JAPFA Legal Advisor · Deep Review · Vietnam Tigervet
EXPIRED · OPERATING WITHOUT PAPER
47 /100 F
Score · Grade F · RED
Vietnam · Tigervet Co., Ltd · 🇻🇳

EXPIRED 30 Sep 2023 — operating without paper for 18 months.

The 2018 five-year exclusive vaccine distribution contract has been over for eighteen months and JAPFA keeps shipping under nothing more than an unsigned rev.7 First Amendment sitting in the folder. If Tigervet refuses to pay a bill tomorrow, JAPFA's legal position is uncertain on every material term — territory, exclusivity, pricing, dispute forum. Three new gaps compound the expiry: Vietnam's new Foreign Contractor Tax (Sept 2025) is silently eating 5% of revenue with no gross-up clause; the hybrid BANI+SIAC dispute clause matches a defect found in seven other JAPFA contracts; KUHPerdata 1266/1267 is not waived, so JAPFA cannot terminate without filing a Jakarta lawsuit first.

⚠️ Pull rev.7 First Amendment, run it through review, close within 30 days. Do NOT sign anything new yet.
5
Critical Risks
12
Material Risks
18mo
Expired Without Paper
F
Verdict · RED

Counterparty

Legal entity
TIGERVET CO., LTD
Country
Vietnam (Hanoi) 🇻🇳
JAPFA party
PT Vaksindo Satwa Nusantara
Agreement type
Exclusive Distributorship Agreement (vet vaccines)

Agreement

Effective date
1 October 2018 (notary deed 11 Dec 2018)
Original term
5 years to 30 September 2023 — EXPIRED
Document length
9 pages / 15 articles (pre-2018 short template)
Current status
Continuing unwritten; rev.3 + rev.7 drafts unsigned
Governing law
Art. 15.a Indonesia
Currency
USD, CIF Vietnam airport (Annex 2)
Critical context renegotiation track already underway

Two unsigned First Amendment drafts sit in the folder

A separate AGREEMENT TIGERVET.pdf and two First Amendment drafts (rev.3 clean and rev.7) sit in the same folder. The existence of two redline iterations strongly suggests an active renegotiation track is already underway. Those drafts are NOT reviewed in this memo — they need a separate /lawyer-advisor pass before any signature.

The deal in 3 sentences: JAPFA signed a 5-year exclusive Vietnam vaccine distribution contract with Tigervet in October 2018. That contract expired in September 2023. JAPFA has continued shipping anyway, with no signed renewal — there are two unsigned First Amendment drafts sitting in the folder, suggesting both sides know they need to fix this.

Top 5 critical risks all fixable in rev.7 First Amendment
C1 Agreement has expired — operating on implied continuation since Oct 2023 Critical
What the contract says (Art. 2)

"The term of this Agreement shall be for a period of five (5) years from the date hereof and will be terminated on September 30, 2023."

What this means in plain English

Your 5-year Vietnam vaccine distribution contract ended on 30 September 2023 — 18 months ago. Every invoice JAPFA has sent and every shipment that's gone out since October 2023 is happening under an "implied continuation" — no signed paper covers those transactions. If a dispute happened tomorrow over a missed payment or a quality claim, the courts (Indonesian or Vietnamese) would have to reconstruct what the parties intended from conduct alone, which gives the other side significant room to argue down any obligation.

What you should do
  1. By 15 May 2026: Pull rev.7 First Amendment from the Vietnam-Tigervet folder. Email Tigervet's GM acknowledging "we both know the 2018 contract expired Sep 2023 and we need to close rev.7 within 30 days."
  2. By 30 May 2026: Have rev.7 reviewed via /lawyer-advisor and signed, with a clause that retroactively ratifies the Oct 2023 → present period.
  3. Owner: JAPFA International Business + JAPFA Legal.
C2 Hybrid forum — BANI Jakarta administering under SIAC Rules (Art. 15.b) Critical
What the contract says (Art. 15.b)

"the Parties agree to bring the dispute to BANI (Badan Arbitrase Nasional Indonesia) and use the Singapore International Arbitration Centre (SIAC) rules."

What this means in plain English

The contract picks the Indonesian arbitration institution in Jakarta (BANI — the Indonesian arbitration body) but says to use the rule book of the Singapore institution (SIAC — the Singapore arbitration body). These are two different institutions with two different rule books, fee schedules, panels, and processes. They cannot be combined. If a real dispute went to either institution, the losing party would have a textbook excuse to refuse to enforce the award in Vietnamese courts under the NY Convention 1958 (the global treaty that makes arbitration awards enforceable across borders). This is the same defect present in 7 other JAPFA portfolio contracts.

What you should do
  1. In First Amendment: Replace Art. 15.b with the Iraq Alabrad clean clause — "Any dispute shall be finally settled by arbitration under the SIAC Rules. The seat shall be Singapore. The arbitration shall be conducted in English by three (3) arbitrators."
  2. Keep Art. 15.a (Indonesian governing law) — it is fine.
  3. Owner: JAPFA Legal.
C3 No Vietnam Foreign Contractor Tax clause — JAPFA silently losing 5% of revenue Critical
What the contract says

Nothing — there is no tax clause. Annex 2 quotes prices "CIF Specified Territory Airport in USD."

What this means in plain English

Vietnam Circular 27 (effective 15 September 2025) makes Tigervet legally required to withhold 5% from every USD payment to JAPFA — that's 5% Vietnamese tax going to Hanoi instead of to JAPFA. Two possibilities, both bad: (a) Tigervet has been withholding for 8 months — JAPFA is silently 5% short on every invoice since September 2025 with no contractual right to recover, OR (b) Tigervet has NOT been withholding — both sides have unaddressed back-tax exposure to Vietnam tax authorities plus penalty interest. In dollar terms: if Vietnam revenue is USD 1M/year, that's USD 50K/year either lost to JAPFA or owed to Vietnam tax.

What you should do
  1. This week: Ask JAPFA finance to pull Vietnam USD receipts since September 2025 and compare against invoices issued. The gap is the FCT.
  2. In First Amendment: Add a tax gross-up clause AND a retro reconciliation clause for the Sept 2025 → present period.
  3. Cleaner alternative: Raise CIF list price by 5% so Tigervet absorbs FCT visibly through a higher list price (less awkward for their downstream customers).
  4. Owner: JAPFA Finance + JAPFA Legal.
C4 KUHPerdata Articles 1266 / 1267 not waived — cannot terminate without a court order Critical
What the contract says

No express waiver clause. The contract is silent on KUHPerdata 1266/1267.

What this means in plain English

Under Indonesian law (the law you chose to govern this contract), if you want to terminate for cause — say Tigervet breaches by selling competing products or missing payment — you cannot simply send a notice and walk away. KUHPerdata Articles 1266 and 1267 are Indonesian Civil Code articles: under default Indonesian law, you cannot terminate a contract without going to court first; a one-line waiver clause fixes it. Without the waiver, JAPFA must file a lawsuit in Jakarta district court (Pengadilan Negeri Jakarta) and get a judge's permission to terminate. That takes 12-18 months minimum.

What you should do
  1. In First Amendment: Add this exact clause — "The Parties hereby waive the application of Articles 1266 and 1267 of the Indonesian Civil Code (KUHPerdata) and agree that termination of this Agreement shall be effective by written notice without need for prior court declaration."
  2. Owner: JAPFA Legal (this is standard JAPFA-template language).
C5 No CISG exclusion — UN treaty auto-applies because Vietnam is a member Critical
What the contract says

Nothing — CISG is not mentioned anywhere.

What this means in plain English

CISG is the UN treaty on cross-border sales of goods (Vienna 1980). Vietnam joined it in 2017 — before this contract was signed; Indonesia is NOT a member. When one party is in a CISG country and the contract chooses the law of a non-CISG country (Indonesia), there is real legal argument that CISG applies anyway. CISG has different rules from Indonesian law on things like warranty timing, what counts as a "fundamental breach," and when risk passes from seller to buyer — and the differences are not always in JAPFA's favour. The standard fix is one line saying "CISG does not apply."

What you should do
  1. In First Amendment, add: "The United Nations Convention on Contracts for the International Sale of Goods (Vienna 1980) is expressly excluded from this Agreement."
  2. Owner: JAPFA Legal.
High & Material risks 17 items total
  • No sales target floor — currently "mutually agreed annually" with no floor; unenforceable. Add USD 250-500K Year 1, 10% escalator, conversion-to-non-exclusive on first miss.
  • No FATF/AML representations — Vietnam off FATF grey list but enhanced monitoring continues; add full compliance reps + audit rights.
  • No PIPL / Vietnam Decree 13/2020 PV clauses — vet pharmacovigilance and personal-data transfer both undocumented.
  • MA / NIE transfer-back has no deadline — JAPFA could lose Vietnam market access for 6-12 months on exit; add 60-day deadline + USD 5K/month liquidated damages.
  • Termination notice silent on cure period — add 30/60 day cure plus immediate-termination triggers for insolvency, sanctions, anti-bribery.
  • No insurance / liability cap — neither party has cap; add mutual 12-month-net-sales cap + carve-outs.
  • Confidentiality has no post-term survival — add 5-year post-term survival clause.
  • UU 24/2009 — no Bahasa Indonesia counterpart — voidability risk under Nine AM v Bangun Karya precedent.
  • UU 10/2020 Bea Meterai stamp duty not visible — affects evidentiary weight in Indonesian court.
  • Various drafting clean-ups — change-of-control trigger, notice clause, force majeure narrowing, IP/trademark non-transferability.

What this contract does well (preserve)

  • Indonesian governing law (Art. 15.a) — keep.
  • MA / NIE registration in JAPFA's name with mandatory transfer-back (Art. 6.a, 6.d) — strongest section.
  • TT pre-payment 7 working days before shipment (Art. 5) — JAPFA-favourable.
  • USD CIF pricing with unilateral JAPFA price-reset right (Art. 4.a, 4.c).
Negotiation priority stack close rev.7 within 30 days
# Issue Negotiability What to say in meeting
1Close rev.7 First Amendment — retroactive ratification of Oct 2023 → presentHigh"We both know the 2018 contract expired Sep 2023. Let's get rev.7 reviewed and signed within 30 days — both sides need certainty."
2Replace hybrid forum (Art. 15.b) — SIAC Singapore + 3 arbs + EnglishHigh"The current clause names two arbitral institutions — it's broken. Clean SIAC Singapore benefits both of us at enforcement time."
3FCT gross-up clause — 5% Vietnamese tax allocationMedium"Vietnam Circular 27 requires you to withhold 5%. Let's gross up so neither side carries silent leakage. Or raise CIF 5% — your call."
4KUHPerdata 1266/1267 waiverHigh"One-liner; benign for both sides. Without it neither party can terminate cleanly under Indonesian law."
5CISG exclusionHigh"Vietnam is a CISG signatory; Indonesia is not. One line of express exclusion avoids future law-of-the-contract argument."
6Sales target floor + escalator — USD 250-500K Year 1, 10% YoYMedium"Both sides benefit from a floor — gives us shared baseline and lets you forecast inventory."
7MA / NIE transfer-back deadline — 60 days + LDHigh"If we ever part ways we both need certainty around the registration handover."
8FCPA / Sanctions / Tipikor repsHigh"Standard compliance language — required by our banks."
9Bilingual Bahasa Indonesia counterpartHigh"UU 24/2009 requires it. We'll handle translation."
10Liability cap + insurance — mutual 12-month net sales capMedium"Right now neither side has any cap — let's make it mutual and fair."

Concession bank (give early)

  • Extend payment from "7 working days before shipment" to "5 working days before shipment" — small operational ease for Tigervet.
  • Co-fund 50% of Vietnam KOL marketing up to USD 25k/year.
  • Provide marketing material at JAPFA cost in exchange for AE reporting upgrade.

Do NOT concede

  • Indonesian governing law (Art. 15.a).
  • SIAC seat Singapore + English.
  • KUHPerdata 1266/1267 waiver.
  • MA / NIE bailee construction — JAPFA owns registrations.
  • FCPA / sanctions reps + audit rights.
  • FCT gross-up — JAPFA must net out clean of Vietnamese tax.
Compliance review two jurisdictions

🇮🇩 Indonesian law

  • KUHPerdata 1266/1267 — NOT WAIVED. Indonesian Civil Code requires court order to terminate. Fix: add waiver.
  • UU 24/2009 (Bahasa language) — single English execution. Voidability risk under Nine AM v Bangun Karya. Fix: bilingual counterpart.
  • UU 10/2020 (Bea Meterai stamp duty) — not visible. Evidentiary weight in Indonesian court. Fix: post-signing e-meterai.
  • UU 31/1999 + 20/2001 (Tipikor anti-corruption) — no reps. Fix: add Article 25 compliance reps block.
  • UU 27/2022 (UU PDP data protection) — silent. Fix: cross-border data transfer clause.
  • Permentan 14/2017 (vet pharmacovigilance) — NIE owner not specified. Confirm JAPFA holds Vietnam MA.
  • UU 5/1999 (Anti-Monopoly) — exclusive distribution permissible. No KPPU exposure. ✓

🇻🇳 Vietnamese law

  • Circular 27 / FCT (effective 15 Sept 2025) — mandatory 5% withholding on USD outbound. No gross-up clause. Silent revenue leakage or back-tax exposure.
  • Decree 13/2020 (vet pharmacovigilance) — no clause. Adverse event reporting timeframes undocumented. Fix: 24h serious / 5d non-serious.
  • Vietnam PDPL Decree 13/2023 — no data-protection clause. Fix: cross-border transfer assessment.
  • Foreign exchange controls — SBV repatriation rules. Verify USD payment routing.
  • CISG — Vietnam acceded 2015, in force Jan 2017. No express exclusion in contract. Fix: add exclusion (Critical #5).
  • FATF — Vietnam off grey list (2023 onwards). Annual screening still recommended.
  • NY Convention 1958 — Vietnam IS signatory. SIAC awards enforceable IF Art. 15.b fixed. ✓ (after fix)

Cross-border & international

  • NY Convention 1958 (the global treaty that makes arbitration awards enforceable across borders) — both Indonesia and Vietnam are signatories. SIAC awards become enforceable in Vietnam once Art. 15.b is fixed.
  • MK Decision 100/PUU-XXII/2024 (3 January 2025) — Indonesian Constitutional Court confirmed pure territoriality: SIAC Singapore-seated awards are "international" and immune from Indonesian set-aside.
  • CISG (the UN treaty on cross-border sales of goods) — Indonesia NOT a member; Vietnam IS a member since 2017. Patchwork risk; express exclusion needed.
Obligations timeline re-paper within 30 days
Day 0 · TODAY
Issue reservation-of-rights letterEmail Tigervet GM acknowledging the 2018 contract expired 30 Sep 2023 and committing to close rev.7 First Amendment within 30 days. Ask JAPFA Finance to pull Vietnam USD receipts since Sept 2025 vs invoices issued — measure the FCT leakage.
Day 15
15 May 2026 — Pull rev.7 First Amendment for legal reviewRun rev.7 through /lawyer-advisor. Identify any defects carried over from the 2018 paper before signature.
Day 30
30 May 2026 — Sign First AmendmentExecute First Amendment with: term renewal + retroactive ratification of Oct 2023 → present + FCT gross-up + clean SIAC Singapore + 1266/1267 waiver + CISG exclusion + sales target floor.
Day 60
30 June 2026 — Stamp + bilingualApply Bea Meterai e-meterai to Indonesian execution copy. Execute Bahasa Indonesia bilingual counterpart.
Day 90
30 July 2026 — FCT reconciliationComplete back-tax reconciliation for Sept 2025 → May 2026 period. Document Tigervet's withholding behaviour going forward.
Year 1
30 September 2026 — Year-1 anniversary reviewConfirm minimum sales target achieved (USD 250-500K floor). Re-run sanctions screening on Tigervet + UBOs.
Annual
Recurring obligationsAnnual SDN / OFAC / EU / UN / FATF screening; annual confirmation Vietnam MA / NIE remains valid; quarterly rolling 12-month forecast; 5-year DRAP/Vietnam MA renewal cycle at -12 month trigger.
Section-by-section scores 47 / 100 weighted
Governing Law (Art. 15.a)
B
Dispute Forum (Art. 15.b)
D
Term & Renewal (Art. 2)
F
Payment Terms (Art. 5)
C
Tax / FCT (silent)
F
MA / NIE (Art. 6.a, 6.d)
B
Termination & Cure
D
Indemnity / Liability cap
D
Compliance reps (FCPA/AML)
F
Pharmacovigilance & AE
F

Score commentary

Why the score dropped from prior portfolio scan's 55 to 47: Three new gaps surfaced once the full 9 pages were OCR'd: (1) the contract is expired, (2) Vietnam's new Foreign Contractor Tax (Circular 27, September 2025) requires Tigervet to withhold 5% from every JAPFA invoice — but the contract has no gross-up clause, so JAPFA is silently losing 5% of revenue with no contractual recovery right, (3) Article 1266 of Indonesia's Civil Code is not waived — meaning JAPFA cannot terminate without going to court first.

Post-rev.7 projected score: If rev.7 First Amendment closes with all 5 Critical fixes and the top-tier Material fixes, score moves from 47/F → ~78/B-.

Action checklist 17 items, owners assigned
1. Pull rev.7 First Amendment from Vietnam-Tigervet folder; email Tigervet GM committing to close within 30 days.
By 15 May 2026
JAPFA Int'l Business
2. Run rev.7 through /lawyer-advisor; verify no carried-over defects.
By 22 May 2026
JAPFA Legal
3. Pull Vietnam USD receipts since Sept 2025 vs invoices issued; quantify FCT leakage.
This week
JAPFA Finance
4. Execute First Amendment with FCT gross-up + clean SIAC + 1266/1267 + CISG exclusion + sales target floor.
By 30 May 2026
JAPFA Legal
5. Replace Art. 15.b hybrid forum with SIAC Singapore + English + 3 arbitrators.
In First Amendment
JAPFA Legal
6. Add KUHPerdata 1266/1267 waiver clause.
In First Amendment
JAPFA Legal
7. Add CISG express exclusion.
In First Amendment
JAPFA Legal
8. Add Vietnam FCT gross-up + retro reconciliation clause.
In First Amendment
JAPFA Finance + Legal
9. Add sales target floor (USD 250-500K Year 1, 10% escalator, conversion-to-non-exclusive on first miss).
In First Amendment
JAPFA Legal + Sales
10. Add MA / NIE transfer-back deadline — 60 days + USD 5K/month liquidated damages.
In First Amendment
JAPFA Legal + Regulatory
11. Add full FCPA / UK Bribery / Tipikor / OFAC / EU / UN sanctions reps + annual re-screening.
In First Amendment
JAPFA Legal + Compliance
12. Add mutual liability cap (12-month net sales) + insurance + indemnity.
In First Amendment
JAPFA Legal
13. Add 5-year post-term confidentiality survival.
In First Amendment
JAPFA Legal
14. Apply Bea Meterai e-meterai to Indonesian execution copy.
By 30 June 2026
JAPFA Legal
15. Execute Bahasa Indonesia bilingual counterpart with "English prevails" clause.
By 30 June 2026
JAPFA Legal
16. Add Vietnam Decree 13/2020 pharmacovigilance schedule — 24h serious AE / 5d non-serious AE.
In First Amendment
JAPFA Regulatory
17. Annual sanctions screening of Tigervet + UBOs starting Sept 2026.
Annual
JAPFA Compliance