Refund Policy

Last Updated: June 2026

1. Overview

PT Anargya Aset Manajemen ("Anargya," "we," "us," or "our") is committed to fair, transparent, and investor-friendly refund practices. This Refund Policy ("Policy") describes the circumstances under which refunds may be available for fees paid in connection with our investment management services, mutual fund subscriptions, and advisory engagements. This Policy should be read in conjunction with the relevant Fund Prospectus, our Terms of Service, and OJK regulations governing the Indonesian mutual fund industry. All refund determinations are made on a case-by-case basis and in accordance with applicable Indonesian law and OJK regulations.

2. Refund Eligibility for Fund Subscriptions

Investors in Anargya mutual funds have the right to redeem their fund units (sell their investment) at any time, subject to the redemption terms in the applicable Fund Prospectus. However, redemption of units at the prevailing NAV/NAB (Net Asset Value) is distinct from a refund of subscription or management fees. Refunds of fees may be considered under the following circumstances:

• Duplication of subscription: Where a subscription transaction has been erroneously processed twice resulting in double payment, the duplicate amount will be refunded in full, less any unrecoverable bank or payment processing charges that we have incurred.
• Administrative errors: Where Anargya or its agents have made an administrative error in processing a subscription — such as incorrect unit allocation or fee application — that results in an overpayment by the investor, the excess amount will be refunded promptly upon verification.
• Erroneous transfer: Where funds have been transferred to Anargya's account in error without a corresponding subscription instruction, the full amount will be returned after identity and ownership verification, less applicable bank charges.
• Unauthorized transactions: Where a subscription has been processed without proper authorization from the investor due to system error, fraud, or security breach attributable to Anargya's systems, a full refund of the subscription amount will be provided.

To be eligible for a refund of fund subscription fees, the request must be submitted within thirty (30) calendar days of the transaction date and accompanied by supporting documentation, including: the transaction confirmation or receipt; bank statements showing the payment; a written explanation of the grounds for the refund request; and proof of identity matching the registered account holder. For unauthorized transaction claims, a police report or notarized affidavit may be required.

3. Refund Eligibility for Advisory Services

For bespoke investment advisory engagements, refund eligibility is governed by the terms of the individual advisory agreement signed between Anargya and the client. Generally, the following principles apply:

• Retainer fees: Retainer fees for ongoing advisory services are typically non-refundable for periods during which services were rendered. However, where services have been prepaid for a future period and the advisory agreement is terminated in accordance with its terms, the unearned portion of the retainer will be refunded on a pro-rata basis.
• Project-based fees: For discrete advisory projects with defined deliverables and milestones, refunds of milestone payments are subject to the specific terms of the engagement letter. Where Anargya has failed to deliver agreed-upon work products, the client may be entitled to a partial or full refund of fees paid for the undelivered portion.
• Cancellation before commencement: Where an advisory engagement is cancelled by the client in writing before Anargya has commenced substantive work, any prepaid fees will be refunded in full, less any reasonable costs already incurred by Anargya (such as data procurement, third-party research subscriptions, or travel booked specifically for the engagement), provided such costs are documented.

4. Non-Refundable Items

The following are generally not eligible for refunds:

• Market losses: Investment losses resulting from market movements, security selection, portfolio strategy, or any investment decision made in good faith in accordance with the stated investment objectives and strategy of the fund are not subject to refund. All investments carry risk, and investors should read the Risk Disclosure section of the Fund Prospectus carefully before investing.
• Redemption fees: Fees charged upon redemption of fund units, as disclosed in the Fund Prospectus, are non-refundable. These fees compensate the fund for transaction costs and are applied uniformly to all redeeming investors to protect remaining unitholders.
• Taxes and levies: Any taxes, stamp duties, regulatory levies, or other government charges applied to transactions are non-refundable, as they are remitted to the relevant authorities.
• Subscription fees already incurred: Standard subscription fees (biaya pembelian) paid at the time of investment — as distinct from the subscription amount itself — are generally non-refundable once the subscription has been processed and units have been allocated, as these fees compensate distribution and processing costs already incurred.
• Change of mind: Simply changing your mind about an investment after the subscription has been processed and the statutory cooling-off period (if applicable) has expired does not qualify for a refund of subscription fees. Investors who wish to exit their investment may do so through the standard redemption process at the prevailing NAV.

5. Refund Process

To request a refund, please follow these steps:

Step 1 — Prepare your request: Compile all relevant documentation, including: the transaction confirmation or receipt; bank statements showing the relevant payment; a detailed written explanation of the reason for your refund request; and proof of identity matching the registered account holder (KTP for Indonesian citizens, passport for foreign nationals).

Step 2 — Submit your request: Send your refund request by email to info@anargya-aam.it.com with the subject line "Refund Request — [Your Name] — [Transaction Date]." Alternatively, you may submit your request in writing to our registered office address: PT Anargya Aset Manajemen, The Manhattan Square Lantai 18 Mid Tower B, Jalan TB Simatupang Kav. 1-S, Cilandak Timur, Pasar Minggu, Jakarta Selatan 12560.

Step 3 — Review and verification: Upon receiving your request, we will acknowledge receipt within three (3) business days. Our compliance team will review your request, verify the transaction details against our records, and may contact you for additional information or clarification. We aim to complete our review within ten (10) business days of receiving all required documentation.

Step 4 — Resolution: You will be notified of the outcome of our review in writing. If your refund is approved, we will process the refund to the originating bank account within seven (7) business days of the approval date. If your refund is denied, we will provide a detailed explanation of the reasons for denial and, where applicable, inform you of any alternative remedies available to you.

6. Refund Methods

Payment method: Approved refunds will be returned via the same payment method used for the original transaction whenever possible. For bank transfers, refunds will be credited to the originating bank account from which the payment was made, subject to anti-money laundering verification. For payments made through third-party distribution platforms, refunds must be processed through the same platform in accordance with that platform's policies.

Processing time: Once a refund is approved, the processing time for the funds to appear in your account depends on your bank or payment provider. Typically: domestic Indonesian bank transfers take two to five (2-5) business days; international bank transfers may take five to fifteen (5-15) business days; and third-party distribution platform refunds follow the timeline specified by the respective platform. Anargya is not responsible for delays caused by intermediary banks, correspondent banks, or payment processors.

7. Exchanges and Service Modifications

While Anargya does not offer exchanges in the traditional retail sense, investors may switch between Anargya funds (subject to the switching terms specified in each Fund Prospectus). Switching fees, if applicable, are disclosed in the prospectus. For advisory services, where a client wishes to modify the scope of an engagement rather than cancel outright, we will work with you to adjust the engagement terms and fees accordingly. Any reduction in fees resulting from a reduction in scope will be credited to future billing or refunded as appropriate.

8. Damaged or Defective Services

Investment management and advisory services are intangible professional services. If you believe that our services have not met the standards described in our marketing materials, advisory agreement, or Fund Prospectus — for example, if you have received materially inaccurate reporting, experienced significant service delivery failures, or can demonstrate that Anargya has breached its fiduciary duties — you should contact us immediately to discuss your concerns. We are committed to resolving service issues promptly and fairly. In cases where service failures are substantiated and attributable to Anargya's error or negligence, we will take appropriate remedial measures, which may include: (a) Correcting the error at our expense; (b) Providing additional services without charge to make you whole; (c) Waiving or refunding fees directly attributable to the period of service failure; or (d) In serious cases of negligence or misconduct, compensation as agreed between the parties or as determined through the dispute resolution process described in our Terms of Service.

9. Special Circumstances

Force Majeure: Anargya shall not be liable for any failure or delay in processing refunds arising from circumstances beyond our reasonable control, including acts of God, natural disasters, war, terrorism, civil unrest, government orders, pandemic, labor disputes, telecommunications or internet failures, bank closures, or financial market closures. In such events, we will process refunds as soon as reasonably practicable once normal operations resume.

Regulatory suspension: If OJK or another competent regulatory authority suspends fund redemptions or otherwise restricts the movement of funds — for example, during periods of severe market disruption — refund processing may be temporarily suspended in compliance with such regulatory directives. We will communicate any such suspension to affected investors and resume processing as soon as regulatory restrictions are lifted.

10. Contact Information for Refund Requests

For all refund-related inquiries and submissions, please use the following contact details:

PT Anargya Aset Manajemen
Attn: Refund Processing
The Manhattan Square Lantai 18 Mid Tower B
Jalan TB Simatupang Kav. 1-S, Cilandak Timur
Pasar Minggu, Jakarta Selatan 12560
Indonesia
Phone: +62 21-29407184
Email: info@anargya-aam.it.com (subject line: "Refund Request — [Your Name]")

Please include your full name, investor account number (if applicable), transaction date, transaction amount, and a clear explanation of the refund request. Our team will acknowledge your submission within three (3) business days.

11. Policy Updates

We may update this Refund Policy periodically to reflect changes in our practices, service offerings, or legal obligations. Material changes will be communicated by: (a) Posting the updated policy on anargya-aam.it.com/return.html with a revised "Last Updated" date; and (b) For registered investors, providing at least thirty (30) days' notice via email or account notification. The revised policy will apply to transactions and refund requests submitted on or after the effective date of the updated policy. Refund requests submitted before the effective date will be governed by the policy in effect at the time of submission.

12. Dispute Resolution

If you are dissatisfied with the outcome of a refund request, you may escalate the matter through the dispute resolution process described in Section 15 of our Terms of Service. This process begins with good-faith negotiation and, if unresolved, proceeds through mediation or arbitration under the Indonesian Capital Market Arbitration Board (BAPMI). You also retain the right to file a complaint with OJK's consumer protection division if you believe your rights as an investor have been violated. Nothing in this Policy limits any statutory rights you may have under Indonesian consumer protection law or OJK investor protection regulations.