thanks for posing an interesting question...one I have seen before in another location...and the resulting answer shows no one is to be trusted.
similiar answer from jepp
but, know this once and for all...JEPP does not make up the procedure, the local authority (like FAA in the USA) makes up a written description of the approach and JEPP just draws it out...USING THE INFO THEY ARE GIVEN.
so, it is my best guess that the local issuing authority screwed up something...I would call, yes TELEPHONE JEPP and mention this to them and they may, say again MAY contact the local authority to make sure.
but I wouldn't fly this approach without dme (ground and air)...after all, you might want to circle to land, how would you know the MAP...and there is no timing published so...
good luck, fly safe and if you fly safe, the legality shouldn't come into question