The whole procedure looks to me that it was constructed pre-PANSOPS
There are a lot of those in South East Asia. Thailand, Malaysia, Cambodia Vietnam abound with these 'hybrid' approaches. The aviation authorities need to amend them - it's just laziness.
(just ask any PANSOPS guy to fit a CAT C holding at 5000 ft MSL to an NDB surrounded by a 10 x 15 NM controlled airspace)
There isn't such a thing as a PANSOPS pilot. There are those who are more used to PANSOPS and those more used to TERPS, but pilots aren't certified on each standard. I think you will find many of us are used to both.
This approach is sloppy, but shouldn't have been too difficult on the ATR with it's flight management system. We don't know the exact reason and the circumstances as to why they went around. It wasn't the approach that killed them It was impacting the ground on go around and we don't know why that happened either.