively
introduced involving contractor/s Deterrence use Industrial relations strategies.
and Masmindo staff Capability

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Analysis

The TARA process has identified a number of risks which include Critical Risks that need the Client’s
immediate attention for prevention or mitigation. These risks are perceived as critical as they can obstruct or
delay vital elements of the Client’s mining project which are the successful acquisition of required land, the
overall improvement of road access, the protection of environmental compliance and the associated
reputation of being compliant, environmentally friendly, responsible towards the community and beneficial
to local economies.

Critical Risks

The Critical Risks are as follows:

 Delays to the land compensation process
 Environmental allegations
 Protests and Pressure from Ring Two village communities
 Illegal narcotics entering the operating environment

The management implications of these risks are that immediate action and contingency planning is
necessary, because if these risks cannot be managed, the business operations may be at risk. Thus, these
risks require constant and careful management.

Serious Risks

In addition, a number of Serious Risks were identified:

 Criminal groups conducting theft

 Natural Disasters
 Social impacts of Client employees or contractor employees on local communities
 Regional media joining negative environmental campaigns against the Client

The management implications of these risks are that senior management attention is needed to fix and
prevent the risks. It is important to lessen the impact if the risk should occur, which requires careful
contingency planning.

Significant Risks

Furthermore, a number of Significant Risks were identified:

 The Regional Government issuing regulations detrimental to the Client

 Fraud and Corruption impacting the Client
 Terrorist and extremist groups
 Business entities pressuring the Client

The management implications of these risks are that routine risk management is appropriate. Some risks can
be dismissed as irrelevant. However, care is needed not to overreact or to miss signals of a new type of risk.
The Significant Risks require some contingency planning.

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CONCLUSION
There are a number of threats and risks, including critical risks, which need the Client’s immediate attention
for prevention and mitigation. These critical risks can obstruct, delay, suspend, or shut down vital elements
of the Client’s mining project. They include the successful acquisition of required land, the overall
improvement of road access, the protection of environmental compliance and the associated reputation of
being compliant, environmentally friendly, responsible towards the community and beneficial to local
economies. These critical risks are as follows:

 Delays to the land acquisition and compensation process

 Environmental allegations
 Protests and Pressure from Ring Two village communities
 Illegal narcotics entering the operating environment

In the current environment, the perception of many local communities in Latimojong and Bajo Districts as
well as Belopa is either negative or critical towards the Client and its mining project. The Client has to
carefully manage these perceptions to prevent the occurrence of the identified threats such as
environmental allegations or refusal to sell land, as these can result in significant to devastating
consequences to the Client’s Awak Mas gold mining project.

This perception and reputation management is largely dependent on the Client’s ability and level of success
in developing a robust and effective security and risk management capacity that can address the threats
identified.

RECOMMENDATIONS
The recommendations in this report have been separated into the same threat categories highlighted in the
findings section of this report. Based on this approach, the suggested recommendations and mitigation
measures developed in the report have been linked to the threats and risks identified.

The recommendations for Client review and consideration are as follows:

Security Action Management Plan Recommendations (SAMP)

Client management establishes and maintains a security management department that is capable,
professional and supported by senior management. The Client security management department must
be able to provide a strong level of SAMP execution in the immediate and short term. The Client may
consider using an appropriate outsourced provider to recruit, train and mentor the Client security
manager and other required security department personnel. This will enable the identified outsourced
provider to implement all immediate actionable requirements of the SAMP in a timely manner. This level
of support would require an interim-Security Manager and department members arranged by the
Provider to select suitable and experienced security professionals to populate the Clients security
department.

Client maintains a process of continual review of security capacity and capability to regularly review
changes in the security environment during and after the construction phase.

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Interim-Security Manager and team will use international standards of security and risk management to
implement the SAMP and develop the capacity and capability of the Client’s Security Department within
a specific time period to fully support the Client’s Construction Phase and operations beyond this phase.
Elements of the SAMP include but are not limited to the following:

a. Identify suitable and competent Security Manpower Providers (SMP) focused on overall
security at the mine site, the command and control centre and the gold room. The different
SMPs should be used for the different functions to minimize the potential of collusion and theft.
There remains a need for a portion of these security guards recruited from the local area.

b. The Client contracts additional SMPs outside of South Sulawesi Province that are specifically
trained in Gold Room Security functions and requirements tailored to the Client’s requirements
at their mine site. This SMP will provide a guard force that remains isolated from the rest of the
workforce at the mine site to reduce any potential risk of criminal collusion and theft of gold or
other high value items from the gold room.

c. Establish and maintenance security command and control centre to coordinate physical
security, access control, intrusion detection, CCTV, incident response, crisis management
requirements and other technical security requirements, etc.

Client improves current information collection, collation and analytical capability/capacity. The majority
of key threats to the Client are external and outside the Client’s facility. This requires the
implementation of an All-source Information Collection Process that collates and analyses information
producing actionable intelligence that enables Client senior management to make timely and informed
decisions. Furthermore this process provides Client management with the option of developing counter-
narratives, strategies and programs that can deploy action management plans to manage and mitigate
security threats and risks. These action management plans can be executed by teams not associated
with the Client, thereby minimizing risk to the Client while remaining compliant to senior Client
management oversight and audit requirements. The aim and objectives are as follows:

a. Ability to rapidly identify potential political, commercial, NGO/activist and other adversaries,
including issue-motivated stakeholders attempting to negatively influence and manipulate
community members and present other threats and risks that will impact the Client.

b. Ability to convert collected information in a timely manner from multiple sources, employing an
All Source Information Collection and Analysis Process, which will enable Senior Management to
make timely and informed management decisions.

c. Ability to develop, implement and maintain counter-narratives, strategies, and programs

including initiation of action management plans that mitigate the risk from identified threats to
the Client and their contractors impacting Client operations in Luwu Regency. This external
information collection capability serves as an early warning system that is aimed at proactively
mitigating threats and risks. This approach allows the Client to make well-informed decisions
that can prevent, address or resolve security and risk issues early before threats escalate and
become significant to the Client’s operation.

Client develops an investigative capability predominantly focused on Due Diligence investigations,

background checks, fraud, theft, and corruption investigations. The aim and objectives are as follows:

a. The Client undertakes effective, secure and mandatory background checks of its employees as
well as requiring all contractors to conduct background checks on their employees. The

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background checking process is focused on identifying criminal behaviour and/or affiliations,

sympathies or support-activities to terrorist or extremist organizations that form a threat.

b. The Client undertakes effective, secure Due Diligence capability prior to working with or
utilizing entities, organizations and affiliated suppliers, contractors as an element to maintain a
robust security management footprint and minimize the potential threat of theft, fraud and
corruption.

c. The Client undertakes effective, fraud, theft and corruption investigations as required to
mitigate such threats impacting the client including financial loss and reputational damage.

Client establishes a MoU with the South Sulawesi Police (Polda Sulsel). This MoU must include an
agreement that includes Voluntary Principles of Security and Human Rights and a formalized use of force
agreement, setting out and establishing the rules and guidelines for police support and assistance.
Furthermore, such an agreement needs to define codes of conduct and expectations on both sides,
including outcomes. The MoU should also outline agreements for police assistance in counter-terrorism,
illegal narcotics, land encroachment, illegal mining, and other associated crime types impacting the
Client’s operations. In addition, this MoU must define the specific agreements between the Client and
the INP concerning police response and support to the Client during road blockades by protests that
disrupt its operations as an example.

Client registers the mine site into a National Vital Object (Obvitnas), which can obtain support and
assistance from government security and law enforcement agencies.

Client ensures suitable security training is provided by an external provider coordinating and executing
training for all facility Management, HSSE and Security personnel at the project mine site for Voluntary
Principles of Security and Human Rights. The aim and objectives are as follows:

a. That all security personnel at the Client’s project site have a basic knowledge of human rights.

b. Security personnel will always act in accordance with universally adopted Human Rights during
their security duties, including during interactions with community members and individuals.

c. Client management displays a strong commitment to the protection of human rights and
compliance with international standards in the protection of a national vital object.

Land Ownership - Delays in Land Acquisition and Compensation

Currently local residents in Ring One want to sell however, they are being influenced by narratives from
multiple stakeholders wanting to be included in and influence the land acquisition process. These
stakeholders will continue to delay the process, motivated by economic opportunity and social jealousy.
Suggested recommendations are as follows:

Continue improving socialization of the Client’s historical development of the project to improve local
residents understanding of the facts, goals and objectives leading up to and including the land
acquisition and compensation process. The aim and objectives are as follows:

a. Improve local residents’ understanding by promoting information narratives that build stronger
relationships with the surrounding villages in Ring One based on accuracy and facts to counter
misinformation, influence and manipulation of negative stakeholders who are only motivated by
economic opportunity and social jealousy.

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b. Enhance the Client’s image by maintaining current social and economic programs with a
renewed focus that is targeted toward minimizing dissenting opinion in the local communities of
Ring One and Two through positive reinforcement, changing dissenter’s opinion to support the
Client.

c. Reduce local village resident’s suspicion of the company by continued transparent

communication with local residents which is essential in building a stronger relationship.

d. Improve communities’ trust in the Client by increasing local resident’s positive experiences with
the Client, by regular communicating and delivering on tangible community and economic
benefits and expectations.

Client improves current information collection, collation and analytical capability/capacity. The aim
and objectives are as follows:

a. Ability to rapidly identify potential political, commercial, NGO/activist and other adversaries,
including issue-motivated stakeholders attempting to negatively influence and manipulate
community members and are delaying the land acquisition and compensation process.

b. Ability to convert collected information in a timely manner from multiple sources, employing an
All Source Information Collection and Analysis Process, which will enable Senior Management to
make timely and informed management decisions.

c. Is able to develop, implement and maintain counter-narratives, strategies, and programs

including initiation of action management plans that mitigate the risk from identified threats to
the Client and their contractors impacting Client operations in Luwu Regency.

Undertake further continued investigation into disputed and multiple claims on specific land ownership
cases, impacting and delaying land acquisition and compensation process negotiations.

Client maintains detailed records, documentation, copies of negotiation video footage, etc. of land
agreements and their negotiation with local villagers and stakeholders. This is to protect the Client
against any future claims or allegations that the land acquisition and compensation process was unfair,
involved coercion or lacked transparency.

Client establishes a targeted Social Media Engagement Plan as an element of its overarching Corporate
Communication Plan. To mitigate and manage adversary strategies that influence and manipulate
landowners and local residents in Ring One, initiate a dedicated social media campaign to disseminate
facts as part of a counter-narrative educating local community members about the history and future
goals and objectives of the Client and the project.

Environmental Allegations

Where the Client will operate, the environment is of most importance to residents of local villages that grow
coffee, cloves, cocoa and rice for their main source of income. The threat of environmental damage is real
and communities fear the environmental impact that threatens their livelihood and standard of living.
Allegations of pollution and other damage to the environment including loss of life and property from
landslides are triggers that are easily manipulated by adversaries to influence communities, promote unrest,

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and destabilize Client/community relationships, increase government scrutiny and intervention and
adversely impact the Client’s operations and reputation. Suggested recommendations are as follows:

Client establishes additional village-based information and socialization service centres, leasing small
houses or facilities in surrounding communities for liaison, communication and coordination with local
communities in the Latimojong District. Centres would be integrated into the Client’s broader
socialization program to improve local residents understanding of historical and current facts and Client
goals and objectives. This would include the Clients’ commitment towards environmental management,
compliance, commencement of environmental initiatives and dissemination of factual information and
counter-narratives/programs that limit and mitigate the negative impact of identified adversary’s
strategies to manipulate and influence the local community.

Client develops and implements mine site visits (medium to long-term plans) for members of the local
communities and other stakeholders. This would be an element of the Client’s continued socialization
toward ongoing transparency on environmental compliance and sincere environmental initiatives that
build trust and strong relationships with local communities, while promoting the Clients’ image.

Client initiates a Corporate Communication Plan (CCP) aimed at engaging with environmental groups in
Luwu Regency to develop a positive working relationship. This needs to engage all stakeholders including
land owners, local communities, regional and local government, activists and NGOs. Concurrently, the
Client needs to maintain a continuous level of information collection and deployable action management
plan capability to address the activities, campaigns, and networks of identified organizations,
stakeholders and adversaries.

Client develops an active Media Communication Plan (MCP) as an element of its overarching Corporate
Communication Plan. The MCP will identify dissenting media sources and focus on changing the
narrative through engagement with local journalists and media to socialize factual information on the
mining project’s history/goals/objectives, employing mining technologies and their impact on the
environment and Client compliance to environmental regulations.

Client establishes an environmental monitoring capability deploying monitoring stations and activates
its information collection capability to provide early indication of incidents of environmental pollution of
water sources and environmental degradation in the area. Concurrently, establish a communications
hotline enabling the Client to maintain close coordination with local village administrations and work
with government agencies (to include disaster response agencies such as Basarnas) to monitor potential
locations susceptible to landslides and the pollution of water sources in the Bajo and Latimojong
Districts. This would include areas of Client and their contractor activity, main supply routes, any
locations where illegal mining or community mining is occurring and areas where incidents would
endanger life and property in local communities. The Client would also coordinate with law enforcement
in managing non-compliant environmental regulation in its area.

Client maintains or has access to an in-depth investigations capability that can be used proactively as
soon as allegations of environmental pollution or damage are directed to the Client. The aim and
objectives are as follows:

a. At short notice establish accurate facts, collect evidence, establish a detailed chronology of
circumstances that communicated to senior management in a timely manner, allowing them to
make informed decisions.

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b. Maintain close levels of communication and coordination with the Client’s External Relations,
Government Relations and Corporate Communications teams supporting timely and accurate
information-sharing, early threat identification and coordination of response actions.

c. Maintain a capacity to counter any false reporting or baseless allegations. This includes timely
development and implementation of counter-narrative initiatives and other strategies and
programs deploying Action Management Plans to contain the threat and mitigate the risks.

Political/Corruption/Extortion/Coercion/Fraud

Client management needs to develop a detailed understanding of the political environment to manage the
changing security environment. The same applies in identifying and proactively managing potential
incidence(s) of corruption, extortion, coercion, and fraud that can result in financial loss and/or reputational
damage for the Client and its operations. Suggested recommendations are as follows:

Client uses its information collection capability to provide timely and accurate information enabling
senior management to make informed and timely decisions. The aim and objectives are as follows:

a. Maintain an ability to monitor and assess the continually changing local and regional political
environment, and issues involving corruption, extortion, coercion, and fraud to develop and
maintain an accurate and timely appreciation of the security environment and the actors
involved in illicit and criminal activity targeting the Client.

b. Maintain a capacity and capability for in-depth levels of understanding of new or changing
developments, situations, and incidents. This includes changing stakeholder, shifting allegiances,
business affiliations, and the impact and consequence of current or immediate events. A
capability essential for maintaining an early warning system and understanding the
consequences of any impact on the Client and its business operations, including how to manage
and mitigate those consequences. This is inclusive of a collection capability that can also monitor
and detect potential fraudulent practices by employees, contractors, subcontractors, and other
business affiliated entities.

c. Implement counter strategies, narratives, and programs to protect the Client’s Project. Senior
management needs to make timely decisions and maintain a capability that supports senior
management with legislatively compliant, workable solutions that are effective, efficient and
timely.

Client always conducts thorough Due Diligence investigations into contractors, subcontractors,
foundations and other organizations that may become associated with Client. There is also a need to
conduct thorough pre-employment background checks of these entities’ personnel. These processes
allow senior management the ability to immediately assess political affiliations, commercial associations
and potential legal and reputational issues related to these entities and individuals. The objective is to
protect the Client from engaging with any business entity/individual that is linked to graft, fraud, and
corruption or maintain a political affiliation that is a conflict of interest. The results of Due Diligence and
background investigations allow Client senior management the ability to formulate an appropriate
response.

Client utilizes an advisory and compliance monitoring capability through its Security and Risk
Management Department or appointed entity. The purpose is to support senior management with an
advisory and monitoring capability during tender processes, especially during construction projects

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involving the Regional Government. The capability will assist in ensuring that tenders for construction
projects are compliant to Indonesian legislation and international best practices minimizing instances of
corruption, fraud, poor performance, operational delays and financial and reputation damage suffered
by the Client.

Client establishes a proactive good governance and business ethics program to communicate Client
policy and compliance guidelines. This would also include and Ethics compliance and violation hotline
with a follow-up investigative capability. The program would focus on its employees, contractors and
other business affiliated entities and highlight the company’s business ethics policy, guidelines, and
company regulations.

Illegal Narcotics

Illegal narcotics trafficking in South Sulawesi presents significant law enforcement, social, health and security
issues. Narcotics are present in Luwu Regency. Levels of drug trafficking, drug use and affiliated crime will
increase once the Client commences its operation due to the presence of a sizeable, well-paid workforce
with large disposable incomes in a community where there is little money to spend. Suggested
recommendations are as follows:

Client immediately implements a Narcotics Prevention and Detection Plan and Policy, developed as
part of the SAMP. The aim and objectives are as follows:

d. The Client develops the capacity to adopt an effective regular random drug testing system to
conduct effective random drug testing among its workforce in Luwu Regency in compliance with
the Client’s Collective Labor Agreement and company policies.

e. The Client establishes and maintains close relationships with relevant government agencies
including the INP, BNN Anti-Narcotics Agency, Regional Health Agency and heads of the local
village administrations to share information and monitor any indication of drug trafficking and
drug use in the Client’s wider operating environment.

The Client also needs to liaise and coordinate with these relevant government agencies to interdict
drug trafficking and other affiliated criminal activity impacting its operations and the relationship
with the local community, including adverse community social and health issues.

Client uses its information collection capability to provide timely and accurate information enabling
senior management to make informed and timely decisions. The aim and objectives are as follows:

a. Maintain an ability to monitor and assess drug trafficking and other affiliated crime types to
develop and maintain an accurate and timely appreciation of the security environment and the
stakeholders involved in illicit criminal activities targeting the Client.

b. Maintain a capacity and capability for in-depth levels of understanding of the security
environment including changing developments, situations and incidents. This includes changing
stakeholders, shifting allegiances, business affiliations, and the impact and consequence of
current or immediate events. This capability is essential for maintaining an early warning system
and understanding the consequences of drug related and other affiliated criminal impact on the
Client and their business operations, including how to manage and mitigate those consequences.

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f. Implement counter strategies, narratives, and programs to protect the Client’s Project. Senior
management needs to make timely decisions and maintain a capability that supports legal
compliance and offers workable solutions that are effective and efficient.

Client maintains a professional competent Security management footprint as part of the SAMP that
sustains the Client’s operation.

Theft

Gold mines by their nature face high threat levels: risk gold theft or other high value items and material. The
Client must develop and maintain as part of the SAMP a robust security management footprint to prevent or
reduce potential theft at its facilities in Luwu Regency. Suggested recommendations are as follows:

Compartmentalizes the project area by implementing security-in-depth and crime prevention through
environmental design (CPTED) considerations that develop deter, detect and delay and develop a
response capability, (i.e., ensuring employees are only provided access to specific designated work
spaces and cannot enter other areas.

Conduct strict access control and bag searches during access and egress of employees and contractor
employees entering work or storage areas. Similar policies need to manage vendor and contractor
delivery and operation.

Same gender search and inspection procedures are used to conduct body and personal item checks and
body searches on suspicion of potential theft or access requirements.

Security officer rotations transferring security personnel regularly and randomly including in areas
where high value material is stored to reduce the risk of insider threat.

Conduct regular security audits, reviews, assessments, spot checks and supply stock item inventory at
irregular and random intervals.

Closely monitor fuel distribution and consumption, fuel transportation and other consumable item
usage (i.e., vehicle spare parts, tires, etc.).

Install overt and covert GPS monitoring devices. Only notify drivers of the overt GPS device in
applicable vehicles (i.e., fuel and supply trucks) to monitor routes and locations where vehicles stopped.

Install security ID recognition systems to ensure that only one specific driver can use a fuel truck to limit
potential fuel theft risk.

Conduct in-depth pre-employment background checks for employees and demand that all contractors
conduct the same before their workers are brought onsite, using Client-approved background check
vendors.

Regularly announce the Ethics Hotline so that employees are aware that they can anonymously and
safely report theft or indications of theft, graft, fraud and corruption without having to fear
repercussions from perpetrators.

Provide sufficient and effective security personnel to support the Clients SAMP including static and
mobile patrol requirements, access control, intrusion detection, rapid incident response, reporting and

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manning and supporting Command and Control Room functions (i.e., CCTV and intrusion detection
system monitoring, etc.).

Use fixed CCTV zoom-in areas of the facility with high net worth value material to prevent employee
manipulation of Pan Tilt Zoom (PTZ) cameras to aid theft.

Use separate guard forces for the Gold Room, man the Command and Control Center and general
security functions to prevent collusion between security personnel in the field, command and control
center and gold room.

Gold Room Recommendations are required for the high value area.

a. Policy and Procedures

i. Develop a separate and detailed Gold Room Security Management Plan, outlining policy and
procedures, security personnel requirements including Key Performance Indicator (KPI)
requirements, management systems, access control, gold doré transport procedures, CCTV
and electronic security requirements as well as safety measures.

ii. Develop separate procedures and KPI management systems for the security contractor
responsible for securing the gold room.

iii. Provide effective training to the gold room security personnel focused on knowledge of gold
room operations, understanding ‘tricks of the trade’ in attempt of stealing gold, how gold is
concealed and how to conduct a thorough search.

iv. Maintain at the minimum two guards in the gold room to ensure that at least one guard is
always present to observe the gold room operation (e.g., if one guard needs to step out for a
break etc.).

v. Conduct regular and unannounced inspections to ensure the gold doré collection procedure
is fully complied with by all personnel and contractor personnel involved. This includes
regular compliance checks and searching gold room operators, maintenance staff and
visitors.

b. Access Control

i. Install electronic interlocks on any doors leading into the gold room including pedestrian
access. The outer set of doors installed should provide interlocking capability to prevent
anyone rushing into the gold room or forcing their way in and preventing staff member from
being coerced to enter the gold room (e.g., a person following the staff member with a
weapon forcing them to enter the gold room gaining illegal access). The gold room facility
provides separation, and if forced, provides early warning of duress forced entry, initiating
rapid response.

ii. Adopt a security policy of Dual Access to minimize collusion.

iii. Use a remote control door opening system supported by communications and CCTV.

iv. Ensure vehicle entrance double door airlock system. The design should permit a reasonable
sized vehicle to enter the first set of doors while the second set remains closed and locked.

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Once the outside doors are locked, the inner doors could be opened to permit access to the
vehicle from inside the gold room while not exposing the operation to the outside.

v. The vehicle trap should be fully clad to prevent a visual into either the vehicle trap or gold
room. However, in this situation it is considered overriding importance that airflow through
the gold room should take precedence over security issues; and therefore, the vehicle trap
should be constructed using material such as Amplimesh.

vi. No other visiting vehicles or persons should be inside the Process Plant area during gold doré
collection. This is potentially the most vulnerable time when the full production of the gold
room is exposed outside of the gold room. All other mine staff should be kept well away
from the gold room entrance during gold doré collections.

vii. Security transport staff is searched first after the gold doré is collected. All other mine staff
should be kept inside the gold room until the transport vehicle has departed.

viii. The security personnel transporting the gold will receive Personal Protective Equipment
prior to entering the gold room. This PPE can be returned at the gold room, whilst the gold
doré armoured vehicle is escorted directly to the front entrance gate to proceed without the
need to stop at any time.

ix. Only selected gold room security personnel and no other personnel should keep safe and
hold all keys and control access and egress to all doors of the gold room.

x. Strict discipline in opening and locking doors to ensure only one door is open at any one
time must be instilled in all gold room security personnel.

xi. Ensure that CCTV covers all areas of the gold room including access and egress points and
that there are no blind spots.

xii. Ensure the gold room has proper walls and is fully closed off so that there are no holes
where gold doré can be handed through to a person outside of the gold room.

xiii. Ensure that pedestrian access and vehicle access are separate areas and are closed off from
each other by a proper wall.

xiv. Use electronically locked doors for the gold room. The existing card system should use full
functionality. The Client needs to decide which department is responsible for programming
cards with selected programming access protected by an effective password. This
department requires strict management supervision.

xv. Photos of card holders must be recorded on the access card system so card holder images
may be compared with the holder in person or by camera.

xvi. The emergency door is a particularly weak link in gold room. A metal lip should be welded
around the outside of the emergency door to butt against the frame. This would make it
difficult for the door to be breached. The lock would be obscured from the outside and gaps
would be covered to prevent gold from being passed through.

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xvii. Install an emergency push bar door as the emergency door to provide greater ease of egress
in an emergency. As part of the electronic security upgrade; alarms, concealed reed
switches and loud sirens are recommended for the door to activate upon opening.

Command and Control Centre needs to be manned by a separate entity than Gold Room security and
the rest of the facility. To minimize the threat of collusion the Client has two options. The first is to
develop an in-house command and control centre manning capability. The other option is to outsource
this requirement to a provider that can coordinate security responses. It is a consideration that the
provider is capable of training and mentoring Client in-house personnel from the security management
department that will eventually take over this function.

Terrorism, Extremism and Radicalism

By its nature the Clients’ operations in Luwu Regency are a national vital object and may present a target of
opportunity to a potential terrorist attack. However, in the current security context the likelihood of a
terrorist attack being mounted Luwu Regency is low. However, the potential exists for extremist elements
to infiltrate the workforce as well as attempts to radicalise employees. Suggested recommendations are as
follows:

The Client maintains a robust security management posture as part of the SAMP including
maintenance of concentric security-in-depth and CPTED security design considerations.

The Client ensures that SMP contractor personnel receive adequate training relevant to the threat of
terrorism, extremism and radicalization. This is to include but not be limited to receiving training in
Explosives Recognition, Vehicle Born Improvised Explosive Devices (VBIED), surveillance, counter-
surveillance and identification and detection of suspicious behavior, etc.

The Client’s Security Department maintains relationships with security agencies including
relationships with the South Sulawesi Police based on the MoU and with police to receive regular
updates on potential terrorist threats and risks impacting the operating environment. Similar
information sharing, coordination and liaison activities would maintain with TNI organizations
(commands and personnel).

The Client uses its information collection capability to provide timely and accurate information
enabling senior management to make informed and timely decisions.

Illegal Mining

Incidents of illegal mining support entrenched security and social issues in Sulawesi. However, there are no
current incidents of illegal mining occurring in Luwu Regency. Limited Community Mining is occurring in the
Bajo and Latimojong Districts. However, once the Client’s mining operations commence, it is likely that a
number of Illegal miners from other areas in Sulawesi will be attracted to the area, lured by the promise of
economic benefit.

According to the Client, illegal mining will likely be limited and sporadic considering the technical difficulties
in extracting gold in quantities large enough to make it viable. However, the threat of damage to the
environment and pollution by the limited numbers of illegal miners expected presents potential
environmental and reputational issues. Suggested recommendations are as follows:

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The Client uses its information collection capability to provide timely and accurate information on the
activities of illegal miners in their area and the wider community. The aim and objectives are as follows:

a. Monitor potential illegal mining groups travelling from other parts of Sulawesi to the wider area
of the mining project attempting to establish mining activities.

b. The Client develops and maintains its level of liaison and coordination with INP and TNI local
and regional organizations, commands, and personnel to share information on criminal issues
including the potential arrival of illegal mining groups in the area and to monitor access routes
into the Clients wider area of operations and incidents of illegal mining activity.

c. The Client’s Security Department maintains accurate and updated records using a
comprehensive security incident database to record incident levels, and security responses
initiated or required as follow-up action.

Social Issues

The Client understands its need to be accepted by the community as a fully integrated community member.
The community needs to understand that when the Client benefits, so does the community. Client
community support, including protection, is essential to the Client’s Security Action Management Plan. The
SAMP is reliant on the Clients’ ability to assist in managing community social issues. Potentially some of
those issues are the result of the negative impact generated by the Client and their contractor’s presence.
Recommendations are as follows:

The Client conducts regular and thorough induction training that includes local culture, community
values and potential sensitive local social issues that can escalate into significant security issues that
damage Client /community relationships.

The Client implements a selection and recruitment program that promotes employment opportunities
and develops a trainee or internship program. Local community members including the younger
generation can benefit from this Client employment initiative where the Client benefits from locally
sourced staff and maintains strong community relationships, developing trust and enhancing its image.

The Client implements a local procurement program using suitable local businesses to supply resources
and provide services that sustain its operations where applicable. This will create a mutual dependence,
strengthening local community relationships that promote local economies.

General Threats

There are a number of general threats that present varying risks that can impact the Client and its
operations. This includes but is not limited to natural disasters, infrastructure and health is highlighted as
follows:

Natural Disaster
Recommendations are as follows:

1. Develop transport and logistics contingency plans that are updated regularly.

2. Instruct contractors and sub-contractors to develop and coordinate their own plans.

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3. Develop and regularly update Emergency Evacuation Plans and coordinate these plans with
Contractors and sub-contractors.

4. Brief Client and contractor employees on identification of potential landslides and reporting
procedures.

5. Develop and maintain relationships with the regional branch of the Indonesian Agency for
Meteorology, Climatology and Geophysics (BMKG) and monitor their information closely.

6. Maintain close relationships with Basarnas Search and Rescue Agency to develop and coordinate
joint training and other cooperation opportunities.

7. Conduct regular emergency drills to train for and develop response capabilities to manage disasters
that include landslides, flooding, wild fires and earthquakes.

8. Maintain oversight and coordinate security manpower provider (SMP) contractor’s guard force in
fire response activities including the manning of Emergency Response Teams (ERTs) along with
other Client employees. This is to include fire response training and emergency drills.

9. Conduct a specific assessment of the natural disaster risks for the Client mine, Belopa and other
Client facilities, including emergency response planning and response capability of the regional
administration.

Infrastructure
Recommendations are as follows:

1. Closely monitor potential landslides that can obstruct portions of the Trans- Sulawesi Road and what
the impact of these blockages will be on client operations.

2. Where practicable, develop multiple alternative logistics routes that can be used if the main supply
route is blocked.

3. Develop detailed procedures on vehicle driving requirements reducing the risks of traffic accidents.
Brief Client and contractor drivers about All Driver Safety Client policy, procedure, and process.

4. Install speed monitoring devices on all Client and contractor vehicles.

Health
Recommendations are as follows:

1. Monitor health trends in the area and maintain a relationship with the Luwu Regional Health Agency
and local health clinics to collect data.

2. Assess capacity of regional hospitals and other medical facilities to provide emergency medical
support and general medical support.

3. Establish on-site medical support center and medical personnel including air evacuation capability to
support medical emergencies.

4. Conduct regular medical evacuation simulations.

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5. Demand that all contractor employees are subjected to medical check-ups before entering the
Client’s worksite.

6. Provide ad hoc medical support to local community members during an emergency as part of CSR
supporting the objective of integrating with the community.

7. Maintain general fitness, social sporting and lifestyle programs for employees to ensure they have
sufficient physical activity and social outlets to reduce fatigue and stress levels. Allow the same
opportunities and programs to be adopted by contractors.

8. Provide food catering that is nutritious supporting dietary health levels among Client and contractor
workers as applicable.

9. Promote health awareness, health risk indicators and health reporting procedures among all Client
and contractor employees to manage medical complaints or health issues.

PT Concord Consulting Indonesia

September 2020

Annex A: Stakeholder Mapping

Annex B: Overview of Registered Organisations in Luwu Regency

Annex C: Overview of South Sulawesi Security Incidents

Annex D: Overview of Registered Organizations in Luwu Regency

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ANNEX A

South Sulawesi

Governor Nurdin Abdullah

President Joko Widodo inaugurated former Bantaeng regent Nurdin Abdullah and
Andi Sudirman Sulaiman as the new governor and deputy governor of South
Sulawesi at the State Palace in Central Jakarta on September 5, 2019. They replaced
Syahrul Yasin Limpo and his deputy Agus Arifin Nu’mang. Abdullah and Sulaiman,
backed by the National Mandate Party (PAN), Prosperous Justice Party (PKS) and
Indonesian Democratic Party of Struggle (PDI-P), secured 1,867,303 votes or 43.87%
of the total during the June 27 simultaneous regional poll.

Abdullah was born on February 7, 1963 in Pare-Pare. Abdullah was the eldest of six
siblings. His father, Andi Abdullah, was a member of the Armed Forces (TNI).

Deputy Governor Andi Sudirman Sulaiman

Sulaiman attended junior high school in his hometown of Pare-Pare, before heading
to Makassar for his senior high school studies, graduating in 1986. He continued his
education at Hasanuddin University in Makassar, studying agriculture and forestry.
After obtaining his bachelor degree, he continued to Kyushu University in Japan,
earning his masters and doctorate in 1994.

He studied agricultural science in Kyushu University and returned home to run his
own business and teach before becoming the regent of Bantaeng for two terms.
During this period, the regency saw significant economic growth in addition to
improvement in the health sector.

Andi Sudirman Sulaiman was born on September 25, 1983 in Bone regency. He is the younger brother of
current Agriculture Minister Amran Sulaiman and is the 11th child of 12 siblings. His father was a member of
the Armed Forces and later became a farmer.

During his study at Hasanuddin University in Makasssar he had the opportunity to enrol in the Thiess
Undergraduate Scholarship Program. During college, he was also known as an activist and outstanding
student. After graduating, he started his career by working in several mining and oil companies, including PT
Thiess from 2005 to 2008, PT Petrosea Tbk from 2008 until 2009, PT Marine Engineering Services from 2009
until 2014 and PT Offshore Services Indonesia in a project with Conoco Philips from 2014 until 2017. He then
entered politics and became Deputy Governor in 2018.

Luwu Regency

On 27 July 2018 the Luwu Regional Election Commission announced that H. Basmin Mattayang and his
candidate for deputy regent Syukur Bijak had won the election with 117,230 votes against their component
Patahuddin and Emmy Tallesang who had received 76.206 votes.

Mattayang was supported by a wide coalition of parties consisting of the National Democrat Party (Nasdem),
Indonesian Democratic Party of Struggle (PDI-P), United Development Party (PPP), National Conscience Party
(Hanura), Indonesian Justice and Unity Party (PKPI), the Crsecent Star Party (PBB) and National Awakening
Party (PKB).

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Regent Basmin Mattayang

Basmin Mattayang was born in Wara on 12 December 1957. He has a vast level of
experience in Indonesian government agencies. He worked in the 1983 – 2003
period in the South Sulawesi Regional Government Staff, Education Agency. He was
Luwu Regency’s first Regent and served in the period 2004 – 2009.

In 1977 he was member of the Indonesian Islamic Student Association (HMI). In

1980 he was Coordinator of the Muhammadiyah Student Organization (IMM). He is
also the founder of The Yayasan, Mitra Bahari South Sulawesi Foundation. Mattayang was chairman of the
Luwu Regional Branch from 2004 to 2009. In that period he also held the position of Coordinator of the
South Sulawesi Regional Governments, Coordination Agency.

During his first tenure as Luwu regent, Mattayang, along with administration officials and dozens of
lawmakers were under police investigation in 2007 for their alleged involvement in misappropriation of IDR
1 billion in local budget. Mattayang maintained his innocence, arguing that the money he disbursed was
allocated from the previous administration. On February 5, 2009, the Makassar District Court acquitted
Mattayang, former Administration Secretary Baso Gani, and 27 lawmakers in the case.

After his first term as Regent, Mattayang became Deputy Dean of the PEPABRI University in Makassar. He
established two companies: PT Tasi Celebes Internasional where he is a Director and PT Ahkam Mega Putra
where he is a Commissioner. PT Tasi Celebes Internasional is involved in logistics, importation and export
and distribution. No information was identified on the activities of PT Ahkam Mega Putra.

Mattayang supported the political campaign for Luwu to become a separate province, although the Central
Government still maintains a moratorium on new provinces.

Mattayang is married to Hayarna Basmin Hakim. She was head of the Luwu Legislature from 2009 until 2014.
He has three sons and one daughter. His sons are Muhammad Arhan Basmin (eldest), Andi Muhammad
Ahkam Basmin and Arfan Basmin (youngest). They are all politically active. His daughter, named Andi Zullilat
Tazlilah Basmin intends to join the Luwu government as a local official but has yet to be appointed a
position.

Deputy Syukur Bijak

Syukur Bijak is the current Luwu Deputy Regent. He was born in Batusitanduk, on 28
November 1972, and has held the Deputy Regent position on two occasions, from 2009
to 2014 under Andy Mudzakkar and currently under Mattayang. Bijak was a legislator at
the Luwu Regional House of Representatives from 1999 unil 2009 when he became the
Deputy Regent under Regent Andy Mudzakkar.

Between 2005 and 2010, he was Development Department Head of the Indonesian
Association of Muslim Intellectuals (ICMI) Luwu.

Since 2006 he has served as Chairman of the Forum for the Formation of Central Luwu Regency. He has also
served since 2010 as Chairman of the Perbakin Fire Arms Association Luwu Branch and Chairman of the Anti-
Narcotics National Movement (Granat) Luwu.

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From 2011 until now he has been Chairman of the Democrat Party Luwu branch Luwu. In 2012 he became
the Chairman of the Democrat Party’s youth wing in Luwu Regency. Since 2012 he has been Chairman of the
Indonesian Mosque Board of Luwu Regency.

Information sources stated that Bijak was arrested over possession of sabu-sabu (crystal meth) earlier this
year. Allegedly, because of his political connections, he was released. In the area many local residents still
often associate him with drugs. His support base consists of local thugs that he mobilises and uses as his
political muscle. Access to this political muscle is likely one of the reasons that Mattayang selected him as his
running mate. Local sources stated that Bijak himself also has a background as a local enforcer and
strongman, which has provided him the network to mobilise local ‘preman’ or street thugs around him. He
has also been involved in violent altercations with political opponents.

During gubernatorial elections he once hurled a rock to damage the vehicle of supporters of then Governor
Syahrul Yasin Limpo and Agus Arifin Nu’mang. He reportedly had a contentious relationship with the former
Regent Andi Mudzakkar while serving as his Deputy Regent. On one occasion he crashed his vehicle against
former regent’s the vehicle. Bijak likely has his own political ambitions to run for Luwu Regent in the 2023
election.

Bijak has a son who is a member of the Indonesian House of Representatives in Jakarta. Muhammad Dhevy
Bijak represents the Democrat Party for South Sulawesi. Inquries have identified that Muhammad Dhevy
Bijak is a Commissioner of a tin mining company operating in Luwu Regency, PT Bintang Utama Abadi. The
company’s registered address is Desa Harapan, Kec. Walenrang, Kabupaten Luwu. Jl Poros Harapan Luwu
91951.

District and Village Leaders

It was identified that two Village Heads in the area harbour animosity against the Client. They also have the
capacity to conduct negative action against the Client. These two Village Heads in question are Bonelemo
Village Head, Baso Ubas Gandangsura and Lambanan Village Head, Burharuddin, SE.

Bonelemo Village Head (Kades), Baso Ubas Gandangsura

Baso Ubas Gandangsura was born in Bonelemo Village. He was appointed as Village
Head on 22 January 2020. He has a Bachelor of Law, from Hasanuddin University in
Makassar where he studied from 1993 until 1994. He was Chairman of the Islamic
Student Association HMI at Hasanuddin University. From 1986 until 1987, he was
Chairman of the Muhammadiyah Student Association IPM Bonelemo.

On 5 July 2020 he rejected workers from the Client to enter his village who were
conducting geographical mapping activities in Bonelemo Village. He said the reason was that they had not
coordinated their activities with the village administration.1

On 6 March 2020 Gandangsura facilitated a national meeting of the NGO AMAN in his village. More than 50
participants attended the meeting, which indicates closeness between Gandangsura and AMAN, which is an
NGO focused on customary rights of indigenous groups in Indonesia. He is an active member of AMAN.

From 2014 to 2019 he was a Legislator at the Luwu Regional House of Representatives. He then became
active in several national and international NGOs. Between 2004 and 2007 he was a Project Officer in an
NGO capacity-building project funded by the Japan International Cooperation Agency (JICA) and the National
Development Planning Agency (Bappenas). He was then involved in a project on Conflict Management on
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https://sulawesi24.com/2020/07/05/ini-alasan-kades-bonelemo-usir-karyawan-pt-mda-saat-mengukur-jalan/

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Natural Resources Exploitation, which was funded by the Center for People and Forests (an international
NGO), the UN Food and Agriculture Organization, the German aid agency GTZ2 and the Indonesian Forestry
Ministry.

In 2007 Gandangsura became involved in a project focused on Disaster Risk Assessment Program
Development and Finance Management, a British branch of human rights organization, Oxfam. Between
2009 and 2011, he was the Program Coordinator for the Forestry Social program funded by Indonesian NGOs
DID-KONSTAN LINGKAR and Telapak.

In 2011 Gandangsura became the Monitoring Coordinator for Forestry Management in Luwu Regency in
cooperation with the Independent Network of Forestry Supervisory Organization. In 2012 he became
Program Coordinator for the Water Supply Management program in Luwu, in cooperation with Indonesian
NGOs Swadaya Lingkar and Telapak. In 2013 he was a member of the Mediation Team for Conflict Resolution
between the Karunsi Customary Community and PT Vale.

He started his political career in 2014 when he became a legislator at the Luwu Regional House of
Representatives representing the Gerindra Party, which is the party chaired by current Defense Minister
Prabowo Subianto.

Lambanan Village Head (Kades), Burhanuddin, SE

Burhanuddin, SE has a Bachelor Degree in Economics. He claims to have a deep understanding about land
prices in his area. During field interviews with Burhanuddin, he has said that community members would be
foolish to even accept land prices of IDR 500,000 per square meter from the Client. Meanwhile, the price of
land in Belopa City has reached IDR 700,000 to IDR 1 Million per square meter. Burhanuddin explained that
the land price should be significantly higher in the mining area operated by Masmindo in comparison to the
land prices in Belopa due to the presence of gold. Burhanuddin said that he had mentioned this during a
meeting with Masmindo.

He added that in the past, he and Luwu former Regent Ir. H. Andi Muzakkar had brought a 30 centimeter
diameter, rock from the village to a geo testing facility in Bandung, West Java to analyze the rock content.
Allegedly, the rock contained gold and some diamond.

Burhanuddin said that when he joined the meeting with Masmindo in approximately June 2020, he debated
land prices. He explained that he did not agree with this price because it was clear that the land contained
gold which is more valuable. During the meeting he advised the other Village Heads to abstain from selling
the land for the price that was offered by the Cleint.

Burhanuddin said that he participated in the meeting was because he was convinced that his village would
be the next mining location, and he did not want land prices to be the same as the prices in the Desa Rante
Balla Village.

Latimojong District Head (Camat)

The Latimojong District Head is Supriadi, S.Pd. M.M. He was appointed on 22 October 2019.
In March 2020 he assisted villagers remove the rubble of a landslide from a main access
road into Latimojong District.

Supriadi is the head of the Latimojong branch of PP. He is also a former member of the
Latimojong Student Association (HIPMAL) and is also an affiliate of Nur Agam, the former
2
Gesellschaft für Technische Zusammenarbeit or German Technical Cooperation Agency.

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Village Head of Desa Ulu Salu.

Rante Balla Village Head (Kades), Irfan Marasing

Irfan Marasing is the Village Head of Rante Bella. He has been Village Head since at least 2018. In an article
on the environmental news website www.mongabay.com dated 23 June 2018, he raised concerns that the
mining project of the Client would have an environmental impact on the area and socio-economic impact on
the community. In the article he also questioned how local agriculture would be managed if everyone
worked at the mine.

Kadundung Village Head (Kades), Parambung Mahdika

Parambung Mahdika Latimojong is the head of Kadundung Village and is also a local
customary leader. He was elected to a second term on 18 September 2020 by the current
regent Basmin Mattayang.

Boneposi Village Head (Kades), Hamka

Hamka is the Village Head of Boneposi Village. He was appointed to this position on 28 December 2017 by
the previous Regent Andi Mudzakkar.

Local Community and Figures

Community Leaders

Besides the Village Heads of the various villages, the following community leaders are highlighted:

 Bp. Eli: Businessman involved in local coffee production and trade as well as the clove trade and corn.
 H. Kamal: Largest trader in coffee in Latimojong District and is the Village head of Tolajuk Village. He
has considerable influence through his business position and network among coffee farmers. He is
the father of Badar, a smaller local coffee trader who has a house in Bajo District. Kamal buys
approximately three tons of local coffee during each harvest season.
 Bp. Ponggi: Former Village Head of Rante Bella Village. He currently lives in Palopo, but still owns a lot
of land in the area.
 Bp. Pong Parenge Edi: Land owner who owns many plots of land in the area surrounding the mine
site. Many local community members don’t like him because he allegedly acted aggressively in
expanding his land ownership taking land from others.
 Sultan D. Somme: Village Head of Sampeang Village and has been critical of the Client.

Community leaders in Desa Rante Balla:

 Risno: Local businessman that sells insecticide to local farmers.

 Suparman Polubuntu: Former Village Head and a large landowner.
 Pak Lucas: Local Christian leader and teacher at a local elementary school

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 Pak Aziz: Local youth leader and member of Pancasila Youth

 Pak Hasan: Local Islamic religious leader

Community leaders in Desa Kadundung:

 Hasran: Religious leader and teacher.

Community leaders in Desa Boneposi:

 Mardi Mading: Former Village Head, current head of the Latimojong Health Clinic (Puskesmas
Latimojong) and also chairman of the Village Consultation Body (Badan Permusyawaratn Desa /BPD)
 Andar: Local youth leader
 Samperante: Largest coffee trader in Boneposi Village
 Safar: Coffee trader

Community leaders in Desa Tibusan:

 Sudirman: Village Head of Tibusan and coffee farmer

 Abas: Head of Tibusan Sub-district and farmer
 Talianes: Head of the local Religious Affairs Agency
 Jemi: Former legislative candidate for the Justice and Welfare Party (PKS). He is a businessman who
owns his own shop in Cilallang sub-district in Kamanre District.
 Ibrahim: Youth leader and also Chairman of the Karang Taruna youth organization

Community leaders in Desa Ulu Salu:

 Mujisat, Spd: Ulu Salu Village Head and former official of the Luwu Regional Lighting Department
 Nur Agam: Former Village Head, a former employee of the Client and now teacher. He is an expert
on Luwu history and culture, and therefore is a well-respected figure in the village. Agam is also a
former member of the Latimojong Student Association HIPMAL.3
 Lukman S: Staff member at the Local Religious Affairs Office and the village Islamic cleric (Imam).
 Anton Hasyim: Youth leader and chairman of the Karang Taruna youth organization.

Community leaders in Desa Buntu Sarek:

 Sabil, S.Ag: Village Head and farmer

 Sabri: Former Village Head. He is also a civil servant in Latimojong District and holds a lot of influence
in the village.
 Ancong: Local member of Pancasila Youth
 Murhadi S.Ag: Religious leader and civil servant at the local Religious Affairs Agency

Community leaders in Desa Tolajuk:

 Junaedi: Youth leader and farmer

3
Himpunan Mahasiswa Latimojong (HIPMAL)

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NGOs and Activists

Indonesia has an active and extensive network of national NGOs that are well-connected to international
NGOs while maintaining local grass-root level branches. Both Indonesian and international companies in the
energy sector can expect some scrutiny and monitoring by these organizations for environmental impact,
waste management and compliance to government regulations.

Many of the national, regional and local NGOs operating in Indonesia are affiliated to political individuals and
organizations amidst a political culture where graft and collusive practices are firmly entrenched. Often
these NGOs have underlying political agendas or financial interests to conduct a campaign or attack a
company.

Currently there are 44 community organizations registered with the Luwu Regency Government. The list
comprises of 28 national organizations, 9 regional organizations and 7 local organizations.

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management.

Registered local organizations in Luwu Regency that have high relevance to the mining issues are identified as follows:

Scope of
Organization Key Personnel Establishment Address Capability
Network
Pengurus Pusat Ikatan Chairman: Paisal 5 August 1958 Tirowali Local -  Raising issues related to mining operation by conducting student
Pelajar Mahasiswa Secretary: Ahmad Sub-District, Regional demonstrations in South Sulawesi
Indonesia Luwu (PP- Syawal Ponrang  Gaining attention from local and regional media in South Sulawesi
IPMIL) Treasurer: Annha District  Influencing other political mass organization such as Pemuda Pancasila,
Fabryan other political party youth wings; demanding meetings with regional
lawmakers
Forum Komunikasi Chairman: Ridwan 12 March 2014 Jl. Andi Local-  Raising issues related to mining operation by facilitating meetings between
Badan Mabbi Mukkulau Regional local community with local government officials
Permusyawaratan Secretary: Irham no.24,  Gaining attention from local and regional media in South Sulawesi
Desa (FK-BPD) As’ad Lamunre  Influencing opinions of the local community
Treasurer: Sub-District,  Conducting demonstrations in South Sulawesi
Sumarling Belopa  Demanding meetings with regional lawmakers
Utara
District
Asosiasi Penambang Chairman: Robby 19 September Kampung Local-  Consulting local community regarding mining issues
Rakyat Indonesia Tanduk Langi 2014 Baru, Bajo National  Influencing opinions of the local community
(APRI) Secretary: Hamsah Sub-District,  Gaining attention from local to national media
Hamid Bajo District  Influencing other national or international NGOs
Treasurer:  Demanding meetings with government officials in local, regional and
Burhanuddin national level
 Conducting demonstrations
Aliansi Masyarakat Chairman: Muslim 23 November Jl. Karaeng Local -  Consulting local community regarding mining issues; influencing opinions
Adat Nusantara Andi Yusuf 2015 Mate’ne no. National of the local community
(AMAN) Secretary: Asdar 1,  Gaining attention from local to national media
Azis Larompong  Influencing other national or international NGOs
Treasurer: Dharma Sub-District  Demanding meetings with government officials in local, regional and
Fidyasari national level
 Conducting demonstrations

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WALHI and JATAM, two national-based NGOs, have conducted numerous campaigns against mining
companies throughout Indonesia, including in Sulawesi.

WALHI
The Friends of the Earth Indonesia (Walhi) is an NGO working on a wide range of issues, including agrarian
conflict over peasants, coastal and marine and deforestation; access to natural resources; and indigenous
rights

Walhi has been proactive in its campaigns against companies operating in Sulawesi, including PT Newmont
Minahasa Raya Mining which faced an aggressive campaign by Walhi and the Regional Government in 2004
and 2005 in relation to its North Sulawesi mining operations.

Energy and Mineral Resources Minister Ignasius Jonan was sued by Walhi on 27 February 2018 over the
issuance of allegedly problematic mining permits in Central Sulawesi Province. The first lawsuit disputed a
Ministerial Decree, issued on 14 November 2017, which allowed a total of 85,180 hectares of land to be used
for gold mining activity in the regencies of Donggala and Parigi Moutong.

The concession in Central Sulawesi was given to PT Citra Palu Minerals (CPM), a subsidiary of the Bakrie
Group's PT Bumi Resources Minerals, the country's largest thermal coal miner.

Accoridng to Walhi, extending permits for mining activities would further damage the environment in the
affected areas. Activists feared that gold mining activities by PT CPM in Central Sulawesi Province would
spoil nearby rivers, the main sources of clean water for the provincial capital of Palu and neighboring areas.

Local groups accused PT CPM of contaminating the environment with mercury and cyanide in the Poboya
gold mining block in Poboya sub-district, Mantikulore district, Palu. Minister Jonan promised to investigate
the allegation.

JATAM
Mining Advocacy Network (JATAM) is a network of non-governmental organizations and community-based
organizations working on issues concerning human rights, gender, environment, indigenous people and
social justice regarding mining, oil, and gas industries.

JATAM4 and its affiliated organization Freedom Land Foundation (YTM) in May 2016 reported that only 2
(out of 79 companies holding mining permits (IUP) in 4 regencies in Central Sulawesi Province) conducted
reclamation programs of mined land. Jatam and YTM urged Central Sulawesi Governor Longki Djanggola to
issue a gubernatorial decree to regulate the reclamation of mined land.

Business Leaders

Many local business owners in Luwu Regency are former government officials or children of former
government officials, such as retired TNI or Police generals and other government officials. Due to their
previous career or network through their family members, they have strong political access to regional
governments and other agencies or are directly active in politics themselves. They will actively use this
political influence to respond to any economic threat coming from another business entity or competitor. In
many cases this will result in an active political campaign against the respective business competitor.

4
Jaringan Advokasi Tambang or Mining Advocacy Network.

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An example in Palopo is the young business woman Putri Dakka who has developed four companies. Putri
Dakka has a large fuel cargo company operating several large vessels to transport fuel. She is the daughter of
a former head of the Indonesian Police Counter Terrorism Unit, Detachment 88.

In the wider Luwu area powerful business figures are generally located in Palopo. However, there are no
large business groups such as Haji Kalla or the Bosowa Group that are based in Makassar.

Regional business owners in South Sulawesi Province have not yet massively invested in Luwu Regency nor
have a strong interest in the area. The Luwu Regency Chamber of Commerce is relatively inactive and not
influential, due to a lack of interest from the business community. In 2019 it was said that Luwu Kadin
branch was practically extinct, however the organization became more active in 2020.

Kalla Group
The Kalla Group comprises the Jusuf Kalla’s family, and his extended family of his brother-in-law Mahmud
Aksa and his son Erwin Aksa. Kalla owns the Haj Kalla group that owns many businesses in cement, nickel
mining, car dealerships and property. Aksa controls the Bosowa Group which has many businesses including
property, hotels, energy and media.

Both Haji Kalla and Bosowa Group are present in Palopo, including car dealer showrooms. In Luwu Regency,
the Kalla Group has developed a mining smelter facility in Bua District through its subsidiary PT Bumi Mineral
Sulawesi (BMS). Construction of the smelter was completed in 2019.

PT BMS has faced many issues and challenges during its operation in Luwu Regency. This included local
groups making the following allegations against PT BMS:

 Licensing discrepancies
 Building in protected forest areas
 Violating the AMDAL environmental survey
 Lack of employment opportunities for the local workforce
 Lack of transparency in land compensation payments

On 25 November protesters from two villages named Bukit Harapan and Karang-Karangan held a
demonstration in front of the Luwu House of Representatives in Belopa demanding PT BMS to cease
operations5.

Sampoerna Group
Besides the Kalla Group, another business conglomerate active in Luwu Regency is the Sampoerna Group
through its subsidiary PT. Sumber Graha Sejahtera (SGS). The subsidiary now operates under the brandname
Sampoerna Kayoe. The company focuses on the production of plywood and has a factory in Luwu Regency
near Palopo.

PT SGS is the largest plywood producer in South Sulawesi Province. The company exports to forty different
countries and has developed significant plywood market shares in Southeast Asia, Japan, South Korea and
the United States.

The company has four factories in Java: Balaraja, Salatiga, Purwokerto and Jombang as well as a factory in
Jambi and the factory in Palopo.

5
https://makassar.sindonews.com/berita/35150/4/warga-dua-desa-ancam-tutup-pt-bumi-mineral-sulawesi

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Religious Leaders
The following religious leaders play a prominent role in Luwu Regency:

 KH Muhammad Idris: Islamic Scholars Council (MUI) Luwu branch Chairman. He is also the chairman
of the Luwu inter-faith forum (FKUB) which is an important platform for leaders of different religions
to gather and discuss inter-faith relations in the area.

 Drs. Abd. Samad: Nadhlatul Ulama Luwu Chairman. NU is a Moderate-islamic based organization and
is the largest Muslim organization in Indonesia. Former President Abdurrahman Wahid was a leader
of NU. The organization is originally based in Central Java.

 H.M. Rusydi Hasyim: GP Ansor Luwu Chairman. GP Ansor is a mass organization affiliated to NU. The
organization has a tense relationship with hard-line Muslim organizations.

 Yamin Kibe: Muhammadiyah Luwu Branch Chairman. Muhammadiyah is the second largest Muslim
organization in Indonesia. The organization was founded in Java. It has many organizations and a
strong support base in South Sulawesi.

 Muh. Ashar Sabry, SH I: Mosque Youth Communication Forum Indonesia (BKPRMI) Luwu Chairman.

 Muchlisin, S.Sos: Indonesian Islam Propagation Institute (LDII) Luwu Chairman. LDII is a conservative
Muslim organization that has close links with hard-line organizations such as the Islamic Defenders
Front FPI. Many LDII members also become active in the conservative Islamic Justice and Welfare
Party (PKS).

 Sultan, D. Somme: Muslim Brotherhood (PARMUSI) Luwu Chairman. PARMUSI is a well-established

and old Muslim organization that is politically connected to the United Development Party (PPP),
and the Islamic Student Association (HMI). Somme is the Village Head of Sampeang Village.

 Ezra Arung: Bethel Tabernakel Alfa Omega Church, Imanuel Setiarejo Congregation Chairman. This
is one of the largest church congregations in Luwu Regency.

 Agustinus Payung, S. Th.: Bethel Tabernakel Alfa Omega Church, To’lemo Congregation Chairman
This is the same church, but with To’lemo as the congregation location.

 Johannes Liku Ada: Archbishop of the Catholic Church in Luwu since 11 Nov. 1994. The church is
within the scope of the Archdiocese of Makassar

 Henry Sumitomo: Chairman of the Council of Buddhist Communities (Walubi) of South Sulawesi.

Youth Leaders and Organizations

Pancasila Youth

Pancasila Youth has an influential and well-established position within Luwu Regency. This is a nationalist
organization with branches all through Indonesia and a close affiliation with the Golkar Party. In South
Sulawesi Province they remain politically influential due to the support of former Vice President Jusuf Kalla
and the Golkar Party that also remains powerful in South Sulawesi.

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Many PP members and at least one PP leader reside in Latimojong District. The PP regional leadership will
use them for information collection on the Client’s activities and to conduct detrimental actions against the
Client, including road blocks and protest demonstrations in Belopa if required.

Other social groups in Belopa don’t like to work with Pancasila Youth because this organization is using its
social activities for financial gain. It is highly likely that PP will use its political and social influence to try and
win contracts from MDA and its contractors. If the Luwu PP leadership fails to win contracts and/or have
immediate benefit from the MDA start of operations. This will be a critical loss of face for the organization,
especially considering that the chairman and previous chairman are the sons of the current regent. It can be
expected that PP will initiate and undertake various adverse campaigns against the Client in this situation.
This will include political coercion through affiliation with the regent, protests, personal intimidation and
campaigns to stir up local sentiment against the company.

Indonesian National Youth Committee (KNPI)

KNPI is a national organization that prepares local young leaders for a political future in the regional,
provincial and national government. Many current government officials have a background in KNPI. In Luwu
Regency as well as in many other places, KNPI is led by children of regional officials.

In South Sulawesi Province, KNPI is led by Basmin Mattayang’s son, Arham Basmin Mattayang. He was
appointed on 7 March 2020 until 2022. The organization has a close affiliation with Pancasila Youth and the
Golkar Party.

The organization has been internally divided in South Sulawesi Province due to a conflict in leadership that
emerged in 2019. This has also impacted the Luwu branch of KNPI.

Muhammadiyah Youth

The moderate Islamic-based organization, Muhammadiyah has a presence in Luwu Regency. This
organization has a youth wing named Pemuda Muhammadiyah.

On 22 August 2020 the organization appointed Zulkifli the new chairman of the Luwu branch of
Muhammadiyah Youth. Many prominent politicians were present at the inauguration, including national
legislator Muhammad Dhevy Bihak (son of Deputy Regent Syukur Bijak) as well as Arham Basmin Mattayang
(the son of Luwu Regent Basmin Mattayang and chairman of the Indonesian National Youth Committee’s
Luwu branch).

Zulkifli is a local politician who is also deputy chairman of the Luwu Legislature representing the Golkar
Party. Amin Abdullah is the Deputy Chairman of the Muhammadiyah Youth branch in Luwu Regency.

Luwu Student Youth Bond (IPMAL)

This organization is based in Palopo and focuses on students that are from Luwu Regency and that study in
Palopo. The association has its own boarding house on Jalan Imam Bonjol in Palopo, its headquarters are
located on. Jl. Andi Pangerang No.mor 25, Pattene in Palopo.

On 24 January 2020 IPMAL held a gathering for students in Ponrang District during which the KNPI South
Sulawesi chairman and Luwu Regent’s son Andi Muhammad Arham Basmin was the guest of honor.

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Latimojong Students Association (HIPMAL)

This organization focuses on students that originate from Latimojong District, and has close relations with
universities in Palopo. HIPMAL Head of Science and Recruitment, Imran Lewa is also the deputy head of the
Student Executive Board of the Indonesian Islamic State University (IAIN) Syariah Faculty in Palopo. The
association has many prominent alumni including Luwu Regent’s son, Arham Basmin Mattayang.

HIPMAL conducts many social and charity activities. In recent times the organization has been involved with
construction plans for a modern Islamic boarding school or Pesantren named Al Mubarak Ratelajan.

The organization has a good relationship with the Latimojong District Head, Supriyadi.

Media

The following media in Luwu Regency has been identified:

Websites/Printed Media
 http://newstabloidsar.com: owned by Rachmat K. Foxchy alias ‘Bang Ories’ a well-connected activist
that conducts aggressive campaigns against local officials
 Tribun Timur: a large regional newspaper based in Makassar with a network of local correspondents
spread throughout Sulawesi.
 Palopo Pos: a regional newspaper that provides political insight and conducts crime reporting.
 Fajar: a popular news website and daily newspaper based in Makassar. Fajar is part of the Jawa Pos
group and focuses on both national and regional news.

Television
 Pemda Luwu Channel; This is a television channel owned by the Regional Government and is used by
the current Regent to broadcast his speeches and visits to villages as well as provide explanation on
regional programs.

Government Agencies

Government Agencies that have direct authority over mining operations include:

1. Luwu Public Works (Dinas Kimpraswil)

This position is currently not filled. However the former head Ridwan Tumbalolo remains influencial.
He was appointed to Luwu Regional Secretary on 1 August 2020. This is an influential position within
the Regional Administration. It is likely that Regent Mattayang will appoint a loyalist to this position
due to its importance in regional development and business.

2. Environment and Hygiene Agency (Dinas Lingkungan Hidup dan Kebersihan)

On 15 April 2020 Regent Mattayang appointed Andi Pangerang as Head of the Regional Environment
and Hygiene Agency after he was previously Head of the Regional Agricultural Agency. In his previous
position Pangerang received criticism by farmers in Luwu that his agricultural aid programs were not
effective.

3. Capital Investment and One-Stop Integrated Service Agency

Regent Mattayang has not appointed a current head to this agency, and is believed to have
maintained a level of direct influence in managing this agency. H Mustafa Rahima is the current acting
head.

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4. Luwu Manpower Agency

On 15 February 2019 Regent Mattayang appointed Ir. H. Saiful Abdul Latief as the new Head of the
Luwu Regional Manpower Agency. His previous position was Administrative Head of the
Development and Procurement Service department within the Luwu Regency Secretariate.

5. Luwu Regional Trade and Industry Agency

On 30 December 2019 Mattayang appointed Drs. Husain Parewoi as Head of the Regional Trade and
Industry Agency, following his previous position as Secretary of the Regional Office for Women and
Children Empowerment.

6. Luwu Regional Transport Agency

Regent Mattayang has not appointed a current head to this agency, and is believed to have
maintained a level of direct influence in managing this agency. Supriadi is the current acting head.
This is a different person than Supriyadi who is the Latimojong District Head.

Police Units and Chiefs

South Sulawesi Police Chief (Kapolda)

National Police Chief, Gen. Idham Aziz on 3 August 2020 issued a decree
appointing Insp. Gen. (Pol.) Merdisyam, as the Commander of South Sulawesi
Regional Police. Merdisyam was born in Jakarta on 4 May 1968. He graduated
from the Police Academy in 1991.

Merdisyam began his career in West Java Province. He served as the junior
officer of Sukabumi Resort Police in West Java in 1992. In 1993, he became the
Operations Division Head of the Investigation Unit, Sukabumi Resort Police.

He was later appointed as the Deputy Chief of the Police Investigations Unit, Sukabumi Resort Police in 1994,
a position he held for two years. He was appointed as the Head of Cisaat Sectoral Police, Sukabumi Resort
Police in 1996. In 1997, Merdisyam was transferred to the National Police Academy in Semarang, Central
Java where he served as a police cadet, Platoon Commander. In 1998, he was appointed as a police cadet,
Company Commander. That same year, he went to the National University of Police Science, South Jakarta
to further his police education.

He became a member of the Metro Jaya Regional Police in Jakarta in 2001. Merdisyam served in several
positions in Jakarta between 2001 and 2007. In 2007 he became Head of the Intelligence and Security
Directorate, Metro Jaya Regional Police. In 2009, he entered the National Police, Middle Rank Officer,
Leadership School. On completing his education at the school in 2009, he became the Operational Head,
Cirebon Region, West Java Regional Police.

From 2009 to 2015, Merdisyam served in various police leadership positions in West Java, Jakarta, and
Gorontalo. In 2015, he was appointed Economic Policy Analyst, Intelligence and Security Agency, of the
Indonesian National Police Headquarters based in Jakarta.

After three years in this position, he became the Director of Social & Culture of the Intelligence and Security
Agency of the Indonesian National Police Headquarters in 2018. In 2019, he was promoted to Southeast
Sulawesi Regional Police Chief.

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National and regional media reported in March 2020 that amidst the COVID-19 pandemic Merdisyam
allowed 49 Chinese foreign workers to enter the province and work in a nickel smelter factory operated by
PT Virtue Dragon Nickel Industry (VDNI) in Morosi, Konawe Regency. Merdisyam was forced to make a public
apology over the mistake. Despite this mistake, he was appointed as the South Sulawesi Regional Police
Chief on 3 August 2020.

Merdisyam is married to Libriani Dwi Arsanti. Together, they have three children: Ariq T. Arsyam, Rifqi F.
Arsyam, and Dandy F. Arsyam.

Polda South Sulawesi is an A-level Polda based on the geographic area that it needs to cover and the large
number of Polres stations. Police commanders need to be ranked Inspector-General (two star) at the
minimum to lead an A-level Polda command. The South Sulawesi Police structure consists of the following
Police Resorts:

No Police Resort Police Chief/Kapolres

1 Polrestabes Makassar Kombes. Pol. Yudhiawan Wibisono, S.I.K., M.Si.
2 Polres Pelabuhan Makassar AKBP Muhammad Kadarislam Kasim
3 Polres Maros AKBP Musa Hengky Pandapotan Tampubolon
4 Polres Pangkajene dan Kepulauan AKBP Ibrahim Aji S.I.K
5 Polres Gowa AKBP Boy FS Samola
6 Polres Takalar AKBP Beny Murjayanto
7 Polres Jeneponto AKBP Kesit Dwijayanto
8 Polres Bantaeng AKBP Wawan Sumantri
9 Polres Bulukumba AKBP Gany Alamsyah
10 Polres Kepulauan Selayar AKBP Temmangnganro Machmud S.IK. MH.
11 Polres Bone AKBP I Made Ary Pradana
12 Polres Soppeng AKBP Puji Saputro Bowo Leksono
13 Polres Wajo AKBP Dedy Dewantho,
14 Polres Sinjai AKBP Iwan Irmawan, S.IK, M.Si.
15 Polres Parepare AKBP Budi Susanto
16 Polres Barru AKBP Welly Abdillah
17 Polres Pinrang AKBP Dwi Santoso
18 Polres Sidenreng Rappang (Sidrap) AKBP Leonardo Panji Wahyudi
19 Polres Enrekang AKBP Endon Nurcahyo, S.Ik
20 Polres Tana Toraja AKBP Gregorius Liliek Tribhawono Iryanto
21 Polres Toraja Utara AKBP Yudha Wirajati Kusuma SIK. MH
22 Polres Luwu AKBP Fajar Dani Susanto
23 Polres Luwu Utara AKBP Agung Danargito
24 Polres Luwu Timur AKBP Indratmoko
25 Polres Palopo AKBP Alfian Nurnas

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Luwu Resort Police Chief (Kapolres)

The Luwu Resort Police Chief is Adj. Sr. Comm Fajar Dani Susanto.

He was appointed as new chief of the Luwu Police based on a directive issued by the
National Police on 3 February2020.

Susanto replaced Adj. Sr. Comm. Dwi Santoso, who was assigned as the Pinrang
Police chief.

Susanto was born in Semarang, Central Java on 16 November1977. He graduated from the Police Academy
in 2000 and spent the first nine years of his career in West Kalimantan, where received his master’s degree
in law in 2014. Susanto is married to Ayu Fajar Dani. They have four children, named Bintang, Gilang, Bumi
and Jagat.

After his appointment as Luwu Police chief, Susanto created a YouTube channel where he publishes video
logs (vlogs) as police chief, such as leading rolling calls and inspections, visiting remote areas in Luwu, and
training his wife, Ayu Fajar Dani, to use a firearm. He is very active on social media, which can potentially
have an impact on the Client during a security incident.

Susanto is currently the head of the coronavirus taskforce in Luwu and is in charge of the daily operations of
the unit. On 29 February 2020, Susanto visited the Client’s project site. Susanto held discussion with Eben
Ezer Sirait, the mine's risk management official, and observed security arrangements in the area.

No Police Sector Police Sector Chief (Kapolsek)

1 Polsek Ponrang Iptu. Sadsali Kareba
2 Polsek Bua Iptu. Hasdin S.Sos.MH
3 Polsek Bupon Ipda. Firman Akbar
4 Polsek Telluwanua Iptu. Idris SH
5 Polsek Pitumpanua AKP. Jasman Parudik
6 Polsek Wara Utara Iptu. Patobun S. Pd
7 Polsek Wara Selatan Iptu. Marthen
8 Polsek Bajo Luwu Iptu. Py Catur Suhendra
9 Polsek Suli Iptu. Ralim
10 Polsek Belopa AKP. Ahmad S.Sos
11 Polsek Walenrang AKP. Samuji
12 Polsek Larompong Iptu. Syarief Sikati SH
13 Polsek Bastem AKP. Syamsuddin
14 Polsek Lamasi Iptu. Idul

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Bastem Sector Police Chief (Kapolsek)

The Bastem Police Chief is Adj. Comm. Syamsuddin. He has been commander since
2017.

Syamsuddin has experience in community relations, mediating during road blockades,

and natural disaster emergency response such as response actions to major landslides
in the area. He is familiar with the rough terrain of the Bastem-area including
Latimojong district.

Luwu Regional Attorney General

Erny Veronika Maramba was appointed as Head of Luwu Attorney General’s Office in
October 2019. Previously she was Head of the Administration Department at the
Jakarta Attorney General’s Office since 2018. During her previous positions, she
investigated various corruption cases committed by government officials.

In 2014 Maramba sought a 12-year jail sentence and IDR 5 Billion in fines for
Hendrianus Langen Projo, a high-ranking official from the Indonesian Customs Office
located on the Indonesian–Malaysian border in Entikong, West Kalimantan Province for collusion to smuggle
imported goods from China. On 10 November 2014 the Jakarta Special Corruption Court sentenced Projo to
eight years in jail for receiving bribes related to smuggling activities.

On 8 January 2015, she was included among 100 state attorneys selected as a member of the Special
Taskforce for Countermeasure Acts and Disposal of Corruption Cases (P3TPK), a team formed by the
Attorney General’s Office as an effort to strengthen the presence of the state in eradication of corruption.

In 2017 Maramba represented the Attorney General’s Office in seeking a two year jail sentence for Achmad
Fauzi, an investigator from the East Java Attorney General’s Office who was on trial for demanding illegal
payments amounting to IDR 1.5 billion. On 20 February 2017 the Surabaya Special Corruption Court
sentenced Achmad Fauzi to two years for receiving bribes.

Maramba comes from Tana Toraja Regency in South Sulawesi Province. She obtained a Master’s Degree in
law from the Diponegoro University in Semarang, Central Java Province.

Military Units and Commanders

Luwu Regency comes under the Hasanuddin Regional Military Command XIV (Kodam XIV/Hasanuddin),
following the reinstatement of this command by the Army. Prior to the reinstatement, Kolaka Regency
operated as part of Wirabuana Regional Military Command VII (Kodam VII/Wirabuana).

Army Chief of Staff Gen. Mulyono on 12 April 2018 officiated the re-instatement of Kodam XIV, replacing
Kodam VII, which was dismantled following the re-instatement of the Merdeka command (Kodam XIII)
covering North and Central Sulawesi as well as Gorontalo.

Kodam XIV/Hasanuddin, headquartered in Makassar, South Sulawesi, is responsible for military activities in
West Sulawesi, South Sulawesi and South East Sulawesi. Previously, Kodam Wirabuana oversaw military
activity in all of Sulawesi.

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Hasanuddin Regional Military Commander (Pangdam)

The XIV/Hasanuddin Regional Military Commander is Maj. Gen. Andi Sumangerukka,

who was inaugurated on 09 January 2020 replacing Maj. Gen. Surawahadi. Born in
Makassar, South Sulawesi on 11 March 1963, Sumangerukka graduated from the
Military Academy (Akmil) in 1987. He was one of the classmates of Army Chief of Staff
Gen. Andika Perkasa. Sumangerukka’s father was the late Maj. Syam Daud, who was
among the first Kendari Regional House of Representative (DPRD) members in 1970.

Prior to his current appointment, he served as Expert Staff for Ideology and Politics at
the National Intelligence Agency (BIN) in 2019. He served as the South East Sulawesi Regional Intelligence
Chief Kabinda from 2015-2019. He was the Inspector General at V/Brawijaya Regional Military Command
from 2013 to 2015 and 143/Halu Oleo Resort Military Commander from 2012 to 2013.

He was lauded for his involvement in the settlement of the Papuan student conflict in Makassar and student
shooting in Kendari in 2019. The Hasanuddin Regional Military Command coordinates the following Resort
Military Commands (Korem):

Korem 141/Toddopuli Commanded by Col. Suwarno

Toddopuli Military Resort Command

(Korem 141/Toddopuli) in Bone, Gowa,
Bantaeng, Bulukumba, Selayar, Maros,
Jeneponto, Takalar regencies in South
Sulawesi. Units under Korem
141/Toddopuli are highlighted in the
diagram to the right.

Korem 142/Taroada Tarogau commanded by Col. Eventius Teddy Danarto

Taroada Tarogau Military Resort

Command (Korem 142/Taroada
Tarogau) is located in Parepare, Barru,
Soppeng and Wajo regencies in South
Sulawesi. Units under Korem
142/Taroada Tarogau are highlighted in
the diagrame to the right.

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Korem 143/Halu Oleo commanded by Col. Yustinus Nono Yulianto

Halu Oleo Military Resort Command

(Korem 143/Halu Oleo) in Southeast
Sulawesi. Units under Korem
143/Halu Oleo are highlighted in the
diagram to the right.

KODIM Makassar commanded by Col. Andriyanto

Kodim 1408/BS (Berdiri Sendiri) Makassar (1408/Independent Makassar) is a separate District Command
covering Makassar.

Taroada Tarogau Resort Resort Military Commander (Danrem)

Firman Dahlan is the commander of the Taroada Tarogau Resort Military

Command (Korem 142) in Mamuju, West Sulawesi Province since 24 April
2020. Korem 142 operates under the Hasanuddin Regional Military Command
(Kodam XIV), which oversees military operations in West Sulawesi, South
Sulawesi and Southeast Sulawesi.

Firman Dahlan was born in Wajo regency, South Sulawesi on 24 October 1964.
His father was a school teacher and his family members have no known
military ties.

After graduating from high school, he was accepted into South Sulawesi’s Hasanuddin University Faculty of
Engineering in Makassar, but he left to enroll in the Military Academy. He graduated in 1988 with the rank of
2nd lieutenant, specializing as a combat engineer.

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Firman Dahlan was first assigned as a member of the Army’s 4th Combat Engineer Battalion (Yon Zipur 4) at
the Diponegoro Regional Military Command (Kodam IV). Kodam IV oversees military operations in Central
Java and Yogyakarta.

He served as chief of the Army’s Wirabuana Engineer Corps (Zeni VII) in Makassar from 2012 until 2013. The
Zeni Corps is involved in a wide range of disaster relief and public works projects within the country, as well
as in combat support operations.

He then served as an inspector at the Iskandar Muda Regional Military Command (Kodam IM) from 2018
until 2020. (Kodam IM oversees military operations in Aceh.) Dahlan has participated in military
deployments to Timor Leste in 1990 and 1994 and in deployments against separatists in Aceh in 2003 and
2005. He has also taken part in the Army’s humanitarian missions to New Zealand, Singapore and Myanmar.

Korem 142/ Taroada Tarogau coordinates the following District Military Commands (Kodim):

No District Military Commands District Military Commander (Dandim)

1 Kodim 1401/ Majene Letkol Inf. Yudi Rombe ST.,M.Si
2 Kodim 1402/ Polmas Letkol Arh. Hari Purnomo S.Hub.Int., M. Han
3 Kodim 1403/ Palopo Letkol Inf. Gunawan
4 Kodim 1404/ Pinrang Letkol Inf. M. Wahyudi Amry
5 Kodim 1405/ Pare-pare Letkol Kav. Ali Syahputra Siregar
6 Kodim 1414/ Tana Toraja Letkol Czi. Zaenal Arifin
7 Kodim 1418/ Mamuju Letkol Inf. Tri Aji Sartono
8 Kodim 1419/ Enrekang Letkol Inf. Utju Samsul Komar
9 Kodim 1420/ Sidrap Letkol Inf. Jarmot Parluhutan Situmorang
10 Kodim 1421/ Pangkep Letkol Inf. Adi Sabaruddin
11 Kodim 1427/ Pasangkayu Letkol Inf. Kadir Tangdiesak
12 Kodim 1401/ Majene Letkol Inf. Yudi Rombe ST.,M.Si
13 Kodim 1402/ Polmas Letkol Arh. Hari Purnomo S.Hub.Int., M. Han
14 Kodim 1403/ Palopo Letkol Inf. Gunawan

Sawerigading District Military Commander (Dandim)

Lieutenant Colonel, Gunawan is the commander of the the Sawerigading District

Military Command (Kodim 1403) in Palopo, South Sulawesi since 19 August 2019.

Kodim 1403 falls under the jurisdiction of the Toddipuli Resort Military Command
(Korem 141) which is overseen by the Hasanuddin Regional Military Command

(Kodam XIV). Kodam XIV is in charge of military operations in West Sulawesi, South
Sulawesi and Southeast Sulawesi.

Gunawan served as a cadet battalion commander at the Military Academy AKMIL before being appointed
commander to Kodim 1403. Gunawan and the Kodim played an active role in aiding victims of the North
Luwu floods that occurred in July 2020.

20
 BUSINESS-IN-CONFIDENCE
The sources of information for this document may have been derived from sensitive and/or confidential sources. The recipient of this document is to ensure its limited distribution on a
business basis only. No third party dissemination without written approval of management.

Kodim 1403 commands the following Military Rayon Commands or Koramil:

No Sub-District Military Commands Sub-District Military Commander (Danramil)

1 Koramil 1403-01/ Larompong Kapten Inf. Semual Lawa
2 Koramil 1403-02/ Suli Kapten Czi. Syarifuddin
3 Koramil 1403-03/ Belopa Kapten Cba. Marten Luter
4 Koramil 1403-04/ Padangsappa Kapten Inf. Arsid
5 Koramil 1403-05/ Bastem Kapten Kav. Mursalim
6 Koramil 1403-06/ Wara Kapten Inf. Alex Makale
7 Koramil 1403-07/ Walenrang Kapten Inf. Takdir
8 Koramil 1403-08/ Limbong Kapten Inf. Marjaman
9 Koramil 1403-09/ Sabbang Kapten Yesaskar Garay
10 Koramil 1403-10/ Malangke Kapten Inf. Amir Sahabu
11 Koramil 1403-11/ Masamba Kapten Czi. Waskito
12 Koramil 1403-12/ Bone-Bone Kapten Inf. Yonatan Tandesak
13 Koramil 1403-13/ Wotu Lettu Inf. Rustam
14 Koramil 1403-14/ Mangkutana Kapten Kav. Mujahid
15 Koramil 1403-15/ Malili Kapten Inf.Takdir P
16 Koramil 1403-16/ Nuha Kapten Inf. Dahlan

Air Force

Air Force Operational Command II (Koopsau II) is the Air Force operational command
covering the Eastern area of Indonesia: Sulawesi, East Kalimantan, part of Central
Kalimantan, South Kalimantan, East Java, Gorontalo, Bali, Nusa Tenggara, Maluku,
part of Central Java and Papua. Its headquarters is located in Makassar. A third
command, Koopsau III, was added on 11 May 2018 based at Biak, Papua.

First Marshal, Donny Ermawan Taufanto was inaugurated as the new Koops AU II
commander on 10 October 2018. He replaced First Marshal Henri Alfiandi, who was
appointed as the new Air Force Staff and Command School (Seskoau) Chief.

Taufanto was born in Solo, Central Java on 12 December 1965. He graduated as the best graduate from the
Military Academy in 1988. He served as Iswahyudi Air Base Commander between 2014 and 2015. He was
then assigned as Chief of Staff, Koops AU II between 2015 and 2017. He was the Deputy Chief of the Armed
Forces' (TNI) Strategic Intelligence Agency (BAIS) until 2018. He was appointed as Special Staff to Air Force
Chief of staff, Air Marshal Yuyu Sutisna, his last posting before becoming Commander of Koops AU II.

The Air Force is planning to establish two more squadrons at the Sultan Hasanuddin base in Makassar,
sources stated in May 2018. Air Force Chief, Air Marshal Yuyu Sutisna said the squadrons planned to be
operational in 2019 and would consist of 33 cargo aircraft and nine helicopters. He said the additional
squadrons were expected to improve interoperability between all military branches in the Eastern Region.

The Air Force's National Air Defense Sector Command (Kosekhanudnas) IV in Biak, Papua and state aviation
navigation operator AirNav Indonesia’s Air Traffic Service Center’s Makassar office (MATSC) in South
Sulawesi signed a memorandum of understanding (MoU) on 30 April 2018 to strengthen air space security in
Eastern Regions.

Kosekhanudnas IV covers Papua, West Papua, Maluku, North Maluku and East Nusa Tenggara. The MoU
stipulates cooperation on aviation safety system management focusing on information exchanges and
enforcement against air space and flight violations. As a result of the MoU, Kosekhanudnas IV is in

21
 BUSINESS-IN-CONFIDENCE
The sources of information for this document may have been derived from sensitive and/or confidential sources. The recipient of this document is to ensure its limited distribution on a
business basis only. No third party dissemination without written approval of management.

discussions to station a combat squadron on Biak Island in Biak Numfor Regency, Papua. The establishment
of the combat squadron is part of the armed forces’ (TNI) strategic plan and the recent status upgrade of the
Manuhua Air Force Base in Biak from Level B to Level A. Kosekhanudnas IV and other air force bases that
host combat squadrons in Makassar are combining efforts to enhance air space security in the Eastern part
of the country.

Navy

There are three three naval commands in Indonesia: Koarmada I, II and III. The newest Koarmada
(Koarmada III) was added on 11 May 2018 and is based in Sorong, West Papua, with Vice Admiral Ariawan as
the commander. Marine commands were also reorganized. The former Pasmar II, headquartered in Jakarta,
is now Pasmar I, headquartered in Surabaya. East Java, is now Pasmar II. The new command, Pasmar III, is
based in Sorong. Brig. Gen. Amir Faisol was inaugurated as Pasmar III commander.

South Sulawesi is under the command of the Navy’s Second Fleet Command (Koarmada II), based at Tanjung
Perak Port in Surabaya, East Java.

First Adm. Heru Kusmanto was appointed as the head of the Navy’s Second Fleet
Command following a directive issued by Armed Forces (TNI) chief Air Marshal Hadi
Tjahjanto on 25 September 2019. Kusmanto replaced Rear Adm. Mintoro Yulianto.
Before the appointment, he was assigned as the chief of the Navy's Sea Traffic
Command (Kolinlamil).

Yulianto graduated from the Naval Academy in 1988. He became adjutant to former
Vice President Budiono in 2009. In 2014, Yulianto was appointed Chief of Staff to the
Navy’s Eastern Fleet (Guspurlatim) and then served as Commander of the fleet in 2014. In 2016, he served as
commander of Jayapura Navy Base (Lantamal X) before being assigned as Chief of Staff of Western Fleet
Command (Koarmabar) in 2017 and Navy's First Fleet Command (Koarmada I) in 2018.

22
 BUSINESS - IN - CONFIDENCE

Initial
Luwu Regency
Political & Business
Association Chart

Close associate and

former campaign manager of Mattayang
during 2019 regional elections

Appointed by Mattayang
Link
Commissioner

Director &
Chairman
Shareholder (50%) Previously active in Himpunan
Luwu Executive Board
(DPC) Mahasiswa Islam (Islamic Students
Basmin Mattayang Association) and Ikatan Mahasiswa
Luwu Regent Rusli Sunali Muhammadiyah (Muhammadiyah
Husain Parewoi Andi Pangerang Wife
(2019-2024) Head of Luwu Regional Student Association)
Agency Head of the Regional Agency Head of the Regional Jl. Syech Yusuf No. 97A, Legislative Council
Trade and Industry Agency Environmental Agency PT Ahkam Makassar, South Sulawesi
Deputy Regent (2019-2024)
Mega Putra Wara, South Sulawesi,
12 December 1957
Shareholder Master Degree in Education
(40%) Management from Makassar PPP
State University (2000) United Development Party
Agency Head PT Tasi Celebes Hayarna Hakim
Internasional Bachelor Degree from
Head of Luwu Family Welfare
Established in Makassar 1 May Ujung Pandang Teachers Muhammadiyah
Agency Head Movement (PKK); Former Head Training Institute (IKIP),
2003 by Mattayang and family. Allegedly controls many Organization
of Luwu Legislative Council currently known as Makassar
Authorized capital IDR 100 (2009-2014) State University
local street-thugs and can
Million, issued capital IDR 50 provide Mattayang Member
571219060605 (KTP)
Luwu Regional Million, paid-up capital of IDR political muscle for protest
Adiministration 25 Million. Classified as a small demonstrations and road
enterprise as per Law 20/2008. blockades.
Micro, Small and Medium
Enterprise.
Business activities include
mining (nickel, coal, iron, marble,
Regional Trade and Regional Environmental granit, oil and gas), transportation, President Director &
Close Associate
Industry Agency Agency business consulting and distribution Loyalist Owner
Jl. Sech Yusuf No. 97A, PT Mitra Pratama Milenia
Gunung Sari, Rappocini,
Abdul Hafid Pasiangan Current Client Security
Makassar, South Sulawesi
Former member of the South Manpower Provider (SMP)
Agency Sulawesi Legislative Council
Agency Head
Head representing PPP (2014-2019);
Mustofa Rahima Regional Investment Regional Transport Supriadi Chairman Former member Presidential
Acting Head of the Agency Agency Acting Head of the Security Detail Paspampres
Regional Investment Regional Transport Shareholder
Agency Agency (10%)
Syukur Bijak
Deputy Luwu Regent
(2019-2024);
Agency Head Former Deputy Regent
(2009-2014), under Regent
Manpower Agency Saiful Abdul Latief Andy Mudzakkar
Children
Official Batusitanduk, South Sulawesi,
28 November 1972

Alleged Criminal Issue

Son Syukur Bijak

GRANAT PERBAKIN Indonesian

Anti-Narcotics Fire Arms Association Mosque Board
Mattayang removed the Agency Active
National Movement Luwu Branch Luwu
Heads from the previous regime, Children of Basmin Mattayang member
Luwu Branch
replacing them with temporary Democrat Party
Muhammad Dhevy Bijak
Acting Heads. Mattayang will
Member of Indonesian House
appoint new Heads
of Representatives (DPR)
Batusitanduk, South Sulawesi,
23 May 1992

Arham Basmin Andi Zullilat Tazlilah

muhammad.bijak@dpr.go.id Democrat Party Democrat Party
Ahkam Basmin Arfan Basmin
Basmin Luwu Branch Youth Wing Luwu Branch
First son Second son Third son
Ujung Pandang, South Sulawesi, Public Administration Village Head of Senga Selatan, Fourth Child
31 March 1982 Institute, Bandung, First Daughter
Belopa District, Luwu Regency,
Bachelor Degree from West Java
South Sulawesi
17 Agustus 1945 University, Muhammad Andi Ahkam Basmin
Jakarta (2007)
Muhammad Andi Arham Basmin
Chairman of She will likely fill a Commissioner
Local sources allege that Bijak was
South Sulawesi local government arrested for possession of Crystal
KNPI position Methamphetamine also called
sabu-sabu. However, it is alleged
because of his political connections
Supriadi he was released
Latimojong District Head;
Former member of the HIPMAL
Head of Luwu Pancasila Head of Luwu APDESI (Latimojong Student
Youth Organization (2020-2025) Association)
Buntu Sarek Village, PT Bintang Utama Abadi
(2019-2024)
Luwu, South Sulawesi Galena-mining company
operating in Luwu Regency
Jl Poros Harapan,
KNPI Luwu 91951.
Head of Latimojong Affiliate to
National
Former Chairman Pancasila Youth
Youth Committee
Organization
Pemuda Pancasila
Pancasila Youth
Organization

APDESI
Indonesian Association of
PP Members Village Administrations

In close proximity to client site

Nur Agam
LEGEND
Azis Ancong
Former Village Head of Luwu Regency Political Chart
Ulusalu Village, Luwu,
Local Youth Leader and Local Member of South Sulawesi
Local Member of Pancasila Youth Address Date of Birth
(Ring Two)
Pancasila Youth Buntu Sarek Village,
Rante Balla Village, Luwu, South Sulawesi Education Background Full Name
Luwu, South Sulawesi (Ring Two)
(Ring One)
Identification Number Type of Business

Email Address

Male Office

Link
IF03092020

Page 1 of 1
ANNEX C

Crime and Terrorism/ Extremism Incidents in South Sulawesi July 2019-July 2020

The information in Annex C is found through open sources such as media websites and
newspapers reporting on crime incidents in South Sulawesi Province.

Crime

South Sulawesi Crime Cases from July 2019 to July 2020

No Crime Category Cases
1 Assault 58
2 Murders 38
3 Burglary/Robbery/Armed Robbery 18
4 Social Conflict 61
5 Major Narcotics Cases 8
6 Sexual Assaults 5
7 Frauds/scams 7
8 Terrorism Incidents 1
9 Violent Extremism incidents 3

Assaults

 A man was injured in an assault on Jl. Barawaja 2 Lorong 4 in Pampang sub-district, Tallo
district, Makassar on 11 July 2020. The suspect slashed the victim's arm and back with a
bladed weapon over a misunderstanding while under the influence of alcohol. The victim
was taken to hospital.

 A 40-year-old man was severely injured by several thugs at the Lakessi traditional market on
Jl. Lasinrang in Soreang district, Pare-Pare on 11 July 2020. The victim was beaten up and
assaulted with a bladed weapon after he reprimanded one of the suspects who was causing
a public disturbance by demanding money from the traders.

 A man was injured after being assaulted by another man at a café in Batu Lappa sub-district,
Watang Pulu district, Sidenreng Rappang regency on 5 July 2020. The suspected attacked
the victim repeatedly with a bladed weapon for unclear reasons.

 A man was beaten to death by an angry mob at the BTN Mawang Asri residential complex in
Mawang sub-district, Somba Opu district, Gowa regency on 29 June 2020. The man attacked
his wife with a bladed weapon over a petty dispute and four residents who came to her
rescue. The mob later assaulted the suspect, who died on the scene. The five victims were
admitted to hospital. Police are still trying to identify those involved in the lynching.

 A 31-year-old man was assaulted by three suspects in the Villa Bougainville residential
complex in Majang sub-district, West Tanete Riattang district, Bone regency on 29 June
2020. The victim told police that three men broke into his home and assaulted him

1
 repeatedly over a debt dispute. Two of the suspects who remain at large were wearing
tracksuits commonly used by members of the Armed Forces (TNI).

 A 70-year-old man was attacked by his neighbor in Carebby village, Awangpone district,
Bone regency on 17 June 2020. Police said the 59-year-old suspect slashed the victim with a
bladed weapon after accusing him of poisoning his dog.

 Three people were assaulted by eight youths on Jl. Ahmad Yani in Nuha district, East Luwu
regency on 14 June 2020 after they accused one of the victims of theft. Two of the victim's
cousins, who came to his rescue, were also beaten and stabbed during the incident.

 A 58-year-old man was severely injured when a group of youths attacked him on Jl. Andi
Tonro II in Tamalate district, Makassar on 14 June 2020. The assailants said the incident was
in retaliation for a previous assault.

 A Police officer in South Sulawesi Province was attacked by a group of men on Jl. Andi Tonro
in Jongaya sub-district, Tamalate district, Makassar on 12 June 2020. The victim was on his
way home at around 2:00 AM local time when several of the assailants chased and struck
him with an arrow.

 A detainee was assaulted by five people at a police station on Jl. Poros Maros-Soppeng in
Cempaniga sub-district, Camba district, Maros regency on 15 May 2020. The suspects broke
into the police station's detention center and assaulted the victim while accusing the police
of refusing to charge him for theft. Police fired warning shots to quell the violence before
arresting the suspects and seizing bladed weapons from them.

 A member of a local coronavirus task force was beaten by a group of youths in Muktisari
village, Bone-Bone district, North Luwu regency on 2 May 2020. The victim sustained a head
injury after reprimanding the youths for not wearing face masks.

 A 21-year-old man was assaulted over a petty dispute by six teenagers on Jl. Pampang IV in
Panaikang sub-district, Panakkukang district, Makassar on 27 April 2020. Police arrested the
suspects shortly afterward and seized a bladed weapon used in the attack.

 A teenager was seriously injured in an assault at the Sayang Park in Puncak Indah village,
Malili district, East Luwu regency on 26 April 2020. The victim was loitering in the park when
an unknown assailant on a motorcycle slashed him for unknown reasons. The suspect
remains at large.

 A 77-year-old man was assaulted by his son in Songing village, South Sinjai district, Sinjai
regency on 26 April 2020. The victim was feeding his chickens when the culprit slashed him
for unknown reasons. The suspect was arrested.

 A 16-year-old male suffered severe injuries after being attacked with a bladed weapon in
Masamba district, North Luwu regency on 21 April 2020. The assailant stabbed the victim
after seeing him at his former girlfriend's house. The suspect remains at large.

2
 Three people were admitted to hospital after they were attacked by a teenager on Jl.
Flamboyan in Mariso district, Makassar late on 13 April 2020. The 19-year-old suspect
stabbed them after they reprimanded him for visiting his girlfriend while intoxicated. Police
later rescued the suspect from an angry mob who set his motorcycle on fire. He has been
detained.

 Two people were seriously injured in an assault by unknown men on Jl. Kijang in Makassar
district, Makassar on 29 March 2020. One of the victims was stabbed in the back, while the
other suffered a head injury. The motive for the attack is unknown. The assailants are still at
large.

 Three college students were injured in an assault by unknown assailants at the Bumi
Tamalanrea Permai housing complex in Tamanlarea district, Makassar on 23 March 2020.
The suspects attacked the victims with bladed weapons following an altercation over a
personal dispute. The attackers remain at large.

 A 20-year-old police officer was assaulted by an unknown person in Moncongloe district,

Maros regency on 18 March 2020. The off-duty officer was intercepted and beaten for
unclear reasons by the assailant who fled after the attack. The victim sustained minor
injuries.

 A man was assaulted by an unknown person while riding his motorcycle in Barowa village,
Bua district, Luwu regency on 17 March 2020. The victim was slashed with a bladed weapon.
The suspect remains at large.

 A man was stabbed by an unidentified assailant in Barowa village, Bua regency, Luwu
regency on 17 March 2020. The victim and his friend were riding home when the suspect,
also on a motorcycle, attacked them for unknown reasons.

 A security guard attacked a village head in Panakkukang district, Makassar on 16 March

2020. The culprit assaulted the victim after he was fired from his job. The suspect was
arrested.

 A man was seriously injured in an assault by another man in Pabbundukang hamlet, Benteng
sub-district, Bangkala district, Jeneponto regency on 10 March 2020. The assailant
intercepted the victim's vehicle and attacked him with stones before leaving him
unconscious for unclear reasons.

 A 50-year-old-man was seriously injured in an assault by his nephew at the Kuwarasan

traditional market in Tomoni district, East Luwu regency on 8 March 2020. The victim was
stabbed with a bladed weapon when he arrived at the market. The assailant was arrested.

 Two restaurant employees were injured in an assault at their workplace on Jl. Pelita in
Rappocini district, Makassar on 3 March 2020. Three suspects attacked the victims with
bladed weapons and kitchenware after trading insults. No arrests were reported.

3
 A 35-year-old-man was assaulted by his brother-in-law and nephew in Siwa sub-district,
Pitumpanua district, Wajo regency on 27 February 2020. He was attacked with a bladed
weapon over a long-running grudge.

 A 16-year-old student was assaulted by a group of unknown men at a vocational high school
on Jl. Mesjid Raya in Somba Opu district, Gowa regency on 21 February 2020. Witnesses said
the victim was beaten inside a classroom before being dragged to a car parked outside. The
suspects took the victim to a hospital after realizing that they assaulted the wrong person.
Police on 23 February 2020 said the incident followed an earlier assault. All the five
assailants were arrested.

 Two people were injured when a group of teenagers went on a rampage at a food court on
Jl. Jend. Sudirman in Pinrang regency on 19 February 2020 at around midnight. Police said
the teenagers targeted a person over a previous assault. A security guard who tried to
intervene was injured. Three suspects, including a minor, were arrested on the next day.

 A man sustained a severe laceration in an assault at a rubber plantation in Turungan Baji

village, West Sinjai district, Sinjai regency on 18 February 2020. Police said the suspect
caught the victim sapping his trees.

 A couple was attacked by their 29-year-old son at their home in Binamu district, Jeneponto
regency on 15 February 2020. The suspect, who allegedly suffers from mental illness,
attacked the couple with a bladed weapon while they were sleeping. He was arrested
shortly after the incident.

 A man was arrested on 10 February 2020 for assaulting a married couple at their house in
Makassar district, Makassar on 8 February. The husband died after he was struck by an
arrow, while his wife sustained a slash wound. Police said the assault stemmed from an old
grudge.

 Six people were injured when a 65-year-old man went on a rampage in Nyiur Indah village,
Takabonerate district, Selayar Islands regency on 23 January 2020. Police said the elderly
man used a bladed weapon to attack the victims, whom he accused of constantly mocking
him. The suspect was arrested.

 An Afghan refugee was assaulted at an immigrant shelter on Jl. Perintis Kemerdekaan VII in
Tamalanrea Indah sub-district, Tamalanrea district, Makassar on 8 January 2020. The
assailant, who is also an Afghan migrant, hit the victim in the face over a dispute over food.
The assailant was arrested.

 A man was stabbed by another on Jl. Maccini Raya in Panakkukang district, Makassar on 1
January 2020. The suspect was angered by the victim's alleged rude behavior. The suspect
has been arrested.

 A 60-year-old widow was assaulted at her house in Bontosunggu village, Tamalatea district,
Jeneponto regency on 1 January 2020. The woman was hit in the face when she confronted

4
 a man looking for her grandson, with whom the assailant had a previous altercation. The
man also broke several pieces of furniture inside the woman's house before fleeing.

 A truck driver was assaulted by a group of men on Jl. Andi Tonro in Somba Opu district,
Gowa regency on 30 December 2019. According to witnesses, the incident occurred after
other drivers accused the victim of failing to give way to an ambulance responding to an
emergency. The man sustained a broken nose.

 A 51-year-old man stabbed his uncle over a personal dispute at the Pallateang Residence in
Biraeng sub-district, Minasatene district, Pangkep regency on 29 December 2019. The
suspect was arrested immediately after the crime.

 A man was assaulted by a colleague over a petty dispute at their office on Jl. Gagak in
Mariso district on 17 December 2019. The alleged assailant hit the victim several times,
injuring him in the left eye. The suspect was arrested.

 A 45-year-old woman was assaulted by an alleged mentally-ill man in Subur village,

Sukamaju district, North Luwu regency on 6 November 2019. The culprit attacked the victim
with a bladed weapon, severing several fingers and causing wounds to other parts of her
body. The assailant was arrested shortly after the incident. The cause of the incident was
unclear.

 A father and his son were assaulted, allegedly by their neighbor, in Boronglamu village,
Arungkeke district, Jeneponto regency on 30 October 2019. The culprit slashed the father's
abdomen following a verbal dispute. The son was stabbed in the chest when he attempted
to help his father. The assailant was arrested several hours after the incident.

 A 65-year-old woman was assaulted, allegedly by her neighbor, in Pabiringa sub-district,

Binamu district, Jeneponto regency on 27 October 2019. The 53-year-old culprit hit the
victim in the head following an argument. No arrest was reported.

 A 17-year-old male was assaulted by another teenager in Biringere sub-district, North Sinjai
district, Sinjai regency on 21 October 2019. The assailant beat the victim for no apparent
reason at around 3:00 PM local time. The victim sustained bruises to his body. No arrest was
reported.

 A 58-year-old man was beaten by four of his neighbors in Panakkukang district, Makassar
early on 3 October 2019. The victim reprimanded the assailants who were drinking alcohol
near his home, leading to the assault that injured his face and head. The culprits were
arrested.

 A 35-year-old man was critically injured after being stabbed in Pampang sub-district,
Panakkukang district, Makassar on 29 September 2019. The victim was on his way home
from a party when another man stabbed him three times in the abdomen for unclear
reasons. The culprit was arrested.

5
 A 19-year-old man was assaulted by a group of four men on Jl. Yos Sudarso in Pontap sub-
district, East Wara district, Palopo on 16 September 2019. The group beat the victim and
shot him with an arrow for no apparent reason. The victim also sustained a stab wound to
his back. The assailants were arrested a day later.

 A man and a woman were assaulted by another man at a boarding house in Tamalanrea
district on 9 September 2019. The assault was triggered by a personal dispute. The woman
sustained slight injuries to her face. Her husband was hospitalized with stab wounds to his
back and arm. The 25-year-old assailant was arrested.

 A 27-year-old police officer was beaten by four illegal parking attendants at a mini-market in
Tamalate district, Makassar on 8 September 2019. Rappocini Police officer 2nd Brig. Irsan
refused to pay the parking fees, prompting the assault. The officer sustained wounds to his
face. Three of the attackers were arrested.

 A 42-year-old man was stabbed by another man in Kalosi village, Duapitue district,
Sidenreng Rappang regency on 7 September 2019. The assailant attacked the victim, the
husband of his former wife, allegedly over jealousy. The victim was hospitalized with
wounds to his arms. The assailant remains at large.

 An Armed Forces (TNI) member was attacked by a group of men on a road in Makassar
district, Makassar on 5 September 2019. Two of the assailants, a father and his son, were
involved in an altercation with a motorcycle taxi driver. The 35-year-old soldier was beaten
by the two assailants and several other residents when he attempted to intervene. The
soldier was wounded in the face and chest. Four assailants, including the father and the son,
were arrested.

 A student was assaulted allegedly by his teacher at the SMAN 18 state senior high school in
Tambangan village, Kajang district, Bulukumba on 4 September 2019. The culprit beat the
victim when he told another student that they could avoid sanctions for arriving late to
school by bribing the teacher. The victim suffered injuries to his neck. No arrest was
reported.

 A female teacher was assaulted by two women at the SDN Pa'bangiang state elementary
school in Tombolo sub-district, Somba Opu district, Gowa regency on 4 September 2019.
The victim was attacked allegedly over a fight involving the culprits’ children. No arrests
were reported.

 A 60-year-old man was stabbed by another man in Tammanyeleng village, Barombong

district, Gowa regency late on 26 August 2019. The victim reprimanded the assailant for
urinating near his home, prompting the assault. The victim was hospitalized with wounds to
his head. The 30-year-old suspect remains at large.

 An online media journalist was injured in an attack by a group of men in Polewali village,
Gantarang district, Bulukumba regency on 7 August 2019. Reports said the victim was taken
to a shop-house in the Kampung Baru area and beaten after he was caught taking pictures

6
 of the assailants siphoning fuel from a car. The men forced the victim to delete the pictures
and threatened to kill him if he reported them to the authorities. No arrests were reported.

 A student of the Makassar State University (UNM) was allegedly assaulted by Husain Syam,
the university's rector, on Jl. A.P. Pettarani in Tidung sub-district, Rappocini district,
Makassar on 1 August 2019. The victim, a journalist with the campus' student press
organization, was beaten over an article on an alleged violation of the Higher Education and
Research Ministry's regulation by the university's management. The victim was left with
facial bruises. No arrest was reported.

 A 38-year-old man was assaulted by another man at the Bantimurung National Park in
Kalabbirang sub-district, Bantimurung district, Maros regency on 1 August 2019. The victim
was beaten allegedly over an unpaid debt. The assailant is still at large.

 A man was allegedly assaulted by his son-in-law at their home in Macanang sub-district,
West Tanete Riattang district, Bone regency on 1 August 2019. The culprit stabbed the
victim for preventing him from meeting his wife. The assailant was arrested.

 A brigadier-ranked police officer suffered injuries to his eyes in an assault by a group of

college students on Jl. Bitoa in Manggala district, Makassar on early 26 July 2019. Manggala
Police chief Comm. Hasniati Amir on 27 July said the officer, who was stationed at the local
Community Security and Order Unit (Bhabinkamtibmas), intervened in an altercation among
road users following a traffic accident in the area. The students, who mistakenly thought the
officer was ticketing their fellow student who had been involved in the accident, assaulted
the officer. Residents broke up the commotion. Police later raided a dormitory in the area
and detained dozens of students, along with unidentified amounts of alcoholic beverages
and bladed weapons. Makassar Police crime unit chief Adj. Sr. Comm. Indratmoko said the
culprits were allegedly under the influence of alcohol when they committed the assault.

 A 23-year-old waitress was injured in an assault by a brigadier-ranked police officer at a café

in Banrimanurung village, Bangkala district, Jeneponto regency on 19 July 2019. Jeneponto
Police spokesman Adj. Comm. Syahrul said the officer, serving at Takalar Police station,
kicked and hit the victim in the face when she refused to have sex with him. The internal
division (Propam) of Takalar Police detained the suspect, who was believed to be intoxicated
when the incident occurred.

 A local anti-corruption activist was injured in an assault by several men claiming to be police
officers on Jl. Mutiara Boulevard in Bringkanaya district, Makassar at 1:00 AM local time on
12 July 2019. The victim, identified as Yusril, said he was riding a motorcycle when several
people shouted at him and intercepted his vehicle. One of them, who claimed to be a police
officer, threatened him at gunpoint. They proceeded to beat the victim for unclear reasons.
The journalist said he had filed a report to Biringkanaya Police station on 13 July, but no
progress had been made.

7
Murders

 A man was murdered by another man in Gona village, Kajuara district, Bone regency on 6
July 2020. Security camera footage showed the suspect attacking the victim with a bladed
weapon. The victim succumbed to his wounds at a public health center (puskesmas).

 The body of a man was found on the side of the road on Jl. Poros Macanda in Mawang sub-
district, Somba Opu district, Gowa regency on 29 June 2020. Police said the victim had slash
and stab wounds over his body, suggesting foul play. A machete, allegedly used to commit
the crime, was also found nearby.

 A 27-year-old woman murdered her four-year-old stepson at their home in Pinrang regency
on 16 June 2020. The woman stabbed the victim with a pen multiple times.

 Two five-year-old children were murdered in Sumilin village, Masamba district, Luwu Utara
regency on 14 June 2020. The assailant, believed to be mentally ill, stabbed the first victim
in the head before decapitating the other one. The assailant also stabbed a 37-year-old man
on a bicycle.

 A 33-year-old man was murdered by five men in Salobulo sub-district, North Wara district,
Palopo on 11 June 2020. The suspects stabbed the victim and his friend for unclear reasons.

 A neighborhood defense officer, locally known as hansip, was killed by a man on Jl. Bete-
bete in Sinjai Borong district, Sinjai on 25 May 2020. The victim was involved in a heated
argument with the assailant's wife who confronted the victim about the government's cash
transfer program (BLT) after she failed to receive any of the aid. This prompted the assailant
to stab the victim multiple times. The victim succumbed to his wounds and the suspect was
arrested.

 A 39-year-old man was killed by his nephew in Nepo village, Mallusetasi district, Barru
regency on 18 May 2020. The suspect stabbed the victim 11 times over a personal dispute.
The victim's body was found in a plantation by a neighbor who claimed that he earlier heard
the victim and the suspect shouting at each other.

 Eight members of the same family were arrested over their alleged involvement in the
murder of a 16-year-old relative in Pattaneteang village, Tompobulu district, Bantaeng
regency on 9 May 2020. The case was uncovered after police personnel searched the
family's house following a report of a hostage situation at the family's residence. Police
found the teenager's body in a room with deep cuts to her head and neck. Bantaeng Police
chief Adj. Sr. Comm. Wawan Sumantri said the victim, identified as the fifth child in the
family, was killed by the first and fourth child for having sex with her 45-year-old nephew,
who was taken as one of the hostages.

 A man was killed by another man on Jl. Ratulangi in Palopo regency early on 3 May 2020.
Police said the suspect hit the victim with metal rod repeatedly and stabbed him in the chest
for having an affair with his wife.

8
 A teenager was killed in an attack on 2 May 2020 on Jl. Perintis Kemerdekaan in Tambasa
Hamlet, Tamalanrea district, Makassar. A group of youths attacked the victim with bladed
weapons when he was at a food stall. The incident was allegedly in retaliation for a previous
clash.

 A suspect was arrested for murdering a man in Jalanjang sub-district, Gantarang district,
Bulukumba on 24 March 2020. The victim was stabbed in the neck multiple times after the
suspect mistook him for someone else. The suspect surrendered to the police shortly after
the incident.

 A 60-year-old woman was found dead in the backyard of her house in Mappideceng district,
North Luwu regency on 16 March 2020 after she was reported missing three days earlier.
Neighbors found the victim's body underneath a pile of banana leaves with a cut wound to
her neck.

 A farmer was killed by two other farmers in Welado village, Ajangale district, Bone regency
on 15 March 2020. The victim was stabbed multiple times by the culprits during an
altercation. Both suspects were arrested.

 The body of a woman was found covered in blood at a traditional market in Bonto-Bonto
village, Ma'rang district, Pangkep regency on 13 March 2020.

 A 35-year-old-man was stabbed to death by his cousin during an altercation in Kampili

village, Pallangga district, Gowa regency on 1 March 2020. Both were reportedly under the
influence of alcohol when an argument broke out. The victim died on the way to hospital.
The suspect, who fled the scene, was arrested later.

 A man was mutilated by a village head in Palambarae village, Gantarang district, Bulukumba
regency on 24 February 2020. The victim's eye was peeled from its socket and his penis was
cut off by the suspect after they were involved in an altercation. The suspect, who was
allegedly drunk at the time, was arrested.

 An eight-year-old child was murdered by a man in Mattirotasi village, Watang Pulu district,
Sidenreng Rappang regency on 12 February 2020. The suspect, who allegedly drowned the
child in a bathtub after failing to rape him, has been arrested.

 A 42-year-old man was arrested for stabbing a neighbor to death on Jl. Sunu in Lemba sub-
district, Lalabata district, Soppeng regency on 10 February 2020. Police said the victim hit
the suspect with a piece of wood during a petty dispute, prompting the incident.

 A man was stabbed to death by a friend on Jl. East Pamalongan, East Bara-Baraya sub-
district, Makassar district, Makassar on 8 February 2020. The incident reportedly involved a
personal dispute. The suspect was arrested after the victim died in a local hospital.

 A 75-year-old man was killed by another tenant at a facility for senior citizens in Romangloe
village, Bontomarannu district, Gowa regency, on 23 January 2020. The suspect, who is also
elderly, struck the victim in the head with a brick multiple times before strangling him for

9
 sleeping on a couch. A staff member said the two were often involved in altercations. The
suspect has been arrested.

 A woman was killed by her husband at her home in Parenreng village, Segeri district,
Pangkajene Island regency on 16 January 2020. The suspect, who had been locked out of the
house, stabbed the victim multiple times after gaining entry through a window at around
midnight. He also stabbed the victim's nine-year-old son, who tried to intervene. The
suspect has been arrested.

 A 21-year-old woman was found dead at her home in Borongloe sub-district, Bontomarannu
district, Gowa regency on 13 January 2020. The victim's mother discovered the body
covered in bruises, indicating foul play. The victim's husband has been missing since the
incident.

 A man was found dead near the Citraland Celebes residence on Jl. Tun Abdul Razak in Gowa
regency on 19 December 2019. Police said the body, which was found at around 6:30 AM
local time, had slash wounds to the abdomen and lower back.

 A man was killed by his 41-year-old brother at their home in Manggala district, Makassar on
15 December 2019. The suspect was under the influence of alcohol when he pelted stones
at his younger brother repeatedly, allegedly due to a previous fight. The culprit has been
arrested.

 A woman was found murdered in Tamangapa sub-district, Manggala district, Makassar late
on 14 December 2019. The victim, a local university student, was allegedly killed by her
boyfriend after he learned that she was pregnant. The man suffocated the woman with a
pillow and stabbed her with a bladed weapon, police said.

 A 14-year-old male was murdered in Bulurokeng sub-district, Biringkanaya district, Makassar

on 30 November 2019. The victim died of blunt force trauma after the suspect, identified as
his 51-year-old uncle, struck him over the head with a piece of concrete at a construction
site where they both worked, police said on 1 December . The suspect remains at large.

 A man was murdered by another man in Mangepong village, Turatea district, Jeneponto
regency in the early hours of 7 November 2019. The victim was stabbed in the chest
multiple times following an altercation with the culprit. The assailant was arrested several
hours after the crime.

 A 73-year-old man was killed by another man in Campulili hamlet, Sawaru village, Camba
district, Maros regency on 20 October 2019. A petty argument reportedly caused the two
men to attack each other until the victim was fatally stabbed. The suspect was arrested.

 A 55-year-old man was killed after being stabbed by his younger brother at their home in
Cinennung village, Cina district, Bone regency early on 15 October 2019. The 47-year-old
perpetrator, allegedly mentally ill, was arrested.

10
 A 24-year-old man was shot with an arrow and killed by seven men on Jl. Sultan Alauddin in
Rapocini district, Makassar on 14 October 2019. Police said the victim was attacked and
repeatedly beaten by the culprits after some of them were involved in a personal dispute
through social media. The suspects, aged 17 to 21 years old, were apprehended at separate
locations in the city following the incident. Police seized several bladed weapons, two bows
and 14 arrows from the suspects.

 A 76-year-old man was murdered by his allegedly mentally ill neighbor in Bontosunggu
hamlet, Pa’rappunganta village, North Polangbangkeng district, Takalar regency on 14
October 2019. The victim died after he was slashed in the neck for unclear reasons. The
suspect has been placed in custody.

 A 17-year-old male died after being shot with an arrow near a dormitory in Sudiang sub-
district, Biringkanaya district, Makassar, late on 2 October 2019. The identity of the attacker
is unknown.

 A man was murdered in Tello Baru sub-district, Panakukkang district, Makassar on 23 August
2019. Makassar Police chief Adj. Sr. Comm. Indratmoko said the 49-year-old victim was
playing cards with several neighbors when three men suddenly approached and attacked
him with bladed weapons for unclear reasons. The victim sustained slash wounds to his
stomach and arms while a neighbor who attempted to intervene suffered minor injuries.
The victim succumbed to his wounds at hospital, Indratmoko said, adding the assailants
have been identified but remain at large.

 A 31-year-old man was killed by another man following an altercation on Jl. Toddopuli 2 in
Panakkukang district, Makassar late on 4 August 2019. The culprit was reportedly drunk
when he accused the victim of being an undercover police informant. They engaged in a
fight and the victim was fatally stabbed in the chest. The culprit turned himself in to the
authorities soon after the incident.

 A man was arrested for murdering his five-month-old child at a home in Lewandi village,
West Walenrang district, Luwu regency on 30 July 2019. Police said the crime took place at
around 10:00 PM local time, when the 35-year-old man was involved in an altercation with
his wife, who allegedly had cheated on him. He strangled the baby and broke its neck. The
suspect also set fire to the home of a neighbor who attempted to intervene. He was
arrested several hours later.

 Three men were arrested in three separate locations on 29 July 2019 over the murder of a
man. Panakkukang Police spokesman chief Brig. Ahmad Halim said the men assaulted and
stabbed the victim with a knife following a heated argument while under the influence of
alcohol in Panakkukang district, Makassar on 26 July 2019. Police said the first suspect was
apprehended on Jl. Sultan Hasanudin in Watang Sawitto district, Pinrang regency following a
tip-off. The second culprit was caught hiding at a boarding house on Jl. Merdeka in Lalabata
district, Soppeng regency, while the third was nabbed in Lempangang village, Palangga
district, Gowa regency. Police personnel were forced to shoot two of the suspects as they
attempted to flee during the search for evidence near the Tallo River, where they allegedly
threw the murder weapon.

11
 A 73-year-old man was murdered while the culprit was lynched by a mob in West Batu
Le'leng hamlet, Mallasoro village, Bangkala district, Jeneponto regency on 24 July 2019.
Jeneponto Police said the 71-year-old suspect broke into the victim's house and stabbed him
with a bladed weapon early in the morning, killing him instantly. Angry residents chased the
suspect and beat him unconscious with wooden blocks until authorities arrived. The man
died at a hospital. Reports said the culprit killed the victim out of jealousy after suspecting
the latter of having an affair with his wife.

 The body of a 35-year-old housewife was found at a plantation in Poleonro village, Libureng
district, Bone regency on 15 July 2019. Police were treating the case as murder due to
injuries to the victim's face. No arrest was reported.

Burglaries/Robberies/Armed Robberies

 A woman was injured in a robbery on Jl. Sabutung Raya in Ujung Tanah district, Makassar on
2 July 2020. Two suspects on a motorcycle stole the victim's jewelry, causing her to fall and
sustain minor injuries.

 Thieves stole IDR 115 million in a burglary at a house in the Griya Ganggawa housing
complex in Majjelling sub-district, Wattangpulu district, Sidrap regency on 7 June 2020.

 A woman was robbed of a cellular phone on Jl. Abdullah Daeng Sirua in Panakkukang
district, Makassar city on 23 April 2020. The suspects, who were recently released from
prison under the government's assimilation program, threatened the victim at knifepoint.
They were later arrested on Jl. Andi Pettarani in Makassar while trying to sell the victim's
phone.

 A husband and wife were robbed by five armed men at their home on Jl. Pinus in Paropo
sub-district, Panakukang district, Makassar on 5 April 2020. The robbers threatened the
victims at knifepoint before fleeing with cash and valuables worth IDR 10 million.

 A man held a 25-year-old woman at knifepoint after breaking into her home on Jl. Perintis
Kemerdekaan IV in Tamalanrea Jaya sub-district, Tamalanrea Jaya district, Makassar on 30
March 2020. The suspect fled with the woman's laptop computer.

 A mini-market was broken into and goods worth IDR 11 million were stolen in Sukaraya sub-
district, East Baturaja district, Ogan Komering Ulu regency on 28 March 2020. The thief
gained entry by breaking a rolling door and stole cartons of cigarettes and perfume. No
arrests were reported.

 A 36-year-old man was arrested after robbing two people in separate locations on 19 March
2020. The suspect snatched a 70-year-old woman's gold necklace at her house in Tino
Jeneponto village, Taroang district, Jeneponto regency. He later tried to snatch a 50-year-old
woman's gold necklace in Panaikang hamlet, Bonto Manai village, Bissappu district,
Bantaeng regency but was arrested when police heard the victim calling for help.

12
 A passenger of an online taxi was robbed near the Wisma Nirmalasari Mall in Tamalanrea
district, Makassar on 14 December 2019. The driver picked up the woman on Jl. Tallasa City
at around 10:00 PM local time. The victim was in the front seat of the vehicle, while the
driver's accomplice suddenly appeared from the back seat and threatened her at knifepoint.
The man stole IDR 1.4 million, a cellular phone and a watch worth around IDR 5 million from
the victim before abandoning her unharmed on the side of a road. The culprits remain at
large.

 A 40-year-old woman was sexually assaulted during a robbery at her house in Bendoro
village, Watang Sidenreng district, Sidenreng Rappang regency on 5 November 2019. The
victim was sleeping when the 32-year-old suspect broke into the home and groped her. He
choked the woman when she screamed for help and fled on a motorcycle with two stolen
cellular phones. The suspect was arrested soon afterwards.

 Around IDR 10 million was stolen from a house in Julupamai village, Pallangga district, Gowa
regency on 23 September 2019. The home was broken into when the occupants were
attending a music concert. The culprits remained at large.

 Around IDR 55 million was stolen from ground service provider PT Gapura Angkasa's main
office at Sultan Hasanuddin International Airport in Maros regency on 22 September 2019.
The culprit was identified as an airport taxi driver who broke into the office’s safe at around
5:00 PM. He was arrested at a hotel on Jl. Jend. M. Jusuf in Makassar the following day.

 Two laptop computers were stolen from a state high school in Rappang sub-district, Panca
Rijang district, Sidenreng Rappang regency on 11 September 2019. Teachers found the
administration room broken into and the computers missing when they arrived at school in
the morning.

 A man was robbed and slightly injured on a road in Caile sub-district, Ujung Bulu district,
Bulukumba regency on 3 September 2019. The victim was on his way to a bank to deposit
Rp40 million when two robbers knocked him off his motorcycle. The culprits fled with a bag
containing the money.

 A 46-year-old man was injured in a robbery on a road in Wajo district, Makassar late on 17
August 2019. A robber attempted to grab the victim’s bag when he was walking towards his
car but the victim resisted. That prompted the robber to stab the victim in the arm, forcing
him to hand over the bag containing money and valuables worth nearly IDR 14 million in
total. The victim was hospitalized. The 37-year-old robber was arrested.

 At least IDR 100 million was stolen from a local government office in Pantan sub-district,
Makale district, Tana Toraja regency early on 12 August 2019. The robbers damaged a door
and a safe at the unattended office of the Tana Toraja administration. No arrests were
reported.

 A 27-year-old man was caught during a robbery at an unoccupied boarding room in

Tamalanrea Indah sub-district, Tamalanrea district, Makassar on 29 July 2019. He broke into
the room by breaking its door with a screwdriver and stole the occupant's belongings. Police

13
 said the suspect is believed to have broken into 25 boarding houses in the area since March.
Dareda said the man stole cellular phones and laptop computers of Hasanuddin University
students who boarded in the area. Police seized several cellular phones, a motorcycle and a
screwdriver allegedly used in the crime.

 An alleged robber targeting bank customers on motorcycles was fatally shot on Jl. Metro
Tanjung Bunga in Tamalate district, Makassar, police said on 26 July 2019. South Sulawesi
Police mobile investigation unit (Resmob) chief Adj. Comm. Edy Sabhara said the suspect
was wanted for stealing IDR 100 million from a motorcycle storage compartment belonging
to a bank customer in Sinjai regency in November 2016. He was apprehended at a house on
Jl. Tamangapa Raya in Manggala district on 24 July 2019. The police decided to transport
him to Jeneponto for a further probe regarding additional reports on motorcycle robberies.
On his way to Jeneponto, the man said he needed to go to the toilet but tried to escape,
prompting officers to shoot him. He was pronounced dead at a hospital due to blood loss.

 Two Iranian nationals were arrested on 25 July 2019 in relation to the robbery of a stall in
Bombongan sub-district, Makale district, Tana Toraja regency. One of the foreigners, posing
as a buyer, kept two employees involved in a conversation while the other stole IDR 12
million in cash from a drawer. The foreigners were arrested in the provincial capital of
Makassar four days after the robbery.

Social Conflicts (including land dispute, soccer violence, biker gang violence, road rage)

 Eight teenagers were arrested for their involvement in a clash on Jl. Tol Reformasi in
Makassar on July 15, 2020. The incident occurred at around 5:00 AM local time when
residents of Tallo and Ujung Tanah districts attacked each other with arrows.

 Residents of two districts clashed on Jl. Tol Reformasi in Makassar on 14 July 2020. The
incident occurred at around 5:30 AM local time when residents of Tallo and Ujung Tanah
districts attacked each other with arrows and rocks. Police used tear gas to restore order.
No casualties were reported. Three people were arrested for public violence, while dozens
of arrows, slingshots and rocks were seized.

 A local government office was damaged during a clash between two groups of youths in
Mancani sub-district, Tellu Wanua district, Palopo on 8 July 2020. The incident occurred at
around 10:00 PM local time when the youths started pelting each other with rocks after
taunts.

 Four people were injured during clashes in Biringkanaya district, Makassar on 4 July 2020.
The first incident occurred at around 7:30 PM local time when an 11-year-old boy was struck
with an arrow when passing Jl. Pajjaiang where he and his mother tried to avoid an ongoing
clash. An app based motorcycle taxi driver was also injured after being struck with an arrow
while passing Jl. Goa Ria at 9:00 PM local time, allegedly by the same culprits. Two more
people were injured after being struck with arrows at the same location at 10:00 PM local
time.

14
 Eight teenagers were arrested following a clash between two groups of youths in Tallo
district, Makassar on 30 June 2020. No casualties were reported. The cause of the violence
was unclear.

 Eight youths were arrested for their involvement in a clash on Jl. Lembo in Tallo district,
Makassar on 29 June 2020. The suspects were arrested while hiding in a nearby
neighborhood after fleeing from the police. Several bows and arrows were seized. No
casualties were reported.

 At least 11 teenagers were arrested and several bladed weapons were seized following a
clash on Jl. Lembo in Makassar on 19 June 2020.

 Eight youths were arrested for planning to initiate public violence on Jl. Sabutung Cambayya
in Ujung Tanah district, Makassar on 17 June 2020. Patrolling police officers arrested them
after noticing them loitering on the side of the road. Several bladed weapons were seized
from the suspects.

 A house was damaged when two groups of youths attacked each other near the Karuwisi
traditional market on Jl. Keamanan in Maccini Parang sub-district, Makassar district,
Makassar on 16 June 2020.

 A clash between youth groups broke out on Jl. Galangan Kapal in Tallo district, Makassar
early on 15 June 2020. The residents of Pannampu and Paccelang sub-districts attacked each
other with rocks allegedly over an old grudge. Another clash occurred at the same location
on 14 June 2020, when youths from Paccelang and Capoa sub-districts attacked each other
with bladed weapons.

 Three teenagers were arrested in a clash involving several youth groups in Makassar on 12
June 2020. The groups comprised youths from Jl. Dangko and Jl. Balang Baru. They attacked
each other with rocks, bladed weapons and firecrackers. Several bladed weapons were
seized. Elsewhere in the province, two youths were arrested for their involvement in a clash
on Jl. Mannuruki Daya in Biringkanaya district, Makassar on 11 June. The cause of the
violence between youths from the Kodam 2 housing complex and the Yayasan Gubernur
housing complex was unclear.

 Two people were injured and a house was damaged during a mob attack by residents on Jl.
Sinassara in Tallo district, Makassar on 9 June 2020. Dozens of residents of Sinassara village
vandalized the home and injured the homeowners after accusing them of drinking alcohol.
The incident forced several other occupants to be evacuated to a nearby police station.
Several bladed weapons were seized.

 Two people were injured in a clash between youths on Jl. Sembilan in Bontoala district,
Makassar on June 8, 2020.

 A local official was injured when a mob attacked a local government office in Maccini
Gusung sub-district in Makassar district, Makassar on 8 June 2020. Makassar Police
spokesman Comm. Edi Supriadi Idrus said the mob was angered by a rumor that the office

15
 would be converted to serve as an isolation ward for a coronavirus patient. Idrus said a mob
of about 50 people first arrived at a local clinic to look for the patient and later marched to
the sub-district office where they went on a rampage, smashing windows and damaging a
computer and other property. At least one official was injured after being assaulted by the
mob. Three cellular phones belonging to employees were stolen during the incident.
Makassar district head Andi Ardi Sulham said the rumor was false and the patient was
already sent home.

 A man was murdered by his brother-in-law in Sappa village, Belawa district, Wajo regency
on 7 June 2020. The suspect stabbed the victim over a land dispute.

 One person was injured in a clash between groups of youths on Jl. Sungai Pareman in
Makassar on 4 June 2020. The 15-year-old victim suffered serious injuries after being struck
with an arrow. The clash reportedly involved an old grudge. Elsewhere in the province, nine
teenagers were arrested for trying to initiate a clash on Jl. Terong in Tompo Balang sub-
district, Bontoala district, Makassar. They were detained after reports by residents that
youths of Maccini sub-district were planning to attack another group.

 Five youths were arrested for their involvement in a clash on Jl. Andi Pangeran Pettarani in
Makassar on 3 June 2020. Two groups pelted rocks at each other, allegedly over an old
grudge.

 One person was injured and several houses and a car were damaged in a clash involving two
groups of youths on Jl. Gunung Merapi in Makassar on 2 June 2020. Police said the mob,
comprised of residents from Jl. Sungai Preman Lorong 54 and Lorong 57, pelted each other
with rocks at around 4:00 PM local time. The melee broke out after a teenager from Lorong
57 was assaulted by youths from Lorong 54.

 One person was injured in a clash between residents of Balandai sub-district in Bara district,
Palopo on 31 May 2020. They attacked each other with rocks and homemade weapons over
unknown reasons. Elsewhere in the province, five people were arrested after for their
involvement in a clash in Makassar. The five suspects, who are believed to have provoked
the clash on Jl. Maccinni Pasar Malam in Makassar district on 24 May 2020 were arrested
following a tip-off. The confrontation reportedly involved a dispute related to the
management of a parking lot. Police seized rocks and bows and arrows.

 A man was injured in a clash between residents from two hamlets near the border of Buntu
Mondong village in Buntu Batu district, Enrekang regency on 24 May 2020. Police said the
incident took place after youths of Banca hamlet in Bontongan village, Baraka district
exchanged insults with youths of Gura hamlet in Buntu Mondong. The victim, identified as a
resident of Gura hamlet, suffered an injury to his hand after he was attacked with a bladed
weapon. A car and two motorcycles belonging to residents of Banca hamlet were set on fire
by the mob.

 A car was damaged in a clash between two groups of youths on Jl. Muhammadiyah in Wajo
district, Makassar on May 17, 2020. A witness said the mob, comprised of residents of
Malimongan Tua sub-district and neighboring Layang sub-district in Bontoala district,

16
 attacked each other at around 2:45 AM local time. Elsewhere in the province, two people
were arrested following a clash between two youth groups on Jl. Malaja in Surutanga sub-
district, East Wara district, Palopo on May 17, 2020. The clash stemmed from an old grudge,
police said.

 At least 17 youths were arrested for their alleged involvement in a clash on Jl. Gunung Lokon
in Makassar district, Makassar on 12 May 2020. The mob used spears, bow and arrows and
slingshots to attack each other during the clash, which followed an earlier incident. Police
fired tear gas to quell the violence.

 A 25-year-old woman was killed by her neighbor in Balutan village, Bupon district, Luwu
regency on 12 May 2020. The suspect hit the victim's head with a wooden stick following an
altercation over a land dispute.

 One person was killed in a clash involving mostly youths on Jl. Barawaja in Panakkukkang
district, Makassar on 10 May 2020. The 30-year-old victim was struck with an arrow and
succumbed to his wounds at a hospital. Four people were arrested and dozens of bows and
arrows were seized following the violence, police said.

 A teenager was arrested following a clash between two youth groups on Jl. Urip Sumoharjo
in Makassar on 5 May 2020. The arrest followed complaints by residents about youths,
some armed with bladed weapons, pelting rocks at each other. The clash reportedly
involved an old grudge. Two bows and arrows were seized from the suspect.

 Two youths were injured in a clash at the Lepping housing complex on Jl. Jalan Kumala II in
Tamalate district, Makassar at around 7:30 PM local time on 2 May 2020. The violence
broke out after a group of youths from the neighboring Kumala II housing complex attacked
their rivals at the Lepping housing complex. The youths attacked each other with arrows,
rocks and glass bottles. Several homes were damaged in the melee.

 A hospital providing free testing for the coronavirus in Makassar, South Sulawesi was pelted
with stones following rejection by residents, police said on 22 April 2020. Windows at the
Sayang Bunda Hospital in Rappocini district were shattered with stones hurled by
unidentified culprits, Rappocini Police crime unit chief 1st Insp. Nurtjahyana said.

 The attack occurred late on 21 April 2020. Police said a day before a group of protesters
gathered in front of the hospital to reject its voluntary services related to coronavirus
testing, fearing the virus might spread in their community. Makassar is scheduled to
implement the expanded social distancing (PSBB) policy on 24 April as confirmed cases of
the coronavirus in South Sulawesi are the highest outside of Java with 387 infections and 30
deaths as of 22 April.

 Two groups of residents attacked each other on Jl. Kumala Dua in Makassar early on 15 April
2020. The violence was triggered by an old grudge. Police personnel were forced to fire
warning shots and tear gas to disperse the mob. Several bladed weapons were seized from
the scene. No arrests were reported in any of the incidents.

17
 A house was damaged in a clash between two youth groups on Jl. Andi Tadde in Tallo
district, Makassar early on 13 April 2020. One group armed with bows and arrows and
stones attacked the rival group for unknown reasons. The groups dispersed when the police
arrived. No arrests or injuries were reported.

 Three youths were arrested for public brawling on Jl. Tinumbu in Makassar on 8 April 2020.
Police said the clash was linked to an old grudge between two rival groups. The mob
dispersed when police arrived. No injuries were reported. A spear, arrows, glass bottles and
rocks were seized.

 A food stall and a car were set on fire by a mob in apparent retaliation over a prior assault in
Jipang village, South Bontonompo district, Gowa regency, South Sulawesi on 30 March 2020.
Police on 31 March 2020 said the attack was carried out by the family members of a man
who was killed in a clash on 29 March which involved the coffee stall’s owner.

 Two groups of youths were involved in a clash on Jl. Tinumbu in Bontoala district, Makassar
on 26 March 2020. Residents said the clash had been going on for several nights, causing
property damage in the neighborhood. Police were forced to use tear gas to disperse the
clash earlier.

 A car and a motorcycle were set on fire during a clash involving motorcycle gang members
and residents on Jl. South Veteran in Maricaya sub-district, Makassar district, Makassar early
on 7 March 2020. Police said the bikers pelted stones at the residents following a dispute
over a motorcycle race in the area. Police officers fired warning shots to end the melee. No
injuries or arrests were reported.

 Two people were injured in a brawl between students of Makassar Senior High School 11 on
Jl. Andi Mappaodang in Tamalate district, Makassar on 26 February 2020. Police said the
brawl broke out inside the school following an earlier confrontation between junior and
senior students. A student and a school administrator were injured after being struck by
stones and shattered glass. The students, who were armed with bladed weapons, were later
dispersed by police. Three students were arrested. Students who were not involved in the
brawl were sent home early for safety reasons.

 Dozens of people were injured and a car driver was assaulted in a road rage incident on Jl.
Urip Sumoharjo in Panakkukang district, Makassar late on 25 February 2020. The driver
intentionally hit dozens of motorcyclists and pedestrians along the road before being
intercepted by a mob near the Tello Traffic Police station. Dozens of people sustained light
injuries and nine of them, including a child, were hospitalized. Police said officers were
forced to fire warning shots to stop the mob from further damaging the car and assaulting
the driver, who is believed to be mentally ill. The culprit also threatened to kill his wife and
son who were inside the vehicle.

 Two teenagers were injured in a clash between two groups of youths in Lambarese village,
Burau district, East Luwu regency on 17 February 2020. No arrests have been reported and
the cause of the violence is unknown.

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 Two men believed to be responsible for a Molotov attack targeting a resident's home on Jl.
Tidung in Rappocini district, Makassar, were arrested on Jl. Daeng Tata Raya and Jl.
Karunrung in the district on 18 January 2020. Police on 19 January said the attack, which
occurred on 1 December 2019, damaged a car belonging to the homeowner. However, no
casualties were reported. Police said the motive behind the attack was an old grudge with
the homeowner's son.

 Eight students were arrested and an air-soft gun, bladed weapons and bows and arrows
were seized after a clash broke out at the Makassar Muhammadiyah University on Jl. Sultan
Alauddin in Rappocini district, Makassar on 16 January 2020. Witnesses said 10 masked men
gained entry to the campus after threatening security guards with bows and arrows. They
attacked a student center at the engineering faculty. The situation escalated when about 30
engineering students retaliated. The clash continued off campus on Jl. Sultan Alauddin and
Jl. Talasapang 1, and only ended after police officers were deployed. No casualties were
reported.

 Three personnel from the Public Order Agency (Satpol PP) were hospitalized for injuries they
sustained when an eviction turned violent at the Andi Mattalatta Mattoanging Stadium in
Mario sub-district, Mariso district, Makassar on 15 January 2020. Dozens of members of
private entity the South Sulawesi Sports Foundation (YOSS), which had been managing the
stadium for several years, blockaded the entrance and pelted the officers with various
projectiles. One of the officers was wounded by an arrow, while the other two were struck
in the head by stones that were being thrown at them. The stand-off ended after police
arrived and fired tear gas at the occupants. One member of the foundation was arrested
nearby with four Molotov cocktails in his possession.

 A village head was assaulted in Bentenge village, Mallawa district, Maros regency on 9
January 2020. The culprit attacked the victim with a gardening tool and a bladed weapon
over a land dispute, causing a broken hand and several slash wounds to the village head's
body. The assailant was arrested.

 Three people were injured in a clash between two groups of residents in Bulusuka village,
Bontoramba district, Jeneponto regency on 31 December 2019. The clash broke out when
members of one of the groups were told not to ignite fireworks in the area. The victims
were attacked with bladed weapons, while two houses were damaged in the melee. No
arrests were reported.

 A student was injured in a clash between two groups at the Makassar Muhammadiyah
University (Unismuh) in Gunung Sari sub-district, Rappocini district, Makassar, South
Sulawesi on 11 December 2019. Students armed with bladed weapons and arrows attacked
each other at around 8:30 PM local time, allegedly over the chairmanship of an association.
The injured student was struck in the head by an arrow. At least 14 students were arrested
over the clash.

 A security guard was severely injured in an attack, reportedly involving a land dispute, at a
housing complex on Jl. Manggis in Ujung Pandang district, Makassar on 10 December 2019.
Police said a family of three allegedly attacked the 50-year-old victim and stabbed him

19
 multiple times at a neighborhood watch post early in the morning. The suspects, who are
still at large, were warned earlier to evacuate their home due to the land dispute.

 Two people were injured in a clash between students from Makassar State University (UNM)
in Parangtambung sub-district, Tamalate district, Makassar on 21 November 2019. Police
said the students from two different faculties attacked each other with bladed weapons and
arrows. The victims were hospitalized after being shot with arrows. The violence ended
when dozens of police personnel arrived at the scene. No arrests were reported. A previous
clash occurred at the UNM campus on 21 October during which two students were stabbed
and injured. Police said the clash was triggered by a scuffle between students from the two
faculties on 17 October. No arrests were reported.

 Residents found a headless body at the bottom of a cliff in Pangapusang hamlet, Taring
village, Biringbulu district, Gowa regency on 11 November 2019. The alleged culprit,
identified as the victim’s nephew, turned himself in soon afterwards. A bladed weapon
believed to have been used in the murder was recovered from the scene. Police said a land
dispute between family members may have been the motive.

 Two men were injured in a violent protest against a sand mining operation by privately-
owned PT Alam Sumber Rejeki (ASR) near the Saddang River in Salipolo village, Cempa
district, Pinrang regency on 5 November 2019. Tensions escalated when around 250
residents armed with bladed weapons from the villages of Salipolo and Bababinanga arrived
at the site and demanded the company cease its activities. The residents claimed the mining
activity has caused floods in the villages, forcing many residents to evacuate from their
homes. An argument between the two sides at the mining site led to a clash. A 55-year-old
farmer from the village and a 50-year-old worker from the mining site were hospitalized
after sustaining stab wounds. No arrests were reported. Environmental watchdog Friends of
the Earth Indonesia (Walhi) has called for an official probe to clarify the legal status of the
mining operation following allegations that PT ASR has committed zoning violations since
2017. Salipolo village is strictly a non-mining zone, according to local regulations. Residents
of the village held several protests against PT ASR's operation at the governor's office in
Makassar and the Pinrang Regional House of Representatives (DPRD) in October. The
protesters also claimed that five villagers had received warning letters from the Pinrang
Police after being accused of obstructing the company's mining activities.

 Four homes and several motorcycles were set on fire over the death of a resident in Loeha
village, Towuti district, East Luwu regency on 5 November 2019. Angry relatives of the victim
set the homes ablaze when they discovered the victim had been beaten by 10 men earlier in
the day. The victim was stabbed in the neck with a bladed weapon when he attempted to
break up a fight between the culprits and another man, allegedly over a dispute related to
the ownership of land. The victim succumbed to his wounds while being rushed to a public
health center (puskesmas). No arrests were reported.

 Three people were injured in a clash between students from different faculties at a private
Islamic university in Panaikang sub-district, Panakkukang district, Makassar on 28 October
2019. Two groups of students attacked each other during the commemoration of Youth
Pledge Day near a flyover on Jl. Urip Sumoharjo. One of the students was seriously wounded
by a bladed weapon. No arrests were made.

20
 Two people were stabbed and injured after a clash broke out at the Makassar State
University (UNM) in Parang Tambung sub-district, Tamalate district, Makassar on 21
October 2019. Students from the Art Faculty attacked students from the Language Faculty at
around 8:00 PM, police said. A motorcycle was set on fire and several windows were
shattered. Police said the clash was triggered by a scuffle between students from the two
faculties on 17 October 2019. No arrests were reported. A similar clash occurred at the
university on 26 May 2019 when a classroom was set ablaze after rival student groups
attacked each other over an old grudge.

 The administration office for Biangkeke village in Pa’jukukang district, Bantaeng regency was
vandalized by a mob on 17 October 2019. Earlier in the day, around 200 residents staged a
protest at the Bantaeng Community Development, Women’s Empowerment and Child
Protection Agency in Lembang sub-district, Bantaeng district. They demanded a manual vote
recapitulation in a village head election held the previous day, alleging foul play. The
protesters later moved to the village administration office and attacked it with stones at
around 7:00 PM local time, as their demand was ignored. They also vandalized the official
residence of the Biangkeke village head and the office of the local voting committee (PPS).
The mob dispersed at 1:00 AM following mediation with South Sulawesi Police officers. No
arrests or casualties were reported.

 A printing services store was damaged in a Molotov cocktail attack on Jl. Sultan Alauddin II
in Tamalate district, Makassar on 16 October 2019. The incident took place at around 12:50
AM when two men on a motorcycle threw a firebomb into the building, which was still open
at the time. A copier, a stack of papers and a sofa caught fire. No casualties were reported.
The attackers fled and the motive behind the attack remains unclear. The owner said it was
the third attack on his business in the last six months. The outlet was previously attacked
with stones and arrows in August.

 Dozens of students held a protest which turned violent at the Makassar Regional House of
Representatives (DPRD) on Jl. Pettarani in Rappocini district on 16 October 2019. A brief
scuffle erupted when the students burned tires to block the road. No casualties were
reported. The protest was staged to reject President Joko Widodo's inauguration, which is
scheduled to take place on 20 October in Jakarta.

 A clash broke out between youths and students of a vocational high school on Jl. Mesjid
Raya in Somba Opu district, Gowa regency on 10 October 2019. The violence erupted at
around 4:30 PM local time when both groups began pelting stones at each other. Reports
said the brawl was triggered by a prior conflict. No casualties were reported.

 Two men, aged 60 and 55, were killed during a fight over a land dispute in Lacappa hamlet,
Taccipi village, Amali district, Bone regency on 26 September 2019. The victims were
reportedly involved in an argument with three other men over claim to an empty lot. They
died after being stabbed with bladed weapons during the melee. The three culprits were
arrested.

21
 Two students and a police officer were injured when a protest turned violent at the South
Sulawesi Governor's Office in Panakukkang district, Makassar on 16 September 2019
Tensions escalated when a stone was pelted towards the students from inside the office,
allegedly thrown by Public Order Agency (Satpol PP) personnel. The students responded by
pelting stones at the Satpol PP personnel and attempting to forcibly enter the building. The
students and the police officer sustained head injuries after being struck by stones. No
arrests were made. The protest was staged to reject the government's plan to double the
premiums for the National Health Insurance (JKN) and Indonesia Health Card (KIS) programs.

 A 17-year-old male was injured and a car was vandalized in a road rage incident on Jl. Syekh
Yusuf in Gunung Sari sub-district, Rappocini district, Makassar on 10 September 2019. Angry
residents pelted stones at the car when they witnessed the teenager driving the vehicle hit a
street vendor at around 1:00 PM local time. The teenager was fleeing from several motorists
he hit earlier. The driver suffered an injury to his head. Police said the car belonged to the
teenager's father who is a local lawmaker. No arrest was reported.

 A home and a motorcycle repair shop were damaged in a series of clashes involving two
groups of youths on Jl. Banta-bantaeng in Banta-bantaeng sub-district, Rappocini district,
Makassar late on 26 August 2019. The youths attacked each other with bamboo sticks and
stones, police said. A man was arrested for his alleged involvement in the violence. No
casualties were reported. The two groups also clashed at the same location in the early
hours of 25 August. The violence allegedly was triggered by a personal dispute.

 A 19-year-old supporter of the provincial-based PSM Makassar soccer club was wounded by
an arrowhead near Andi Mattalatta Stadium on Jl. Padjongan Daeng Ngalle in Mariso
district, Makassar on 28 July 2019. The victim was exiting the stadium area when three
people on a motorcycle suddenly shot an arrow that hit the victim in the chest. One pulled
out a knife in an attempt to attack the victim before the arrow was fired. The victim was
hospitalized, while the perpetrators and motive behind the attack remained unknown.

 Two people were injured when a mob attacked a bus carrying players of the Jakarta-based
Persija soccer club at the Andi Mattalatta Mattoanging Stadium in Mario sub-district, Mariso
district, Makassar on 27 July 2019. Supporters of the PSM Makassar soccer club pelted
stones at the bus. A Persija player and a club official were injured in the attack while the bus
was left with shattered windows. Following the attack, the Indonesian Soccer Association
(PSSI) postponed the second match of the Indonesian Cup final between the two clubs
scheduled to be held on 28 July. No arrests were reported.

 Two people were injured in a clash between two groups of students from three universities
in Tanjung Merdeka sub-district, Tamalate district, Makassar on 7 July 2019. The groups
attacked each other with arrows and stones at a coastal tourist area before police arrived
and ended the melee. Two people were injured and several motorcycles were damaged.
Four students from the University of Muhammadiyah Makassar, the Indonesian Muslim
University, STIKI Makassar and a resident were arrested. Twenty-five arrows and four bows
were seized.

22
Narcotics

 An alleged drug courier was arrested with 1 kg of crystal methamphetamine during on Jl.
Jampue in Aluppang hamlet, Maacorawalie sub-district, Watang Sawitto district, Pinrang
regency on March 28, 2020. Police said the drugs are believed to have come from Wakatobi
in Southeast Sulawesi.

 Three drug dealers were arrested with 1.8 kg of crystal methamphetamine in Makassar on 2
March 2020.

 Three drug traffickers were arrested with 1.3 kg of crystal methamphetamine in Mallang
village, Duampanua district, Pinrang regency on 20 January 2020.

 Two people were arrested with 5,000 ecstasy pills in Makassar on 15 January 2020. The
arrests came after a tip-off that the drugs would be delivered to a house on Jl. Daeng Tata in
Tamalate district, Makassar. The narcotics were hidden inside a water pump. Police said the
pills were intended for distribution in the province. The suspects reportedly previously
served time at the Makassar Penitentiary for a similar offense. One of the suspects was shot
in the leg while trying to escape.

 A man was arrested with 40 small packages of crystal methamphetamine at a home in

Mandonga district, Kendari on 6 January 2020. Police said the suspect was allegedly part of a
drug syndicate led by a convict currently serving time at a prison in the city.

 A police officer was arrested in Tompotikka sub-district, Wara district, Palopo, for
possession of crystal methamphetamine, police said on December 26, 2019. Five packages
containing small amounts of the narcotic were found in a raid on the brigadier-ranked
officer's boarding house on 25 December 2019.

 A police officer with the rank of second inspector was arrested along with a woman at a
hotel in Balang Toa sub-district, Binamu district, Jeneponto regency on 9 November 2019.
Police said the suspects were allegedly consuming an unspecified amount of crystal
methamphetamine. They were taken to Jeneponto

 A man was arrested with 1 kg of crystal methamphetamine in Rappang sub-district, Panca

Rijang district, Sidenreng Rappang regency on 7 October 2019. The drugs were hidden inside
Chinese tea packages. Authorities refused to provide more details, citing an ongoing
investigation.

Kidnapping

 A former soldier was arrested in Bone regency for allegedly kidnapping a 10-year-old boy on
3 March 2020. Police said the suspect was dismissed from the Armed Forces (TNI) in 2018.
The victim was identified as the son of the suspect's ex-wife. The former soldier kidnapped
the child from a playground near a convenience store on Jl. Besse Kajuara in Watampone at
10:00 AM local time. He carried the child to his house and assaulted him with a broom for

23
 misbehaving, causing bruises to his body. Police rescued the boy and arrested the suspect
hours later. According to the victim's family, the suspect suffers from a mental illness.

 A man was arrested for allegedly kidnapping and raping underage girls in Makassar, police
said on 3 October 2019. The arrest occurred at a home on Jl. Syech Yusuf in Katangka village,
Somba Opu district, Gowa regency, Makassar Police crime unit chief, 2nd. Insp. Ahmad Syah
Jamal said. The 40-year-old suspect kidnapped five children and raped two of them, Jamal
said, without elaborating. The suspect searched for children who were not accompanied by
adults. He would pretend he was ordered by the victims' parents to pick them up. The man
was arrested with jewelry stolen from his victims, Jamal said, adding the suspect was shot in
the leg for resisting arrest.

Sexual Assaults

 A teenager was arrested for allegedly raping and assaulting a 15-year-old girl in Mebali sub-
district, Gandang Batu Silanan district, Tana Toraja regency on 24 May 2020. The suspect hit
the victim and raped her in a toilet while she was unconscious.

 A man was arrested in Timampu village, Towuti district, East Luwu regency on 24 May 2020
for allegedly sexually assaulting his daughter several times over the past two years. Police
said the case was uncovered after the victim admitted to her friend that she was raped
repeatedly by her father while her mother was sleeping at night.

 A man was arrested on 4 May 2020 for allegedly raping a 15-year-old girl near the Masamba
traditional market in Masamba district, North Luwu regency. The suspect sexually assaulted
the victim near a sports field in Mappedeceng district before taking her to the market where
she was also raped by four accomplices on 2 April 2020. The other suspects remain at large.

 Two men were arrested in a separate sexual assault cases in Luwu regency, police said in
late March 2020. The first suspect was arrested for raping a teenager. He later confessed
that he was also raped by another man posing as a journalist, identified as Aswandi, last
year when he was still a minor. Police detained Aswandi at his house in Ponrang district,
Luwu on 29 March and discovered two more victims of his crime.

 Two men were arrested for allegedly raping an 18-year-old female in South Sulawesi's
capital of Makassar on 28 August 2019. The victim was allegedly gang-raped at a rented
room in Manggala district at around 1:00 AM by five men, one of whom she met on
Facebook, said Makassar Police chief Adj. Sr. Comm. Indratmoko. Indratmoko said the victim
was picked up by the acquaintance on Jl. Hertasning in Rappocini district, also in the city,
before she was raped. The perpetrators also stole Rp400,000 from the woman, Indratmoko
said, adding the victim was found crying on Jl. Sungai Saddang in Makassar district several
hours after the sexual assault. Sexual violence against women and minors is rampant in
Indonesia.

24
Frauds/Scams/Extortions

 Three people were arrested in early July 2020 for their involvement in an internet banking
scam in Tulung Selapan district, Ogan Komering Ilir regency. Police said the suspects tricked
cellular provider operators to grant access to the victim’s SIM card. The suspects used the
information to gain access to the victim’s mobile and internet banking accounts, stealing IDR
415 million.

 Four people were arrested and named suspects for defrauding more than 4,000 people in an
investment scam that caused IDR 131 billion in estimated losses in Tana Toraja regency,
police said on 18 June 2020. Tana Toraja Police chief Adj. Sr. Comm. Liliek Tribhawono said
the suspects ran the operation using an unregistered company named PT Axelle Jaya Trade
Asset Management, which provided asset trading services in foreign exchange markets. The
suspects were arrested following complaints by customers claiming that the company ran a
pyramid scheme, Tribhawono added.

 A 40-year-old woman was arrested for allegedly defrauding her friend out of IDR 1.3 billion
in Bulujaya village, Bulujaya sub-district, West Bangkala district, Jeneponto regency on 17
May 2020. The suspect convinced the victim that she could connect her to a shaman via
telephone who could cure her illness. The victim transferred the money to the shaman in
several installments since 2017. The shaman was later revealed to be the suspect herself,
after the victim realized that the shaman’s bank account was the same name as the suspect.

 A married couple was arrested for allegedly defrauding a neighbor out of millions of rupiah
in Mandai district, Maros regency on 3 April 2020. Mandai Police crime unit chief 1st. Insp.
Amilang said the suspects, who already owed the victim Rp6 million, told him they knew a
shaman who could multiply his money. The couple told the victim to give them several
million rupiah more and wait for the shaman's arrival at his home to perform the ritual. The
victim reported the suspects to the police after the shaman failed to show up after several
days.

 A man was arrested in Bone regency for fraud involving a total of IDR 286 million on 16
March 2020. The suspect allegedly sold two cars for IDR 176 million he borrowed from the
first victim without informing the victim about the sale. He also borrowed IDR 110 million
from another victim to buy more cars he sold without notifying the victim. The suspect also
embezzled a car belonging to one of the victim's relatives.

 A man was arrested at his office in Jupanddang sub-district, Enrekang district, Enrekang
regency on 3 March 2020 for alleged fraud. He swindled his victims out of IDR 12.5 million
after convincing them to buy 87 trees to be processed into timber, which was never
delivered.

 Two people were arrested in Makassar for their alleged involvement in online fraud by
impersonating Jakarta-based PT Tempo Inti Media director, Toriq Hadad, police said on 12
July 2019. They hacked into Hadad's WhatsApp account and asked the victims (whose
numbers are on Hadad's phone contacts) to lend them an unidentified sum of money.
Jakarta Police special crime unit chief Sr. Comm. Iwan Kurniawan said the first suspect, who

25
 collected the money transferred to their bank accounts by the victims, was arrested in
Rappocini district, Makassar on 9 July 2019 while the hacker was apprehended at his
boarding house, also in the city. The arrests were made after Hadad filed a report on 2 July
2019. Police seized an ATM card, two cellular phones and also obtained CCTV footage from
the ATM as evidence.

Terrorism/ Extremism Incidents

 The National Police on 23 July 2019 identified an Indonesian couple who allegedly carried
out a suicide bombing at a church in Jolo, Philippines that left 22 dead and was claimed by
the Islamic State of Iraq and Syria (ISIS). The bombers were Rullie Rian Zeke and Ulfah
Handayani Saleh, allegedly members of Jamaah Ansharut Daulah's (JAD) branch in Makassar,
South Sulawesi, National Police spokesman Brig. Gen. Dedi Prasetyo told a press conference.
JAD is an umbrella organization in Indonesia supporting ISIS.

Zeke and Saleh were identified following the arrest of a suspected militant, Noviandri, in
Padang, West Sumatra last week and another JAD suspect in East Kalimantan. Zeke and
Saleh allegedly entered the Philippines illegally after being deported from Turkey in 2017,
police said. They left Indonesia to join ISIS in March 2016 with their three children. But
before they could reach Syria and Iraq, they were arrested in Turkey in January 2017 and
deported to Indonesia that same month. In Indonesia, they went through a short
rehabilitation program and were then released. They apparently later decided to pursue
their cause in Mindanao instead and took their children with them. The suicide bombers
were reportedly assisted by another wanted Indonesian terrorist identified as S, who is
based in Afghanistan. Twenty-two people were killed as two bombs hit a church in Jolo on
the morning of January 27, 2019 as mass was being celebrated, and was followed by a
second explosion in the parking lot as troops responded Hours later, ISIS claimed
responsibility for the attack via its Amaq news agency. Philippine Interior Minister Eduardo
Año said the suicide attack was carried out by an Indonesian couple with the help of Abu
Sayyaf militants. Abu Sayyaf is a militant organization notorious for kidnappings and
extremist factions and has pledged allegiance to ISIS.

Extremism/ Radicalism

 A man was arrested on 14 July 2020 after threatening to detonate an explosive at a

McDonald’s restaurant on Jl. A.P. Pettarani in Panakkukang district, Makassar. South
Sulawesi Police spokesman Sr. Comm. Ibrahim Tompo said the suspect, identified as 35-
year-old Muhammad Hasbi, on 13 July entered the fast food outlet, harassed a cashier and
made the bomb threat. The suspect later fled the scene on a motorcycle, he added. No
damage or casualties were reported. Based on witnesses testimony, the suspect was
arrested at a mosque on Jl. Urip Sumoharjo in Makassar the following day. Hasbo told police
that he committed the act because he despises foreign products.

 Tens of residents rallied in front of a home used to hold the Christmas Eve mass on Jl.
Wahidin Sudirohusodo in Caile sub-district, Ujung Bulu district, Bulukumba regency on 24
December 2019. The mob rejected the gathering claiming lack of permit. The rejection has
been ongoing since 2017 as the congregation said their proposal to build a church in the
regency has yet to be approved by the regional administration.

26
 The Makassar administration issued a circular in anticipation of the spread of Shia teachings.
The circular dated 9 September 2019 was signed by city administration secretary M. Ansar.
Acting Makassar mayor Iqbal Suhaeb on 10 September 2019 said the circular was based on a
recommendation from the Makassar branch of the Indonesian Ulema Council (MUI), the
country's highest Islamic authority. In the circular, the Makassar administration called on
residents not to participate in Shia events as they are deemed blasphemous. Ashura is the
10th day of the month of Muharram, which commemorates the martyrdom of Hussein, one
of the grandsons of the Prophet Muhammad, in the battle of Karbala, now in southern Iraq,
in 680. Shiites believe that only the descendants of Muhammad through Ali, Hussein's
father, can be true Islamic leaders. This belief is rejected by Sunnis, who constitute the
majority of Muslims in Indonesia and worldwide.

Jihadists increase activity in Poso Regency

For nearly 10 years, a ragtag group of militants based in the hilly jungles of Poso, Central
Sulawesi has proved to be a localized but very resilient terrorist threat to the government and
more recently the local population.

The Mujahedeen in Indonesia (MIT) terrorist group was born out of a major crackdown on
jihadist activity that began in 2010 and led to the deaths and incarceration of most of the
leaders and key players from a spate of al Qaeda-inspired bombings in Jakarta and Bali in the
2000s.

Since then, MIT has posed a localized but serious security threat, committing several bombings
in the Poso region and acting as a source of training and funding for other Islamic State of Iraq
and Syria (ISIS) militants throughout Indonesia.

Militants from the southern Philippines and ethnic Uighurs from the Xinxiang region of China
have also sought cooperation with MIT. But even at the height of its strength, MIT boasted no
more than several dozen members and has never conducted a successful operation outside of
the Poso area.

In addition, a joint police and military counter-terrorism operation has been in place in Poso
since 2016 with a mandate to neutralize the terrorist group. Whether by design or luck, this
band of jihadists in Central Sulawesi has shown a significant degree of resilience, despite the
sustained counter-terrorism pressure and changes in the jihadist group's leadership over the
past decade.

Since the death of MIT's founder Santoso, alias Abu Wardah, in 2016, the group has expanded
its recruitment and fundraising capabilities. MIT's current leader, Ali Kalora, sees the onset of
the coronavirus pandemic as a possible sign of the "end of times" and another reason to target
the security forces as they are preoccupied with addressing the unprecedented health crisis.

27
The remoteness of MIT's area of operations as well as years of security crackdowns against its
sister organization, the ISIS-linked Jamaah Ansharut Daulah (JAD), which has been responsible
for at least 13 terrorist attacks in Indonesia since early 2016, have also played indirect roles in
bolstering the fortunes of MIT.

However, history shows that when MIT and its leaders become too arrogant, the security forces
tend to push back hard. Sources have told Concord Strategic that the State Palace has
demanded an end to the threat from MIT.
This has already resulted in a series of arrests by the police's Detachment 88 counter-terrorism
squad throughout the county and the deployment of more soldiers to join the police-led
Tinombala security operation in Poso. Around 150 soldiers from the Army's Strategic Reserve
Command (Kostrad) also arrived in Poso in mid-August to help pursue the militants.

History

MIT had once been seen as flash in the pan in terms of militant networks in Indonesia, but
despite the solid abilities of Indonesia's counter-terrorism apparatus, the group has managed to
weather the capture and killing of its leaders as well as the rise and fall of ISIS' self-declared
caliphate in the Middle East.
MIT was the first terrorist group in Indonesia to make a public pledge of allegiance to ISIS' slain
founder Abu Bakr al Baghdadi in 2014.

A video of Santoso's oath of loyalty to ISIS was uploaded to YouTube in June 2014, causing alarm
among Indonesian officials who had yet to grasp the potential threat from ISIS' main
organization and its growing number of local supporters at the time.

MIT under Santoso was able to form low-level cooperation with the Syria-based global terrorist
group. At least seven MIT members are confirmed to have traveled to ISIS' now-defunct
"caliphate" in Syria and Iraq.

However, MIT can also trace its roots back to the Jemaah Islamiyah (JI) regional terrorist group,
which was responsible for major bombings in Jakarta and Bali in the 2000s.

MIT's main goal has always been the creation of an Islamic state in Indonesia. It was primarily
focused on targeting the "near enemy" – the Indonesian state – but anti-Western rhetoric also
featured in its propaganda, which is deeply rooted in the Salafist-jihadist ideology espoused by
ISIS as well as al Qaeda.

Since its founding, MIT has been responsible for several local attacks on residents, police and
soldiers, including a suicide bombing at a police station in Poso in 2013 and the murders of
several police officers in 2011 and 2012.

MIT was placed on the US' Specially Designated Global Terrorists list in September 2015, largely
due to MIT's support for ISIS.

28
Security operations have been launched continuously in the Poso region since 2012 targeting
MIT, including the launch in January 2016 of Operation Tinombala, involving members of the
National Police and the Armed Forces (TNI).

Roots of MIT

The rise of MIT and Santoso began in mid-

2010 when leaders of the terrorist-linked
group Jemaah Ansharut Tauhid (JAT)
decided to make Central Sulawesi their
main area of operations following a failed
attempt at uniting several militant
networks from Indonesia and the southern
Philippines at a terrorist training camp in
Aceh.
The camp, known as the lintas tanzim, or
"cross-organizational" project, sought to
unite jihadist groups.
Police officer examines body of slain terrorist after
shootout in Aceh Besar regency, Aceh in 2010. Tempo
The coalition included members of
KOMPAK, Darul Islam (DI), JI, JAT, Indonesian Mujahedeen Council (MMI), the Islamic Defenders
Front (FPI), Ring Banten and Wadah Islamiyah, which is closely associated with the Makassar-
based militia Laskar Jundallah.

The project was led at the time by one of Southeast Asia's most wanted terrorists, Dulmatin,
who was one of the leaders of the 2002 Bali bombings.

When police swooped down on the camp in the remote Jantho Mountains of Aceh in February
2010, it created a sort of "big bang" effect, scattering nearly 200 of Indonesia's most-active
jihadists across the archipelago.

Eighty of the militants were captured or killed in the aftermath of the police raids in Aceh,
including Dulmatin, Abu Bakar Ba'asyir and Kang Jaja – the head of the Ring Banten terrorist
group – a DI offshoot.

Those who escaped the police crackdown re-settled in traditional terrorist hotbeds, such as
Bima, West Nusa Tenggara; Medan, North Sumatra; Solo, Central Java; Poso, Central Sulawesi
and parts of West Java and Jakarta.

Over time, this leaderless diaspora of jihadists, bolstered by new, younger recruits, began to
gradually link up once again, create new groups and cells and formulate plans to obtain funding
and continue with their quest of turning Indonesia into a country ruled by Islamic law.

29
It was in this environment that the early stages of MIT were formed, but Santoso's history with
Islamist militancy was rooted in the tumultuous years following the fall of the late former
autocrat Suharto in 1998.

Santoso was a graduate of Darusyahadah, an Islamic boarding school in Boyolali, Central Java
connected to JI and the network of slain terrorist mastermind Noordin M. Top.

Santoso had served as a commander of an Islamist group when sectarian conflict erupted in
Poso in December 1998. In November 2003, Santoso was sentenced to four years in prison by
the Palu Administrative Court in Central Sulawesi in a case involving firearms possession and
attempted murder.

In 2009, Santoso was recruited by Mustofa, alias Abu Tholut, to conduct military-style training in
Poso. Tholut was later jailed for terrorist activities and attempting to smuggle weapons into
Indonesia from the southern Philippines.

Santoso was involved in the May 2011 shooting of three police officers at a branch of Bank BCA
in Palu, after joining the group of local cleric Ustad Yasin and forming a JAT branch in Poso.

Yasin remains a key figure in the recruitment of personnel for MIT and allegedly provides
indirect support for the group through his Islamic boarding school in Poso.

Following disagreements with JAT's leadership in 2011, Santoso broke away and together with
Daeng Koro formed MIT, announcing the group in a series of postings on hacked police websites
the following year.

Santoso was killed by counter-terrorism forces in Poso on July 18, 2016, several months after his
second-in-command Koro was arrested. Since then, MIT has been led by Kalora, who has shown
more leadership abilities than his predecessors.

Despite Santoso's previous status as the most-wanted terrorist in Indonesia for five years, MIT
has never posed much of a threat outside of the Poso area.

The group did however serve a role in training militants from across the archipelago and some
foreign countries in the jungles of Poso and played a key role in maintaining cooperation
between different domestic militant networks.

However, unlike the al Qaeda-linked JI, MIT does not have a history of maintaining very deep
links with transnational groups.

The ISIS threat in Indonesia hardly forms a coherent and united front, which, despite making it
less coherent operationally, also makes it challenging to tackle. It is largely comprised of pledges
of support by individuals as well as smaller local movements such as MIT.

30
Coronavirus rejuvenation

Kalora has viewed the emergence of the coronavirus as a sign and ally in his quest to defeat
MIT's enemies, often linking the pandemic to Islamic "end of times" prophesies in his
propaganda.
This renewed enthusiasm by Kalora as well as a handful of young recruits appears to have given
MIT the drive to commit more violence.

While the members of other ISIS-linked groups in Indonesia continue to lick their wounds from
years of sustained counter-terrorism operations, Kalora has remained relatively active.

He has increased MIT's propaganda profile, appearing in videos calling for attacks and showing
the beheading of locals accused of cooperating with the security forces.

Since March, members of MIT have been blamed for killing four civilians and wounding two
police officers in separate incidents. The militants allegedly also kidnapped several locals in Poso
suspected of cooperating with the authorities.

In the most brazen incident, two MIT members were killed in a raid on April 15 after they shot
and injured a police officer in Poso several hours earlier.

The officer was shot in the chest during a hit-and-run attack by two armed men on Jl. Pulau Irian
Jaya in Gebangrejo, Poso regency. The suspects opened fire from a motorcycle at two officers
who were stationed outside a branch of a state-owned bank.

Other nearby officers returned gunfire at the suspects. However, the suspects managed to flee
the scene. Police later intercepted them in Moengko village, where both were shot and killed.

Police also found homemade bombs wrapped around the bodies of the two suspects, identified
as Ali, alias Darwin Gobel, and Muis Fahron, alias Abdullah, as well as a handgun, cellular phone
and several rounds of ammunition.

On June 2, the bodies of two farmers suspected of being killed by MIT militants were found with
gunshot wounds at a plantation near the Gayatri Mountains in Maranda village, North Poso
Pesisir district. The area is a known stronghold of the terrorist group.

On June 7, a police officer was injured in a shootout with alleged MIT members, also in North
Poso Pesisir district.

On August 9, two farmers from Sangginora village in South Poso Pesisir district were abducted
and one of them murdered by a group of men believed to be MIT members.

Endgame

31
Despite MIT's wavering fortunes, years of activity by the militants in Poso have served as an
example for other terrorist networks in Indonesia.
While Santoso and Kalora have failed to pull off a major terrorist attack, MIT has provided an
avenue for training and relationship-building between militant cells from across the county.

MIT's leadership has operated several terrorist training camps in the jungles of Poso since 2011,
indoctrinating and bolstering the capabilities of jihadists from Medan, North Sumatra; Bima,
West Nusa Tenggara; and East Java, creating a jihadist triangle of cells that share the goal of
establishing an Islamic state in Indonesia.

While the threat of terrorism in Poso is largely contained due to the ongoing Tinombala
Operation, it is unlikely to be eliminated from the region.

Poso has long been seen as a secure location by militants, especially after hundreds of jihadists
infiltrated the area during sectarian violence there in the early 2000s that claimed thousands of
lives.

MIT is also the only militant group since the DI rebellion in the 1950s and early 1960s to have a
claim over territory, a feat that serves as inspiration for jihadists in other areas of the country.

This also makes the Poso region hugely symbolic to the wider domestic terrorist movement.

However, with several potential terrorist hotspots across the country, some observers say the
logic of maintaining the large-scale counter-terrorism action in Central Sulawesi is questionable,
especially if Kalora and his follower are not neutralized soon.

While the operations have resulted in the arrests and deaths of several dozen alleged terrorists
and have largely kept the threat from MIT confined to the Sulawesi region, the results are seen
by many as inadequate relative to the funding and resources expended.

It is clear from the recent surge in terrorist activity in Central Sulawesi that the remaining
members of MIT are not keen to go down without a fight, with ISIS-linked propaganda in
Indonesia recently calling for jihadists from across the archipelago to join the fight in Poso.

But if the renewed counter-terrorism push brings an endgame in Poso, the government will
need to apply the lessons learned from years of operations against MIT to prevent the
emergence of more similar groups and the localized instability they inevitably cause.

32
Annex D

List of Mass Organization 2015/2019

Index Name of Organization Registration Number and Key Personnel Date of Address Validity Status
Date Establishment
1 Purna Prakarya Muda 220-19-17/0001/I/2017 Chairman: Hamid, S.Ag. MA 17 October 2006 Mamara hamlet, 2016 - 2022 Active
Indonesia, youth Secretary: Muharni, S.AN Salubua Sub-District,
association Treasurer: Andi Nurdiana, S.Pd Suli Barat District
2 Central Board of 220-19-17/0003/II/2017 Chairman: Paisal 5 August 1958 Tirowali Sub-District, 2017 - 2022 Active
Indonesia Luwu Secretary: Ahmad Syawal Ponrang District
Student Association Treasurer: Annha Fabryan
(PP-IPMIL)
3 Village Consultative 220-19-17/0017/IX/2017 Chairman: Ridwan Mabbi, S.Ag 12 March 2014 Jl. Andi Mukkulau 24, 2017 - 2022 Active
Assembly Secretary: Irham As’ad, S.Ag Lamunre Sub-District,
Communication Treasurer: Sumarling North Belopa District
Forum (FK-BPD)
4 Luwu Raya Sailor 220-19-17/0012/VII/2017 Chairman: Miswar Paturusi 27 April 2017 Pammanu Sub- 2017 - 2022 Active
Association (KPLR) Secretary: Supriadi Sahude District, Belopa
Treasurer: Albar District
5 Karang Taruna, youth 220-19-17/0010/IV/2017 Chairman: Sul Arrahman 2 February 2016 Barana Pance 4 area, 2017 - 2022 Active
organization Secretary: Ihlas North Belopa
Treasurer: Achmadi Ahmad
6 Luwu Chapter of 01/220/Kesbang/I/2016 Chairman: Zul Arrahman 31 December Luwu Regency Office 2016 - 2021 Active
Indonesia National Secretary: Ihlas 1966 Complex area, Belopa
Sport Committee Treasurer: Achmadi Ahmad
(KONI)
7 Indonesia Tapak Wali 220-19-17/0002/I/2016 Chairman: Khairil, Mmg 7 February 2005 Jl. Andi Makkulau 2016 - 2021 Active
Breathing Martial Art Secretary: Rifaldi Dusun, North Belopa
Organization Treasurer: Fitriani, Amd. Keb. District
8 Luwu Boyscout 220-19-17/0008/V/2016 Chairman: H. Syaiful Alam, SE,MM 20 May 1961 Simpurisiang Building, 2016 - 2021 Active
nd
Chapter Secretary: Andi Iskandar, S.Sos 2 Floor
Treasurer: Drs. Muh. Jufri
9 Muhammadiyah Luwu 220-19-17/0014/VI/2016 Chairman: Drs. M. Yamin Kibe 18 November Jl. Hati Damai 8, 2016 - 2021 Active
branch, moderate Secretary: Drs. Alimin, M.Pd 1912 Central Lamunre Sub-
Muslim organization. Treasurer: Drs. Bahar Nada District, North Belopa
District
10 Moslem Cleric 220-19-17/0016/VI/2016 Chairman: Tasrum, S.Pd. MM 1975 Senga Sub-District, 2016 - 2021 Active
Association Luwu Secretary: Alimuddin, SKM, M.Kes Belopa District
Chapter (PERSAMIL) Treasurer: Drs. H. Safar Hasyim
11 Senkom Police 220-19-17/0019/VII/2016 Chairman: Paidjo, S.Si. Apt 21 April 2005 Jl. Komplek Pasar 15, 2016 - 2021 Active
1
Index Name of Organization Registration Number and Key Personnel Date of Address Validity Status
Date Establishment
Partners (Public- Secretary: Mujahidin Agus, S.Pd, M.Si Belopa District
Police Communication Treasurer: Nur Hasan
Center)
12 Yamaha V-One 220-19-17/0021/IX/2016 Chairman: Kasman 14 July 2016 Senga Sub-District, 2016 - 2021 Active
Celebes Club Chapter Secretary: Anwar Subair Belopa District
Luwu Treasurer: Mahmuddin
13 Nahdatul Ulama (NU) 220-19-17/0030/XI/2016 Chairman: Drs. Abd. Samad S. M. Pd. I 23 October 2002 Jl. Sungai Paremang 2016 - 2021 Active
Luwu chapter, Secretary: Drs. Dirman Arkam 183, Sabe Sub-
moderate Muslim Treasurer: Drs. Safar Hasim District, North Belopa
organization District
14 Mosque Youth 220-19-17/0031/XI/2016 Chairman: Muh. Ashar Sabry, SH. I 15 November Masjid Agung 2016 - 2021 Active
Communication Secretary: Ramlan, S.Sos, M.Si 2007 complec, Tampumia
Forum Indonesia Treasurer: Drs. Safar Hasim Radda Sub-District,
(BKPRMI) Belopa District
15 Nahdatul Ulum, 220-19-17/0032/XI/2016 Chairman: H.M. Rusydi Hasyim 28 September Jl. Poros Cilallang, 2016 - 2021 Active
Islamic boarding Secretary: Rahmawati 2016 Tabbaja hamlet,
school founded by Treasurer: Iswana Kamanre District
former Vice President
Jusuf Kalla, linked to
NU.
16 GP Ansor, affiliated 220-19-17/0033/XII/2016 Chairman: H.M. Rusydi Hasyim 28 September Jl. Poros Cilallang, 2016 - 2021 Active
organization of NU Secretary: Kahar Agung 2016 Tabbaja hamlet,
Treasurer: Sulpiadi Kamanre District
17 Gasema Football Club 220-19-17/0033/XII/2016 Chairman: Taufik 16 November Jl. Salla, Belopa Sub- 2016 - 2021 Active
Belopa Secretary: Andi Alfian Ashari 2016 District, Belopa
Treasurer: Sedarianto Attas District
18 Indonesian Islam 220-19-17/0036/XII/2016 Chairman: Muchlisin, S.Sos 30 November Jl. Pramuka 13, 2016 - 2021 Active
Propagation Institute Secretary: Nurhasim, ST 2005 Central Lamunre Sub-
(LDII), Islamic hard- Treasurer: H. Deddy Waluyo District
line organization
19 Contact Committee 220-19-17/00027/XI/2016 Chairman: Dra. Hj. Hafisah Saleng 4 January 2012 Religious Agency, 2016 - 2021 Active
Board for Islamic Secretary: Nuraeni, S.Pd Luwu Regency Office
Propagation ( BKMT ) Treasurer: Hj. Hartini Haeridah, S.An
20 Indonesian Ulema 220-19-17/0029/X/2016 Chairman: Muh. Aswawi, BA 2 January 2012 Belopa Grand 2016 - 2021 Active
Council (MUI), Secretary: Drs. H. Armin, M.S.Sos.I Mosque
government affiliated Treasurer: Hj. Nurlaily, S.Ag
religious organization
21 Kub Rio Rennu 220-19-17/0028/XI/2016 Chairman: Rudianti Mukhtar, S. Ag 4 August 2016 Larompong District 2016 - 2021 Active
Larompong, local Secretary: Drs. Siming
2
Index Name of Organization Registration Number and Key Personnel Date of Address Validity Status
Date Establishment
organization Treasurer: Andi Rosanti
22 Walmas Adventure 220-19-17/0037/XI/2016 Chairman: Muh. Hajar Harike, S. Kom 18 August 2016 Jl. Poros Lamasi, 2016 - 2021 Active
Community Secretary: Jumrani Sandana, S.Pd Lamasi District
Treasurer: Arisa
23 Nature Lovers 220-19-17/0037/XII/2016 Chairman: Muh. Hajar Harike, S. Kom 1 May 2014 Pammanu Sub- 2016 - 2021 Active
Community Indonesia Secretary: Jumrani Sandana, S.Pd District, North Belopa
Adventure of Treasurer: Arisa District
Mountain Limit’s
24 Kindergarten Teacher 220-19-17/0035/XII/2016 Chairman: Idasari, S.Pd 30 November Islahul Ummah 2016 - 2021 Active
Association Indonesia Secretary: Syahriwati R, Pd. AUD 2005 Kindergarten, Belopa
Treasurer: Besse, S.Pd. AUD District
25 LCB Luwu Classic 220-19-17/0019/XII/2017 Chairman: Muhammad Arsyad 7 November Jl. Ali Semmang, 2017 - 2022 Active
Bikers Secretary: Sufian Sabila 2017 Tanamanai Sub-
Treasurer: Andi Mulyadi District, Belopa
District
26 Indonesia People 210/30- Chairman: Robby Tanduk Langi 19 September Kampung Baru Area, 2017 - 2022 Active
Miner Association Orsospol/Kesbang/XII/2017 Secretary: Hamsah Hamid 2014 Bajo District
(APRI) Treasurer: Burhanuddin
27 Anti-Corruption 210/510- Chairman: Drs. H. Abd. Hafid, M.Si 14 February Jl. Jannong, Malela 2017 - 2022 Active
Movement Orsospol/Kesbang/XI/2018 Secretary: Yasmin, SH. MH 2017 Sub-District, Suli
Organization Treasurer: Hamid, S.Ag District
28 Muslim Brotherhood 220-19-17/003/II/2018 Chairman: Sultan, DS 26 Jl. Topoka 2, Senga 2018 - 2023 Active
(PARMUSI), affiliated Secretary: Sahar Madjid September 1999 Sub-District, Belopa
to moderate Islamic Treasurer: Sufyan, SP District
United Development
Party (PPP)
29 Maddika Sitodong 220-19-9/001/II/2018 Chairman: Sahibu 16 September Babang Sub-District, 2018 - 2023 Active
Customary Secretary: Iswan Pajar, ST 2017 South Larompong
Organization Treasurer: Amiruddin District
30 Latimojong Art Studio, 220/25- Chairman: Hartono 2014 Saringan Hamlet, Ulu 2014/2015 Active
local cultural group Bid.III/Kesbang/VI/2014 Secretary: Hasran, S.Pd Salu Sub-District,
Treasurer: Hasirah Latimojong District
31 Alliance of Indigenous 210/451- Chairman: Muslim Andi Yusuf, SH. MH 23 November Jl. Karaeng Mate’ne Indefinite Active
Peoples of the Orsospol/Kesbang/VIII/2019 Secretary: Asdar Azis 2015 1, Larompong District
Archipelago (AMAN) Treasurer: Dharma Fidyasari, S.Pi,
MM
32 CSR Management 210/451- Chairman: Jumadil Kadir 31 May 2018 Jl. Poros Palopo Indefinite Active
Association Indonesia, Orsospol/Kesbang/IX/2019 Secretary: Sinta, S.PT Makassar, Cilallang
Luwu Chapter Treasurer: Ferawati Akbar Sub-District, Kamanre
3
Index Name of Organization Registration Number and Key Personnel Date of Address Validity Status
Date Establishment
District
33 Bethel Tabernakel 210/456- Chairman: Ezra Arung, S. Th 18 May 2005 Setiarejo Sub-District, Indefinite Active
Alfa Omega Church, Orsospol/Kesbang/IX/2019 Secretary: Amos Kandolla Lamasi District
Imanuel Setiarejo Treasurer: Markus Kimbu
Congregation
34 Bethel Tabernakel 210/457- Chairman: Agustinus Payung, S. Th 18 May 2005 To’lemo Sub-District, Indefinite Active
Alfa Omega Church, Orsospol/Kesbang/IX/2019 Secretary: Isak Palungan East Lamasi District
To’lemo Congregation Treasurer: Kristina
35 Adhyaksa Association 210/471- Chairman: Titin Dian Herawati 2008 South Senga Sub- Indefinite Active
Dharmakarini (IAD) Ormas/Kesbang/IX/2019 Secretary: Munira District, Belopa
Treasurer: Masrah District
36 Luwu Customary and 220/029- Chairman: Awaluddin 2014 Kariako, Buntu Karya 2014/2015 Active
Art Lover Community BID.III/Kesbang/IX/2014 Secretary: Firta, ST Sub-District, Ponrang
Treasurer: Sadda District
37 Luwu Bukkojo, local 220/360- Chairman: Samsir 2015 Jl. Sungai Paremang, 2015 - 2016 Active
cultural organization. Ormas/Kesbang/IX/2015 Secretary: Roni Barana Pance Sub-
Treasurer: Didit District, Belopa
District
38 Indonesia Journalist 220/347- Chairman: Saidil Syahar 2015 Muhajirin Hamlet, 2015 - 2016 Active
Association (PWRI) Ormas/Kesbang/X1/2015 Secretary: Surahman Gafar Komba Sub-district,
Treasurer: Sulfian Larompong District
39 Indonesian Amateur 220/71- Chairman: Drs. H. Alim Bahry 2008 Jl. Topoka 55, Belopa 2008 - 2016 Active
Radio Organization Orsospol/Kesbang/III/2015 Secretary: Ahmad Gajali M District
(ORARI) Treasurer: Yunus Sisong
40 Sikamali Community, 220/04- Chairman: Benyamin. P. A, SPAK 2014 Jl. Poros Palopo – 2014 - 2015 Active
local cultural BID.III/Kesbang/I/2014 Secretary: Martono Estepanus Siwa KM 31, Padang
organization. Treasurer: Hermanto Dudung Rayo Sappa Sub-District,
Ponrang District
41 Harapan Kita Youth 220/10- Chairman: Tapsir 2014 Jl. A. Leluasa, 2014 - 2015 Active
Organization BID.III/Kesbang/II/2014 Secretary: Martono Estepanus Barakasanda Hamlet,
Treasurer: Hermanto Dudung Rayo Bunga Eja Sub-
District, Kamanre
District
42 Women Organization 220/82- Chairman: Hj. Andi Tenri K 2014 Jl. A. Leluasa, 2014 - 2016 Active
(GOW) Orsospol/Kesbang/IV/2015 Secretary: Hj. Hasliana Nurdin Barakasanda Hamlet,
Treasurer: Suarni Muhaddar Bunga Eja Sub-
District, Kamanre
District
43 World War II Veteran 220/031- Chairman: Djamaluddin Makka 2014 Complex BTN Damai 2014 - 2015 Active
4
Index Name of Organization Registration Number and Key Personnel Date of Address Validity Status
Date Establishment
Legion BID.III/Kesbang/XI/2014 Secretary: Bayang.HT Baru Lorong III/5-6,
Treasurer: Hj. Besse Central Lamunre Sub-
District, North Belopa
District
44 Youth Organization 220/03- Chairman: Irzul Satir 2014 Sabe Sub-District, 2014 - 2015 Active
Sipakainge BID.III/Kesbang/I/2014 Secretary: Herianto North Belopa District
Treasurer: Rili