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Embedding Sustainable Value into Every Aspect of Life 2025 Sustainability Report PT Bank Tabungan Negara (Persero) Tbk
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
At BTN, sustainability is
not a standalone agenda,
it is how the Bank delivers
its purpose: empowering
Indonesian families through
inclusive, responsible,
and sustainable housing
ecosystems.
Embedding BTN embeds sustainability principles into every policy, product, and service as part of its long-term business strategy. This approach
ensures that business growth creates not only economic value but also positive impacts on social well-being and environmental
Sustainable Value protection. As a result, sustainability is directly experienced by customers, employees, and communities.
into Every Aspect This commitment is implemented through the 5P principles, namely Planet, People, Peace, Partnership, and Prosperity, which serve as the
of Life foundation for BTN’s sustainable finance development. Low-emission housing initiatives, increased financial inclusion, the development
and strengthening of the circular economy, and cross-stakeholder collaboration reflect the Bank’s efforts to integrate sustainable values
into various aspects of life while supporting the achievement of the Sustainable Development Goals and the principles of Environmental,
Social, and Governance.
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Contents 01 02 03
6 Sustainability Performance
Highlights
8 Recognition of BTN’s
Commitment and Innovation
13 BTN’s Tangible Impact on BTN Profile and Journey Building a Sustainable Finance Managing the Environment
Sustainability Ecosystem Responsibly
16 BTN’s Support for the Sustainable
Development Goals (SDGs) 28 BTN at a Glance 47 ESG Principles 70 Energy Management
21 Message from the President 30 Vision, Mission, and Sustainability 55 ESG Framework 73 Emissions Management
Director Values 56 ESG Governance 79 Water and Effluent Management
32 Organizational Structure 57 ESG Policy 81 Waste Management
33 BTN Sustainability Transformation 58 ESG Achievements and Results 84 Environmental Control and
265 About The Report Journey Compliance
267 Independent Assurance 34 BTN Business Activities
Statement 36 Operational Areas and Markets
273 Standard Report Index Served
290 Feedback Sheet 37 Sustainable Supply Chain
39 Significant Changes
39 External Initiatives and
Association Membership
40 Economic Performance
43 Loan Disbursement
User Instructions
Home Page Table of Contents Previous Page Next Page
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
04 05 06 07
Developing Employee Potential Strengthening Communities Driving Innovation in Financial Strengthening Governance as the
and Well-Being through Care and Inclusion Products and Digitalization Foundation of Sustainability
86 Human Capital Management 122 Corporate Social Responsibility 142 BTN Service Roadmap 192 BTN Sustainability Governance
89 Diversity, Equity, and Inclusion 129 Financial Inclusion and Literacy 145 Environmental and Social Risk Structure
101 Competency Training and Management in the Credit 197 Commitment to Governance
Development Process Implementation
111 Protection and Fulfillment of 148 BTN Portfolio Guideline 200 Governance Strategy
Employee Rights 155 ESG-Based Products 201 Governance, Risk, and
117 Employee Health and Safety 163 Digital Innovation for Modern Compliance Roadmap
119 Harmonious Industrial Relations Services 208 Nomination Process of the
120 Social and Economic Compliance 172 Financial Product Oversight Highest Governance Body
173 Advertising Policy 212 Performance Evaluation of the
174 Customer Financial Protection Highest Governance Body
175 Customer Data Privacy and 213 Risk Management
Security 248 Code of Conduct and Business
185 Debt Collection Policy Ethics
187 Handling of Financial Product 252 Anti-Fraud and Conflicts of
Complaints Interest
190 Customer Satisfaction 256 Implementation of the Principle of
Prudence
258 Internal Control and Anti-
Gratification
260 Whistleblowing System
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Sustainability Performance Highlights
Economic Performance [OJK B.1] Environmental Performance [OJK B.2]
Total Consolidated Assets Consolidated Current Year Profit
Environmentally Friendly Financing of 11,412 low-emission housing units using at
(Billion Rupiah) (Billion Rupiah)
Products [OJK B.1] least 10% environmentally friendly materials
527,793
3,501 Energy Waste and Effluent
3,501
469,615 3,007
438,750
Reduction in energy Waste generation
2023 2024 2025 2023 2024 2025 consumption
145.25
85,115 ton
Consolidated Interest and Non- Quantity of Products/Services Sold Gigajoule
Interest Operating Income
(Billion Rupiah)
4
Effluent reduction
Renewable
energy use
40,449 Product
Consumer 806.38 14,297 m3
Categories Banking Gigajoule
34,118
32,172
Commercial Banking
Reduction in energy Circular Economy
Banking Services
intensity
2023 2024 2025 Sustainable financial innovation
Corporate 10.53% through the “Pay Your Mortgage with
Banking
Your Waste” program and Low-
Emission Housing
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Social Performance [OJK B.3] Governance Performance [OJK B.2]
Establishment of the ESG Committee, Enterprise
Emissions Total Composition of Female
& ESG Risk Management Division, and ESG
Employees Employees
Department
Reduction in Scope 1 and Scope 2
Emissions 11,429 employees 50.15% The first State-Owned Bank to sign Principles for
Responsible Banking (PRB) from United Nations
9,922 ton CO eq 2
Employee with Suppliers Environment Programme Finance Initiative (UNEP FI)
Disabilities (TKPD)
Financed Emissions Disclosure
100%
3,734,612 ton CO eq 2 0.25% from 11,429
employees
of BTN’s suppliers are local Development of the Sustainable Finance
Framework and the Social Finance Framework
suppliers
Tree Planting
Disbursement of Disbursement of People’s Development of ESG Framework, Strategy, and
Inclusive Mortgage Business Credit and
Number of trees Financing Micro, Small, and Medium Roadmap
planted Enterprise loans
26,648 trees Rp157,298 Billion
Rp6.99 Trillion Development of the Governance, Risk, and
increased 6.34% from 2024
Carbon sequestration increased 12.80% from 2024 Compliance (GRC) Roadmap
31,600
ton CO2eq Signing the commitment as a member of the
Rp119,91 Partnership for Carbon Accounting Financials
billion (PCAF)
Climate Risk Stress Test (CRST) Social and Rp88,97
Environmental Rp80,00
billion Implementation of Anti-Money Laundering
Responsibility billion
Refining climate risk analysis and Counter-Terrorism Financing policies,
through CRST in accordance with data privacy protection, cybersecurity, and risk
OJK guidelines 2023 2024 2025 management
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Recognition of BTN’s Commitment Index
and Innovation
BTN continues to strengthen its ESG BTN is included in the Climate Change BTN is included in the KEHATI Group indices,
Awareness Index, which includes: which include:
implementation through green product
innovation, transparent governance, and • IDX LQ45 Low Carbon Leaders • SRI KEHATI
inclusive social programs. This commitment • ESGQ 45 IDX KEHATI
• ESG SL IDX KEHATI
is reflected in external assessments and
recognitions that show year-on-year
improvement in the Bank’s sustainability
performance.
During the reporting year, BTN recorded ESG index achievements as
a reflection of the integration of sustainability principles across its
business activities. The details of the index performance are presented
as follows.
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
During the reporting year, BTN received BTN ESG Ratings
several ESG ratings from independent
institutions as recognition of its
commitment and performance in
integrating sustainability principles
across its business activities.
ESG Rating: ESG Percentile Rank (%): ESG Score:
AA 75 77/100
Details of the ESG assessment results
are presented as follows:
(Leader) Dout of
Rank:
43,262 companies 78 out of 1,158 Banking
Services companies
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Awards Received in 2025:
Award:
Public Company with Trusted Green Achievement in Emission Reduction
BTN received various awards from national and international and Trusted Diamond Achievement in Emission Transparency
institutions recognizing the Bank’s contributions to
Category:
sustainable product innovation, strong governance, and The Best Corporate Emission Reduction Transparency Awards
social and economic empowerment of communities. Organizer:
Investortrust.id & Datatrust
The list of awards is presented in the following table. Date:
April 2025
Award: Award: Award: Award:
Prominent Awards 2025 ESG Awards 2025 Indonesia ESG Leadership Awards 2025 Indonesia Sustainable Synergy Awards 2025
Category: Category: Category: Category:
Best Green Mortgage Bank Transformation Platinum Star Awards - Medium Cap Leadership AAA - Indonesia’s Leaders in ESG Indonesia Sustainable Synergy Awards 2025 for
Organizer: Organizer: Transparency Environmentally Friendly Business Practices and
Metro TV, Salutee.id Investortrust Organizer: Improving Community Well-being
Date: Date: BGK Foundation Organizer:
September 2025 October 2025 Date: Netral News
November 2025 Date:
November 2025
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Award: Award: Award: Award:
Best Social Business Innovation Awards 2025 Editors Choice Award Editors Choice Award Editors Choice Award
Category: Category: Category: Category:
Best Social Business Innovation Awards 2025 Best Literacy for Climate Resilience Best Innovative Conservation Best Emission Reduction
Organizer: Organizer: Organizer: Organizer:
The Economics The Investing on Climate The Investing on Climate The Investing on Climate
Date: Date: Date: Date:
November 2025 December 2025 December 2025 December 2025
Award: Award:
5th TJSL & CSR Award Detikcom Awards 2025
Category: Category:
Gold rating for the following pillars: Housing Sector Entrepreneurship
Social Pillar, Economic Pillar, Environmental Pillar Empowerment Bank
Organizer: Organizer:
BUMN Track Detikcom
Date: Date:
June 2025 November 2025
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Certification
ISO 37001:2016 • Small Medium Enterprise Banking Division (SMBD);
Anti-Bribery Management System • Credit Operation Division (COD);
Validity: • Commercial Banking Center (Jakarta Area, Bekasi, Bandung, Bintaro Area);
December 21, 2022 – December 20, 2025 • SME Restructuring (West Java Regional Office; Jakarta II Regional Office; East Java,
Bali Nusa Tenggara Regional Office; Sumatera Regional Office, Sulawesi Maluku Papua
Certified Unit:
Regional Office, Central Java & Special Region of Yogyakarta Regional Office);
• Procurement and Fixed Asset Management
• Commercial Asset Management Division (CAMD);
Division (PFAD);
• Jakarta Harmoni Branch Office.
• Commercial Banking Division (CMBD Head Office);
• Corporate Banking Division (CBD); Issued by:
• Wholesale Credit Risk Division (WRD); National Accreditation Committee
ISO 27001:2013
ISO 9001:2015
Information Security
Quality Management System
Management System
Validity:
Validity:
December 17, 2024 – December 16,
July 11, 2023 – October 31,
2027
2025
Certified Unit:
Certified Unit:
Transformation & Partnership
Data Center
Management Division
Issued by:
Issued by:
BSI
BSI
Sertifikat Indi 4.0 Level 3
Validity:
July 18, 2022 – July 18, 2025
Certified Unit:
PT Bank Tabungan Negara (Persero) Tbk
Issued by:
Ministry of Industry
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
BTN’s Tangible Impact on
Sustainability
For BTN, sustainability is not merely an objective
but the core of every innovation and service
delivered, viewing its products and business
activities as vehicles to create positive impacts
for society and the environment. Accordingly,
BTN consistently integrates economic, social,
and environmental values into every decision.
Each step taken not only meets customers’
financial needs but also encourages behavioral
change and generates long-term benefits for
Indonesia’s sustainability.
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Pay Your Mortgage with Your Waste
BTN continues to strengthen its role in advancing sustainable finance through innovations that deliver economic,
social, and environmental benefits simultaneously. One such initiative is the “Pay Your Mortgage with Your Waste”
program. Through this program, mortgage customers and/or borrowers can convert household waste, such as
plastic, cardboard, metal, glass, and used cooking oil, into economic value that can be used to reduce monthly
installments. Through this mechanism, waste is no longer viewed solely as a by product but as a new source of
economic value that provides direct benefits to households.
Measurable impacts of the 2025 program:
716 kg inorganic
Environmental waste
Impact collected
Social
Impact 21 clusters with waste
management services
Financial
56 debtors who deposit waste
number of customers and
Impact
The program reflects BTN’s approach to linking financial access with positive environmental As part of its commitment to expanding the program’s impact, the Bank targets
behavior change. It helps ease household financial burdens while encouraging active implementation across 100 locations in Indonesia by the end of 2026. The initiative has
community participation in responsible waste management and strengthening the also received recognition from Queen Máxima of the Netherlands, the United Nations
implementation of the circular economy at the community level. Secretary-General’s Special Advocate for Inclusive Finance for Development, who views
the program as a tangible example of financial sector innovation that can strengthen
household economic resilience while supporting environmental sustainability and
national waste reduction.
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Low-Emission Housing
The development of healthier and more environmentally friendly housing has become materials. The Bank is continuing to strengthen its collaboration with the eco-friendly
a key focus in achieving sustainable development. To support this objective, BTN has set materials developer & supplier partners to accelerate low-emission housing in Indonesia,
a target to develop 150,000 low-emission housing units by 2029. This program not only in alignment with government programs on national housing development and the
addresses the need for decent and affordable housing but also supports the national green economy.
climate agenda through the application of more sustainable design concepts and
Measurable impact of the 2025 program:
Environmental 57 tons of waste diverted from 157.6 tons of CO2 emissions avoided Equivalent to the ecological benefits Strengthening the
potential landfills through the through the use of eco-friendly of planting 2,627 trees, which help circular economy
Impact
use of recycled materials materials and energy-efficient absorb emissions and improve air through the use of
designs quality recycled materials
Social
11,412 low-emission housing units have 22 low-emission housing development 5 startup or SME suppliers that have
Impact been developed partners collaborated with the Bank
Energy Efficiency 1. Air circulation by increasing ventilation Beyond its environmental dimension, the program
2. Window-to-wall ratio 15% to 30%
upholds the principle of affordability, ensuring that
low- and middle-income communities can access
To ensure housing 1. Using low-flow faucets
2. Proper sanitation management
healthier and more sustainable housing. BTN also
quality and resource Water Efficiency
3. Having an infiltration well maintains close collaboration with the government,
efficiency, developers
4. Using PDAM for water supply developers, and local communities to enhance social
are required to comply
impacts, ranging from the promotion of the circular
with sustainability Waste
Management Conducting waste sorting with appropriate economy to improvements in overall environmental
standards that include: waste bins quality.
Emission 1. Have carbon-absorbing plants (1 tree per house)
Reduction 2. Eco-friendly materials: minimum 15% per house
3. Green and open spaces in-house and public facilities:
minimum 10%
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
BTN’s Support for the Sustainable Development Goals (SDGs)
Sustainability has become an integral part of BTN’s business strategy. Accordingly, the and the financing of low-emission housing using environmentally friendly materials. The
implementation of the Sustainable Development Goals (SDGs), which encompass 17 Bank has also implemented a Portfolio Guideline to maintain asset quality and focus
goals, has been directly integrated into product development, risk management, and on sustainable sectors while strengthening the circular economy through the “Pay Your
financing processes. Mortgage with Your Waste” and Low-Emission Housing Program. In addition to financing
activities, BTN has increased its contribution to the SDGs through various ESG programs
To translate this commitment into concrete policy direction, BTN has developed various and initiatives throughout 2025, as outlined under each material topic in the 2025
sustainable finance initiatives to strengthen its green financing portfolio and ensure Sustainability Report.
that business processes are aligned with ESG principles. This approach is supported
by BTN’s ESG Roadmap and Framework, as well as the 5P framework, which includes At the national level, the implementation of the SDGs in Indonesia is articulated through
People (community welfare), Planet (environmental responsibility), Prosperity (shared Action Plans and SDGs Indicator Metadata, which are continuously updated in line
prosperity), Peace, and Partnership as the foundation for creating sustainable value. with global developments and national data availability. Within this framework, the
17 SDGs are grouped into four development pillars, namely the Social Development
As part of this approach, BTN has undertaken a range of initiatives to support the Pillar, Environmental Development Pillar, Economic Development Pillar, and Legal and
achievement of the SDGs, including the distribution of subsidized mortgage loans (KPR) Governance Development Pillar. Based on this classification, BTN’s contributions to the
for low-income communities, the development of sustainable financial instruments, SDGs are mapped to Indonesia’s SDG pillars and presented in the table below.
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
BTN’s Contribution to Indonesia’s SDG Pillars
Social The social pillar serves as the foundation for the equitable and inclusive fulfillment of basic human rights in order to improve the quality of life of all people.
Development This agenda includes poverty alleviation, food security, health, education, and gender equality. The pillar also ensures that all groups, including vulnerable
Pillar communities, have access to essential services and equal opportunities to thrive. With measurable indicators, the Social Pillar forms the basis for achieving
inclusive welfare and sustainable human development.
Employment Community Development
• BTN facilitated regular medical check-ups and medical services to support • BTN runs the Micro and Small Business Funding Program (PUMK). In 2025,
early detection and treatment, and promoted employee health through a the Bank disbursed Rp6.55 billion to 161 assisted partners.
week-long series of health seminars. • BTN provides the Micro, Small, and Medium Enterprise Loan Program
• BTN implemented work-life balance through the launch of the BTNers (KUMKM). In 2025, disbursements reached Rp5.67 trillion, an increase of
Club, comprising 26 employee communities in sports, arts, and spiritual 28.68% from Rp4.40 trillion in 2024.
activities, supported by various programs involving employees across the • BTN implements the People’s Business Credit Program (KUR). In 2025, BTN
Bank. disbursed Rp1.07 trillion to 8,788 borrowers, consisting of 6,429 Micro KUR
• BTN provided scholarship support for 54 employees pursuing and 2,359 Small KUR borrowers.
undergraduate (S1) and postgraduate (S2) degrees, both domestically • BTN provided education scholarships to 108 children of outsourced workers,
and overseas, in 2025. This represented a 38% increase from 39 employees including operational and security personnel.
in 2024. • BTN delivered MSME development training reaching 250 MSMEs, supported
• BTN consistently fulfills employees’ rights to maternity and paternity leave. by mentoring and workshops to strengthen managerial capabilities and
In 2025, these benefits were utilized by 512 female employees and 285 access to sustainable financing.
male employees. • BTN organized English language training and competency certification
• BTN held the Expert Talk Series on Women’s Leadership (Srikandi BTN), for 100 persons with disabilities as part of the Bank’s commitment to
attended by 324 employees, to strengthen women’s leadership capacity expanding access to education.
in the workplace.
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Environmental The environmental pillar forms the foundation of sustainable development by ensuring ecosystem quality through prudent natural resource management,
Development biodiversity conservation, and enhanced climate resilience. This pillar includes pollution control, improvements in water, air, and land quality, as well as
Pillar climate change mitigation and adaptation. These efforts support long-term ecological balance and environmental resilience.
Climate Change and Ecosystems Sustainable Products and Services
• BTN implemented a tree-planting program by planting 26,648 trees in • BTN implemented its Low-Emission Housing financing program and
2025, equivalent to an estimated carbon absorption of 31,600 tCO2e. promoted the use of environmentally friendly materials. The program
• BTN installed solar panels across 12 BTN buildings and replaced 806.38 reached 11,412 units in 2025, up 777.85% from 1,300 units in 2024.
GJ of conventional electricity consumption in 2025, a 1,071% increase from • BTN’s digital initiatives reduced paper usage through the adoption of
68.87 GJ in 2024, when solar panels were installed in 7 BTN buildings. end-to-end procurement, e-MOM, e-RKK, and e-Committee as well
• In 2025, BTN planted 7,600 mangroves, an increase of 137.5% from 3,200 as paperless features in the balé by BTN app, BTN Properti, and other
mangroves planted in 2024. supporting operational and financial services applications. As a result,
• BTN Tower 2 achieved Green Building certification with the highest rating, BTN’s paper usage in 2025 totaled 105,969,841 sheets.
Platinum, from the Green Building Council Indonesia (GBCI), delivering • In 2025, BTN planted 2,214 trees through the redemption of balé Points by
21.86% energy efficiency, a 32.1% increase in green area, and 26.7% water customers via the balé by BTN app. This increased by 118.34% from 1,014
savings. trees planted in 2024.
Resource Use and Environmental Management
• In 2025, BTN ran the “Pay Your Mortgage with Your Waste” program, which
collected 716 kg of inorganic waste.
• BTN supported access to clean water and sanitation for homeowners
through its housing loan (KPR) schemes, totaling 1.63 million units in 2025.
This increased by 4.23% from 1.57 million units in 2024.
• As part of its environmental responsibility, BTN provided access to clean
water and proper sanitation through its TJSL program in 2025, with a budget
realization of Rp455,714,000. This was a 379.7% increase from Rp95,000,000
in 2024.
• BTN utilized 25 infiltration wells, each with a capacity of 3.39 m³, and 22
biopore points across the BTN Tower area.
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Economic The economic pillar is directed toward achieving quality growth through productive job creation, strengthening industry and innovation, and providing reliable
Development infrastructure. It emphasizes access to affordable and clean energy, reduced inequalities, and partnerships that support business expansion. By promoting
Pillar an inclusive, efficient, and competitive economy, this pillar underpins sustainable development that enhances welfare and strengthens national economic
resilience.
Community Development • BTN processed 17,051 online mortgage applications in 2025 through the balé
• BTN delivered MSME development training for 250 MSMEs, supported by Properti platform, up 14.82% from 14,850 mortgage signings in 2024.
mentoring and workshops to strengthen managerial capabilities and improve • BTN’s Sustainability Bond portfolio stood at Rp1,193.53 billion in 2025, up 26.8%
access to sustainable financing. from Rp941.21 billion in 2024.
• BTN organized the BTN Entrepreneurship Competition as an innovation • BTN issued two sustainability bond instruments: Sustainable Subordinated
platform within the housing ecosystem, attended by 1,170 participants. Bonds I Bank BTN Tranche I 2025 and Social Bonds Tranche I, with a total
• Through its Housing Finance Center (HFC), BTN has conducted the Mini MBA in issuance value of Rp2.29 trillion.
Property Training Program since 2016 and, to date, has trained more than 800 • In 2025, BTN disbursed Sustainable Business Activities (KKUB) loans of Rp203.45
prospective and existing housing developers. trillion, up 10.61% from Rp183.93 trillion in 2024.
• BTN implemented the Micro and Small Business Funding Program (PUMK), • BTN’s nationwide network, including in remote areas, helps create job
with 2025 disbursements of Rp6.55 billion to 161 assisted partners, supported opportunities and supports more balanced income distribution. Through
by a total fund allocation of Rp11 billion. the balé agen program, BTN expands access to formal financial services for
• BTN provided MSME loans (KUMKM) totaling Rp5.67 trillion in 2025, up 28.68% unbanked communities in underserved regions. In 2025, BTN recorded 6,300
from Rp4.40 trillion in 2024. agents, up 26% from 5,000 agents in 2024.
• BTN delivered People’s Business Credit (KUR) financing of Rp1.07 trillion to 8,788 Sustainable Procurement
borrowers in 2025, comprising 6,429 KUR Micro and 2,359 KUR Small. • In 2025, BTN worked with 1,092 local suppliers, with a total transaction value of
Sustainable Products and Services Rp1.23 trillion.
• BTN provides the balé by BTN Super App, which makes it easier for customers Governance
to access banking products and services. In 2025, transaction value reached • BTN operated 48 electric vehicles (EVs) for operational purposes in 2025, up
Rp103.61 trillion, up 27.74% from Rp81.11 trillion in 2024. 33.33% from 36 units in 2024.
• BTN disbursed subsidized housing loans (KPR Subsidi) totaling 1.63 million
units, equivalent to Rp157.30 trillion, increasing from 1.56 million units worth
Rp147.32 trillion in 2024.
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Legal and The legal pillar emphasizes legal certainty, access to justice, and accountable governance to support sustainable development. This pillar encompasses
Governance efforts to reduce violence, expand legal aid services, enhance the integrity of public institutions, and ensure inclusive and transparent decision-making. Its
Development implementation is measured through various indicators, including the handling of violence cases, the quality of public services, representation within state
Pillar institutions, and the protection of human rights as the foundation for creating a safe and just society.
Information Security Governance
• BTN strengthened governance and compliance in 2025 through • BTN has developed a Net Zero Emission (NZE) Roadmap as a guideline
cybersecurity awareness programs, data privacy management training, for emissions reduction, energy efficiency, clean energy transition, and
AML/CFT (APU/PPT) training, business code of ethics training, and anti- continuous monitoring.
bribery and anti-corruption training. • BTN has joined various sustainable finance initiatives and networks at the
• BTN strengthens data protection and cybersecurity through policies, global and national levels, including:
IT infrastructure enhancement, training and certification programs for - United Nations Environment Programme Finance Initiative (UNEP FI)
employees to mitigate operational risks, and security awareness education - Indonesia Sustainable Finance Initiative (IKBI)
for all employees, customers, and third parties. - Asian Venture Philanthropy Network (AVPN)
Business Ethics and Code of Conduct - Partnership for Carbon Accounting Financials (PCAF)
• All employees are required to sign the Integrity Pact in accordance with the Human Rights
values of the Code of Conduct. • BTN conducts recruitment of employees with disabilities by prioritizing
• BTN implements a gratification control program through anti-corruption equality and fairness. In 2025, the proportion of Employees with Disabilities
campaigns and ethics education to strengthen employee integrity and was 0.28% male employees and 0.23% female employees, compared to
create a transparent work environment. 0.17% male employees and 0.19% female employees in 2024.
20 PT Bank Tabungan Negara (Persero) Tbk
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Digitalization
Message from
On the other hand, the President Director [OJK D.1]
BTN continues
to carry out its
Esteemed Shareholders and Stakeholders,
longstanding role in
providing subsidized We extend our sincere gratitude to God Almighty for His grace
housing for low- and guidance, which have enabled PT Bank Tabungan Negara
income communities. (Persero) Tbk, hereinafter referred to as “BTN” or the “Bank,” to close
the year 2025 with resilient performance amid global economic
For more than
dynamics and continuously evolving industry challenges. This
four decades, BTN resilience reflects BTN’s steadfast commitment to safeguarding
has consistently business sustainability while creating inclusive, long-term value
expanded access to for all stakeholders.
affordable housing
As part of our commitment to transparency and accountability, BTN
finance as a tangible presents the 2025 Sustainability Report, which comprehensively
contribution to outlines the Bank’s performance, policies, and strategic direction
improving the welfare in sustainability. This report underscores BTN’s role as an enabler
of the national housing finance ecosystem, with a focus on
and quality of life
providing decent, affordable, and increasingly environmentally
of the Indonesian friendly housing solutions. These efforts are aligned with national
people. development priorities and global commitments to addressing
climate change and advancing social aspects.
Responding to Sustainability Challenges [GRI 2-22, 2-23, 2-24] [OJK E.5]
Nixon L.P. Napitupulu BTN views sustainability as an integral part of the Bank’s
President Director business strategy and governance. In response to the evolving
business environment and rising stakeholder expectations, BTN
consistently integrates environmental, social, and governance
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Digitalization
(ESG) principles into its sustainability roadmap, Sustainable Finance Action Plan (SFAP), expanded access to affordable housing finance as a tangible contribution to improving
as well as its risk management framework and strategic decision-making processes. the welfare and quality of life of the Indonesian people.
To establish a focused and measurable sustainability roadmap, BTN applies a double As part of its sustainable finance innovation, BTN has also introduced the “Pay
materiality assessment process as the basis for identifying material issues. Through Your Mortgage with Your Waste” program, which integrates financial inclusion with
this approach, BTN is able to systematically identify and manage material issues with environmental management. This program enables sorted inorganic household waste
significant impacts, along with relevant risks and opportunities, from both a financial to be converted into rupiah credited to the customer’s savings account and can also
perspective and an impact perspective on society and the environment. This approach be used to reduce mortgage installments while simultaneously encouraging behavioral
ensures that the implementation of sustainable finance is not merely symbolic but is change and the adoption of circular economy practices at the community level.
embedded across financing activities, operations, product innovation, and corporate Throughout 2025, this program successfully managed approximately 716 kg of inorganic
governance. waste with 21 housing clusters with waste management services. This program provides
direct economic benefits to customers while contributing to environmental burden
Advancing Sustainable Business and Finance [GRI 2-22, 2-23, 2-24] reduction. This initiative underscores BTN’s role in delivering inclusive, innovative, and
sustainably impactful financing solutions.
In line with its vision to become a “Leading Partner in Empowering the Financials of
Indonesian Families,” BTN continues to strengthen its role as a catalyst for inclusive and Strategy, Governance, and Business Resilience
sustainable economic growth. BTN’s sustainability roadmap is designed to create long-
term value through a balanced integration of the 5P (People, Planet, Prosperity, Peace, The achievement of BTN’s sustainability targets is supported by strengthened
and Partnership) aspects, supported by Portfolio Guidelines to ensure that financing governance, risk management, cross-stakeholder collaboration, and the utilization of
activities are aligned with ESG principles. digital innovation. As part of its long-term commitment to the national climate agenda,
the Bank has set a target to reduce greenhouse gas emissions by at least 30% toward net
The Bank’s primary focus is directed toward the development of sustainable housing zero emissions for Scope 1 and 2 by 2030.
finance as part of its support for the Government’s national housing program, implemented
by the Low-Emission Housing Program, which targets the development of up to 150,000 To further reinforce this foundation, BTN developed the governance, risk, and compliance
housing units by 2029 through the use of environmentally friendly materials, energy- (GRC) Roadmap 2025–2029 as a strategic guide to addressing regulatory dynamics, risk
efficient designs, and circular economy principles. In 2025, the initial implementation of management, and governance challenges. This roadmap promotes a more proactive,
this program delivered tangible impacts, including the diversion of approximately 57 tons integrated, and resilience-oriented approach to long-term business sustainability.
of plastic waste from potential landfill disposal, avoiding carbon emissions of 157.6 tons
of CO2e, and ecological benefits equivalent to the planting of approximately 2,627 trees. Throughout the reporting year, BTN maintained consistency in the implementation of
On the other hand, BTN continues to uphold its historical role in providing subsidized sustainable finance. However, the Bank also encountered several challenges. From
housing for low-income communities. For more than four decades, BTN has consistently an external perspective, these included changes in housing finance policies, potential
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Digitalization
natural disasters, global economic uncertainty, and exchange rate volatility. From an Future Outlook
internal perspective, key challenges include strengthening ESG data capabilities, aligning
policies and risk management with ESG principles, enhancing employee competence Going forward, BTN is committed to continuously conducting sustainable banking
and understanding of sustainability issues, ensuring the readiness of the developer operations, developing inclusive and responsible financing products and portfolio
ecosystem, and balancing the expansion of housing finance inclusion with prudent credit management, and strengthening the integration of ESG components into the enterprise
risk management. [OJK E.5] risk management framework.
Contribution to the Sustainable Development Goals BTN will also cultivate an ESG-oriented culture and responsible leadership, establish an
internal control environment integrated with ESG aspects, strengthen ESG monitoring,
All BTN policies and initiatives are aligned with the achievement of the Sustainable communication, and reporting programs, and expand strategic partnerships and
Development Goals (SDGs), as mandated by Presidential Regulation No. 59 of 2017 and collaborations with a broad range of stakeholders.
POJK No. 51/POJK.03/2017. Through the SFAP, CSR programs, and the implementation of
good corporate governance, BTN ensures balanced business growth while delivering Closing
positive social and environmental impacts.
On behalf of BTN Management, we extend our sincere appreciation and gratitude to
From an environmental perspective, the Bank’s initiatives during the reporting period all stakeholders for their continued trust and support. Our highest appreciation is also
contributed to a reduction in Scope 1 and 2 emissions of 9,922 tons of CO2eq. On the social conveyed to all BTN employees for their dedication, integrity, and innovation, which form
front, BTN promotes equality and inclusivity, including the employment of persons with the foundation of the Bank’s achievements.
disabilities, which accounted for 0.25% of the total workforce. In terms of governance, BTN
continues to strengthen its ESG frameworks, strategies, and roadmaps as the foundation We believe that sustainability is a shared journey. Through strong collaboration and a
for integrating sustainability into the Bank’s overall management. well-defined strategy, BTN remains committed to delivering inclusive, responsible, and
sustainable financial solutions in support of a better future for Indonesia.
This commitment was reflected in various recognitions from national and international
institutions. During the reporting period, BTN achieved an ESG rating of AA from MSCI,
indicating that the Bank’s management of sustainability-related risks and opportunities
is at a strong level compared to global peer banking institutions. In addition, BTN received Jakarta, March 2026
several ESG-related awards, including Leadership AAA – Indonesia’s Leaders in ESG
Transparency, the Indonesia Sustainable Synergy Awards, and Best Literacy for Climate
Resilience. These awards further reinforce the Bank’s consistent efforts to integrate
sustainability principles into its strategy, governance, and business operations.
Nixon L.P. Napitupulu
President Director
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Board of Commissioners Statement We, as the Board of Commissioners of PT Bank Tabungan Negara (Persero) Tbk., have evaluated
on Accountability for the content of this Sustainability Report and confirmed that the report has covered all material
sustainability topics for the Bank and the Bank’s stakeholders. We are responsible for the accuracy of
PT Bank Tabungan Negara (Persero) Tbk the contents of this Sustainability Report.
2025 Sustainability Report [GRI 2-14]
Jakarta, March 2026
Suryo Utomo
President Commissioner
Dwi Ary Purnomo* Fahri Hamzah Ida Nuryanti
Vice President Commissioner Commissioner Independent Commissioner
Pietra Machreza Paloh Panangian Simanungkalit Didyk Choiroel **
Independent Commissioner Independent Commissioner Commissioner
*Resigned on 25 February 2026 following his appointment as a member of the Board of Directors of PT Asuransi Kerugian Jasa Raharja.
**Appointed at the Extraordinary General Meeting of Shareholders (EGMS) on 7 January 2026 and effective upon obtaining OJK approval following the Fit and Proper Test.
24 PT Bank Tabungan Negara (Persero) Tbk
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Board of Directors Statement We, as the Directors of PT Bank Tabungan Negara (Persero) Tbk., have evaluated the content of this
on Accountability for Sustainability Report and confirmed that the report has covered all material sustainability topics for
the Bank and the Bank’s stakeholders. We are responsible for the accuracy of the contents of this
PT Bank Tabungan Negara (Persero) Tbk Sustainability Report.
2025 Sustainability Report [GRI 2-14]
Jakarta, March 2026
Nixon L.P. Napitupulu Oni Febriarto Rahardjo
President Director Vice President Director
Setiyo Wibowo Hirwandi Gafar Nofry Rony Poetra Eko Waluyo Tan Jacky Chen
Director of Risk Management Director of Consumer Director of Finance and Strategy Director of Human Capital and Director of Information Technology
Banking Compliance
Venda Yuniarti Helmy Afrisa Nugroho* I Nyoman Sugiri Yasa Rully Setiawan Hermita
Director of Treasury and Director of Corporate Banking Director of Operations Director of Network and Retail Director of Commercial
International Banking Funding Banking
*Appointed at the Annual General Meeting of Shareholders (AGMS) on 26 March 2025 and effective upon obtaining OJK approval following the Fit and Proper Test.
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01
BTN Profile and
Journey
28 BTN at a Glance
30 Vision, Mission, and Sustainability
Values
32 Organizational Structure
33 BTN Sustainability Transformation
Journey
34 BTN Business Activities
36 Operational Areas and Markets
Served
37 Sustainable Supply Chain
39 Significant Changes
39 External Initiatives and Association
Membership
40 Economic Performance
43 Loan Disbursement
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Digitalization
Company Name [GRI 2-1] [OJK C.2] Date of Establishment Website
PT Bank Tabungan Negara (Persero) Tbk February 9, 1950 www.btn.co.id
BTN at a
Head Office Address [GRI 2-1] [OJK C.2]
Glance BTN Tower
Jl. Gajah Mada No. 1,
BTN Tower 2
Jl. H.R. Rasuna Said No. 1
Jakarta 10130, Indonesia Jakarta Selatan, 12980
62-21 6336789 Indonesia
62-21 6346704
Listing on the Indonesia Legal Entity Form [GRI 2-1] Business Sector
Stock Exchange
Limited Liability Company Commercial Banking, including
December 17, 2009 the conduct of banking activities
based on Sharia principles
Stock Code Share Ownership: [GRI 2-1] [OJK C.3]
BBTN PT Danantara Asset Management 60.00%
Domestic Public 29.44%
Stock Exchange
Foreign Public 10.56%
Indonesia Stock Exchange
* The Government of the Republic of Indonesia is the principal and controlling shareholder of BTN through
its ownership of Series A Dwiwarna shares.
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BTN Business Scale [GRI 2-6] [OJK C.3]
Description Unit 2025 2024 2023
Total assets* Billion Rupiah 527,793 469,615 438,750
Total equity* Billion Rupiah 36,210 32,572 30,480
Total liabilities* Billion Rupiah 491,583 437,043 408,271
Total employees People 11,429 12,847 12,045
Number of Office Unit
conventional 642 630 631
service networks
Number of products Product/ 4 (four): 4 (four): 4 (four):
and services offered Service 1. Consumer 1. Mortgage and 1. Mortgage and
Categories Banking Consumer Consumer
2. Commercial Banking Banking
Banking 2. Housing and 2. Housing and
3. Corporate Commercial Commercial
Banking Banking Banking
4. Banking Service 3. Sharia Banking 3. Sharia Banking
4. Treasury 4. Treasury
& Asset & Asset
Management Management
*Financial data is presented on a consolidated basis.
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Vision, Mission, and Sustainability Values [GRI 2-23] [OJK C.1]
• Becoming the main partner of the
government in housing and financial
inclusion
• Providing the best customer experience
through integrated digital and financial
Leading partner in services
Vision Mission • Increasing shareholder value through
empowering the financials
sustainable profitability growth
of Indonesian families • Becoming a home for Indonesia’s best
talent
• Implementing good corporate
governance practices and sustainable
business innovations for community
welfare and environmental sustainability
Review of Vision and Mission by the Board of Commissioners and Directors
BTN conducts periodic reviews of its vision and mission to ensure The results of this review have been integrated into BTN’s 2025–
alignment with the company’s long-term plan as well as changes 2029 RJPP and the 2026 Sustainable Finance Action Plan. The
in strategic conditions. The most recent review, conducted on 30 main difference compared to the previous formulation lies in
September 2024 by the Board of Commissioners and Directors, the expansion of the Bank’s focus, which now emphasizes not
confirmed that the updated vision and mission are aligned with only mortgage financing but also the development of a more
both the Bank’s internal and external developments. comprehensive banking ecosystem.
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Corporate Culture [GRI 2-23]
#MelayaniSepenuhHati
Broad Impact High Empathy Customer-Oriented Comprehensive Standards
Across All State-Owned Employees and Business Operations and Technology Products and Services
Enterprises Processes
Accountable Knowledgeable Harmonious Loyal Adaptive Kinship
Sustainability Values
BTN’s sustainability values are rooted in the AKHLAK corporate culture. These values also serves as the Bank’s basis for strengthening employee engagement and retention to
are further reinforced through the Employee Value Proposition (EVP), which is delivered support the implementation of sustainable finance.
through four core elements: Learn, Grow, Contribute, and Engagement. This EVP framework
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Digitalization
Organizational Structure As of 31 December 2025, BTN’s Organizational Structure is as follows
General Meetings of Shareholders
Board of
Commissioner
President Director
Vice President Director Audit
Committee
Remuneration
& Nomination
Network & Information Risk Finance & Human Capital Committee
Consumer Commercial Corporate Treasury & Int Operations
Retail Funding Technology Management Strategy & Compliance
Banking Director Banking Director Banking Director Banking Director Director
Director Director Director Director Director
Risk Monitoring
Committee
SEVP
SEVP SEVP
Assets
Digital Business Credit Risk
Management
Digital Consumer
Corporate
Subsidized Sales & Banking Business Corporate IT Strategic Collection, Customer Wholesale Policy & Human Capital Internal
Treasury Strategy &
Mortgage Distribution Product Banking Banking Planning Recovery & Experience Credit Risk Procedure Strategy Audit
Planning
Development Asset Sales 1
Financial Consumer
Mortgage Digital Enterprise
Retail Commercial Institutional Institution IT Collection, Credit Retail Finance & Human Capital Corporate
& Secured Banking & ESG Risk
Funding Banking Banking 1 & Capital Development Recovery & Operations Credit Risk Accounting Management Secretary
Loan Sales Management
Market Asset Sales 2
Procurement Commercial Digital & Investor
Personal Wealth Institutional Wholesale IT Digital Human Capital Marketing
& Fixed Asset Asset Operations Risk Relations &
Banking Management Banking 2 Transaction Operations Operations Business Partner Communication
Management Management Management Research
Transformation Data
Regional IT Central Learning
& Partnership Management
Office Security Operations Management
Management & Analytics
• Branch
Compliance
Office
& Governance
Legal
Transformation Integrated Risk Capital &
Asset & Liability IT Steering Risk Management Human Capital Credit Policy Credit Business ESG Bank Syariah
Steering Management Subsidiary
Committee Committee Committee Committee Committee Committee Committee Committee Nasional
Committee Committee Committee
Committee Board SEVP Division Distribution Subsidiary Regional Offices Line Comando Line Coordination
32 PT Bank Tabungan Negara (Persero) Tbk
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Digitalization
BTN Sustainability Transformation Journey
BTN’s structured commitment to sustainability was marked by the preparation of its first ESG initiatives that support long-term and responsible growth. This approach reflects
Sustainability Report in 2009. Since then, the Bank has continuously strengthened the BTN’s evolution from a conventional banking institution into a leading player in the
integration of sustainability principles into its operations and business activities, including implementation of sustainable finance in Indonesia.
the development of policies, sustainable finance practices, and the implementation of
• The first year of The Bank The opening Became a Housing Selected for • Directed the • Achieved an AA rating in
Sustainability Report participated of the Jakarta Market Maker and inclusion in the implementation of the MSCI ESG Rating.
preparation. in supporting Harmoni Smart strengthened its SRI-KEHATI Index ESG by developing • Received an “Excellent”
• Mortgage securitization the successful Branch as part of position as the 5th on the IDX. BTN’s ESG framework, rating from Sustainable
through the first Asset- implementation the development largest bank. strategy, and roadmap Fitch for its Sustainable
Backed Securities of the One Million of digital-based and establishing the Finance Framework (SFF),
Collective Investment Houses Program for products and ESG Committee, Risk which serves as a reference
Contract (KIK-EBA) in the public. services. Management & ESG Work for green and social
Indonesia. The Bank Unit, and ESG Department. financing.
conducted its Initial • First year of financed • Joined the Partnership
Public Offering (IPO) emissions calculation. for Carbon Accounting
and was listed on Financials (PCAF) to
the Indonesia Stock reaffirm BTN’s commitment
Exchange (Go Public). to achieving net zero
financed emissions by
2060.
2009 2013 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025
The Bank carried out a The Bank continued Development of a Updated its vision to • Issued a rights issue • BTN’s transformation toward the Beyond Mortgage
transformation toward its transformation digital ecosystem “Best Mortgage Bank to strengthen capital concept through updates to its logo, vision, and mission,
becoming a leading agenda through to support the in South East Asia” by in support of the goal harmonization of initiatives with ESG through various
housing bank and world- the “Digital Banking Bank’s business as 2025. of becoming the best sustainable banking and finance programs, and the
class banking. Periods.” Indonesia’s leading mortgage bank in South launch of the balé by BTN super app and BTN Digital
housing finance bank. East Asia. Store.
• Selected for the IDX LQ45 • First year of Climate Risk Stress Testing (CRST) reporting.
Low Carbon Leaders • The first SOE bank in Indonesia to join UNEP FI and sign
Index on the Indonesia the Principles for Responsible Banking (PRB).
Stock Exchange.
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Digitalization
BTN Business Activities [GRI 2-6] [OJK C.4]
The scope of BTN’s business activities is stipulated in Article 3, paragraph (2) of the
Articles of Association, which have been amended several times and were most recently
updated through the Deed of Statement of Resolutions of the Annual General Meeting
of Shareholders No. 9 dated 4 December 2025, executed before Notary Ashoya Ratam,
S.H., M.Kn., in Jakarta, and approved under the Decree of the Minister of Law No. AHU-
AH.01.03-0256621 dated 22 December 2025. Based on the Articles of Association, BTN
carries out its main business activities as follows:
1. Mobilization of public funds
2. Provision of credit and financing
3. Payment system services
4. Interbank fund placement and borrowing
5. Issuance and trading of securities
6. Safekeeping of goods and securities
7. Foreign exchange business activities
8. Assignment of receivables
9. Equity participation
10. Temporary equity participation for the handling of non-performing loans
11. Establishment and management of pension funds
12. Other financial services, including investment banking and commercial banking
13. Cooperation with financial and non-financial institutions
14. Other business activities subject to approval from the Financial Services Authority
(OJK)
BTN has carried out all business activities as stipulated in its Articles of Association. In addition, the Bank undertakes various supporting activities to strengthen its core business and
optimize the utilization of resources. All such activities are conducted in compliance with applicable laws and regulations. More detailed information on BTN’s products, services, and
business activities is available on the Bank’s website at https://www.btn.co.id/.
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Product
Conventional Banking Sharia Banking*
Consumer Banking Product Commercial Banking Product Corporate Banking Product Sharia Products
Consumer Loan Products:: Commercial Loan Products: Corporate Loan Products: Sharia Financing Products:
• Housing Loans • Investment Loans • Working Capital Loans • Consumer Financing
• Non-Housing Loans • Working Capital Loans - Property Working Capital • Commercial Financing
• Property Working Capital Loans - Contractor Working Capital
Consumer Deposit Products: • Construction Working Capital Loans - Bridging Loans Sharia Deposit Products:
• Consumer Savings • Bridging Working Capital Loans - Secured Working Capital (Cash Collateral) • Sharia Current Accounts
• Retail Time Deposits • Linkage Loans • Investment Loans • Sharia Savings
• Individual Current Accounts • Secured Loans • Refinancing • Sharia Time Deposits
• Loans to Ministries/Agencies of the Republic
Wealth Management Products:: Commercial Deposit Products: of Indonesia
• Bancassurance • Institutional Time Deposits • Term Loan Facilities
• Mutual Funds • Institutional Current Accounts • Corporate Line Facilities
• Retail Government Bonds (Primary • Treasury Line Facilities (for Non-Financial
Market) Institutions)
• Government Bonds (Secondary Market)
• Foreign Exchange
Services
Conventional Banking Sharia Banking*
• Electronic Data Capture (EDC) • Electronic Channel ATM • Other Banking Services • BSN Safe Deposit Box • BSN Payroll
• balé Korpora • BTN Priority and Private Banking Services • BTN Open API • BSN Bank Guarantee • BSN Cash Management
• Virtual Account • PLUS by BTN Prioritas • balé Business • BSN Program • BSN Virtual Account
• Visa/GPN Debit Card & Online Debit • Bank Branchless Services (balé Agen) • balé Merchant • Operational Development • Online Onboarding for Open
• Internet Banking • balé Community • balé Developer • BSN Online Account
• Super App balé by BTN • Online Account Opening • Hajj Cost Receipt Issuance • Bancassurance
• SKBDN (Domestic Letter of Credit) • Cash In Cash Out (CICO) • balé Syariah by BSN
• Bank Guarantees • CRM • BSN Card Debit
*) Following the approval of the spin-off of the Sharia Business Unit of PT Bank Tabungan Negara (Persero) Tbk through the transfer of its rights and obligations to PT Bank Syariah Nasional, Sharia banking products
are no longer part of the Company’s product portfolio as of 22 December 2025.
35 PT Bank Tabungan Negara (Persero) Tbk
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Digitalization
Operational Areas and Markets Served [GRI 2-1, 2-6] [OJK C.3]
BTN operates with its Head Office in Jakarta and a network of offices spread across Sulawesi Maluku Papua RO
all 38 provinces in Indonesia. In line with the provisions of Financial Services Authority Sumatra RO
Regulation No. 12/POJK.03/2021 on Commercial Banks, a simplification of branch
Kalimantan RO
network classification was reported to the regulator. Accordingly, branch offices below
the main branch level were standardized into Sub-Branch Offices and Functional
Offices, resulting in the reclassification of Cash Offices as Sub-Branch Offices.
Central Java & DIY RO
As a public company listed under the stock code BBTN, BTN’s business growth
continues to expand its service coverage nationwide. As of 31 December 2025, BTN’s
operational network comprised 8 Regional Offices, 82 Conventional Branch Offices, 35
Sharia Branch Offices, 548 Conventional Sub-Branch Offices, 83 Sharia Sub-Branch
Jakarta I & II RO
Offices, and 4 Functional Offices, collectively strengthening the Bank’s capacity to
serve housing finance needs across various regions in Indonesia. West Java RO East Java, Bali, & Nusa Tenggara RO
BTN’s Branch Network and Banking Services Distribution of BTN’s Operational Network Across Indonesia
Description 2025 2024 2023 Central Java
East Java,
& Special
Conventional Network West Java Jakarta I Jakarta II Bali, & Nusa Sumatra Sulawesi, Kalimantan
Region of
Description Regional Regional Regional Tenggara Regional Maluku, Papua Regional
Regional Offices 8 8 6 Yogyakarta
Office Office Office Regional Office Regional Office Office
Regional
Branch Offices 82 82 81 Office
Office
Sub-Branch Offices 548 536 541
Regional Offices 1 1 1 1 1 1 1 1
Functional Offices 4 4 3
Branch Offices 10 11 8 16 11 11 8 7
Sharia Network
Sub-Branch Offices 79 100 90 79 74 38 56 32
Sharia Branch Offices 35 35 34
Functional Offices 0 0 1 0 1 0 2 0
Sharia Sub-Branch Offices 83 75 75
Sharia Branch Offices 5 3 3 4 10 3 4 3
Network
Sharia Sub-Branch Offices 11 9 6 14 21 2 16 4
ATM and CRM 2,091 2,071 2,209
BTN Priority Outlets & Lounges 6 12 11 9 9 5 5 5
ATM and CRM 336 342 263 330 307 167 212 133
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Digitalization
Sustainable Supply Chain [GRI 2-6] [OJK B.1]
Supply chain management plays a vital role for BTN in ensuring operational continuity, Through this policy, BTN also reaffirms its commitment to prioritizing the use of domestic
service quality, and the implementation of sustainability principles across its business products and partnerships with local suppliers based within Indonesia. Foreign suppliers
activities. In this regard, BTN refers to the Special Policy on the Guidelines for the are engaged only when domestic needs cannot be fulfilled or when specific considerations
Procurement of Goods and Services KK.9-H, supported by an end-to-end procurement apply. This approach is aligned with the Circular Letter of the Minister of SOE No. SE-10/
system.Through this policy, the Bank establishes mandatory clauses for suppliers to MBU/08/2020 on enhancing the role of MSMEs, as well as the SOE Procurement Regulation
ensure support for sustainability by reducing negative environmental impacts, ensuring No. PER-2/MBU/3/2023 concerning the Governance and Significant Corporate Activities
fair working conditions, and promoting inclusive economic growth. The clauses stipulated of SOEs. [GRI 3-3]
including the following: [GRI 3-3]
1. Compliance with environmental documentation, including UKL-UPL, AMDAL, As part of its sustainable supply chain management, BTN also applies the prudential
environmental permits, and technical assessments. principle in the use of outsourced labor in accordance with POJK No. 9/POJK.03/2016
2. Implementation of environmental protection measures and minimization of impacts by ensuring that core activities remain managed internally. Outsourcing is limited
on communities. to supporting functions to maintain effective operations, align with good corporate
3. A written commitment to environmentally friendly procurement and ESG principles. governance principles, and consistently uphold service quality for customers. In 2025,
4. Assurance of worker protection, including the prohibition of child labor and the the Bank conducted 716 procurement activities for goods and/or services involving 1,092
exploitation of vulnerable women. registered suppliers. This number increased compared to 2024, which recorded 939
5. Provision of insurance for workers in high-risk roles. suppliers. From the 1,092 registered suppliers, 100% were local suppliers originating from
6. Have anti-corruption policies and integrity pacts to ensure compliance. Indonesia. [GRI 204-1, 414-2]
Percentage of Procurement Transaction Value by Supplier Total Value of
Procurement 2025 2024 2023
Location
Transactions with
Local Suppliers
Rp1.23 Rp1.63 Rp2.31
Description 2025 2024 2023
Local Suppliers 100% 100% 100%
Foreign Suppliers 0% 0% 0% Trillion Trillion Trillion
Total 100% 100% 100%
37 PT Bank Tabungan Negara (Persero) Tbk
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
In supporting the implementation of sustainable procurement, BTN conducts capacity Aligned with these efforts, BTN ensures that all procurement of goods and services
building and oversight of suppliers to ensure compliance with sustainability standards is carried out through procedures that adhere to the principles of Good Corporate
throughout the entire procurement process. These efforts are carried out through the Governance (GCG), namely transparency, accountability, responsibility, independence,
issuance of formal communications and socialization activities to ensure that suppliers and fairness, as well as the implementation of Fair Bid Treatment Provisions to ensure
understand and comply with sustainability principles, including the reduction of equitable treatment for all procurement participants.The Bank regularly conducts audits
environmental impacts, the application of fair social practices, and adherence to ethical and evaluations to ensure that each stage of the procurement process is carried out in
standards in their operations. In addition, BTN strengthens engagement with suppliers a fair and efficient manner, free from potential misuse, and supportive of sustainable
through supplier and vendor engagement activities to enhance awareness of sustainable resource management in compliance with applicable regulations.
practices, with a focus on paperless processes, transparency, and monitoring.
38 PT Bank Tabungan Negara (Persero) Tbk
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Significant Changes [GRI 2-6] [OJK C.6]
During the reporting year, BTN updated its vision and mission and carried out the spin-off of its Sharia Position within the
Association Names
Association
Business Unit (UUS). In accordance with the Sharia Banking Law and OJK Regulation No. 12/2023, this step
Association of State-Owned Banks (Himbara) Member
was taken as BTN Syariah’s assets as of the fourth quarter of 2023 reached Rp54.3 trillion, thereby meeting
Indonesian Bankers Association (IBI) Secretary
the regulatory threshold for the spin-off. The spin-off became effective on 22 December 2025 through
the transfer of all rights and obligations of the UUS to Bank Syariah Nasional (BSN), demonstrating BTN’s World Savings and Retail Banking Institute (WSBI) Member
commitment to compliance while strengthening governance and sharpening its focus on developing National Commercial Banks Association (Perbanas) First Vice
Chairperson
a more inclusive and sustainable sharia banking business. Following the spin-off, the Bank adjusted
its organizational structure and established two new committees: the Integrated Risk Management SOE Public Relations Forum Member
Committee and the Capital & Subsidiary Committee. Indonesian Issuers Association Member
External Loss Data Consortium (KDKE) Member
Certified Wealth Manager’s Association (CWMA) Member
External Initiatives and Association Membership Indonesian Payment Systems Association (ASPI) Member
Associate Cambiste Internationale (ACI) Indonesia Member
(Forexindo)
Banking Compliance Directors Communication Forum Member
External Initiatives Association Memberships [GRI 2-28] [OJK C.5] (FKDKP)
Indonesian Banking Alternative Dispute Resolution Member
Institution (LAPSPI)
BTN proactively implements Sustainable Finance BTN’s membership in various associations and
and responds to climate change by participating in organizations supports the strengthening of its Association of Internal Bank Auditors Member
external initiatives and adopting relevant national business capacity and role within the national The Institute of Internal Auditor (IIA)-lndonesia Chapter Member
and international guidelines. This commitment banking industry. Through this involvement, United Nations Environment Programme Finance Initiative Member
(UNEP FI)
is reflected in the preparation of the Sustainable the Bank gains access to strategic information,
Finance Action Plan (SFAP/RAKB) in accordance with regulatory developments, and industry Indonesian Sustainable Finance Initiative (IKBI) Member
OJK Regulation No. 51/POJK.03/2017, as well as ESG trends, while also expanding collaboration Asian Venture Philanthropy Network (AVPN) Member
risk and opportunity mapping to assess material and knowledge sharing with other industry Bankers Association for Risk Management (BARa) Vice Chairperson
financial impacts, integrate ESG considerations participants. Details of BTN’s memberships are Risk Management Forum Treasurer
into credit processes, and strengthen sustainable presented as follows. Partnership for Carbon Accounting Financials (PCAF) Member
financing, in alignment with IFRS S1 and IFRS S2.
39 PT Bank Tabungan Negara (Persero) Tbk
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Economic Performance
Indonesia’s economic performance in 2025 demonstrated a sustained recovery amid Table of Comparison of the Bank’s Business Plan and Financial Realization in 2025
[OJK F,2]
global dynamics. Data from Statistics Indonesia (BPS) recorded economic growth in
the fourth quarter of 2025 at 5.04% year-on-year (yoy), reflecting continued positive 2025 Realization 2025 Plan
Description Achievement
momentum in national economic activity. This momentum reinforced the role of the (Rp Billion) (Rp Billion)
banking sector in maintaining stability while promoting the integration of sustainability Financial Position
principles, including ESG factors, into financial products and services to support more Assets 527,793 510,095 103.47%
inclusive and sustainable growth. Loans Disbursed* 385,262 378,834 101.70%
Liabilities* 491,583 475,545 103.37%
In line with these conditions, BTN capitalized on economic growth opportunities by
Deposits from Customers 405,500 362,736 111.79%
strengthening housing finance and consistently advancing the implementation of ESG
Current Accounts** 167,446 156,427 107.04%
within its business strategy. Throughout 2025, BTN disbursed 1.9 million housing loan (KPR)
Savings Accounts** 36,932 43,021 85.85%
units, including 1.6 million subsidized KPR units valued at Rp157.30 trillion, resulting in an
Time Deposits** 201,122 163,288 123.17%
81.09% market share in subsidized mortgage financing. This achievement underscores
Equity 36,210 34,971 103.54%
BTN’s strategic role in providing decent housing for low-income communities and
reinforces its position as the national market leader in housing finance. Profit (Loss)
Interest Income 36,341 35,287 102.99%
Consistency in executing its sustainability strategy and maintaining operational Non-Interest Operating Income 4,108 4,670 87.97%
performance resulted in a net profit of Rp3.5 trillion, or grew by 16.8% yoy. Despite ongoing Profit Before Tax 4,382 4,380 100.05%
economic and industry challenges, BTN’s focus on sustainable innovation and strong Net Profit 3,501 3,504 99.91%
governance is expected to continue strengthening its competitiveness and delivering Financial Ratios (Parent Entity) (%)
added value to stakeholders. [OJK F.2]
Capital Adequacy Ratio (CAR) 19.02 18.19 104.56%
Non-Performing Loan (NPL) 3.17 3.14 100.96%
As the basis for presenting its economic performance, BTN reports the economic value Gross
generated and distributed at the national level, in line with the Bank’s operational scope Return on Assets (ROA) 0.89 0.90 98.89%
and audited consolidated financial statements, thereby reflecting the scale of economic
Return on Equity (ROE) 11.57 11.60 99.74%
impact most significant to stakeholders. [GRI 201-1]
*) Including sharia financing
**) Excluding syirkah
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
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Digitalization
Economic Value Generated and Distributed Table of Economic Value Generated and Distributed [GRI 201-1] [OJK B.1]
2025 2024 2023
The creation of sustainable economic value is an integral part Description
(Rp Billion) (Rp Billion) (Rp Billion)
of BTN’s role in supporting national development and delivering
Economic Value Generated
benefits to stakeholders. Direct economic value is generated
through income from the Bank’s operational activities and is Interest Income 31,880 25,473* 24,722
subsequently allocated in the form of employee remuneration Sharia Profit-Sharing Income 4,461 4,069 3,559
and benefits, tax payments to the government, and the
Other Operating Income 4,108 4,576 3,891
implementation of Social and Environmental Responsibility
programs for the community. [GRI 3-3] Non-Operating Income 26 (52) (160)
Total Economic Value Generated 40,475 34,066 32,012
Throughout 2025, BTN managed its finances independently
Economic Value Distributed
without receiving financial support from the government. The
Bank also did not generate income arising from opportunities Interest Expenses (15,910) (16,114) (13,406)
or financial implications related to climate change during the Sharia Profit-Sharing and Bonus Expenses (2,420) (1,935) (1,445)
reporting period. Details of the economic value generated and
Other Operating Expenses **) (6,790) (5,817) (5,034)
distributed are presented in the following table. [GRI 201-2, 201-4]
Employee Salaries and Benefits (5,004) (4,446) (3,983)
Procurement of Goods and Services (1,230) (1,635) (2,313)
Dividend Payments to Shareholders (752) (700) (609)
Payments to Government (3,620) (3,764) (3,143)
Expenditure for Community Social Investment **) (120) (89) (79)
Total Economic Value Distributed (35,846) (34,500) (30,012)
Total Economic Value Retained 4,629 (434) 2,000
*) Operating expenses excluding employee salaries and benefits
**) Realization of disbursement for the Social and Environmental Responsibility program
***) This figure is not related to the profit or loss reported in the Bank’s financial statements
41 PT Bank Tabungan Negara (Persero) Tbk
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
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Financial Performance Contribution to the State
BTN presents audited consolidated financial statements to provide a comprehensive view The implementation of ESG principles, particularly good governance and social
of the Bank’s financial position and performance, including the impact of the separation responsibility, has been an integral part of BTN’s operations. This commitment is reflected
of the Sharia Business Unit in accordance with applicable accounting standards. A in transparent and integrity-driven business practices, including fiscal contributions
summary of the financial performance is presented in the following table. through the payment of taxes and dividends. Throughout 2025, BTN contributed taxes
amounting to Rp3.6 trillion, creating added value for the state and supporting sustainable
Table of BTN Consolidated Financial Performance [GRI 201-1] [OJK B.1] national development and economic growth.
2025 2024 2023
Description Table of BTN Contribution to the Government
(Rp Billion) (Rp Billion) (Rp Billion)
Total Assets 527,793 469,615 438,750 2025 2024 2023
Description
(Rp Billion) (Rp Billion) (Rp Billion)
Bank Loans/Financing 385,262 344,916 318,106
Taxes
Third-Party Funds *) 437,479 381,756 349,699
Income Tax (PPh) 3,585 3,715 3,123.04
Total Liabilities 491,583 437,043 408,271
Value Added Tax (VAT) and Luxury Goods Sales 16 26 24.31
Total Equity 36,210 32,572 30,479 Tax
Net Profit 3,501 3,007 3,501 Import/Export Duties, Excise Duties, and Stamp 4 9 1.90
Duty
Financial Ratios (Parent Entity) (%)
Capital Adequacy Ratio (CAR) 19.02 18.50 20.14 Land and Building Tax for Plantations, Forestry, 15 13 0.36
and Mining
Non-Performing Loan (NPL) Gross 3.17 3.16 3.01
Total Tax Contribution (Total A) 3,620 3,763 3,419.61
Return on Asset (ROA) 0.89 0.83 1.05
Non-Tax State Revenue (PNBP)
Return on Equity (ROE) 11.57 10.76 13.54
Dividends 451 420 365.41
Net Interest Margin (NIM) 4.20 2.86 3.75
Total PNBP Contribution (Total B) 451 420 365.41
Operating Expenses to Operating 89.04 88.70 86.10
Income (BOPO) Total Contribution to the State (Total A and B) 4,071 4,183 3,515.02
Loan to Deposit Ratio (LDR) 91.28 93.79 95.36
*) including deposits from other banks and temporary syirkah funds
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
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Digitalization
Loan Disbursement
In 2025, BTN disbursed loans amounting to Rp270.16 trillion, representing an increase of Table of Consumer Loan Disbursement Volume
Rp15.10 trillion, or equivalent to 5.92% compared with 2024. This achievement was mainly
2025 2024 Increase (Decrease)
driven by mortgage lending, including both subsidized and non-subsidized home loans Type of Consumer Loans
(Unit) (Unit) (Unit) (%)
Meanwhile, in 2025, subsidized mortgage disbursements reached 1.6 million units, up
Housing Loans
by 68 thousand units, or 4.35%. Non-subsidized mortgage disbursements totaled 342
Subsidized Mortgage Loans 1,627,469 1,559,647 67,822 4,35%
thousand units, up by 8 thousand units, or 2.51%.
Non-Subsidized Mortgage Loans 342,313 333,922 8,391 2,51%
Other Housing Loans 53,045 59,214 (6,169) (10,42%)
Total Housing Loans 1,961,174 2,014,436 (53,262) (2,64%)
Non-Housing Loans 68,799 65,798 3,001 4,56%
Consumer Loan Disbursement
2,083,235 2,026,972 56,263 2,78%
Volume
*Restated
BTN recorded an increase in the value of housing loan disbursements as of December Table of Consumer Loan Disbursement Values
31, 2025, amounting to Rp262.41 trillion. This represented an increase of Rp14.88 trillion, or
2025 2024 Increase (Decrease)
equivalent to 6.01% compared to Rp247.53 trillion in 2024. Type of Consumer Loans
(Rp Billion) (Rp Billion) (Rp Billion) (%)
Housing Loans
Subsidized Mortgage Loans 157,298 147,321 9,977 6,77%
Non-Subsidized Mortgage Loans 96,107 91,653 4,454 4,86%
Other Housing Loans 9,012 8,558 454 5,31%
Total Housing Loans 262,416 247,533 14,883 6,01%
Non-Housing Loans 7,742 7,523 219 2,91%
Consumer Loan Disbursement
270,158 255,056 15,102 5,92%
Volume
*Restated
43 PT Bank Tabungan Negara (Persero) Tbk
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Pendahuluan BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
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Digitalization
BTN recorded 371,435 units of sharia consumer financing disbursement as of the end of Table of Sharia Consumer Financing Disbursement Volume
2025. This represents an increase of 60,183 units, or 19.33%, compared to 311,252 units in
Increase (Decrease)
2024. The growth was primarily driven by housing financing, which rose by 59,004 units, Types of Sharia Consumer 2025 2024
or 19.18%, supported by an increase in subsidized mortgage financing of 53,400 units, or Financing (Unit) (Unit)
(Unit) (%)
21.29%, as well as non-housing financing, which grew by 1,179 units, or 32.11% year-on-year.
Housing Loans
Subsidized Mortgages 304,208 250,808 53,400 21,29%
Non-Subsidized Mortgages 61,581 55,899 5,682 10,17%
Non-Mortgage Financing 795 873 (78) (8,93%)
Total Housing Financing 366,584 307,580 59,004 19,18%
Non-Housing Financing 4,851 3,672 1,179 32,11%
Consumer Financing
371,435 311,252 60,183 19,33%
Disbursement Volume
As of 31 December 2025, BTN recorded consumer financing disbursements of Rp51.35 Table of Sharia Consumer Financing Disbursement Value
trillion. This represents an increase of Rp10.20 trillion, or 24.78%, compared to Rp41.16 trillion
Increase (Decrease)
in 2024. The growth was mainly driven by housing financing, which reached Rp50.86 Types of Sharia Consumer 2025 2024
trillion, up 24.45% year-on-year. Financing (Rp Billion) (Rp Billion)
(Rp Billion) (%)
Housing Loans
Sharia performance for 2025 is presented based on historical data up to the effective
date of the spin-off, or on a full-year pre-transfer basis, in accordance with the applied Subsidized Mortgages 33,883 26,522 7,361 27,75%
reporting methodology. Non-Subsidized Mortgages 16,935 14,303 2,632 18,40%
Non-Mortgage Financing 39 41 (2) (4,88%)
Total Housing Financing 50,857 40,866 9,991 24,45%
Non-Mortgage Financing 495 290 205 70,69%
Non-Housing Financing 51,353 41,156 10,197 24,78%
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
02
Building a
Sustainable Finance
Ecosystem
47 ESG Principles
55 ESG Framework
56 ESG Governance
57 ESG Policy
58 ESG Achievements and Results
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
As a financial institution with a strategic role in driving national economic growth, BTN For BTN, building a sustainable financial ecosystem that balances economic growth,
recognizes its responsibility to ensure that the investment flows under its management social considerations, and environmental protection requires a collaborative approach.
not only generate economic value but also deliver social benefits and safeguard Accordingly, BTN consistently collaborates across sectors and with relevant stakeholders.
environmental sustainability. BTN believes that economic development aligned with As a concrete step, BTN has comprehensively mapped its sustainability ecosystem,
social and environmental considerations requires prudent resource management and a encompassing ESG principles, governance, processes, and performance outcomes. The
long-term, value-oriented approach. primary focus is directed toward strengthening sustainable finance practices to deliver
positive impacts for society and the environment, while reinforcing BTN’s role as a catalyst
BTN is committed to promoting sustainable financing through the application of for inclusive, ethical, and sustainable banking in Indonesia. [OJK A.1]
environmental, social, and governance (ESG) principles across its business activities and
operations. This commitment is reflected in the Bank’s efforts to manage environmental
impacts, address social aspects, and maintain ethical and transparent governance
practices.
BTN Sustainable
ESG Principles Sustainable Impact, Double
Ecosystem Sustainable Triple Bottom Three Lines
Development Stakeholder Theory Materiality, dan
Finance Line Model
Goals Value Chain
ESG Framework The Future of Finance
Integrated
Sustainable Climate Change People and Stakeholder ESG in the
Governance, Risk,
Finance and Ecosystem Community Inclusiveness Value Chain
Compliance
ESG Governance
and Organizational ESG Committee Enterprise & ESG Risk Management Division
Structure
Process
ESG Framework & Strategy Development ESG Policy & Implementation ESG Data Reporting & Communication
Outcome
Implementation of ESG initiatives and roadmap, growth in sustainability performance, and improvement in the Bank’s ESG ratings
46 PT Bank Tabungan Negara (Persero) Tbk
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
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Digitalization
ESG Principles
Sustainable Finance [GRI 2-12, 2-13] [OJK B.3, E.1] 5. Informative Communication
Ensuring transparent disclosure of strategies, performance, and business prospects
Since January 1, 2019, the Bank has implemented sustainable finance principles in to all stakeholders.
accordance with POJK No. 51/POJK.03/2017. This regulation governs the implementation 6. Inclusiveness
of sustainable finance for financial services institutions, issuers, and public companies, Expanding access to banking products and services, particularly for underserved
and emphasizes the importance of establishing dedicated units with the authority to communities.
manage and coordinate sustainable finance-related activities. 7. Development of Priority Leading Sectors
Supporting financing for sectors that contribute to sustainable development and
In advancing its sustainability agenda, the Bank is guided by eight sustainable finance climate change mitigation.
principles stipulated in the regulation, as follows: 8. Coordination and Collaboration
1. Responsible Investment Strengthening synergy with various stakeholders to enhance economic and social
Prioritizing investments in projects that generate long-term economic, social, and welfare, as well as environmental quality.
environmental benefits.
2. Sustainable Business Strategy and Practices BTN is committed to supporting inclusive and environmentally conscious economic
Minimizing adverse impacts through policies and business strategies that are growth through the implementation of the Sustainable Development Goals (SDGs). This
integrated with sustainability considerations. commitment is aligned with Indonesia’s national Sustainable Development Goals policy,
3. Social and Environmental Risk Management as stipulated in Presidential Regulation No. 59 of 2017, which serves as a guideline for
Integrating social responsibility and environmental protection into the Bank’s risk balancing economic, social, and environmental aspects.
management processes.
4. Governance To reinforce this commitment, BTN has adopted the 5P approach, consisting of People,
Applying the principles of transparency, accountability, responsibility, independence, Planet, Prosperity, Peace, and Partnership, to ensure that all business activities are aligned
and fairness. with sustainability values and shared progress.
47 PT Bank Tabungan Negara (Persero) Tbk
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Enhancing community welfare through inclusive financial products and services, as
People
well as empowerment and education programs.
Implementation
of the
5P Planet Promoting sustainable banking by prioritizing environmentally responsible financing
Approach
and initiatives.
[OJK A.1]
Supporting sustainable economic growth through the provision of affordable housing
Prosperity
finance.
Implementing sound and transparent governance to foster an ethical and constructive
Peace
business environment.
Strengthening collaboration with the government, private sector, and communities to
Partnership
support the achievement of the SDGs.
Stakeholder Engagement [GRI 2-29] [OJK E.4]
Stakeholder theory emphasizes that a company’s responsibilities extend to all As a financial institution that plays a role in economic and social development, the
parties affected by its business activities, including employees, customers, suppliers, Bank applies this principle by engaging stakeholders in decision-making processes
communities, and government, positioning stakeholder well-being as an integral and the formulation of strategic policies. Through open and constructive dialogue, BTN
component of business success. seeks to maintain a balance between economic performance, social responsibility, and
environmental stewardship.
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
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Digitalization
BTN regards stakeholders as key partners in achieving its sustainability objectives, with 4. Diversity
engagement conducted in an active, transparent, and accountable manner to enable The differences in stakeholders’ characteristics, backgrounds, and interests are
each party to contribute constructively to long-term value creation. understood and respected to ensure inclusive policies and decisions that fairly
address the needs of various parties.
In identifying stakeholder groups, BTN applies several criteria to ensure that engagement 5. Willingness to Participate
is constructive and supports the achievement of sustainability goals, including: Stakeholders’ willingness to participate in decision-making processes and corporate
1. Influence initiatives to achieve mutually beneficial shared objectives.
The extent to which stakeholders have an influence on BTN’s sustainability-related
decisions. Based on these criteria, BTN has identified its key stakeholder groups and established
2. Dependency appropriate response mechanisms and communication strategies tailored to the
BTN has a degree of dependence on the stakeholder, either directly or indirectly. characteristics of each stakeholder group. [GRI 2-29]
3. Needs
Stakeholders’ understanding of the needs, expectations, and aspirations of
stakeholder groups related to the Bank’s products or services.
Internal Stakeholders
Stakeholder Engagement Method Frequency Priority Topics BTN’s Response
Employees Employee Engagement Annually Employee satisfaction level • Provision of training and development programs
Survey • Performance appraisal and promotion system
• Development of collective labor agreements
Internal Bulletin Annually Employment-related policies and strategies
SmartShare Accessible at any time • Discussion forum, job-related discussions,
quizzes, and information sharing
• Diversity and equal opportunity
• Training and education
Innovation Award Annually processes and productivity improvement
Labor Union Collective Labor Agreement Annually • Harmonious industrial relations Organization of the Bipartite Cooperation Institution (LKS
discussions • Fulfillment of employees’ rights and obligations Bipartite)
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
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External Stakeholders
Stakeholder Engagement Method Frequency Priority Topics BTN’s Response
Shareholders Annual General Meeting of Annually • Achievement of the Bank’s performance targets • Formulation of strategies to improve economic performance
Shareholders (AGMS) and economic performance and business sustainability
• Market presence • Determination of dividend distribution policies
Performance presentations Quarterly
• Anti-corruption • Provision of periodic information on BTN’s performance
Extraordinary General As needed • Development of ESG and decarbonization • Organization of AGMS
Meeting of Shareholders roadmaps
(EGMS)
Customers Customer satisfaction survey Twice a year • Service quality and standards • Innovation in products and services in line with customer
• Product portfolio needs and technological developments
Customer communication Monthly
• Customer data privacy • Provision and disclosure of product and service information
media
• Protection and storage of customer data in accordance with
Customer Call Center As needed regulations
services • Provision of customer complaint handling services, both
BTN website and Frontline Accessible at any time manual and digital, including resolution mechanisms
Information • Socialization of sustainable finance implementation
Direct visits As needed
Developer Partners Property Awards Annually Housing sales opportunities • Provision of competitive financing schemes to support
sustainable housing development
Gathering As needed Success of the three million housing program and
• Encouragement of green building concepts and energy
low emission housing initiative.
efficiency in development projects
Capacity building As needed Transparency • Organization training sessions and workshops to strengthen
the capacity of developer partners
Business Partners / Suppliers Work contracts As needed Procurement processes • Socialization of company policies
• Focus group discussions to gather feedback and aspirations
Investment partners As needed Business cooperation
from suppliers
Seminars and workshops As needed Development of merchant banking
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
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Digitalization
Stakeholder Engagement Method Frequency Priority Topics BTN’s Response
Government and Financial Self-Assessment GCG Twice a year Compliance with disclosure and assessment of • Alignment of internal policies and regulations with those
Services Authority GCG implementation issued by the Government and the Financial Services
Authority
GCG Compliance Report Annually Compliance with disclosure of GCG
• Implementation of GCG principles across all work units
implementation
• Disclosure of performance and activity reports
Reporting of CSR activities to Four times a year Disclosure of information on CSR implementation • Publication of the Sustainable Finance Action Plan, Annual
the BP BUMN / Danantara Report, Sustainability Report, CSR Report, and other reports
Business Organizations Meetings and activities As needed Enhancement of the Bank’s governance practices Organization of meetings and activities
at national, regional, and
international levels
Community Organizations / Strategic cooperation in As needed Optimization of CSR programs and indirect • Provision of employment opportunities for local communities
Social Organizations / NGOs implementing social and economic impacts on local communities • Optimization of CSR programs
environmental responsibility
programs
Media Press releases and press As needed Provision of information on the Bank’s business Dissemination of information to the public regarding BTN’s
conferences and activities activities and latest programs
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Digitalization
Materiality Assessment [GRI 3-1, 3-2, 3-3]
BTN applies the principles of impact, double materiality, and value chain as an integrated The Bank defines material topics as issues that have a significant impact on sustainability
framework to understand, measure, and manage the economic, social, and environmental performance and may influence stakeholder decision-making. The materiality
impacts of all its operational activities. Through this approach, the Bank is able to identify determination process also considers BTN’s enterprise risk management framework.
the most relevant and significant issues, both in terms of business sustainability and their Through this process, risks and opportunities related to material sustainability topics
impact on society and the environment. are identified, evaluated, and managed in a comprehensive manner to support the
achievement of the Bank’s strategic objectives.
Material Topic Review and Approval of Materiality Matrix
Material Topic Assessment
Identification Material Topic
• Identifying potential material The determination of material Following a comprehensive
topics aligned with BTN’s ESG topics is conducted using the review, the Board of Directors Human Rights
Higher
Roadmap by benchmarking double materiality assessment approved and evaluated the
Sustainable Information
against peer industries, global (DMA) approach, involving material topics disclosed in
Products and Security
standards (GRI, SASB, and stakeholders to assess the the report. Material topics that
Services
OJK), as well as ESG rating impacts and risks of material contribute to value creation are
agencies (MSCI, Sustainalytics, topics affecting the environment then aligned with the Bank’s
and S&P Global) with and society, as well as to strategy and assessed for their
reference to prior reports and evaluate the extent to which relevance to the Bank’s risks and
stakeholder input. these topics may influence opportunities. Community
Impact Materiality
• These topics are then further financial performance. Development
Business Ethics and
reviewed to result in 10 key • Environmental and social
Code of Conduct
material topics. The results materiality (impact
of this review are used as materiality): Use of Natural Resources
the basis for developing The assessment focuses on & Environmental
questionnaires to be the impacts of material topics Management Governance
distributed to both internal on external stakeholders,
and external stakeholders, including the environment and
in order to capture their society.
perspectives on the • Financial materiality:
Climate Change and Employment
significance and prioritization The assessment focuses
Ecosystems
of each topic. on potential impacts on
the Company’s financial Sustainable
performance and business Procurement
continuity.
Financial Materiality Higher
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Digitalization
In 2025, BTN reaffirmed the material topics established in the previous year, as they Material topics serve as a foundation for policy formulation, decision-making, and
remain relevant and significant to the impacts, risks, and opportunities associated with the implementation of sustainability initiatives while also providing a reference for
the Bank’s sustainability performance, as well as stakeholder expectations. A review the integrated management of economic, social, and environmental performance.
of material topics is conducted through an annual evaluation involving the Board of This ensures that the Bank’s responses to sustainability issues remain aligned with
Directors to ensure alignment with the Bank’s sustainability strategy, risk profile, and stakeholder priorities and expectations. The boundaries and scope of each material topic
evolving business dynamics. are presented in the following list.
Topic Boundary
Material Topic Materiality Consideration Internal
External Stakeholders
Stakeholders
Environmental Aspect
Climate Change and Ecosystems Describes the Bank’s commitment to addressing climate change challenges by Employees Investors, government, financial services authorities,
minimizing the environmental impacts of its operations through the management of GHG business partners/suppliers, and the media.
emissions and the improvement of energy efficiency.
Resource Use and Environmental Describes the Bank’s efforts to ensure the efficient use of water and material resources, Employees Investors, government, financial services authorities,
Management responsible waste management, and compliance with applicable environmental business partners/suppliers, and the media
regulations.
Social Aspect
Employment Describes human capital management with a focus on training, career development, Employees Customers, government, financial services authorities,
occupational health and safety (OHS), and the creation of a productive work environment. business partners/suppliers, and community/social
organizations/non-governmental organizations
Human Rights Describes the Bank’s commitment to upholding human rights, diversity, equity, and Employees Customers, investors, government, financial services
inclusion across all operational activities, employment relationships, and services. authorities, business partners/suppliers, the media, and
business organizations
Community Development Describes the Bank’s commitment to actively engaging in supporting communities Employees Customers, investors, government, financial services
through various financial literacy and empowerment programs to enhance community authorities, and community /social organizations/non-
well-being. governmental organizations
Information Security Describes the Bank’s efforts to safeguard the Bank’s data, customer data, and financial Employees Customers, investors, government, financial services
transactions from cyber threats, including hacking, data theft, and malware attacks. authorities, and the media
Governance Aspect
Governance Describes the Bank’s commitment to implementing sustainability governance, including Employees Customers, investors, government, financial services
strategic oversight of environmental and social–related risks and opportunities, as well as authorities, business partners/suppliers, community
monitoring sustainability performance. organizations/social organizations/non-governmental
organizations, the media, and business organizations
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Digitalization
Topic Boundary
Material Topic Materiality Consideration
Internal
External Stakeholders
Stakeholders
Sustainable Products and Services Describes the Bank’s efforts to integrate ESG aspects into the lifecycle of banking products Employees Customers, investors, government, financial services
and services, encompassing initial assessment, product and service development, authorities, business partners/suppliers, community
monitoring, evaluation, and impact assessment of products and services. organizations/social organizations/non-governmental
organizations, the media, and business organizations
Business Ethics and Code of Describes the Bank’s commitment to upholding business ethics and a code of conduct to Employees Customers, investors, government, financial services
Conduct maintain banking integrity and customer trust. authorities, business partners/suppliers, and business
organizations
Sustainable Procurement Describes the Bank’s commitment to managing a responsible supply chain by ensuring Employees Customers, investors, government, financial services
that suppliers comply with strict ethical, social, and environmental standards. authorities, business partners/suppliers, and business
organizations
Three Lines Model
As an essential framework for strengthening governance and the effectiveness of risk 2. Role of the First Line
management, the Three Lines Model serves as a guiding principle for BTN to ensure clear Acting as the primary executor and risk taker in risk management. This line ensures
roles, responsibilities, and coordination across all levels of the organization, supporting that strategies are implemented effectively, business decisions are made based on
transparent, accountable, and integrity-driven risk management while reinforcing the thorough risk analysis, and all operational activities comply with internal policies
integration of ESG principles. while integrating sustainability values.
1. Role of the Governing Body 3. Role of the Second Line
Holds primary accountability to stakeholders to ensure that the Bank’s activities Provides support and oversight for the implementation of risk management,
are conducted transparently, with integrity, and in alignment with good corporate including regulatory compliance, internal controls, and the execution of sustainability
governance principles. The Governing Body sets the strategic policy direction and practices. This line also ensures that ethical standards and governance principles
ensures the effective implementation of risk management and ESG principles in are applied consistently through the enterprise risk management (ERM) framework.
support of the Bank’s long-term objectives. 4. Role of the Third Line
This role is carried out by the Internal Audit function, which provides independent and
objective assessments of the effectiveness of governance and risk management
systems. The function ensures that all Bank policies and practices are aligned with
ESG principles and ensure that the Bank’s practices align with applicable regulations
and ESG principles, while providing recommendations for continuous improvement.
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Digitalization
ESG Framework
The ESG framework comprises six interrelated core components that serve as a reference
for the implementation of the Bank’s activities and operations.
The Future of Finance
Components of BTN’s ESG Framework
ESG in the Value Chain
Sustainable Finance Management of products and services that support the transition to
Climate Change & a low carbon economy, promote environmental sustainability, and
Sustainable Finance People & Community
Ecosystem maintain social balance by ensuring equitable access to financial
services and capital.
Climate Change and Management of climate change risks and their impacts on ecosystem
Ecosystem capacity.
Stakeholder Inclusiveness
People and Community Management of impacts on individuals, communities, and society at
Integrated GRC large.
Governance Risk Compliance ESG in the Value Chain Establishing a sustainable business system integrated with ESG
aspects across BTN’s entire business value chain.
Integrated GRC
Stakeholder Inclusiveness Prioritizing stakeholder inclusivity as a key focus in achieving
sustainability objectives.
As part of its commitment to strengthening sustainability governance, BTN has developed
an ESG framework entitled The Future of Finance, serving as a strategic guide for
managing business practices that are oriented toward performance impact and support Integrated Governance, Ensuring that sustainability is not merely a business foundation, but is
Risk, and Compliance fully integrated across all aspects of governance, risk management,
the achievement of the SDGs. Through this framework, BTN has established a foundation [GRC] and compliance
for more comprehensive, measurable, and sustainability-aligned decision-making.
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Digitalization
Awareness of the importance of good governance has become an integral
part of the Bank’s sustainability foundation. Transparent and accountable
governance serves as the cornerstone of all BTN’s sustainability efforts, ensuring
that every initiative is conducted with integrity, compliance, and responsibility.
ESG Governance [OJK E.1]
As the two main pillars of sustainability management, BTN has established the ESG Committee and the Enterprise
and ESG Risk Management Division (ERMD) as the two main pillars of sustainability management within the
Company. The ESG Committee, chaired by the President Director and comprised of members of the Board of
Directors and SEVPs. The Committee ensures that strategic direction, policies, and sustainability targets are
aligned with the SDGs and the Company’s climate targets. Throughout the reporting year, the ESG Committee
convened several meetings to review performance and formulate continuous improvement measures.
The ERMD operates under the oversight of the Board of Directors and is responsible for the implementation and
monitoring of ESG initiatives, including climate risk management, carbon emission reduction, and the conduct
of the Climate Risk Stress Test (CRST) to assess the impacts of climate change on business sustainability. The
Division also manages and coordinates sustainable finance initiatives through cross-unit collaboration with the
Corporate Secretary, Compliance and Governance, Commercial Banking, Corporate Banking, Digital Banking
Product Development, and other supporting units to ensure the integration of ESG aspects across all BTN business
processes.
More detailed information on sustainability governance policies, structures, and practices, including risk
management, regulatory compliance, and commitments to ethical standards and transparency, is presented in
the chapter Upholding Governance as the Foundation of Sustainability.
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Digitalization
ESG Policy
Strategy Development
BTN has formulated 9 (nine) strategic steps that are carried out in an inclusive and applying ESG principles across the organization. These policies are further reinforced by
integrated manner to strengthen the application of sustainability principles across all technical guidelines on the Climate Risk Stress Test (CRST), greenhouse gas emissions
business lines, as follows: management, and the preparation of sustainability reports, ensuring that business
1. Implementing sustainable banking operations and business activities. practices are aligned with sustainable development objectives.
2. Developing sustainable and inclusive banking products and portfolio management.
3. Integrating ESG components into the enterprise risk management (ERM) framework Reporting and Communication
and business risk management programs.
4. Developing ESG culture programs and responsible leadership. As part of its commitment to sustainability principles, the Bank systematically manages
5. Establishing a control environment integrated with ESG components. ESG performance data and information across all operational lines, with a strong
6. Developing ESG monitoring, communication, and reporting programs. emphasis on accuracy, transparency, and compliance with reporting standards.
7. Building robust ESG data management. Monitoring is carried out through the Digital Action Log & Monitoring System (DAMS), which
8. Navigating ESG-related regulatory and policy trends. facilitates regular updates on the progress of ESG initiatives, and is further strengthened
9. Building partnerships and collaborations. by the Integrated ESG Dashboard System as part of the strategy to Establish ESG
Monitoring, Communication, and Reporting Program. The dashboard presents ESG data
Policy in a centralized digital platform, covering environmental, social, and sustainable portfolio
aspects to support data-driven decision-making.
BTN continues to strengthen the implementation of sustainability principles to realize its
vision as the “Leading partner in empowering the financials of Indonesian families”. These ESG data is used to assess progress against sustainability targets and identify areas
principles serve as the foundation for all operational activities and business decision- for improvement, serving as a basis for refining ESG policies and initiatives to enhance
making. As a manifestation of this commitment, the Bank has established General effectiveness. Performance evaluations are conducted periodically through one-on-one
Policy No. KU.10 on Environmental, Social, and Governance (ESG) and Special Policy No. sessions with work units to ensure that ESG implementation is consistent, measurable,
KK.10-A on ESG Implementation Procedures, which serve as the primary guidelines for and delivers positive impacts for all stakeholders.
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Digitalization
ESG Achievements and Results
BTN ESG Roadmap
BTN’s sustainability roadmap is designed to realize The Future of Finance through clear In formulating its ESG framework, strategy, and roadmap, BTN places stakeholder
and measurable stages. Each phase represents a distinct area of focus in strengthening engagement as a key element in the design process. This approach is reinforced through
the Bank’s ESG transformation journey, as illustrated below. benchmarking activities with companies, both domestically and internationally, that
have successfully implemented effective ESG practices. In addition, at the early stage
of implementation, BTN conducted an ESG workshop involving 20 internal work units as
2023-2025 | Action Phase supporting validators to review and refine the proposed framework and ESG initiatives,
ensuring alignment with the Bank’s readiness and ambitions.
During this phase, BTN began integrating ESG principles into its operational
and business activities. The primary focus was on strengthening the ESG
In 2025, through the implementation of various sustainability initiatives across the
implementation foundation so that it becomes an integral and embedded part
ESG pillars, BTN successfully achieved several targets set at the beginning of the year,
of every Bank process.
including:
Environmental Aspect
2026-2027 | Advance Phase
2025 2025
During this phase, BTN strengthens its commitment to ESG by expanding the Initiative Indicator
Target Achievement
scope and impact of its initiatives. The Bank focuses on enhancing social and
Sustainable credit Total sustainable loans/financing (Rp 200.26 203.45
environmental responsibility, with efforts directed toward increasing positive financing trillion)
contributions to society and the environment.
Social Aspect
2028-2029 | Fase Accelerate 2025 2025
Initiative Indicator
Target Achievement
This phase reinforces BTN’s commitment to accelerating the positive impact of
Employee diversity Average composition of nominated talent
ESG implementation through effective initiatives aligned with the Bank’s vision.
These efforts reflect BTN’s determination to advance sustainable finance in Female talent 28% 33.3%
support of the achievement of the SDGs. Young talent 16.5% 16.67%
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Digitalization
2025 2025 The achievements of programs and activities in support of sustainable finance in 2025
Initiative Indicator
Target Achievement
are presented based on the following five main pillars:
Financial inclusion Total MSME loan disbursement (Rp 4.41 5.67
trillion)
Creating equal Number of employees with disabilities, 10 14 Sustainable Finance
opportunities for recruitment to support equal
employment opportunities for persons
with disabilities BTN 5
Pillars
Governance Aspect Risk
Management, Social and
Human
Product Governance, Technology Environmental
2025 2025 Resources
Initiative Indicator Procedures, and Responsibility
Target Achievement Policies
Cybersecurity breach Number of reported cybersecurity breach 0 0
incidents
Description Driving the Ensuring that Enhancing human Digital Implementing
Sustainable Finance Action Plan (SFAP) [OJK E.1, D.1.b] development of procedures, resource capacity applications a range of
products and/ policies, and risk to support the to support the programs related
or services in line mitigation are implementation development to environmental
As one of the largest banks in Indonesia, BTN is committed to strengthening the with economic, implemented in of sustainable of the Bank’s and social
implementation of sustainable finance through the Sustainable Finance Action Plan social, and accordance with finance products and/or responsibility
environmental the Bank’s product services
(SFAP), which serves as a strategic guide for the development of its financing portfolio,
aspects and/or service
the strengthening of business processes, and the implementation of responsible risk standards
management.
This commitment is aligned with BTN’s support for the government’s program to develop The SFAP not only serves as a strategic guideline but also acts as a relevant driver of
three million housing units for low-income communities (MBR). Through inclusive and change within the Bank’s business processes and risk management. The SFAP plays a
sustainable financing, BTN contributes to strengthening the national housing ecosystem central role in ensuring the integration of ESG risk management across all of the Bank’s
and promoting equitable development. business activities, implementing various programs under the 2025 SFAP, including:
The 2025 SFAP focuses on five main pillars of BTN’s sustainable finance framework, which
serve as the basis for the implementation of various programs and activities. BTN ensures
the application of the prudential principle and effective risk management to maintain
business stability while enhancing community welfare.
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Digitalization
Risk Management, Governance, Social and Environmental
Product Pillar Human Resources Pillar Technology Pillar
Procedures, and Policies Pillar Responsibility (CSR) Pillar
• Provision of working capital • Implementation of a gratification • Empowering Women in Leadership • e-Statement for current account • BTN Entrepreneurship
and/or investment financing control program • Creating Equal Opportunities for statements Competition
to companies in the renewable • Installation of solar panels at BTN offices Persons with Disabilities • Paperless time deposit • Skills enhancement programs
energy sector • Development of electric vehicle • Short courses, training, and (certificate-free deposit) for persons with disabilities
• Support for the Drinking Water charging stations (SPKLU) education programs in • Enhancement of electronic • Tree and/or mangrove planting
Supply System (SPAM) project • Procurement of one ambulance unit at collaboration with universities, Credit Committee meetings initiatives
• Credit disbursement for the BTN Tower 2 associations, institutions, and (e-RKK) • MSME development training
construction of fertilizer plants • Replacement of the cooling machine agencies • Virtual debit card programs
using renewable technologies to (chiller) in the BTN Tower • Public lectures and workshops • Government bond (SBN) • Social Return on Investment
support production efficiency • Payroll customer flagging for universities, associations, purchases via mobile banking (SROI) assessment
• Credit disbursement for • ESG and low-emission housing institutions, and agencies • Digitalization of MSME loan • Scholarships for the children of
sustainable natural resource and awareness initiatives • Seminars for alumni of short applications (BTN Laku) BTN outsourced workers
land management • ESG ratings and signatory initiatives course, training, and education • Web-based mortgage
• Thematic ESG wholesale funding • Development of a Net Zero Emission programs conducted in application submission
• Thematic credit disbursement to (NZE) roadmap collaboration with universities, • Tree planting through the
financial institutions • Use of electric vehicles (EVs) as associations, institutions, and redemption of balé poin on BTN
• Eco Property Developer Meeting operational vehicles agencies Mobile
• Eco Housing Fee Saver • Green building certification for bank • Enhancing ESG-based MSME • Annual ESG campaign programs
• Digital MSMEs operational offices or other strategic capabilities through social media and
• Green Kring financing (paperless buildings • Implementation of ESG training internal media
end-to-end process) • Efficiency in paper usage and programs • Development and enhancement
• Kring Go Green implementing an procurement • ESG Day implementation of ESG data architecture
end-to-end and 100% paperless • Efficiency in electricity and water • Customer engagement • Development of an ESG
process consumption activities through training and/ knowledge portal
• MSME loans • Fuel efficiency aligned with the growth or socialization with customers • Digital signature implementation
• Subsidized mortgage loans of electric vehicles related to financed emissions • Enhancement end to end
• Use of 15% eco-friendly materials in • Use of electric and hybrid vehicles as • Development of ESG award procurement
10,000 low-emission housing units official operational vehicles (COP) for programs for both internal and • Implementation of digital
Bank management (Division Heads and external stakeholders branches across 7 branch
Regional Heads) • Socialization and education on offices
• Supplier and vendor engagement digital mindset
activities related to sustainable • Employee scholarships
practices • Enhancement of employee
• Enhancement of data privacy and diversity programs
cybersecurity
• Development of nursery room facilities
at 82 branch office
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Digitalization
BTN’s Commitment to the Principles for Responsible Banking
As part of its efforts to strengthen the role of the financial sector in advancing sustainable development, the Bank has been an official
signatory to the UN Principles for Responsible Banking (PRB) since 2024. This global framework, developed in collaboration with the United
Nations Environment Programme Finance Initiative (UNEP FI), aims to ensure that banking strategies and practices are aligned with the
SDGs and the Paris Agreement.
As the first state-owned bank in Indonesia to adopt these principles, BTN is committed to strengthening its sustainability strategy through
the integration of ESG aspects across all business activities. This step also serves as an important foundation for fostering innovation and
expanding sustainable finance within the national banking sector.
BTN applies the six core PRB principles as guidelines for its operations and decision-making. The following presents the key explanations
and the implementation progress of each principle:
Principle 1: Implementation Progress
Alignment BTN aligns its business strategy, operational activities, and financing policies with national housing development
priorities and the global sustainable development agenda (SDGs). As a bank with a primary focus on housing finance,
This principle emphasizes aligning business strategies BTN directs its main contribution toward expanding access to adequate and affordable housing, particularly for low-
with the needs of individuals and broader development income communities, while also supporting the development of more energy-efficient and lower-emission housing.
objectives, in line with the Sustainable Development
Goals (SDGs), the Paris Agreement, and relevant national This commitment also supports the achievement of Indonesia’s Nationally Determined Contribution (NDC) targets as
and regional frameworks. part of the transition toward a low-carbon economy, particularly through more sustainable financing in the property
sector.
BTN aligns its policies and practices with regulations issued by the Otoritas Jasa Keuangan related to sustainable finance,
including POJK 51/POJK.03/2017, the Principles for Responsible Banking, and other relevant national and international
frameworks.
To ensure structured and measurable implementation, BTN has developed an ESG Roadmap as a guideline for
implementing its sustainability strategy, which will continue to be refined in line with evolving business developments,
regulatory requirements, and stakeholder expectations.
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Digitalization
For further information, please refer to the BTN Sustainability Report in the following chapters/sub-chapters:
• Real Impact of BTN for Sustainability
• BTN’s Contribution to the Sustainable
• Development Goals
• Sustainability Vision, Mission, and Values
• BTN Business Activities
• Building a Sustainable Finance Ecosystem
Implementation Progress
Principle 2:
BTN systematically identifies, prioritizes, and manages both the positive and negative impacts arising from its financing
Impact and Target Setting
and operational activities.
This principle emphasizes a commitment to increasing
In 2024, BTN conducted an impact analysis using the United Nations Environment Programme Finance Initiative Impact
positive impacts while minimizing negative impacts
Analysis Tools. The analysis identified two primary impact areas, namely Finance and Housing, reflecting BTN’s core role
and risks to society and the environment arising from
within the financial system and the housing sector.
activities, products, and services. To support this
commitment, sustainability targets are established and
The analysis was conducted on the consumer banking portfolio, which represents 86% of the Bank’s total assets, using
disclosed, focusing on areas with the most significant
data as of December 2023. Within this portfolio, subsidized mortgage financing for low-income communities accounts
impacts.
for a significant share, representing approximately 60% of the total consumer loan portfolio.
In line with the results of the impact analysis, BTN is preparing to establish targets for the identified key impact areas.
These targets will be disclosed in greater detail in a separate report to be released in mid-year.
For further information, please refer to the BTN Sustainability Report in the following chapters/sub-chapters:
• ESG Achievements and Results
• BTN Commitment to the Principles for Responsible Banking
• BTN Impact Radar
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Digitalization
Principle 3: Implementation Progress
Clients and Customers BTN implements responsible banking practices by ensuring that financing is provided in a prudent, transparent, and
sustainability-oriented manner to support the long-term financial well-being of customers.
This principle emphasizes responsible engagement with
clients and customers to promote sustainable business By supporting low-income communities in accessing adequate housing and improving their quality of life, BTN
practices and economic activities that create prosperity advances its business growth while contributing to society’s ability to address broader global challenges. This approach
for present and future generations. strengthens the Bank’s ambitions in environmental, social, and governance (ESG) performance.
• Customer engagement is carried out through:
• Comprehensive affordability assessments and prudent lending principles
• Transparency of product information and fees
• Financial literacy and education programs
BTN also ensures the protection of customer data and privacy through the implementation of information security
systems, strengthened internal controls, and compliance with applicable data protection regulations.
Through these efforts, relationships with customers are built on trust, protection, and long-term sustainability.
For further information, please refer to the BTN Sustainability Report in the following chapters/sub-chapters:
• Driving ESG and Digital Product Innovation
• Risk Management
• Financial Product Oversight
• Fair Advertising Policy
• Customer Financial Protection
• Customer Data Privacy and Security
• Handling Complaints on Financial Products
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Digitalization
Implementation Progress
Principle 4:
BTN recognizes that understanding sustainability impacts, risks, and opportunities requires active dialogue with
Stakeholders
stakeholders. Stakeholder engagement plays a key role in ensuring that the Bank’s sustainability strategy and priorities
remain relevant and responsive to evolving expectations.
This principle emphasizes a proactive approach to
consulting, collaborating, and building partnerships with
BTN engages customers, investors, NGOs, senior management, employees, regulators, and supervisory authorities
relevant stakeholders to achieve shared objectives for
through a structured process. The process begins with stakeholder mapping to classify stakeholders based on their
society.
level of significance and the material issues involved, enabling targeted communication and collaboration approaches.
In the context of transforming the housing sector, BTN collaborates with developers and suppliers to encourage the
adoption of more energy-efficient construction practices. This includes the use of sustainability parameters and
checklists in project evaluation. These efforts aim to build a more sustainable housing ecosystem and create long-term
value for all stakeholders involved.
For further information, please refer to the BTN Sustainability Report in the following chapters/sub-chapters:
• Stakeholder Engagement
• Materiality Assessment
• Social and Environmental Responsibility.
Principle 5: Implementation Progress
Governance and Culture BTN ensures that its commitment to the Principles for Responsible Banking (PRB) is integrated into the Bank’s governance
system and decision-making processes. This integration is carried out through strengthening the organizational
This principle emphasizes the implementation structure, enhancing strategic oversight, updating relevant internal policies, and aligning ESG and PRB principles within
of sustainability commitments through effective the Bank’s governance framework.
governance practices and the strengthening of a
responsible banking culture. As part of this implementation, BTN has established an ESG Committee chaired by the President Director to provide
strategic direction and oversee the implementation of the ESG Roadmap. Operational support is provided by the ESG
Department, which coordinates with the risk management directorate to ensure the integration of ESG aspects within
the Governance, Risk, and Compliance (GRC) framework, including the management of climate-related risks.
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
BTN recognizes that effective governance depends on both organizational structure and a strong culture that supports
its implementation. In this regard, BTN strengthens the internalization of sustainability values through the development
of ESG curricula for employees, continuous training programs monitored through an internal learning dashboard, and
the integration of sustainability principles into the Bank’s risk culture and corporate values.
For further information, please refer to the BTN Sustainability Report in the following chapters/sub-chapters:
• BTN Sustainability Governance Structure • Code of Ethics and Business Conduct
• Commitment to Governance Implementation • Human Capital Management
• Governance Strategy • Training and Competency Development
• Risk Management
Principle 6: Implementation Progress
Transparency and Accountability BTN is committed to maintaining transparency and accountability in the implementation of the Principles for Responsible
Banking (PRB) and in managing the impacts generated by its business activities.
This principle emphasizes periodic reviews of the
implementation of sustainability principles while ensuring Sustainability information is disclosed through the Annual Report and Sustainability Report, prepared in accordance
transparency and accountability for impacts and with applicable regulations and relevant reporting standards, including the Global Reporting Initiative, the Task Force on
contributions to sustainable development objectives. Climate-related Financial Disclosures, and the International Financial Reporting Standards Foundation.
To enhance credibility and disclosure quality, sustainability information has undergone an independent assurance
process based on the AccountAbility and the GRI Standards.
Through the implementation of Good Corporate Governance principles, strengthened internal control systems, and
periodic evaluations of sustainability policies and practices, BTN ensures that its commitment to responsible banking is
implemented consistently and remains accountable to all stakeholders.
For further information, please refer to the BTN Sustainability Report in the following chapters/sub-chapters:
• About This Report • Code of Ethics and Business Conduct
• Independent Assurance Statement • Implementation of the Prudential Principle
• Report Standard Index • Internal Oversight and Anti-Gratification Practices.
• BTN Sustainability Governance Structure
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
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y
it ke
Cred ive
t
nega rea
ct a
impa
To ensure effective implementation, the Bank has conducted an
initial impact analysis of its customer portfolio, preparing its first
PRB report within 18 months of becoming a signatory. In addition,
BTN has set specific targets for priority impact areas, reflecting its
consistency in implementing the PRB principles in a measurable
and sustainable manner.
BTN Impact Radar
In implementing the UN Principles for Responsible Banking,
the Bank recognizes the importance of evaluating the social,
neg key
e
economic, and environmental impacts of its financial activities.
ativ
are t
ac
dit
a
imp
Cre
Through the adoption of the Impact Radar framework developed
positiv
Credit
impac
by UNEP FI, the Bank is able to comprehensively identify and
key
Credit
e
t
positiv
impac
key
manage both positive and negative impacts. This framework
e
t
encompasses the three main pillars of sustainable development,
namely economic, social, and environmental, which serve as the
foundation for integrating sustainability into the Bank’s business
strategy.
This approach is further strengthened through the use of the
UNEP FI Portfolio Impact Analysis Tools, which support BTN in
establishing sustainability priorities in a contextual and data-
driven manner. These tools enable measurable strategic
actions to maximize positive impacts while mitigating potential
negatives. The combination of the Impact Radar and the portfolio
analysis tools serve as a key foundation for the development of
comprehensive impact management guidelines, while ensuring
alignment with global efforts to achieve the SDGs.
C
re
po ke dit key
dit
im it y
s Cre tive &
s i
pa ive po ative
ct neg t Area
ac y
imp ing ke
Sav sitive
po t area
ac
imp
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
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Through this approach, BTN conducts an analysis of impact areas and topics that are In the housing sector, BTN contributes to expanding access to decent and affordable
relevant to its portfolio, particularly in the financial and housing sectors, which represent housing with approximately 61% of BTN mortgage beneficiaries located in rural areas with
two strategic areas with the most significant contributions to sustainable development. limited access to housing. In terms of age profile, around 68.12% of beneficiaries belong
The analysis focuses on the customer portfolio, which accounts for approximately 70% of to the productive age group between 30 and 60 years, and 31% of mortgage financing
the Bank’s total portfolio. is extended to women, reflecting BTN’s commitment to supporting gender equality in
housing access and strengthening household economic empowerment.
In the financial sector, the analysis results indicate that BTN plays a critical role in
advancing financial inclusion through financing for low-income communities. This is Through the impact analysis process, BTN is able to evaluates the extent to which its
reflected in the allocation of 59% of the mortgage portfolio to the subsidized mortgage activities contribute to the achievement of the SDGs. This not only strengthens the Bank’s
segment, thereby expanding access to housing finance for vulnerable groups and capacity to manage social and environmental impacts, but also reinforces its position as
strengthening social and economic stability within communities. a responsible financial institution with a long-term sustainability orientation.
BTN Impact Analysis on the SDGs
Goal 5 Goal 8 Goal 9 Goal 10 Goal 11
Promoting gender equality by Supporting job creation and Contributing to the Prioritizing financing for Providing access to decent
providing inclusive financial economic growth by providing development of sustainable low-income communities, and affordable housing to
access for women through affordable financing. housing infrastructure and particularly in rural areas. support the development
specially designed products innovation. of safe and sustainable
and services. communities.
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Pendahuluan BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
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Digitalization
Promoting BTN strengthens housing finance inclusion for low-income communities, including informal workers and first-time homebuyers, through
Sustainable the distribution of subsidized mortgages designed to be more affordable. The scheme reduces initial barriers to homeownership
Financial Health through lower upfront costs, affordable installments, and simplified application and approval processes, including down payment
through Inclusive support starting from 1%.
Homeownership
To strengthen customers’ long-term financial health, the Bank encourages sound financial management through the provision of
savings and investment products, while promoting payment discipline through fixed and predictable installment structures. The Bank
also provides bundled home and life insurance, as well as post-purchase support to help customers manage their financing obligations
responsibly. Access to these complementary products is further expanded through integration within the balé by BTN Super App.
In line with its sustainability agenda, the Bank has introduced the “Pay Your Mortgage with Your Waste” initiative, which allows residents
to exchange household waste at recycling locations for points that are converted into Rupiah and used to pay mortgage installments.
The Bank also supports the development of more environmentally friendly residential areas through the implementation of low-
emission housing that incorporates eco-friendly materials, including recycled materials, waste segregation practices, water efficiency
measures, and energy efficiency features. These include building designs with improved natural ventilation, a window-to-wall ratio
of 15%–30%, and the use of solar-powered street lighting, contributing to cleaner, healthier, and more cost-efficient communities for
residents.
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03
Managing the Environment
Responsibly
70 Energy Management
73 Emissions Management
79 Water and Effluent Management
81 Waste Management
84 Environmental Control and
Compliance
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
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Climate change and environmental degradation are increasingly tangible global challenges
that affect economic sustainability and societal well-being. Recognizing this urgency, the Bank
is committed to minimizing the environmental impacts of all its operational activities while
strengthening the management of climate and ecosystem-related risks as an integral part of the
ESG framework.
As a manifestation of this commitment, BTN has developed various climate change In addition, the Bank ensures compliance with all environmental and social management
mitigation and ecosystem protection programs, reflecting the Bank’s support for the requirements through the regular submission of the Environmental Management and
government’s commitment to achieving net zero emission by 2060 and its contribution Monitoring Plan (RKL–RPL) reports twice a year. This reporting is conducted in accordance
to the achievement of the SDGs, particularly Goal 13: Climate Action. with the Decree of the Minister of the Environment No. 45 of 2005 and applicable laws and
regulations, as a demonstration of BTN’s responsibility to maintain a balance between
business activities and environmental conservation.
Energy Management
Energy availability is critical to the continuity of banking operations and services. In Although energy consumption in the banking sector is relatively lower compared to other
carrying out its activities, the Bank utilizing electricity to support lighting systems, air industries, BTN recognizes that its operational activities still have the potential to impact
conditioning, elevators, and various office equipment. In addition, the Bank uses fuel for the environment. Accordingly, energy management constitutes an important component
operational vehicles and generators as backup power sources. of the Bank’s efforts to support sustainability.
[GRI 3-3]
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Energy Management Performance
BTN conducts comprehensive measurement and recording of energy consumption BTN also measures energy intensity within the organization to assess the level of energy
that serves as a basis for evaluating the effectiveness of energy-saving initiatives and use efficiency in relation to operational activities, based on both the revenue and the
improvements in operational efficiency. Since 2024, the scope of data has been expanded number of branch offices, as presented in the following table: [GRI 302-2, 302-3] [OJK F.6]
to include several branch offices, resulting in data that is more representative of the
Bank’s overall operations, including the Head Office, Regional Offices, and Branch Offices. Energy Consumption Intensity
In light of this expansion, BTN has set 2024 as the baseline year for energy consumption
Denominator Unit 2025 2024 2023
calculations, which will serve as a reference for assessing trends in energy efficiency in
Revenue GJ/Rp 0.000000007 0.000000011 0.000000004
subsequent years.
Office Unit GJ/office unit 459.82 513.95* 157.56
Energy measurement uses the methodology of the Ministry of Energy and Mineral *Data restated
Resources, by multiplying the volume of energy consumed in physical units by the
corresponding calorific values. Based on this methodology, total energy consumption Based on the table above, energy intensity per office unit in 2025 will decrease by 10.53%
within the organization during the reporting year is presented as follows: compared to the previous year. This decrease is due to increased energy efficiency
initiatives in the Bank’s operations.
Energy Consumption [GRI 3-3, 302-1] [OJK F.6]
Energy Source Unit 2025 2024 2023
Non-renewable Energy
Electricity GJ 162,616 224,920 34,276
Fuel GJ 131,783 155,332 82,321
Renewable Energy
Electricity (Solar Power Plant) GJ 806 69 -
Total Energy Consumption GJ 295,206 380,321* 116,597
*Data restated
Based on the table above, energy use in 2025 will decrease by 22.38% or 85,115 GJ compared
to the previous year. This decrease is due to energy efficiency initiatives. Although the
Bank has not yet calculated energy consumption outside BTN or the energy reductions
associated with sold products and services, the Bank is committed to developing a more
comprehensive methodology to measure overall energy efficiency in the future.
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Energy Management Initiatives
As part of its sustainability strategy, BTN implements various energy efficiency initiatives
focused on areas with the most significant contribution to the Bank’s overall energy Solar Panels Electric Vehicles EV Charging
consumption. Based on the identification results, air conditioning systems (chillers) Station
12 offices 48 units 8 offices
and elevators are the two primary contributors to electricity usage in office buildings.
Accordingly, efficiency programs have been implemented at BTN Tower through a
range of measures, including optimal temperature settings, the use of energy-efficient
equipment, and regular maintenance to ensure optimal performance of electrical
systems. The initiatives implemented include: [GRI 302-4, 302-5, 305-5] [OJK F.7, F.12] Increasing the Use of New and Renewable Energy (NRE) [GRI 302-4, 302-5] [OJK
1. Utilizing 48 electric vehicles to support operational activities; F.7]
2. Establishing 8 public electric vehicle charging stations at BTN Tower 1 BTN Tower 2,
as well as several Regional Offices and Branch Offices to support the adoption of As part of its commitment to the clean energy transition, BTN has gradually increased the
electric vehicles and reduce the Bank’s carbon footprint; utilization of new and renewable energy (NRE) through the installation of solar panels at
3. Encouraging employees to use public transportation when commuting to the office; several operational offices. As of the end of the reporting year, 12 BTN offices had installed
4. Using fuel for all operational vehicles in accordance with government policy solar panels with a total capacity of 473.08 kWp.
prohibiting the use of high-octane fuel;
5. Supporting and participating in Earth Hour activities since 2022;
6. Implementing policies to reduce electricity loads in office buildings after operational Solar Panel Utilization in
hours; 2025
7. Utilizing a Building Automation System (BAS) to regulate the use of electrical
equipment, such as lighting, elevators, and air conditioning, to improve efficiency.
The system includes adjustments to operating schedules;
223,995.26 kWh
8. Conducting energy-saving awareness campaigns for BTN employees;
9. Replacing tubular lamps (TL) and essential lighting with light-emitting diode (LED)
lamps;
806.38 GJ
10. Modernizing 10 elevator units with more efficient, latest-model control and mechanical
systems;
11. Installing motion sensors in meeting rooms to reduce lighting use; Solar panels successfully replaced 806.38 GJ of conventional electricity consumption,
12. Replacing outdated or inefficient chillers at BTN Tower; representing an increase of 1,071% compared to 2024 at 68.87 GJ, thereby reducing the
13. Replacing and procuring new air conditioning units with inverter-type systems; and Bank’s reliance on fossil-based energy. This initiative serves as tangible evidence of BTN’s
14. Using LED videotron media for advertising purposes. commitment to mitigating carbon emissions and strengthening the implementation of
sustainability principles across its operational activities.
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Emissions Management
Greenhouse Gas Emissions
As a financial institution supporting the transition toward a low-carbon economy, In line with this commitment, BTN is strengthening its emissions management by developing
BTN places greenhouse gas (GHG) emissions management as a key focus under the more comprehensive Net Zero Emission (NZE) targets and advancing a decarbonization
Climate Change and Ecosystem pillar within its ESG framework. Through this approach, strategy aligned with the Science Based Targets initiative (SBTi) framework. This
the Bank seeks to ensure that environmental impacts are managed in a structured commitment is reflected in a time-bound and measurable decarbonization pathway
and measurable manner and integrated with its business strategy and long-term risk (Net Zero Path), covering short- to long-term horizons as a guideline for gradual and
management. [GRI 3-3] consistent emissions reduction toward achieving NZE by 2050. [GRI 3-3]
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The decarbonization pathway serves as a reference framework for implementing and strengthening operational efficiency. These initiatives are implemented in line with
various emission reduction initiatives in the Bank’s operations (Scope 1 and 2), including BTN’s ESG Roadmap 2023–2029 and support the Bank’s contribution to the Sustainable
improving energy efficiency, optimizing digitalization to reduce paper consumption, Development Goals (SDGs), particularly Goal 13 on Climate Action.
Base-year (2024)
Ne
tZ
ero
Pa
th SBTi’s Target
42%
NZE 2050
Historical Near-Term Long-Term
(2020-2025) (1-5 years) (5-20 years)
By 2030, BTN will achieve 42% By 2050, BTN will achieve Net-Zero
emissions reduction for Business emissions with residual emissions
Operational Emissions less than 2%
2020 2025 2030 2035 2040 2045 2050
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Greenhouse Gas Emissions Reduction Performance Scope 1 and Scope 2
BTN’s GHG inventory measures the global warming potential (GWP) of CO2, CH2, and
N2O, with calculation results expressed in tons of CO2 equivalent (tCO2e). Emissions are
monitored on a regular basis across all operational areas, covering the Head Office,
Regional Offices, and Branch Offices, including:
Scope 1 Scope 2
Direct emissions from the Indirect emissions from the
use of fuel for transportation, consumption of electricity
generators, and refrigerant. supplied by PLN.
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Emissions calculations are conducted using the operational control approach and into operational efficiency, enabling the Bank to monitor emission reduction trends over
are based on the IPCC Guidelines 2006 (2019 update) as well as ISO 14064 standards. time and serving as an indicator of progress toward its emission reduction targets. [GRI
Electricity emission factors refer to the Directorate General of Electricity 2020, while fuel 305-4] [OJK F.11]
emission factors are derived from Lemigas, Ministry of Energy and Mineral Resources 2021.
Biogenic CO2 emissions are excluded from these calculations. [GRI 305-1, 305-2] [OJK F.11] Table of Scope 1 and Scope 2 GHG Emissions Intensity
Denominator Unit 2025 2024 2023
BTN’s Scope 1 and Scope 2 GHG emissions performance during the reporting period is
Revenue ton CO2eq /Rp 0.0000000014 0.0000000020 0.0000000005
presented as follows:
Office Unit ton CO2eq /office unit 90.66 92.07 21.95
Table of Scope 1 and Scope 2 GHG Emissions
Emission Source Remarks Unit 2025 2024 2023
Greenhouse Gas Emissions Reduction Performance Scope 3
Scope 1 GHG Emissions
Direct emissions from ton CO2eq
271 210 124 In line with the expansion of BTN’s emissions reporting, the Bank has also mapped
stationary combustion
Fuel and calculated Scope 3 GHG emissions. Measurements were taken for three types
Direct emissions from ton CO2eq
7,692 9,160 4,844 of greenhouse gases, namely CO2, N2O, and CH2. Scope 3 emissions cover three main
mobile combustion
Refrigerant Use Fugitive emissions ton CO2eq 5,028 2,685 2,314
categories:
Total Scope 1 GHG Emissions ton CO2eq 12,992 12,054 7,282
Scope 2 GHG Emissions Purchased goods and services: Emissions arising from goods and
Electricity ton CO2eq 40,292 56,074 8,694 services purchased by the Bank, calculated in accordance with the
Total Scope 2 Emissions ton CO2eq 40,292 56,074 8,694 GHG Protocol;
Total Scope 1 and Scope 2 Emissions ton CO2eq 53,284 68,128 16,246
Business travel: Emissions generated from employee business
GHG emissions from Scope 1 and 2 in 2025 will decrease by 14.56% compared to 2024 travel, including transportation and accommodation, calculated in
as the base year. This decrease is influenced by energy efficiency initiatives that have line with the GHG Protocol standards;
been implemented and increased use of renewable energy sources.The year 2024
was chosen as the baseline because the data coverage used has been assessed as
the most comprehensive, covering all work units and applying a proxy approach to Financed emissions: Emissions associated with BTN’s financial
previously unavailable data, thus providing a more accurate and representative basis services, investments, and lending activities to customers,
for comparison. calculated using the Partnership for Carbon Accounting Financials
(PCAF) standard. The analysis is conducted by business sector,
In addition to total emissions, BTN calculates GHG emission intensity, defined as the including construction, energy, transportation, and manufacturing
amount of emissions per revenue and per office unit. This intensity metric provides insight industries.
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The calculation of Scope 3 emissions provides a strategic basis for the Bank to assess Greenhouse Gas Emissions Reduction Initiatives [GRI 305-5] [OJK F.12]
and manage its overall GHG impacts in a comprehensive manner, serving as a reference
for the formulation of more targeted and measurable supply chain emission reduction Based on the results of emissions measurement and analysis, BTN has implemented
policies and initiatives in the future. various initiatives to reduce GHG emissions, both from direct operations and through
portfolio and supply chain management:
However, given the breadth and diversity of categories in Scope 3, measurements are 1. Energy efficiency and renewable energy
currently still being carried out in stages and the Bank has not yet established a baseline Installation of solar panels at 12 offices and the use of 48 electric vehicles to support
for Scope 3. BTN is also developing Net Zero Emissions (NZE) targets and a roadmap, low-carbon operations.
which will serve as the basis for establishing a baseline and strengthening a more 2. Sustainable procurement and sustainable waste management
comprehensive Scope 3 emissions reduction strategy going forward. Reducing emissions from purchased goods and services while minimizing the
environmental impact of operational waste.
Information on the results of the Scope 3 GHG emissions calculations is presented as 3. ESG-based Portfolio Guidelines
follows: [GRI 305-3] [OJK F.11] Safeguarding the credit portfolio by avoiding financing to sectors with high
environmental risk, while also managing financed emissions.
Summary of BTN’s Scope 3 Emissions 4. Engagement with business partners
Encouraging the disclosure of GHG values associated with products transacted with
Category Unit 2025 2024 2023
the Bank to enhance value chain transparency and accountability.
Purchased goods and services ton CO2eq 4,922 4,739 6,447
Business travel ton CO2eq 711 3,294,32 285
Green Initiatives for Carbon Sequestration
Financed emissions* [FN-CB-410b.3] ton CO2eq 3,734,612 573,032 691,256.65
Total ton CO2eq 3,740,245 581,065.32 698,018.65 BTN is committed to environmental preservation through various conservation programs
*Financed emissions coverage in 2025: 100% of corporate portfolio and 100% of commercial portfolio
and initiatives. One key measure is ensuring that its operational offices are not located
within conservation areas or protected biodiversity zones. This commitment serves as a
In 2025, Scope 3 GHG emissions, particularly financed emissions, increased due to foundation for the Bank in designing and implementing environmental initiatives. [GRI 3-3]
changes in methodology from the previous year. [OJK F.9, F.10]
As part of these efforts, the Bank implements reforestation programs through the planting
of various types of trees, such as teak, mahogany, and mangroves, to support ecosystem
preservation while contributing to carbon emission reduction. These activities are carried
out across several Branch Offices and various other locations. To ensure effectiveness,
the Bank calculated the carbon absorption generated by the planted trees so that the
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impact can be measured quantitatively. The details are presented in the following table. Carbon Sequestration from Tree Planting
carbon emissions. To ensure effectiveness, the Bank calculated the carbon absorption
Description Unit 2025 2024 2023
generated by the planted trees so that the impact can be measured quantitatively. The
Total Number of Trees Tree 26,648 29,615 5,323
details are presented in the following table.
Total Carbon Sequestration Value ton CO2eq 31,600 18,291 3,449
Mangrove Planting
The mangrove ecosystem restoration program for blue carbon, covering mangrove restoration for
biodiversity and blue carbon, is a strategic BTN initiative to support coastal ecosystem conservation,
climate change mitigation and adaptation, and the strengthening of social and economic resilience
in coastal communities. The program was implemented in 2025 at three priority locations, namely the
Lantebung Mangrove Rehabilitation Learning Site in Makassar City, Wonokerto Village in Pekalongan
Regency, and Mangrovesari Kaliwlingi in Brebes Regency, also Muara Adang Village (Paser Regency). The
program covered a total rehabilitation area of 3 hectares with the planting of 7,600 mangrove seedlings.
Program implementation focused on mangrove rehabilitation and species enrichment through planting,
replanting, maintenance, and growth monitoring, including the development of monitoring access routes.
The program also applied a community based approach by involving local groups and grant partners
throughout all stages of implementation. This approach supports the long term sustainability of mangrove
ecosystem management and strengthens institutional capacity within coastal communities.
Support for Strengthening Mangrove and
Mud Crab Ecosystems in Lantebung
BTN, in collaboration with Yayasan KEHATI and YKL Indonesia, strengthens the coastal ecosystem in
Lantebung, Makassar, through the planting of 2,500 mangroves and the release of 100 mud crabs,
involving local communities. This initiative directly contributes to coastal ecosystem restoration,
enhances carbon sequestration for climate change mitigation, increases green open space, and
supports community livelihoods through ecotourism and fisheries, with long-term sustainability
maintained through community-based maintenance and monitoring.
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Ozone-Depleting Substances, Persistent Organic Pollutants, and air emissions. One tangible measure undertaken is the gradual reduction in the use of
Other Significant Air Emissions refrigerants in air conditioning (AC) systems to minimize the potential release of gases
with high global warming potential. [GRI 305-6, 305-7] [OJK F.11, F.12]
As a financial institution focused on financial services and investment activities, the
Bank’s operational activities are not associated with ozone-depleting substances or Information on refrigerant usage is presented in the following table:
other significant air emissions, such as persistent organic pollutants (POPs), volatile
organic compounds (VOCs), particulate matter (PM), and similar emissions. Accordingly, Table of Refrigerant Usage
BTN has not conducted calculations related to these pollutants. Nevertheless, BTN
Description Unit 2025 2024 2023
remains committed to managing its environmental impacts through efforts to reduce
Refrigerant usage kg 3,868 2,065 1,780
Water and Effluent Management
Water Conservation
Water management is critical in supporting the continuity of the Bank’s operations, Water consumption is monitored through the recording of usage based on PDAM billing
particularly for office domestic needs such as sanitation, religious activities, and irrigation data and flow meter measurements. Starting in 2024, the data presented will include Head
of green areas. The majority of the Bank’s water supply is sourced from the local water Office, Regional Offices, and Branch Offices. As of the reporting year, the Bank has not yet
utility (PDAM), with the remainder obtained from deep wells. Taking into account potential conducted an assessment of water stress levels in its operational areas. Information on
environmental risks such as effluent discharge, water scarcity, and flooding, BTN manages water usage is presented in the following table:
water resources in a responsible manner. All aspects of water resource management are
carried out in accordance with Law No. 17 of 2019 on Water Resources. [GRI 3-3, 303-1] Table of Water Withdrawal and Water Use [GRI 303-3, 303-5] [OJK F.8]
Water Source Unit 2025 2024* 2023
As part of its environmental commitment, the Bank has set a target to reduce water
Third-party water (PDAM) m 3
409,384 2,230,324 284,419
consumption by 30% by 2029, serving as a reference for enhancing water use efficiency
Groundwater m 3
542,959 20,199,179 7,095
across all operational units without compromising water availability for the surrounding
Total m3 952,344 22,429,503 291,514
environment.
*Data restated
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To support the achievement of its water reduction targets, the Bank implements various 2. The utilization of treated wastewater from the WWTP and harvested rainwater for
water efficiency and sustainable water management initiatives. These initiatives include: non-consumptive operational activities, such as landscape irrigation, fountain water
1. Using PDAM water as the primary water source in accordance with local regulations replenishment, and vehicle washing.
governing groundwater utilization;
2. Using of 25 infiltration wells, each with a capacity of 3.39 cubic meters;
3. Maintaining 22 biopore points distributed across the BTN Tower area;
4. Installing awareness posters in restroom areas to promote water conservation;
5. Regulating water flow rates in the BTN Tower building; and
6. Using of cooling water for plant irrigation.
Effluent Management
The Bank ensures that wastewater is managed responsibly in accordance with Governor
of DKI Jakarta Regulation No. 122 of 2005. Wastewater quality is tested on a quarterly basis
to ensure that all parameters comply with applicable quality standards prior to discharge
into the environment. A summary of wastewater discharge volumes throughout the
reporting year, including data from the Head Office, is presented as follows: [GRI 303-2, 303-4]
[OJK F.13]
Water Discharge Volumes
Water Discharge Unit 2025 2024* 2023*
Total Water Discharge m3 11,944 26,241 25,009
*Data restated
To ensure that wastewater is managed safely and does not impact the environment, the
Bank complements its treatment processes with various supporting measures. Effluent
management is further strengthened through the following initiatives: [OJK F.14]
1. The operation of the wastewater treatment plant (WWTP) at BTN Tower, with a
capacity of 260 m³ per day, is conducted in accordance with the applicable
wastewater discharge permit. Meanwhile, the WWTP at BTN Tower 2 has a capacity
of 18 m³ and operates in compliance with established wastewater management
standards.
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Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Waste Management
Waste Management
BTN’s operational activities generate various types of waste that must be properly
Reduced
0.58 tons
managed to prevent adverse impacts on the environment and public health. This of waste through recycling in 2025 in collaboration with licensed
includes non-hazardous waste, such as office waste and unused furniture, as well as third-party partners.
hazardous and toxic waste (B3), which comprises used oil from vehicles and generators,
damaged electronic equipment, used lamps, and used batteries. [GRI 3-3, 306-1]
Waste management is carried out in accordance with applicable laws and regulations,
including Law No. 18 of 2008 on Waste Management, Government Regulation No. 101 of
2014 on Hazardous and Toxic Waste (B3) Management, and Government Regulation No. 74
on the Management of Hazardous and Toxic Materials. For B3 waste, BTN cooperates with
licensed third parties to ensure that handling and transportation processes comply with
technical standards and the precautionary principle. [GRI 3-3, 306-2, 306-4]
Information on the volume and management of waste at the Head Office during the
reporting year is presented in the following table:
Table of Waste Generation [GRI 306-3. 306-4. 306-5] [OJK F.13. F.14]
Type of Waste Unit 2025 2024 2023
Building waste Ton 108.29 131.76 119.01
Food and beverage waste (organic) Ton 17.81 5.47 5.47
Paper and cardboard Ton 11.91 0.00 0.00
Glass, cans, and plastics Ton 7.40 0.00 0.00
Used oil Ton 0.53 0.00 0.01
Used fluorescent lamps (TL), PLCs, ballasts, and cables Ton 0.02 0.01 0.03
Used freon cylinders Ton 0.03 0.00 0.00
Other types of waste Ton 0.00 0.00 0.00
Total Ton 145.25 137.77 124.52
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Digitalization
All waste generated by the Bank, both hazardous and non-hazardous, is managed 100% To reduce reliance on physical documents, BTN has strengthened digital transformation
off-site by licensed third parties in accordance with applicable regulations. Specifically across various work processes. These initiatives also enhance service efficiency and
for non-hazardous waste, it is sorted into three categories, namely inorganic waste that improve data management quality. The digitalization programs implemented include:
is processed at a recycling center and redistributed for recycling, organic waste that is [GRI 305-5, 306-2] [OJK F.1, F.12]
reused (including as maggot feed), and residual waste that cannot be processed and is 1. Digitalization of Business Processes and Services
subsequently disposed of at a final disposal site (TPA). Quantitative information on each • End to end procurement application for end to end digitalization of the procurement
waste category cannot be disclosed, as the entire management and recording process process;
is carried out by the appointed third party. [GRI 306-4, 306-5] • Virtual debit card and Government Securities features in balé by BTN;
• BTN Properti application as a web based platform listing housing projects from
To minimize environmental impacts, various waste management initiatives are in line developers partnered with BTN;
with the 3R principles (reduce, reuse, recycle). These efforts focus on reducing waste • e Bank Guarantee application to manage bank guarantees issued by the Bank at
generation, optimizing reuse, and ensuring the safe management of hazardous waste. the customer’s request to cover specific risks arising from the customer’s failure to
The initiatives implemented includes: [GRI 306-4] meet obligations to the beneficiary;
1. Internal education to reduce the use of single-use products; • e Deposit service in balé by BTN to digitalize the business process for deposit
2. Composting of leaf waste; funding;
3. Provision of temporary waste storage facilities (TPS) with a capacity of 14 m³ at BTN • NEXA application with features for individual customer onboarding and account
Tower and 18 m³ at BTN Tower 2; opening, e forms, signature verification, and a queue management system to
4. Provision of waste segregation facilities on each floor to facilitate effective waste support digital customer services at Branch Offices; and
management; • BTN Digital Store featuring digital customer service, augmented reality experiences,
5. Provision of temporary storage facilities for hazardous and toxic waste (TPS B3) to video banking, faster account opening processes, use of artificial intelligence
ensure safe handling prior to transfer to licensed waste management parties. technology, digital forms, and the living city concept to digitalize banking services.
Paper Management and Digitalization Initiatives 2. Digitalization of Documents and Internal Administration
• Use of email for correspondence;
Paper is one of the most widely used materials in BTN’s operational activities, ranging from • iWork/iFlow application for document management and workflow routing;
administrative processes and report printing to transaction-related documents. High • PPDigital application as an internal policy portal;
levels of paper consumption may increase waste generation, contribute to higher GHG • e-Mom application for managing Board of Directors meeting minutes;
emissions, and have environmental impacts. Accordingly, the Bank strives to manage • Operational Risk Tools application for operational risk management;
paper consumption in a more efficient and sustainable manner. [GRI 3-3, 306-1] • The e-Committee and e-RKK applications for managing Board of Directors meeting
minutes;
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
• BTN Best, B Gate, iLoan, iDocs, iWealth, and Smart Collection applications as part of In addition to digitalization, BTN has implemented a series of initiatives to reduce paper
the digitalization of the Bank’s internal administrative processes; and waste generation. These include plastic-free campaigns, reuse of paper that is still
• Digital Signature features to improve efficiency and simplify document signing suitable for use, secure destruction of obsolete confidential documents, and partnership
processes related to credit agreement approvals, bank guarantee documents, with third parties for recycling non-confidential paper waste. Currently, BTN has not yet
and internal memoranda at BTN. utilized environmentally friendly materials such as recycled paper or reclaimed materials
in its operations. [GRI 3-3, 301-1, 301-2, 301-3, 306-2] [OJK F.5]
BTN optimizes its digitalization programs as a key measure to reduce paper consumption.
During the reporting year, this initiative resulted in savings of approximately 3,318,019 Information on paper usage during the reporting year is presented in the following table:
sheets of paper, equivalent to avoiding around 199.1 tons of CO2eq emissions or conserving
approximately 3,318 trees per year. Table of Paper Usage
Description Unit 2025 2024 2023
Paper Usage Sheet 82,039,575 78,987,938 25,592,000
Strengthening Governance through Digitalization and AI
In 2025, BTN strengthened governance and ESG
implementation through the use of PPDigital and the
launch of AI Pvita. PPDigital was accessed by 9,516 users
with a total of 192,237 visits, while AI Pvita recorded 12,011
accesses during the year. The use of AI enables employees
to search for and understand regulations quickly and
accurately, improving work efficiency and productivity.
This initiative also strengthens compliance with the
latest regulations, reduces the risk of misinterpretation,
and supports a digital culture and technology driven
transformation across the workplace.
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Environmental Control and Compliance
The management of materials that pose potential environmental risks is a key area of As part of its commitment to maintaining environmental quality, BTN has a dedicated
concern for BTN, as spills of chemicals, oil, or fuel may result in environmental and health budget for environmental management activities, as follows. [OJK F.4]
impacts. The Bank has implemented strict handling procedures to prevent such incidents.
In 2025, there were no recorded spills or significant complaints related to non-compliance Environmental Management Costs [OJK F.4]
with environmental management. This achievement reflects the effectiveness of BTN’s
Description Management Costs
internal controls and its adherence to applicable environmental standards. [OJK F.15]
Wastewater treatment management Rp483,284,869
BTN’s commitment to implementing best practices and complying with applicable Solid waste management Rp136,228,640
environmental laws and regulations is further demonstrated by the absence of any Tree planting program Rp5,266,887,500
violations resulting in fines or non-monetary sanctions throughout 2025, as well as the
Total Rp5,886,401,009
absence of environmental complaints received during the reporting year. [GRI 3-3, 2-27] [OJK
F.16]
Green Building [GRI 305-5] [OJK F.12]
BTN has adopted the green office concept as an integral part of its environmental commitment in operational Bank.
All implementations are carried out in accordance with national regulations related to environmental management,
water, waste, and B3 waste. Through the application of green building principles, BTN enhances energy and water
efficiency, improves waste management, utilizes environmentally friendly materials, and maintains indoor air quality.
The green building certification process is conducted after construction is completed as part of a comprehensive
evaluation of the building’s environmental performance. [OJK F.1]
This commitment was recognized when BTN Tower 2 obtained Platinum green building certification from the Green
Building Council Indonesia (GBCI), demonstrating strong performance, including energy efficiency of 21.86%, an
increase in green open space by 32.1%, and water savings of 26.7%. This achievement has driven the expansion of
green building implementation across BTN facilities, including buildings located in Kelapa Gading Square, Kebon Jeruk,
Ecopark Gandul, and the BTN Learning Center in Dago.
All these initiatives support the achievement of environmental sustainability targets under the SDGs and align with the
ESG Roadmap, strengthening BTN’s position as a pioneer of sustainability practices in the banking sector.
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
04
Developing Employee
Potential and Well-Being
86 Human Capital Management
89 Diversity, Equity, and Inclusion
101 Competency Training and
Development
111 Protection and Fulfillment of
Employee Rights
117 Employee Health and Safety
119 Harmonious Industrial Relations
120 Social and Economic Compliance
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Human Capital Management
BTN has established the mission of
“Becoming the home of Indonesia’s best
Home of Indonesia’s Best Talents
talents.” This is implemented through
various short- and medium-term human
Dynamic Workplace FIlled with Productive, Prominent, and Prosperous Talents with Global Mindset
capital development programs aligned
with the strategic direction of the BTN Talent, Leadership, & Employee Wellbeing & HC Operational Excellence
Talent Magnet Employee Productivity
Corporate Plan 2025–2029, including: Capabilities Development Experience & Technology
Creating a workplace Delivering superior HC
Becoming a top-of-mind Achieving employee Building a strong leadership
that supports employees’ policies and faster, better,
company for Indonesia’s productivity above the Top pipeline and becoming a
physical, mental, financial, cheaper HC services
best talents 10 banks’ average talent producer
and social well-being through technology
Employer Branding Ranking Profit/Employee % MCJ Successor Ratio Employee Wellbeing Index % AI Adoption in HC Cycle
Employee Engagement HC Service Satisfaction
Global-Oriented Talents PPOP/Employee % BUMN Qualified Talent
Index Index
Turn Over Rate Assets/Employee %Women and <42 Talent Culture Assessment Index
3. Workforce Planning & Recruitment:
1. Organization Design: Develop Agile 2. Culture: Develop Culture Program to Shape
Reshaping “Soccer Field” & Improve
Organization & Optimize HC Advisory Productive and High Performing Employee
feeder quality aligned with Bank Strategic
Function Behaviour
Initiatives
4. Learning & Capability Development: 6. Leadership Development & Succession:
5. Talent & Career Management: Create solid
Develop Critical Capabilities to be able to Develop solid Talent Bench strength/
talent pool through well-designed Talent
execute Bank Strategic Initiatives through Leadership pipeline through best in class
Management & Progressive Career path
Up-skilling & Re-skilling leadership development program
7. Performance Management: 8. Compensation & Benefit 10. HC Technology: Accelerate
Revamp Individual Management: Enhance 9. Employee Wellbeing: Ensure Automated HC Operations &
Performance Management Performance Based Employee Wellbeing through Establish AI- Infused Decision
System linking with Compensation Packages Supportive & Inclusive Working Support System to elevate
Productivity/ Drive Business & Maintain Market Environment HC Service Effectiveness &
Output Competitiveness efficiency
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Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Strategies are implemented through the following human capital initiatives: 7. Develop IT, Digital, Risk Management, and Analytic Capabilities
1. Optimize Human Capital Business Partner Function Strengthen IT, digital, risk management, and analytics capabilities through
Enhance the role of Human Capital Business Partners (HCBP) as strategic business upskilling, reskilling, and strategic talent development programs to support digital
partners by strengthening their consultative role, workforce analytics capabilities, transformation, effective risk management, and accurate, timely data-driven
and end-to-end understanding of business strategy and models, ensuring HC decision-making.
policies and interventions directly impact performance, productivity, and growth. 8. Develop Dual Career Path for Sales, IT, and Dealer
2. Establish New Pillar “Digital Culture” & Strengthen Sales Culture Develop dual career path schemes for Sales, IT, and Dealer functions to provide
Build a new Digital Culture pillar integrated with a strengthened Sales Culture through equal career pathways between specialist and leadership tracks, thereby increasing
internalization of digital mindsets, utilization of data and technology, and embedding motivation, retention of high-performing talent, and sustainability of critical expertise
a results-oriented and customer-centric approach to create an adaptive and agile within the organization.
organization focused on sustainable revenue growth. 9. Revamp Mission Critical Job (MCJ) KPI
3. Develop Strong Governance, Risk and Compliance (GRC) Culture for Leaders Enhance Mission Critical Job (MCJ) KPIs to be more closely aligned with corporate
Strengthen GRC culture among leaders by enhancing leadership capabilities in risk strategy and focused on value-added contributions, business outcomes, and
management, compliance, and good governance to ensure prudent, ethical, and productivity, thereby driving optimal performance in roles with the greatest impact
sustainable strategic decision-making. on strategic objectives.
4. Improve Change Agent Capabilities to Drive Productivity 10. Enhance Performance-Based Remuneration Scheme
Enhance the capabilities of change agents across the organization by strengthening Strengthen the performance-based remuneration scheme by reinforcing the
competencies in change leadership, strategic communication, and transformation linkage between individual achievement, unit performance, and corporate results to
execution, to ensure that every change initiative drives improvements in productivity, promote a pay-for-performance culture, increase productivity, and ensure fair and
process efficiency, and acceleration of business target achievement. competitive rewards.
5. Recompose Manpower Posture Inline with Business Strategy 11. Implement Employee Recognition Programs
Strategically realign the manpower posture to be in line with business direction and Implement structured and sustainable employee recognition programs to appreciate
priorities through optimization of organizational structure, reallocation of human outstanding performance, innovation, and strategic contributions, thereby increasing
resources, and competency adjustments to improve cost efficiency, organizational engagement, loyalty, and a high-performance culture across the organization.
agility, and productivity per employee. 12. Develop Employee Well-Being Program
6. Develop Sales Capabilities by Establishing Sales Academy Develop holistic and integrated employee well-being programs covering physical,
Develop comprehensive and sustainable sales capabilities through the establishment mental, financial, and social aspects to create a healthy, productive, and sustainable
of a structured Sales Academy, focusing on product mastery, consultative selling, work environment, while supporting improved performance and organizational
data utilization, and customer lifecycle management to drive improved sales resilience.
performance and corporate competitiveness.
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Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
13. Automation of Human Capital Processes
Implement end-to-end automation of Human Capital processes through the use of digital technology and integrated systems to improve operational efficiency, data accuracy,
and quality of HC services, while enabling the Human Capital function to focus more on strategic roles.
Human Capital Summit 2025,
Strengthening Talent Transformation
The BTN Human Capital Summit 2025 served as a strategic forum to strengthen talent
transformation toward BTN Vision 2029. The event, attended by the Minister of Manpower
of the Republic of Indonesia, members of the Board of Commissioners, Board of Directors,
and employees from across Indonesia, emphasized the importance of an innovative,
sustainable, and harmonious human capital ecosystem, while encouraging the
development of resilient, adaptive, and productivity-oriented talent in an era of disruption
and digitalization.
At the event, BTN activated eight flagship Human Capital programs, including PKB 2025–
2027, the Human Capital Long-Term Plan 2025–2029, Corporate Culture 2025–2029, Expert
Talks, the Learning Culture Festival, Human Capital ServEase, HC system digitalization, and
the Talent Acceleration Program. All initiatives are designed to strengthen the competencies
of BTNers, promote a digital learning culture, enhance engagement, and accelerate the
development of high-potential talent to support the business transformation to a more
adaptive, productive, and future-ready organization.
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Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Diversity, Equity, and Inclusion
Diversity, equity, and inclusion form the foundation of human capital management at Diversity of the Board of Commissioners and Board of Director [GRI 2-9]
BTN, principles that are applied in accordance with Law No. 13 of 2003 on Manpower and
the Bank’s commitment to upholding human rights. They are further reinforced through Diversity in the Board of Commissioners and Board of Directors is important in creating
General Policy No. KU.3 on Human Resources and the Collective Labor Agreement. inclusive governance and more strategic decision-making. Differences in age, education,
experience, expertise, and background help broaden perspectives in assessing
Implementation covers the entire employment lifecycle, from recruitment and opportunities and risks, resulting in decisions that are more accurate, innovative, and
competency development to career management, remuneration, and employee relevant. Although there are currently no members from underrepresented social groups,
welfare, where BTN ensures that every employee receives equal opportunities without the Board of Commissioners and Board of Directors remain committed to understanding
discrimination based on gender, religion, ethnicity, race, or other personal backgrounds. and advocating for the aspirations of these groups. The complete composition is
This approach fosters an inclusive, safe, and productivity-supporting work environment. presented in the tables below.
[GRI 3-3, 2-23] [OJK C.3, F.18]
Diversity of the Board of Commissioners [GRI 405-1]
Name Position Age Gender Education Work Experience Expertise
Suryo Utomo President Commissioner 56 Male Doctor of Philosophy (PhD) Philosophy (PhD) Experience in finance Economics
Dwi Ary Purnomo Vice President 50 Male Master of Law Experience in finance and risk management Law
Commissioner
Fahri Hamzah Commissioner 54 Male Bachelor’s in Economics Experience in economics Economics
Ida Nuryanti Independent 58 Female Master of Management Experience in banking Management, Law
Commissioner
Pietra Machreza Paloh Independent 54 Male Master of Business Experience in the energy and mining sectors Business Administration
Commissioner Administration
Panangian Simanungkalit Independent 65 Male Master’s in Engineering Experience in housing and property Engineering
Commissioner and Geoinformatics
Technology
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Digitalization
Diversity of the Board of Directors [GRI 405-1] The proportion of female Directors at BTN currently stands at
16.67%, with two out of a total of twelve members of the Board
Name Position Age Gender Education Work Experience Expertise of Directors. This representation reflects the Bank’s commitment
Nixon L.P. President Director 56 Male Bachelor’s in Experience in economics Economics to strengthening diversity and inclusion at the leadership level.
Napitupulu Economics
In accordance with applicable regulations, the appointment
Oni Febriarto Vice President 54 Male Master of Experience in economics Engineering,
of the Bank’s Board of Directors is the authority of the majority
Rahardjo Director Management Management
shareholder, PT Danantara Asset Management. To support
Tan Jacky Chen Director of 42 Male Master of Experience in Engineering,
increased female representation on the Board, BTN has developed
Information Management information technology Management
Technology a succession pipeline, proposing female Director candidates as
Venda Yuniarti Director of Treasury 45 Female Master of Experience in banking Business nominated talent. Currently, eight women have been identified
& International Business Administration as nominated talent, representing 33% of the Bank’s total 24
Banking Administration
nominated talents.
Helmy Afrisa Director of 44 Male Master of Experience in banking Agribusiness
Nugroho Corporate Banking Agribusiness
Diversity of the Board of Commissioners
Setiyo Wibowo Director of Risk 48 Male Master in Experience in banking Engineering,
Management Finance & Finance
Banking Male Female
Hirwandi Gafar Director of 57 Male Bachelor’s Experience in banking Engineering
83.3% 16.7%
Consumer Banking in Civil
Engineering
Nofry Rony Director of Finance 57 Male Master of Experience in banking Business
Poetra & Strategy Business Administration,
Administration Economics
Diversity of the Board of Directors
Eko Waluyo Director of 54 Male Master of Experience in banking Business
Human Capital & Business Administration,
Compliance Administration Management, Male Female
Accounting
83.3% 16.7%
I Nyoman Sugiri Director of 48 Male Master of Experience in banking Business
Yasa Operations Business Administration
Administration
Rully Setiawan Director of Network 48 Male Master of Experience in banking Management,
& Retail Funding Management Economics
Hermita Director of 57 Female Master of Experience in banking Agribusiness,
Commercial Agribusiness Law
Banking
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Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Employee Demographics [GRI 2-7, 2-8, 405-1] [OJK C.3, F.18]
Employee related information in this report is compiled from
the Human Capital Management Unit database and has been
verified for accuracy. In 2025, BTN employed a total of 11,429
personnel, consisting of 11,414 employees and 15 Directors and
Senior Executive Vice Presidents. In addition, BTN engaged
8,902 non-employee workers, including outsourced personnel
in administrative services, office support, drivers, security,
marketing, collection, and information technology support roles.
All BTN employees are full time employees. Details on employee
composition and characteristics are presented in the following
table:
Employee Demographics by Gender [GRI 2-7, 405-1] [OJK C.3.b]
2025 2024 2023
Gender
Total % Total % Total %
Male 5,697 49.85 6,576 51.06 6,288 52.20
Female 5,732 50.15 6,288 48.94 5,757 47.80
Total 11,429 100.00 12,864 100.00 12,045 100.00
*Including Directors and SEVP
Employee Demographics by Nationality [GRI 2-7, 405-1] [OJK C.3.b]
2025 2024 2023
Nationality
Total % Total % Total %
Indonesia 11,429 100.00 12,864 100.00 12,045 100.00
Total 11,429 100.00 12,864 100.00 12,045 100.00
*Including Directors and SEVP
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Digitalization
Employee Demographics by Age Group, Gender, and Position Level [GRI 2-7, 405-1] [OJK C.3.b]
2025
Age Range (years) Entry-level Mid-level Senior-level Executive-level
Total
M F M F M F M F
18-25 440 1,070 145 185 0 0 0 0 1,840
25-35 1,959 2,325 1,042 659 3 2 0 0 5,990
35-45 525 712 829 481 110 48 2 1 2,708
45-55 26 36 334 157 256 51 8 0 868
>55 0 0 8 3 7 1 3 1 23
Total 2,950 4,143 2,358 1,485 376 102 13 2 11,429
*M= Male | F= Female
**Including Directors and SEVP
2024
Age Range (years) Entry-level Mid-level Senior-level Executive-level
Total
M F M F M F M F
18-25 553 1,158 126 191 - - - - 2,028
25-35 2,542 2,759 1,152 721 4 - - - 7,178
35-45 482 682 852 446 94 43 1 - 2,600
45-55 29 36 416 191 300 57 10 - 1,039
>55 1 1 3 2 6 - 5 1 19
Total 3,607 4,636 2,549 1,551 404 100 16 1 12,864
*M= Male | F= Female
**Including Directors and SEVP
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Digitalization
2023
Age Range (years) Entry-level Mid-level Senior-level Executive-level
Total
M F M F M F M F
18-25 424 913 86 161 - - - - 1,584
25-35 2,544 2,742 1,288 702 4 - - - 7,280
35-45 332 519 684 381 70 31 2 - 2,019
45-55 29 34 468 213 353 60 9 - 1,166
>55 - - 2 - 4 1 3 1 11
Jumlah 3,329 4,208 2,528 1,457 431 92 14 1 12,060
*M= Male | F= Female
**Including Directors and SEVP
Employee Demographics by Employment Status and Work Location [GRI 2-7, 405-1] [OJK C.3.b]
2025
Employment Status Head Office Regional Office Branch Office Total
M F Total % M F Total % M F Total % M F Total %
Permanent 2,365 1,428 3,793 98.55 389 187 576 99.83 2,863 4,091 6,954 99.51 5,617 5,706 11,323 99.20
Contract 39 17 56 1.45 1 0 1 0.17 27 7 34 0.49 67 24 91 0.80
Total 2,404 1,445 3,849 100.00 390 187 577 100.00 2,890 4,098 6,988 100.00 5,684 5,730 11,414 100.00
*M= Male | F= Female
**Including Directors and SEVP
2024
Employment Status Head Office Regional Office Branch Office Total
M F Total % M F Total % M F Total % M F Total %
Permanent 2,256 1,320 3,576 98.05 438 182 620 99.36 3,791 4,712 8,503 99.15 816 724 12,699 98.85
Contract 40 31 71 1.95 2 2 4 0.64 33 40 73 0.85 8 8 148 1.15
Total 2,296 1,351 3,647 100.00 440 184 624 100.00 3,824 4,752 8,576 100.00 6,560 6,287 12,847 100.00
*M= Male | F= Female
**Including Directors and SEVP
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Digitalization
2024
Employment Status Head Office Regional Office Branch Office Total
M F Total % M F Total % M F Total % M F Total %
Permanent 2,051 1,045 3,096 93.19 383 163 546 98.56 3,550 4,078 7,628 92.95 5,984 5,286 11,270 93.56
Contract 114 112 226 6.80 8 - 8 1.44 182 359 471 7.05 304 471 775 6.43
Total 2,165 1,157 3,322 100.00 391 163 554 100.00 3,732 4,437 8,169 100.00 6,288 5,757 12,045 100.00
*M= Male | F= Female
**Including Directors and SEVP
Employee Demographics by Position Level and Gender [GRI 2-7, 405-1] [OJK C.3.b]
2025 2024 2023
Male Female Male Female Male Female
Position Level Percentage Percentage Percentage Percentage Percentage Percentage
Number of of Number of of Number of of Number of of Number of of Number of of
employees employees employees employees employees employees employees employees employees employees employees employees
(%) (%) (%) (%) (%) (%)
Entry-level 2.950 51.78 4.143 72.28 3.607 54.85 4.636 73.73 3.329 52.82 4.208 73.08
Mid-level 2.358 41.39 1.485 25.91 2.549 38.76 1.551 24.67 2.528 40.11 1.457 25.30
Senior-level 276 6.60 102 1.78 404 6.14 100 1.59 431 6.84 92 1.60
Executiv e-level (Including 13 0.23 2 0.03
16 0.24 1 0.02 14 0.22 1 0.02
Directors and SEVP)
Total 5.697 100.00 5.732 100.00 6.576 100.00 6.288 100.00 6.302 100.00 5.758 100.00
Employee Demographics by Education Level and Gender [GRI 2-7, 405-1] [OJK C.3.b]
2025 2024 2023
Education Level
M F Total % M F Total % M F Total %
Postgraduate 333 198 531 4.65 373 189 562 4.37 367 168 535 4.44
Bachelor’s Degree 4,910 4,880 9,790 86.77 5,574 5,212 10,786 83.96 5,254 4,627 9,881 82.03
Associate Degree 377 520 897 7.86 511 706 1,217 9.47 539 734 1,273 10.57
Senior High School 64 132 196 1.72 102 180 282 2.20 128 228 356 2.96
Total 5,684 5,730 11,414 100.00 6,560 6,287 12,847 100.00 6,288 5,757 12,045 100.00
*M= Male | F= Female
**Including Directors and SEVP
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Employee Demographics by Employment Status and Gender, Including Outsourced Personnel [GRI 2-7, 2-8, 405-1] [OJK C.3.b]
2025 2024 2023
Employment Status
M F Total % M F Total % M F Total %
Permanent 5,617 5,706 11,323 58.05 6,485 6,214 12,699 61.69 5,984 5,286 11,270 55.98
Contract 67 24 91 0.47 75 73 148 0.72 304 471 775 3.85
Total (Excl. Outsourced) 5,684 5,730 11,414 58.52 6,560 6,287 12,847 62.41 6,288 5,757 12,045 59.83
Outsourced 6,804 1,288 8,092 41.48 6,551 1,187 7,738 37.59 6,930 1,157 8,087 40.17
Total 12,488 7,018 19,506 100.00 13,111 7,474 20,585 100.00 13,218 6,914 20,132 100.00
*M= Male | F= Female
**Including Directors and SEVP
Employee Demographics by Length of Service and Gender [GRI 2-7, 405-1] [OJK C.3.b]
2025 2024 2023
Length of Service
M F Total % M F Total % M F Total %
>30 89 66 155 1.36 124 80 204 1.59 50 58 108 0.90
25-30 479 95 574 5.03 584 142 726 5.65 642 179 821 6.82
20-25 0 68 68 0.60 - - - - 129 21 150 1.25
15-20 191 268 459 4.02 213 306 519 4.04 112 231 343 2.85
10-15 1,566 1,344 2,910 25.50 1,473 1,519 2,992 23.29 1,046 1,345 2,391 19.85
5-10 1,988 1,658 3,646 31.94 2,733 2,043 4,776 37.18 2,672 1,758 4,430 36.78
0-5 1,371 2,231 3,602 31.56 1,433 2,197 3,630 28.26 1,637 2,165 3,802 31.56
Total 5,684 5,730 11,414 100.00 5,560 6,287 12,847 100.00 6,288 5,757 12,045 100.00
*M= Male | F= Female
**Including Directors and SEVP
Based on the employment data table, several aspects reflect BTN’s commitment to are ensured to be free from child labor practices and fully compliant with prevailing labor
implementing fair and responsible labor practices. The composition of male and female regulations. Overall, these conditions reaffirm BTN’s commitment to creating a fair and
employees is relatively balanced, indicating that the recruitment process is conducted inclusive working environment that upholds the principles of equality and respect for
openly and provides equal opportunities for all applicants. Then, the Bank does not human rights. [GRI 3-3, 405-1, 406-1, 408-1] [OJK F.19]
employ individuals below the minimum working age; therefore, all operational activities
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Respectful Workplace Policy
BTN is committed to building a safe and respectful workplace that upholds the dignity
and rights of every individual. This commitment includes the prevention of all forms of
discrimination, exclusion or restriction, bullying, harassment, and violence, whether physical
or psychological. This principle is aligned with the implementation of the Respectful
Workplace Policy as stipulated in the Ministry of State Owned Enterprises Circular Letter No.
SE-3/MBU/04/2022 on Respectful Conduct in the Workplace within State Owned Enterprises,
and is internalized through Special Policy No. KK.3-C of 2024 on Employment Regulations
and Administration, particularly Chapter III on Employee Relations.
This policy serves as the foundation for labor management practices across all BTN
work units to ensure an inclusive, conducive, and productive working environment, while
supporting the Bank’s sustainability by upholding human rights. In its implementation, this
policy also includes measures to prevent unethical practices, including human trafficking,
forced labor, and child labor exploitation. In line with this commitment, BTN has established
preventive measures to prevent unfair practices or treatment that may disadvantage
employees, including:
1. Discrimination BTN anti-discrimination policies implement the principles of diversity
and gender inclusion across all work activities. The Bank ensures that there is no form
of direct or indirect differentiation, marginalization, or restriction based on religion, tribe,
race, ethnicity, social or economic status, marital status, language, political preference, As part of strengthening a culture of mutual respect, in 2025 BTN will consistently disseminate
gender, or disability. information about its Respectful Workplace Policy. The policy ensures that all BTN personnel,
2. Violence This includes any act or behavior that is threatening, coercive, or harmful from the Board of Commissioners and the Board of Directors to all employees, actively
to others in the workplace. Such behavior may occur in public or private situations contribute to creating a safe, inclusive, productive, and discrimination-, violence-, and
and may result in physical, psychological, sexual, or economic harm to the affected harassment-free work environment. This approach reflects BTN’s commitment to the values
individuals. of equality, respect for diversity, and the fulfillment of human rights.
3. Harassment Any form of harassment, whether through words, behavior, actions, or 1. Respecting the diversity of each employee’s background, including ethnicity, race,
gestures, has the potential to disrupt employees’ sense of security. Harassment may nationality, skin color, age, religion, gender, disability, and individual perspectives, to
occur directly in the workplace or through various communication channels and foster a healthy and productive work environment.
includes acts that violate human rights provisions. Such behavior may cause physical, 2. Ensuring that all employees are treated fairly without discrimination of any kind and are
psychological, sexual, or economic distress, make victims feel humiliated or threatened, provided equal access to facilities and infrastructure.
and create an unconducive working atmosphere.
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3. Building a work environment based on mutual respect and free from discrimination, implementation along with supporting documentation in digital form, which are
violence, and harassment in any form. subsequently reviewed by the Change Leader for approval or returned to the Change Agent
4. Providing inclusive facilities for employees and customers with disabilities, including for improvement. All reporting processes are conducted online in the form of electronic
access ramps, priority seating, disability-friendly restrooms, tactile guiding blocks, and documents, thereby improving efficiency, accountability, and supporting paper use
designated areas to enhance comfort and accessibility. reduction.
To support monitoring and strengthen the implementation of corporate values and culture, In 2025, BTN did not receive any reports or identify any cases of discrimination, harassment,
BTN provides the Culture Report Website as a reporting platform for the implementation human rights violations, or forced labor. This outcome reflecting the effectiveness of internal
of the Corporate Culture Program. This platform is used to submit updates on program policies and the Bank’s commitment to maintaining a fair and safe work environment. [GRI
3-3, 406-1, 408-1, 409-1]
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Workshop on Diversity, Equity, and
Inclusion [GRI 404-2]
As part of its strategic commitment to fostering a harmonious and innovative work environment, BTN has
consistently implemented training programs focused on diversity, equity, and inclusion throughout the year.
BTN delivers a training curriculum designed to raise awareness among all BTN employees about the
importance of respecting differences in background, perspectives, and identities within the workplace.
The training program also ensures that every employee has equal access to competency development
opportunities, without discrimination based on gender, age, or disability.
New Employee Recruitment and Employee Turnover [GRI 401-1]
BTN fulfills its workforce needs through both internal and external recruitment, In 2025, BTN targeted the recruitment of 618 employees and successfully realized 802
internal recruitment selects employees who meet the criteria to fill specific positions, employees demonstrating the Bank’s commitment to expanding career opportunities
while external recruitment includes pre-graduate candidates, fresh graduates, and and strengthening organizational capacity. Detailed data on new employees are
experienced applicants. All recruitment processes prioritize Indonesian citizens; therefore, presented in the following tables:
all employees, including senior management, are sourced from the local community.
The Bank also provides opportunities for vulnerable groups such as women, minorities, Composition of New Employees by Age Group and Gender [GRI 401-1] [OJK C.3.b]
indigenous peoples, and persons with disabilities. [GRI 3-3, 202-2]
2025 2024 2023
Age Group
M F Total M F Total M F Total
The recruitment process is conducted in accordance with Special Policy No. KK.3-A on the
≤ 51 3 2 5 4 - 4 1 2 3
Human Capital Cycle, which ensures that the selection stages are structured, transparent,
31 – 50 51 18 69 20 16 36 22 8 30
and fair in line with applicable standards. BTN also has a mechanism for the appointment
of new employees as permanent employees. Every individual who passes the selection ≤ 30 231 497 728 463 728 1.191 237 425 662
process is entitled to receive remuneration in accordance with labor regulations. In Total 285 517 802 487 744 1.231 260 435 695
addition, the Bank supports the recruitment of persons with disabilities through special *M = Male | F = Female
initiatives of the Ministry of State-Owned Enterprises (SOEs) and the Indonesia Human
Capital Forum (FHCI). [GRI 3-3]
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Composition of New Employees by Work Location and Gender [GRI 401-1] Composition of Employee Turnover by Work Location and Gender [GRI 401-1]
2025 2024 2023 2025 2024 2023
Age Group Age Group
M F Total M F Total M F Total M F Total M F Total M F Total
Head Office 120 119 239 135 134 269 70 75 145 Head Office 28 22 50 20 16 36 21 21 42
Regional Office 12 14 26 13 8 21 8 1 9 Regional Office 3 3 6 4 1 5 3 2 5
Branch Office 153 384 537 339 602 831 182 359 541 Branch Office 58 110 168 34 89 133 49 91 140
Total 285 517 802 487 744 1.231 260 435 695 Total 89 135 224 58 106 164 73 114 187
*M = Male | F = Female *M = Male | F = Female
Changes in the number of employees may result from termination of employment due Enhancing Workforce Diversity
to retirement, resignation, end of contract, death, and other reasons. All such processes
are carried out in accordance with Special Policy No. KK.3-A on the Human Capital Cycle Strengthening diversity is one of BTN’s priorities in human capital management. The
to ensure that every termination decision is made in an orderly, transparent, and fair principles of equal employment opportunity and gender diversity are implemented
manner, while maintaining the continuity of the Bank’s operations. through Special Policy No. KK.3-C on Employment Regulations and Administration, with
direct oversight by the Board of Directors to ensure consistent implementation across all
Employee Turnover Rate [GRI 401-1] business processes.
Description 2025 2024 2023
As part of its sustainability commitment, BTN has also set quantitative targets to increase
Number of New Employees 802 1,231 695
the representation of underrepresented groups in recruitment. The Bank targets 0.5% of
Number of Employee Turnover 224 164 187
new hires in 2025 to come from underrepresented groups, increasing to 1% in 2026 and
Number of Employees at Beginning of Year 12,847 12,045 11,745
2% in 2028. These targets include persons with disabilities and other groups requiring
Number of Employees at End of Year 11,414 12,847 12,045 affirmative action, in line with efforts to create a more inclusive and diverse workplace.
Turnover Rate 1.96% 1.27% 1.55%
In line with these targets, in 2025 BTN successfully recruited 14 employees with disabilities
Composition of Employee Turnover by Age Group and Gender [GRI 401-1] who passed the selection process, exceeding the initial target of 10. The full demographics
of employees with disabilities in 2025 are presented in the following table:
2025 2024 2023
Age Group
M F Total M F Total M F Total
≤ 51 5 1 6 6 1 7 5 2 7
31 - 50 44 59 103 24 34 58 43 55 98
≤ 30 80 75 115 28 71 99 25 57 82
Total 89 135 224 58 106 164 73 114 187
*M = Male | F = Female
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Persons with Disabilities Total Employees PWD Percentage Implementation of Employee Training on Diversity
(PWD)
Implementation Number of
Training Name Method
Time Participants
16 5,697 0.28% Creative Leadership for Gen Z March Self Learning 4,309
Expert Talk Series Woman Leadership Mei and Hybrid 324
(Srikandi BTN) December
13 5,732 0.23% Creating a Culture That Inspires Your June Self Learning 581
Employees
Internalization of Respectful June Self Learning 10,846
BTN continues to strengthen an inclusive work culture by providing an accessible Workplace Policy (RWP)
facilities for employees from diverse backgrounds. This facilities training, infrastructure
adjustments, and ongoing assistance to ensure every individual can perform and
Supporting Asta Cita on Gender Equality, BTN Promotes
develop optimally. To accelerate diversity implementation, BTN has undertaken several
Women’s Empowerment
initiatives, including:
1. Induction training for all PWD employees covering product knowledge, code of ethics,
business processes, and corporate culture; BTN continues to strengthen its commitment to gender equality through the
2. Inclusive management training for managers; and empowerment of Srikandi BTN as part of the Bank’s transformation toward a more
3. Regular assessments of diversity target achievements conducted transparently. inclusive and adaptive work environment. Female representation in leadership is
a key pillar in fostering a collaborative and service-oriented work culture and BTN
Employee Training on Diversity [GRI 404-2] believes that female leadership brings values of empathy, attention to detail, and
sensitivity that are highly relevant in the banking industry.
Workplace diversity at BTN is promoted through a series of training and awareness
programs provided to all employees, from junior level to Senior Executive Vice President. Through the Srikandi BTN Workshop and Working Meeting 2025, BTN reaffirmed
These programs feature external speakers to strengthen understanding of diversity, its support for capacity building and mentoring of female leaders at various
equity, and inclusion principles and to ensure consistent implementation across all work organizational levels. The event also marked the handover of the Srikandi BTN
units. management for the 2025 term and included visits to BTN-assisted MSMEs as a
form of support for community economic empowerment. This initiative is aligned
All initiatives receive full support from the Board of Directors through top management with the President’s Asta Cita on gender equality and further strengthens BTN’s
oversight to ensure that diversity policies are fully integrated into daily business and efforts to build an empowered, inclusive work environment and to foster the
operational processes. The focus is on building an inclusive and respectful workplace growth of women leaders in the digital transformation era.
that reflects BTN’s diversity values. The training programs include:
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Competency Training and Human Capital Transformation as a Catalyst
for BTN’s Sustainable Business Growth
Development
Competency development is a top priority in BTN’s human capital management. Through
Special Policy No. KK.3-A on the Human Capital Cycle, every employee is encouraged to
enhance both technical and non-technical skills to work more effectively, adapt to change,
and be prepared to assume more strategic roles, with the principle of equality applied so
that all employees have equal access to training without gender discrimination. [GRI 3-3]
Development programs are designed with a focus on knowledge, skills, and attitudes,
using the ADDIE approach (analysis, design, development, implementation, evaluation)
to ensure structured and measurable learning processes. BTN also applies the 70:20:10
method, where 70% of learning is gained through practical experience, 20% through Sustainable business transformation requires a parallel transformation of the
interaction with mentors or colleagues, and 10% through formal training. Various forms of people within the organization, with young talent serving as the primary driver
development are carried out on an ongoing basis, including training, education, special toward adaptive and innovative leadership. BTN emphasizes the development of
assignments, rotations, and promotions, enabling employees to meet the demands of a productive human capital through four core elements: deep knowledge, excellent
dynamic work environment. skills, the right culture, and high motivation. BTN leaders are expected to balance
the roles of directing, structuring, and guiding; to encourage teams through
challenging projects; to facilitate the transfer of tacit knowledge; and to foster a
culture of timely feedback in order to create a sustainable, learning-based work
ecosystem.
BTN’s Human Capital function acts as a catalyst for innovation and competitive
advantage through a five-year Human Capital Framework. The five dimensions
of human capital development, Talent Magnet, Employee Productivity, Talent,
Leadership and Capabilities Development, Employee Wellbeing and Experience,
and HC Operational Excellence and Technology, ensure strong synergy between
human capital and business objectives, enabling BTN’s talent to support sustainable
business growth.
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Employee Development Strategy [GRI 404-2] 1. Employee Scholarship Program
BTN provides undergraduate (S-1) and postgraduate (S-2) education scholarships in
Talent development is a top priority for BTN in strengthening adaptive, competitive, and collaboration with leading universities domestically and internationally, including the
future-ready human resources. Throughout the reporting year, various strategic initiatives University of Indonesia (UI), Master of Management Universitas Gadjah Mada (MM
were implemented through collaboration with external partners, scholarship programs, UGM), School of Business and Management Institut Teknologi Bandung (SBM ITB),
advanced training, and professional certifications as part of the Bank’s commitment The University of Sydney, Monash University, International Institute of Management
to building high-quality human capital. All development programs are designed to be (IMD), The University of Melbourne, The University of Edinburgh, and the University of
inclusive and cover all employees involved in the Bank’s operations, including permanent Bristol. This program aims to provide access to high-quality education for employees
employees, contract employees, outsourced personnel, contractors, and part-time seeking to further develop their capabilities. The data on scholarship recipients are
workers, to ensure equal access to competency development opportunities across the presented below.
organization. These initiatives include
3 13 28
Undergraduate (S-1)
Scholarships
9 16 16
2023 2024 2025 Domestic Postgraduate (S-2)
Scholarships
2 10 10
Overseas Postgraduate (S-2)
Scholarships
Total: 14 Total: 39 Total: 54
Growth (%): 179 Growth (%): 38
2. Human Capital Capability Development
BTN partners with educational institutions to develop or deliver joint training All programs are designed to be relevant and practical in addressing evolving
programs for employees that focus on enhancing technical skills, leadership, and business needs, and to form part of the long-term talent pipeline strategy that
strategic competencies. Through collaboration with Indonesia University, the Bank ensures the availability of competitive, high-quality talent in the future. Additional
has developed and implemented integrated training and advanced education information is available at the following link: Training Program for Employees.
programs to support employee readiness in responding to the dynamics of the
banking industry.
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3. BUMN School of Excellence Sharia Finance Professional Certification Agency (LSP KS), Indonesian Capital Market
This program prepares future leaders through intensive training focused on Financial Industry Professional Certification Agency (LSP IKEPAMI), and ACI Financial
managerial capacity building and strategic leadership development. BTN actively Markets Association (ACIFMA). Through these certifications, employees receive
participates to ensure a strong talent pipeline that is ready to assume key positions. formal recognition of professional expertise in accordance with financial industry
standards.
4. Professional Certification
BTN collaborates with various accredited certification bodies to strengthen All programs are reviewed periodically by senior management to ensure effectiveness
employee credibility and technical competence. These include the Risk Management and alignment with business direction. Through these initiatives, BTN builds a sustainable
Certification Agency (BSMR), Banking Professional Certification Agency (LSPP), talent foundation while supporting the achievement of SDGs related to quality education
and decent work.
ESG Day
ESG Day 2025 provided internal momentum to strengthen the internalisation of
sustainability values while activating employee engagement in ESG implementation.
The event served as a shared platform for communicating ESG directions and programs,
delivered through a series of participatory activities such as Countering Day (CA),
sustainability journey sharing sessions, and waste management education. Through
the implementation of ESG Day, ESG principles were not merely conveyed as strategic
commitments, but were manifested in daily work practices through collective action and
cross-employee collaboration.
Competency Development by Position Level [GRI 2-17, 404-2] [OJK E.2, F.22] [FS4]
Competency Development for the Board of Commissioners
To strengthen their oversight role and enhance understanding of sustainability issues, the Board of Commissioners joined various training programs, workshops, conferences, and
seminars related to governance and ESG throughout the reporting year. Details of these activities are presented in the table below.
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Training Attended by the Board of Commissioners Competency Development for the Board of Directors
Name Position Type of Training Time and Venue Organizer
During 2025, members of the Board of Directors participated in various competency
Suryo Utomo President Risk Management April 16–17 2025, Indonesian
Commissioner Certification Briefing – Jakarta Banking development programs, including training, workshops, conferences, and seminars
Level 6 (Fast Track) Development focusing on governance and ESG aspects. Their participation is summarized in the table
Institute (LPPI) below.
Dwi Ary Vice President Risk Management April 16–17 2025, Indonesian
Purnomo Commissioner Certification Briefing – Jakarta Banking Training Attended by the Board of Directors
Level 6 (Fast Track) Development
Institute (LPPI) Name Position Type of Training Time and Venue Organizer
Fahri Hamzah Commissioner Risk Management April 16–17 2025, Indonesian Nixon L.P. President Win the Market with February 7 2025 PT Bank Tabungan
Certification Briefing – Jakarta Banking Napitupulu Director Digital Leadership and Negara (Persero) Tbk
Level 6 (Fast Track) Development Customer Centricity
Institute (LPPI)
Oni Febriarto Vice President Win the Market with February 7 2025 PT Bank Tabungan
Ida Nuryanti Independent Risk Management April 16–17 2025, Indonesian Rahardjo Director Digital Leadership and Negara (Persero) Tbk
Commissioner Certification Briefing – Jakarta Banking Customer Centricity
Level 6 (Fast Track) Development
Institute (LPPI) Risk Management March 13 2025 Garda Multi Talenta
Certification Briefing –
Pietra Independent Risk Management April 16–17 2025, Indonesian Level 7
Machreza Commissioner Certification Briefing – Jakarta Banking
Paloh Level 6 (Fast Track) Development Eko Waluyo Director Win the Market with 7 Februari 2025 PT Bank Tabungan
Institute (LPPI) of Human Digital Leadership and Negara (Persero) Tbk
Capital & Customer Centricity
Risk Management June 18–19 2025, Indonesian Risk Compliance
Refreshment – Banking Batam Professional Risk Management March 13 2025 Garda Multi Talenta
Industry Preparedness Association (IRPA) Certification Briefing –
in Responding to Level 7
Escalating Climate Risk Hirwandi Gafar Director of Win the Market with 7 Februari 2025 PT Bank Tabungan
& Cyber Risk (2025) Consumer Digital Leadership and Negara (Persero) Tbk
Panangian Independent Risk Management April 16–17 2025, Indonesian Banking Customer Centricity
Simanungkalit Commissioner Certification Briefing – Jakarta Banking Nofry Rony Director of Win the Market with 7 Februari 2025 PT Bank Tabungan
Level 6 (Fast Track) Development Poetra Finance & Digital Leadership and Negara (Persero) Tbk
Institute (LPPI) Strategy Customer Centricity
Setiyo Wibowo Director Win the Market with February 7 2025 PT Bank Tabungan
of Risk Digital Leadership and Negara (Persero) Tbk
Management Customer Centricity
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Name Position Type of Training Time and Venue Organizer BTN employees participated in various training programs, certifications, workshops,
Tan Jacky Director of Risk Management April 29-30 2025 Indonesian Banking conferences, and seminars, including those focusing on ESG aspects. Details of employee
Chen Information Certification Briefing Development Institute
training programs are presented in the table below.
Technology & Competency (LPPI)
Assessment – Level 7
(Fast Track) Training Attended by Employees
Venda Yuniarti Director of Risk Management April 29-30 2025 Indonesian Banking
Number of
Treasury & Certification Briefing Development Institute No Training Name Implementation Time Methods
Participants
International & Competency (LPPI)
Banking Assessment – Level 7 1 Responsible product offering and April, August & October Classroom 94
(Fast Track) marketing
Helmy Afrisa Director of Risk Management April 29-30 2025 Indonesian Banking 2 Data privacy management June – December Hybrid 12,274
Nugroho Corporate Certification Briefing Development Institute
Banking & Competency (LPPI) 3 Cybersecurity January – December Hybrid 40,834
Assessment – Level 7 4 ESG risk identification January – December Hybrid 1,579
(Fast Track)
5 Mentorship programmes January – December Hybrid 896
I Nyoman Sugiri Director of Risk Management June 18-19 2025 Indonesian Risk
Yasa Operations Refreshment – Banking Batam Professional 6 Diversity practices March – July & December Hybrid 16,060
Industry Preparedness Association (IRPA)
7 Anti-money laundering and March & May Hybrid 14,953
to Respond to
terrorism financing
Escalating Climate and
Cyber Risks (2025) 8 Avoiding of tax evasion facilitation November Classroom 104
Rully Setiawan Director of Risk Management 24-25 April 2025, Indonesian Risk 9 ESG initiatives April – May & September Hybrid 21,990
Network & Certification Briefing Jakarta Professional
Retail Funding & Competency Association (IRPA) 10 Anti-bribery and corruption June – October Classroom 105
Assessment – Level 7
11 Code of conduct June – November Hybrid 766
Hermita Director of Chief Business 20-22 Agustus Danantara x INSEAD
Commercial Development Officer 2025, Singapore
Banking (CBDO) Program
Number of Employees Receiving Training by Employment Status
Employee Competency Development
Description 2025 2024 2023
Permanent Employees 11,323 12,699 11,270
BTN ensures that all employees, including permanent, contract, part-time, and
Contract Employees 91 148 775
outsourced personnel, have equal access to competency development programs. This
Part-Time and Outsourced Employees 8,092 7,738 8,807
inclusive approach is designed to foster a work culture that encourages continuous
learning and strengthens human capital capacity across all operational lines. In 2025, Total Employees 11,414 12,847 12,045
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Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Number and Average Training Hours by Gender [GRI 404-1]
2025 2024 2023
Description
Male Female Male Female Male Female
Number of Employees 5,684 5,730 6,560 6,287 6,288 5,757
Number of Training Participants 16,968 17,443 16,941 15,630 17,342 14,086
Total Training Hours 414,861 382,760 334,376 322,746 393,096 349,610
Average Training Hours per Participant 24.45 21.94 19,74* 20.65 22.67 24.82
Average Training Hours per Employee 72.99 66.80 52.50 51.34 65.52 60.73
Total Training Participants 34,411 32,571 31,428
Percentage of Employees Trained 100% 100% 100%
Total Training Hours 797,621 667,122 742,706
*Data restated
**Excluding outsourced employees
Number and Average Training Hours by Position Level [GRI 404-1]
2025 2024 2023
Position Level
Participants Total Hours Avg. Hours Participants Total Hours Avg. Hours Participants Total Hours Avg. Hours
Level 5B (22) 34 723 21 20 386 19 13 290 22
Level 4C-5A (19-21) 525 12,689 24 482 8,244 17 599 13,874 23
Level 3C-4B (15-18) 5,882 115,670 20 5,786 96,066 17 5,792 111,066 19
Level 3A-3B (13-14) 8,430 219,708 26 8,676 164,066 19 9,061 317,128 35
Level 2D-2F (11-12) 13,462 290,819 22 13,020 280,402 22 12,395 234,147 19
Level 2A-2C (8-10) 6,078 158,012 26 4,587 118,002 26 3,568 66,201 19
22= Executive Vice President 14= Assistant Manager
21= Senior Vice President 13= Assistant Manager
20= Vice President 12= Senior Staff
19= Vice President 11= Senior Staff
18= Assistant Vice President 10= Staff
17= Senior Manager 9= Staff
16= Manager 8= Junior Staff
15= Manager *Excluding outsourced employees
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Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Job-Specific Development Training Programs [GRI 404-2]
BTN focuses not only on general competency development but also on training tailored As a further enhancement, BTN provides professional certification programs for employees
to the specific needs of each job function. Job-specific development programs are in roles requiring specific specialization. These certifications serve as formal recognition
designed to strengthen employees’ technical expertise so they can perform their roles of employee competencies and support career development as well as the Bank’s
and responsibilities effectively amid the dynamic banking industry. These programs competitiveness in the banking industry. The certification programs are implemented in
are developed based on job requirements and functional needs, ensuring relevant and accordance with industry standards and applicable regulations through collaboration
applicable competency development. Implementation is carried out in collaboration with recognized professional certification bodies, with the types of certifications held by
with competent third parties, including educational institutions, training providers, and BTN employees shown in the table below.
professional partners, to ensure alignment with industry standards and the Bank’s
business needs. In 2025, BTN provided more than 457 types of virtual training programs Number of Employee Certifications
covering business, credit risk, leadership, and sales and service.
Description 2025 2024 2023
Risk Management Certification (SMR) 2.067 3.297 2.555
Job-Specific Development Training Programs
Mutual Fund Selling Agent Representative Certification 199
175 110
Number of (WAPERD)
Number of Total Training
Training Program Training Methods Treasury Certification 44 40 40
Employees Hours
Types
Commercial Banking Academy 45 5,093 Hybrid 67,910 Competency Development Costs
Consumer Banking Academy 54 8,823 Hybrid 202,459
GRC Academy 29 4,143 Hybrid 52,992 In 2025, BTN strengthened employee competency development by increasing its training
IT & Digital Academy 64 533 Hybrid 14,801
budget by 24.55% compared with the previous year. This investment was driven by the
need to ensure that all employees possess relevant and adaptive skills in response to
Leadership Academy 22 8,253 Hybrid 200,585
industry changes. To support program effectiveness, the Bank implemented a blended
Operations & Finance Academy 171 8,268 Hybrid 162,270
learning approach combining online learning, virtual classes, and self-directed learning.
Sharia Business Academy 63 3,131 Hybrid 46,395
This approach provides flexibility without compromising content quality, enabling
Treasury & Capital Market
9 1,912 Hybrid 8,416 optimal development of both technical competencies and future-ready skills. Details of
Academy
competency development budget allocation are presented in the table below.
Competency Development Cost (Million Rupiah) Growth
2025 2024 Million Rupiah Percentage
131,435 105,530 25,905 24.55
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Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Career Development In addition to potential mapping, BTN also implements a job posting program to provide
broader opportunities for employees to develop their careers through a transparent and
BTN implements a comprehensive succession planning and development program at competitive process.
multiple levels for all employees, tailored to their potential and the organization’s needs.
Each individual is mapped through a performance and future capability based potential
Job Posting Program Implementation Process
matrix to design targeted development strategies.
The system covers multiple levels, from staff to leadership, to ensure a sustainable talent
ANNOUNCEMENT
pipeline and succession readiness.
The Bank announces vacancies for specific positions to all
employees, along with the required candidate criteria.
BTN Career Development Matrix
7 NEED TO
High
8 POTENTIAL 9 STAR SELECTION
DEVELOP
BTN conducts a selection process based on the suitability of
PERFORMANCE
applicants’ profiles with the position requirements. The selection
Medium
4 SLOW includes both desk review and face-to-face assessments
5 AVERAGE 6 POTENTIAL
STARTER
(interviews, simulations, etc.).
2 SLOW 3 NEEDS TO DECISION
Low
1 UNFIT
STARTER DEVELOP
The Board of Directors confirms the selected employee based on
the results of the selection process.
Low Medium High
PLACEMENT
POTENTIAL
The selected employee is formally placed in the
respective position.
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Digitalization
To ensure the availability of talent for
Succession Planning Process for Development Program
strategic positions, a succession planning
• Communication of development
Strategic Positions
process through nomination and programs to successors
selection of high-potential employees • Implementation of development
programs
based on structured stages is in place. Monitoring and Evaluation
• Monitoring Identification of Successors
• Evaluation • Defining success criteria for the target
position
• Assessing profile suitability and successor
readiness
• Ownership and appointment of successor
Mulai Identification of Key Positions Integration with Other HC Processes
• Criteria for key positions • Learning and development
• Methods for identifying and finalizing • Performance management
key positions • Employee movement (mobility)
The Talent Acceleration Program (TAP) Number of Participants in TAP, FLMDP, MMDP, and SMDP in 2025
prepares future leaders at BOD–1 to
Person Grade TAP Batch 1 TAP Batch 2 BTN Millennial Leader Regional Leader Development Program (RLDP)
BOD–3 levels through two pathways: a
2E - - - -
fast-track for employees under 40 years
3A - - - -
old, and the BTN Millennials Program for
3B - 18 4 -
new employees under 26 years old and
existing employees under 30 years old. 3C 53 45 42 7
3D 32 11 9 15
3E/4A 9 1 1 11
4B 2 - - 5
4C - - - 1
Total 96 75 56 39
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Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
The TAP focuses on strengthening leadership capabilities, expanding exposure, and employees, through remuneration adjustments that consider position, length of service,
deepening experience through job rotation with a dual-path approach, providing workload, and performance. This comprehensive evaluation approach strengthens
development opportunities in both managerial and functional career tracks. The employee engagement and ensures BTN’s talent readiness to support future business
selection of pathways is based on organizational needs, employee competencies, and objectives.
career aspirations.
BTNers Excellence Award 2025 (BXA 2025)
To support career growth, BTN has also designed a clear career path structure based
on position categories, job families, and individual career planning integrated with the
learning curriculum. In addition, in 2025, the Bank implemented coaching programs to
strengthen both technical and non-technical skills, including leadership, communication,
challenge management, and work–life balance. Through these various initiatives, BTN is
building a transparent, structured, and inclusive career ecosystem that enables every
employee to develop optimally.
Regular Performance Appraisals and Feedback Processes
In reviewing and assessing employee performance, BTN refers to the General Human
Resources Policy No. KU.3 on Career Management. Through this policy, the Bank ensures
that every evaluation process is conducted objectively and without discrimination
based on gender, focusing instead on competencies, performance achievements, and
individual potential. The results of these evaluations serve as the basis for decisions The organization of the BTNers Excellence Award 2025 (BXA 2025) formed part of the
related to promotion, rotation, and career development opportunities. [GRI 3-3] Bank’s 75th anniversary celebration and reflected a commitment to strengthen its
Employee Value Proposition (EVP) in line with shareholder aspirations to enhance
In 2025, BTN provided performance feedback to 100% of employees across all job levels productivity and implement employee welfare programs. At the event, which was
without exception. Assessments were conducted through semi-annual and annual attended by President Commissioner Chandra M. Hamzah and Deputy President
reviews using key performance indicators (KPIs), and were reinforced by the Continuous Director Oni Febriarto Rahardjo, the Bank recognized outstanding employees
Professional Development (CPD) program as an open dialogue mechanism to discuss through five award categories: Best Employee, Best Innovation, Best Change
achievements, development areas, and career plans. [GRI 404-3] Agent, Best Service, and Best Performance 2024, as an encouragement to foster an
adaptive, innovative, and performance-oriented work culture.
To ensure fairness, BTN’s performance-based remuneration strategy includes merit
increases, incentives, and bonuses in accordance with individual and team contributions.
This policy guarantees equal career opportunities for all employees, including female
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Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Protection and Fulfillment of Employee Rights
BTN is committed to protecting employee rights as a foundation for job satisfaction, BTN ensures that there are no differences in base salary ratios or total remuneration
strong performance, and business sustainability. This commitment is realised through between male and female employees in the same positions. This consistency is reflected
policies that ensure every employee works in a safe, fair environment that respects the in the median salary ratio for men and women, which stood at one-to-one in 2025. Total
balance between working hours and rest periods. salaries for male and female employees amounted to IDR89.2 billion and IDR62.4 billion,
respectively, with average monthly salaries of IDR15.8 million for male employees and
The prevention of forced labour is implemented through General Human Resources Policy IDR11.1 million for female employees. These variations reflect differences in job distribution
No. KU.3 on Working Days and Working Hours, which clearly regulates working time and rather than discrimination, as the wage system based on person grade and performance
stipulates overtime compensation for employees who work beyond standard working achievement is applied consistently. [GRI 405-2]
hours. Through this policy, BTN ensures that no forced labour practices exist in any of its
operational activities. [GRI 409-1] Composition of Male and Female Employee Salaries
Gender Number of Total Salary Average Salary Median Salary
BTN also maintains two-way communication with employees through the dissemination Employees
of information related to policies, procedures, and career development. All the latest Male 5,684 89,234,863,664 15,855,519 10,230,552
provisions can be accessed through the PPDigital, ensuring that employees receive
Female 5,730 62,439,957,044 11,074,842 8,814,926
consistent and transparent information.
Total 11,414 151,674,820,708 26,930,361 19,045,478
Employee Remuneration The Bank’s salary structure is also aligned with government regulations, including Law No.
6 of 2023 on Job Creation. BTN sets minimum salaries above the Regional Minimum Wage
BTN implements a fair, transparent, and non-discriminatory remuneration policy in line and conducts salary reviews at least once a year. The Bank also maintains remuneration
with diversity principles and labour regulations. Remuneration is recognition for employee competitiveness by keeping salary levels above the P60 percentile of the industry. BTN
performance and responsibilities and is not influenced by gender, ethnicity, race, ensures compliance with applicable minimum wage provisions for all workers, including
religion, personal characteristics, or other factors unrelated to competence. This policy is non-employee workers/outsourced personnel, And wages for non-employee workers are
stipulated in Special Policy No. KK.3.B on Remuneration and refers to the regulations of the determined in accordance with the minimum wage applicable in the respective work
Financial Services Authority (OJK), including OJK Regulation No. 45/POJK.03/2015 on the location and prevailing laws and regulations. [GRI 202-1, 409-1] [OJK F.20]
Implementation of Governance in Remuneration for Commercial Banks and OJK Circular
Letter No. 40/SEOJK.03/2016 on the Implementation of Governance in Remuneration for As a comprehensive implementation of its remuneration policy, BTN provides various
Commercial Banks. [GRI 3-3] benefits cover all employees. These benefits include base salary, annual salary
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Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
adjustments, religious holiday allowance, annual leave allowance, and long leave As a performance-oriented bank, remuneration is aligned with individual, unit, and
allowance every three years of service. BTN also ensures that annual leave is not only organisational performance achievements. Employees who work beyond official
granted administratively, but is actually taken by employees through integrated leave working hours receive overtime compensation in accordance with applicable provisions
monitoring and management as part of efforts to support work life balance and employee and proportional to their job level. Variable remuneration is also provided in line with
well being. The Bank also provides comprehensive healthcare facilities for employees and organizational needs and prevailing policies, including overtime pay, clothing allowance,
their families, including inpatient care, outpatient care following hospitalisation, maternity sales bonuses, annual bonuses, and location and position allowances. In accordance
expenses, dental services, medical check-ups, and optical benefits. BTN ensures that with Special Policy No. KK.3.B on Remuneration, the Bank also provides a Long-Term
these non-salary benefits are provided equitably, including to contract employees. Incentive (LTI) scheme in the form of shares, cash, or other facilities as determined by the
Board of Directors, as a retention mechanism and reward for the Company’s strategic
Employee Remuneration and Benefits Components
achievements. [GRI 409-1] [OJK F.20]
Permanent Contract
Remuneration and Benefit Components
Employees Employees In addition, BTN supports employee welfare through employee welfare loan facilities and
Basic Salary a Car Ownership Program to help employees meet basic needs in a more accessible
Position Allowance and affordable manner. All remuneration components and benefits are aligned with
employment status, and the rights of contract employees are ensured to comply with
Functional Allowance
applicable standards. [GRI 401-2]
Religious Holiday Allowance
Annual Leave and Extended Leave Allowance Employee Equity Programs
Clothing Allowance *)
As part of its ongoing evaluation of the effectiveness of its incentive policies, BTN has
Allowances for Housing, Vehicles, Expertise, Location, and Tax
completed the implementation of the MESA Management Employee Stock Allocation
Performance Bonus program and the MESOP Management and Employee Stock Option Plan. These programs
Employee Welfare Loan previously served as share-based incentive instruments aimed at increasing the
motivation and engagement of employees, executives, the Board of Directors, and the
Pension Program
Board of Commissioners through share ownership opportunities.
Social Security Covering Employment and Health
Periodic Health Check Facilities Since the completion of these programs, BTN has neither extended nor introduced similar
Medical Assistance schemes for management or employees. The Bank has chosen to reassess the relevance
of share-based incentives and to shift its focus to other forms of rewards deemed more
Bereavement Assistance
appropriate to organizational needs and long-term strategy reflecting the adjustment of
Length of Service Award
BTN’s human capital management policies to current business dynamics and corporate
*Clothing allowance is provided in the form of uniforms (front liner, superstaff, priority banking)
priorities.
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Digitalization
Employee Well-Being Program
The Employee Value Proposition (EVP) is strengthened through the development of a work In addition, the Bank provides productivity-supporting facilities that further enhance the
culture that supports the physical and mental health of all employees. Throughout 2025, employee experience, such as co-working areas, daycare, nursery rooms, and revitalized
the Bank implemented a range of structured well-being programs aimed at enhancing gym centers designed to improve workplace comfort.
comfort, fitness, and work–life balance. The programs are presented in the following table:
BTNers Club
No Program Name Description Objective
1 Employee A program to improve employee Meningkatkan kesehatan pegawai
Wellness health, covering both physical BTN untuk menunjang kinerja dan
Program (EWP) and mental well-being, through mendukung kesejahteraan mereka.
the provision of consultation
platforms with experts.
2 Roadshow Pekan A socialization program across • To enhance employees’
Sehat all BTN operational areas on understanding of the importance
employee health improvement of maintaining health to improve
programs and the use of health productivity
consultation platforms. • To enable employees to utilize
the available platforms as health A healthy and collaborative culture is also realized through the BTNers Club, a
consultation media
platform that brings together 26 sports, arts, and religious communities. The
3 Financial A program to increase employee To enable employees to manage presence of the BTNers Club supports the creation of work–life harmony while
Wellness Webinar awareness of financial their finances effectively and achieve
providing space for employees to develop hobbies, interact across units, and
management. financial wellness.
expand informal networks. As part of the Employee Wellbeing Program (EWP), this
4 Pekan Sehat A one-week employee health • To help employees establish more
dan Seminar improvement program consistent healthy lifestyles and initiative helps foster a more positive, inclusive, and productive work environment.
Kesehatan consisting of mini medical gain insights from health experts In 2025, this commitment was further strengthened through the organization of
(Health Seminar) check-ups (MCU) and health • To provide employees with an
BTN Mini Olympic 2025, an annual event held in conjunction with BTN’s anniversary
seminars under the theme “Fit at overview of their current health
Work, Happy in Life.” condition through examinations. that features sports and arts competitions among employees. The event involved
contingents from each Regional Office and served as a platform for self expression,
5 Donor Darah A routine quarterly activity To facilitate employees in maintaining
(Blood Donation) conducted across all Regional their health while contributing to sportsmanship, and cross regional collaboration. Through the BTN Mini Olympic,
Offices. society. the Bank fosters positive energy, strengthens employee engagement, and supports
work life balance as a foundation for productivity and sustainable performance.
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Digitalization
Through the integration of well-being programs and the strengthening of internal Maternity Leave
communities, BTN seeks to safeguard employees’ holistic well-being so that they can
continue to contribute optimally and sustainably to the Bank’s growth. Birth related leave entitlements are an important part of BTN’s support for employee family
well being. Through General Human Resources Policy No. KU.3 on Industrial Relations
BTN Jakarta International Marathon 2025 Management, the Bank clearly regulates the types of leave available to employees.
Female employees are entitled to three months of maternity leave, while male employees
are entitled to five days of leave to accompany the childbirth process. BTN also provides
45 days of miscarriage leave for permanent female employees and offers fertility related
leave of up to 30 days in accordance with applicable regulations.
Detailed information on the implementation of these leave entitlements is presented in
the following table: [GRI 401-3]
Maternity Leave
2025 2024 2023
Description
Male Female Male Female Male Female
Number of employees entitled to
3,874 3,068 4,597 3,593 4,506 3,520
maternity leave
The BTN Jakarta International Marathon (BTN JAKIM) 2025 successfully attracted
Number of employees who took
31,000 runners from Indonesia and abroad, making it one of the largest running 285 512 337 384 514 564
maternity leave
events in the country. Organized in collaboration with the DKI Jakarta Provincial Returned after taking maternity leave 282 422 332 350 506 472
Government and various stakeholders, the event applied the 4S concept (Sterile,
Secure, Safety, Smooth) in accordance with international standards and once
again received World Athletics Label Road Races recognition. The participation In 2025, BTN recorded 282 male employees and 506 female employees returning to work
of running communities and the general public reflects strong enthusiasm for after maternity related leave and remaining employed for at least 12 months after their
healthy lifestyles and sports tourism in Jakarta. return. The return to work rate after leave reached 98.9% for male employees, while the
rate for female employees was 82.4%. The post leave retention rate was 98.9% for male
The event generated significant social and economic impacts through increased employees and 98.8% for female employees. These results reflect BTN’s commitment to
hotel occupancy, MSME activities, and transaction growth in the culinary, retail, supporting sustainable employee careers, particularly for women, and the effectiveness
and tourism sectors. With successful implementation, BTN JAKIM 2025 contributed of labor policies that promote a balance between family responsibilities and professional
to the development of the sports ecosystem, strengthened community roles.
engagement, and promoted Jakarta as an international sports destination city.
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Pre-Retirement Program Employee Grievance Handling
BTN ensures that employees approaching retirement receive adequate support through Grievance Management
the 12-month Pre-Retirement Program (Program Masa Persiapan Pensiun/MPP) designed
to help employees prepare for retirement in terms of skills, mental readiness, and long- Healthy and communicative working relationships are viewed as an essential foundation
term well-being. The program covers emotional, spiritual, and intellectual aspects, for a safe, productive, and trust-based work environment. To support this, the Bank
enabling participants to enter retirement in a healthy, productive, and empowered provides various internal communication channels that are easily accessible and
manner. [GRI 404-2] designed to ensure employees can obtain information quickly and transparently. One of
these is the BTNBest digital HR platform, which serves as a central hub for information and
The process in the MPP is delivered through three main methods: services related to administration, policies, and employee development.
1. Experiential learning, which builds understanding through direct experience and
interaction with other participants. In addition, the Bank provides a structured grievance and escalation mechanism for labor
2. Quantum learning, which encourages two-way communication in a comfortable and human capital issues. Complaints are submitted in stages, starting with the direct
training atmosphere and motivates behavioral change. supervisor, followed by the unit head, and then the Regional Office head or the Human
3. Technical methods, including presentations, role-playing, discussions, case studies, Capital Management Unit. If the issue remains unresolved, employees may involve the
independent assignments, and multimedia use. BTN Labor Union to obtain support during follow up with the Human Capital Management
Unit. All processes are carried out with confidentiality and protection of the complainant’s
The program is provided to permanent employees approaching retirement age as a identity, handled objectively and professionally, and supported by follow up services such
form of appreciation for their contributions during their service at BTN, with benefits that as counseling and assistance from professional practitioners when required.
can be tailored to each employee’s individual planning needs. Upon reaching retirement
age, 56 years for general employees and 36 years for certain positions such as tellers, As part of its commitment to creating an integrity-driven workplace, BTN also has a
customer service officers, and secretaries, employees are entitled to receive retirement Whistleblowing System (WBS) managed by an independent third party. This system
benefits in accordance with General Human Resources Policy No. KU.3 on Employment provides a secure and confidential reporting channel for employees to report alleged
Termination Management. These benefits include: [GRI 201-3] violations without fear of retaliation. The WBS is used not only for fraud reporting but
1. A defined benefit program based on the formula set by the pension fund. also as a channel for complaints related to employment and human rights issues, in
2. A defined contribution program derived from employee contributions of 2.5 percent, accordance with Technical Guideline No. 7-B.2 on Whistleblowing System Management.
Bank contributions of 7.5 percent, and investment returns. This facility is available at all times.
3. Maximum pension benefits of up to 80 percent of basic pensionable income in
accordance with BTN pension fund provisions. Throughout the reporting year, there were no cases of violations related to the work
environment. The Bank continues to ensure a professional, safe, and mutually respectful
Through this support, BTN ensures that its employees enter retirement with better work environment through the implementation of effective policies and monitoring
preparedness while recognizing their dedication throughout their service. mechanisms. Any indication of a violation of applicable regulations will be followed
up objectively and thoroughly, and if a violation is proven, the Bank will impose
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disciplinary sanctions in accordance with internal policies and applicable regulations Employee Satisfaction Index
as a manifestation of its commitment to upholding behavioral standards, maintaining
Description Unit 2025 2024 2023
fairness, and strengthening a work culture that promotes openness and psychological
Satisfaction Index
security. % 92 93 86
(average score)
Coverage (% of
To complement this support, BTN also provides a Legal Clinic, an online consultation employees participating % 89 91 93
service that assists employees in obtaining answers to simple legal questions related in the survey)
to daily tasks. This service ensures that employees always have access to accurate and
reliable legal information, while strengthening transparency and certainty in daily work The survey results serve as the basis for developing strategic programs to improve
processes. employee productivity, employee wellbeing, and talent management initiatives.
The findings also drive improvements in communication between employees and
Employee Engagement Survey management to support and strengthen a positive and productive work culture.
The annual employee engagement survey aims to understand employees’ work
experiences, needs, and motivation levels and covers 100 percent of employees serving
as a primary tool to assess the effectiveness of HR policies and identify areas for
improvement.
The assessment uses a 100-point scale, with results reflecting strong engagement
across various aspects. The indicators measured include benefits and compensation,
performance management, talent development, leadership, collaboration, innovation,
and well-being. The detailed results are presented in the following engagement index
table:
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Employee Health and Safety
Occupational Health and Safety Management System [GRI 403-1, 403-2]
Occupational health and safety is fundamental in creating a safe, productive, and and third parties working under BTN’s supervision. SMK3 implementation covers all
sustainable work environment and the principle aligns with the Bank’s aspiration to activities within the operational environment and is supported by a centralized recording
become a home for Indonesia’s best talents, where every employee can work in an system managed by the Human Capital Management Unit, as well as the development
atmosphere that ensures both physical and mental security, in accordance with Law and implementation of standard operating procedures to ensure that all work processes
No. 13 of 2003 on Manpower. To uphold this standard, the Bank has established a zero comply with occupational health and safety standards. [GRI 403-7, 403-8]
accident and zero occupational disease target as its primary commitment to employee
protection. [GRI 3-3] [OJK F.21] The implementation of SMK3 is supported by employees certified as General OHS Experts
(Ahli K3 Umum/AK3U), who have been prepared since 2020 through certification programs
The Occupational Health and Safety Management System (Sistem Manajemen by the Ministry of Manpower. AK3U-certified employees are responsible for ensuring the
Keselamatan dan Kesehatan Kerja/SMK3) serves as an integrated framework for effective implementation of OHS standards, identifying hazards using the hierarchy of
managing health and safety risks across all work units. The framework encompasses controls principle, conducting risk assessments, and investigating reports of hazardous
policy development, planning, implementation, monitoring, and continuous evaluation, situations or incidents to prevent recurrence. The certification program covers, among
and is formalized through: [GRI 403-1] others: [GRI 403-2, 403-5, 403-7]
1. Special Policy No. 9 AG on the Occupational Health and Safety Management System; 1. Building support facilities such as elevators, generators, air conditioning systems,
and and lighting;
2. Technical Guideline No. 9 AG.1 on the Implementation of SMK3. 2. Regular medical check-ups;
3. Work equipment requirements to prevent adverse health impacts; and
All policies refer to Minister of Health Regulation No. 48 of 2016, which requires all offices 4. Periodic employee rotation to maintain psychological well-being.
to implement a structured occupational health and safety system to prevent workplace
accidents and occupational diseases. The development of SMK3 is also carried out In addition to this main framework, the Bank also implements supporting policies,
adaptively to suit the characteristics of office-based operations. Regulated aspects including the prohibition of narcotics and addictive substances, prevention of the spread
include the establishment of OHS policies, OHS planning, implementation of work plans, of infectious diseases, and the management of contractors and third parties to ensure
monitoring and evaluation, as well as periodic review and performance improvement. compliance with OHS standards.
BTN’s Occupational Health and Safety Management System policies and implementation These preventive efforts are complemented by the provision of consultation facilities,
apply to all parties within BTN’s operational scope and cover all personnel without hazard reporting channels, and transparent communication regarding all OHS standards.
exception, including permanent employees, contract employees, outsourced workers, Although a formal OHS committee involving management and employees has not
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yet been established, the implementation of SMK3 has demonstrated positive results. services covering promotive, preventive, curative, and rehabilitative aspects. With this
Throughout the reporting year, the Bank successfully maintained a work environment free support, employee health can be sustainably maintained while strengthening productivity
from workplace accidents and occupational diseases, underscoring the effectiveness of and workplace comfort. Health services provided to employees include:
its safety management practices. [GRI 403-4, 403-9, 403-10] 1. Periodic medical check-ups and medical treatment services to detect and manage
diseases at an early stage.
Employee Safety Management Program [GRI 403-5] 2. Various health benefits, including inpatient and outpatient care, maternity costs,
dental care, eyeglasses, hearing aids, laboratory tests, and other medical services.
The Bank has various programs designed to ensure that every employee can work safely. 3. Access to polyclinics and physicians for employees and their families.
All operational offices are equipped with safety devices in accordance with government 4. Health seminars such as drug abuse prevention, HIV/AIDS awareness, and other
standards, including fire protection systems and evacuation facilities. The safety health education programs. [GRI 403-5]
programs implemented include: 5. BPJS Kesehatan (national health insurance) coverage for employees and their
1. Provision of safety equipment such as fire extinguishers, smoke detectors, diesel families.
pumps, and emergency stairways in accordance with Minister of Public Works 6. Health talk activities as an educational and literacy effort for all employees on the
Regulation No. 26/PRT/M/2008 on Technical Requirements for Fire Protection Systems importance of maintaining health through a healthy lifestyle.
in Buildings and Their Surroundings.
2. Routine inspections and maintenance to ensure all equipment functions optimally.
3. Certification for safety equipment operators, including lifting and transport equipment
and electrical occupational health and safety, attended by Building Management
personnel.
4. Provision of fire evacuation plans and safety procedures in all rooms and on all floors
of buildings.
5. Implementation of emergency response training and simulations related to fire and
disasters in the office environment.
6. Training and certification for General Occupational Health and Safety Experts for
BTN employees and outsourced personnel as part of efforts to strengthen safety
competencies.
Employee Health Management Program [GRI 403-3, 403-6]
Efforts to maintain employee well-being are carried out through the provision of
comprehensive health facilities, supported by cooperation with external medical service
providers. This approach ensures that every employee has access to adequate health
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Harmonious Industrial Relations
Respect for freedom of association is important in creating healthy and equitable To foster harmonious, conducive, and sustainable industrial relations, BTN consistently
industrial relations. The Bank provides full opportunity for employees to establish, join, upholds the principles of transparency, partnership, and constructive social dialogue
and participate in labor organizations, in line with Indonesia’s commitment as a country between management and the labor union. This commitment is implemented through
that has ratified 19 International Labour Organization (ILO) Conventions. This policy regular Bipartite Cooperation Institution meetings, which serve as a formal communication
affirms that open dialogue between employees and management is a foundation for and consultation forum between management and the BTN Labor Union to discuss labor
maintaining harmonious employment relations, improving welfare, and resolving labor and industrial relations matters.
issues constructively.
In 2025, BTN conducted negotiations and signed a Collective Labor Agreement for the
This freedom is in accordance with various national regulations, including Article 28E 2025–2027 period as a commitment to strengthening constructive industrial relations.
paragraph (3) of the 1945 Constitution, Law No. 21 of 2000 on Trade Unions, and ILO The agreement serves as the foundation for regulating the rights and obligations of both
Convention No. 87 of 1948 on Freedom of Association. By referring to these provisions, parties and reflects a mutual agreement that upholds fairness, employee protection,
the Bank ensures that all employees have equal access to express their aspirations and and legal certainty in employment relations. The 2025–2027 Collective Labor Agreement
participate in industrial relations processes. [GRI 3-3] guarantees the protection of labor rights for 100% of employees and ensures that
all employees (100%) who are members of the BTN Labor Union have equal access to
This commitment is realized through the establishment of the BTN Workers Union on dialogue and employment dispute resolution mechanisms. The agreement is designed
24 June 1999, which has been officially registered with the DKI Jakarta Department of to build an inclusive, productive, and sustainable workforce ecosystem, aligned with the
Manpower under registration number Kep-2241/W.26/K.2/1000. The workers union serves enhancement of employee welfare and the Bank’s long-term performance.
as a dialogue partner to management and operates in accordance with Minister of [GRI 2-30] [OJK F.19]
Manpower Regulation No. 28 of 2014. Employees are given full freedom to: [GRI 407-1]
1. Become members of the workers union;
2. Channel their aspirations through the workers union; and
3. Participate in labor organization activities.
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Social and Economic Compliance
All Bank operational activities are conducted in accordance with applicable labor
regulations and socio-economic standards. This commitment is reflected in fair,
transparent employment practices that respect human rights, including the prohibition of
human trafficking, forced labor, child labor, and all forms of discrimination in employment
relations and customer services.
In terms of OHS, the Bank consistently creates a safe, comfortable, and risk-free work
environment. From an economic perspective, the Bank upholds fair competition, rejects
monopolistic practices, and implements anti-corruption policies as part of responsible
governance. The wage structure is maintained to remain reasonable, proportional to
employee contributions, and in line with applicable labor regulations. [GRI 3-3] [SASB FN-CB-
510a.1]
This commitment to compliance is reflected in the absence of fines, non-monetary
sanctions, or cases brought to dispute resolution mechanisms throughout the reporting
year. No violations related to labor regulations, product legality, or other social issues
were identified, indicating the effectiveness of internal controls and the Bank’s operational
compliance. [GRI 2-27]
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05
Strengthening
Communities through
Care and Inclusion
122 Corporate Social Responsibility
129 Financial Inclusion and Literacy
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Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
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As a financial institution that grows alongside the community, BTN is committed to delivering
tangible and sustainable impact. Its role extends beyond providing financial services to acting as
an active partner in social development. Through social responsibility programs, empowerment
initiatives, and strengthened financial inclusion and literacy efforts, BTN addresses socio
economic challenges while promoting long-term community self reliance.
This approach reinforces BTN’s commitment to managing its social impact on In line with PER-1/MBU/03/2023 and the Sustainable Development Goals (SDGs), BTN
communities and stakeholders, while ensuring that its sustainability strategy aligns designs programs that integrate its social role with expanded access to financial services
with expanding inclusive and equitable access to financial services. This commitment to ensure that the initiatives implemented not only address social, economic, and
is reflected in the ESG Roadmap and the Sustainable Finance Action Plan, which position environmental issues, but also create opportunities for communities to enhance financial
community development, financial inclusion, and financial literacy as strategic pillars to literacy and expand access to banking services.
ensure that business growth delivers broader and lasting social benefits.
Corporate Social Responsibility [GRI 203-1, 203-2, 413-1] [OJK F.23, F.25, F.3]
For BTN, social contribution goes beyond compliance and reflects its commitment to To ensure that each program delivers measurable benefits, implementation refers to ISO
grow and create shared value with the community. Through its Social and Environmental 26000 on Social Responsibility. This framework ensures that each initiative is precisely
Responsibility program, BTN implements initiatives focused on community empowerment, targeted, delivers measurable impact, and creates added value for communities,
improving quality of life, and supporting environmental preservation across its employees, and the environment. Through this approach, the BTN continues to strengthen
operational areas, positioning the program as a key pillar of the Sustainable Finance its role in supporting sustainable social, economic, and environmental development.
Action Plan and reinforcing that sustainable business performance must align with social
and environmental progress.
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During the reporting year, total CSR realization amounted to IDR119.91 billion. Details of
budget utilization are presented in the table below.
CSR Program Realization
SDG 2025 (Rp) 2024 (Rp) 2023 (Rp)
Social Pillar
1 No Poverty 24,300,797,801 11,045,972,420 10,505,377,274
2 Zero Hunger 32,834,988,494 21,159,374,300 14,798,413,813
3 Good Health and Well-Being 3,669,211,000 14,845,051,673 12,348,435,325
4 Quality Education 9,425,235,044 8,645,104,300 12,635,697,919
5 Gender Equality 582,000,000 220,000,000 -
Environmental Pillar
6 Clean Water and Sanitation 455,714,000 95,000,000 270,000,000
11 Sustainable Cities and Communities 9,746,385,077 14,900,539,959 14,993,831,355
12 Responsible Consumption and
532,678,800 1,079,576,859 -
Production
13 Climate Action 25,000,000 295,078,954 -
14 Life Below Water 516,763,040 375,120,000 -
15 Life on Land 5,417,365,000 1,592,977,380 1,184,084,000
Economic Pillar
7 Affordable and Clean Energy 616,347,374 1,205,465,000 50,000,000
8 Decent Work and Economic Growth 25,330,651,968 5,278,260,444 4,361,935,431
9 Industry, Innovation, and Infrastructure 4,648,205,100 6,236,867,228 2,270,000,000
10 Reduced Inequalities 836,174,388 1,445,294,797 5,734,719,287
17 Partnerships for the Goals 452,974,000 495,017,300 943,694,328
Legal and Governance Pillar
16 Peace, Justice, and Strong Institutions 521,230,966 50,000,000 -
Total 119,911,722,052 88,964,700,614 79,996,188,732
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Social Pillar
BTN’s commitment to growing together with the community is reflected in various social initiatives aimed at
improving the welfare and quality of life of the community in social, cultural, and religious aspects. This focus
aligns with SDGs 1, 2, 3, 4, and 5, which emphasize poverty alleviation, food security, better health, access to
education, and gender equality.
1. Disability Skills Development
BTN organized English language training and competency certification for 100 persons
with disabilities. This program enhances participants’ skills, expands employment
opportunities, and promotes economic self reliance as part of BTN’s commitment to
widening access to jobs and empowering vulnerable groups.
2. Scholarships for the Children of BTN Outsourced Workers
As part of its social responsibility, BTN provided educational scholarships to the children
of outsourced workers, including operational and security personnel. The program
supported 108 beneficiaries, expanded access to education, improved family welfare,
and strengthened an inclusive social ecosystem within the BTN’s environment.
3. BTN Provides Assistance for the Renovation of Uninhabitable Houses
BTN President Director, Nixon L.P. Napitupulu, together with the Director of Human
Capital and Compliance and the Financial Transaction Reports and Analysis Center,
distributed assistance for the renovation of uninhabitable houses to communities in
North Jakarta, Cikarang, and Cianjur. A total of 15 housing units received renovation
support as part of BTN’s commitment to improving housing quality and enhancing
community welfare.
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Environmental Pillar
Environmental conservation efforts are realized through natural resource management and various initiatives
to preserve ecosystem sustainability. This aligns with SDGs 6, 11, 12, 13, 14, and 15, which emphasize clean water
management, sustainable cities, responsible consumption and production, climate action, and the protection
of terrestrial and marine ecosystems.
1. Tree and Mangrove Planting
BTN carried out the planting of 19,048 trees and 7,600 mangroves as part of its
environmental conservation commitment. This program increased environmental
awareness, strengthened green ecosystems, and encouraged active participation
from communities and stakeholders in sustainable business practices. The activities
were complemented by education and networking sessions among developers,
suppliers, and other stakeholders to strengthen green business synergies that are
environmentally friendly and sustainability-oriented.
2. Tree Planting in a National Strategic Project Area with the Theme “Growing
Together with Nature”
BTN planted 5,000 tree seedlings in Depok to strengthen the area’s ecological function
as a water catchment zone. This initiative is expected to increase CO₂ absorption
capacity while supporting environmental preservation and long-term ecosystem
sustainability.
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Economic Pillar
Efforts to strengthen inclusive economic growth are carried out through initiatives to expand employment
opportunities and develop community enterprises. These initiatives support quality and sustainable community
economy, in line with SDGs 7, 8, 9, 10, and 17, which emphasize energy access, economic growth, innovation,
inequality reduction, and development partnerships.
1. BTN Entrepreneurship Competition
BTN organized the BTN Entrepreneurship Competition as an innovation platform
within the housing ecosystem, with 1,170 participants. The program encouraged the
emergence of sustainable business ideas with positive social and environmental
impacts, opened new business opportunities, strengthened participants’
entrepreneurial skills, and reinforced the BTN’s contribution to building an inclusive
and competitive housing sector.
2. MSME Development Training
The MSME development training program focused on enhancing the capacity of
business actors in the property and housing sectors. Through mentoring sessions
and workshops, BTN strengthened managerial capabilities and access to financing
to enable MSMEs to grow sustainably within the national housing ecosystem. The
program successfully reached 250 MSMEs, delivering a positive impact on the
capacity and skills of business owners.
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Legal and Governance Pillar
Efforts to improve legal compliance and governance are carried out through transparent, accountable,
and integrity-based policies and oversight, supporting the creation of effective, fair, and professional
institutions in line with SDG 16.
&$!#%!
NO MOR
E
V IO LE N 1. Support for Facilities and Infrastructure of Rifka Annisa Women’s Crisis Center
CE
BTN is committed to delivering its Social and Environmental Responsibility (TJSL)
programs under the Law and Governance Pillar by supporting Rifka Annisa Women’s
Crisis Center. Rifka Annisa is a women’s crisis center in Yogyakarta that focuses
on eliminating gender-based violence against women and children through
comprehensive support services. The organization also advocates for policies that
are more responsive to violence against women and contributes to prevention efforts
through training, research, and multi-stakeholder partnerships.
RE
MO CE
NO LEN
I O
V
2. Support for a High-Profile Case (HPC)
Support for the High-Profile Case (HPC) involving Susanti binti Mahpud Dharab
represents comprehensive assistance for a case receiving significant public attention
and requiring special sensitivity. This support is provided to help ensure the case is
handled professionally and transparently, in accordance with applicable laws and
regulations. Susanti binti Mahpud Dharab is an Indonesian migrant worker from
Karawang, West Java, who faced the death penalty in Saudi Arabia. BTN participated
in a donation drive to help cover the required penalty payment and support efforts to
save her life.
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CSR Outcome This approach provides a more comprehensive picture of the extent to which programs
address community needs, deliver tangible benefits, and create long-term impact. Every
Assessing the success of a social program cannot rely solely on output or the size of rupiah spent is assessed in terms of its social return, enabling more targeted and effective
the budget; it must also be evaluated on the changes experienced by the community. decision-making and program planning.
Based on this principle, the Social Return on Investment (SROI) approach is applied to
understand the social and environmental value created by each sustainability initiative. The results of the SROI assessment for several sustainability programs are presented in
SROI indicates the social value generated for every rupiah invested; for example, an SROI the table below, illustrating the social contributions generated throughout the reporting
ratio of 3:1 means that an investment of one rupiah produces social benefits equivalent year. [GRI 413-1]
to three rupiah for the community.
Table of CSR Outcome
Program Name Program Objective Target Beneficiaries SROI Ratio
BTN Housingpreneur Strengthen the capacity of micro, small, and medium enterprises operating across housing Students and the general public 2.22
related value chains, including design, housing development, material innovation, and
supporting sectors within the housing ecosystem.
Home Renovation for Substandard Housing Improve housing quality for low income communities. Communities in Lagoa Subdistrict, North Jakarta; 0.45
Hegarmukti Village, Cikarang Bekasi; and
Margaluyu and Girimukti Villages, Cianjur Regency
Ruang Guru MSME Training Program Strengthen MSME capacity through improved digital skills, business management, and BTN Rumah BUMN participants 2.13
sustainable entrepreneurship development.
Stunting Prevention and Reduction Support child health and balanced nutrition through the provision of supplementary food. 25 children across five subdistricts 2.35
Program
International Training and Certification for Enhance the capacity and competitiveness of persons with physical disabilities to access 50 participants 2.70
Persons with Disabilities Batch 1 more decent, equal, and inclusive employment opportunities.
International Training and Certification for Enhance the capacity and competitiveness of persons with physical disabilities to access 50 participants 1.54
Persons with Disabilities Batch 2 more decent, equal, and inclusive employment opportunities.
Planting of 5,000 Trees Support environmental conservation, ecosystem quality improvement, and climate Communities in Depok City 2.29
change mitigation through increased green vegetation cover.
Urban Green Transformation Urban Support urban food security, environmental quality improvement, and community Communities in Kalisari Subdistrict, Pasar Rebo 1.60
Farming empowerment through sustainable urban farming. District, East Jakarta
Planting of 5,000 Trees Support environmental conservation, ecosystem quality improvement, and climate Communities in the upper watershed of the 2.30
change mitigation through increased green vegetation cover. Citarum River Basin
Mangrove Restoration and Capacity Protect coastal ecosystems, mitigate climate change, and strengthen community Communities in Lantebung Makassar, Wonokerto 0.82
Building for Blue Carbon 7,500 seedlings empowerment based on sustainable natural resource management. Pekalongan, and Mangrovesari Kaliwlingi Brebes
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Financial Inclusion and Literacy [FS6] [SASB FN-CB-240A.2]
BTN provides financing to the Micro, Small, and Medium Enterprises segment as part Number of Assisted Partners (Business Activities) and Funds Disbursed
of its commitment to promoting inclusive economic growth, with a focus on targeting
Description 2025 2024 2023
underserved communities with limited access to financial services. This commitment is
implemented through several MSME financing programs with distinct characteristics and Number of Assisted Partners 161 498 170
target segments, as outlined below. Total Funds Disbursed (in Rp million) 6,554 14,850 9,162
In the reporting year, BTN’s MSME financing recorded outstanding balances of Rp140,585
million in the past due category, reflecting non performing loans, and Rp175,566 million in Realization of UMK Financing Program Disbursement by Business Sector [SASB FN-CB-
410a.1]
the nonaccrual category, which have been classified as write offs. Past due refers to loans
that have exceeded their payment due date, while nonaccrual refers to problem loans 2025 2024 2023
No Business Sector
for which interest income is no longer recognized due to indications that the borrower is Rp Million % Rp Million % Rp Million %
unable to meet repayment obligations. [FN-CB-240a.2]
1 Industry 606 9.25 601 4.05 170 1.85
2 Trade 4,019 61.32 6,014 40.50 6,539 71.27
Micro and Small Enterprise Financing Program (PUMK)
3 Agriculture 385 5.87 45 0.30 95 1.04
4 Plantation 50 0.76 - - 550 6.00
Empowering micro and small enterprises is one of the Company’s main priorities in its
5 Livestock 135 2.05 226 1.52 95 1.04
social programs. Through the Micro and Small Enterprise Financing Program (PUMK),
efforts are made to strengthen business capacity so that entrepreneurs can grow, 6 Fisheries 120 1.83 190 1.28 100 1.09
improve competitiveness, and make tangible contributions to the local economy. The 7 Services 1,065 16.24 2,347 15.80 1,622 17.70
program also serves as a bridge for business actors who have potential but do not yet 8 Others 175 2.67 5,427 36.54 - -
meet the requirements of conventional bank financing. Total 6,554 100.00 14,850 100.00 9,162 100.00
PUMK financing is provided in a measured manner by considering business sectors Realization of UMK Financing Program Disbursement by Region [SASB FN-CB-410a.1]
and operational areas, ensuring that the benefits are more targeted. PUMK funding was
2025 2024 2023
distributed in a structured manner through partnership schemes with third parties, with a No Region
Rp Million % Rp Million % Rp Million %
total allocation of Rp11 billion and Rp6.55 billion disbursed to 161 assisted partners during
1 Sumatra - - - - 935 10.20
the reporting year.
2 DKI Jakarta 375 5.72 - - 788 8.60
3 DI Yogyakarta 489 7.46 781 5.26 115 1.26
4 West Java and Banten 134 2.04 2,935 19.77 1,882 20.63
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2025 2024 2023 collection personnel; merchants, agents, performing
No Region
Rp Million % Rp Million % Rp Million % • Establish dedicated call desks for mortgage loans, and performing
5 Central Java 4,110 62.71 1,760 11.86 1,002 10.94 MSME credit; KUR loans.
6 East Java 1,446 22.06 1,517 10.22 980 10.70 • Provide on site support to Branch 4. SME Debtor Savings Transactions
7 Bali - - 410 2.76 60 0.65 Offices; and • Implement bundling programs for
8 East Nusa Tenggara - - - - 880 9.60 • Deliver targeted training for sales Business Savings, QRIS or EDC, and
staff. Cash Management Services; and
9 West Nusa Tenggara - - - - 525 5.73
2. Business Process • Develop propositions to
10 Kalimantan - - 480 3.23 780 8.51
• Portfolio quality reviews; encourage debtor savings and
11 Sulawesi - - 6,966 46.91 970 10.59
• Implementation of stop-and-go transaction activity.
12 Maluku - - - - 245 2.67
procedures; and 5. Partnerships and Sector Expansion
13 Papua - - - - - -
• Improvement of credit processes • Develop strategic partnerships;
Total 6,554 100.00 14,850 100.00 9,162 100.00 through BTN Laku. and
3. Value Chain & Ekobiz • Expand SME lending to high growth
Micro, Small, and Medium Enterprises Loan Program (KUMKM) • Optimize sales across customer sectors with low non performing
value chains and ecobiz loan levels.
Improving access to financing for MSMEs is an important part of the sustainable economic segments;
empowerment strategy. Through the provision of working capital and investment • Support debtor upgrading to The following is BTN’s KUMKM credit
financing, support is extended to MSMEs with potential and feasibility across various higher business classes; distribution portfolio (Rp Million):
economic sectors. This not only helps expand business capacity but also encourages
productivity, competitiveness, and readiness to grow in an increasingly competitive
(Rp Million)
market.
As part of its economic intermediation role, the KUMKM program is designed to provide
financing of up to IDR5 billion to business actors, enabling them to strengthen operations,
increase production capacity, and create more employment opportunities. This initiative
has a direct impact on local economic growth and community welfare. [SASB FN-CB-240a.1]
To expand outreach and improve the effectiveness of MSME credit distribution during the 2025 2024 2023
reporting year, BTN implemented the following strategies:
1. Human Capital Competency and • Implement MSME development 5,667,275 4,404,263 3,431,071
Capability programs; and
• Increase sales productivity; • Optimize databases covering
• Add outsourced sales and
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KUMKM Credit Distribution by Economic Sector [FS6, FS7] [SASB FN-CB-410a.1] Total Distribution (Rp Million)
Province
2025 2024 2023
Total Distribution (Rp Million)
Economic Sector Bengkulu 27,707 92,584 28,955
2025 2024 2023
Lampung 107,680 55,621 59,467
Agriculture, Hunting, and Forestry 17,647 17,777 12,700
Riau Islands 116,022 73,286 42,869
Fisheries 6 - -
Bangka Belitung 53,930 579,815 29,874
Mining and Quarrying - - -
DKI Jakarta 577,018 938,274 489,751
Manufacturing 28,131 47,499 27,809
West Java 1,149,051 404,100 748,559
Electricity, Gas, and Water 46,592 8,015 22,063
Central Java 397,037 31,866 275,130
Construction 3,915,168 2,833,438 2,465,069
D.I. Yogyakarta 52,947 678,309 38,428
Wholesale and Retail Trade 967,301 1,049,866 582,679
East Java 810,937 506,216 411,762
Accommodation and Food Services 29,444 44,881 30,175
Banten 537,959 55,715 360,785
Transportation, Warehousing, and Communication 92,027 24,418 32,381
Bali 67,543 39,345 49,555
Real Estate, Rental, and Business Services 179,524 153,945 85,942
West Nusa Tenggara 57,671 25,684 40,670
Education Services 750 700 1.500
East Nusa Tenggara 49,625 - 29,245
Health and Social Services 6,500 - -
North Kalimantan 22,656 23,469 9,225
Community, Social, Cultural, Entertainment, and
300,234 158,791 124,528 West Kalimantan 75,878 15,807 32,507
Personal Services
Activities Not Clearly Defined 83,952 65,532 45,864 Central Kalimantan 17,136 50,985 20,087
Total 5,667,275 4,404,263 3,431,071 South Kalimantan 127,483 47,053 77,177
East Kalimantan 58,977 5,085 47,323
North Sulawesi 64,185 26,020 30,546
KUMKM Credit Distribution by Province [FS6, FS7]
West Sulawesi 45,461 45,489 10,172
Total Distribution (Rp Million)
Province Central Sulawesi 88,279 157,894 37,041
2025 2024 2023
South Sulawesi 256,323 51,004 132,119
Aceh - 112,768 -
Southeast Sulawesi 100,002 21,580 53,022
North Sumatra 218,786 49,630 110,036
Gorontalo 41,833 27,606 12,967
West Sumatra 86,424 35,670 35,333
Maluku 15,659 6,912 913
Riau 130,355 91,963 36,113
North Maluku 58,346 13,627 15,206
Jambi 100,212 111,483 75,955
Papua 16,969 7,185 5,274
South Sumatra 137,184 22,218 85,007
Total 5,667,275 4,404,263 3,431,071
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People’s Business Credit (KUR)
Since 2017, BTN has supported government policy in strengthening capital for the real
KUR Distribution Portfolio
sector through the distribution of People’s Business Credit (KUR). This support is realized
(Million Rupiah)
by providing financing access to micro, small, and medium enterprises, particularly in
construction, housing, and related supporting sectors. Through KUR Micro and KUR Small,
financing is provided for both working capital and investment needs, helping strengthen
borrowers’ business capacity and create opportunities to increase productivity.
The KUR scheme is designed to reach bankable MSMEs that do not yet have access
to conventional financing, including those without additional collateral. Financing is
provided not only to individuals and small businesses but also to business entities and 2025 2024 2023
productive business groups that meet eligibility criteria.
1,073,762 1,799,621 1,807,673
To ensure optimal distribution, BTN implemented the following strategies during the
reporting year: *Excluding KPP Demand
1. Increasing high-yield loan distribution (Eagle Project)
• Direct KUR sales to mortgage (KPR) debtors and other consumer credit customers.
• KUR sales segmentation based on ecosystems or communities according to KUR Distribution (Bank) [FS8]
regional potential through BPI SME.
2025 Realization 2024 Realization 2023 Realization
2. Increasing awareness and engagement KUR BTN Credit Limit Credit Limit Credit Limit
• Conducting various socialization activities to introduce KUR products to MSME Debtors Debtors Debtors
(Rp Million) (Rp Million) (Rp Million)
actors. Mircro 369,106 6,429 543,593 9,067 249,906 3,965
Small 704,656 2,359 1,265,028 3,943 1,557,767 4,249
During 2025, BTN disbursed KUR Micro and KUR Small to 8,788 debtors with a total plafond
Total 1,073,762 8,788 1,799,621 13,010 1,807,673 8,214
of IDR1.07 trillion. The complete KUR distribution portfolio is presented below.
*Excluding KPP Demand
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KUR Distribution by Economic Sector [FS6, FS7] [SASB FN-CB-410a.1] Total Distribution
2025 2024 2023
Total Distribution Economic Sector
Credit Limit Credit Limit Credit Limit
2025 2024 2023 Debtors Debtors Debtors
Economic Sector (Rp Million) (Rp Million) (Rp Million)
Credit Limit Credit Limit Credit Limit
Debtors Debtors Debtors International
(Rp Million) (Rp Million) (Rp Million)
Organizations and
- - - - - -
Agriculture, Hunting, Other Extraterritorial
10,975 24 11,660 36 39,298 118
and Forestry Bodies
Fisheries 600 2 1,515 7 6,560 36 Personal Services for
- - - - - -
Households
Mining and Quarrying - - 830 5 - -
Activities Not Clearly
Manufacturing 26,441 196 27,443 207 37,124 204 29,160 313 72,456 622 81,284 402
Defined
Electricity, Gas, and
3,085 21 3,663 31 6,100 37 Total 1,073,762 8,788 1,779,621 13,010 1,807,673 8,214
Water
*Excluding KPP Demand
Construction 57,920 137 191.400 452 511.569 1.097
Wholesale and Retail
654,999 5,825 1,104,183 8,729 811,480 4,592
Trade
KPP Distribution by Province [FS6, FS7]
Accommodation and
153,586 1,238 199,297 1,574 147,147 926
Food Services Total Distribution
Transportation, 2025 2024 2023
Warehousing, and 11,840 68 20,354 77 17,862 64 Province
Communication Credit Limit Credit Limit Credit Limit
Debtors Debtors Debtors
(Rp Million) (Rp Million) (Rp Million)
Real Estate, Rental, and
15,756 59 24,010 102 30,976 123 Bali 46,117 353 45,550 350 26,200 141
Business Services
Financial Bangka Belitung 12,202 62 27,572 101 26,387 80
- - - - - -
Intermediation Services Banten 48,610 509 123,974 1,178 147,576 907
Education Services 3,310 21 5,360 36 4,750 26 Bengkulu 7,870 50 22,251 106 19,293 67
Health and Social D,I, Yogyakarta 33,272 233 49,264 323 31,116 176
14,240 60 - - - -
Services
DKI Jakarta 98,986 917 160,266 1,349 165,798 921
Community, Social,
Gorontalo 19,445 128 17,203 100 11,416 92
Cultural, Entertainment, 91,851 824 137,450 1,132 112,124 586
and Personal Services Jambi 11,808 77 40,730 127 53,880 114
West Java 176,646 1,819 337,849 3,021 422,064 1,879
Central Java 104,711 952 192,144 1,439 148,096 731
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Total Distribution Housing Program Loans (KPP)
2025 2024 2023
Province
Credit Limit Credit Limit Credit Limit Housing program loans (KPP) are financing facilities provided to support the sustainable
Debtors Debtors Debtors
(Rp Million) (Rp Million) (Rp Million) development of the housing sector by strengthening both the supply and demand sides
East Java 142,098 1,292 222,843 1,800 230,475 1,093 of housing. The program is intended for business actors within the housing ecosystem,
West Kalimantan 22,068 94 25,739 135 19,649 56 including developers and micro, small, and medium enterprises, to accelerate the
South Kalimantan 16,903 162 17,070 180 53,781 164 provision of adequate housing and promote inclusive economic activity.
Central Kalimantan 18,610 116 14,468 97 9,526 46
East Kalimantan 7,290 77 15,455 117 17,364 110 Through KPP, financing is provided in the form of working capital and investment loans
North Kalimantan 2,285 24 9,675 71 9,690 82
to support housing development, purchase, and renovation activities in accordance with
applicable provisions. The scheme is designed to strengthen the capacity of housing
Riau Islands 18,527 130 48,185 217 36,322 133
sector businesses, maintain the continuity of the housing supply chain, and contribute to
Lampung 17,789 106 20,332 124 17,775 110
sustainable economic and social value creation.
Maluku 10,195 48 12,848 71 13,023 78
North Maluku 3,015 20 12,050 79 12,610 85
In general, KPP covers the following:
Aceh - - - - - - • Financing on the housing supply side for developers and housing support businesses to
West Nusa Tenggara 14,641 137 20,495 216 16,180 78 support housing construction and procurement.
East Nusa Tenggara 18,925 171 14,587 133 8,796 42 • Financing on the housing demand side for MSMEs and business actors for the purchase,
Papua 5,780 72 8,965 93 16,212 121 construction, or renovation of housing that supports business activities.
Riau 16,601 92 33,470 169 63,280 130
West Sulawesi 18,175 54 20,975 67 14,066 52 KPP disbursement forms part of BTN’s efforts to expand access to housing finance,
South Sulawesi 44,284 256 83,899 380 40,980 217
support national housing programs, and strengthen the contribution of the housing
sector to inclusive and sustainable economic development. Details of KPP disbursement
Central Sulawesi 15,585 85 12,398 71 11,860 38
are presented in the following table.
Southeast Sulawesi 26,894 156 25,800 90 15,500 44
North Sulawesi 6,690 73 8,071 72 9,349 56
KPP Realization [FS6, FS7] [SASB FN-CB-410a.1]
West Sumatra 19,676 98 23,890 116 21,860 55
2025
South Sumatra 16,555 85 24,717 123 40,980 109 KPP BTN
Credit Limit (Rp Million) Debtors
North Sumatra 51,510 340 106,887 495 63,641 207
KPP Supply 2,389,138 749
Total 1,073,762 8,788 1,799,621 13,010 1,807,673 8,214
*Excluding KPP Demand
KPP Demand 262,742 1,097
Total 2,651,880 1,846
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KPP Realization by Province [FS7]
KPP Supply KPP Demand Total KPP Supply KPP Demand Total
Province Credit Limit Credit Limit Credit Limit Province Credit Limit Credit Limit Credit Limit
Debtors Debtors Debtors Debtors Debtors Debtors
(Rp Million) (Rp Million) (Rp Million) (Rp Million) (Rp Million) (Rp Million)
Bali 19,658 9 6,832 30 26,490 39 Lampung 52,061 17 4,957 23 57,019 40
Bangka Belitung 18,148 6 1,273 6 19,420 12 Maluku 1,450 1 960 3 2,410 4
Banten 159,268 47 21,030 91 180,298 138 North Maluku 13,411 4 2,370 11 15,781 15
Bengkulu 24,356 7 826 7 25,183 14 West Nusa Tenggara 47,958 17 1,412 7 49,369 24
DI Yogyakarta 14,498 4 3,719 15 18,217 19 East Nusa Tenggara 33,750 11 3,447 13 37,197 24
DKI Jakarta 188,564 51 27,814 86 216,378 137 Papua 5,500 2 136 1 5,636 3
Gorontalo 12,528 4 1,000 3 13,528 7 Riau 50,645 19 2,838 15 53,484 34
Jambi 47,141 16 1,198 9 48,339 25 West Sulawesi 28,232 11 118 1 28,350 12
West Java 519,822 154 73,526 268 593,348 422 South Sulawesi 107,890 36 6,991 27 114,881 63
Central Java 158,117 55 22,821 114 180,939 169 Central Sulawesi 34,335 10 1,500 3 35,835 13
East Java 343,306 100 47,894 235 391,200 335 Southeast Sulawesi 76,952 25 548 4 77,500 29
West Kalimantan 47,080 13 3,162 11 50,243 24 North Sulawesi 20,186 8 795 2 20,981 10
South Kalimantan 75,069 28 2,613 12 77,682 40 West Sumatra 39,739 16 2,180 8 41,919 24
Central Kalimantan 22,228 9 1,314 7 23,542 16 South Sumatra 57,710 17 1,836 12 59,546 29
East Kalimantan 19,390 6 6,205 21 25,595 27 North Sumatra 102,294 32 3,207 12 105,501 44
North Kalimantan 3,080 2 3,425 13 6,505 15 Total 2,389,138 749 262,742 1,097 2,651,880 1,846
Riau Islands 44,771 12 4,794 27 49,565 39
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Branchless Banking (balé Agent) [FS16] The Student Savings Program (SimPel) [FS16]
The expansion of access to formal financial services is implemented through the Laku The Student Savings Program (SimPel) is one of BTN’s key initiatives to expand financial
Pandai (Officeless Financial Services for Financial Inclusion) program initiated by the inclusion among the younger generation. Through a simple savings mechanism, free of
Financial Services Authority (OJK) and aligned with the National Strategy for Financial administrative fees, and easily accessible to students from elementary school to high
Inclusion (SNKI). This program targets communities that have not yet been reached by school levels are introduced to the importance of saving, money management, and
banking services, including remote areas and groups vulnerable to informal financing basic financial planning from an early age. The simplicity of the requirements allows
practices. more students to connect with formal financial services at a young age.
Through this scheme, BTN has established a network of agents as an extension of In 2025, the program reached more than 858,276 participants across various regions
banking services at the community level. The public can conduct basic transactions in Indonesia. The educational focus was directed toward digital financial training,
easily and close to their place of residence, including account opening, cash deposits enabling students to understand banking products and manage finances more wisely.
and withdrawals, bill payments, fund transfers, balance inquiries, mini statements, Collaboration with schools, educational institutions, and local communities expands the
PIN changes, and the purchase of financial products. This initiative not only expands program’s reach, including in areas with limited access to financial services.
financial inclusion but also enhances financial literacy and provides additional income
opportunities for individuals who join as agents. Financial education was also extended to the general public, particularly in remote areas,
to help communities use banking services more effectively. This increase in financial
The general requirements to become a balé Agent include the following: knowledge is expected to encourage the use of a wider range of banking products while
1. Registration is conducted through the nearest Branch Office or Sub-Branch Office. supporting local economic empowerment.
2. Prospective agents must be BTN customers with an active savings account used to
accommodate deposits, commissions, and transaction fees. Proportion of Account Ownership [SASB FN-CB-240a, FN-CB-240a.3]
3. Have a business that has been operating for at least one year.
Description 2025 2024 2023
4. Possess a valid business license, at a minimum a certificate from the local
Total Account
neighborhood authority (RT).
5. Not be listed on Bank Indonesia’s National Blacklist. Total savings product accounts 7,045,749 6,139,468 7,099,737
6. Successfully pass the Bank’s due diligence process. SimPel Accounts
Total accounts 850,879 824,069 795,592
Percentage of total accounts 12.18% 13.42% 11.00%
As of 2025, there are
6,300
The 4.15% increase compared with the previous year was driven by the strengthening of
financial education and literacy programs, as well as collaboration with schools, which
supports one of BTN’s strategies to increase low cost funding.
balé Agents distributed across Indonesia.
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Housing Finance Center (HFC) [FS16]
Mission
Vision
To provide excellent,
To become a leading innovative, and
center for research, integrated services in
The large number of households in Indonesia that still do not own homes indicates education, and research, education, and
that the housing sector continues to have significant potential for sustainable growth, consultation in housing consultation on housing
supported by the increasing number of new families and facilitation of homeownership. finance finance for clients
HFC leverages this opportunity to support the growth of the housing sector in Indonesia.
HFC was established on October 16, 2014, with the following vision and mission.
HFC Functions
Through HFC, the commitment to supporting housing supply and fostering new developers
in the housing sector is strengthened. This role is carried out through three main functions
Learning The Indonesian housing finance education center through
that serve as the pillars of HFC’s business:
various education and training programs.
Advisory The Indonesian property and housing finance consultation
center to assist stakeholders (communities, developers,
and government) in decision-making.
Research The Indonesian housing finance information and innovation
center through various scientific studies related to markets,
business actors, and housing industry trends.
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From these three main activities, several derivative programs have been developed, including:
Main HFC Activities
Function: Mini MBA in Property The Mini MBA in Property program is a collaboration between HFC and SBM-ITB and is regularly conducted to develop new entrepreneurs in the property
Learning industry. Since 2016, this program has been implemented on a continuous basis. In 2025, the program was conducted in three batches, namely Batch 23,
Batch 24, and the Makassar (in-house) batch. Through this program, more than 800 graduates have been produced.
Literacy Seminars / Public HFC actively organizes seminars, public lectures, workshops, and talkshows in collaboration with various institutions, universities, and associations to
Lectures / Workshops / Talkshows enhance audience understanding of the property business, banking digitalization, and other relevant topics. In 2025, the following activities were conducted:
1. Indonesia Property Outlook 2025 in the Midst of National Economic Slowdown.
2. Public Lecture and Talkshow at Universitas Negeri Malang titled “Unlocking Business Opportunities Amidst Global Economic Shifts and Digital
Transformation”.
3. Public Lectures at Universitas Udayana and Univeristas Diponegoro titled “Green Financing in the Digital Era for a Sustainable Economy.”
4. Scientific Oration at Universitas Negeri Padang titled “Green Financing in the Digital Era for a Sustainable Economy.”
Function: Advisory Clinic The Advisory Clinic is a program designed to enable participants and alumni of HFC Learning Programs to engage in more intensive discussions or
Advisory consultations with instructors to deepen their understanding of the materials taught during class training. The Advisory Clinic conducted in 2025 was titled
“Understanding Housing Consumer Behavior to Increase Sales.”
Function: BTN HPI (House Price Index) The BTN House Price Index presents data on changes in housing prices at the national, regional, provincial, and district/city levels, based on mortgage
Research realizations with similar quality and characteristics, including non-subsidized mortgages. The index covers various housing types (21–36, 37–45, and
46–70) as well as a number of districts/cities. Data are published quarterly, with monthly calculations using the matched sales method.
National Economic Forum HFC research results are published through annual national scientific forums, including those organized by Bank Indonesia, OJK, ISEI, and Perbanas, in
Publications accordance with the themes of each event.
Implemented Research Research and studies conducted by HFC in 2025 include: 9. Housing Finance Schemes
1. Economic and Housing Update 2025 10. Feasibility Study on the Establishment of the BTN Research
2. House Price Index Study FY2024 Institute
3. Preliminary Study on the Establishment of Danantara 11. BTN Deposit Market Share
4. Preliminary Study on the Establishment of the BTN Research Institute 12. BTN Mortgage Market Share
5. Study on the Impact of the Three Million Houses Program on the Economy 13. Study on Redesigning Housing Finance Schemes
and Employment Absorption 14. Study on Factors Behind the Decline in Non-Subsidized
6. Study on Trump Tariffs Mortgage Market Share
7. Discussion on Developments and Outlook of Household Consumption, 15. Study on Reducing Cost of Funds (CoF) for Deposits
Investment, and Consumer Credit 2025–2026 16. BTN Research Institute FS with ITB
8. Regional Potential Study 17. Industry Outlook 2026
18. Informal Sector Study
Research Fellowship HFC collaborates with researchers, academics, and practitioners from universities and research institutions for knowledge transfer, with the aim of
enhancing the competence, capacity, and capability of HFC researchers in research related to economic development and BTN business development.
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Other Financial Literacy Programs [FS16]
BTN strengthens financial literacy through partnerships with financial education
organizations, as well as collaboration with educational institutions, government
agencies, and local communities, with initiatives specifically designed to reach specific
demographic groups. Various training sessions and socialization activities are conducted
to expand public understanding of financial management, particularly in relation to
banking and housing finance.
One of the main initiatives is a financial inclusion program targeting university students
and campus communities. Through collaboration with higher education institutions,
participants gain a basic understanding of personal financial management, financial
planning, and the importance of access to banking services. This program also reaches
unbanked communities to improve access to formal financial services.
Education on banking products, including payroll services, is also expanded through
socialization activities to various government institutions. This approach helps
communities understand the benefits of banking services while encouraging more
prudent use of financial products.
Through these initiatives, BTN seeks to accelerate financial inclusion and strengthen
community economic empowerment. This program is expected to foster financial
literacy from an early age and encourage the younger generation to play an active role
in sustainable economic development.
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06
Driving Innovation in
Financial Products and
Digitalization
142 BTN Service Roadmap
145 Environmental and Social Risk
Management in the Credit Process
148 BTN Portfolio Guideline
155 ESG-Based Products
163 Digital Innovation for Modern
Services
172 Financial Product Oversight
173 Advertising Policy
174 Customer Financial Protection
175 Customer Data Privacy and
Security
185 Debt Collection Policy
187 Handling of Financial Product
Complaints
190 Customer Satisfaction
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As a financial intermediary, BTN bears indirect responsibility for the environmental and social
impacts arising from its debtors’ activities, as inadequate management can increase credit
risk and affect the Bank’s reputation. Therefore, the management of environmental and social
aspects forms an integral part of banking risk management.
BTN Service Roadmap
As part of a commitment to realizing its vision as “the leading partner in empowering
BTN
To deliver a reliable, uniquely differentiated, convenient
Indonesian families financially” and its mission to “deliver the best customer experience Service
service beyond customer expectations
through integrated digital and financial services,” BTN has formulated a Service Vision Vision
supported by 19 key initiatives which serves as a strategic guide for service development
ands the foundation for the BTN Service Roadmap 2023–2025.
The roadmap was developed based on an initial survey to capture the Voice of Customer
1. To cultivate an integrated service culture across the organization
(VoC) through the measurement of the Customer Experience Index (CEI). Approved by
by adopting a solution-centric approach to achieve service
the Board of Directors and disseminated to Senior Executive Vice Presidents (SEVPs), excellence.
relevant division heads (product and channel owners), as well as Regional Office Heads 2. To establish consistent service standards across all service
1 and 2 through a forum organized by the Customer Experience Division in collaboration BTN channels and customer touchpoints, ensuring a seamless and
with external consultants, the BTN Service Mission was also agreed upon as a further Service exceptional experience at every interaction.
articulation of the Service Vision, and Service Values were established. Mission 3. To become a trusted financial partner and housing advisor
by delivering distinctive services grounded in organizational
authenticity.
4. To provide the best service experience by focusing on customer
expectations and serving customers as we would our own family,
with genuine warmth and care.
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BTN Service Values
Reliable Uniquely Differentiated Convenient Services
F A M I L Y
Fostering Assurance Meaningful Inspire Light-hearted Yearning
Approach to building A commitment to Delivering meaningful, The ability to inspire The sincerity and generosity Strong internal ambition
relationships and delivering consistently provide personalized, and impactful beyond financial solutions, of BTN personnel in creating and motivation to deliver
service comfort aligned certainty, security, and trust services, interactions, and while also serving as comfort throughout the superior service standards
Meaning
with the family concept. to all customers. experiences aligned with a positive catalyst for customer’s financial journey and consistently exceed
customers’ needs and improvement and progress through genuine, warm, and customer expectations.
aspirations. across the broader banking heartfelt service.
ecosystem.
Fostering Long-term Assuring Reliable Meaningful Inspiration for Achieving the Light-hearted Yearn for
Value Dimensions
Relationship Support Personalization Dream Atmosphere Excellence
Fostering Incremental Assuring Solution-Centric Meaningful Inspiration for Light-hearted Yearn for Customer
Service Excellence Services Experience Your Home Assistance Satisfaction
Fostering Digital Assuring Ethical Meaningful Inspiration for Light-hearted Yearn for
Transformation Practices Long-term Impact Excellence Approach Integration
BTN has established FAMILY as its Service Values framework, reflecting services that are In alignment with the Service Blueprint, service enhancement focuses on the three key
reliable (Fostering and Assurance), uniquely differentiated (Meaningful and Inspire), and dimensions—people, process, and physical evidence—as the new standard across
convenient (Light-hearted and Yearning), with an approach that engages customers as all service channels. This is the foundation for the implementation of the BTN Service
valued members of the BTN family. To support the Service Mission and drive customer Roadmap 2023–2025, structured as follows:
acquisition and loyalty, Solution-Centric is now a core value by providing basic advisory
services for new customers and advanced advisory services for existing and churning
customers.
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BTN Service Quick Win Mid-Term Long-Term
1. 2. 3.
Roadmap 2023–2025
• Solution-Centric Response Mechanism • Service Competency Enhancement Program (S-CEP) • Hackathon
Implementation Plan
• Service-focused Squad • BTN Mobile Advancement • BTN Heritage
• FinEase Acceleration • CRM Empowerment
• BTN Care • BTN Housing & Mortgage Advisory
Referring to the Service Program Prioritization discussed and agreed upon within the primary entry point and a key touchpoint that shapes the overall customer
BTN Service Roadmap 2023–2025, four Quick Win Service Programs have continuously experience. In line with efforts to improve customer satisfaction, BTN refined its
implemented service quality improvement strategies since 2023. The following strategies lending service process, particularly at the loan agreement execution stage,
and programs achieve these objectives: through the following initiatives:
1. FinEase Acceleration • Setting maximum time limits and standard durations for loan agreement
The FinEase (Finish-Ease) Acceleration program focuses on improving service execution.
quality at the first point of customer interaction with BTN, particularly the account • Digitising the delivery of information during the agreement stage to ensure
opening process and the execution of consumer loan agreements, to deliver a better prospective borrowers understand their rights and obligations as BTN
customer experience. As part of the implementation, BTN has enhanced several entry borrowers.
points, including: • Improving comfort during the agreement process by setting layout
a. FinEase Acceleration: Account Opening arrangements and minimum standards for supporting facilities at the
Service enhancements focused on accelerating the account opening process agreement venue.
for walk-in customers at each outlet, in line with established Service Level 2. Solution-Centric Response Mechanism
Agreements (SLAs). These improvements were implemented through the Service improvement strategies for handling customer complaints, including both
following measures: soft and hard complaints, have been standardised across all BTN outlets through the
• Refining the account opening service flow. following measures:
• Optimising the layout and placement of bank staff to support process a. Establishing Standard Operating Procedures (SOPs) and providing supporting
efficiency. infrastructure to enable bank staff to resolve customer complaints.
• Digitising the account opening process. b. Conducting training for all frontliners on handling customer complaints at BTN
• Strengthening the competency and capacity of service staff, including the use outlets.
of an effective and efficient account opening script. 3. Service-focused Squad
b. FinEase Acceleration: Consumer Loan Agreement BTN has established a service organisation to ensure consistent implementation of
As BTN’s core business, mortgage services (KPR) often serve as the public’s service standards while fostering a learning culture and environment. In line with
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the Service Roadmap, BTN assigned additional service staff at each branch office in infrastructure. The program also supports a family-friendly service environment by
the form of Duty Officers to support fast service delivery. Duty Officers help improve providing rooms and facilities that enhance customer comfort during transactions.
branch operational efficiency, accelerate service processes, and ensure a smooth BTN Care facilities include:
customer experience when conducting transactions and receiving services at a. Accessibility facilities for persons with disabilities, such as wheelchair ramps or
branch offices. pathways, handrails, dedicated seating, and accessible toilets.
4. BTN Care b. Lactation room for breastfeeding mothers.
BTN Care is an initiative to meet regulatory requirements while strengthening service c. Kids’ Corner for children while parents or family members wait for service or
access for customers with special needs, including those with disabilities, the elderly, transactions at BTN branches.
pregnant women, and breastfeeding mothers, by improving branch facilities and
Environmental and Social Risk Management in the Credit Process [GRI 2-25] [SASB FN-CB-410A.2]
In its funding and lending processes, BTN consistently applies an environmental and social In practice, each Business Unit conducts assessments based on industry sector research,
(ESG) risk management system across all financing activities and credit portfolios as ESG risk analysis, and studies of sector risks and potential in line with the BTN Portfolio
part of its implementation of sustainable finance principles. This practice is aligned with Guideline, including for sectors with higher ESG risk. The assessment results form the basis
OJK Regulation No. 40/POJK.03/2019 on the Assessment of Asset Quality for Commercial for the pre-approval process using credit risk tools that incorporate environmental and
Banks, which requires a borrower’s business prospects assessment to consider efforts to social factors. ESRM is then applied throughout the credit cycle, including credit analysis,
maintain environmental sustainability. legal and compliance review, credit approval, and post-disbursement monitoring, to
ensure consistent risk control across the loan lifecycle.
In line with the growth focus of its commercial loan portfolio, environmental and social
aspects are integrated into the credit process through an Environmental and Social Risk As part of the legal and compliance review, BTN’s General Policy No. KU.1 on Lending or
Management (ESRM) framework applied end-to-end and coordinated by the Business Financing sets out project legality requirements, including: [FS1, FS2, FS9]
Unit, the Credit Operation Division/Unit, and the Wholesale Credit Risk Division/Unit. BTN 1. Land use permit;
also defines risk appetite and industry appetite that incorporate environmental and 2. Site plan approved by the duly authorized party;
social considerations, as set out in the Risk Acceptance Criteria (RAC) technical guidelines 3. Building construction permit;
within the BTN Portfolio Guideline, in accordance with Technical Guideline No. PT.8-H.3. [FS1] 4. Proof of ownership or control;
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5. Copy of the Land and Building Tax Due Notification Letter (SPPT); environmental impacts arising from a proposed business and/or activity, covering
6. Proof of right of access (access road); abiotic, biotic, and socio-cultural aspects, and is prepared during the project planning
7. Flood elevation certificate; stage. The implementation of AMDAL refers to Government Regulation No. 27 of 2012 on
8. Water utility (PDAM) statement; and Environmental Permits. In addition, BTN conducts monitoring and on-site verification
9. Environmental feasibility certificate or Environmental Management Efforts (UKL-UPL) to ensure prospective borrowers comply with applicable environmental requirements.
and/or Environmental Impact Assessment (AMDAL). This covers the completion of environmental and social documents in line with internal
policies, and is carried out both before and after loan signing, at least once every three
BTN incorporates the results of the Environmental Impact Assessment (AMDAL) are months. This approach forms part of the prudential principles applied in credit risk
incorporated into credit risk assessment prior to making financing decisions for management. [FS1, FS2, FS3, FS5, FS9]
a project. AMDAL is a licensing requirement that contains an analysis of potential
Integration of ESG Considerations into the Credit Process
Pre-screening Legal and Compliance Review Credit Approval Credit Operation Division
1. 3. 5. 7.
Business Unit and Wholesale Legal and Compliance Authorised Officer Credit Operation Division
Credit Risk Division
Credit Analysis Credit Committee Meeting Credit Documentation Credit Monitoring
2. 4. 6. 8.
Business Unit and Wholesale Business Unit and Wholesale Business Unit, Wholesale Business Unit, Wholesale
Credit Risk Division Credit Risk Division Credit Risk Division, and Credit Credit Risk Division, and Credit
Operation Division Operation Division
To clarify the involvement of each unit and the key control points at every stage, the following outlines the loan disbursement process and the roles of the relevant units, from pre-
screening through to monitoring.
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ESG Integration Across the Credit Cycle and Credit Risk Assessment
1.
BTN integrates ESG considerations throughout the credit cycle, from application to monitoring, through a comprehensive risk assessment framework. The Bank also
identifies eligible financing and projects in line with regulations and global standards.
Standards-Based ESG Assessment and Climate Risk
BTN strengthens its assessment of sectors with higher ESG exposure to ensure alignment with its sustainability policies, including:
a. Policy Compliance
The Bank refers to sustainability standards and guidance such as OJK’s Climate Risk Stress Test guidance, MSCI ESG Industry Risk, and OJK Regulation (POJK) No.
51/POJK.04/2017, and incorporates ESG criteria into its compliance checklist.
b. Sector-Based ESG Risk Assessment
2.
A sector-based ESG scoring system for sectors with higher risk to environmental risk, such as energy, agriculture, and oil and gas, including the application of
Enhanced Due Diligence (EDD) to ensure compliance.
c. Climate Impact and Risk Analysis
BTN assesses the impact of climate change on its portfolio by combining Scope 3 financed emissions calculations, physical and transition risk analysis, and a
comprehensive climate risk stress test. The results inform business units, the risk management, and the Board of Directors in developing mitigation and adaptation
strategies for climate-related risks.
Governance and Oversight
3.
The Risk Management Committee overseas ESG commitments, with senior management from Risk, Business, and Compliance to ensure financing decisions are
managed transparently and accountably while considering environmental, social, and climate-related risks.
Transparent Disclosure of ESG Financing
4.
BTN enhances transparency by disclosing ESG financing data in its annual sustainability report, in line with applicable regulations and recognized best practice
disclosure standards.
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BTN Portfolio Guideline
In responding to economic growth dynamics and the direction of monetary policy,
The Porfolio Guideline aims to:
credit risk management is strengthened to safeguard financial stability and business
sustainability. For this purpose, the Portfolio Guideline as a strategic instrument to
Objectives of the Portfolio Guideline Manage concentration risk
manage credit concentration risk through measured portfolio diversification. through measured portfolio
Priority Industry Sector Allocation Limits diversification aligned with the
The Portfolio Guideline maintains asset quality by prioritizing credit allocation to sectors results of priority sector research,
Restrictive Industry Sub-Sectors
ESG risk assessment, and sectoral
with sustainable growth prospects,. supporting business growth while also contributing to
risk analysis.
the mitigation of ESG risks. The Portfolio Guideline plays a critical role in balancing credit 1 2
expansion and risk control in accordance with BTN’s sustainability principles. Priority Encourage diversified and high-
Industry ESG Risk
5 quality credit growth.
Sector Analysis
Research Risk Acceptance Provide guidance on priority
Criteria (RAC) sectors for credit growth.
4 3
Business Industry
Regulate governance and
Potential Sector Risk
technical guidance in managing
(Pipeline) Analysis
risk limits and priority sectors.
Tata Kelola dan Petunjuk Teknis Portfolio Guideline
Portfolio Guideline Implementation Mechanism Priority sectors include:
a. Environmentally friendly e. Wholesale and retail trade;
Priority Industry Sector Research transportation and public f. Construction;
transportation, warehousing, and g. Real estate, rental businesses, and
To support of ESG principles in financing, the Portfolio Guideline in accordance with communications; corporate services;
Technical Guideline No. PT.8-H.3 is a tool to control credit concentration risk. This directs b. Financial intermediation; h. Agribusiness; and
lending toward specific industry sectors by integrating ESG considerations, prudential c. Health services and social activities; i. New and renewable energy.
principles, and sound credit management, thereby ensuring alignment with ESG aspects. d. Education services;
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ESG Risk Analysis Risk Acceptance Criteria (RAC)
Portfolio screening based on ESG risk analysis referring to regulations and best practices, To strengthen prudential principles and inherent risk management in priority industries,
including the OJK Climate Risk Stress Test Guidelines, MSCI ESG Industry Risk, and OJK Risk Acceptance Criteria (RAC) evaluate prospective debtors, with General RAC minimum
Regulation (POJK) No. 51/POJK.04/2017. The analysis is summarized in the Portfolio Guideline criteria applicable to all sectors and Specific RAC: criteria tailored to the characteristics
Composite Rating Matrix, which maps industry sectors based on business prospects and of each business sector. Both RAC types cover debtor, technical, and financial aspects,
ESG risks and impacts, including emissions intensity, social impact, governance quality, and include sector-specific provisions as guidance for BTN’s wholesale marketing and
and other relevant factors. Sectors under particular attention include: [FS5] [FS10] lending activities.
a. Transportation, warehousing, and communications;
b. Mining and quarrying; Credit Policy for High ESG Risk Sectors
c. Electricity, gas, and water;
d. Agribusiness; BTN’s commitment to sustainable finance is reflected through the establishment of
e. Manufacturing; and Portfolio Guideline Terms & Conditions as an instrument for managing credit risks
f. Construction. related to ESG. These provisions ensure that lending is conducted selectively, particularly
for priority sectors with high ESG risk, based on ESG risk analysis results, through clear
Industry Sector Risk and Potential Analysis standards for identifying, evaluating, and limiting exposure to sectors with potentially
significant negative environmental and social impacts.
BTN further assesses the risks and opportunities of each industry sector to maintain a
healthy and sustainable credit portfolio. Credit allocation is determined based on internal The Bank continues to establish specific terms and conditions for both sectors as part of
data, national banking data, and indicators such as Non-Performing Loan (NPL) ratio, its commitment to ESG-based credit risk management. The provisions for sectors with
credit yield, and contribution to the Corporate Work Plan and Budget (RKAP) targets. This high ESG risk are as follows:
analysis also considers ESG aspects across sectors and subsectors with strong business
potential, enabling risks to be managed in alignment with sustainability principles.
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Agriculture (Agriculture, Forestry, and Fisheries)
The Bank applies binding credit policies for debtors in this sector c. Have Standard Operating Procedures (SOPs) for land
to ensure that they: fire prevention and response, appropriate firefighting
1. Hold a PROPER Gold or Green rating. equipment in accordance with land characteristics, fire
2. Are not new companies opening new land areas. monitoring towers, and a dedicated, trained fire response
3. Have a Waste Treatment Facility (IPL) with studies confirming team in line with the standards of the Directorate General
operational availability and compliance with water quality of Plantations.
standards. d. Hold valid Plantation Business Licenses (IUP) in
4. For public companies, publish a Sustainability Report. accordance with the Location Permit, including
5. Commit to No Deforestation, No Peat, No Exploitation (NDPE), Cultivation License (IUP-B), Processing License (IUP-P),
including land clearing, protection of High Conservation and Plantation Business Registration Certificate (SPUP).
Value (HCV), High Carbon Stock (HCS) areas, and peatlands. 8. No significant social or environmental disputes within the
6. For palm oil plantation subsector, possess Indonesian past three (3) years.
Sustainable Palm Oil (ISPO) and/or Roundtable on 9. For the SME segment, ISPO compliance is applied as
Sustainable Palm Oil (RSPO) certification, or at minimum an affirmative covenant, monitored periodically by the
proof of registration. Relationship Manager and subject to periodic internal audit.
7. For palm oil plantation companies that do not yet hold ISPO 10. Hold valid permits for industrial plantation forest
and/or RSPO certification, the following criteria apply: management, including Timber Forest Product Utilization
a. Possess a Code of Conduct and Environmental and License (IUPHHK) and/or Non-Timber Forest Product Utilization
Labor Policies (including Occupational Health and License (IUPHHBK), as well as an approved Business Work Plan
Safety/OHS). (RKU) from the Ministry of Environment and Forestry (KLHK).
b. Hold Environmental Management certification such 11. Do not conduct business activities in areas identified as
as ISO 14001/ISO 45001 or equivalent documentation having high biodiversity value.
acceptable to the Bank.
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Energy
The Bank applies binding credit policies for debtors in this sector 4. Operating power plants hold ISO 14001/ISO 45001 or equivalent
to ensure that they: documentation acceptable to the Bank.
1. Financing is limited to companies with strong ESG 5. Operating power plants have a code of conduct and policies
implementation. related to the environment (carbon emissions, coal ash,
2. Companies hold a PROPER rating and/or at minimum an water and waste management) and labor.
approved Environmental Impact Assessment (AMDAL) or 6. No significant social or environmental disputes.
Environmental Management and Monitoring Efforts (UKL–
UPL).
3. For financing of new coal-fired power plants (PLTU) with PLN
as the offtaker, the financing tenor has considered alignment
with the coal phase-out strategy under the applicable PLN
Electricity Supply Business Plan (RUPTL).
Coal*
The Bank applies binding credit policies for debtors in this sector 4. For coal mining financed as a supplier to PLTU, the financing
to ensure that they: tenor considers alignment with the coal phase-out strategy
1. Financing is limited to top-tier corporates with strong ESG under the applicable PLN RUPTL.
implementation. 5. Have a roadmap for GHG emissions reduction.
2. Companies hold at least a PROPER Green rating and/or 6. Debtors agree to comply with loan agreement clauses
approved AMDAL or UKL-UPL (including reclamation and requiring adherence to all applicable environmental
post-mining guarantees). regulations and documentation; failure to comply may affect
3. Hold ISO 14001/ISO 45001 or equivalent documentation loan continuity.
acceptable to the Bank.
*For reference only. The Bank currently has no exposure to this sector.
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Mining*
The Bank applies binding credit policies for debtors in this sector 4. Implement Good Mining Practice in accordance with
to ensure that they: applicable laws and regulations, supported by an approved
1. Financing is limited to corporate debtors with strong ESG Annual Work Plan and Budget (RKAB) issued by the Ministry of
implementation. Energy and Mineral Resources (ESDM), and/or other relevant
2. Hold at least a PROPER Green rating and/or approved supporting documents.
AMDAL or UKL-UPL (including reclamation and post-mining 5. Maintain internal policies (code of conduct) related to
guarantees) issued by the Environmental Agency (BLH). environmental management and labor practices.
3. Hold Environmental Management certifications such as ISO
14001/ISO 45001 or equivalent documentation acceptable to *For reference only. The Bank currently has no exposure to this sector.
the Bank.
Construction
The Bank applies binding credit policies for debtors in this sector to ensure that they:
1. Hold an approved AMDAL report.
2. Have no significant social or environmental disputes within the past four (4) years that could affect business continuity.
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Oil and Gas
The Bank applies binding credit policies for debtors in this sector greenhouse gas (GHG) emissions, in accordance with
to ensure that they: regulatory requirements at the operating location. For public
1. Financing is limited to corporate debtors with strong ESG companies, a Sustainability Report or equivalent document
implementation. is required.
2. Hold Environmental Management certifications such as ISO 5. Maintain documentation confirming compliance with Oil
14001/ISO 45001 or equivalent documentation acceptable to and Gas Safety requirements (covering installations and
the Bank. equipment, workers, public safety, and environmental
3. Hold approved AMDAL or UKL-UPL (including reclamation and protection); for supporting service providers, this must be
post-operation guarantees) issued by the Environmental evidenced by a valid Supporting Business Certificate (SKUP).
Agency (BLH). 6. Have no deforestation practices, including land clearing, and
4. Demonstrate efforts to improve energy efficiency and reduce no exploitation.
Transportation
The Bank applies binding credit policies for debtors in this sector to ensure that they:
1. Hold Environmental Management certifications such as ISO 14001/ISO 45001 or equivalent documentation acceptable to the Bank.
2. For public companies, publish a Sustainability Report.
3. Demonstrate efforts to improve energy efficiency and reduce emissions, and ensure adequate availability of electricity and water
resources.
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Pulp & Paper
The Bank applies binding credit policies for debtors in this sector
4. Demonstrate efforts to improve energy efficiency and reduce
to ensure that they:
emissions, and ensure adequate availability of electricity
1. Hold Environmental Management certifications such as ISO and water resources.
14001/ISO 45001 or equivalent documentation acceptable to 5. Have adequate wastewater treatment facilities (IPAL/
the Bank. IPL/IPLC) and hazardous waste (B3) treatment facilities,
2. Hold at least a PROPER Blue rating and/or approved AMDAL supported by documentation acceptable to the Bank.
or UKL-UPL (including reclamation and post-operation 6. Hold valid industrial forestry management permits (IUPHHK
guarantees) issued by the Environmental Agency (BLH). and/or IUPHHBK) and an approved Business Work Plan (RKU)
3. For public companies, publish a Sustainability Report. from the Ministry of Environment and Forestry (KLHK).
Biodiversity
The Bank applies binding credit policies for debtors in this activity categories to ensure that they:
1. Hold valid industrial forestry management permits, including IUPHHK and/or IUPHHBK, as well as an approved Business Work Plan
(RKU) issued by the Ministry of Environment and Forestry (KLHK).
2. Do not conduct business activities in areas with high biodiversity value, including Ramsar Convention sites and locations classified
as IUCN Category 1 and 2.
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ESG-Based Products
Evolving stakeholder expectations regarding sustainable financing have driven BTN to Bank’s significant business linked in sustainability-oriented financial products, supported
integrate ESG principles into all investment decisions and transactions. This is intended to by evidence of best-in-class product innovation. BTN has developed a range of ESG and
safeguard financial performance while strengthening positive social and environmental sustainable financing product and service innovations, including: [OJK B.1]
impact across the Bank’s operational areas. This commitment is also reflected in the
BTN ESG-Based Products
Sustainable Business
Sustainability-Linked Subsidized Mortgage Green Initiative
Sustainability Bond ESG Mutual Fund Activity Category Loans
Loan (SLL) (KPR Subsidi) Programs
(KKUB)
A financing instrument for A collective investment Financing classified under A credit scheme that links Subsidized housing A series of green economy
environmentally friendly instrument that allocates sustainable business pricing incentives and finance for low-income initiatives integrated
and low-emission projects, funds to a portfolio of activity categories fees to the borrower’s communities (MBR) with with BTN products and
supporting the low-carbon issuers with strong ESG in accordance with achievement of affordable interest rates services, encouraging
economic transition and practices and accountable POJK 51/2017, covering sustainability KPIs and and schemes, expanding customer participation
national climate targets, governance. The product environmentally oriented targets, encouraging financial inclusion and promoting
supported by strict ESG aims to generate business activities (KUBL) improved ESG performance and promoting more sustainable financing and
standards and transparent sustainable financial and socially oriented and measurable sustainable housing, environmental action.
impact reporting. performance while business activities (KUBS). contributions to the SDGs including energy-efficient
delivering long-term social and the low-carbon and green building-based
and environmental impact. economy. homes.
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Sustainability Bond
BTN’s ESG-based Green/Social/Sustainability Bond portfolio, consists of bonds issued to Berwawasan Sosial Tahap I was intended to finance and/or refinance eligible social
finance projects that support environmental sustainability through the integration of ESG projects, with a focus on affordable housing for low-income communities (MBR),
principles. It instrument emphasizes environmental aspects such as carbon emission MSME/KUR financing to support job creation, and the development of affordable basic
reduction and renewable energy development, while also considering social impacts, infrastructure such as access to clean water.
including community empowerment and job creation, and requiring strong governance
and transparency. Projects financed must comply with strict ESG standards and are To ensure accountability in the use of proceeds, the project evaluation and selection
subject to transparent reporting on both the use of proceeds and impact. process is conducted through a cross-functional Sustainable Finance Working Group,
supported by earmarking mechanisms and recording in the Sustainable Finance Register.
In line with the strengthening of its sustainable finance offerings, a Sustainable Finance BTN is also committed to publishing annual allocation and impact reports, including key
Framework is a reference for the issuance of environmental and social instruments. The social indicators such as the number of homes built, MSMEs financed, jobs created, and
framework covers the use of proceeds, project evaluation and selection, management of improved access to clean water.
proceeds, and reporting, and received an “Excellent” rating under a Second Party Opinion
(SPO) by Sustainable Fitch, confirming its alignment with the International Capital Market In addition, BTN has increased its exposure to sustainable finance instruments through
Association (ICMA) standards. holdings of ESG-based sustainability bonds purchased and held by the Bank. As of 2025,
the value of the sustainability bonds portfolio amounted to Rp1.19 trillion. Details of the
Under this framework, in 2025 BTN issued two of green/social/sustainability bond, ESG-oriented bonds issued and held by Bank Tabungan Negara are presented in the
namely Obligasi Subordinasi Berkelanjutan I Bank BTN Tahap I Tahun 2025 and Obligasi following table. [OJK. F.3]
Berwawasan Sosial Tahap I, with a total issuance value of Rp2.29 trillion. The Obligasi
Value of Green/Social/Sustainability Bond Issued by BTN [OJK. F.3]
Actual Amount Raised from Planned Use of Proceeds Actual Use of Proceeds
Bond Type Unit
Public Offering (per Prospectus) (per Prospectus)
Sustainable Subordinated Bond I of BTN, Tranche I, 2025 Rp Billion 1,992.09 1,992.09 1,992.09
Social Sustainability Bond I of BTN, Tranche I, 2025 Rp Billion 294.81 294.81 294.81
Total Rp Billion 2,286.90 2,286.90 2,286.90
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Nominal Value of BTN’s Green/Social/Sustainability Bond Portfolio [OJK. F.3]
Instrument Series Unit Nominal Value
SBSN Series PBSG001 & PBSG002 Rp Billion 1,003.68
SUKBI110326091MSINR4C87435 Rp Billion 114.85
SMF Sustainability Bond VI, Tranche II, 2021 Rp Billion 25.00
SMF Sustainability Bond VI, Tranche I, 2021 Rp Billion 25.00
Bank Mandiri Sustainability Bond I, Tranche I, 2025, Series B (BMRI01BSLCN1) Rp Billion 25.00
Total Rp Billion 1,193.53
ESG Mutual Funds
As a Selling Agent for Mutual Fund Securities (APERD), BTN has a partnership with Batavia Through these products, BTN facilitates investors in achieving financial benefits while
Prosperindo Aset Manajemen, one of Indonesia’s leading investment managers, to supporting the SDGs by selecting instruments that consider long-term environmental
distribute ESG-based mutual fund products. This collaboration expands investment and social impacts. BTN ensures that this partnership strengthens sustainable finance
options that combine potential financial returns with contributions to the sustainability literacy among domestic investors, in line with the Bank’s commitment to continuously
agenda. The flagship products distributed includeBatavia Global ESG Sharia Equity USD expand its ESG-based mutual fund offerings. To support transparency and performance
Sharia Mutual Fund, Mandiri FTSE Indonesia ESG Index Fund Class A, and Batavia ESG monitoring, the targets and realization of product development and distribution are
Impact Equity Fund. These mutual funds integrate ESG principles into their investment presented in the following table.
portfolios and comply with Sharia principles, with a focus on equity instruments issued by
companies demonstrating strong performance in environmental management, social
responsibility, and transparent, accountable governance.
Assets Under Management in ESG Mutual Funds [OJK. F.3]
Mutual Fund Name 2025 2024 2023
Mandiri FTSE Indonesia ESG Index Fund Class A* 1,005,131,593 6,491,141,068 2,794,377,318
Batavia Global ESG Sharia Equity USD Sharia Mutual Fund* 1,949,012,969 947,622,137 282,042,597
Batavia ESG Impact Equity Fund - - 1,120,201
Total AUM ESG 2,954,144,562 7,438,763,205 3,077,540,116
Note:
*) Figures have been converted into Rupiah.
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Sustainable Business Activity Category Loans (KKUB)
BTN’s ESG Roadmap is reflected in the distribution of financing under the Sustainable Rp183.93 trillion in 2024. These loans were directed to various sustainability-focused
Business Activities Category (KKUB), which refers to financing in accordance with POJK sectors, including:
No. 51/2017 and POJK No. 18 of 2023. These cover environmentally sustainable business 1. Development in the renewable energy sector;
activities (KUBL) and socially sustainable business activities (KUBS). Overall, BTN continues 2. Construction of factories adopting renewable technologies through energy efficiency;
to increase the share of green financing in its loan portfolio, as reflected in the 77% increase 3. Sustainable management of living natural resources and land use;
in KUBL financing compared to the previous year, in line with its commitment to support 4. Environmentally friendly transportation;
the transition toward a more sustainable economy. KKUB financing is distributed through 5. Sustainable water and wastewater management;
various types of loans, including construction, investment, working capital, corporate, and 6. Green buildings;
short-term loans, which are directed toward sustainability-focused projects. In 2025, BTN 7. Affordable housing; and
disbursed KKUB financing with a total loan portfolio of Rp205.32 trillion, up 11.63% from 8. Job creation, including MSME financing.
KKUB Loan Disbursement [OJK F.3]
Renewable Efisiensi Energi Sustainable Management of Living Environmentally Friendly
Energy Natural Resources and Land Use Transportation
Total KKUB loan disbursements
in 2025 amounted to
KUBL Loans Rp1.99 Rp453.33 Rp3.01 Rp126.98
billion billion trillion billion
Rp205.32
RP8.88
trillion Sustainable Water and Green Buildings Business Activities and/or
Wastewater Management Other Activities Categorized as
or 4.33% of
Environmentally Sustainable Activities
trillion total KKUB
disbursements
Rp485.13 Rp945.43 billion Rp485.13
51.26% of total loan disbursement. billion billion
Increased 11.63% KUBS Loans
compared to the previous Affordable Housing Job Creation and MSME Financing
year.
Rp196,43 trillion
Rp191.19 trillion Rp5.25 trillion
or 95,67% of total KKUB disbursements
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Sustainability-Linked Loan (SLL) Subsidized Mortgage (KPR Subsidi)-Social Product Outstanding
BTN has developed a Sustainability-Linked Loan (SLL) policy framework to respond to Expanding access to banking and financial services is being realized through the
growing financing demand that increasingly emphasizes sustainability performance. provision of inclusive and sustainable products, including the development of subsidized
This scheme is designed to support BTN’s ESG objectives in alignment with the SDGs mortgage financing (KPR Subsidi) for low-income communities (MBR) with low interest
and the transition to a low-carbon economy. Through SLL, BTN provides incentives to rates and affordable financing schemes. BTN also has financial literacy and inclusion
companies that achieve sustainability targets, while ensuring that financing contributes programs in line with recommendations from Bank Indonesia and the Financial Services
to measurable positive environmental and social impact. Authority (OJK) to improve public understanding of sustainable financial planning while
supporting the achievement of the SDGs in Indonesia.
Under this framework, SLL terms link financing conditions to the debtor’s verifiable
sustainability performance, measured through Key Performance Indicators (KPIs) and BTN continues to expand its portfolio of ESG-based housing finance products, including
Sustainability Performance Targets (SPTs) agreed by both parties and stipulated in the financing for environmentally friendly housing, such as energy-efficient homes and
Loan Agreement (PK). In 2025, all SLL borrowers settled their obligations in accordance green building-based housing, while encouraging the use of eco-friendly materials in
with the applicable terms, resulting in no outstanding SLL facilities at the end of the residential development. The integration of ESG aspects is also applied in the development
reporting period. Incentives are granted when the agreed KPIs and SPTs are achieved. of mortgage products to support a more sustainable housing ecosystem.
The incentives offered by BTN include:
1. Pricing Incentive In 2025, BTN disbursed 132,803 units of subsidized housing finance with a total value
Pricing incentives are provided through a reduction in the applicable interest rate, of Rp22 trillion. Of this amount,109,752 units valued at Rp18.2 trillion were disbursed to
determined based on the Bank’s internal calculation methodology. This incentive is the millennial segment, while 19,610 units valued at Rp3.2 trillion were disbursed to the
applied through two mechanisms: underserved segment or informal sector, including traders, online motorcycle taxi drivers,
a. Pricing Incentive - Step Up: An incentive applied at the initial period of the SLL and workers with irregular income. By gender, disbursement to female debtors reached
facility. The incentive will be withdrawn and the debtor will be subject to an 48.235 units valued at Rp7.9 trillion, while disbursement to male debtors reached 84,568
increased interest rate for the remaining loan tenor if KPIs and SPTs are not units valued at Rp14 trillion, reflecting BTN’s support for financial inclusion and equitable
achieved. access to housing for all segments of Indonesian society.
b. Pricing Incentive - Step Down: A tiered incentive applied when the debtor
successfully achieves the agreed KPIs and SPTs.
2. All in Fee Incentive
This incentive is granted at the initial period of the SLL facility through a reduction
in the all-in fee, determined based on the Bank’s calculation. The incentive may be
withdrawn and the debtor will be required to pay the reduced portion of the All-in Fee
if KPIs and SPTs are not achieved.
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Targets and Realization of Subsidized Mortgage (KPR Subsidi) Disbursement [OJK. F.3] Product KPR BTN Sejahtera FLPP
Name
Description Unit 2025 2024 2023
Description The Housing Financing Liquidity Facility (FLPP) is a home ownership program
Target Mortgage Value (Rp billion) 25,800 18,145 20,415 initiated by the Ministry of Housing and Settlement Areas for low-income
households (MBR). It offers low interest rates and affordable installments for the
Number of Units (Units) 160,051 117,065 136,100
purchase of landed houses or public apartment units.
Realization Mortgage Value (Rp billion) 22,016 19,451 20,115
Debtor Low-income Communities (MBR)
Number of Units(Units) 132,803 118,665 130,830 Segment
Achievement Mortgage Value % 117.19 93.29 101.49 Income Limit Zone 1
Number of Units % 122.36 98.65 104.03 Java (excluding Jakarta, Bogor, Depok, Tangerang, Bekasi), Sumatra, East Nusa
Tenggara, and West Nusa Tenggara
• Single : Rp8,500,000
• Married : Rp10,000,000
Mortgage (KPR) Disbursement by Mortgage (KPR) Disbursement by Zone 2
Gender in 2025 [OJK. F.3] Employment Type in 2025 [OJK. F.3] Kalimantan, Sulawesi, Bangka Belitung Islands, Riau Islands, Maluku, North Maluku,
Bali
85.23% • Single : Rp9,000,000
• Married : Rp11,000,000
63.68%
Zone 3
Papua, West Papua, Central Papua, South Papua, Highland Papua, and Southwest
36.62% Papua
• Single : Rp10,500,000
14.77%
• Married : Rp12,000,000
Zone 4
Male Female Formal Workers Informal
Jakarta, Bogor, Depok, Tangerang, Bekasi
Workers • Single : Rp12,000,000
• Married : Rp14,000,000
Inclusive Mortgage (KPR) Products Key Terms 1. Maximum loan amount equals the selling price of the property minus the down
payment provided by the debtor. Debtors are also eligible for a government
down payment subsidy (SBUM) of Rp4 million for Java, Sumatra, Kalimantan,
KPR BTN Sejahtera FLPP Sulawesi and Rp10 million for Papua.
2. The mortgage interest rate payable by the debtor is 5% per annum, inclusive of
KPR BTN Sejahtera FLPP is a subsidized home ownership program initiated by the Ministry life insurance, fire insurance, and credit insurance premiums. The interest rate
is fixed for the entire loan tenor (fixed rate) and calculated using the annual
of Housing and Settlement Areas for low-income communities (MBR), offering low interest annuity method.
rates and affordable installments for the purchase of landed houses or public apartment 3. The funding source for the FLPP program consists of 75% government funds
units. This program refers to the provisions of the Housing Savings Management Agency and 25% Bank funds. BTN cooperates with PT Sarana Multigriya Finansial in
providing funding for the FLPP program.
(Tapera) under BTN Regulation No. 9 of 2021 on Home Ownership Financing through the
4. The mortgage tenor is agreed between BTN and the MBR debtor, adjusted to
Housing Finance Liquidity Facility (FLPP). the debtor’s repayment capacity, with a maximum tenor of 20 years.
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KPR BTN Tapera
KPR BTN Tapera is a home ownership loan facility specifically intended for Civil Servants Key Terms 1, Maximum loan amount equals the selling price of the property minus the down
payment provided by the debtor, who must have been a Tapera participant for
(ASN) who are registered participants in the Public Housing Savings Program (Tapera).
at least 12 months.
The program aims to support ASN participants in acquiring their first home under 2, The mortgage interest rate payable by the debtor is 5% per annum, inclusive of
favorable terms and conditions. life insurance, fire insurance, and credit insurance premiums, The interest rate
is fixed for the entire loan tenor (fixed rate) and calculated using the annual
annuity method.
Product KPR BTN Tapera
3, Funding source is derived from Tapera participant contributions,
Name
4, The mortgage tenor is agreed between BTN and the MBR debtor, adjusted to
Description A mortgage facility provided by BTN to eligible MBR Tapera participants for the the debtor’s repayment capacity, with a maximum tenor of 30 years,.
purchase of landed houses or apartment unit.
Debtor Low-income Communities (MBR) Participating in Tapera
In addition to KPR BTN Tapera, BTN also provides Tapera Home Renovation Loans (KRR
Segment
Tapera) and Tapera Home Construction Loans (KBR Tapera) to expand access to
Income Limit Zone 1
Java (excluding Jakarta, Bogor, Depok, Tangerang, Bekasi), Sumatra, East Nusa affordable financing for housing renovation and construction. Through these products,
Tenggara, and West Nusa Tenggara BTN supports the implementation of the Tapera Program while promoting greater access
• General:
to housing and the application of sustainable finance principles.
- Single : Rp8,500,000
- Married : Rp10,000,000
• Single applicant (Tapera participant) : Rp10,000,000
Zone 2
Kalimantan, Sulawesi, Bangka Belitung Islands, Riau Islands, Maluku, North Maluku,
Bali
• General:
- Single : Rp9,000,000
- Married : Rp11,000,000
• Single applicant (Tapera participant) : Rp11,000,000
Zone 3
Papua, West Papua, Central Papua, South Papua, Highland Papua, and Southwest
Papua
• General:
- Single : Rp10,500,000
- Married : Rp12,000,000
• Single applicant (Tapera participant) : Rp12,000,000
Zone 4
Jakarta, Bogor, Depok, Tangerang, Bekasi
• General:
- Single : Rp12,000,000
- Married : Rp14,000,000
• Single applicant (Tapera participant) : Rp14,000,000
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Inclusive Mortgage (KPR) Quota and Realisation [OJK. F.3]
2025 2024 2023
Description Metric
Quota Realization Quota Realization Quota Realization
KPR BTN Sejahtera FLPP Mortgage Value (Rp billion) 25,600 22,006 18,815 18,815 20,738 19,411
Number of Units (Units) 160,000 132,744 114,853 114,853 140,000 126,312
KPR BTN Tapera Mortgage Value (Rp billion) 9.8 9.8 930 636 528 703
Number of Units (Units) 59 59 5.000 3.812 5.000 4.518
Green Initiative Programs Targets and Realization of Tree Planting from Balé Point Redemptions [OJK. F.3]
Description Unit 2025 2024
Environmental preservation is promoted through initiatives that actively engage customer
Target Trees 1,000 500
participation. A tree-planting program uses the redemption of Balé Points in the Balé
Realization Trees 2,214 1,014*
by BTN application, which are converted into donations for mangrove tree planting via
*Restated
the Lindungi Hutan platform, strengthening customer engagement in BTN’s sustainability
agenda.
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Digital Innovation for Modern Services [OJK F.26]
Financial inclusion is promoted through the expansion of strategic, innovative, and
technology-based service access to address Indonesia’s geographic and demographic
challenges. As of 2025, various initiatives ensure that all segments of society, particularly
those in remote areas, can access banking services while strengthening independence
in financial management.
BTN has expanded financial access to more than 20 million Indonesians, including the
underserved demographics. In 2025, 117 Branch Offices (BO) and 631 Sub-Branch Offices
(SBO) were operated as service touchpoints across Indonesia to meet customer needs in
both urban and rural areas, including housing finance services.
24/7 service availability is supported by 1,044 Automated Teller Machines (ATMs), 1,047
Cash Recycling Machines (CRM), and 24 Digital Store outlets. Unlike ATMs, which are
limited to cash withdrawals, CRM (Cash Recycling Machine) enables both cash deposits
and withdrawals in a faster, easier, and real-time manner. BTN has also developed the
balé by BTN digital channel with 3.7 million users, and provides alternative payment
access through 6,000 EDC merchants and 250,000 BTN QRIS points in strategic locations.
Service coverage is further expanded through 6,300 balé agents, who play an important
role in extending financial service access, particularly in areas previously underserved by
conventional banking services.
BTN is committed to maintaining equal service quality for all customers, including
special attention to customers with specific needs, such as those with disabilities. This Ai-based mobile applications deliver a faster, safer, and more convenient banking
commitment is demonstrated through the provision of accessible facilities, including experience, ranging from daily transactions to housing finance applications. Through
ATMs and special lanes equipped with Braille features for visually impaired customers, as continuous development of service channels and innovation, access to banking services
well as dedicated pathways for wheelchair users, ensuring that services are delivered in becomes increasingly equitable and sustainable across Indonesia.
an inclusive and comfortable manner. [FS14]
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Digitalization
balé by BTN balé by BTN is a super app, developed as part of the transformation of BTN Mobile, to simplify banking
transactions and financial services. The application supports the expansion of service access in response
to geographic challenges, particularly for communities in underserved demographics. In 2025, balé by BTN
reached users in underdeveloped regions totaling 3.7 million users, in line with Presidential Regulation of the
Republic of Indonesia No. 63 of 2020, which supports the development of digital technology in these areas.
The integration of balé by BTN includes various services such as balé Properti, balé Community, balé Bisnis,
and other. The application also supports routine payments for household and business needs, as well as
electricity, clean water (PDAM), mobile credit and data packages, environmental management fees (IPL), as
well as security, parking, and property maintenance services. Key features available in balé by BTN include:
1. Online Account Opening, opening a bank account without visiting a branch, anytime and anywhere.
2. Single Sign-On, one account to access all BTN services without switching applications.
3. Cardless Transaction, cash withdrawals at BTN ATMs without a physical card via the application.
4. Auto Debit, automatic recurring bill payments.
5. Auto Transfer, scheduled recurring transfers to other accounts, within BTN and to other banks.
6. Cashflow Tracker, monitoring income and expenses.
7. Split Bill, practical bill-splitting functionality via the application.
For MSMEs customers, balé by BTN provides flexible banking access through a branchless banking approach,
enabling customers to manage transactions and routine obligations more efficiently to support business
activities. The use of the Quick Response Code Indonesian Standard (QRIS) is also a key feature of balé
by BTN enables easy and secure digital payments. The increasing number of QRIS transactions and users
indicates that balé by BTN provides an easy, secure, and inclusive payment solution, while supporting
broader financial inclusion across Indonesia.
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Transactions Using balé by BTN [OJK. F.3]
Description Unit 2025 Target 2025 Realization 2024 2023
Number of Transactions (Financial and Non-Financial) Transactions (million) 1,553 2,216 1,237 415
Transaction Value Rp billion 92,000 103,610 81,111 57,542
Integrated Users Users (thousand) 3,600 3,688 2,220 2,691
Number of Acquisitions Acquisitions (thousand) 1,500 1,615 1,249 1,139
* 2023 reflects the migration process from BTN Mobile Banking (blue version) to the balé by BTN superapp
Transactions Using QRIS [OJK. F.3]
Description Unit 2025 Target 2025 Realization 2024 2023
Number of Merchants Merchants 206,000 250,000 125,082 15,602
Number of Transactions Transactions (million) 27,000 62,294 17.397 3,523
Transaction Value Rp billion 2,400 4,401 1,347 302
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Digitalization
balé Bisnis balé bisnis is a rebranding of BTN Internet Banking Business, designed for MSME customers who hold BTN
Business Savings Accounts, to support business management and development. As part of its digital
transformation, balé Bisnis offers several key advantages that support the operational and financial
management needs of business customers, including:
1. Soft token integrated with balé by BTN
2. Single / multiple authorization
3. High transfer limits
4. Registration Service Level Agreement (SLA): 1 x 24 hours
5. Scheduled transactions
6. Bulk transfer
7. Payroll
8. Cash flow tracker
9. Bank statements in xls, pdf, and mt940 formats
Transaction Using balé bisnis (Financial and Non-Financial) [OJK. F.3]
2025
Description Unit 2025 Target 2024
Realization
Number of Transactions (Financial and Non- Transactions 3,800 61,700 3,751
Financial)
Transaction Value Rp billion 50 1,453 60
Integrated Users Users 4,000 12,000 843
Number of Acquisitions Acquisitions 3,200 11,208 732
*2024 reflects the migration process from BTN Internet Banking Business to balé bisnis.
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Digitalization
BTN Digital Store BTN’s transformation focuses on increasing sales capacity and improving service quality with a strong orientation toward
customer satisfaction. While the branch network continues to serve customers directly, technological developments have
accelerated the shift toward digital banking services, that are efficient, and customer-centric. BTN has responded to this
need through the implementation of BTN Digital Store services within Branch Offices (KC) and Sub-Branch Offices (KCP).
BTN Digital Store utilizes digital devices and applications to meet customer needs while delivering a differentiated service
experience. The service focus emphasizes effective and efficient transactions, as well as a practical and secure customer
experience. This also supports increased sales capacity and employee productivity. To ensure effective implementation,
BTN has prepared adjustments to organizational structure, roles, and responsibilities across office networks, including the
establishment of specific authorities for BTN Digital Store operations. There are three types of BTN Digital Store:
1. Flagship Branch is the most comprehensive Digital Store format, using a hybrid branch concept that focuses on
customer experience, brand image, and transaction convenience. This format is found at selected KC or KCP located
in a business center with a large office area.
2. Digital Oriented Branch focuses on faster and more convenient transactions at selected offices through self-service
facilities supported by “superstaff.” This format is placed at KC or KCP in retail areas, communities, and commercial
hubs that are easily accessible and have sufficient office space.
3. Digital First Branch is a new branch format within BTN’s network, adopting the “Bring Bank to the People” concept. It
focuses on serving the retail segment through a self-service approach. This format is placed in high-traffic areas such
as activity centres, public places, and high-mobility locations, supported by a more space-efficient branch layout.
BTN Digital Store Transactions (Financial and Non-Financial) [OJK. F.3]
Description Unit 2025 Target 2025 Realization 2024
Number of BTN Digital Stores in Operation Units 24 24 1
Number of Transactions (Financial and Non-financial) Transactions 12,000 18,889 2,007
Number of Branches Upgraded to BTN Digital Store Branches 14 14 1
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Digitalization
balé Community balé Community is an enhancement of the BTN Smart Residence platform, integrated with the balé by BTN
Super App, to connect residents and community managers in managing community services end-to-end,
from bill or fee payments to information updates and the submission of complaints or grievances. This
integration supports the digitalization of the housing ecosystem by making processes more transparent,
efficient, and well-documented, in line with BTN’s commitment to digital transformation and the expansion
of community-based services.
For community managers, the platform simplifies billing management and systematic and digitalized bill
reconciliation, centralized and timely communication of updates to residents, and monitoring of complaint
status to improve the quality of community services. For residents, balé Community allows convenient
payments for management fees, parking, and maintenance anytime and anywhere, supported by a fast
and well-documented complaint channel. Key features of balé Community include:
1. Residence and Tenant Management – organizing residents by cluster/tower, block/floor, and unit
number.
2. Billing Management – enabling managers to input individual resident bills.
3. Information Management – sharing the latest residential updates.
4. Complaint Management – monitoring complaints submitted by residents.
Transactions Using balé Community [OJK F.13]
Description Unit 2025 2024 2023
Registered Users Persons 20,000 13,945 8,915
Number of Transactions Transactions 47,000 43,602 16,973
Transaction Volume Rp billion 13.20 11.83 7.46
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Digitalization
balé Properti balé Properti is the transformed version of BTN Properti, developed to support individuals and businesses,
in meeting their property needs, and is integrated with the balé by BTN Super App. Through this platform,
customers can browse and select properties from BTN’s partner developers across Indonesia, apply online
for a Home Ownership Loan (KPR) or Apartment Ownership Loan (KPA), and access productive loans to
support business growth. The presence of balé Properti contributes to enhancing financial inclusion and
expanding access to sustainable housing financing. balé Properti also provides digital capabilities that
support an end-to-end process, from exploration through to monitoring application progress. The platform
can be accessed via btnproperti.co.id and the balé by BTN app. Key features of balé Properti include:
1. Property search by region, developer name, or housing project name.
2. Loan simulation to estimate monthly instalments.
3. Real-time tracking of loan application status.
4. 24-hour live chat service.
5. A 4D Tour service to visit show units virtually through a four-dimensional viewing feature.
Transactions Using balé Properti [OJK F.13]
2025
Description Unit 2025 Target 2024 2023
Realization
Number of Registered Users Users 947,000 986,264 747,456 515,339
Number of loan applications Applications 47,000 62,616 49,217 28,494
submitted
Transaction value (volume) Rp Billion 2,800 2,807 2,405 2,210
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Digitalization
balé Korpora BTN Cash Management is an internet-based service that enables institutional customers to conduct a wide
range of banking and financial transactions online and in real time. Through this service, customers can
transact anytime and anywhere through practical processes supported by appropriate security standards.
In 2025, acquisition realisation reached 154.65% of the target of 2,970. [OJK F.3]
Transactions Using balé Korpora
Description Unit 2025 2024 2023
Number of Transactions (Financial and Non-Financial) Transactions 2,999,876 1,552,528 2,206,654
Transaction Value Rp billion 265,863 218,317.61 88,204.54
Number of Registered Users Users 22,631 17,585 11,922
Number of Acquisitions Acquisitions 4,593 3,917 2,361
Credit Offer Program for Selected Customers
BTN offers a credit offer program for selected existing borrowers to provide faster and visiting a branch, subject to the Bank’s policies. This umbrella program includes KRING BTN
simpler access to financing. The program uses integrated offer channels, does not require Ultimate and KAR Ultimate.
additional documents, and allows loan agreement execution without the customer
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KRING BTN Ultimate
KRING BTN Ultimate is a light credit program offered under a new lending scheme, with loan limits and tenors
determined in accordance with Bank policies, targeting selected (pre-approved) customers and featuring
a faster and more streamlined disbursement process.
Terms and Conditions:
• Selected existing BTN debtors, both subsidized and non-subsidized.
• Offered through telesales channels and the balé by BTN platform (BTN KITA feature).
• No additional documentation required.
KAR Ultimate
KAR Ultimate is a loan program using a Home-Backed Loan (KAR) Top-Up scheme for selected customers.
The top-up is provided as an additional facility, allowing the borrower to hold two credit facilities, with a
limit not exceeding the original facility and a maturity date not extending beyond the main loan. Offers
are delivered through WhatsApp blasts, telesales, BTN KITA, and/or branch offices. The process does not
require additional data or documents, the loan agreement can be carried out without the customer visiting
a branch, and disbursement is processed quickly.
Terms and Conditions:
• Selected existing borrowers, both subsidised and non-subsidised, with a good repayment history for at
least one year.
• Employed with a fixed income.
• The loan is still active and the collateral remains with BTN.
• No additional documents required.
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Financial Product Oversight
BTN ensures that every financial product and service meets standards for fairness, 2. Being responsible for submitting a report on Significant Decisions made to the Board
security, and compliance, while managing potential risks. Each product and financial of Directors Meeting at least once per year; and
service development at BTN is carried out through a strict oversight process to ensure 3. Determining corrective actions related to the Bank’s product development and
compliance with applicable regulations and prudent banking principles. Prior to launch, all reporting such actions to the Board of Directors.
products must obtain approval from Bank Indonesia and the OJK. This approach aligned
with Policy No. KK.9-Z on Customer and Public Protection, which serves as the basis for Through this oversight mechanism, the Business Committee ensures that both product
responsible product and service risk management. development and product discontinuation consider risk management and customer
interests, while continuing to support the Bank’s long-term objectives. In line with
An end-to-end product management approach, covering planning, development, testing, consumer protection principles, BTN ensures that product information is communicated
launch, and post-launch monitoring is applied. For new product plans and/or activities to customers in a transparent, clear, accurate, and easily accessible manner, enabling
undertaken for the Bank’s purposes, the product owner division prepares a proposal and customers to adequately understand the benefits, risks, and terms of products before
submits it through the relevant coordinating function to fulfil the required notification to making decisions.
OJK in accordance with prevailing regulations. Subsequent steps are carried out by each
product owner division, including submitting go-live information in line with the Bank The product assessment process includes input from reviewers and control owners,
Product Implementation Plan (RPPB) through the relevant function for onward submission evaluation reports, assessments of compliance with internal and external standards,
to OJK. and follow-up actions based on investigation criteria related to impact and regulatory
compliance. Assessments are conducted at least once a year, or more frequently in the
Product and service evaluations are conducted regularly to ensure security standards event of significant changes to products or regulations. The results serve as the basis for
and regulatory compliance, while also identifying risks inherent in product development. improving policies and procedures to enhance the quality of inclusive and sustainable
Oversight of this process is through the Business Committee, which comprises members financial services.
of the Board of Directors and Senior Executive Vice Presidents (SEVP). The Business
Committee supports policy formulation and decision-making, and oversees strategic In 2025, product oversight effectiveness was measured through regulatory compliance,
matters related to the development, modification, or discontinuation of BTN’s products customer satisfaction levels, and contribution to financial inclusion, supported by customer
and business activities. The committee’s working procedures refer to Special Policy (KK) feedback. The oversight structure at the level of the Board of Directors and Committees
No. KK.9-D on the Governance Procedures for the Board of Directors’ Committees. ensures that BTN’s products and services remain reliable, secure, and aligned with the
Bank’s sustainability and integrity principles.
The main duties of the Business Committee include:
1. Being accountable for decisions made in Business Committee Meetings and Board of
Directors Meetings;
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Advertising Policy
In line with its commitment to GCG and sustainable business practices, a Fair Advertising compliance, product management, and corporate communications functions to ensure
Policy through several Special Policies (KK), including KK.9-Y on Marketing Communication campaigns are responsible, not misleading, and protective of the Bank’s reputation. The
Activities, to build consumer trust and safeguard business integrity. This ensures that all MCD reports the implementation of these activities to the Board of Directors at least once
marketing, promotional, and public communication materials are prepared with due a year, covering performance, effectiveness, and compliance aspects.
consideration to legal aspects, compliance, reputational risk management, educational
value, and transparency. The principles of transparency, accuracy, and non-misleading In advertising placements, BTN considers the appropriateness of audience, media,
communication form the foundation of BTN’s marketing communications. and timing to minimize potential negative impacts. All materials must undergo legal,
compliance, and risk verification processes prior to publication, including cybersecurity
Marketing communication standards require the use of clear and understandable assessments of the media and channels used. Campaign evaluations are ensure
language, in accordance with proper language rules, and prohibit claims or terminology effectiveness and compliance with applicable provisions.
that may be misleading, including the use of the word “free” when fees are still applicable.
Information regarding promotions, refunds, and customer testimonials must be Regular training programs for marketing and communication teams maintain
conveyed transparently and subject to verification. Through KK.9-Y, BTN also regulates consistency in the application of ethics and integrity in information delivery. Responsible
the use of logos, brands, talents, music, and other digital assets to ensure compliance marketing principles are integrated with customer protection, as stipulated in KK.4-F,
with applicable laws and copyright and intellectual property rights. which emphasizes education, information transparency, responsible business conduct,
and customer data protection. Accordingly, BTN’s marketing activities support business
Marketing and communication activities for products and services are managed by the objectives while strengthening public trust and the implementation of good corporate
Marketing Communication Division (MCD) under the oversight of the Board of Directors. governance, including compliance with sharia principles where relevant. For more
All marketing communications are coordinated with the risk management, legal, information, please visit the following link Fair Advertising Policy.
Employee Training Related to Advertising and Marketing [GRI 404-2]
Training Name Implementation Date Number of Employees Participating Total Training Hours
Customer Service Centre Certification February 2 44
Service Quality Certification August 11 209
Business Communication Skills Development October 18 145
Integrated Marketing Communications October 3 15
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Digitalization
Training Name Implementation Date Number of Employees Participating Total Training Hours
Full-Stack Digital Marketing October 3 30
Creative Thinking and Problem Solving December 25 213
BTN Business Competition Compliance Webinar December 63 16
Customer Financial Protection
In line with product oversight and the control of marketing communications, BTN manages 6. Enforcement of compliance; and
customer protection through financial protection. Customer financial protection is 7. Fair competition.
through Special Policy (KK) No. KK.9-Z on the Protection of Customers and the Public,
which regulates the delivery of product and service information in a clear, accurate, and In managing products and services, BTN applies controls throughout the Product and/or
transparent manner, including the consequences and risks of usage. Controls are aimed Service Life Cycle to ensure consistent implementation of consumer and public protection
at reducing potential financial losses and legal risks, while maintaining customer trust in principles, covering the following stages:
interactions and transactions with BTN. 1. Product and service design;
2. Provision of product and/or service information (RIPLAY);
These provisions are aligned with OJK Regulation (POJK) No. 22 of 2023 on the Protection of 3. Delivery of product and/or service information;
Consumers and the Public in the Financial Services Sector. This serves as BTN’s reference 4. Marketing of products and/or services;
in providing fair and responsible financial products and services, while prioritizing 5. Preparation of agreements related to products and/or services;
customer interests and welfare at every stage. The Bank applies fundamental principles 6. Service delivery related to the use of products and/or services; and
of consumer and public protection as the basis for customer financial protection, which 7. Complaint handling and dispute resolution related to customer products and/or
include: services.
1. Adequate education;
2. Openness and transparency of information; In implementing consumer protection principles that support customer financial
3. Fair treatment and responsible business conduct; protection, BTN undertakes the following:
4. Protection of customer assets, privacy, and data; 1. Strengthened human resources and customer protection infrastructure through the
5. Effective and efficient complaint handling and dispute resolution; establishment of structures that perform customer protection functions at each BTN
Branch Office representative.
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2. Development of a strategic planning cycle for financial literacy and inclusion 4. Enhancement of complaint handling services by providing easily accessible
education, implemented through structured education, literacy, and inclusion complaint channels and ensuring that complaint resolution complies with the
programs carried out periodically each year, including the development of digital applicable Service Level Agreement (SLA).
inclusion.
3. Establishment of internal regulations on consumer and public protection that adopt To support the consistent implementation of these principles across all service networks,
external regulations related to customer protection, education and inclusion, and BTN conducts training programs for employees involved in customer financial protection.
personal data protection, as guidelines for Bank operations. Details of the training programs implemented throughout 2025 are presented in the
following table.
Employee Training and Certification Related to Customer Financial Protection [GRI 404-2]
Training Name Implementation Date Number of Employees Participating Total Training Hours
Customer Service Centre Certification February 2 44
Value Creation: Conquering the Market through Digital Leadership and Customer Orientation February 1 4
Fair Competition Compliance Procedures July 25 5
Service Quality Certification August 11 209
High-Impact Business Communication Skills October 15 121
MRI Insights Webinar: Going Beyond the Customer Experience October 5 15
Creative Thinking and Problem Solving December 20 170
Customer Data Privacy and Security
Information Technology (IT) governance is one of the main pillars in safeguarding security. This governance framework is reviewed periodically and regulated at a high
service reliability, information security, and the Bank’s operational effectiveness, covering level through the General Policy No.KU.5 on Information Technology, Data Management,
aspects of management, planning, development, operational infrastructure, and system and Digital.
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To ensure consistent implementation across the organization, these provisions are 4. Information Security Manager (ISM);
supported by Special Policies that regulate technical aspects and provide more detailed 5. Information Asset Owner (IAO);
operational and supervisory guidance, applying to all relevant business lines and 6. Information Asset Custodian (IAC);
subsidiaries of BTN, and cover the entire data lifecycle, from data collection, processing, 7. Head of Work Unit;
storage, to data destruction. 8. Information Security Management System (ISMS) Team;
9. Cyber Security Incident Response Team (CSIRT);
BTN’s comprehensive IT governance and policy framework encompasses technical 10. Compliance Work Unit;
guidelines, data and digital management, IT procedures and standards, IT security, 11. Operational & Digital Risk Management Work Unit;
and operational resilience, supported by Business Continuity Management (BCM) and 12. Employees; and
recovery planning, including Business Impact Analysis (BIA), Business Continuity Plan 13. Third Parties.
(BCP), and Disaster Recovery Plan (DRP). This framework also includes IT, digital, and
cyber risk management, as well as governance over electronic system placement and Policy Framework and Controls for Customer Data Security
committee structures to ensure consistent implementation throughout the organization.
Further details regarding oversight, policy frameworks, and customer data security BTN places customer privacy and information security is a top priority, based on two key
controls are elaborated in the sections below. principles. First, customer data obtained through the Bank’s services is confidential, must
be protected, and must not be disclosed without consent. Second, the increasing use of
Responsibilities and Oversight for Data Privacy and Security data through digital applications has also increased exposure to cyber threats that may
disrupt data security.
The effective management of privacy, cybersecurity, and data protection happens
through a clearly defined information security structure and mechanisms, including the The risk of data leakage is controlled through internal storage systems with strict
implementation of dual control to maintain segregation of duties within IT operations. access controls, and limitations on the use of customer data strictly in accordance with
Governance responsibilities are at the level of the Board of Commissioners and Board- the customer’s explicit consent and applicable legal provisions. Risk management is
level Committees, in accordance with the Special Policy on Personal Data Protection, the supported by the Operational and Digital Risk Management Work Unit, which manages
Technical Guidelines for Data Governance Implementation, and compliance with the operational, IT, and digital risks, including the application of risk management to every
Personal Data Protection Law (UU PDP). Oversight is carried out through supervision of technology solution developed to ensure that services remain secure and reliable. [OJK
committees under the Board of Directors formed to support decision-making aligned F.27]
with the Bank’s vision, mission, and strategy, with the Information Security Organization
structured as follows: These provisions are aligned with regulations issued by the Financial Services Authority
1. Board of Commissioners; (OJK) and laws and regulations of the Indonesian government relating to banking,
2. Information Technology Steering Committee (KPTI); consumer protection in the financial services sector, customer data confidentiality and
3. Director in Charge of Information Technology; security, bank secrecy, and personal data protection, and are supported by internal
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Special Policies on data governance and customer and public protection. A Special Information Technology (IT) Operations and Digital Security
Policy on Information Technology Security No. KK.5-B and on Personal Data Protection
No. KK.6-K adopt the principles of confidentiality, integrity, and availability (CIA) to ensure IT operations are positioned as a key enabler of the Bank’s operational effectiveness and
that management is effective, efficient, secure, orderly, well-governed, traceable, and efficiency. To manage its broad scope, BTN structures IT operations into four primary
auditable. [GRI 418-1] [SASB FN-CB-230a.2] domains with distinct roles and focus areas: [GRI 3-3]
Control implementation includes IT security training for users, the use of authorized and Four Domains of BTN’s IT Operations
regularly updated software, password standardization, and routine evaluation of the
data security architecture to ensure continued adequacy and effectiveness. In 2025,
there were no complaints related to breaches of customer data security, including loss, Plan The Bank Change the Bank Run the Bank Secure the Bank
theft, or data leakage. In addition to awareness programs, the Bank also conducts data
security risk identification through: [GRI 418-1] [SASB FN-CB-230a.2, FN-CB-230a.1] IT operations and
Information Protection of
1. Record Security Management policies; IT system infrastructure
Technology (IT) systems and
2. Retention of sensitive information; development reliability for
Planning applications from
3. Identification of critical records; the Bank and
IT security risks
customers
4. Storage of critical records;
5. Storage of business source documents;
6. Storage of application transaction data;
7. Destruction of information;
8. Storage of sensitive information; and
Three Pillars of Digital
9. Storage of violation and security incident records.
Security Approach
BTN is committed to protecting customer rights as personal data subjects in accordance 1. People
with applicable regulations, including the Personal Data Protection Law. Customer 2. Process
protections, include the right to receive clear information regarding the collection and use 3. Technology
of their personal data, the right to complete or rectification data in case of inaccuracies
or incompleteness, and the right to access and obtain copies of personal data held by
the Bank. Customers also have the right to terminate, delete, or destroy their personal
data if the data is no longer required or if consent previously granted is withdrawn.
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As IT evolves and digital banking transactions continue to increase, BTN has strengthened e. Wallpaper Desktop Security Awareness
its focus on the “Secure the Bank” domain to ensure that services remain protected f. Screen Saver Security Awareness
against key IT-related risks, namely data breaches and cyberattacks. In response, BTN g. Bulletin Security Awareness
implements digital security through a combination of proactive and reactive approaches h. Security Awareness Understanding Survey
based on the three main pillars: People, Process, and Technology, to protect customer
data and transactions and ensure that digital services remain secure and reliable. For third parties, education is conducted annually to ensure proper information security
management and protection of BTN data under their control. For customers, the focus
Pillar: People is on secure transactions, cybercrime awareness, and personal data protection.
Communication is delivered through BTN’s e-channels, BTN social media platforms
The People pillar focuses on strengthening information security awareness and (Instagram, X, Facebook, etc.), and various offline events and marketing activities
capabilities across the entire ecosystem, including employees, customers, and third organized by the Bank.
parties. Its implementation is carried out through two main focuses: security awareness
and competency development through training and certification. Competency Development [GRI 404-2]
Security Awareness BTN is committed to strengthening cybersecurity professionalism and competence
through training and certification programs conducted at least once per year for
BTN fosters a strong security culture is fostered across all work units through an IT employees, as well as vendors and contractors who support operations, system
Security Index program that monitors the effectiveness of security awareness initiatives development, or maintenance and may access the Bank’s information and IT assets.
in mitigating cyber and information security risks. Senior management delivers monthly The scope of training and certification provided includes cybersecurity and digital risk
updates to employees, emphasizing the direct link between information security, management, personal data protection, privacy and compliance, as well as cyber
customer trust, and the Bank’s reputation. Security awareness education is conducted defence preparedness and cybercrime response.
regularly for employees, customers, and third parties. For employees, dissemination is
carried out through BTN’s digital platforms, including: As part of this competency development program, BTN conducts cybersecurity and
a. BTN official website personal data protection training and certification for employees, particularly those
b. Podcast directly involved in IT risk management, information security, system development and
c. Learning Management System operations, as well as incident monitoring and handling. Details of implementation during
d. Email Blast Security Awareness 2025 are presented in the table below.
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Employee Training and Certification Related to Data Privacy and Cybersecurity
Number of Employees
Training Name Implementation Date
Participating
IBM i System ADM & Control AS400 January 2
Training CompTIA® Security+ March 2
Pelatihan Keamanan & Pelindungan Data March 4
Comptia Pentest+ March 1
Refreshment Sertifikasi Manajemen Risiko March 14
Training Sosialisasi Cyber Threat & Digital Risk Awareness April 9,963
Certified Information System Security Professional (CISSP) April 1
Microsoft Identity & Access Administrator April 3
Digital Forensic Management May 2
Certified Risk & Information System Control (CRISC) May 3
Comptia Security+ May 2
Training CompTia Security+ (SY0-701) June 2
Training The Future of Cybersecurity : Threats, Challenges, and Innovations June 6
Training Keamanan & Perlindungan Data July 4
Training Compliance Excellence - Data Privacy Excellence August 12,011
Training Certified Indonesia Data Protection Officer (CIP DPO) August 2
Secure Coding with GenAI November 3
Training CompTia Security+ October 2
Training Perlindungan Data Pribadi December 28
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Pillar: Process
Governance is implemented in accordance with applicable standards and regulations - Ransomware
by applying SOP-based operational processes that are consistently communicated - Operational/Management Incident
and implemented by all stakeholders. In alignment with these standards, BTN has - Web Application Attack
implemented the following initiatives:
1. Establishment of a Computer Security Incident Response Team (CSIRT) that 3. In 2025, BTN’s operations were certified under ISO 27001:2022 for its Information
collaborates with regulators and is supported by advanced technology and a Security Management System. To ensure consistent implementation of the standard,
monitoring system in the form of Security Incident and Event Management (SIEM). BTN conducts annual internal and external audits of its information security system,
2. Periodic cybersecurity testing on network, system, and data security in accordance including Data Center operations.
with regulatory requirements, including: 4. BTN conducted an assessment of its implementation of SEOJK No. 29/SEOJK.03/2022
• Vulnerability-based testing through vulnerability assessments and penetration on Cyber Resilience and Security, carried out by an external auditor registered with
testing for new applications, application developments, and regular applications the Indonesian Payment System Association (ASPI). Based on the assessment results,
based on criticality levels, conducted by certified independent external parties BTN achieved a Level 2 rating for cyber security risk, indicating that the Bank’s overall
registered with the Indonesian Payment System Association (ASPI). cyber security maturity is at a high level.
• Scenario-based testing, including table-top exercises, social engineering 5. In support of government and regulator programs to combat online gambling and
exercises (phishing via email), and Adversarial Attack Simulation Exercise (AASE). the sale of accounts under customer identities, BTN conducts cyber patrols using its
Table-top exercises are conducted by cross-unit CSIRT teams to review attack Cyber Threat Intelligence (CTI) tools.
playbooks, response, and recovery, covering topics such as:
- Data Breach Guidelines Pillar: Technology
- Snapshot Server DFIR
- Chain of Custody BTN applies a defense-in-depth approach through layered security controls to enhance
- Server Forensics information technology security capabilities and optimize defense. This approach
- Insider Threat includes endpoint security, application security, network security, IT infrastructure
- Social Engineering security, and data security, to safeguard confidentiality, integrity, and availability, and to
- Data Breach Incident protect customer data and transactions.
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Implementation of Layered IT Security Controls
Security Layer Initiative / Technlogy Primary Objective
Endpoint Security Enhanced Endpoint Protection for servers To detect, prevent, and respond to malware/ransomware in real-time and reduce the risk of data
leakage, damage, or theft.
Endpoint Security Enhancement of DNS Security and IP Address Management To mitigate access to unsafe domains and improve traceability of endpoints accessing IT resources.
Application Security Security by design & Mobile Application Security To safeguard customer mobile applications through strengthened design and security controls on
access devices.
Application Security Enhancement of API security To detect and prevent Application Programming Interface (API)-based attacks in line with the increased
use of open banking.
Application Security Enhancement of IBB security through content delivery network To improve security of web-based applications while maintaining access performance for Internet
Banking Business (IBB).
Application Security Manage Service Digital Application Protection To provide comprehensive application protection and support monitoring and operational follow-up on
digital transactions.
Network Security Implementation of Network Access Control (NAC) To regulate, verify, and monitor device access to the network based on policy to prevent unauthorized
access.
Network Security Enhancement of Internet Access Control and Proxy Outbound To separate and identify internet traffic for business transactions and back-office productivity through
access control and outbound proxy.
Network Security Enhancement of email security To protect email systems from spam, phishing, and malicious attachments.
IT Infrastructure Security Enhancement of Network Time Protocol (NTP) To maintain time synchronization for audit log accuracy, security control consistency, and to mitigate the
risk of data manipulation.
IT Infrastructure Security Implementation of active-active security infrastructure To enhance availability, resilience, and reliability of transactional infrastructure to ensure service
continuity.
IT Infrastructure Security Strengthening of security management for Microsoft-based To apply best practices and professional service support for current security, operational support, and
systems (Windows, Active Directory, MSSQL, Microsoft Office, access to the latest technology.
Office 365)
Data Security Implementation/Improvement Data Loss Prevention (DLP) To mitigate customer and Bank data leakage through preventive controls and monitoring of data flows.
Data Security Cyber Threat Intelligence (CTI) and Digital Right Protection To actively monitor cyber threat patterns and perform takedowns of content that may harm customers
and the Bank’s reputation.
Data Security Enhancement of database security To limit and prevent attacks that exploit databases as digital access and transactions increase.
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Disclosure and Control of Data Shared with Third Parties 5. The Bank manages third-party security risks related to IT service providers and digital
partners through Third-Party Risk Assessments, Security Questionnaires, and Security
BTN ensures that data protection standards also apply to suppliers and business Scorecards, to ensure these third parties meet the Bank’s IT security standards.
partners who process Bank data or have access to the Bank’s network, and that data is
not transferred to third parties except for legitimate service provision purposes and in Personal Data Protection
accordance with applicable regulations.
Personal data protection is a systematic effort to safeguard the privacy rights of personal
Third-party compliance with information security standards and procedures is regulated data subjects by protecting the confidentiality, integrity, and availability of their personal
under Special Policy (KK) No. 5-B on Information Technology Security and reinforced data. This process emphasizes. Transparency so that data subjects understand how their
through clauses in cooperation agreements or Non-Disclosure Agreements (NDA), data is collected, used, and protected. The framework sets out the obligations of the data
including the obligation for suppliers and business partners to maintain data protection controller, namely the Bank, as well as the rights of personal data subjects to protect their
and information security policies or to comply with BTN policies. Implementation is carried interests.
out through the following key measures:
1. The Bank manages information security and cybersecurity risks throughout the BTN personal data protection practices maintain customer trust and comply with Law
service delivery process by suppliers and partners through comprehensive processes No. 27 of 2022 on Personal Data Protection. A Data Privacy Unit acts as the Personal Data
and procedures to ensure the security, integrity, and confidentiality of information Protection Officer within the Compliance function under the Human Capital, Compliance &
during IT solution delivery. Legal Directorate, overseen by the Board of Directors through the Information Technology
2. The Bank ensures that any amendments to cooperation agreements with suppliers Steering Committee (KPTI) and the Risk Management Committee. The Data Privacy Unit
and partners must be mutually approved in accordance with applicable change develops the governance framework and policies and runs personal data protection
procedures, accompanied by identification and review of information security program to ensure holistic control implementation.
requirements for any agreed scope changes.
3. The Bank conducts supervision and inspection through routine monitoring of services BTN’s personal data protection and management practices are governed by an
provided, requires periodic reporting on service delivery outcomes, and ensures the internal policy framework covering the entire data processing lifecycle, from collection,
availability of support and information required for internal audit processes to verify use, and sharing, through to storage and deletion. Special Policies (KK) cover personal
compliance. data protection, IT security, customer and public protection, and records management
4. Upon termination of cooperation, the Bank also implements an exit strategy to ensure implemented through Technical Guidelines (PT) that address data subject consent,
that data remains protected even after the relationship with suppliers or partners Records of Processing Activities (ROPA), impact assessments, data protection incident
ends. handling, management of data protection aspects in third-party engagements, and
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Digitalization
records management procedures. To safeguard data, BTN applies technical security Protection and KK No. KK.5-B on Information Technology Security, incorporating
controls in line with internal requirements, including masking of sensitive data based control procedures aligned with ISO 27001:2022 Information Security Management
on the relevant Security Baseline Technical Guideline, and restrictions on data transfers System.
through Data Loss Prevention (DLP) solutions in accordance with the applicable DLP 3. BTN has established a mechanism to provide timely notifications to personal data
Technical Guideline. subjects in the event of changes to requirements, processing purposes, and/or
personal data protection incidents. This provision is supported by incident response
The confidentiality of personal data is maintained through information security controls guidance for handling personal data protection failures, with reference to Special
and governance over data sharing with third parties. BTN also ensures that personal data Policy (KK) No. KK.6-K and Technical Guideline (PT) No. PT.6-K.4 on the Handling of
is processed on a lawful basis, used only for the purposes communicated to customers, Personal Data Protection Failures.
and deleted once those purposes have been fulfilled. 4. BTN ensures that data processing is lawful and transparent, with explicit consent
obtained when required. Consent from data subjects, both individuals and corporates,
BTN does not sell, provide, or rent personal data belonging to personal data subjects is clearly obtained for informed purposes, including when involving third parties, and
associated with BTN to third parties, except for transaction processing, financial service recorded in ROPA in accordance with KK No. KK.6-K.
delivery, regulatory reporting, law enforcement requests, and other exceptions as 5. BTN requires third parties involved in data sharing to comply with the Bank’s policies
stipulated by law. BTN also does not collect or use customer personal data from third through third-party risk management and compliance standards, as stipulated
parties without customer consent. Transparency regarding data use and protection is in KK No. KK.6-K and PT No. PT.6-K.5 on Third-Party Cooperation for Personal Data
provided through a privacy notice accessible on the Bank’s official website. The Bank also Protection.
applies the principle of data minimization in data processing.
In line with these obligations, BTN implements Law No. 27 of 2022 on Personal Data
As a data controller, BTN ensures the consistent application of personal data protection Protection, which requires the deletion of personal data but does not explicitly specify
obligations through the following commitments: a retention period. Accordingly, BTN refers to its internal policies, namely Technical
1. BTN ensures that the collection and processing of personal data is limited to data Guideline No. PT.9-J1 on Records Management as the framework for the Records Retention
that is necessary and relevant for specific purposes, in accordance with the data Schedule, and Technical Guideline No. PT.9-M.1, which sets out detailed data retention
minimization principle. Processing purposes are defined in writing and approved by periods by category. Under these provisions, the retention period for personal data is
the data subject prior to processing, as stipulated in KK No. KK.6-K on Personal Data set at a minimum of 10 (ten) years for transaction data, customer data, and credit data.
Protection and Technical Guideline No. PT.6-K.1 on Data Subject Consent. Upon expiry of the retention period, personal data is deleted provided that the customer
2. BTN adopts data protection standards set out in KK No. KK.6-K on Personal Data no longer has any active products or services with BTN and the data does not fall under
the exceptions stipulated in Article 50 of Law No. 27 of 2022 on Personal Data Protection.
Retention periods for other data categories are determined by the respective data
owners based on the product, service, and data type, in accordance with the applicable
retention schedule.
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BTN’s privacy policy at Privacy Policy and on other BTN digital platforms, and fulfills data
subject rights in accordance with applicable laws and regulations. Requests related to
data subject rights may be submitted through balé by BTN, BTN Call Center, or customer
service at Bank outlets. Customer service handles requests for personal data information,
data updates or corrections, and requests for processing termination and data deletion,
while access to personal data information is also available via balé by BTN.
Additionally, BTN has initiated a periodic evaluation process regarding personal data
protection, conducted by an internal team, and involving third parties appointed by the
Bank to support the process.
During this reporting period, BTN did not record any incidents of personal data protection
failure, tangible evidence of BTN’s commitment to maintaining privacy and protecting
customer data to the highest standards. Furthermore, BTN did not receive any similar
complaints, either from regulatory authorities or institutions responsible for monitoring
and overseeing banking sector regulations. [GRI 418-1]
The Bank’s Internal Audit Division (SKAI) carried out audits focused on cybersecurity
and applications, including data security, through its Information Technology (IT) Audit
activities. These covered mandatory audits required by regulators, such as security audits
of BI Payment System applications, cybersecurity risk management, and data security
management, as well as thematic audits of critical applications covering the validity of
information processing, data integrity, and the security of applications and data. All of
these audit activities were conducted in accordance with the Annual Audit Plan.
Additional information is available at the following link: Data Collection, Use, Storage, and
Retention Policy.
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Debt Collection Policy
A Standalone Debt Collection Policy is a structured and transparent guideline for collection BTN ensures that each stage of the collection process is implemented systematically,
activities, aligned with responsible and sustainable banking practices designed to protect starting from data review and verification, debtor confirmation, collection execution, to
consumer rights while safeguarding business sustainability through the application of reporting of results. Complete and validated documentation is mandatory, including
GCG principles. All employees and authorized parties involved in collection activities request memoranda, collection reports, invoices, and payment reconciliation evidence.
are required to uphold ethical standards, respect debtor rights, and conduct collection Payment of success fees to third parties is made only upon realization of debtor payments
professionally in accordance with applicable regulations. and fulfillment of all documentation requirements. All collection processes are conducted
while respecting debtor rights and privacy, without physical or verbal coercion, and in
The Standalone Debt Collection Policy refers to Special Policy (KK) No. KK.1R and Technical accordance with prescribed timing and communication channels.
Guideline (PT) No. PT.1-R.1 on Consumer Segment Credit Collection Management
Procedures. These provisions regulate collection workflows through multimedia channels, To ensure consistent implementation regular annual training and certification programs
success fee mechanisms, verification and reconciliation processes, and payment for employees and collection development materials basic collection practices, collection
procedures, to ensure that collection activities are structured, documented, and negotiation techniques, fraud prevention strategies, and operational risk management in
compliant with internal policies and applicable laws. For further information, please visit collection activities.
the following link Debt Collection Policy.
As part of continuous strengthening, BTN has developed the Strategic Collection &
BTN manages consumer credit collection and resolution in accordance with the principles Recovery Excellence (SCORE) Program through the Collection Academy, designed in
of prudence and GCG covering collection activities, restructuring, settlement, and write- stages from basic, intermediate, to advanced levels. The program applies the 10–20–70
offs of consumer loans, conducted professionally, responsibly, and oriented toward credit learning model (10% formal learning, 20% social learning, and 70% experiential learning)
risk mitigation and the achievement of business targets. Collection activities are through and is supported by learning evaluation mechanisms to ensure effective competency
desk collection, direct visits to debtors, and cooperation with collection service partners development. Through this approach, BTN also builds structured career pathways and
based on a success fee mechanism, with an emphasis on debtor data validity, tiered continuously develops a talent pool in the collection function.
approvals, verification, and payment reconciliation.
Details of training and certification conducted during the reporting period are presented
in the table below.
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Employee Training and Certification Related to Debt Collection Policy [GRI 404-2]
Training Name Implementation Date Number of Employees Participating Total Training Hours
Collections Refreshment for Branch Managers January 72 576
SCORE collection February - September 756 6,059
Collection academy level basic April & July 128 1,512
Collection academy level intermediate October 91 1,456
Integrated collection excellence 2025 June - August 79 1,894
Collateral Verification and Valuation Techniques July 233 1,398
Asset Sales Strategy & Credit Settlement August 30 481
Consumer Credit Restructuring Analysis August 26 416
Internalisation of the Collections Code of Ethics October 567 183
Commercial Financing Restructuring (Sharia Banking) October 102 1,854
Commercial Credit Restructuring and Exit Strategy November 31 496
Compliance Excellence – Consumer Collection December 12,271 3,060
Offering of Loan Modification Options
In line with the implementation of customer financial protection and ethical collection Restructuring options offered refer to OJK Regulation (POJK) No. 40 of 2019, including:
practices, BTN provides loan modification options that include income-based 1. Adjustment of Repayment Schedule
considerations and customer access to escalation options for those experiencing financial 2. Temporary Reduction of Loan Interest
difficulties through a restructuring program. Available schemes include adjustments to 3. Principal Payment Moratorium
repayment schedules, temporary reductions in loan interest, and principal payment
moratoriums, with the objective of achieving a balanced solution for both the Bank and Applications are submitted through a debtor’s formal request and subsequently reviewed
the debtor. The restructuring process begins with discussions between the debtor and the by the risk management team. If approved, BTN issues an approval letter in accordance
account officer or Relationship Manager. Debtors may also obtain information regarding with the agreed scheme, enabling the debtor to obtain payment relief while ensuring that
restructuring through OJK. Upon approval, BTN issues a Restructuring Approval Letter that credit risk remains properly managed.
sets out the applicable scheme, terms, and conditions.
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Digitalization
Handling of Financial Product Complaints [GRI 413-2] [OJK F.24]
Transparency and open communication are key to BTN’s efforts to build stakeholder trust. Customer Complaint Mechanism
Accordingly, the Bank provides accessible, responsive, and effective communication
channels that allow stakeholders, including local communities, to submit feedback, Timely and accurate handling of complaints is critical in maintaining service quality
suggestions, and complaints related to the Bank’s operations. These channels also and the customer experience. Special Policy (KK) No. KK.9-K on Customer Complaints is
serve as a dialogue platform to accelerate responses and promote collaborative issue the guideline for complaint management through which the Bank provides complaint
resolution. [OJK F.24] channels accessible to customers across all work units, enabling complaints to be
submitted anytime and from anywhere, without dependence on the branch where
Consistent management of these channels supports BTN in maintaining constructive the customer was initially registered. Complaints may be submitted orally or in writing
relationships with stakeholders while managing the impacts of decisions and operational through various channels, including:
activities in a measurable manner. Throughout the reporting period, the Bank receive no
complaints related to its operations or any negative impacts arising therefrom.
Customer Complaint Channels
Complaints submitted via Contact Center
Complaints submitted directly to BTN at phone number 150286 or 1500286 and the
through Regional Offices, Branch Offices, Bank’s email: btncontactcenter@btn.co.id Complaints submitted through the
1. 2. 3.
Sub-Branch Offices, divisions at Head (Complaints submitted through other Financial Services Authority (OJK), Bank
Office, and the Board of Directors. channels, such as live chat or electronic/ Indonesia, and other institutions.
social media, will be redirected through BTN
email or contact center).
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Digitalization
Customer Complaint Handling Flow
1. 2. 3. 4. 5. 6.
Customer Submits a Customer Data Customer Receives a Follow-Up Process by Complaint Resolution Dissatisfied Customers
Complaint Verification Complaint Reference BTN Completed Escalating to LAPS SJK
Number
The customer submits a The Bank verifies The Bank records the BTN follows up and If the customer agrees Customers who do not
complaint through the customer data in complaint and provides resolves the complaint with the resolution agree with the resolution
channels provided by accordance with a complaint ticket within the stipulated outcome, the complaint may escalate the case
BTN. established procedures. number to the customer. timeframe. is deemed resolved. to the Alternative Dispute
Resolution Institution for
the Financial Services
Sector (LPAS SJK).
To ensure effective complaint handling, BTN collaborates with external parties, including 3. Specialized Employee Training
the Ombudsman and the National Consumer Protection Agency (BPKN), to accelerate BTN conducts complaint-handling training for employees.
timely and accurate complaint resolution while maintaining service credibility. This 4. Enhanced Transparency
collaboration supports the implementation of an Ombudsman-based complaint BTN is committed to periodically reporting complaint statistics, resolution rates, and
handling system, which includes: customer feedback as part of transparency efforts.
1. Integrated Complaint Channels
BTN provides multiple complaint channels, including balé by BTN, call center, and Service quality consistency is supported by the implementation of a validated
physical branches, in accordance with OJK service standards. management system through ISO 9001:2015 certification, which covers Contact
2. Clear Escalation Procedures Center Service Quality Standards and Customer Protection and Complaint Handling
Complaints unresolved at the operational level are subject to evaluation to ensure Management. This validation ensures that contact center services as a complaint channel
independent and accountable resolution. and complaint handling processes are standardized, structured, and documented during
the reporting period.
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Oversight of Customer Complaint Management
The BTN Risk Monitoring Committee at the Board of Commissioners level oversees customer mediation, or litigation, in accordance with applicable regulations. This provision supports
complaint management as part of operational risk management, coordinating with the the management of legal and reputational risks while safeguarding the Bank’s credibility.
Director of Operations to receive complaint performance reports from the Experience Through the application of prudential principles and continuous evaluation, BTN is
Division Unit. This mechanism is used to identify potential risks, ensure appropriate follow- committed to improving the quality of complaint handling and maintaining customer
up, and continuously improve processes so that emerging risks can be minimized and satisfaction and trust.
complaint management remains effective and efficient.
To provide a measurable overview of complaint handling performance, BTN presents a
If a complaint cannot be resolved and escalates into a dispute, customers may pursue recap of the number of complaints, resolution rates, and handling status by product/
dispute resolution mechanisms through authorized institutions, including arbitration, service category in the table below.
Customer Complaint Data
2025 2024 2023
Complaint Category Total Resolved In Process Total Resolved In Process Total Resolved In Process
Complaints Total % Total % Complaints Total % Total % Complaints vTotal % Total %
Funding Products 1,574 1,455 92.44 119 7.56 1,064 654 61.47 410 38.53 318 318 100.00 0 0.00
Lending Products 759 543 71.54 216 28.46 461 324 70.28 137 29.72 208 206 99.04 2 0.96
Partnership Products 4 4 100.00 0 0.00 15 12 80.00 3 20.00 8 8 100.00 0 0.00
Other Products 2,084 1,629 78.17 455 21.83 1,259 808 64.18 451 35.82 812 706 86.95 106 13.05
Payment Systems 68,195 63,032 99.76 163 0.24 90,198 89,385 99.10 813 0.90 61,261 61,261 100.00 0 0.00
Total 72,616 71,663 98.69 953 1.31 92,997 91,183 98.05 1,814 1.95 62,607 61,137 97.64 108 0.17
Resolution Rate 98.69% 98.45% 99.83%
Notes:
• Funding Products category: savings, time deposits, current accounts, etc.
• Lending Products category: subsidized loans, non-subsidized loans, working capital loans, etc.
• Partnership Products category: bancassurance, mutual funds, retail government bonds (ORI), etc.
• Other Products category: officer services, bank guarantees, facility provision, etc.
• Payment Systems category: ATM, mobile banking, internet banking, etc.
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Customer Satisfaction
The Bank maintains product and service quality while ensuring equal access and fair Furthermore, BTN’s marketing communication activities are conducted in accordance
treatment for all customers without exception. Policies and service standards are with applicable regulations to ensure that product and service information is delivered
applied comprehensively across all service touchpoints to ensure a consistent customer accurately and does not cause misperception. During the reporting year, there were
experience and to build sustainable trust in the Bank. [OJK F.17] no negative impacts arising from BTN’s products or services, no products withdrawn
or cancelled, and no instances of non-compliance related to product and service
BTN’s efforts to maintain customer satisfaction include: information or labeling. BTN also received no reports of breaches related to marketing
1. Offering products and services in accordance with established quality standards; communications during 2025. [GRI 3-3, 417-2, 417-3] [OJK F.28, F.29]
2. Providing the best service to all customers and following up on every complaint fairly
and without discrimination; To monitor customer experience and the effectiveness of service standards, BTN uses
3. Conducting service promotion that is healthy, fair, honest, non-misleading, and third-party surveys, namely the Customer Experience Index (CEI) and Net Promoter Score
aligned with generally accepted social norms; (NPS). CEI measures satisfaction, engagement, and loyalty as the average of the Customer
4. Implementing fair trade practices in accordance with BTN policies, namely: [FS15] Satisfaction Index (CSI), Customer Loyalty Index (CLI), and Customer Engagement Index
a. Special Policy No. KK.2-L on Retail Funding Services; (CGI), while NPS assesses loyalty based on customers’ likelihood to recommend BTN’s
b. Technical Guideline PT.2-C.1 on Foreign Exchange Transfer Service Fees; and products or services. The measurement results are used to understand service usage
5. Ensuring that all employees support the Bank’s efforts to achieve customer behaviour, capture customer needs and expectations, and set improvement priorities.
satisfaction and trust. CLI covers referral, repurchase, retention, advocacy, and loyalty, while CGI is influenced
by trust, fairness, pride, and passion.
In addition to ensuring consistent service delivery, BTN provides product information
clearly and transparently, including product name and type, features, benefits, risks, usage The results show improvements across several customer categories in the CEI survey. In
procedures, fees, and other terms, to enable customers to make informed decisions. To 2025, BTN’s CEI reached 80.85, up 3.81%, with CLI at 80.23, increasing by 5.89%, and CGI at
ensure compliance with product labeling and information procedures, BTN conducts 81.56, rising by 6.98% compared with the previous year. These achievements were also
internal review and approval of all information materials before publication through reflected in external assessments through the Satisfaction Loyalty Engagement (SLE)
official channels. Compliance assessment covers 100% of product and service categories index survey at the end of 2025, where BTN ranked first in the NPS category for KBMI 3
marketed to customers, including deposit products, loans/financing, transaction services banks with a score of 50, up 8.49% year-on-year. This improvement highlights stronger
and digital channels, and other service offerings. [GRI 3-3, 417-1] [OJK F.27] customer loyalty and a higher likelihood of customers recommending BTN’s services, in
line with rising satisfaction levels. [OJK F.30]
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07
Strengthening Governance
as the Foundation
of Sustainability
192 BTN Sustainability Governance
Structure
197 Commitment to Governance
Implementation
200 Governance Strategy
201 Governance, Risk, and Compliance
Roadmap
208 Nomination Process of the Highest
Governance Body
212 Performance Evaluation of the
Highest Governance Body
213 Risk Management
248 Code of Conduct and Business
Ethics
252 Anti-Fraud and Conflicts of Interest
256 Implementation of the Principle of
Prudence
258 Internal Control and Anti-
Gratification
260 Whistleblowing System
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BTN Sustainability Governance Structure [GRI 2-9, 2-10, 2-11, 2-12, 2-13]
BTN Governance Structure
BTN’s governance structure established in accordance with
Law No. 40 of 2007 on Limited Liability Companies stipulates
General Meeting of
three main governing bodies, namely the General Meeting
Shareholders (GMS)
of Shareholders (GMS), the Board of Commissioners, and the
Board of Directors whose establishment ensures a clear division
of duties and responsibilities, while supporting the checks and External Audit Board of
Board of Directors
Commissioners
balances mechanism required to implement good, effective, and
accountable corporate governance practices.
Corporate Secretary
Within this framework, the Board of Commissioners supervises
Risk Management
the Bank’s management and provides strategic guidance to Audit Committee Internal Audit
Committee
the Board of Directors, including compliance with applicable
regulations and internal policies and safeguarding shareholders’ Asset & Liability
Risk Monitoring Other Work Units
Committee (ALCO)
interests. The Board of Directors is responsible for the Bank’s Committee
overall management and day-to-day operations, the formulation Credit Committee
and execution of strategy, and performance reporting to the
Credit Policy Committee
Board of Commissioners. Collectively, the Board of Directors
Remuneration
leads the achievement of BTN’s vision and mission in line with the & Nomination IT Steering Committee
mandates of shareholders and stakeholders, while the Board of Committee
Human Capital Committee
Commissioners ensures the consistent application of GCG and
ESG principles through its oversight and control functions. Business Committee
Transformation Steering
Committee
ESG Committee
Integrated Risk
Management Committee
Capital & Subsidiary
Committee
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General Meeting of Shareholders (GMS) [GRI 2-11] Board of Commissioners
The GMS is the highest governing body and holds authorities that are not delegated to Oversight of the Bank’s management is exercised by the Board of Commissioners whose
the Board of Directors or the Board of Commissioners in accordance with Law No. 40 role includes reviewing the policies and performance of the Board of Directors and
of 2007. Through this forum, Shareholders are entitled to obtain information, evaluate providing strategic direction to safeguard the interests of the Bank and its shareholders,
the performance of the Board of Commissioners and the Board of Directors, and while taking into account stakeholder expectations.
approve the Bank’s policies and strategic decisions. In relation to the management of
economic, environmental, and social impacts, the Bank engages Shareholders through To ensure effective oversight, the Board of Commissioners has supporting committees
the submission and discussion of sustainability plans and performance at the Annual that report directly to them. All roles, authorities, and working mechanisms of the Board of
GMS to obtain direction and approval. These plans are prepared by the Board of Commissioners are carried out in accordance with Law No. 40 of 2007, Law No. 7 of 1992,
Directors, reviewed and approved by the Board of Commissioners, and then presented to and applicable regulatory provisions, including those issued by the Financial Services
Shareholders as a form of accountability. [GRI 2-11, 2-12] Authority, Bank Indonesia, and BTN’s Articles of Association.
BTN holds Annual GMS and Extraordinary GMS. The Annual GMS is held no later than six Composition of BTN Board of Commissioners
months after the end of the financial year, while the Extraordinary GMS may be held at
Basis of Effective Date Approved
any time as required by the Bank. In the 2025 financial year, BTN held two Annual GMS, Name Position Gender
Appointment by OJK
with the following details: Suryo Utomo President Male Annual GMS dated 26 June 2025
Commissioner 26 March 2025
Convening of BTN GMS Dwi Ary Purnomo Vice President Male Annual GMS dated 26 June 2025
Commissioner 26 March 2025
Description Date and Time Venue
Fahri Hamzah Commissioner Male Annual GMS dated 17 December 2025
Annual GMS 26 March 2025 Menara BTN, Jakarta 26 March 2025
Extraordinary GMS 18 November 2025 Menara BTN, Jakarta Ida Nuryanti Independent Female Annual GMS dated 9 October 2025
Commissioner 26 March 2025
Pietra Machreza Independent Male Annual GMS dated 15 August 2025
Paloh Commissioner 26 March 2025
Panangian Independent Male Annual GMS dated 15 August 2025
Simanungkalit Commissioner 26 March 2025
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The Board of Commissioners holds regular meetings to ensure that the oversight function Percentage of Attendance at Board of Commissioners’ Meetings
is carried out effectively and in line with the GCG principles. Each meeting documents
attendance, which serve as the basis for assessing members’ participation in strategic Number of Board of Commissioners’ Meetings Average Attendance Percentage
53 100%
decision-making processes and in overseeing the Bank’s operations.
Board of Directors
The Board of Directors is responsible for directing operations, strategy, and asset The appointment of members of the Board of Directors the GMS based on the
protection to achieve the Bank’s objectives in a sustainable manner. Management is recommendation of the Remuneration and Nomination Committee, with a five-year term
reported to the Board of Commissioners, with the appointment of the Board of Directors of office that may be extended for one additional term. The GMS has the authority to
determined through the GMS and effective as of the closing of the GMS. dismiss members of the Board of Directors before the end of their term in accordance
with applicable regulations.
Composition of BTN Board of Directors
Name Position Gender Basis of Appointment Effective Date Approved by OJK
Nixon L. P. Napitupulu President Director Male Annual GMS dated March 16, 2023 June 7, 2023
Oni Febriarto Rahardjo Vice President Director Male Annual GMS dated March 16, 2023 June 7, 2023
Setiyo Wibowo Director of Information Technology Male Extraordinary GMS dated November 27, 2019 July 3, 2020
Hirwandi Gafar Director of Treasury & International Banking Female Extraordinary GMS dated November 27, 2019 August 28, 2020
Nofry Rony Poetra Director of Corporate Banking Male Annual GMS dated March 10, 2021 August 9, 2021
Eko Waluyo Director of Risk Management Male Annual GMS dated March 10, 2021 August 9, 2021
Tan Jacky Chen Director of Consumer Banking Male Annual GMS dated March 26, 2025 September 1, 2025
Venda Yuniarti Director of Finance & Strategy Male Annual GMS dated March26, 2025 September 1, 2025
Helmy Afrisa Nugroho Director of Human Capital & Compliance Male Annual GMS dated March26, 2025 Still undergoing the Fit and Proper Test process.
I Nyoman Sugiri Yasa Director of Operations Male Annual GMS dated March26, 2025 July 25, 2025
Rully Setiawan Director of Network & Retail Funding Male Annual GMS dated March26, 2025 July 25, 2025
Hermita Director of Commercial Banking Female Annual GMS dated March26, 2025 July 25, 2025
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The Board of Directors is responsible for the Bank’s management and administration to 6. Credit Committee
achieve its purposes and objectives in accordance with prevailing laws and regulations, 7. Business Committee
the Articles of Association, and resolutions of the GMS. The Board of Directors represents 8. Transformation Steering Committee
the Bank both in and out of court and ensures that management is conducted effectively 9. ESG Committee
and in alignment with the Bank’s vision, mission, and strategies. The management of the 10. Integrated Risk Management Committee
Bank is led by the President Director, who serves as the principal coordinator in decision- 11. Capital & Subsidiary Committee
making and leadership of the Board of Directors, with duties that include:
1. Leading meetings of the Board of Directors. The Board of Directors has supporting units such as the Corporate Secretary, Internal
2. Fostering a culture of openness and facilitating constructive discussions. Audit Unit, and Risk Management Unit to ensure more integrated management of the
3. Providing advice to members of the Board of Directors regarding the effective Bank. Scheduled meetings of the Board of Directors are complete with attendance
performance of management duties. records serving as the basis for assessing members’ participation in strategic decision-
4. Maintaining relationships and cohesion among members of the Board of Directors in making processes and oversight of the Bank’s operations.
the execution of management responsibilities.
5. Maintaining effective and sound relationships with the Board of Commissioners.
Percentage of Attendance at Board of Directors’ Meetings
Each member of the Board of Directors bears collective responsibility for losses arising Number of Board of Directors’ Meetings Average Attendance Percentage
from errors or negligence in the performance of their duties. A release from liability may
183 85.23%
be granted if a member of the Board of Directors can demonstrate that:
1. The loss was not caused by their error or negligence.
2. They have carried out management duties in good faith, with full responsibility and
due care, in the interests of and in accordance with the purposes and objectives of
the Bank.
3. They have no conflict of interest, either directly or indirectly, in the management ESG Committee
actions that resulted in the loss.
4. They have taken actions to prevent the occurrence or continuation of such loss. As part of its commitment to implementing a structured sustainability approach, BTN
established an ESG Committee at the board level, chaired by the President Director and
To support the effective performance of its duties, the Board of Directors is assisted by the comprising members of the Board of Directors and SEVPs. The Committee functions to
following committees: ensure that environmental, social, and governance considerations are integrated into
1. Asset & Liability Committee the Bank’s policies and to support the achievement of the SDGs and the Bank’s climate
2. IT Steering Committee targets.
3. Risk Management Committee
4. Human Capital Committee The ESG Committee is responsible for formulating ESG and CSR policies, strategies, and
5. Credit Policy Committee program objectives, including oversight of sustainability-related risks and opportunities.
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The Committee establishes strategic decisions in the implementation of programs and regulations, government programs, international developments, future business
through meetings held on a regular basis, and has the following duties and responsibilities: trends, and climate change.
1. Establishing improvement measures related to ESG and CSR programs, including 5. Monitoring, evaluating, and providing recommendations on ESG reports, investor
community development programs, Micro and Small Business Financing (PUMK), the concerns, or feedback from other third parties regarding ESG implementation.
Sustainable Finance Action Plan, and business activities undertaken as part of the 6. Making decisions related to:
Bank’s responsibility to society for business risks arising from the Bank’s operations, a. The objectives and implementation guidelines of the CSR Program.
and reporting these to the Board of Directors. b. The mapping and formulation of the CSR Program.
2. Making decisions on the Bank’s strategies that have impacts on environmental, c. The evaluation of the implementation of the CSR Program.
social, and community aspects within the ESG Program and Roadmap.
3. Monitoring the implementation of the Bank’s ESG Strategy and Roadmap. The ESG Committee is governed by Special Policy No. KK.9-D on the Governance
4. Providing information to Bank management on all ESG-related issues, including laws Procedures of Board Committees, with the following committee composition:
BTN ESG Committee Structure
Structure Position
Chairperson President Director
Members • Vice President Director *)
• Director overseeing Risk Management **)
• Director overseeing Finance & Strategy
• Director overseeing Information Technology
• Director overseeing Human Capital & Compliance
• Director overseeing Operations
• Director overseeing Treasury & International Banking
• Director overseeing Consumer Banking
• Director overseeing Network & Retail Funding
• Director overseeing Corporate Banking
• Director overseeing Commercial Banking
• SEVP overseeing Business Digital
• SEVP overseeing Assets Management
• SEVP overseeing Credit Risk
*) Acting Chair I
**) Acting Chair II
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Commitment to Governance Implementation
BTN places GCG as a fundamental principle in conducting its business and managing The implementation of GCG at BTN is guided by the applicable regulatory framework
the organized manifested through the integration of transparency, accountability, and in the banking sector, capital markets, and SOEs, including provisions issued by the
integrity values into every operational process and decision-making activity, enabling Financial Services Authority (OJK), Bank Indonesia, the government, and the Bank’s
the Bank to maintain public trust and responsibly achieve its long-term objectives. Articles of Association. All serve as the basis for ensuring that governance is implemented
consistently and in compliance with prevailing regulations. BTN also adopts various
BTN ensures that all control mechanisms, risk assessment processes, and oversight governance standards recognized at both regional and international levels to broaden
structures operate effectively to support disciplined operations that are free from the scope of GCG implementation. These standards include:
conflicts of interest. This helps to minimize the potential for fraud and ensures that
strategic decisions are aligned with stakeholder interests and best practices in the
banking industry.
Corporate governance ASEAN Corporate Indonesian Code of Indonesian Banking Principles for Enhancing
principles of the Governance Scorecard Corporate Governance GCG Guidelines issued Corporate Governance
Organisation for Economic issued by the ASEAN Capital (PUGKI) issued by the by KNKG. issued by the Basel
Co-operation and Markets Forum (ACMF). National Committee on Committee on Banking
Development (OECD). Governance Policy (KNKG). Supervision.
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The implementation of GCG sustainable value for the Bank, going beyond a purely Objectives of Implementing GCG Principles
compliance-oriented approach by strengthening the quality of decision-making and
organizational performance. As a form of transparency and accountability, BTN provides
public access to its governance policy commitments and internal control framework
through the Bank’s official website. This includes key policies related to corporate
governance, internal control and audit, risk management, business ethics and code of To support BTN’s vision
conduct, as well as anti-bribery and gratification control, and can be accessed at this link and mission.
Governance Policy. [GRI 2-23]
Governance Commitment and Principles
To provide benefits and added To maintain and enhance
GCG principles are applied consistently across all work processes to ensure that the value for shareholders and sustainable, sound, and
Bank’s operations are conducted in a transparent and accountable manner and aligned stakeholders. competitive business continuity
with the Bank’s vision and mission. For shareholders, this is reflected in the professional over the long-term (sustainable).
and transparent management of the Bank. Accordingly, BTN ensures that every decision
and business activity is carried out in accordance with the principle of accountability to
meet stakeholder expectations.
BTN believes that business sustainability depends on sound internal management.
Through the application of GCG principles, the Bank seeks to maintain a balance between
commercial objectives and social responsibility to generate both short-term and long-
term value for all stakeholders. To ensure continued relevance, BTN refers to governance
practices recognized at the national, regional, and international levels, supporting the
Bank’s readiness to respond to the dynamics of the banking industry and strengthening
organizational resilience.
To increase investor
confidence in BTN.
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BTN is committed to consistently applying GCG principles across all business and primary guideline to ensure that the Bank is managed in a transparent, accountable, and
operational activities. This implementation is based on OJK Regulation (POJK) No. 17 of compliant manner. The GCG principles implemented by BTN include:
2023 on the Implementation of Governance for Commercial Banks, which serves as the
GCG Principles
Transparency Accountability Responsibility Independency Fairness
Openness in decision- Clarity of functions and Compliance with laws Independent and Fair fulfillment of
making and the provision accountability of each and regulations, ethical professional management stakeholders’ rights
of relevant information Bank organ to support standards, and principles of of the Bank, free from in accordance with
regarding the Bank. fair, effective, and efficient sound banking operations. conflicts of interest or undue agreements, regulations, and
performance. influence. sound business principles.
GCG implementation serves as a foundation for BTN in enhancing performance and As part of this commitment, BTN strengthens GCG to align with the needs of modern
accountability, while ensuring the Bank delivers long-term value to shareholders by governance and remain relevant to business sustainability. The Bank strives to manage
taking into account the interests of stakeholders. This is conducted in accordance with all business activities in a professional and ethical manner, supported by competent
applicable regulations and business ethics standards, particularly in addressing the human resources who uphold high standards of work ethics.
increasing complexity of risks.
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Governance Strategy
To ensure that GCG is consistent and supports the established strategic direction, BTN has
defined the GCG Pillar as the main framework for integrated governance management.
The pillar serves as a reference in formulating governance strategies, encompassing
the strengthening of commitment, structuring of governance bodies, management of
processes, and achievement of governance outcomes. This framework is elaborated as
follows:
BTN GCG Pillars
Governance Governance Governance
Structure Process Outcome
Commitment on Governance
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Governance, Risk, and
Compliance Roadmap Corporate Plan 2025 - 2029
1. Gap Analysis in Risk 2. Gap Analysis in Digital 3. Gap Analysis in ESG 4. BTN Top Risk Indicator
Maturity Maturity Aspects Projection 2025-2029
Diagnostic SWOT Analysis
With GCG Pillars as its foundation, BTN has expanded Stream Analysis Diagnostic Gap Analysis
Results Result
implementation through the strengthening of risk
management and compliance. To ensure that
Phase 1: Diagnostic Process
governance remains effective and adaptive, the Strategic Business Process
Funding
Directions SWOT
Governance, Risk, and Compliance (GRC) Roadmap 2025–
Gap Analysis Governance & Analysis
2029 strengthens governance, risk, and compliance, and Gaps Between Organizational (Result)
Lending External Analysis Existing Conditions Structure
drives operational efficiency, sustainable profitability,
(Business and Ideal
and the enhancement of digital services. The Bank has Trends), Conditions, Infrastructure, IT, &
developed a framework as a guideline for formulating Regulation, Constraints,
Operational Data
and/or Internal Key
or Obstacle
the GRC Roadmap, as illustrated in the following chart: Analysis Best Encountered
Watch-Out
People Capabilities & Strategy
Practices/
Risk Design
Benchmarking
Interconnectivity GRC Culture
Strategic Postures for GRC Roadmap
Strategic
Postures
Phase 2:
To Support Business Growth and To Drive Resilience & Secure To Ensure Competency of GRC
Sustainability Operational For Business Continuity Talent and Strong GRC Culture
Implementation Plan
Implementation Plan & Execution Setup
Phase 3:
Implementation Plan Execution Setup
Initiative Charter - Strategic Initiative & Timeline PMO, Tracking Tools, Empower
& Change Management
Governance Risk Compliance Implementation (2025-2029)
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
BTN designed the GRC Roadmap as a strategic framework to manage risk, compliance, the importance of transparency, accountability, and efficiency as a foundation for
and governance in an integrated manner strengthe the Bank’s ability to identify, assess, sustainable growth.
and mitigate risks at an early stage in order to maintain operational and financial stability
amid regulatory dynamics. The Corporate Plan 2025–2029,comprises four main elements as guidelines for the
development of the Bank’s performance, strengthening the Bank’s position in the national
The GRC Roadmap also serves to ensure that compliance is implemented adaptively, housing market while supporting the realization of inclusive and sustainable economic
enabling BTN not only to meet legal requirements but also to leverage policy changes as growth. These four elements include:
opportunities to enhance competitiveness. Through this approach, the Bank underscores
Main Elements of the Corporate Plan 2025–2029
BTN 2029 Aspirations to Achieve the
Vision, Mission, and Values BTN Plan: 1+3+5 Strategic Initiatives Strategic Initiatives
Vision
Reflecting BTN’s purpose and core Describing the Bank’s aspirations Explaining a structured approach Detailing the specific initiatives to
values and ambitions for the next five and key priorities in achieving the be implemented to support the
years objectives Bank’s strategy
BTN 2029 Aspirations to Achieve the Vision 1. Building a Sustainable Savings Engine to Mobilize Rp120 Trillion in Savings
BTN has targeted the mobilization of Rp120 trillion in third-party funds by capturing 3%
BTN’s vision and mission outlines the Bank’s strategic direction, with the 2025 vision, to of savings from the 20 largest provinces. This is supported by the launch of innovative
become the main partner in empowering the financial well-being of Indonesian families, propositions for the payroll segment, first-time homebuyers, and self-employed
underscoring a commitment to expanding access to financial services and enhancing professionals, as well as the strengthening of transaction capabilities to become the
the economic capacity of society. To realize this vision, BTN has formulated the 2029 primary bank for retail and business customers.
Aspirations as a roadmap toward achieving the Bank’s vision through five strategic focus 2. Empowering Indonesian Families through Housing Loan Distribution to Realize
areas that reflect innovation integration, operational efficiency, and sustainability into the Homeownership Aspirations with Approximately Rp450 Trillion in Disbursements
Bank’s business strategy and execution. These aspirations include: Housing loan disbursements of approximately Rp450 trillion, including support for
1.2 million subsidized mortgage (KPR) customers and 290 thousand non-subsidized
mortgage customers are the target. This program also involves empowering 27
thousand housing-related MSMEs through solutions that support the entire business
cycle.
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3. Becoming a Financial Partner for Consumers BTN Plan: 1+3+5 Strategic Initiatives
and Businesses by Providing a Comprehensive
Range of Everyday Banking Solutions To support BTN’s 2029 Aspirations in achieving its vision is the BTN Plan: 1+3+5 Strategic Initiatives, which consists of 1 New core
This includes strengthening the consumer strength pillar, 3 Holistic banking proposition pillars, and 5 Capabilities to deliver at scale pillars.
portfolio through high-margin loans (targeting
8% of the portfolio), developing investment 1 Core Strength 3 Holistic banking propositions 5 Capabilities for success at scale
and payment solutions, and expanding non-
Funding Housing ecosystem Digitization
housing loans (18% of the portfolio). BTN has also • Increase low-cost transactional deposits • Maintain ~60% share in subsidized • Strengthen transaction banking capabilities
targeted increasing fee-based income (FBI) to (CASA) through payroll (target 5% mortgages (KPR) by developing an to deliver new propositions such as payroll
penetration) and higher customer innovative distribution model. and CMS.
approximately 20% of total income and optimizing engagement in mobile banking (~3+ • Grow new customer acquisition through • Digitize four priority lending customer
the conversion of mortgage customers into full- million customers). mortgages, reaching ~1.2 million journeys to scale faster and improve
• Deepen presence in key micro markets subsidized KPR customers and ~0.3 efficiency.
service banking users.
(top 20 cities). million non-subsidized KPR customers • Drive branch efficiency through a no-ops
4. Building a High-Quality Portfolio with • Build a tailored proposition for ~70,000– (cumulative), and strengthen the Bank’s model to achieve CIR <50%.
Operational Efficiency 300,000 high-potential professional role as the primary banking partner. • Enhance front-line sales tools to accelerate
entrepreneurs who are cash-rich, • Deepen partnerships with 50+ established cross-selling.
BTN strengthens portfolio quality through more increasing wealth proposition penetration developers and increase value-chain
efficient digital operations, targeting a cost- and expanding the MSME merchant base. penetration through 25+ anchor clients.
• Capture a larger share of full-transaction Sales model
to-income ratio (CIR) below 50 percent and banking in SME & wholesale (target 20% Redesign the sales and operating model to
Full banking offering enable cross-collaboration (the One-CST
fostering a stronger service culture. Credit risk utilization).
• Increase cross-selling of HYL (target ~8% model) and improve effectiveness (including
• Scale up securitization and direct market
management is directed toward maintaining funding.
of total loans) and expand fee-based selected mono-line lines of business).
income from FTB consumer customers.
NPL below 2.3 percent through underwriting and
• Expand into new lending segments for Upskilling
collection processes supported by AI-based SMEs (including KUR and KUMK Build bank-wide capabilities for a more
technology. customer-centric sales culture through a
Sales Academy.
5. Expanding Service Coverage through Three Financial group
• Develop new funding sources to become
Subsidiaries the second-largest Sharia banking
Tech & data
BTN develops three subsidiaries, including scaling competitor and launch an insurance
• ccelerate modernization of core banking
subsidiary.
up the Sharia Bank to achieve the second-largest platforms to improve stability and speed of
• Establish a multifinance subsidiary to
execution.
national ranking, growing the multifinance improve margins and complement the
• Promote the development and adoption of
business with disbursement targets exceeding mortgage (KPR) offering.
advanced AI assets.
Rp2.5 trillion, and developing the insurance
business with a gross written premium (GWP) Risk Management
Strengthen risk underwriting and enhance
target of more than Rp2 trillion. collections and recovery (process, underlying
models, and technology infrastructure) to
maintain CoC <1.2%.
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Strategic Initiatives acquisition and transaction activity through BTN Mobile/balé, and the strengthening of
retail funding sales with high volume and growth potential.
Strategic initiatives drive sustainable growth and strengthen the Bank’s competitiveness,
strengthening funding, optimizing the housing ecosystem, transforming banking services, As part of monetizing the housing ecosystem, subsidized housing financing at 60% and
developing subsidiaries, and enhancing digital and human capital capabilities. The deeper partnerships with 50 key developers are a priority. This strategy is supported
details of these strategic initiatives are as follows. by the development of value-added banking products, yield enhancement, and the
strengthening of the Sharia business following the spin-off.
Strengthen Engine for Sustainable Funding (2025)
In addition, accelerating digitalization to reduce manual processes, enhance transaction
The strategic initiatives for 2025 are focused on developing a sustainable funding engine service capabilities, and sharpen sales effectiveness through measurable KPIs are
and optimizing the housing ecosystem to deepen market penetration and improve complemented by improvements to advanced data-based underwriting models and
product performance. Key priorities include the development of integrated payroll the strengthening of IT and digital capabilities to support a modern and reliable banking
products, housing product offerings for the millennial segment, increased customer platform.
Impact
No Initiative Objective Remarks
(as of December 2025)
1. Bundle Payroll Increase penetration among existing BTN corporates and NTB (New-to-Bank) by: 1. Growth in active payroll VoA DPK Will be continued and further developed
Proposition • Increasing the number of corporate and commercial companies with payroll systems. position: Rp6.1 trillion under the CASAvolution initiative –
• Increasing the number of payroll accounts. 2. Increase in active payroll NoA Increase payroll customer penetration
• Increasing SA and product holding from employees who are active and transact through position: 635,097 accounts in 2026.
payroll.
2. Geographical • Geographical play to intensify the retail funding sales footprint (internal and outsourced) in Increase in CASA (%) per branch: Will be continued and further developed
Play markets with strong SA volume and growth potential. Rp39.4 trillion under CASAvolution – Expand digital
• Increase SA by expanding BTN’s coverage in the top 20 cash-saturated areas to improve BFS **) Realization as of September 2025 (based store & sales footprint in 2026.
productivity. on BI data already released)
3. Retail Deposit • Increase CASA. 1. NoA position (cash-rich): 316 Will be continued and further developed
War Room • Improve efficiency of transactional customers. accounts under CASAvolution – Develop sector-
• Drive new customer acquisition, digital penetration, and transaction activity via balé, including 2. VoA position (cash-rich): Rp122.7 based solutions in 2026.
win-back for inactive customers and NTB acquisition. billion
4. Driving • Drive registration and utilization of transaction banking products through an integrated 1. eGuarantee volume: Rp5,899 Will be continued and further developed
Registration & platform, launch sector-specific solutions for prioritized, cash-heavy and trade-focused billion under Enhance Transaction Banking
Transactions segments and reactivate dormant accounts institutionally. 2. Trade & supply chain financing Capabilities in 2026.
• Increase CA balances from corporate and commercial segments. volume: Rp4,517 billion
• Increase fee-based income.
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Impact
No Initiative Objective Remarks
(as of December 2025)
5. Wholesale • Target wholesale and top SME customers to increase CASA penetration through campaigns 1. CA balance: Rp28.63 trillion (Large Completed in 2025.
Deposit War supported by advanced analytics. size), CA balance: Rp32.67 trillion
Room • Increase CA balances from mid-size corporates, commercial, and retail funding. (Mid-size)
• Operationalize the war room for key initiatives. 2. Active transaction banking users:
24,294
6. High Yield • Grow high-yield lending (KRING & KAR) by expanding the customer base through advanced 1. KRING disbursement: Rp2.045 Will be continued and further developed
Lending (KAR, analytics, improved credit scoring, consistent omni-channel experience, personalized trillion under Expand High-Yield Loan (HYL)
KRING & KUR) marketing, and automated top-up nudges. 2. KRING yield: 9.98% Portfolio in 2026.
• Grow high-yield lending (KUR) by expanding the customer base through personalized 3. KUR disbursement: Rp1.33 trillion
marketing. 4. KUR yield: 10.92%
• Increase KUR position while maintaining credit quality. 5. KAR disbursement: Rp1.673 trillion
6. KAR yield: 11.92%
7. Digitize Front- Digitize end-to-end customer journeys, including front-end application tools and integration with Project concept design has been Will be continued and further developed
End App and back-end systems, covering: defined for the Digitization stream in under Project Garuda in 2026.
Back-End 1. Consumer loan journey Branch Ops and Consumer Lending;
Processes 2. Branch operations, including back-office processes piloting and implementation will start
in 2026.
8. Automate • Automate branch servicing journeys and back-end operations to eliminate manual intervention Faster account opening service time: Will be continued and further developed
Branch Journey and enable a “No-Ops” environment where processes are simplified, digitized, and self- 12 minutes under Automate Branch Journeys &
and Back-End sustaining. Back-end Operations (Nexa Phase 2) in
Operations • Improve operational efficiency by increasing STP and reducing TAT (turnaround time). 2026.
9. Strengthen • Develop and enhance sales organization capabilities by revamping the network organization Average conventional DPK balance: Will be continued and further
Sales structure (Branch & Regional Office) and implementing the Central Sales Management (CSM) Rp342.48 billion developed under Accelerate
Organization model. Network Transformation & Workforce
and Sales • Explore short- and long-term approaches to improve the sales model and sales transformation, Development in 2026.
Performance while ensuring CSM implementation aligns with business priorities and improves sales
Model performance across retail, mid-size, and SME segments.
10. Client Service Develop the CST model to drive downstream business and value-chain plays from corporate/ 1. Payroll: 954 units Will be continued and further developed
Team (CST) large institutions while maintaining profitability. 2. KRING: 171 units under Implement Client Service Team
3. KAR & Non-subsidized KPR: 139 (CST) in 2026.
units
4. Subsidized KPR: 301 units
11. BPI Monoline Transition collection management from branch-based to monoline, enabling more focused, 1. NPL reduction (pilot area): 3.19% Will be continued and further developed
Collection & sustainable, and efficient processes. 2. Kol 2 reduction (pilot area): 9.4% under Improve Credit Quality through BPI
New CMS (Monoline Collection & NCS) in 2026.
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Broaden Product Propositions and Cross Selling (2026–2027) BTN develops holistic service tools such as RM workbench and CRM, supported by
advanced technology and analytics platforms, strengthened sales organizations, and
The 2026–2027 target period is focused on strengthening the sustainable funding engine, digitally and data-driven personalized customer journeys.
monetizing the housing ecosystem, and expanding products and cross-selling initiatives.
Key priorities include penetrating wealth offerings for cash-rich customers and hidden Strategic Initiatives Roadmap
affluent segments, developing solutions for self-employed professionals, and providing
merchant products for the retail food and restaurant sectors. BTN’s roadmap is a control framework for strategic initiatives to ensure that target
achievement is aligned with timelines, priorities, and resource capacity. Through this
In monetizing the housing ecosystem, BTN optimizes agent-based acquisition channels roadmap, implementation readiness is optimized, anticipating risks at an early stage
for secondary housing, deepens penetration of anchor corporate clients, and launches and ensuring that the execution of the BTN Corporate Plan 2025–2029 is measurable and
bundled products for the construction and real estate sectors. This is complemented by effective.
the development of fee-based products, the expansion of MSME financing in high-growth
and low-risk sectors, and the establishment of an insurance subsidiary through a joint Building a Holistic Framework / Actions for Sustainable Growth (2025)
venture scheme.
In 2025, BTN directs its strategic roadmap toward three main focus areas, namely:
As an enabler, BTN enhances digital marketing capabilities for cross-selling, strengthens • Support Business Growth & Sustainability
technology infrastructure and data analytics, and revitalizes underwriting and collection Optimizing the Bank’s asset and liability management (ALM) structure to support
through integrated omnichannel orchestration. sustainable business growth and enhance bank profitability.
• Drive Resilient & Secure Operations for Business Continuity
Deliver Full Banking Offerings with Superior Customer Experience (2028-2029) Ensuring resilient and secure operations by reducing cyber risks, improving the
effectiveness of Service Level Agreements (SLAs), and preventing fraud.
The 2028–2029 target period is focused on delivering a comprehensive banking offering • Ensure Competency of GRC Talent and Strong GRC Culture
supported by a superior customer experience. The funding strategy emphasizes cross- Developing employee talent and instilling a strong GRC culture to promote
selling to acquire the end-to-end housing value chain, expanding the ecosystem to organizational integrity and high performance.
cash-rich residential segments, industrial estates, and top APBN-related institutions, as
well as increasing the registration and utilization of TB products from 9% to 20% through The implementation of the 2025 roadmap is focused on developing a holistic risk
a single integrated platform. management framework to support balance sheet optimization, asset and liability risk
management, and the strengthening of credit risk through the integration of external
In monetizing the housing ecosystem, churn management and early repayments data using a more proactive and forward-looking approach. The integration of ESG
through centralized counter-offer teams are priorities, along with enhancing the value principles into banking operations is also accelerated, including reducing paper-based
and profitability of joint finance (B2B) schemes and channeling partnerships. To diversify processes through end-to-end digitalization of underwriting and verification.
products and services, BTN plans to establish a multifinance subsidiary.
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
In line with this, operational resilience is strengthened through enhanced data security, advances a strong GRC culture through enhanced leadership development, leadership
fraud detection systems, and regulatory compliance. On the human capital side, BTN forums, the implementation of dual career paths, increased professional certification, the
prioritizes leadership development, professional certification, and the internalization establishment of a Risk Academy, and the integration of GRC into talent management
of a GRC culture across all work units, including subsidiaries. All of these initiatives are and development systems.
designed to ensure sustainable growth, reliable performance, and solid corporate
governance throughout 2025. Accelerate iGRC (integrated Governance, Risk, and Compliance) Excellence
(2028-2029)
Driving Transforming and Effectivity through Advanced Analytics (2026-2027)
In the 2028–2029 period, BTN focuses its roadmap on balance sheet optimization,
The 2026–2027 target period is focused on transformation and enhanced effectiveness strengthening risk management, and enhancing operational effectiveness. Key initiatives
through the use of advanced analytics. In balance sheet optimization, Optimization include the implementation of a market and liquidity risk management system, the
models and a FTP system are implemented, while strengthening ESG-based credit risk integration of credit risk with advanced collection scoring through iLoan, and the
analytics and the use of external data. ESG principles are integrated into core banking strengthening of individual BWMK through Credit Decision Maker Certification. For strategic
operations, and the governance and risk management of subsidiaries are aligned with risk, risk-based capital allocation using the Risk-Adjusted Return on Capital (RAROC)
global standards. Process digitalization continues through data-driven decision-making, method improves performance efficiency and capital utilization, while accelerating ESG
strengthened model risk management using digital tools, and improved operational initiatives to achieve the position of an ESG Champion.
efficiency through the digitalization of inbound documents and sector-priority
mechanisms. On the operational and governance side are Early Warning systems, Stop & Go
Mechanisms, and Model Risk Management through iLoan, while strengthening operational
To further strengthen operational resilience in this advanced phase, oversight of third resilience through AI-based cybersecurity, enhanced data and IT compliance, and the
parties, data security, and fraud detection systems is in place, alongside enhancements reinforcement of zero-trust architecture for AI-based, mobile, and cloud applications. BTN
to risk management systems and regulatory compliance. During this period, BTN also strengthens governance related to AML, CFT, and PF-WMD, develops AI-based fraud
develops an asset and liability risk management framework with a focus on balance detection, and ensures the implementation of the GRC roadmap across all subsidiaries
sheet optimization, cost of funds reduction, and the strengthening of credit risk through through the enhancement of employee integrity and capabilities.
the implementation of core and non-core models. In the area of human capital, BTN
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Nomination Process of the Highest Governance Body [GRI 2-10]
The nomination process for members of the highest governance body involves Commissioners must be free from financial, management, ownership, affiliation, family,
shareholders through the GMS mechanism, as regulated under Special Policy Number business, or shareholding relationships that could impair their independence. The
KK.6-F on Corporate Governance Procedures, with selection and nomination conducted transition from Commissioner to Independent Commissioner may only take place after
transparently, taking into account recommendations from the Remuneration and the required cooling-off period has been fulfilled and approval has been obtained from
Nomination Committee. The appointment and dismissal of members of the Board of the Financial Services Authority through a fit and proper assessment. [GRI 2-10]
Commissioners and the Board of Directors are determined through resolutions of the
GMS. In assessing candidates for the Board of Commissioners and the Board of Directors, The term of office of members of the Board of Directors and the Board of Commissioners
the Bank refers to a set of criteria that includes integrity, honesty, professionalism, is set at 5 (five) years and they may be reappointed for one additional term. The term of
leadership experience, loyalty, and the availability of time to support the Bank’s progress. office of the Board of Directors takes effect from the date determined at the GMS until the
In addition, diversity, as well as expertise and experience in economic, environmental, and closing of the fifth Annual GMS, in compliance with prevailing capital market regulations,
social fields, are also key considerations. The Bank ensures that proposed candidates and members may be dismissed at any time by the GMS. The tenure of a Director ends
do not have financial, familial, or business relationships with members of the Board of upon the expiration of the term of office, resignation, death, dismissal by the GMS, or failure
Commissioners, the Board of Directors, or the Controlling Shareholder that could impair to continue to meet the required qualifications. Members of the Board of Commissioners
their independence. [GRI 2-10] may be reappointed by the GMS for one subsequent term.
Based on the Board of Commissioners’ Charter and Rules of Procedure Number 18/KOM/ Remuneration Policy of the Board of Commissioners and Directors [GRI
BTN/2024, the Bank has established criteria and requirements for Board of Commissioners 2-19]
candidates in accordance with the Bank’s Articles of Association and prevailing laws and
regulations. Candidates are required to pass the fit and proper test in accordance with BTN determines the remuneration of the Board of Commissioners and Directors by
OJK provisions and obtain approval from OJK, with at least one member domiciled in referring to the Regulation of the Minister of State-Owned Enterprises Number PER-13/
Indonesia. During their tenure, members of the Board of Commissioners are required to MBU/09/2021 concerning the Sixth Amendment to the Regulation of the Minister of SOEs
demonstrate integrity, competence, and a good reputation. Number PER-04/MBU/2014 on the Guidelines for Determining the Remuneration of the
Board of Directors, the Board of Commissioners, and the Board of Supervisors of SOEs. In
For Independent Commissioners, the Bank requires adequate knowledge and experience determining remuneration, the Bank also takes into account performance achievements
in the banking and/or financial sectors, as well as compliance with the applicable cooling- as well as the contributions of the Board of Commissioners and the Board of Directors in
off period for former members of the Board of Directors, Executive Officers, or other parties managing the Bank’s impacts on economic, environmental, and social aspects.
with relationships to the Bank, in accordance with prevailing regulations. Independent
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
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Procedure for Determining the Remuneration of the Board of Commissioners and Directors [GRI 2-20]
The Human Capital
The Board of Management Division The KRN formulates The GMS grants authority
The Board of
Commissioners assigns (HCMD), together remuneration The Board of and power to the Board of
Commissioners submits
the Remuneration and with relevant work recommendations for the Commissioners Commissioners to determine
the remuneration
Nomination Committee units, prepares the Board of Commissioners deliberates on the the remuneration, subject
proposal for the Board
(KRN) to conduct a remuneration proposal and Directors to be remuneration proposal to prior approval from
of Commissioners and
remuneration review. for the Board of submitted to the Board of submitted by the KRN. the Series A Dwiwarna
Directors to the GMS.
Commissioners and Commissioners. Shareholder.
Directors.
Within the remuneration determination framework, benchmarking and or salary surveys • The honorarium of the Vice President Commissioner is set at 42.5% of the President
are conducted through cooperation with Willis Towers Watson. In addition, BTN applies a Director’s salary.
mechanism for deferring variable remuneration (malus) and for the clawback of variable • The honorarium of other members of the Board of Commissioners is set at 90% of the
remuneration that has been paid to officials classified as Material Risk Takers (MRTs). President Commissioner’s honorarium.
These policies are implemented by considering the level of loss or reputational impact on
the Bank, as well as the individual’s involvement, whether direct or indirect, in the relevant Remuneration at BTN is not based solely on an individual’s position and responsibilities,
actions or transactions. [GRI 2-19] but is also influenced by the achievement of the established Key Performance Indicators
(KPIs). These serve as metrics to assess the extent to which the Bank’s strategic and
The determination of salaries or honoraria for members of the Board of Commissioners operational objectives are achieved. One of the key parameters within the Board
and the Board of Directors allows for the scale and complexity of the Bank’s business, of Directors’ KPIs is sustainability, which focuses on the achievement of long-term
the inflation rate, as well as the Bank’s financial condition and capacity, while also objectives that support the Bank’s social, economic, and environmental continuity.
considering other relevant factors and ensuring compliance with prevailing laws and This parameter includes the weighting of ESG ratings, growth in green financing, the
regulations. The composition of salaries or honoraria for the Board of Directors and the disbursement of subsidized mortgages (KPR) and the Millennial Housing Program
Board of Commissioners is as follows: mortgages, digital channel services, a zero-accident target, cybersecurity breaches, and
• The salary of the President Director is determined based on internal guidelines women’s representation in the nominated talent pool. The remuneration and benefits
stipulated by the Minister. package received by the Board of Commissioners and the Board of Directors comprises a
• The salary of the Vice President Director is set at 95% of the President Director’s salary. remuneration structure that includes salary, short-term incentives, long-term incentives,
• The salary of other members of the Board of Directors is set at 85% of the President pension benefits, severance pay, allowances, and one-off payments, such as recruitment
Director’s salary. or retention awards. [GRI 2-19]
• The honorarium of the President Commissioner is set at 45% of the President Director’s
salary.
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
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In line with the implementation of a performance-based remuneration structure, BTN Types of Remuneration and Other Facilities Board of Commissioners Board of Directors
provides short-term incentives as a form of recognition for the performance achievements a. Are ownership-based
of the Board of Commissioners, the Board of Directors, and employees within a short- Post-Employment Insurance
term period. The provision of these incentives is regulated under Special Policy Number b. Non-ownership-based
KK.3-B on Remuneration, which refers to POJK Number 45/POJK.03/2015. Short-term
Housing Allowance
incentives are granted in various forms, including cash bonuses, performance-based
Health Facilities
salary increases, profit sharing, and other forms of rewards aimed at encouraging the
achievement of the Bank’s targets within a relatively short timeframe. Transportation Facilities
Communication Allowance
In addition to short-term incentives, BTN also provides long-term incentives as recognition
for the contributions of the Board of Commissioners and the Board of Directors to
sustainable performance. The provisions governing long-term incentives are regulated Ratio of the Highest and Lowest Salaries [GRI 2-21]
under Special Policy Number KK.3-D on the Remuneration of the Board of Directors, the
Board of Commissioners, Senior Executive Vice Presidents (SEVPs), and Supporting Organs To maintain equitable employee compensation, the distribution of remuneration in
of the Board of Commissioners, as well as Special Policy Number KK.3-B on Remuneration, a proportional manner to avoid significant disparities. The Bank does not implement
with reference to the Regulation of the Minister of SOEs Number PER-13/MBU/09/2021 and unconditional variable-based remuneration schemes, as such schemes do not take
POJK Number 45/POJK.03/2015. Long-term incentives may be granted in the form of employees’ length of service into account. As part of its commitment, BTN applies
shares, cash, and other awards to encourage a focus on long-term objectives and to a remuneration system that is competitive, fair, and proportional, and ensures that
support retention and loyalty. The components of remuneration and other facilities for compensation for all employees is provided in accordance with prevailing government
the Board of Commissioners and the Board of Directors are presented in the following regulations.
table.
The remuneration policy is periodically reviewed and adjusted. At the same time,
Components of Remuneration for the Board of Commissioners and the Board of compliance with banking regulatory provisions related to remuneration is implemented
Directors
on a gradual basis. The ratio of the highest to the lowest salaries over the past three years
Types of Remuneration and Other Facilities Board of Commissioners Board of Directors is presented as follows. [GRI 2-21]
Remuneration
Ratio of the Highest and Lowest Salaries
Honorarium/Salary
Description 2025 2024 2023
Regular Allowances (Clothing Allowance and
Income Tax Allowance) Ratio of the highest to the lowest employee salary 31.58 : 1 25.00 : 1 22.44 : 1
Religious Holiday Allowance Ratio of the highest to the lowest Board of Directors’ salary 1.18 : 1 1.18 : 1 1.18 : 1
Ratio of the highest to the lowest Board of Commissioners’ salary 1.11 : 1 1.11 : 1 1.11 : 1
Tantiem
Ratio of the highest Board of Directors’ salary to the highest 2.23 : 1
Other facilities in kind (such as housing, health insurance, and similar benefits) that: 2.89 : 1 2.92 : 1
employee salary
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Ratio of the Highest and Lowest Salaries
Description Unit 2025 2024 2023
Total annual compensation for the highest-paid individual in the organization Rupiah 4,169,759,730 23,977,998,581 18,933,904,119
Median total annual compensation for all employees of the organization, excluding the highest-paid individual Rupiah 199,103,460 189,655,513 184,671,636
Increase in total annual compensation for the highest-paid individual in the organization % 18.43 26.64%
Increase in the median total annual compensation for all employees of the organization, excluding the highest-paid individual % 4.98 2.70%
Share Ownership Policy for Members of the Board of Directors and the
Board of Commissioners
In carrying out share ownership transactions by the Board of Directors and the Board In accordance with these provisions, the Board of Commissioners and the Board of
of Commissioners, BTN refers to Financial Services Authority Regulation Number 11/ Directors disclose information regarding their own share ownership and/or that of
POJK.04/2017 on the Reporting of Share Ownership or Any Changes in Share Ownership of their family members amounting to 5% or more, whether in BTN or in other companies
Public Companies, the Decree of the Board of Directors of the Indonesia Stock Exchange domestically or abroad. Such disclosure is made to ensure transparency and to mitigate
Number KEP-00066/BEI/09-2022 on the Amendment to Regulation Number I-E concerning potential conflicts of interest that could affect corporate governance, as part of BTN’s
Information Disclosure Obligations, as well as the Bank’s Articles of Association. Each commitment to the application of GCG principles and sustainability.
member of the Board of Directors and the Board of Commissioners is required to report
their share ownership and any changes thereto, whether direct or indirect, to the Financial As of December 31, 2025, no members of the Board of Commissioners or the Board of
Services Authority no later than 10 (ten) days after the change occurs. Directors of BTN held shares with total ownership of 5% or more, either in BTN or in other
companies. This indicates the absence of any significant influence arising from share
ownership on independence in carrying out oversight and management functions, and
supports objective decision-making free from conflicts of interest.
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Performance Evaluation of the Highest
Governance Body [GRI 2-18]
In order to maintain the quality of governance implementation, the Bank conducts
periodic performance evaluations to ensure alignment with best practices and business
dynamics. The performance assessment of the highest governance body in relation to the
implementation of GCG and the management of economic, environmental, and social
impacts is through a self-assessment mechanism conducted each year at the end of
June and December without the involvement of third parties, and covers the performance
of the Board of Commissioners, the Board of Directors, and relevant work units based
on the established assessment factors. The development of corporate governance self-
assessment results over the past 3 (three) years is presented in the following table.
Results of the Corporate Governance Self-Assessment
for 2022–2024 Period
2025 2024 2023
2 2 2
A self-assessment result with a rating of 2 indicates that the Bank has generally
implemented GCG through adequate compliance with GCG principles. Although
several weaknesses remain, their impact is assessed as not significant and can be
reasonably addressed by management. Information on the assessment criteria, rating,
recommendations, and follow-up actions arising from the self-assessment is presented
in BTN’s Annual Report.
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In addition to conducting GCG self-assessments, BTN participates in the Corporate BTN also participates in the ASEAN Corporate Governance Scorecard (ACGS), an
Governance Perception Index (CGPI) organized by the Indonesian Institute for Corporate assessment framework developed by the ASEAN Capital Market Forum (ACMF) with
Governance (IICG). In 2025, the Bank achieved a CGPI score of 91.8 with the designation reference to the OECD Principles. The ACGS assessment is conducted by the Domestic
“Most Trusted Company,” an improvement compared to 2024, which recorded a score of Ranking Body (DRB) and Corporate Governance (CG) Experts, which in Indonesia are
91.52. This reflects BTN’s steadfast commitment to the implementation of good corporate represented by PT RSM Indonesia, as part of efforts to enhance global investor confidence
governance. in the quality of corporate governance across the ASEAN region.
Risk Management [GRI 2-23] [OJK E.3]
BTN is a bank focused on providing housing loans and financing, with an asset portfolio occur in a transparent, accountable, and integrity-driven manner, while supporting
dominated by mortgage loans, and influenced by various internal and external risk factors, prudent and sustainable decision-making.
including business climate dynamics, inflation levels, and interest rate fluctuations. To
mitigate potential impacts arising from these factors, sustainable risk management is a To safeguard performance sustainability and the achievement of the Bank’s objectives,
key priority for the Bank. BTN implements a comprehensive risk management system across all operational lines.
This system is supported by four main pillars as the fundamental framework for the Bank’s
In managing risks, BTN refers to GCG principles as the foundation of its risk management risk management implementation, which include:
policies and procedures. GCG implementation ensures that risk management processes
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Pillars of BTN’s Risk Management System
Risk Management Organizational Structure
Board of Commissioners and Board
of Directors Organs Risk Management Unit
Active oversight by the Adequacy of policies, Board of
Board of Directors
Board of Commissioners procedures, and the Commissioners Risk Management Unit
and the Board of Directors establishment of risk limits A unit responsible for
identifying, measuring,
Scope of Risk Risk Monitoring Asset and Liability
monitoring, and
Committee Committee (ALCO)
Management controlling risks to
support the duties and
responsibilities of the
Audit Committee Information Technology
Board of Directors.
Adequacy of risk identification, A comprehensive internal Steering Committee
measurement, monitoring, and control system
control processes, as well as risk Remuneration and Risk Management
Nomination Committee Committee Compliance Unit
management information systems
A unit responsible for
carrying out compliance
Human Capital
functions and preventive
Committee
The following section is structured with reference to BTN’s four pillars of the Risk measures to support the
duties and responsibilities
Management System beginning with active oversight by the Board of Commissioners Credit Policy of the Board of Directors.
and the Board of Directors, followed by the adequacy of policies, procedures, and Committee
the establishment of risk limits. It then addresses the adequacy of risk identification,
Credit Committee
measurement, monitoring, and control processes, including the risk management Internal Audit Unit
A unit responsible for
information system, and concludes with a comprehensive internal control system. Business Committee ensuring internal controls
to support the duties and
Active Oversight by the Board of Commissioners and the Board of Transformation Steering responsibilities of the
Committee Board of Directors.
Directors
ESG Committee
This pillar represents the initial stage in the implementation of risk management. Risk
Policy Unit
oversight and management are effectively carried out by the Board of Commissioners Integrated Risk
A unit responsible for
Management
and the Board of Directors, supported by various committees in accordance with managing policies and
Committee
procedures to support the
applicable regulatory requirements, to ensure that all strategic decisions are aligned
duties and responsibilities
with the principles of GCG. This oversight is supported by the Risk Management Unit, as Capital & Subsidiary of the Board of Directors.
illustrated in the following risk management organizational structure: Committee
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Risk Management Unit (SKMR)
The Risk Management Unit operates under the direct responsibility of the Director in
charge of the Risk Management function. The unit leads the Bank’s risk management
activities and operates independently from Operational Units as risk-taking units, as well
as from the Internal Audit Unit and the Compliance Unit. The Bank’s risk governance is
based on GCG principles and is implemented through the involvement of all governing
bodies in risk management, as reflected in the Bank’s risk management organizational
structure. In addition, the Director of Risk Management oversees ESG risks in the financing
process to ensure effective management in accordance with established policies and
procedures.
The Board of Commissioners conducts risk management oversight through meetings
of the Risk Monitoring Committee, while the Board of Directors manages risks through
meetings of the Risk Management Committee, to ensure that implementation is aligned of the ESG roadmap and conducting continuous evaluations of ESG strategies to ensure
with the Bank’s characteristics, complexity, and risk profile. Both committees play an active consistent application of ESG principles across all Bank activities. The Enterprise & ESG
role in risk management by referring to the Risk Management Implementation Quality Risk Management Unit oversees the ESG Department, the Integrated Risk Management
(KPMR) standards, which cover risk governance, the risk management framework and Department, the Credit Portfolio Risk Management Department, the Market & Liquidity Risk
processes, the adequacy of management information systems, and the effectiveness of Management Department, and Model Validation. The organizational structure of this unit
the internal control system. has been approved by the Board of Commissioners and the Board of Directors and is
designed to strengthen digital banking capabilities and ESG management.
The implementation of the risk management function is supported by the Risk Management
Unit (SKMR), led by the Head of the Unit and reporting directly to the Director of Risk The organizational structure of the Digital & Operations Risk Management Division
Management. Currently, SKMR comprises four divisions, namely the Enterprise & ESG Risk (DORD) comprises the Fraud Risk Management Department, the Digital Risk Management
Management Division (ERMD), the Digital & Operations Risk Management Division (DORD), Department, the Operational Risk Management Department, the Regional Operational
the Wholesale Credit Risk Division (WRD), and the Retail Credit Risk Division (RCRD). Risk Control Department, and the Operational Risk Control Department. The Wholesale
Credit Risk Division and the Retail Credit Risk Division form part of the four eyes principle
As part of the integration of ESG principles, the Risk Management & ESG Unit or the Enterprise and are included in the 1.5 line model. The establishment of the Digital & Operations
& ESG Risk Management Division (ERMD) is led by a BOD-1 and serves as a control tower Risk Management Division structure is aligned with the IT and Digital Risk roadmap and
with directive, controlling, and supportive roles. This unit performs an oversight function responds to the increasing risk trends in the digital IT and operational risk environment.
as the second line of defense and acts as a 1.5 line in the formulation of ESG strategies, The organizational structures of the ERMD and DORD units are presented in the following
initiatives, and roadmaps. Its key responsibilities include overseeing the implementation chart:
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Organizational Structure of the ERMD and DORD Units
Director of Risk Management
Enterprise & ESG Risk Management (ERMD) Digital & Operations Risk Management (DORD) Regional Office
Secretary Secretary
Environmental, Credit Market & Regional
Integrated Risk Model Model Fraud Risk Digital Risk Operational Risk Operational Risk Regional
Social & Portfolio Risk Liquidity Risk Operational Risk
Management Development Validation Management Management Management Control Business Control
Governance Management Management Control
Framework Digital Risk, Regional
Model Model Fraud Strategy Operational Operational Regional
& Strategy Strategic Risk SME Risk Market Risk Governance, Operational
Development Validation & Prevention Risk Risk Control Business Control
Development Monitoring and Risk Control
Development Analyst Supervisor
Reporting Analyst
Policy & Wholesale Fraud
Risk Culture Liquidity Risk Digital Risk Branch
Implementation Risk Operational, Operational Risk
Assessment Business
Detection & Assessment
Control
Investigation
Data Fraud
Consumer Market Middle
Reporting & Sharia Risk Monitoring & CBC Business
Risk Office
Communication Recovery Control
RLPC Business
Control
Regional
Business
Control
Officer
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ESG Risk Management Integration
BTN has integrated ESG principles into the credit due diligence process by directly involving BTN also identifies ESG risk triggers, including conditions or indicators that require
the credit risk management team in the evaluation of ESG aspects, including involvement additional evaluation prior to financing decisions. Where material risks are identified,
in conducting deep-dive assessments for industries with high ESG risk intensity.. Through such as significant environmental impacts, the case is escalated to the ESG Committee
the Risk Management Unit (SKMR), the Bank ensures that all risks arising from business for the formulation of appropriate mitigation measures. Once mitigation measures
activities, including credit risk and ESG-related risks, are identified, measured, monitored, are determined, they are submitted to the Board of Directors for approval and the
and reported in a transparent manner. The results of these evaluations are reported to necessary follow-up actions. This escalation process ensures that significant ESG risks
the Board of Directors to ensure responsible risk management. are addressed in a prudent and responsible manner through a clearly defined ESG risk
escalation process, with details on thresholds for triggering escalation and examples of
The ESG assessment process is conducted in accordance with the Four Eyes Principle, extra due diligence where necessary, in line with BTN’s commitment to sustainability and
involving joint analysis at each stage of the credit approval process. The stages include: good governance principles.
1. Initial Analysis under the Four Eyes Principle
The Four Eyes Principle ensures that credit analysis is conducted by two independent Adequacy of Risk Management Policies and Procedures and the
units, namely the business unit and the risk unit, with due consideration of ESG Establishment of Risk Limits
aspects. The business unit assesses prospective borrowers and collects supporting
documents, while the risk unit evaluates potential credit risks incorporating ESG BTN has established this pillar to translate the oversight direction of the Board of
considerations and provides mitigation recommendations where necessary. Commissioners and the Board of Directors into operational governance instruments.
2. Preparation of the Credit Proposal Risk management policies, procedures, and risk limits are formulated to ensure that risk
Following the ESG analysis conducted by both units, the results are documented exposures are measurable and aligned with the Bank’s risk profile, capital capacity, and
in the credit proposal, which includes a credit risk assessment incorporating ESG performance targets.
aspects, risk mitigation recommendations, and a conclusion on credit feasibility.
3. Pre-Credit Committee Meeting (Pre-RKK) Risk Management Policies and Procedures
At this stage, the business unit and the risk unit present the results of the credit
analysis, including ESG considerations, while the compliance unit and the legal unit Efforts to mitigate the impacts of various risks are implemented through the development
provide input on regulatory and legal aspects. of comprehensive risk management policy guidelines designed to anticipate different
4. Credit Committee Meeting (RKK) types of risks. Implementation represents compliance with Financial Services Authority
The Credit Committee Meeting serves as the final decision-making forum for the Regulation (POJK) Number 18/POJK.03/2016 on the Implementation of Risk Management
credit proposal, where the credit analysis incorporating ESG considerations agreed for Commercial Banks, which requires banks to apply risk management effectively. These
upon during the Pre-RKK is presented. Decisions are reached through consensus, and risk management policies are set out in formal documents that are reviewed and updated
where consensus cannot be achieved, by majority vote. The decision is documented periodically, at least annually, to ensure consistent understanding and implementation
in the meeting minutes and serves as the basis for the issuance of the Credit Approval by risk owners and risk managers.
Letter (SP2K).
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Offices
In line with the strengthening of risk management implementation, BTN has aligned 17. Internal Credit Rating (ICR) Process
its internal policy structure with the new transformation of the policy and procedure 18. Guidelines for the Credit Scoring Model (CSM) Process
architecture. Intended to ensure that risk management policies and procedures remain 19. Credit Authority Limits for Commercial and Consumer Loans
consistent with operational needs and applicable regulations. The policy structure is 20. Guidelines for the Calculation of Allowance for Impairment Losses
arranged in a hierarchy comprising general policies, specific policies, and technical 21. Policy for Debtors Affected by the COVID-19 Pandemic
regulations, thereby supporting business sustainability and the application of GCG 22. Business Continuity Management (BCM)
practices. 23. Standard Operating Procedure for the Business Continuity Plan (BCP)
24. Standard Operating Disaster Recovery Plan (DRP)
Based on the above, the General Risk Management Policy (KUMR) as the primary guideline 25. Standard Operating Business Impact Analysis (BIA)
for the implementation of risk management, which incorporates the minimum provisions
in accordance with regulations issued by Bank Indonesia and the Financial Services Within the risk management policies, ESG risks related to financing activities are
Authority (OJK). In its implementation, the KUMR is further elaborated into various more included. BTN ensures that each financing decision takes ESG aspects into account,
detailed internal derivative policies, including the following: including environmental impacts, compliance with social rights, and the application of
1. Guidelines for the Implementation of Bank Risk Profile Reporting and Assessment sound corporate governance practices. This approach aims to mitigate potential risks
2. Implementation of Bank Soundness Level Reporting and Assessment arising from financing activities that do not adequately consider sustainability and social
3. Risk Model Validation Procedures responsibility principles.
4. Guidelines for Risk Data Collection for the BTN Loss Event Database Application (BTN-
LED Tool) The application of ESG risk considerations in financing is essential to ensure that credit
5. Guidelines for the Liquidity Risk Measurement Process extended by BTN delivers not only financial benefits but also positive impacts on society
6. Guidelines for the Calculation and Reporting of the Liquidity Coverage Ratio and the environment. Accordingly, BTN is committed to consistently applying ESG
7. Guidelines for the Market Risk Measurement Process principles throughout all stages of financing, from risk analysis to impact evaluation.
8. Interest Rate Risk Management in the Banking Book
9. Guidelines for the Implementation of Stress Testing BTN conducts periodic reviews of its internal policies to ensure alignment with the
10. Risk Model Validation Procedures latest regulatory requirements, including gap analysis and adjustments to prevailing
11. Liquidity Monitoring Guidelines best practices in the banking industry to enhance the quality of risk management
12. Risk Management Policy Guidelines (PKMR) implementation.
13. Risk and Control Self-Assessment
14. Guidelines for the Implementation of Action Plans (Recovery Plan) BTN continuously enhances its risk management information system to strengthen the
15. Risk Culture quality of its risk data foundation, aimed at enabling integrated risk measurement and
16. Guidelines and Assessment of Risk Profiles for Branch Offices and Sharia Branch monitoring, supported by the phased development of systems that deliver timely and
accurate information.
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BTN Risk Management Framework
Risk Management Policies and
Procedures and the Establishment of
Output
Risk Limits
Corporate Sound Bank
Strategy Health Level
As a strategic step in implementing risk
management policies, BTN has adjusted
the General Risk Management Policy as
the highest-level policy within the Bank’s Management of Risk Types
Risk Management Strategy in the Bank
risk management framework. This policy
framework covers all risk management Risk Credit Risk
Appetite/ Credit Risk
Risk Management Limit Management
activities, ranging from risk management Risk
strategy to more detailed operational risk Tolerance Market Risk
Market and Liquidity
management, with the ultimate objective Risk Management
Liquidity Risk
Credit Risk Operational Risk
of supporting the achievement of a sound
Capital
bank health level (TKB). Iden Strategy Operational • Operational, Legal,
Recovery & Market ng tifi Environmental
rti ca Risk Compliance, and
Resolution Risk po t Risk Reputational Risk
io
Re
Plan (RPP)
n
As part of the update to its risk management Management
Legal Risk • IT, Cyber, and
Legal Risk Reputational
policies, BTN has adjusted the General Risk
m ent
Risk Risk Digital Risk
Management Management
trol
Management Policy as the highest-level Process Compliance
sure
• New Product and
Con
Risk
Strategic Compliance Activity Risk
ea
policy within the Bank’s risk management Management
M
Risk Risk
framework. This policy framework covers Reputational • Business Continuity
Mon
it o ri n g Risk Management
all risk management activities, from risk Risk
Rate of Return Risk Investment Risk
Management
management strategy to more detailed Organization
• Business • Strategic Risk
operational risk management, with the Continuity Management
Risiko Strategis • Recovery Plan &
Sistem Informasi Manajemen Risiko Management
ultimate objective of supporting the Resolution Plan
• Contingency
achievement of a sound bank health level Plan
Budaya Risiko • Implementation
(TKB). of risk
Risiko Imbal
management Hasil Sharia Risk
Internal
Control for each risk Management
Pedoman Manajemen Risiko type
Risiko Investasi
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The Bank has established a risk limit setting processes are conducted in a prudent manner and in key priority in ensuring that business activities are carried out
process that refers to the Corporate Work Plan compliance with applicable regulations. The Bank requires all prudently and in full regulatory compliance.
and Budget (RKAP) as well as the recovery BTNers to apply this cultural pillar in every activity within their
plan, in accordance with applicable regulatory respective work units. Governance and risk culture remains a
requirements. This is designed to ensure
that risk management is conducted in a
measurable, consistent, and aligned manner
BTN Governance and Risk Culture Framework
with the Bank’s business strategy.
The application of risk limits happens in
BTN AKHLAK
a tiered manner by linking the RKAP, Risk
Appetite, and Risk Tolerance as references for Leading Partner in Empowering the Financials of Indonesian Families To become Leading
Partner in Empower-
risk management under business-as-usual ing the Financials of
4 Cultural Pillars
conditions. When risk exposures approach or Indonesian Families
all BTNers are
exceed the established tolerance thresholds, Driving Growth and
Integrity and required to uphold
Meeting Customer High Performance Continuous Learning
the Bank activates contingencies as well as Expectations Trustworthiness the four cultural
pillars in carrying out
preventive, recovery, and corrective recovery their work activities
plans to safeguard business continuity and Sales & Service Culture Governance & Risk Culture Performance Culture Learning Culture within their respective
units.
maintain the Bank’s financial stability. Further The governance and
The 8 Core Behaviors of BTNers
details on the risk limit implementation process risk culture pillar is a
critical and urgent
are presented in the Bank’s Annual Report. 1 2 3 4 5 6 7 8
pillar to be
Upholding and Continuously Being Mutually Being Being proactive, Being Being open to strengthened, as it
complying with learning, disciplined, respecting, accountable effective, and responsive to collaboration ensures that all
Strengthening Risk Management Policies moral values pursuing consistent, and valuing, and and efficient in change and that creates
business processes
and business improvement, thorough in being open to consistently meeting providing added value.
and Procedures ethics, and
fulfilling
and upholding
intrapreneur-
completing
tasks with the
differences. prioritizing the
Company’s
customer
needs.
opportunities
for continuous
are conducted
commitments ship to enhance highest quality interests. improvement. prudently and in
in accordance individual and outcomes. compliance with
with applicable collective
Risk management policies and procedures are regulations. competencies.
applicable
regulations.
strengthened by internalizing risk management
as one of the pillars of BTN’s corporate culture,
namely governance and risk culture. This plays AKHLAK: Core Values and 18 Behavioral Guidelines
a strategic role in ensuring that all business Trust Competent Harmonious Loyal Adaptive Collaborative
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Based on the illustration above, in supporting the Bank’s objectives grounded in BTN’s identification, measurement, monitoring, and control, supported by a risk management
values and the 8 (eight) Core Behaviors of BTNers, four cultural pillars serve as the main information system that provides relevant and timely data to support effective decision-
foundation of the Bank’s Culture Program, with the following objectives: making.
1. Sales & Service Culture – Driving Growth and Meeting Customer Expectations Risk Identification, Measurement, and Assessment [GRI 2-16]
The targeted end state is to increase sales of funding, lending, and digital products,
as well as to enhance service quality in order to drive BTN’s business growth and BTN conducts risk identification to recognize potential risks that may affect the
overall performance. achievement of business objectives. The results serve as the basis for establishing the
2. Risk & Governance Culture – Integrity and Trust Risk Appetite Statement (RAS), which defines the level of risk the Bank is willing to accept.
Building awareness and understanding of risks and their mitigation, and consistently The RAS functions as a reference for business decision-making and the execution of
and comprehensively applying risk management principles across the organization. operational activities to ensure they remain within the established risk tolerance limits.
3. Performance Culture – Superior Performance
Efforts to enhance performance in order to achieve the established targets. Furthermore, the risk measurement system assesses risk exposures across all business
4. Learning Culture – Continuous Learning activities and compares them with the Bank’s risk appetite. Risk measurement is
Fostering a learning mindset and strengthening critical competencies, including conducted periodically for products, portfolios, and business activities to support the
Sales, Digital Analytics, Risk & Collection, as well as reinforcing BTNers’ understanding determination of appropriate mitigation measures and to ensure capital adequacy in
of the importance of culture and the application of the Core Behaviors in daily absorbing residual risks. The methodologies applied combine standard approaches in
activities. accordance with the provisions of Bank Indonesia and the Financial Services Authority
(OJK) with internal methodologies developed by BTN based on the Bank’s business
To maintain resilience amid the increasing complexity of challenges in the evolving characteristics and level of complexity. All methodologies are reviewed and refined on a
banking industry, BTN conducts regular reviews of its risk management policies. These regular basis or as necessary to ensure the appropriateness of assumptions, accuracy,
reviews aim to ensure the adequacy of risk management policies, procedures, and risk fairness, data integrity, and the effectiveness of procedures.
limit setting, while maintaining alignment with the latest regulatory requirements. The
process is carried out through gap analysis and the adoption of banking industry best To enhance the accuracy of risk measurement and assessment results, BTN conducts
practices, and is conducted at least once a year with the involvement of the Board of stress testing to estimate potential losses under abnormal market conditions. Through
Commissioners and the Board of Directors. defined scenarios, stress testing measures the sensitivity of the Bank’s performance to
changes in risk factors and serves as a basis for reviewing risk policies and limits when
Adequacy of Risk Identification, Measurement, Monitoring, and Control exposures exceed the established tolerance levels. To provide a continuous view of the
Processes as well as the Risk Management Information System Bank’s risk profile, BTN regularly performs a self-assessment of the Bank Soundness
Level (TKB) and prepares a Risk Profile Report. The TKB assessment refers to POJK No. 4/
This pillar ensures that established policies, procedures, and risk limits are implemented POJK.03/2016 and SEOJK No. 14/SEOJK.03/2017 and is conducted on a semi-annual basis,
effectively through an end-to-end process that encompasses continuous risk while the Risk Profile Report is prepared quarterly. The assessment covers risk profile,
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profitability, governance, and capital aspects. The results of the risk identification, measurement, and assessment conducted by BTN cover 9 (nine) main risk categories, which are
presented in detail as follows.
Identification and Assessment of the 2025 Risk Profile
Risk Name Risk Identification Risk Management & Control Risk Measurement & Monitoring Risk Information & Reporting System Risk Profile
Credit Risk Risk arising from the failure of other Implementation of the Credit Portfolio Quality Reviews, monitoring of Reporting of credit quality and risk Inherent Risk Rating:
parties to meet their obligations, and Financing Policy Guidelines, credit exposure against Risk Appetite exposure to the Board of Directors and Moderate
including the risk of borrower default, establishment of a Credit Committee, and Risk Tolerance, implementation relevant units through the Portfolio
credit concentration risk, counterparty application of the Four Eyes Principle of SME Credit Scoring Models and an Quality Review forum, as well as KPMR Rating:
risk, settlement risk, and country risk, through the segregation of business Early Warning System (EWS), as well through the centralized Commercial Satisfactory
originating from credit and financing and risk functions, use of Portfolio as risk measurement in accordance Banking Center (CBC) and SME
activities, as well as financial Guidelines to control concentration with the Basel III Reforms using Processing Center (SPU). Overall Risk Level Rating:
instruments such as securities, risk, and integration of ESG aspects the standardized approach under Low to Moderate
interbank transactions, trade finance, into credit analysis for the commercial SEOJK No. 24/SEOJK.03/2021 on the
foreign exchange, derivatives, and and corporate segments. Calculation of Risk-Weighted Assets
commitments and contingencies. (RWA).
Liquidity Risk The risk of the Bank’s inability to meet Implementation of the Liquidity Risk Measurement conducted by the Monitoring and reporting of the Inherent Risk Rating:
its maturing obligations through cash Management Policy Guidelines, Treasury Division and the Risk Liquidity Coverage Ratio (LCR) and Moderate
flows or high-quality liquid assets active oversight by the Board of Management & ESG Work Unit in Net Stable Funding Ratio (NSFR) in
without disrupting operations and Commissioners and the Board of accordance with Technical Guideline accordance with POJK No. 5 of 2024, KPMR Rating:
financial condition, which may arise Directors, and the establishment of No. PT.8-F.4, using stock-based POJK No. 19 of 2024, and POJK No. 20 Satisfactory
from constraints in cash flows from liquidity risk policies, procedures, and methods, maturity profile analysis, of 2024.
earning assets, asset sales, funding limits. cash flow projections, and stress Overall Risk Level Rating:
activities, interbank transactions, and testing under Bank-Specific Crisis Low to Moderate
borrowings. (BSC) and General Market Crisis
(GMC) scenarios; daily, weekly,
monthly, and quarterly liquidity
monitoring against the Risk Appetite,
Risk Tolerance, Recovery Plan trigger
levels, as well as Early Warning
Indicators (EWI), the Liquidity
Coverage Ratio (LCR), and the Net
Stable Funding Ratio (NSFR).
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Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Risk Name Risk Identification Risk Management & Control Risk Measurement & Monitoring Risk Information & Reporting System Risk Profile
Market Risk Risks of loss arising from changes Market Risk Management is carried Market Risk Measurement is Reporting of IRRBB and Market Risk Inherent Risk Rating:
in market conditions, including out by business units and the conducted through interest rate and RWA is conducted in accordance Low to Moderate
interest rates, foreign exchange rates, Enterprise & ESG Risk Management foreign exchange sensitivity analysis with OJK Circular Letter Number 23/
equity, and commodities, affecting Division through processes of risk on profit (loss) and equity, the SEOJK.03/2022, along with monthly KPMR Rating:
both the trading book and banking identification, control, and periodic repricing gap method for Interest Rate reporting of the Liquidity Coverage Satisfactory
book positions, including derivative discussion within the Assets and Risk in the Banking Book (IRRBB) in Ratio (LCR) and quarterly reporting of
transactions. Liabilities Committee (ALCO), with a accordance with Technical Guideline the Net Stable Funding Ratio (NSFR) Overall Risk Level: Low to
focus on banking book risk. PT.8-F.1, and quarterly reporting through the OJK Online Reporting Moderate
based on OJK Circular Letter Number Application (APOLO) in compliance
12/SEOJK.03/2018. Stress testing is with POJK 19 of 2024 and POJK 20 of
performed at the beginning of each 2020.
year using regulatory and internal
scenarios. Exposure is evaluated
against the Bank’s Risk Appetite
and Risk Tolerance, and the Net
Open Position (PDN) is determined
in accordance with Bank Indonesia
Regulation Number 17/5/PBI/2015.
Operational Risk Risks arising from inadequacies or The Bank implements Operational Risk Operational Risk Measurement and The Operational Risk monitoring Inherent Risk Rating:
failures in internal processes, human Tools to identify, measure, and control Monitoring are carried out through system is supported by Business Moderate
resources, systems, or external events Operational Risk, which include: the results of RCSA in each work unit, Continuity Management (BCM)
that may affect the Bank’s operations analysis of risk event data in the LED to ensure operational continuity KPMR Rating:
and the achievement of its objectives. 1. Risk and Control Self-Assessment to identify patterns and trends, and during natural disasters or IT system Satisfactory
(RCSA) – A mechanism for monitoring of KRIs to detect early disruptions, as well as by the
identifying and evaluating warnings and confirm risk events that Operational Risk Control unit, which Overall Risk Level: Low to
operational risks in each work unit, have occurred. serves as a 1.5th line of defense Moderate
covering daily activities and the responsible for operational risk
achievement of unit objectives. control functions at the Head Office.
2. Loss Event Database (LED) – For In addition, the Business Control
recording operational risk events function acts as a 1.5th line of defense
at Branch Offices in accordance by providing integrated oversight
with Basel II criteria, including of operational risk across Branch
actual loss, near miss, and Offices (KC), Commercial Banking
potential loss. Centers (CBC), and Regional Loan
3. Key Risk Indicator (KRI) – Processing Centers (RLPC) through
Indicators for monitoring Regional Business Control (RBC),
operational risk, both predictive Branch Business Control (BBC), and
and lagging. Commercial Banking Centre Business
Control (CBC-BC).
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Risk Name Risk Identification Risk Management & Control Risk Measurement & Monitoring Risk Information & Reporting System Risk Profile
Legal Risk Risks arising from legal claims and Legal Risk Management is carried out Legal Risk Measurement is conducted Legal Risk Monitoring and Reporting Inherent Risk Rating:
weaknesses in the legal aspects through the implementation of legal by the Risk Management Work Unit is supported by the Legal Application Low to Moderate
inherent in various functional activities policies and procedures, compliance together with the Legal Work Unit System (LApS) to track the progress
of the Bank, including lending, controls over regulations and Bank through the analysis of ongoing legal of criminal and civil legal cases at KPMR Rating:
treasury, investment, operations, limits, as well as the provision of legal cases, contingent liabilities from legal Branch Offices and the Head Office. It Satisfactory
information technology, and human advice and recommendations by claims, and the quality of contractual is also supported by the placement of
resource management. the Legal Work Unit to each division, obligations in lending documents. Regional Legal Representatives (RLR) Overall Risk Level: Low to
including conducting legal reviews of Monitoring is performed periodically in each Regional Office, responsible Moderate
contracts with third parties. to assess the effectiveness of policy for providing litigation assistance,
implementation, procedures, and legal opinions, legal monitoring, and
compliance with regulations. managing Legal Risk in accordance
with Bank Indonesia regulations.
Reputation Risk Risks arising from stakeholders’ Reputational Risk Management Reputational Risk Measurement is Reputational Risk Monitoring and Inherent Risk Rating:
negative perceptions of the Bank, involves all business units, with each conducted by assessing factors that Reporting is supported by the Low to Moderate
originating from sources such as unit acting as the first line of defense affect the Bank’s reputation, including Customer Complaint System (SPN),
customer complaints and adverse in managing customer relationships. the intensity and nature of media which is integrated with Branch KPMR Rating:
media coverage related to the Bank’s Controls are implemented through coverage and customer complaints. Offices and the Contact Center Satisfactory
activities and services. the management of negative Monitoring is carried out by the to centrally monitor customer
media coverage by the Corporate Risk Management Work Unit, which complaints and negative media Overall Risk Level:
Secretary Work Unit and the provides corrective recommendations coverage.
handling of customer complaints based on the evaluation of
by the Customer Service Work Unit Reputational Risk.
in accordance with the applicable
Service Level Agreement (SLA).
Strategic Risk Risks arising from inappropriate Strategic Risk Control is carried Strategic Risk Measurement is Strategic Risk Reporting and Inherent Risk Rating:
strategic decision-making or out through the preparation and conducted by comparing actual Evaluation are submitted regularly to Low to Moderate
execution, as well as failure to evaluation of the business plan by performance against established the Board of Directors and the Board
anticipate changes in the business the Corporate Strategy & Planning targets and monitoring key of Commissioners, including through KPMR Rating:
environment. This includes Work Unit, based on the General Policy performance indicators (KPIs). Risk the review of core strategy, business Satisfactory
misalignment of strategies with established by the Board of Directors. exposure is monitored on a monthly transformation, infrastructure, and
the Bank’s vision and mission, It also involves analyzing the gap basis by the Risk Management & ESG human resource management, Overall Risk Level: Low to
incomplete environmental analysis, between actual performance and Work Unit by assessing the risk level as well as an annual review of Risk Moderate
inconsistencies in strategic plans business plan targets, with corrective against the Bank’s Risk Appetite and Appetite and Risk Tolerance to ensure
across organizational levels, actions reported to the Board of Risk Tolerance. that the Bank’s strategies remain
and changes in technology, Directors on a regular basis. relevant and adaptive.
macroeconomic conditions,
competitive dynamics, and
government or regulatory policies
(Bank Indonesia and OJK).
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Risk Name Risk Identification Risk Management & Control Risk Measurement & Monitoring Risk Information & Reporting System Risk Profile
Compliance Risk Risks arising from the Bank’s non- Compliance Risk Management Compliance Risk Measurement is The monitoring and reporting system Inherent Risk Rating:
compliance with external regulatory is carried out through the role of conducted by assessing the potential for Compliance Risk is supported Low to Moderate
requirements and from internal the Compliance and Governance losses arising from non-compliance by the Compliance Regulatory
policies that are inconsistent with Division (CMGD), which is responsible based on the type of violation, its Management System (CRMS), which KPMR Rating:
applicable regulations. for preparing a list of external frequency, and the compliance provides access to external regulatory Satisfactory
obligations, ensuring the alignment track record. The effectiveness of requirements, alerts on regulatory
of internal policies, and conducting risk management implementation reporting obligations, and periodic or Overall Risk Level: Low to
compliance oversight. Control is is monitored through coordination ad hoc reporting of compliance risks Moderate
further strengthened by the Regional between the Risk Management Work to the Board of Directors as needed.
Compliance Supervisory Officer Unit and the Compliance Work Unit.
(RCSO) at Regional Offices, who
evaluates Branch Offices’ adherence
to transaction flows and standard
operating procedures (SOPs).
BTN’s ESG Risk Appetite Statement (RAS) reinforces the Bank’s commitment to conducting BTN conducts mapping of ESG risks and opportunities, including climate change, to
sustainable business through the management of climate change risks, social impacts, identify, assess, and measure the resulting material financial impacts. The management
and shared prosperity, while supporting the transition toward net zero emission. of climate related risks and opportunities is under the direct oversight of the Board of
Directors, supported by the ESG Committee as a governance mechanism to ensure
ESG Risks ESG integration into strategy and decision making. The results of this mapping serve
as a strategic basis for BTN in formulating risk management actions and leveraging
The implementation of ESG principles, including the management of climate change- opportunities, including through the integration of ESG criteria into credit disbursement
related risks and opportunities, is a material topic for BTN as it has a significant and direct and the strengthening of sustainable financing. These efforts are aligned with IFRS S1 and
impact on the Bank’s risk profile, business sustainability, and financial performance. ESG S2 to safeguard the resilience and sustainability of the Bank’s financial performance.
issues may affect asset quality, income stability, and BTN’s financial position, including
through increased credit risk, reputational risk, and compliance risk if not managed Based on the results of this mapping, the following table presents a summary of the risks,
adequately. At the same time, effective ESG implementation also creates opportunities opportunities, financial impacts, and management strategies related to ESG topics that
for the development of sustainable financial products and services that support long- are material to BTN. [GRI 3-2, 201-2] [FS10, FS11]
term business growth.
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Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Risks and Impacts of Material Topics
Sustainability Description of Potential Negative Impact Time Horizon Financial Statement Affected Financial
Mitigation Measures
Risk Sustainability Risks Impact Short-term Medium-term Long-term Impact Analysis Statement Accounts
Information Security
Cybersecurity risk Potential cybersecurity Financial losses (incident Service disruption Sanctions/regulatory Decline in trust; • Financial losses • Operating Expenses The Bank has committed
and data breaches incidents (e.g., phishing, response costs, recovery and higher incident action; remediation constraints on resulting from malware • Provision Liabilities for to Personal Data
malware/ransomware) costs, higher investment response costs; data costs and increased partnerships/digital attacks or data Legal Litigation Protection, including
(Likelihood: and customer/Bank in controls), potential recovery efforts for security investment; transformation; breaches that require • Third-Party Funds the establishment of
Medium) personal data leakage regulatory sanctions malware-encrypted higher customer churn pressure on system recovery costs. (Deposits from a dedicated ID team
due to weaknesses in and legal claims, data; potential risk and reduced digital performance and • Potential legal claims Customers) and the formation
security controls, human service disruption, and customer claims if transaction activity. company valuation. or compensation to of a Personal Data
error, or third parties. reputational damage personal data is leaked. customers due to data Protection (PDP) unit
resulting in reduced trust in breaches. under the Compliance &
the Bank. • Reputational damage Governance Division.
that may trigger
customer fund
withdrawals (bank run)
and reduce public trust.
Ethics and Code of Conduct
Risk from breaches Risk of breaches of the Financial losses due to Financial losses and Decline in trust; Prolonged reputational • Potential legal claims • Operating Expenses • The Bank has
of the code of code of ethics, fraud, fraud, regulatory sanctions, operational disruption regulatory and investor damage that may or regulatory penalties • Provision Liabilities for established internal
ethics, fraud, gratification, and conflicts legal claims, and due to investigations, scrutiny; higher constrain business related to violations of Legal Litigation policies related to
gratification, and of interest by employees/ reputational damage that process suspension, compliance and growth and the the code of ethics, fraud, • Third-Party Funds gratification.
conflicts of interest management if the reduces trust among the and corrective actions. monitoring costs. Bank’s long-term gratification, or conflicts (Deposits from • The Bank is committed
integrity culture, internal public and investors. sustainability. of interest. Customers) to maintaining integrity
(Likelihood: controls, and oversight • Potential financial losses through the signing of
Medium) mechanisms are not due to declining investor integrity pacts.
effective. confidence, which may • Implementation of
limit access to funding an Anti-Corruption
or investment. Program to raise
• Reputational damage employee awareness.
that may trigger
customer fund
withdrawals (bank run)
and reduce public trust.
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Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Impact Time Horizon
Sustainability Description of Potential Negative Financial Statement Affected Financial
Mitigation Measures
Risk Sustainability Risks Impact Short-term Medium-term Long-term Impact Analysis Statement Accounts
Governance
Reputational risk Risk of declining Declining investor and Increased audit/ Declining investor/ Sustained reputational • Potential losses due • Operating Expenses The Bank has
and declining stakeholder confidence public trust; potential regulatory findings, partner confidence and decline that may to declining investor • Provision Liabilities for implemented anti-
stakeholder trust if the implementation regulatory sanctions/ remediation costs, and pressure on GCG and weaken performance, confidence, which Legal Litigation corruption, anti-fraud,
due to weak of GCG, transparency, actions; increased disruption to decision- ESG ratings. competitiveness, and may reduce access to • Third-Party Funds and anti-bribery controls,
governance (GCG) and compliance is compliance costs; pressure making processes. the Bank’s long-term funding or investment. (Deposits from as well as digitalization
inadequate (e.g., weak on funding access and sustainability. • Reputational damage Customers) initiatives to support more
(Likelihood: oversight, reporting, and cost of funds. to the Bank that may efficient and paperless
Medium) internal controls). trigger customer fund business processes.
withdrawals and reduce
funding stability.
Employment
Risk of high turnover Risk of high employee Lower productivity, Difficulty meeting Reduced long-term Sustained decline in the • Increased recruitment, • Operating Expenses – • Maintain competitive
and competency turnover, competency higher recruitment costs, the Bank’s strategic competitiveness and Bank’s competitiveness training, and human Recruitment Costs remuneration in line
gaps misalignment, and low and increased risk of competency higher risk of losing top over the long term. capital development • Operating Expenses – with market standards.
workforce readiness operational disruption needs and delays talent. costs. Salaries and Benefits • Recruit from Top
(Likelihood: to support digital and service quality in transformation • Decline in productivity • Operating Expenses – 100 universities in
Medium) transformation and ESG. deterioration. initiatives. leading to higher Training Costs Indonesia.
operating expenses. • Profitability Impact: • Fulfill mandatory
• Decrease in service Interest Income, Fees certification
quality that may affect and Commissions, requirements.
the Bank’s revenue Fee-Based Income, • Implement thematic
growth Interest, Allowance for training programs
Impairment Losses focused on critical
(CKPN) capabilities.
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Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Impact Time Horizon
Sustainability Description of Potential Negative Financial Statement Affected Financial
Mitigation Measures
Risk Sustainability Risks Impact Short-term Medium-term Long-term Impact Analysis Statement Accounts
Human Rights
Risk of human Risk of alleged human Complaints and disputes; Complaints/incidents Higher compliance Long-term reputational • Potential regulatory • Operating Expenses • Implement the
rights breaches rights breaches sanctions/regulatory and case handling requirements; impact and declining sanctions, fines, or • Provision Liabilities for Respectful Workplace
in operations, (e.g., discrimination, action; disruption to costs, including constraints on trust, potentially legal costs arising from Legal Litigation Policy (RWP)
supply chain, and harassment, privacy projects/partnerships; investigations. partnerships/financed constraining growth human rights violations. program to foster
financing breaches, workplace reputational damage projects; ESG-related and company value. • Increased investigation a workplace free
safety issues at vendors, and loss of trust among pressure and risk of and case remediation from discrimination,
(Likelihood: child/forced labor in investors and customers. project delays. costs. harassment, and
Medium) the supply chain), and • Potential losses due bullying.
potential social impacts to declining investor • Provide reporting and
from financed projects confidence, which complaint channels for
(e.g., land/relocation may reduce access to RWP-related cases.
conflicts) if due diligence funding or investment. • Increase the proportion
is insufficient. of employees
with disabilities to
strengthen Diversity,
Equity, and Inclusion
(DEI).
Sustainable Products and Services
Risk of losing Risk of lagging in Loss of growth Missed opportunities Reduced Weakening competitive • Loss of potential • Interest Income The Bank has
competitiveness the development of opportunities and cheaper to launch/scale competitiveness position and potential revenue from • Provision and implemented Low-
in sustainable sustainable products and funding access; declining sustainable products and risk of losing decline in ESG ratings, sustainable financing Commission Income Emission Housing
products/services services, resulting in lost competitiveness; ESG and to secure customers/investors affecting funding products, such as • Fee-Based Income initiatives, developed
market opportunities, assessments/ratings may sustainable funding. with ESG preferences. access and reputation. sustainability bonds, • Interest Expense financing and funding
(Likelihood: reduced access to green be suboptimal. sustainability-linked • Credit Loss Expense instruments that support
Medium) funding, and weaker loans, or other green (CKPN) ESG aspects such as
investor support as financing instruments. sustainability-linked loans
investor focus on ESG • Loss of funding and sustainability bonds,
increases. opportunities from and launched the balé by
investors focused on BTN Super App and BTN
ESG. Digital Store.
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Impact Time Horizon
Sustainability Description of Potential Negative Financial Statement Affected Financial
Mitigation Measures
Risk Sustainability Risks Impact Short-term Medium-term Long-term Impact Analysis Statement Accounts
Community Development
Risk of ineffective Risk that community Social impact targets Complaints/negative Declining stakeholder Weakened reputation • Increased social • Non-Operating The Bank ensures that
community development/TJSL not achieved; public assessments of trust and limited and social trust, program costs without Expenses – Environmental and
development programs are not complaints; reputational programs and opportunities for reducing the Bank’s generating optimal Environmental Social Responsibility
programs and low well targeted or decline affecting low community collaboration within positioning as a pioneer impact. Development (TJSL) disbursements
financial literacy effective, as well as low relationships with participation. community/ecosystem in inclusive housing. • Reputational decline • Loans Disbursed are aligned with the four
financial literacy and communities, regulators, initiatives. that may affect • Interest Income TJSL pillars and targeted
(Likelihood: inclusion among target and investors. customer trust. • Third-Party Funds appropriately. BTN also
Medium) communities, which may • Potential decrease in (Deposits from conducts monitoring
reduce social impact and business growth from Customers) and evaluation,
weaken stakeholder trust. community or local • Interest Expense including Social Return
ecosystem segments. on Investment (SROI)
assessments, to
ensure that funds are
distributed effectively and
contribute to community
development and self-
reliance.
Sustainable Procurement
Non-sustainable Risk of procurement Cost inefficiencies, Delays in procurement Risk of service Reputational and • Increased operating • Operating Expenses The Bank urges vendors
procurement practices that do not disruption to supply of processes, audit disruption from vendors company value risks, costs due to inefficient • Provision Liabilities for to implement Sustainable
practices and third- align with sustainability goods/services, audit findings, and increased and increased costs including potential legal procurement processes. Legal Litigation Procurement principles
party risks principles (environmental, findings and compliance operational costs. due to re-procurement issues, vendor fraud/ • Potential losses through formal
social, and ethical issues, and reputational or contract corruption recurrence, arising from fraud or communication.
(Likelihood: aspects), including third- risks if vendors fail to adjustments. or loss of control. non-compliance with
Medium) party/vendor risks and meet good governance contract terms.
lack of transparency that standards. • Additional costs for
may lead to inefficiencies, audits, monitoring, and
fraud, or reputational improvements to the
issues. procurement process.
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Impact Time Horizon
Sustainability Description of Potential Negative Financial Statement Affected Financial
Mitigation Measures
Risk Sustainability Risks Impact Short-term Medium-term Long-term Impact Analysis Statement Accounts
Natural Resource Use and Environmental Management
Climate pattern As a bank with a portfolio • Declining Collateral • Regulatorily, OJK If, over the next 3–5 Over the next 10 • Decline in collateral • Loans BTN has conducted
change risk: water predominantly in the Value & Stranded requires banks to years, there is a years, water crises value and potential • Allowance for Climate Risk Stress
scarcity and housing sector, BTN Assets: Properties in conduct climate risk significant increase in and increasing stranded assets in Impairment Losses Testing (CRST) to assess
flooding (impact faces risks from water areas prone to water stress tests, including rainfall causing flooding flood risks may lead property portfolios (CKPN) on Loans the financial impact
on the housing crises, such as droughts, crises or flooding risk for portfolios located or drought in the areas the government to located in flood-prone • Provision for of physical risks from
portfolio) declining water quality, losing value, reducing in areas prone to where BTN finances tighten regulations on areas. Impairment Losses on flooding and fire on its
and flooding. These the quality of BTN’s flooding and fires. housing, then: water management, • Increase in non- Financial Assets loan portfolio in high-risk
(Likelihood: conditions can reduce credit collateral. This may create • Increased NPL risk in potentially creating new performing loans (NPLs) • Interest Income areas.
Medium) the value of financed • Increased Non- non-compliance risk. the affected areas. risks for BTN, including: due to higher operating • Provision and
assets, increase credit Performing Loan (NPL) • From a profitability • Decline in property • Financing costs for developers Commission Income
risk, decrease property Risk: Water crises perspective, water loan demand in the Restrictions: and reduced property • Foreclosed Assets
attractiveness, and affect and flooding raise crises do not affected areas. Regulations may attractiveness. (AYDA)
the long-term stability of developers’ operational currently pose a • Disruption to prohibit housing • Decrease in mortgage
BTN’s financing portfolio. costs and reduce short-term risk to ongoing projects. development in (KPR) demand due to
property attractiveness, BTN, as the housing • Decline in water-prone areas, public concerns about
increasing the risk of financed by BTN is collateral value reducing BTN’s living in flood-prone
debtor defaults for BTN. presently located and occurrence of opportunities. areas, which may slow
• Reduced Mortgage outside flood-prone stranded assets. • Water Efficiency the growth of BTN’s
Demand: People tend to areas. Requirements: financing portfolio.
avoid houses in high- Implementation of
risk water or flood areas, water conservation
hindering the growth technologies and
of BTN’s mortgage green drainage
portfolio. systems may
increase costs and
slow down projects
• Integration of Water
Risk: OJK may require
banks to consider
water risks in lending,
affecting property
financing.
• Rising Insurance
Premiums: Increased
water risk could raise
insurance costs and
reduce demand for
BTN mortgages.
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Impact Time Horizon
Sustainability Description of Potential Negative Financial Statement Affected Financial
Mitigation Measures
Risk Sustainability Risks Impact Short-term Medium-term Long-term Impact Analysis Statement Accounts
Climate Change and Ecosystems
Compliance risk: Transition risk arising from • Increased NPL: Carbon The direct impact is If the carbon tax is If, after the • Increase in non- • Loans • The Bank has
carbon tax policies carbon tax or levy policies tax raises debtor costs, relatively limited if the extended to BTN’s implementation of performing loans (NPLs) • Allowance for established an
and emissions as regulated under Law increasing the risk of Bank’s exposure to debtor sectors, NPL risk the carbon tax, BTN due to carbon tax, as Impairment Losses exclusion list and a
regulations. No. 7/2021, as well as the default and worsening sectors initially subject will increase. If the bank continues to provide higher operating costs (CKPN) on Loans sustainable finance
potential expansion of loans. to the carbon tax is itself is also subject to loans to sectors subject for debtors increase the • Provision for framework to guide
(Likelihood: coverage to other sectors • Stranded Assets: High- low; however, portfolio the tax, BTN will face to the tax, the impacts risk of default. Impairment Losses on portfolio management
Medium) (including construction emission assets may transition risk mapping higher operational on BTN are: • Potential stranded Financial Assets in reducing exposure to
and industries related to lose value, reducing is required. costs, reduced • Stranded Assets assets in high-emission • Interest Income high-emission sectors
the Bank’s portfolio). BTN’s credit collateral. profitability, and and Declining sectors, leading to a • Provision and by increasing financing
• Declining ESG Ratings: decreased financing for Credit Collateral decline in collateral Commission Income to low-carbon projects.
Financing high-emission high-emission sectors. Value due to stricter value and asset quality. • Foreclosed Assets • The Bank continues
projects may hinder regulations. • Decrease in the debtor’s (AYDA) to develop green
access to green funding. • Declining ESG ESG rating, which may financing products to
• Bank Tax Risk: If BTN is Ratings and Difficulty limit access to funding diversify its portfolio,
subject to carbon tax, Accessing Green and increase credit risk. including green bonds
operational costs rise, Financing. • If the Bank is also and other sustainable
profitability decreases, subject to carbon tax, financing instruments.
and financing for high- higher operating costs • As the majority of
emission sectors is may reduce profitability BTN’s portfolio is in the
reduced. and limit financing to mortgage sector, the
high-emission sectors. Bank primarily finances
low-emission housing
that meets green
building standards,
such as the use of
recycled or eco-friendly
materials and energy
efficiency, supporting
the transition to a more
sustainable property
sector.
• The Bank has
conducted Climate Risk
Stress Testing (CRST)
to assess the impact
of climate risk on its
loan portfolio, including
transition risks related
to carbon tax and
stranded assets.
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Opportunity and Impacts of Material Topics
Description of Impact Time Horizon
Sustainability Potential Positive Financial Statement Impact Affected Financial
Sustainability Mitigation Measures
Opportunity Impact Short-term Medium-term Long-term Analysis Statement Accounts
Opportunity
Information Security
Opportunities from Personal Data Protection With strong PDP Strengthened PDP Reduced frequency Stronger reputation • Reduce the risk of financial • Operating Expenses – The Bank has committed to
Strengthening Law (UU PDP) No. 27/2022 governance and policies/procedures, and severity of and trust supporting losses resulting from data Salaries Expenses Personal Data Protection,
Personal Data became effective in information security, the data classification, incidents; improved digital business breaches or misuse of • Third-Party Funds including strengthening its
Protection (PDP) October 2024, requiring Bank is better protected and employee compliance and growth; easier customer information. (Deposits from IT systems and establishing
and information stronger measures from financial losses such awareness; improved service quality; higher collaboration with • Avoid potential legal claims Customers) (increase) a dedicated Personal
security to protect personal as data breaches and access controls and adoption of digital fintech/ecosystems; or regulatory sanctions. • Loans (increase) Data Protection (PDP) unit
data, prevent misuse, customer lawsuits. audit trails. channels. sustained PDP and • Maintain the Bank’s • Intangible Assets under the Compliance &
(Likelihood: High) and increase public information security reputation and strengthen (Application Governance Division.
trust. Strengthening performance. customer trust. Development)
information security
governance also
improves compliance
and operational
resilience.
Ethics and Code of Conduct
Opportunities from Implementation of the Reduced fraud and Strengthened internal Increased trust Strong corporate • Improved operational cost • Employee Training • The Bank has established
Strengthening code of ethics, anti-fraud breaches, improved compliance and among regulators, culture and efficiency through reduced Expenses for internal anti-gratification
integrity culture, and anti-gratification compliance, and risk control through investors, and reputation as a losses from fraud and ethical socialization programs policies.
code of ethics, programs, integrity enhanced quality of socialization, training, customers. high-integrity violations. • Third-Party Funds • Implementation of an
and effective training, and an effective decision-making. and enforcement of institution, supporting • Increased trust from (Deposits from Anti-Corruption Program.
whistleblowing whistleblowing system discipline. long-term business customers and stakeholders, Customers) • Signing of Employee
system across the organization. sustainability. supporting business growth. • Intangible Assets Integrity Pacts.
• Strengthened reputation, (Application
(Likelihood: High) leading to higher banking Maintenance and
activity and service Enhancement)
utilization.
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Description of Impact Time Horizon
Sustainability Potential Positive Financial Statement Impact Affected Financial
Sustainability Mitigation Measures
Opportunity Impact Short-term Medium-term Long-term Analysis Statement Accounts
Opportunity
Governance
Opportunities from Strengthening Increased investor and Alignment of Improved stakeholder Greater resilience and • Increased access to funding • Third-Party Funds • Strengthen the
Strengthening governance structure regulator confidence; governance policies perception, stronger enhanced company from investors and capital (Deposits from implementation of GCG
GCG, and processes (Board/ stronger risk management and processes; reputation, better value through markets through improved Customers) and transparency to
transparency, Committees and discipline and mitigation; improved disclosure access to funding and stronger governance governance credibility. • Cash and Cash investors and regulators.
and risk-ESG policies), enhancing improved access to more quality; strengthened collaboration, and and more consistent • Improved funding stability for Equivalents • Improve the
integration internal control/ competitive funding. accountability across reduced operational, decision-making the Bank. • Capital Stock/ effectiveness of risk
ICOFR, and improving work units. compliance, and aligned with GCG • Greater operational Additional paid-in management and
(Likelihood: High) transparency in reputational risks. principles. cost efficiency through capital internal controls.
sustainability reporting strengthened internal control • Securities Issued/ • Enhance compliance
to strengthen the Bank’s systems. Subordinated Liabilities with applicable laws and
credibility. • Operating Expenses regulations.
• Improve the quality
of reporting and
information disclosure.
• Optimize funding
strategies to secure
more competitive access
to capital.
Employment
Opportunity Development of Higher employee Improved skills and Better talent retention Becoming an • Increased employee • Salaries Expenses • Implement employer
from capability capabilities through productivity and loyalty, work motivation and a stronger talent employer of choice productivity through • Training and branding programs
development, ESG/digital banking stronger organizational through training pool. and a more adaptive competency development Development Expenses through various
employee and service excellence readiness to respond to and development organization in and strengthening of human • Employee Benefits channels.
wellbeing, and training, strengthened industry changes. programs. response to industry capital capabilities. Expense • Conduct employee
engagement employee wellbeing, changes. • Reduced operating • Operating Expenses engagement
and higher employee costs through improved • Operating Income surveys (EES) by
(Likelihood: High) engagement to employee retention, lowering • Cash and Cash independent parties
enhance organizational recruitment costs due to Equivalents and evaluate program
capabilities. turnover. • Capital Stock/ implementation.
• Improved service quality and Additional Paid-in • Implement career
operational performance, Capital acceleration programs.
which may drive revenue • Securities Issued/ • Conduct salary
growth. Subordinated Liabilities surveys to assess the
• Enhanced investor competitiveness of
confidence in the quality of employee remuneration
human capital management, relative to the market.
supporting funding stability
and business growth.
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Description of Impact Time Horizon
Sustainability Potential Positive Financial Statement Impact Affected Financial
Sustainability Mitigation Measures
Opportunity Impact Short-term Medium-term Long-term Analysis Statement Accounts
Opportunity
Human Rights
Opportunity from Implementation of Fewer social incidents Strengthened policies, Improved quality of Stronger reputation • Reduced Operating Expenses • Third-Party Funds • Ensure supporting
strengthening human rights policies, and disputes; stronger awareness programs, supply chain and and business through improved employee (Deposits from facilities for employees
human rights due diligence for vendors stakeholder trust; improved and grievance/ responsible financing; resilience through retention, lowering costs Customers) and customers with
policy and and financing, effective access to sustainable remediation stronger relationships inclusive practices associated with turnover. •Loans special needs (persons
remediation grievance channels, and financing. mechanisms. with communities that respect human • Increased Interest • Interest Income with disabilities) to DEI
mechanisms inclusion and access and regulators. rights. Income and Provision and • Provision and • Implement the RWP to
programs for vulnerable Commission Income through Commission Income ensure a workplace free
(Likelihood: High) groups. higher productivity and • Other Operating from discrimination,
service quality. Income violence, and
• Increased Personnel • Intangible Assets harassment.
Expenses through enhanced
employee competencies and
engagement.
Sustainable Products and Services
Opportunities Opportunity from ● Higher income: Higher income and Stronger BTN Improved access • Increased revenue through • Provision and The Bank has implemented
from Expanding government NZE targets additional fee-based operating efficiency positioning as to funding through fee-based income from balé Commission Income Low-Emission Housing
green finance and and rising demand for income via balé by (digitalization/ a provider of issuance of green/ digital services. • Non-Interest Income / initiatives, developed
sustainable digital sustainable financing BTN and improved paperless), and a sustainable products social/sustainability • Improved operational Other Income financing and funding
services through Low-Emission cost efficiency from stronger pipeline for and services, and bonds, and stronger efficiency through service • Interest Income instruments that support
Housing programs, paperless/digitalized sustainable financing. higher customer ESG ratings digitalization. • Operating Expenses ESG aspects such as
(Likelihood: High) sustainability-linked processes. satisfaction and supporting the Bank’s • Increased access to • Loans Disbursed sustainability-linked loans
loans, green/social/ ● Stronger ESG rating and loyalty. reputation and trust. funding from ESG funds • Issued Securities / and sustainability bonds,
sustainability bonds, and competitiveness. and international financial Subordinated Liabilities and launched the balé by
stronger digital services ● Better access to institutions. • Third-Party Funds BTN Super App.
such as balé by BTN. green funding from • Diversification of the green (Deposits from
ESG investors and financing portfolio. Customers)
international financial • Additional revenue potential
institutions supporting from carbon trading.
sustainability. • Enhanced reputation and
● Product diversification: ESG rating, strengthening
expanded portfolio of investor and customer
green financial products confidence.
and services, including
OJK KKUB sustainable
sectors.
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Description of Impact Time Horizon
Sustainability Potential Positive Financial Statement Impact Affected Financial
Sustainability Mitigation Measures
Opportunity Impact Short-term Medium-term Long-term Analysis Statement Accounts
Opportunity
Community Development
Opportunity from Financial literacy Increased community Improved literacy Growth in customer Long-term social • Growth of new customer • Loans BTN carries out various TJSL
strengthening programs, local engagement, broader and community base and stronger impact and stronger base from housing • Third-Party Funds (Social and Environmental
inclusion, financial economic empowerment customer base, and engagement; social partnerships reputation as communities and (Deposits from Responsibility) initiatives
literacy, and (MSMEs/housing stronger reputation and strengthened with community/ an inclusive and ecosystems. Customers) across four pillars: Social,
community communities), and trust. relationships with developer sustainable housing- • Increased housing and MSME • Interest Income Economic, Environmental,
empowerment innovative social local governments ecosystems through focused bank. financing disbursement. • Provision and and Governance, with key
initiatives (e.g., housing and communities. housing platforms. • Higher Bank revenue from Commission Income focus areas in Education,
(Likelihood: High) ecosystem, house-to- financing activities and • Issued Securities Environment, and MSME
mortgage) to improve banking services. / Green Bonds / Development. These
welfare while expanding Sustainability Bonds initiatives aim to support
the customer base. business continuity, create
social and environmental
impact, and strengthen
branding and reputation.
BTN views its TJSL programs
as a strategic effort to
build harmonious and
mutually beneficial
relationships with the
environment, communities,
and stakeholders at both
local and national levels,
while also supporting its
mission to deliver positive
impact and contribute
to sustainable economic
development.
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Description of Impact Time Horizon
Sustainability Potential Positive Financial Statement Impact Affected Financial
Sustainability Mitigation Measures
Opportunity Impact Short-term Medium-term Long-term Analysis Statement Accounts
Opportunity
Sustainable Procurement
Opportunities from Sustainable • With this application, the With this application, More integrated The Bank’s reputation • Improved operational cost • Operating Expenses The Bank has developed an
Implementation procurement still has Bank can achieve cost the Bank can achieve and transparent improves as its efficiency through reduced • Intangible Assets End-to-End Procurement
of End-to-End significant potential savings on paper in the cost savings on paper processes, reducing procurement paper usage and enhanced application to support a
Procurement for development, one procurement process. in the procurement risks of fraud or system becomes procurement process sustainable and paperless
of which is through • The Bank’s reputation process. non-compliance more integrated, efficiency. procurement process.
(Likelihood: High) digitalization. improves as its in procurement transparent, and • Enhanced Bank reputation
procurement system activities. paperless, while through a procurement
becomes more business processes system that is more
integrated, transparent, become more transparent, integrated, and
and paperless, while efficient and paperless.
business processes sustainable.
become more efficient.
Natural Resource Use and Environmental Management
Opportunity OJK has issued the • Increased Green • Increased Through lending By maintaining a • Increased green financing • Loans • The Bank has extended
from the Indonesia Green Financing: Focus Sustainable activities to strong commitment through loans to sectors • Interest Income loans to relevant sectors
implementation Taxonomy / Taxonomy on alignment with Financing: Focus sustainable sectors, to sustainability, BTN aligned with the OJK Green • Provision and (KKUB OJK), such as
of KKUB and the for Sustainable Finance in OJK’s KKUB and TKBI on OJK’s KKUB and the Bank will gain can strengthen its Taxonomy. Commission Income SPAM projects, renewable
OJK’s Indonesia Indonesia as a guideline frameworks. Green Taxonomy access to funding, reputation among • Access to funding through and Other Operating energy, environmentally
Sustainable for financial service • Access to Green enhances the such as through investors, improve the issuance of green and Income friendly transportation,
Finance Taxonomy institutions (FSIs) to map Funding: Enables the bank’s reputation the issuance of its ESG ratings, and sustainability bonds. • Issued Securities and others.
(TKBI), as well as and increase financing issuance of green, and investor green, social, or enhance the Bank’s • Improved ESG reputation / Green Bonds / • The Bank has planned
the government’s in the Green sector. In social, or sustainability confidence. sustainability bonds. financial stability and through green building Sustainability Bonds the issuance of thematic
Net Zero Emissions addition, OJK classifies bonds. • Green Building resilience. certifications and • Subordinated Liabilities green, social, and
(NZE) targets Sustainable Business • Support for NZE Certification: environmental initiatives. sustainability bonds.
Activity Categories 2060: Green Building Effective • It also supports
(Likelihood: High) (KKUB) as a guide for FSIs certification and environmental environmental
to support financing in environmental initiatives and waste preservation and waste
sustainable sectors and enhance the Bank’s management management programs,
contribute to the NZE reputation. supports green resulting in Green
2060 target. certification and Building certification for
strengthens the two BTN buildings.
Bank’s reputation.
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Description of Impact Time Horizon
Sustainability Potential Positive Financial Statement Impact Affected Financial
Sustainability Mitigation Measures
Opportunity Impact Short-term Medium-term Long-term Analysis Statement Accounts
Opportunity
Climate Change and Ecosystems
Revenue and The government has • Increased Income: BTN BTN can increase • As the volume • With the increasing • Increased revenue from • Other Operating • The Bank has conducted
innovation enacted Presidential can generate revenue its income through of low-emission volume of the sale of carbon credits Income a feasibility study with
opportunities from Regulation No. 98/2021 on from the sale of carbon carbon trading housing increases, low-emission generated from low- • Provision and consultants as the
carbon credits Carbon Economic Value credits. on the Indonesia BTN may generate housing, BTN emission housing projects. Commission Income basis for the sale of
(NEK) and OJK Regulation • Enhanced ESG & Carbon Exchange more carbon can significantly • Strengthened ESG profile • Other Financial Assets carbon credits from
(Likelihood: No. 14/2023 on Carbon Competitiveness: (IDX Carbon) as well credits that can be enhance revenue and improved investor (Carbon-Related low-emission housing
Medium) Trading through the Participation in carbon as in the operational traded, potentially from carbon attractiveness. Assets / Environmental projects.
Carbon Exchange (IDX trading improves ESG international carbon increasing carbon trading as a stable • Diversification of carbon- Instruments) • As the next step, BTN
Carbon). Under these ratings and attracts markets. trading volumes income source. based financial products and will seek approval from
regulations, BTN has the investors. and contributing to • Carbon credit green financing. relevant authorities to
opportunity to sell carbon • Green Product additional revenue prices are • Support for the transition to a register carbon savings
credits both domestically Diversification: BTN can streams. expected to rise low-carbon economy. and prepare a Climate
and internationally from develop products based • The expansion as emissions Mitigation Action Plan
low-emission buildings on carbon credits. of the domestic regulations (DRAM). The DRAM
that meet sustainability • Support for NZE 2060: carbon market become stricter, draft will be registered
standards. Utilizing carbon credits may create more increasing and evaluated by the
contributes to the competitive and demand from National Registry System
transition toward a low- attractive carbon companies (SRN) and international
carbon economy. credit pricing, required to reduce verification bodies.
providing potential their carbon • BTN currently has 11,412
benefits for BTN. footprint. low-emission housing
• Carbon credits units under a pilot
may become a project, with a target to
more established develop a total of 150,000
financial low-emission housing
instrument, units by 2029.
creating
opportunities for
integrat
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
BTN uses metrics for material topics to set targets and to monitor the achievement of activities supporting the realization of those targets.
Metrics and Targets
KPIs Related to Board of Directors’
Material Topic KPI Strategy and Objectives Realization of KPIs
Compensation
Information Security No incidents related to cybersecurity BTN continuously enhances its Information Technology security capabilities as part of its No incidents related to cybersecurity
breaches were recorded. commitment to strengthening strategic IT security capacity, supporting a secure digital breaches were recorded.
environment, and minimizing the risk of cybersecurity breaches. These efforts are carried
out through the implementation of a defense-in-depth approach covering endpoint,
application, network, IT infrastructure, and data security.
In line with regulatory priority controls, BTN also continues to strengthen its cyber resilience
and improve cyber risk management by implementing the NIST Cybersecurity Framework,
which includes the functions of Govern, Identify, Protect, Detect, Respond, and Recover.
In addition, BTN regularly measures and evaluates the effectiveness of its information
security controls to ensure the optimal protection of systems and data. These efforts are
reflected in the achievement of ISO/IEC 27001:2022 certification and the implementation of
the IT Security Index as part of the mechanism for assessing the maturity level of Information
Technology security across BTN.
Employment Human Capital Diversity improved, with the BTN remains committed to upholding human rights, diversity, equality, and inclusion across The ratio of women in the nominated
average ratio of women in the nominated all of its operations, employment practices, and services. This commitment covers the full talent pool was targeted at 28%, with
talent pool reaching 25%, and millennials employee lifecycle, from recruitment, including employees with disabilities, to competency actual realization reaching 33.3%.
(under 42 years old) accounting for 15% of development, career management, remuneration, and employee welfare. BTN ensures that Meanwhile, the ratio of young top
those included in the nominated talent pool all employees have equal opportunities without discrimination based on gender, religion, talent (≤ 42 years old) in the nominated
(BoD–1 level), who were proposed to the ethnicity, race, or other personal background. This approach helps create an inclusive and talent pool was targeted at 16.5% and
Ministry of SOEs based on performance and safe working environment that supports employee productivity. achieved 16.67%.
capability.
In addition, BTN strengthens organizational capabilities through competency development Going forward, BTN will continue its
programs in ESG, digital banking, and service excellence, as well as through employee efforts to maintain diversity within the
welfare improvement and employee engagement initiatives. Board of Commissioners and Board
of Directors, particularly in terms of
gender and age diversity.
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
KPIs Related to Board of Directors’
Material Topic KPI Strategy and Objectives Realization of KPIs
Compensation
Sustainable Products Sustainable financing/loans categorized BTN is committed to implementing sustainable finance by providing broad support for Sustainable financing/loans
and Services as Sustainable Business Activities (KKUB) sustainable economic growth through sustainable financing. In doing so, BTN refers to amounted to Rp203.45 trillion,
amounted to Rp200.26 trillion. the Sustainable Business Activities Category (KKUB) as the basis for supporting business consisting of Rp7.01 trillion in Green
activities that aim to preserve the environment and improve social well-being. Financing and Rp196.43 trillion in Social
Financing.
The number of active users of the balé by BTN BTN prioritizes digitalization and access to financing through the development of digital 3.7 million balé by BTN users
app supports the digitalization of financial platforms such as the balé by BTN Super App, balé Properti, and balé Community to make
services for customers. A total of 1.69 million inclusive financial services more accessible, especially for underserved communities.
users were registered. Collaboration with merchants, fintech companies, and banking agents (Agen BTN) enables
the Bank to expand its service reach, supported by continuously strengthened technology
infrastructure to ensure system security and reliability. BTN also actively develops digital
solutions and expands technology-based service channels to reach more users and provide
financial literacy programs for underserved, underbanked, and MSME communities.
Several material topics are also considered important to external stakeholders and are material topics identified as key priorities are Community Development and Sustainable
therefore managed in a targeted manner to address their expectations and needs. Products and Services. These topics reflect the Bank’s commitment to supporting social
BTN emphasizes efforts to create positive impacts while minimizing negative impacts and environmental sustainability in a sustainable manner.
arising from all operational activities, products, and services. Within this framework, two
Material Issues for External Stakeholders
Related
Material Topic Impact Explanation of Impacts on Stakeholders Quantitative Target Realization
Stakeholders
Community Community, Positive BTN plays an active role in supporting community development TJSL disbursement amounted to Rp120 TJSL disbursement amounted to
Development Regulators through economic empowerment programs, support for MSMEs, billion. Rp119.91 billion.
provision of access to adequate housing, and improved access
to education and healthcare. These initiatives create economic
opportunities, generate employment, and help build more
independent, inclusive, and competitive communities.
Negative Challenges such as dependency risk, misalignment between
programs and local needs, and potential social inequality must
be anticipated to ensure that the programs remain effective and
sustainable.
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Related
Material Topic Impact Explanation of Impacts on Stakeholders Quantitative Target Realization
Stakeholders
Sustainable Community, Positive BTN continues to play an active role in implementing ESG principles • MSME loan disbursement amounted • MSME loan disbursement amounted
Products and Regulators across the Bank’s business processes and operations through to Rp4.41 trillion. to Rp5.67 trillion.
Services inclusive financing, particularly for the MSME sector and subsidized
mortgage programs. This initiative aims to improve public access to
affordable financing, support local economic growth, and enhance
community welfare through access to decent housing and the
strengthening of micro, small, and medium enterprise capacity.
Negative Challenges such as the potential dependency of communities
on subsidized financing programs, including People’s Business
Credit (KUR) and Subsidized Mortgages, need to be balanced with
improved financial literacy and stronger business capacity to
ensure that these programs remain effective and sustainable.
Climate Risk Stress Testing (CRST) Matriks Climate Disorderly Too Little, Too Late
Risk Stress
High
Since the Financial Services Authority (OJK) issued the Climate Risk Testing (CRST)
Stress Testing (CRST) guidance in 2023, BTN has integrated CRST
into the risk management framework as part of strengthening
climate risk management and long-term financial resilience. Delayed
CRST is implemented through scenario-based stress testing to 2º C
Transition Risk
identify, quantify, and assess the transmission of climate change
risks, covering both physical and transition risks, and their
potential impacts on the Bank’s risk profile, financial performance,
and capital adequacy in a comprehensive manner. Net Zero
2050
(1,5ºC)
Current
Policies
Orderly Hot House World
Low
Low Physical Risk High
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
BTN uses climate scenarios developed by the Network for Greening the Financial System variables, including gross domestic product (GDP), inflation, exchange rates, and interest
(NGFS) and adapted to Indonesia’s conditions by OJK, namely: Current Policies, which rates, as the main risk drivers to assess the impact of climate risks on credit risk, market
reflects existing policies with no additional changes; Delayed Transition, which assumes risk, liquidity risk, and operational risk, as well as the implications for the Bank’s capital
a postponed shift to a low-carbon economy that requires significant adjustments in the adequacy and overall financial resilience.
future; and Net Zero 2050, an ambitious transition scenario aimed at achieving net zero
emissions by 2050. These scenarios are linked to projections of key macroeconomic The following presents an illustration of the CRST methodology, covering the process from
information gathering to the assessment of capital adequacy impacts.
CRST Framework Overview
1. Information Collection 2. Climate Risk Transmission 3. Impact Assessment
NGFS Portfolio Level Transition Risk Indicators Credit Risk
Transition:
Risk Assessment: Probability of Default (PD) Expected Credit Loss (ECL)
• Macro
Loan
• Micro
Quantitative
Credit RWA Stressed Test Impact
Physical
Non-Performing Loan Capital Adequacy Ratio
Interest Income
(CAR)
Loss Given Default (LGD)
IPCC Market Risk
Loan To Value Ratio (LTV) Market RWA
Physical Changes in the PD matrix
Operational Risk Equity (B/S)
Securities Operational RWA
Mark-to-Market (MtM)
Internal Data:
Qualitative
• Borrowers Interest Income rate changes
• Bank Repricing Gap
Liquidity Risk
Inflow
Physical Risk Assessment
High Quality Liquid Asset
External Data: LCR
Loss Event (HQLA)
• Public of Collateral Outlaw
• Private
To translate scenario-based stress testing results into portfolio analysis, BTN enhances projections are translated into sectors with higher climate risk exposure. The following
its modeling through the collection of relevant internal and external data. Internal data chart presents the Distribution of Climate Risk Exposure by Sector, summarizing exposure
include credit portfolio profiles and sectoral exposures, including borrower and collateral concentration and supporting the prioritization of mitigation actions within the credit
information as required for the analysis, while external data is used to enrich the risk context portfolio.
and strengthen variable assumptions. Using a top-down approach, macroeconomic
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Distribution of Climate Risk Exposure by Sector
Agriculture, Forestry, and Fisheries 0.01%
Manufacturing 0.33%
Mining and Quarrying 0.49%
Transportation and Trade 1.42%
Electricity, Gas, Steam/Hot Water Supply 1.51%
Other Sectors Outside the Climate Risk Scope* 3.31%
Construction 5.36%
Mortgage Loans (KPR) 87.57%
0% 10% 20% 30% 40% 50% 60% 70% 80% 90%
A. Transition Risk Scenario Analysis Macroeconomic Projection Chart
To assess transition risk, BTN applies scenario-based stress testing using projections
of key macroeconomic variables sourced from the NGFS and adapted to Indonesia’s Coal Price Gas Price Oil Price
8,100
conditions by OJK. The variables analyzed serve as risk drivers to assess the 7,100
MAIN INDICATORS
Chart Legend:
6,100
transmission of transition risk to the Bank’s credit portfolio, including the implications 5,100
4,100
for key credit risk metrics such as stressed Probability of Default (PD), stressed Loss 3,100
2,100
Given Default (LGD), and Non-Performing Loans (NPL). 1,100
100
Year Year Year
Benchmark Interest Rate USD /IDR Exchange Rate Inflation Rate Total Population GDP growth rate
SUPPORTING INDICATORS
6.60 16,500 1.70 5.50
6.40 16,000 1.50 5.00
6.20 15,500 1.30 4.50
6.00
15,000 4.00
5.80 1.10
%
%
14,500 3.50
5.60 0.90
14,000 3.00
5.40
0.70
5.20 13,500 2.50
5.00 13,000 0.50
2.00
Year Year Year Year
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
(dalam Rp Miliar)
The CRST simulations under the Current Policies, Delayed Transition, and Net Zero 2050 Mapping of Physical Risk
Pemetaan Exposure
Agunn for BTN Mortgage (KPR) Collateral
Debitur KPR BTN
scenarios indicate that transition risk can affect capital adequacy through changes in
CKPN (expected credit loss allowances), mark-to-market movements in securities, and 18.00%
Pare-Pare, Sidoarjo
adjustments to risk-weighted assets (RWA) for credit, market, and operational risk. Across Malang, Kediri
15.00%
the simulations, BTN’s capital adequacy ratio (CAR) remained at around 18.5% and stayed
Tangerang Regency and Tangerang Selatan
Mataram
above the regulatory minimum, although at certain horizons capital pressure increased, 12.00%
Bogor
as reflected by the breach of the Bank’s internal thresholds in line with the applicable risk
Damage Ratio
appetite framework and trigger levels. 9.00% Surabaya
6.00% Bandung
B. Physical Risk Scenario Analysis Jakarta Utara Karawang
Within the CRST framework, BTN identifies physical risk as the risk arising from disaster 3.00%
events such as floods and fires that may impair collateral quality and increase Loss
Given Default (LGD). To manage this risk, BTN maps collateral portfolio exposure 0.00%
Rp- Rp10,000 Rp20,000 Rp30,000 Rp40,000
Collateral Value 2025 (in Rp Billion)
by considering collateral values and regional damage ratios to identify exposure
© 2025 BTN “Mitra utama dalam pemberdayaan finansial keluarga Indonesia”
concentrations and collateral vulnerability, which serve as the basis for prioritizing
physical risk mitigation. C. Climate Change Mitigation Plan
Following the CRST results, BTN has developed climate change mitigation plans
Based on the mapping results, BTN assesses the distribution of exposure and areas focused on strengthening data foundations and enhancing climate risk management
with relatively higher vulnerability as part of its qualitative operational risk assessment. capabilities. Key initiatives include the development of GHG Data Management,
Considering historical disaster events, the characteristics of the collateral portfolio, increased automation of climate risk measurement and scenario analysis, as well as
and mitigation measures already in place, the overall physical risk impact from floods the preparation of a decarbonization plan and the establishment of Net Zero targets
and fires in 2025 is assessed as minimal or close to nil. The mapping of physical risk to guide the Bank’s long-term transition.
exposure against collateral values and regional damage ratios is presented in the
following chart. In addition to portfolio mapping, BTN also considers the financial implications of
climate risk within CRST simulations. Based on these simulations, BTN estimates the
financial impact of physical risks from floods and fires increased by 56.46% compared
to the previous year, driven by the expansion of its Sustainable Finance Action Plan
(RAKB) programs.
Gradually, climate risk analysis results are integrated into underwriting policies and
pricing strategies through adjustments to Risk Acceptance Criteria (RAC), risk limits,
and BTN Portfolio Guidelines. This approach aims to strengthen risk discipline, support
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
the development of a green portfolio, and ensure that climate risk considerations are availability. In this regard, the risk management information system is managed in a
embedded in business decisions and credit portfolio management. coordinated manner across divisions, with a focus on enhancing the quality of the risk
data repository, enabling risk measurement and monitoring processes to be carried out
Risk Management Information System Management in an integrated, timely, and regulator-compliant manner.
The Bank operates a risk information management mechanism that covers risk exposures, Impact and Risk Assessment
risk tolerance, compliance with internal limits, stress testing results, and the consistency
of policy and procedure implementation. This risk information is presented in periodic Impact and risk assessment is a comprehensive evaluation process carried out by the
reports to management as a basis for decision-making, the determination of mitigation Bank to identify and analyze potential risks and impacts arising from specific activities or
measures, and the required follow-up actions. policies. This assessment aims to ensure effective risk control while ensuring that every
business decision considers its implications for the Bank’s operations and long-term
The reliability of the risk information management mechanism is supported by sustainability. The process comprises the following key elements:
the provision of adequate back-up systems to minimize potential disruptions. The
effectiveness of the system is reviewed periodically to ensure the continuity of risk data
Key Elements of Impact and Risk Assessment
New Product Development BTN Technology / Applications Responsible Investment Human Resource Development Policy
The Bank conducts risk assessments The risks associated with the use Each investment is assessed The human resource development
for new funding and lending products of technology are specifically based on sustainability principles policy is evaluated to ensure that the
by considering their potential impacts evaluated with a focus on data by considering its social and management and enhancement of
on customers, operations, as well as privacy and cybersecurity to ensure environmental impacts, thereby employee competencies are carried
business, information technology, the protection of customer data and generating financial value out effectively, support the Bank’s
compliance, legal, and financial the reliability of information systems, while fulfilling social and ethical strategic objectives, and do not
aspects, to ensure that product as well as to prevent data breaches responsibilities. create additional operational risks.
implementation is carried out in a safe and cyberattacks.
and controlled manner.
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Comprehensive Internal Control System
All supervisory activities, policies, and risk processes are supported by a comprehensive with regulations and applicable laws, and mitigate potential losses, irregularities, and
and consistent internal control mechanism. This pillar ensures compliance with breaches of prudential principles.
applicable regulations, the effectiveness of controls, and the implementation of corrective
follow-up actions, thereby maintaining risk management discipline and supporting the Within this framework, risk control is a core element embedded in the internal control
sustainability of the Bank’s performance. system and functions to ensure that risk exposures and risk levels remain within the
established tolerance. Control mechanisms include, among others, hedging, the issuance
Risk Control System of guarantees, asset securitization, credit derivatives, and capital strengthening to
absorb potential losses. The reliability of the internal control system is the responsibility of
BTN implements a comprehensive internal control system to ensure the effective all operational units, supporting units, and the Internal Audit Unit. Audits of all operational
application of risk management. This system aims to safeguard the Bank’s assets, activities are conducted comprehensively at least once every 3 (three) years. All control
ensure the reliability of financial and management reporting, enhance compliance processes are designed in an integrated manner and are outlined through the following
stages.
Risk Control Framework
Three Lines Model
Governing Body
Governing Body Board of Commissioners (BoC)
Accountability to stakeholders for oversight of the organization
External Assurance Provider
Management
Role of the Governing Body: integrity, leadership, and transparency
Board of Directors (BoD)
First Line:
Management Internal Audit Business & Operational Units
Actions (including risk management) to achieve organizational objectives Independent Assurance Second Line:
Compliance, Risk & Policy Units
Third Line Role
Second Line Role Providing independent and Third Line:
First Line Role
Providing expertise, support,
Delivery of products and services objective assurance and Internal Audit
monitoring, and oversight on risk- advisory services on all matters
to customers; risk management
related matters related to the achievement of
objectives
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Internal Control Over Financial Reporting (ICOFR)
An Internal Control over Financial Reporting (ICOFR) is part of the internal control system In line with this implementation, the Bank has conducted an ICOFR diagnostic since
to provide reasonable assurance over the reliability and integrity of financial reporting, 2024 and began implementation in 2025. The Bank has also established Special Policies
in accordance with POJK No. 15/2024 on the Integrity of Bank Financial Reporting and SK- and Technical Guidelines and formed a dedicated working unit (UKK) within the Digital
5/2024 on the Technical Guidelines for Internal Control over Financial Reporting (ICOFR) & Operations Risk Management Division to ensure ICOFR implementation follows the
for State-Owned Enterprises. defined stages, including:
Stages of BTN’s ICOFR Diagnostic Review
Stage 1 Stage 2 Stage 3 Stage 4 Stage 5
Design Implementation and Ongoing Evaluation Remediation Reporting
BTN has defined the ICOFR scope Monitoring BTN is currently in the evaluation In this stage, several BPM and RCM BTN will prepare a management
by coordinating with the First Line, BTN has conducted Control Self- phase, which includes data items from the First Line require assessment report by considering
Second Line, and Third Line. The Assessment (CSA) by the First Line, preparation by the First Line improvement due to identified the Degree of Deficiency (DOD)
design phase includes preparing, followed by validation of control supported by the Second Line deficiencies in control design based calculation results and the ICOFR
reviewing, and approving the design and evaluation of CSA for assessment by the Third on CSA results conducted by the evaluation outcomes from the
Business Process Mapping (BPM) results by the Second Line through Line. At this stage, the Third Line First Line and TOO performed by Third Line, referring to the roadmap
and Risk Control Matrix (RCM) by the the Test of One (TOO). evaluates the effectiveness of the Second Line. The Third Line outlined in the Technical Guidelines.
First Line, which are then evaluated ICOFR implementation through the reassesses remediation outcomes
by the Second Line. Test of Design (TOD) and Test of through TOD and TOE.
Effectiveness (TOE).
Through the implementation of ICOFR, BTN reaffirms its commitment to GCG principles strengthening internal controls, enhancing the transparency and accountability of financial
reporting, and supporting business sustainability amid the evolving dynamics of the banking industry.
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Basel Implementation
The Basel framework is an international standard aimed at strengthening banking stability through enhanced capital adequacy, liquidity, and risk management. In Indonesia, the
implementation of Basel is carried out in accordance with OJK regulations to maintain bank resilience, customer confidence, and financial system stability. In line with the application
of risk management, particularly Basel II and Basel III, which apply to all commercial banks, BTN has complied with the following requirements:
Requirements Status
Implementation of Basel The Bank has implemented market risk measurement using the standardized approach in accordance with SEOJK No. 38/SEOJK.03/2016 dated September
II Pillar 1 15, 2016 concerning Guidelines for the Use of the Standardized Approach in the Calculation of the Minimum Capital Adequacy Requirement for Commercial
Banks by Taking Market Risk into Account. The portfolios included in the calculation of the Market Risk Capital Adequacy Requirement comprise the trading
book portfolio for interest rate risk, as well as both the trading book and banking book portfolios for foreign exchange risk. The Bank has also prepared for the
implementation of SEOJK No. 23/SEOJK.03/2022 dated December 7, 2022 concerning the Calculation of Risk-Weighted Assets for Market Risk for Commercial
Banks, which became effective on January 1, 2024. This preparation included trial calculations and reporting to the Financial Services Authority (OJK) for Market
Risk RWA positions as of June 2023, September 2023, and December 2023.
Implementation of Basel The Bank has submitted reports on the implementation of risk management for Interest Rate Risk in the Banking Book (IRRBB) and IRRBB calculation reports to the
II Pillar 2 regulator on a quarterly basis, in accordance with SEOJK No. 12/SEOJK.03/2018 dated August 21, 2018 concerning the Implementation of Risk Management and
Standardized Measurement Approach for Interest Rate Risk in the Banking Book (IRRBB) for banks.
Implementation of Basel In relation to the regulator’s plan to implement Basel III as stipulated in OJK Regulation No. 22 of 2022/2023, the Bank has maintained its Capital Adequacy Ratio
III (CAR) at 20.92%, well above the minimum Basel III requirement of (12.75%).
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Code of Conduct and Business Ethics [GRI 2-23, 2-24]
The Code of Conduct is BTN’s commitment to GCG by referring to banking best practices. Business Ethics and Code of Conduct are accessible to all parties through BTN’s official
Credibility and the trust of the public, shareholders, and customers form an essential website, ensuring transparency and openness of information. The Code of Conduct
foundation for the Bank’s business sustainability. Accordingly, all of BTN’s business not only sets the expected standards of behavior in a business context but also aligns
activities are required not only to comply with applicable laws and regulations but with respect for Human Rights, in accordance with the United Nations Guiding Principles
also to uphold prevailing norms and ethical standards within society and the business on Business and Human Rights (UNGP BHR). It underscores the Bank’s commitment to
community. Strong ethical implementation is a key element in building reputation and operating ethically and upholding the fundamental rights of individuals in all aspects of
strengthening BTN’s position as a good corporate citizen. To this end, the Bank upholds its business activities. [GRI 2-23]
integrity through the implementation of clear conduct and ethical guidelines as a
reference for all BTN personnel in carrying out their duties professionally, in line with BTN’s In addition, every action undertaken by the Bank must be carried out in accordance
vision, mission, values, and applicable internal and external provisions. with the principle of prudence, meaning that all decisions and activities are conducted
with careful consideration and full accountability. The implementation of BTN’s Code of
BTN has ethical and conduct standards that are aligned with the Bank’s vision, mission, Ethics requires all relevant parties to perform due diligence, namely a thorough review of
and cultural values, with implementation formalized through the Joint Decree of the prospective customers, business partners, or other related parties, to ensure compliance
Board of Commissioners Number 01/SKPB/KOM/BTN/2024 and the Board of Directors with the ethical and legal standards established by BTN.
Number SKPB-01/DIR/BTN/2024 concerning the Business Ethics and Code of Conduct of
PT Bank Tabungan Negara (Persero) Tbk. This Code of Conduct provides clear guidance Compliance with the Code of Ethics has a direct impact on BTN’s reputation and risk
for all members of the Bank to act in accordance with the values upheld by the Bank and profile. Ethical breaches may give rise to reputational risks that can affect operational
to maintain integrity and professionalism in every aspect of its operations. and credit risks. Therefore, the Code of Ethics is implemented to foster professional
conduct and instill a work culture grounded in BTN’s values. The Code comprises four
main sections, as follows.
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Introduction Business Ethics Standards Employee Conduct Standards Implementation and Enforcement
The Code of Conduct constitutes a The ethical standards govern the Bank’s Members of the Board of Commissioners, Any violation of the Corporate Code of
compilation of policies and provisions that relationships with employees, customers, the Board of Directors, and employees Conduct must be reported to the Human
establish standards of behavior for the Board business partners, government institutions, are required to avoid conflicts of interest Capital Management and Culture Specialist
of Commissioners, the Board of Directors, and communities, the media, and competitors. and abuse of authority, and are prohibited Division, with confidentiality guaranteed.
employees. Its implementation serves as a These relationships are conducted based from giving or receiving gratuities that Reports are followed up through evaluation
reference for business activities, managerial on principles of honesty, transparency, may influence decision making. They and the determination of sanctions or
practices, and performance assessments, and mutual respect to safeguard the are expected to uphold fair business corrective actions by the Board of Directors
while also supporting the application of GCG Bank’s integrity. competition, conduct business ethically and or the Board of Commissioners, and are
principles. in accordance with applicable laws and reinforced by preventive measures to avoid
regulations, avoid monopolistic practices, recurrence of breaches. [GRI 2-16]
and comply with all legal requirements and
internal regulations.
Oversight of Ethical Issues
In an effort to strengthen good governance and ensure compliance with ethical As part of its commitment to managing fraud risk, the Anti-Fraud Sub-Committee is
principles, BTN implements rigorous oversight of fraud and ethical breaches through responsible for determining the necessary corrective actions and reporting significant
the Anti-Fraud Sub-Committee under the Risk Management Committee. This Sub- decisions to the Board of Directors. In carrying out its duties, the Sub-Committee
Committee plays a strategic role in establishing policies, strategies, and the fraud risk formulates policies and fraud risk tolerance limits, evaluates the effectiveness of the
management framework to prevent, detect, and address potential breaches. The Anti- prevention strategies that have been implemented, and ensures that any risks that arise
Fraud Sub-Committee comprises permanent and non-permanent members from remain within acceptable limits. In addition, BTN conducts periodic audits across all Bank
various directorates, including Risk Management, Operations, Information Technology, operations at least once every three years.
and Legal, with the Head of the Operational and Digital Risk Management Work Unit
serving as the secretary.
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Meetings of the Anti-Fraud Sub-Committee are held regularly at least once every three Internalization of the Code of Conduct
months, or more frequently if necessary. Decisions are made through deliberation or, if
consensus cannot be reached, by voting. All decisions are documented in formal meeting The Code of Conduct applies to all members of the highest governance bodies and
minutes and signed by the chairperson and all committee members as a demonstration employees in every aspect of the Bank’s business activities, including interactions with
of transparency and accountability. stakeholders. This is stipulated in BTN’s Business Ethics and Code of Conduct. The Bank
requires every individual within the organization to sign an Integrity Pact to ensure that
To ensure the effective implementation of anti-fraud policies, the Anti-Fraud Sub- the Code of Conduct is implemented responsibly. The successful implementation of the
Committee is supported by a Supporting Group responsible for developing strategic Code of Conduct is the responsibility of leaders at each work unit, who are required to
recommendations, collecting data, and evaluating policy implementation. In addition, the ensure that all employees understand and properly apply the Code of Conduct within
Operational and Digital Risk Management Work Unit plays an important role in monitoring their respective working environments.
and following up on the outcomes of decisions made in committee meetings. Through
this structured oversight mechanism, BTN is committed to fostering a high-integrity BTN implements the Code of Conduct in a comprehensive manner, covering introduction,
working environment, mitigating potential fraud risks, and ensuring that the principles of awareness campaigns, implementation, reporting, and follow-up on breaches of the
good corporate governance are applied consistently across all Bank operations. Code of Conduct. [GRI 2-23]
Code of Conduct Internalization Process
Socialization Implementation Reporting and Follow-Up
• The Code of Conduct is disseminated and accessible to all • Completion and signing of the Integrity Pact by all employees in • Implementation of the Anti-Bribery Management System (ABMS)
Bank personnel through the Digital Room for E-learning Modules accordance with the values set out in the Code of Conduct; ISO 37001:2016 as part of the application of business ethics and
(DREAM). In addition, quizzes on the Code of Conduct are • Internalization of the Code of Conduct, gratification control, and conduct as stipulated in the Code of Conduct;
conducted to assess employees’ level of understanding; and the Anti-Bribery Management System (ABMS) for all employees • Implementation of the Whistleblowing System (WBS); and
• Commitment to the implementation of the Code of Conduct through the Digital Room for E-learning Modules (DREAM); • Imposition of sanctions on employees who violate the Code of
is also formalized through an Integrity Pact that must be • Collaboration with the Corruption Eradication Commission Conduct.
signed by all members of the Board of Directors, the Board of (KPK) through the Integrity Professional Program (PROFIT), which
Commissioners, and Bank employees. Furthermore, the Code of includes the development of competent human resources to
Conduct is accessible to all Bank stakeholders through the Bank’s strengthen integrity and support corruption prevention within
website. the Bank. This is carried out through participation in training
as Integrity Development Experts (API), certification as Anti-
Corruption Counselors (PAKSI), and joint anti-corruption
campaigns with KPK through various communication channels;
• Implementation of the gratification control program in
accordance with the established plan and periodic reporting of
its implementation to KPK on a semiannual basis; and
• Management of reports on the receipt of gratification from all
work units and reporting to KPK in accordance with applicable
regulations.
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As part of its efforts to internalize its commitment to maintaining high ethical standards, This training constitutes an important element in strengthening BTN’s ethical culture
BTN conducted Code of Conduct training in 2025 for all employees, including permanent and ensuring that all actions align with the values of integrity, transparency, and
employees, contract employees, part-time workers, as well as contractors and developer accountability. By involving all employees and business partners, BTN is committed to
partners. This training aimed to ensure that all parties involved understand, embrace, fostering an ethical working environment and safeguarding the Bank’s reputation and
and comply with the principles of conduct applicable at the Bank and are able to apply credibility. The training also aims to raise awareness of the importance of ethical conduct
them in their daily activities. In addition, all new employees are required to participate in business interactions and to equip participants with the skills to manage potential
in business conduct training as part of their orientation to ensure they understand and conflicts of interest.
implement the established standards of conduct.
Implementation of Employee Training on Ethical Standards [GRI 404-2]
Training Name Training Date Number of Employees Participating Total Training Hours
Know Your Employee February 11,463 2,866
Gratification Control and SMAP ISO 37001:2016 Policy March 10,979 6,404
Employee Disciplinary Sanctions April 11,784 7,097
Conflict of Interest (COI) Management June 11,636 3,172
Fair Business Competition Compliance Procedures July 11,957 2,586
In line with efforts to internalize and strengthen an ethical culture, BTN consistently enforces and organizational discipline. The following presents details of the number of employees
its Code of Conduct through the imposition of sanctions for every proven violation. subject to sanctions for breaches of the Code of Conduct by sanction category during
Sanctions are applied in a graduated manner according to the severity of the violation, the period 2023–2025.
as a manifestation of the Bank’s accountability and commitment to upholding integrity
Sanctions for breaches of the Code of Conduct
Number of Employees
No Sanction Categories Types of Sanctions
2025 2024 2023
1 Minor Sanctions Minor Category A 20 4 11
Minor Category B 25 15 15
Minor Category C 0 0 11
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Number of Employees
No Sanction Categories Types of Sanctions
2025 2024 2023
2 Moderate Sanctions Moderate Category A 24 8 15
Moderate Category B 14 20 12
Moderate Category C 0 0 10
3 Severe Sanctions Severe Category A 4 3 1
Severe Category B 42 27 43
Severe Category C 5 4 1
Total 134 81 119
Anti-Fraud and Conflicts of Interest [GRI 2-15]
BTN has implemented detailed formal policies on bribery and anti-corruption, which are Anti-Fraud
set out in the form of special policies and technical regulations. These policies aim to
prevent bribery practices across all Bank operations. In 2023, the President Director and Public trust in integrity is a foundation for BTN in building sustainable relationships with
the President Commissioner of BTN signed the BTN Anti-Bribery Policy, which forms part of stakeholders. Accordingly, the Bank conducts its business activities honestly, fairly, and
the Anti-Bribery Management System (ABMS) Guidelines. The signing underscores BTN’s free from corruption, bribery, and fraud, recognizing that any violation may have a
commitment to upholding integrity and transparency in every aspect of its operations. material impact on the Bank’s reputation and sustainability performance.
Through these policies and guidelines, BTN ensures that all Bank personnel and business BTN emphasizes that any breach of anti-corruption, anti-bribery, and anti-fraud policies
partners comply with high standards of integrity and anti-corruption. The Anti-Bribery is a serious violation and will be subject to strict sanctions in accordance with applicable
Policy is supported by clear guidelines, procedures, and internal controls to prevent bribery regulations. This commitment is supported by General Policy No. 6, which covers legal and
practices, while strengthening a culture of accountability and ethics. The implementation compliance matters, AML (APU), CFT (PPT), counter-proliferation financing (PPPSPM), and
of this policy supports compliance with applicable legal requirements, safeguards BTN’s GCG principles, and applies to all employees, both permanent and contract, including
reputation, and fosters a clean and trustworthy business environment. the Board of Commissioners and the Board of Directors. It is further reinforced through
guidelines, procedures, and internal controls. In line with POJK 12/2024, the Bank has
developed the 2024–2026 Anti-Fraud Strategy (SAF) Roadmap based on OJK’s four pillars
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and translated into ten key aspects: (1) Organization, (2) Strategy & Policy, (3) Procedure Anti-Fraud Strategies for Commercial Banks. This program is supported by integrated
and Governance, (4) Process, (5) Fraud Investigation, (6) System, (7) Use of Data, (8) fraud prevention, detection, investigation, and monitoring measures. The Bank
Use of Analytics, (9) Digital Channels, and (10) Reporting/Training. BTN also established a consistently conducted anti-fraud policy awareness sessions for all employees (100%),
Fraud Risk Management Department under the Digital and Operations Risk Management totaling 11,414 employees during the reporting year. The Bank also communicated its anti-
Division (DORD) to ensure effective implementation. [GRI 3-3] corruption policy to all active vendors (100%), totaling 1,092 vendors during the reporting
year, through the inclusion of SMAP clauses in contracts, reinforced by regular anti-
In line with these efforts, BTN operates a Zero Tolerance to Fraud and Zero-Defect program corruption and anti-fraud training. The following is a breakdown of employee anti-fraud
in accordance with OJK Regulation Number 39/POJK.03/2019 on the Implementation of training conducted in 2025. [GRI 205-2]
Implementation of Employee Anti-Fraud Training [GRI 404-2]
Training Name Training Date Number of Employees Participating Total Training Hours
Compliance Excellence – Anti-Fraud Strategy (SAF) January 10,813 2,703
Identification of Critical Fraud Points in Procurement of Goods/Services and Corporate Sector Supply February 15 180
Chain Management
Monitoring and Maintaining Whistleblower: Towards an Effective Anti-Fraud Mechanism March 2 28
Fraud Auditing Training July 1 16
National Anti-Fraud Conference July 6 108
POJK 12 Socialization on the Implementation of Anti-Fraud Strategy July 10 35
Certified Fraud Examiner (CFE) August 1 40
Fraud Risk Assessment (FRA) Workshop August 3 21
Anti-Fraud Manager Certification (CAFM) Training October 3 63
Fraud Risk Assessment
BTN remains vigilant to exposures arising from its involvement in business activities or To mitigate these risks, BTN implements a Fraud Risk Assessment (FRA) to identify and
operations in regions with higher incidences of corruption. Such risks include potential analyze potential fraud risks, whether arising from internal or external sources. The FRA
involvement in controversies related to corrupt practices, which may undermine the covers various business activities and functions, including funding, lending, human
Bank’s reputation, affect relationships with stakeholders, and result in legal sanctions that capital, operations, and IT, using a proactive and structured approach to strengthen
could adversely impact BTN’s operational stability. oversight and enhance employee awareness of fraud risks.
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BTN affirms that the Bank has no exposure to corruption scandals or involvement in applies to the Board of Directors, employees, and related parties, with provisions focused
political and social instability. The implementation of the FRA is carried out in accordance on human resources, procurement processes, and credit activities, to ensure the
with Technical Guidelines Number PT.8-D.2 as an early detection mechanism for fraud consistent implementation of controls in line with the principles of GCG.
risks. The results of the FRA are used to assess the impact of identified risks and to
formulate the necessary corrective and preventive measures to ensure that the Bank’s BTN has also established provisions to reinforce the integrity and independence of the
operations remain transparent and free from corrupt practices. Board of Directors in performing their duties in order to ensure the effective implementation
of policies. Each member of the Board of Directors is prohibited from obtaining or receiving
Conflict of Interest [GRI 2-15] personal benefits beyond the remuneration and lawful facilities approved by the GMS,
and from using the Bank for personal, family, or other interests that may be detrimental
BTN recognizes that interactions, both internal and with external parties, may give rise to to the Bank. The Board of Directors is also prohibited from giving, offering, or receiving
potential conflicts of interest that could affect the objectivity and integrity of decision- anything of value from customers or government officials to influence decisions or as
making. Accordingly, the Bank is committed to identifying, managing, and resolving any compensation for certain actions, in accordance with applicable laws and regulations.
conflicts of interest in a firm and transparent manner to prevent detrimental practices,
including corruption, collusion, and nepotism, and to maintain sound and sustainable If a member of the Board of Directors has an interest in a transaction or contract involving
relationships with all stakeholders. the Bank, the concerned individual is required to disclose such interest at a Board of
Directors’ meeting and refrain from voting on the related decision. In situations involving
Every BTN employee is required to avoid making decisions that involve conflicts of interest. a potential conflict of interest, particularly where the Bank’s economic interests are not
In circumstances where a decision must still be made, any such conflict is required to aligned with personal economic interests, members of the Board of Directors are required
be disclosed openly. Provisions governing transactions involving conflicts of interest are to:
stipulated in the Guidelines and Rules of Procedure of the Board of Directors and the 1. Prioritize the Bank’s interests and not reduce the Bank’s benefits in the event of a
Board of Commissioners. In the event of a conflict of interest between the Bank and its conflict of interest.
shareholders, the Board of Commissioners, the Board of Directors, executive officers, or 2. Refrain from participating in decision-making in situations where a conflict of interest
other related parties, the concerned parties are prohibited from participating in decision- exists.
making that may be detrimental to the Bank and are required to disclose the conflict to 3. Make full disclosure if a decision must still be taken under conditions involving a
ensure transparency and accountability. conflict of interest.
4. In the event of credit facilities granted to members of the Board of Directors, ensure
Conflict of Interest Prevention Policy that such facilities are provided on an arm’s length basis, in accordance with the
Bank’s prevailing regulations and without preferential treatment compared to other
Special Policy No. KK.6-H on Conflict of Interest Handling Procedures as the primary customers.
guideline for managing potential conflicts of interest throughout the Bank. This policy 5. Report any transactions involving the Bank’s shares within 3 (three) working days.
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To ensure governance independence and accountability, the Board of Commissioners is conflicts of interest related to concurrent positions, share ownership, relationships,
not involved in operational banking decision-making, except in specific matters expressly transactions, and outstanding balances with related parties, in accordance with
regulated in the Bank’s Articles of Association and prevailing laws and regulations, applicable laws and regulations. [GRI 2-15]
including the provision of funds to related parties. Any involvement or approval by the
Board of Commissioners does not diminish the responsibilities of the Board of Directors Alleged breaches involving conflicts of interest may be reported through the
in managing the Bank. Furthermore, the Board of Commissioners is prohibited from Whistleblowing System (WBS), which enables secure and anonymous reporting. To
making decisions that may give rise to conflicts of interest or that are contrary to legal minimize the risk of conflicts of interest, all Bank employees are required to sign an
provisions and ethical standards of office, and is therefore required to consistently apply Integrity Pact as a commitment to BTN’s Code of Ethics. Information on the disclosure
the following principles: of conflicts of interest, including multiple directorships, cross ownership, the presence of
1. Prioritizing the interests of the Bank and not reducing the Bank’s benefits in the event controlling shareholders, as well as relationships and transactions with affiliated parties,
of a conflict of interest. is comprehensively presented in BTN’s Annual Report. [GRI 2-15]
2. Disclosing ownership of shares held by the member and/or their family amounting to
5% (five percent) or more in the Bank or in other companies domiciled domestically In addition, credit disbursement also refers to Special Policy Number KK.1-A on Commercial
or overseas. Loan Procedures, which reinforces the principle that lending activities must be free from
3. Disclosing any family, financial, management, or ownership relationships with conflicts of interest. Under this policy, the Bank is prohibited from extending credit, whether
other members of the Board of Commissioners, members of the Board of Directors, in rupiah or foreign currencies, to the following businesses:
controlling shareholders of the Bank, and/or other parties in relation to the Bank’s • Nightclubs
business activities. • Horse racing
4. Disclosing any concurrent positions held. • Casinos
5. Making disclosure if a decision must still be taken under conditions involving a conflict • Turkish baths
of interest, and ensuring that the concerned member of the Board of Commissioners • Massage rooms
does not participate in the Bank’s decision-making process related to such matter. • Other businesses prohibited by the government and regulators
6. Not requesting, receiving, permitting, and/or approving the receipt of rewards,
commissions, additional payments, services, cash, valuables, and/or anything of BTN may also provide project financing to several categories of projects, including:
economic value or other benefits for personal, family, or other parties’ interests in the • Toll roads
conduct of the Bank’s business activities and other activities related to the Bank. • Power plants
• Airports
All disclosures of conflicts of interest are documented and recorded in meeting minutes in • Monorail projects
accordance with applicable regulations to ensure transparency and accountability. The • Telecommunications
Bank discloses such conflicts of interest to stakeholders through the prevailing disclosure
mechanisms as part of the implementation of good corporate governance, including
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Policy on Fair Treatment of Shareholders 3. Individuals who, due to their position, profession, or business relationship with the
Bank, may obtain inside information
BTN has established specific provisions on insider trading as part of its conflict of 4. Parties who, within the last six months, are no longer included in the categories
interest controls. These provisions are stipulated in Special Policy Number KK.9-EE on referred to in points 1, 2, and 3 above
Investor Relations Activities, the Board of Directors’ Rules of Procedure, and the Board of
Commissioners’ Rules of Procedure. Under these policies, Bank insiders are prohibited Restrictions on securities transactions for insiders are based on the principle of
from purchasing or selling BTN securities or the securities of other companies that have transparency in the capital market to ensure equal access to information in investment
transactions with BTN. decision making. Insiders are prohibited from trading BTN securities if they possess
Bank insiders are defined as: material information that has not been publicly disclosed (inside information or material
1. Commissioners, Directors, or employees of the Bank facts). Transactions may only be conducted after such information has been officially
2. The Bank’s principal shareholders announced to the public.
Implementation of the Principle of Prudence [GRI 2-23]
Know Your Customer (KYC) and Know Your Employee (KYE)
BTN strengthens the application of the principle of prudence through two main BTN conducts online training for employees based on CDD case studies to strengthen
approaches, namely Know Your Customer (KYC) and Know Your Employee (KYE), as part understanding and vigilance in every transactional activity.
of its operational risk management framework. The implementation of KYC has been
further developed into customer due diligence (CDD), which encompasses the processes Anti-Money Laundering (AML), Counter-Terrorism Financing (CTF), and
of identification, verification, and monitoring of customers and prospective customers to Proliferation Financing of Weapons of Mass Destruction (PFWMD)
ensure that transactions are consistent with their risk profiles, both for walk-in customers
(WIC) and registered customers. BTN’s Anti-Money Laundering (APU), Counter-Terrorism Financing (PPT), and Counter-
Proliferation Financing of Weapons of Mass Destruction (PPPSPM) programs within its
The implementation of CDD refers to POJK Number 23/POJK.01/2019 concerning the customer due diligence (CDD) process are in accordance with applicable banking laws
Amendment to POJK Number 12/POJK.01/2017 on the implementation of AML and CTF and regulations. To ensure these AML/CFT/CPF programs are implemented effectively and
programs in the financial services sector. To enhance implementation effectiveness, in full compliance with regulatory requirements, the Bank has established a dedicated
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working unit (UKK) for APU, PPT, and PPPSPM, which is responsible for overseeing the 1. Submission of Financial Transaction Reports to the Financial Transaction Reports and
implementation of these programs at BTN. Analysis
a. Suspicious Financial Transaction Reports (LTKM);
At the operational level, Regional Office Heads and Branch Management, acting as Senior b. Cash Financial Transaction Reports (LTKT);
Officers, are responsible for ensuring that all activities related to the implementation of c. Cross-Border Fund Transfer Financial Transaction Reports (LTKL); and
the APU, PPT, and PPPSPM programs within the units under their supervision are carried d. Integrated Service User Information System (SIPESAT).
out effectively, through oversight, monitoring, and coordination functions in accordance 2. Submission of Data/Information Compliance to Law Enforcement Agencies and
with applicable regulations. Regulators, as follows:
a. AML–CTF Program Information System (SIGAP) to the Financial Services Authority
Anti-Money Laundering and Counter-Terrorism Financing Policy (AML and (OJK);
CTF) b. AML–CTF reports through the OJK APOLO Application;
c. Terrorism Financing Suspect Information System (SIPENDAR) to PPATK;
BTN has established comprehensive policies and strategies for the implementation of Anti- d. Electronic Data Exchange (PEDAL) to the Corruption Eradication Commission
Money Laundering (AML), Counter-Terrorism Financing (CTF), and Proliferation Financing (KPK); and
of Weapons of Mass Destruction (PFWMD) programs. These policies are approved by the e. Fulfilment of data requests from Supervisory and Regulatory Institutions (LPP)
Board of Directors and aligned with applicable laws and regulations, as well as relevant and other law enforcement agencies, including the Police, the National Narcotics
national and international standards. They are designed to mitigate risks and ensure that Agency, and the Public Prosecutor’s Office.
the Bank’s transactions and business activities are not used as instruments for money 3. Submit monitoring reports on transactions related to the Free Nutritious Meal Program
laundering, terrorism financing, or the financing of the proliferation of weapons of mass (MBG) to PPATK.
destruction.
Strategic Awareness Initiative Program
BTN is committed to maintaining clean, transparent, and accountable banking practices
by involving all employees and business partners in education and training programs 1. Thematic refreshment on AML, CTF, and PFWMD.
to ensure effective understanding and implementation of AML, CTF, and PFWMD policies, 2. AML, CTF, and PFWMD training is provided to employees in accordance with their
thereby supporting a secure financial system that is not misused for unlawful purposes. roles and responsibilities. The training is conducted on an ongoing and periodic basis
Furthermore, to support the implementation of these policies, the Bank submits reports through internal programs and/or in collaboration with external parties.
and/or data to regulators and/or law enforcement authorities in accordance with 3. Branch Visit and Surprise Visit.
applicable regulations, including but not limited to:
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4. Internalization program for the implementation of AML, CTF, and PFWMD through Enhanced Due Diligence and High-Risk Jurisdictions
site visits to Branch Offices to enhance employees’ understanding of AML, CTF, and
PFWMD programs, as well as Surprise Visits to Sub-Branch Offices to assess employee BTN’s enhanced due diligence (EDD) and proportionate countermeasures manage risks
awareness and evaluate the effectiveness of program implementation. arising from business relationships and transactions involving prospective customers,
5. AML, CTF, and PFWMD Coaching Clinic. existing customers, walk-in customers (WIC), and related parties originating from high-
6. Discussion and coordination forums between Regional AML officers and Branch risk jurisdictions as published by the Financial Action Task Force (FATF). Monitoring of
Offices to address issues and identify solutions related to challenges in implementing High-Risk Jurisdictions is conducted through the AML, CTF, and PFWMD system, which is
AML, CTF, and PFWMD programs. accessible to all relevant personnel, including frontliner staff such as customer service
officers. The Bank has also ensured that throughout the reporting year, there were no
violations related to money laundering, terrorism financing, or the financing of the
proliferation of weapons of mass destruction.
Internal Control and Anti-Gratification
Internal Control
The internal control system support the achievement of the Bank’s optimal performance To strengthen the effectiveness of these controls, BTN’s management implements
while creating added value for stakeholders. This mechanism is designed to minimize continuous monitoring mechanisms (on an ongoing basis) to safeguard the Bank’s
potential losses, ensure compliance with regulations, and maintain the Bank’s assets, ensure the reliability of reporting, and enhance regulatory compliance. The system
operations in a sound, efficient, and well-controlled manner. In developing its internal is also directed toward improving cost efficiency, reducing potential financial losses, and
control framework, BTN refers to the Committee of the Sponsoring Organizations of the preventing irregularities, including fraud, integrity risks, and potential conflicts of interest.
Treadway Commission (COSO) – Internal Control–Integrated Framework to ensure the Internal supervision serves as a primary instrument in ensuring compliance with ethical
effectiveness of controls over operational activities, financial reporting, and compliance standards and responsible business conduct. In this context, internal control forms the
with applicable regulations. foundation for the implementation of gratification controls as part of the Bank’s efforts to
reinforce a culture of integrity and strong corporate governance.
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Gratification Control
In managing compliance risk and strengthening integrity, BTN has structured gratification goods and/or services within the Procurement and Fixed Asset Management Division
controls through Special Policy KK.6-A – Gratification Control Procedures, which serves (PFAD); commercial lending activities within the Commercial Banking Division (CMBD
as a guideline for all employees across work units to report any acceptance or refusal – Head Office), Corporate Banking Division (CBD), Wholesale Credit Risk Division (WRD),
of gratuities to the Compliance & Governance Work Unit through the Gratification and Commercial Banking Centers (Jakarta Raya, Bekasi, Bandung, and Bintaro Jaya);
Control Unit (UPG), as part of efforts to foster a culture of integrity and strong corporate SME Restructuring across Regional Offices (West Java, Jakarta II, East Java Bali Nusra,
governance. Sumatra, Sulawesi Maluku Papua, and Central Java DIY); as well as the Business Banking
Division (BBD), Credit Operation Division (COD), with extended scope including the
Gratification control is carried out through mechanisms for identification, reporting, Commercial Asset Management Division (CAMD), and Jakarta Harmoni Branch Office. The
analysis, and follow-up of any indications of gratuities, including assessments based scope is determined based on corruption risk within the Bank’s core business activities.
on value, the context of the provision, and potential conflicts of interest. This process This approach ensures that the Bank’s operations remain aligned with principles of
is integrated with WBS as an alternative reporting channel for alleged breaches. To transparency, integrity, and compliance with applicable regulations. [GRI 205-1]
reinforce anti-fraud values, BTN consistently conducts internalization of the anti-fraud
strategy and WBS through socialization activities facilitated by independent third parties,
to ensure objective and transparent implementation. Number of Gratification- 2025 2024 2023
Related Reports Received
90 79* 78
Throughout the reporting year, BTN received 90 gratification reports originating from
the Head Office and Branch Offices, covering bribery, official gratuities, gifts provided
ahead of religious holidays, as well as refusals of gratuities. As part of its efforts to *Restated
prevent gratification and corruption, the Bank continued to strengthen operational risk
oversight. In order to maintain its ISO 37001 – Anti-Bribery Management System (ABMS)
certification, in 2025 BTN conducted a Surveillance Audit covering the procurement of
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Whistleblowing System
BTN’s anti-fraud strategy is part of its risk control framework to prevent and address implementation of know your employee policies. As part of strengthening the compliance
potential fraud in a structured manner, carried out through the following four main pillars: culture, the Bank consistently conducts internal training on the internalization of WBS
for employees to ensure effective understanding and application of the whistleblowing
Prevention reporting mechanisms. The number and percentage of employees who participated in
the training, including their distribution by Work Region, are presented below. [GRI 205-2]
The prevention pillar encompasses various measures aimed at reducing the risk of fraud
through enhanced anti-fraud awareness, identification of potential vulnerabilities, and the
Implementation of Employee Training on the Internalization of BTN’s WBS [GRI 404-2]
Passed Did Not Pass Did Not Access
Total
Work Region Number of Number of Number of
Participants % % %
Employees Employees Employees
Head Office 3,742 3,728 99.63% 10 0.27% 4 0.11%
Jakarta I Regional Office 1,172 1,144 97.61% 22 1.88% 6 0.51%
Jakarta II Regional Office 1,003 968 96.51% 27 2.69% 8 0.80%
West Java Regional Office 1,169 1,135 97.09% 31 2.65% 3 0.26%
Central Java & Yogyakarta Special Region Regional Office 768 726 94.53% 33 4.30% 9 1.17%
East Java, Bali & Nusa Tenggara Regional Office 1,207 1,184 98.09% 19 1.57% 4 0.33%
Kalimantan Regional Office 511 482 94.32% 26 5.09% 3 0.59%
Sulawesi, Maluku & Papua Regional Office 726 697 96.01% 27 3.72% 2 0.28%
Sumatra Regional Office 1,116 1,094 98.03% 20 1.79% 2 0.18%
Total 11,414 11,158 97.76% 215 1.88% 41 0.36%
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Detection
The detection pillar of BTN’s Anti-Fraud strategy is directed toward the early identification 3. Protection against retaliation by the reported party, which may include:
of potential fraud through various integrated mechanisms, including the implementation a. Physical and/or psychological protection, for the whistleblower and/or their
of the Whistleblowing System (WBS) policy, the conduct of surprise audits, the use of family members;
surveillance systems, and direct supervision by the Operational Responsible Officer (PJO). b. Protection of personal and family assets from threats or acts of retaliation;
The implementation of WBS refers to Regulation of the Financial Services Authority (POJK) c. Administrative protection, including protection against threats of delayed
Number 39/POJK.03/2019 on the Implementation of Anti-Fraud Strategies for Commercial promotion, dismissal, improper transfers, assurance of employment, and other
Banks, and serves as a means of prevention and early detection of irregularities that may adverse actions; and
affect the Bank’s reputation, compliance, and business sustainability, while also fostering d. Legal protection, including protection through litigation processes in accordance
an open, transparent, and safe work culture for employees in reporting breaches. [SASB with applicable regulations.
FN-CB-510a.2]
A total of 276 complaints were received in 2025, consisting of 99 complaints submitted
BTN has developed supporting facilities for the implementation of its Whistleblowing through SMS/telephone/WhatsApp and 177 complaints submitted via email/website/
System (WBS) policy. Any complaint report may be submitted through the following P.O. Box. Based on the complaints received, 227 were unsubstantiated, 43 remain under
channels: information gathering or follow-up review, and the remaining 6 complaints have been
Mail : PO Box 2828 JKP 10028 resolved and/or resulted in sanctions.
Website : idn.deloitte-halo.com/btnsiips
Email : btnsiips@tipoffs.info Investigation, Reporting, and Sanctions
SMS : +62 813 8870 1117
WhatsApp : +62 813 8870 1117 Under the investigation, reporting, and sanctions pillar, the Bank manages structured
Telephone : +62 21-50928882 / +62 21-5092888 systems and mechanisms to obtain information, collect and assess evidence, manage
reporting, and recommend and impose sanctions for fraud incidents. Every report
BTN is committed to providing protection guarantees for whistleblowers who report received, including those submitted through WBS, is followed up in accordance with
breaches in good faith, particularly where such breaches have the potential to cause established procedures through verification and investigation processes to ensure
losses to the Bank. These guarantees are implemented through the following policies: the validity and completeness of the information. The BTN WBS Team responsible for
1. Provision of independent and confidential WBS reporting channels. Whistleblowers managing WBS reports consists of:
receive information on the status of their WBS reports from the Independent WBS 1. Head of the Internal Audit Division;
Administrator through the designated communication channels. 2. Deputy Head of the Internal Audit Division; and
2. Guarantee of confidentiality of the whistleblower’s identity, and anonymous 3. WBS Unit within the Fraud Investigation & Whistleblowing System (WBS) Department
reporting is permitted, except where legal requirements mandate disclosure of the of the Internal Audit Division.
whistleblower’s identity before a court of law.
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In its implementation, every report received through the WBS is followed up in accordance controls, enhance early detection and prevention of misconduct, and gradually foster
with established procedures through verification and investigation processes to ensure an open, honest, sincere, and accountable work culture at BTN. Details of the number of
its validity. Based on the results of the handling process, the Bank imposes proportionate complaints and their follow-up actions are presented below.
sanctions on parties proven to have committed breaches in order to strengthen internal
Number of Whistleblowing System (WBS) Reports Followed Up Through the Audit Process
Submission Method Follow-Up Action
Report Still in Process Report Completed
Year Report Referred to
SMS / Telephone / Report Closed (Audit Process / and/or Sanctioned
Letter / P.O. Box Email / Website Investigators (criminal
WhatsApp (Unsubstantiated) Reporting Process / (incl. administrative
or corruption cases)
Cross-Division Process) sanctions)
2025 0 0 1 0 0 1 0
2024 0 0 3 0 1 2 0
2023 0 1 4 0 0 5 0
Monitoring, Evaluation, and Follow-up
Through this pillar, BTN carries out continuous monitoring and evaluation to identify Untuk memastikan WBS dikelola secara efektif dan akuntabel, BTN memperkuat sistem To
potential fraud and ensure the availability of adequate follow-up mechanisms. ensure that WBS is managed effectively and accountably, BTN strengthened its complaint-
Throughout the reporting year, BTN recorded 38 internal fraud cases, of which 38 cases handling system through cooperation with the Corruption Eradication Commission. This
were resolved, while the remaining cases are still in the process of being handled. All collaboration aims to enhance the quality of handling reports submitted by employees
identified cases are followed up through the applicable handling mechanisms, including and external parties through an integrated, professional, and transparent approach, while
legal proceedings where necessary, as part of the Bank’s commitment to upholding upholding the principles of confidentiality and whistleblower protection. Every complaint
integrity, compliance, and discipline across all operational activities. [SASB FN-CB-510a.1] received through WBS is followed up in accordance with established procedures through
verification and investigation stages to ensure the validity of the report.
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The WBS Team follows up on every report received through the following mechanism: Commissioner(s) and Committee Member(s) under the Board of Commissioners
1. If the reported party is a BTN employee up to 2 (two) levels below the Board of Directors who are not related to the complaint, as well as to the WBS Administrator of the
and is not a member of the BTN WBS Team, the Independent WBS Administrator Ministry of SOEs (specifically for reported Commissioners).
submits the report to the BTN WBS Team. 6. If the reported parties are Commissioners acting collectively, the Independent WBS
2. If the reported party is a BTN employee 1 (one) level below the Board of Directors and Administrator submits the report to the WBS Administrator of the Ministry of SOEs.
is not a member of the WBS Team, the Independent WBS Administrator submits the 7. If the reported party is a member of the Board of Directors and/or the Board of
report to the President Director. Commissioners of a Subsidiary, the Independent WBS Administrator submits the
3. If the reported party is a member of the BTN WBS Team, the Independent WBS report to the President Director of the Bank.
Administrator submits the report to the President Director.
4. If the reported party is a member of the Board of Directors, the Independent WBS Below is a summary of internal fraud cases handled by the Fraud Risk Management
Administrator submits the report to the Board of Commissioners and the WBS Department through Whistleblowing System (WBS) reports, internal audit findings, and
Administrator of the Ministry of SOEs. internal investigations.
5. If the reported party is a Commissioner and/or a Committee under the Board of
Commissioners, the Independent WBS Administrator submits the report to the
Table of Internal Fraud in 2025 [GRI 205-3]
Number of Internal Fraud Cases Committed
Members of the Board of Commissioners and
Permanent Employees Non-Permanent Employees
Internal Fraud Throughout 2025 Members of the Board of Directors
Previous Year*
Previous Year (2024) Current Year (2025) Current Year (2025) Previous Year (2024) Current Year (2025)
(2024)
Total Reports 0 0 24 38 1 1
Resolved 0 0 24 38 1 1
In Process of Internal Resolution within the Bank 0 0 0 0 0 0
Not Yet Subject to Resolution Efforts 0 0 0 0 0 0
Followed Up through Legal Proceedings 0 0 0 0 0 0
Notes::
1. The number of cases in the current year is based on the Special Audit Result Reports and Preliminary Review Result Reports for the period from January to December 2025;
2. The number of cases categorized as “Resolved” refers to cases that had received a sanction decision from the Board of Directors as of December 2025;
3. The number of cases categorized as “In the process of internal resolution within the Bank” refers to cases that had not yet received a sanction decision from the Board of Directors as of December 2025; and
4. The number of cases categorized as “Followed up through legal proceedings” refers to cases that had been resolved and had received criminal sanction decisions. The legal proceedings were followed up by LGD.
*Restated
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As part of its governance mechanism, the outcomes of complaint handling that are Based on the results of complaint handling and directions from the relevant governance
classified as significant matters are reported to the Board of Directors and/or the Board of authorities, the Bank determined appropriate follow-up actions and proportionate
Commissioners through the applicable forums and reporting channels. During the 2025 sanctions for parties proven to have committed breaches. This approach aimed to ensure
reporting period, BTN submitted four reports to the Board of Directors and/or the Board of consistent enforcement of discipline, prevent the recurrence of similar breaches, and
Commissioners through the Anti-Fraud Sub-Committee, containing a summary of fraud strengthen internal controls. The implementation of sanctions was carried out through a
cases arising from breaches of internal policies, fraudulent activities, and significant structured and integrated process flow in accordance with the respective authorities of
administrative violations. All material issues presented in these reports were followed each function, including both internal mechanisms and legal proceedings, to ensure that
up in accordance with the relevant authority and served as a basis for management all stages were conducted objectively, accountably, and in compliance with applicable
decision-making as well as for strengthening the Bank’s internal control framework. [GRI regulations.
2-16]
Sanction Process Flowchart – Legal Proceedings Flowchart of the Disciplinary Process at BTN
Anti-Fraud Committee Human Capital Legal Division Employee
Start IAD Board of HCMD Done
Management & Culture Disciplinary &
Directors
Specialist Division Sanctions
Committee
Issues at Preliminary
Branch Offices, Done
Review
Regional
Offices, and
Divisions
1b 1a There Is
a Violation
Initiation of Sanction
Receives a Copy of the
Enforcement through No Further
Sanction Decision Severity Review Required
Legal Proceedings Level of Decision of the Decision of the Implementation
of the Decision
the Issue Board of Directors Board of Directors
N
Requires
Y Further Review Implementation
N of the Decision
2 3 Exceeding
Special Audit Authority
Preparing the
Coordination with
Legal Team and
the Legal Division for Y
Legal Actions, and
Preparation of Legal
Overseeing the Legal Within Authority
Proceedings
Process
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About the Report Reporting Period and Scope [GRI 2-2, 2-3, 2-4]
This report presents a comprehensive overview of BTN’s sustainable finance The 2025 Sustainability Report presents the Bank’s operational performance for the
direction and implementation, carried out through strengthening the business period from 1 January to 31 December 2025, covering the Head Office, Regional Offices,
portfolio as well as developing innovative financial products and services. In and Branch Offices in Indonesia, and is aligned with the audited Consolidated Financial
addition, the report outlines BTN’s strategic contributions in supporting the Statements as of 31 December 2025. This report is the 17th edition, continuing the previous
Sustainable Development Goals (SDGs), as reflected in achievements and edition published in March 2025. The preparation of this report refers to GRI Standard
initiatives across environmental, social, and governance (ESG) aspects. 2021, OJK Regulation No. 51/POJK.03/2017 concerning the Implementation of Sustainable
Finance for Financial Services Institutions, Issuers, and Public Companies, as well as in
accordance with the Technical Guidelines for the Preparation of Sustainability Reports
for Issuers and Public Companies as set out in OJK Circular Letter No. 16/SEOJK.24/2021.
BTN ensures that all data and information are presented accurately. If there are
changes compared to the previous period, including those resulting from adjustments in
measurement methods, the notation “* restated” is used to explain such adjustments. As
of the date of this report, BTN does not have any Subsidiaries and/or Associated Entities,
including joint ventures; therefore, there is no disclosure regarding the list of entities and
ownership information.
IFRS S1 and S2 Implementation Plan
The IFRS S1 and S2 implementation plan reflects BTN’s commitment to strengthening
the quality of its sustainability reporting in line with global standards. In 2026, BTN is
conducting a gap analysis and developing an implementation roadmap, targeting initial
adoption by year-end, followed by full implementation and further enhancements in the
subsequent year.
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Reporting Standards [GRI 2-3]
BTN refers to a number of national and international standards in preparing this Sustainability Report, including:
• Financial Services Authority (OJK) Regulation No. Standar Global Sustainability Accounting
51/POJK.03/2017 concerning the Implementation Reporting Initiative (GRI) Standard Board (SASB)
of Sustainable Finance for Financial Services
Institutions, Issuers, and Public Companies. Partnership for
• OJK Circular Letter No. 16/SEOJK.04/2021 concerning International Financial Reporting Standards (IFRS) S1 Carbon Accounting
the Form and Content of Annual Reports of Issuers and S2, which have been adopted in Indonesia as the Financials (PCAF)
or Public Companies. Sustainability Disclosure Standards (PSPK) 1 and 2.
External Assurance [GRI 2-5, 2-14] [OJK G.1] Feedback and Report Contact [GRI 2-3] [OJK G.2, G.3]
BTN appointed an independent third party to perform external assurance on the 2025 BTN provides a Feedback Form at the end of the report to facilitate two way communication
Sustainability Report to enhance the reliability of disclosures and ensure the absence with stakeholders. Feedback, suggestions, and opinions are handled by the Corporate
of conflicts of interest. The assurance was conducted by CBC Global Indonesia, which Secretary or the Information and Documentation Management Officer and are used as
is certified under AA1000AS v3 (license number 000-310) and was not involved in the input to improve the quality of future reporting. As of 2025, BTN had not received any
preparation of the report. The assurance statement is available on page 267. In addition feedback on the Sustainability Report for the previous reporting period. This report is
to external assurance, the Board of Commissioners and the Board of Directors ensured intended for all stakeholders, who may access information related to the Sustainability
that all material topics were comprehensively covered and subsequently approved and Report by contacting:
signed the report on pages 24 and 25.
PT Bank Tabungan Negara (Persero) Tbk Menara 2 BTN
Corporate Secretary Division Jalan H.R. Rasuna Said No. 1
South Jakarta, 12980
Email : csd@btn.co.id
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INDEPENDENT ASSURANCE STATEMENT
PT. Bank Tabungan Negara Tbk.
Sustainability Report 2025
Statement No: 01/IAS/CBC/III/2026
Type 2, Moderate Level
Scope of Engagement in Assurance
CBC Global Indonesia (“CBC Global Indonesia”, “us” or “we”) were commissioned by PT. Bank Tabungan Negara Tbk. (“Bank BTN”) with the
objective to provide assurance of Bank BTN’s 2025 Sustainability Report (the “Report”) in relation with accordance to GRI Standards, POJK
No.51/POJK.03/2017, SEOJK No.16/SEOJK.04/2021, SASB, IFRS, and the adherence to AA1000 Accountability Principles (2018) with
assurance over the Subject Matter presented in the Report, for the period from 1st January 2025 to 31st December 2025. This statement is
intended to be used by stakeholders & management of Bank BTN.
The scope and limitation of our work is restricted to the following areas:
1. Subject Matters
- Climate Change and Ecosystems (Including GHG Emission)
- Natural Resource Use & Environmental Management
- Employment (Education and HSE)
- Human Rights (Diversity, Equity, dan Inclusion)
- Community Development
- Information Security
- Governance
- Sustainable Products and Services
- Business Ethics and Code of Conduct
- Sustainable Procurement
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2. AA1000 Principles (2018)
Our assurance engagement was planned and performed to meet the requirements of a Type 2 “moderate level” of assurance as defined
by AA1000 Assurance Standard (AA1000AS) v3 to evaluate the nature and extent of Bank BTN’s adherence to the four AA1000
AccountAbility Principles (2018): Inclusivity, Materiality, Responsiveness and Impact. Sufficient appropriate evidence has been obtained
to support our conclusion. This reduces the risk of error, but does not reduce it to a very low level or to zero.
We have not performed any work, nor do we express any conclusion, on information other than the Subject Matter included within the scope
of our assurance engagement that may be presented in the Report. We have assumed that the financial data and figures provided by Bank
BTN have been audited by independent parties. Accordingly, the presentation of financial data and figures in the Report is not within the scope
of this assurance engagement. The verification of greenhouse gas emissions was conducted based on the methodology applied by Bank
BTN. Our assurance procedures included reviewing the underlying activity data and performing sample-based recalculations. No additional
external verification standard was applied in relation to the emissions data.
Responsibilities of Management of Bank BTN
The Management of Bank BTN is responsible for the preparation and fair presentation of the Subject Matter in accordance with the Reporting
Criteria. This responsibility includes designing, implementing, and maintaining appropriate internal controls to ensure that the Subject Matter
information is free from material misstatement, whether arising from fraud or error. Management is also responsible for ensuring that the data
and information subject to assurance are not edited, amended, or otherwise altered following the completion of the assurance engagement.
Responsibilities, Competencies and Independency of CBC Global Indonesia
Our responsibility is to conduct the assurance engagement in accordance with the agreed scope and criteria, and to express an independent
conclusion based on the procedures performed. We plan and perform our work to obtain a moderate level of assurance that the Subject Matter
information is free from material misstatement.
The engagement was carried out by a team of qualified sustainability assurance professionals with appropriate knowledge, skills, and
experience in sustainability reporting, non-financial data verification, and assurance methodologies. At least one member of the team holds
the Certified Sustainability Assurance Practitioner (CSAP) credential issued by AccountAbility.
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CBC Global Indonesia is bounded by rules of conduct and professional practice relating to independence and quality overseen by
AccountAbility (www. accountability.org/standards/licensing/ AA1000 as licensed-providers) and has established policies and procedures that
are designed to ensure that our team maintain independence and integrity. We had no financial interest in the operation of Bank BTN other
than for the assessment and assurance of this report. We don’t accept or assume responsibility (legal or otherwise) or accept liability for or in
connection with any other purpose for which it may be used, or to any person by whom the independent assurance opinion statement may be
read.
Methodology
We conduct the following assurance procedures and activities:
• Pre-engagement to ensure the independence and impartiality of the assurance team.
• Kick-off meeting and initial analysis of the report draft.
• Review, assess and evidence the reliability and quality of sustainability performance and disclosed information as specified in the Report
content for the reporting period of 1st of January up to 31st of December 2025.
• Evaluate the adherence of report content, disclosure and presentation against the agreed criteria.
• Conduct in-depth interview with the representatives of the relevant functions/divisions of the Bank BTN.
• Obtained an understanding of how material topics are identified, how responses to these topics are managed, and how material impacts
are monitored and measured, including stakeholder engagement. It also includes understanding how information and data are collected,
compiled, and aggregated internally.
• Performed limited substantive testing, on a sample basis, of the sustainability information identified, to verify the assumptions, estimations
and computations Bank BTN made and to check that data had been appropriately measured, recorded, collated and reported.
• Compare the subject matter presented in the report to corresponding information in the relevant underlying sources on a sample basis.
• Discuss and analysis data and reports with management of Bank BTN and data contributor to determine whether there are any material
misstatement of fact or material inconsistencies based on our understanding obtained as part of our assurance engagement.
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Finding and Conclusions
Based on the assurance procedures performed and the evidence obtained, a detailed review against the agreed criteria is presented below:
INCLUSIVITY
Bank BTN has identified its significant stakeholders based on factors such as influence, dependence, needs, diversity, and willingness to
engage. Each stakeholder group has been involved through appropriate engagement mechanisms, allowing the Bank to understand their key
interests and concerns. For instance, customer privacy and product portfolio are priorities for customers, while anti-corruption measures and
decarbonization strategies are considered material by investors, as they ensure Bank BTN remains aligned with global sustainability issues.
Based on our review, we conclude that Bank BTN has applied the principle of inclusivity in its sustainability reporting processes.
MATERIALITY
In determining material topics, Bank BTN applies a double materiality approach. Both internal and external stakeholders are engaged to assess
the significance of the Bank’s impacts on the environment and people, as well as how social and environmental aspects may pose risks to
Bank BTN’s sustainability. The assessment results are then mapped according to their level of significance. Based on our review, we conclude
that Bank BTN has applied the principle of materiality in its sustainability reporting processes.
RESPONSIVENESS
Bank BTN has developed an ESG framework titled The Future of Finance, covering all material topics and serving as a strategic guide across
the organization. The Bank has also established an ESG Committee and an Enterprise and ESG Risk Management Division (ERMD) as the
two main pillars for sustainability management, with the ESG Committee chaired by the President Director. This approach ensures that Bank
BTN provides appropriate decisions, actions, and performance management for each material topic. Based on our review, we conclude that
Bank BTN has applied the principle of responsiveness in its sustainability reporting processes.
IMPACT
The Report presents Bank BTN’s performance data for each material topic, demonstrating that the Bank monitors, measures, and is
accountable for its impacts. The Bayar Angsuranmu Pakai Sampahmu program is an initiative that generates positive outcomes not only for
local communities but also for the environment. In addition, the Bank’s low-emission housing development initiatives, while maintaining
affordability for low- and middle-income households, effectively address both local economic issues and global climate-related challenges.
Based on our review, we conclude that Bank BTN has applied the principle of impact in its sustainability reporting processes.
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GRI STANDARDS
The disclosures in the Report are in accordance with the GRI Standards, consistent with Bank BTN’s claim regarding the preparation of the
Report. The disclosures of management approach for each material topic in general is fairly disclosed. The Management of Bank BTN has
applied the principles for defining the report’s quality (balance, comparability, accuracy, timeliness, clarity, and reliability) and the principles for
defining the report’s content (stakeholder inclusiveness, sustainability context, materiality, and completeness) and supporting documents were
adequately presented during the assurance.
Adherence to POJK No.51/POJK.03/2017, SEOJK No.16/SEOJK.04/2021, SASB, and IFRS
Based on the procedures performed and the evidence obtained, we conclude that the disclosures in Bank BTN’s Sustainability Report are in
alignment with the reporting requirements outlined in POJK No. 51/2017 and SEOJK No.16/2021. In addition, the disclosure of sustainability-
related financial information in the Report is consistent with the recognition and measurement requirements of IFRS, as well as the applicable
SASB Standards. In particular, with regard to climate-related transition and physical risks, Bank BTN has disclosed its strategies to address
these risks, including how it provides credit to customers in high-risk industries. The Report provides a fair representation of the Bank’s
sustainability performance in accordance with the above criteria.
Opinion Statement
Our professional and certified team of sustainability report assurer has assured this report in accordance with AA1000AS v3. We believe that
the evidence we have obtained is sufficient and appropriate to provide a basis for our conclusion, nothing has come to our attention that causes
us to believe that the subject matter in the Report for the period from 1 January 2025 to 31 December 2025 are materially misstated. The
Report provides a fair representation in accordance with the agreed criteria.
Conclusion & Recommendations
• Strengthening Stakeholder-Driven Materiality
Bank BTN is encouraged to more systematically integrate stakeholder engagement outcomes into the identification of material impacts and
risks, including insights from customer satisfaction surveys, employee engagement surveys, and community programs. This would ensure
that material topic selection is not driven primarily by peer practices, reporting standards, or rating agency expectations.
A more impact-focused approach would allow stakeholders to surface the issues most relevant to them and support the determination of
material topics based on a clear and consistent criterion: the significance of impacts and/or the associated financial and non-financial risks.
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• Enhancing Oversight of Waste Management
Bank BTN could consider obtaining more detailed reports from its contractors on the final treatment of non-hazardous (non-B3) waste from
the BTN Tower after it has been managed by third parties, including information on the quantities and types of waste that are recycled,
recovered, or disposed of to landfill. Strengthening monitoring at this post-transfer stage would enhance traceability of non-B3 waste
streams, improve data accuracy and transparency, and reinforce the Bank’s accountability for its environmental impacts in line with its
sustainability commitments.
For and on behalf of:
Jakarta, March 9th, 2026
Dr. Erna Lovita, SE., MSi., Ak., CA., CSRS., CSRA
Engagement Leader
Certified Sustainability Reporting Specialist No. S-UB3-1407-305
Certified Sustainability Reporting Assurer No. A-UB1-1506-146
PT CBC Global Indonesia
The Icon Horizon Broadway Blok M.5 No.3 BSD City, Tangerang, Indonesia 15345
Tel: (62)(21) 87780058
Email: services@cbcglobalindonesia.com
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Report Standard Index
GRI Content Index
Statement of Use PT Bank Tabungan Negara (Persero) Tbk has reported in accordance with the GRI Standards for the period 1 January until
31 December 2025.
GRI 1 Used GRI 1: Foundation 2021
Applicable GRI Sector Standard GRI G4 Financial Services
Omission
No. Ref. Standar
GRI Standard Disclosure Page Requirement
Reason Explanation Sektor GR
Omitted
General disclosures
GRI 2: General 2-1 Organizational details 28, 36
disclosures 2021
2-2 Entities included in the organization’s sustainability reporting 265
2-3 Reporting period, frequency and contact point 265-266, 290
2-4 Restatement of information 265
2-5 External assurance 266-272
2-6 Activities, value chain, and other business relationship 29, 34-37, 39
2-7 Employees 91-95
2-8 Workers who are not employees 91, 95
2-9 Governance structure and composition 89-90, 192,
196
2-10 Nomination and selection of the highest governance body 192, 208-209
2-11 Chair of the highest governance body 192-195
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Omission
No. Ref. Standar
GRI Standard Disclosure Page Requirement
Reason Explanation Sektor GR
Omitted
2-12 Role of the highest governance body in overseeing the 47, 192-193,
management of impacts 196
2-13 Delegation of responsibility for managing impacts 47, 192, 196
2-14 Role of the highest governance body in sustainability reporting 24-25, 266
2-15 Conflict of interest 252-255
2-16 Communication of critical concerns 221, 249, 264
2-17 Collective knowledge of the highest governance body 103-105
2-18 Evaluation of the performance of the highest governance body 212-213
2-19 Remuneration policies 208-210
2-20 Process to determine remuneration 209-210
2-21 Annual total compensation ratio 210-211
2-22 Statement on sustainable development strategy 21-23
2-23 Policy commitments 21-22, 30-31,
89, 198, 213,
248, 250, 256
2-24 Embedding policy commitments 21-23, 248-
249
2-25 Processes to remediate negative impacts 145-147
2-26 Mechanisms for seeking advice and raising concerns 261-262
2-27 Compliance with laws and regulations 84, 120
2-28 Membership associations 39
2-29 Approach to stakeholder engagement 48-51
2-30 Collective bargaining agreements 119
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Omission
No. Ref. Standar
GRI Standard Disclosure Page Requirement
Reason Explanation Sektor GR
Omitted
Material Topics
GRI 3: Material topics 3-1 Process to determine material topics 52-54
2021
3-2 List of material topics 52-54, 225-
237
Economic Performance
GRI 3: Material Topics 3-3 Management of material topics 41
2021
GRI 201: Economic 201-1 Direct economic value generated and distributed 40-42
Performance 2016
201-2 Financial implications and other risks and opportunities due to 41, 225-237
climate change
201-3 Defined benefit plan obligations and other retirement plans 115
201-4 Financial assistance received from government 41
Market Presence
GRI 3: Material Topics 3-3 Management of material topics 98, 111
2021
GRI 202: Market 202-1 Ratios of standard entry level wage by gender compared to 111
Presence 2016 local minimum wage
202-2 Proportion of senior management hired from the local 98
community
Indirect Economic Impacts
GRI 3: Material Topics 3-3 Management of material topics 122
2021
GRI 203: Indirect 203-1 Infrastructure investments and services supported 122-128
Economic Impacts 2016
203-2 Significant indirect economic impacts 122-128
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Omission
No. Ref. Standar
GRI Standard Disclosure Page Requirement
Reason Explanation Sektor GR
Omitted
Procurement Practices
GRI 3: Material Topics 3-3 Management of material topics 37
2021
Gri 204: Procurement 204-1 Proportion of spending on local suppliers 37
Practices 2016
Anti-corruption
GRI 3: Material Topics 3-3 Management of material topics 252-253
2021
GRI 205: Anti-corruption 205-1 Operations assessed for risks related to corruption 259
2016
205-2 Communication and training about anti-corruption policies and 253, 260
procedures
205-3 Confirmed incidents of corruption and actions taken 263
Materials
GRI 3: Material Topics 3-3 Management of material topics 82-83
2021
GRI 301: Materials 2016 301-1 Materials used by weight or volume 83
301-2 Recycled input materials used 83
301-3 Reclaimed products and their packaging materials 83
Energy
GRI 3: Material Topics 3-3 Management of material topics 71
2021
GRI 302: Energy 2016 302-1 Energy consumption within the organization 71
302-2 Energy consumption outside of the organization 71
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Omission
No. Ref. Standar
GRI Standard Disclosure Page Requirement
Reason Explanation Sektor GR
Omitted
302-3 Energy intensity 71
302-4 Reduction of energy consumption 72
302-5 Reductions in energy requirements of products and services 72
Water and Effluents
GRI 3: Material Topics 3-3 Management of material topics 79
2021
GRI 303: Water and 303-1 Interactions with water as a shared resource 79
Effluents 2018
303-2 Management of water discharge-related impacts 80
303-3 Water withdrawal 79
303-4 Water discharge 80
303-5 Water consumption 79
Emissions
GRI 3: Material Topics 3-3 Management of material topics 73-75
2021
GRI 305: Emissions 2016 305-1 Direct (Scope 1) GHG emissions 76
305-2 Energy indirect (Scope 2) GHG emissions 76
305-3 Other indirect (Scope 3) GHG emissions 77
305-4 GHG emissions intensity 76
305-5 Reduction of GHG emissions 72, 77, 82, 84
305-6 Emissions of ozone-depleting substances (ODS) 79
305-7 Nitrogen oxides (NOX), sulfur oxides (SOX), and other significant 79
air emissions
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Omission
No. Ref. Standar
GRI Standard Disclosure Page Requirement
Reason Explanation Sektor GR
Omitted
Waste
GRI 3: Material Topics 3-3 Management of material topics 81
2021
GRI 306: Limbah 2020 306-1 Waste generation and significant waste-related impacts 81-82
306-2 Management of significant waste-related impacts 81-83
306-3 Waste generated 81
306-4 Waste diverted from disposal 81-82
306-5 Waste directed to disposal 81-82
Employment
GRI 3: Material Topics 3-3 Management of material topics 98
2021
GRI 401: Employment 401-1 New employee hires and employee turnover 98-99
2016
401-2 Benefits provided to full time employees that are not provided to 112
temporary or part time employees
401-3 Parental leave 114
Occupational Health and Safety
GRI 3: Material Topics 3-3 Management of material topics 117
2021
GRI 403: Occupational 403-1 Occupational health and safety management system 117
Health and Safety 2018
403-2 Hazard identification, risk assessment, and incident investigation 117-118
403-3 Occupational health services 118
403-4 Worker participation, consultation, and communication on 117-118
occupational health and safety
403-5 Worker training on occupational health and safety 117-118
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Omission
No. Ref. Standar
GRI Standard Disclosure Page Requirement
Reason Explanation Sektor GR
Omitted
403-6 Promotion of worker health 118
403-7 Prevention and mitigation of occupational health and safety 117
impacts directly linked by business relationships
403-8 Workers covered by an occupational health and safety 117
management system
403-9 Work-related injuries 117-118
403-10 Work-related ill health 117-118
Training and Education
GRI 3: Material Topics 3-3 Management of material topics 101, 110
2021
GRI 404: Training and 404-1 Average hours of training per year per employee 106
Education 2016
404-2 Programs for upgrading employee skills and transition 98, 100, 102-
assistance programs 105, 107, 115,
173, 175, 178,
186, 251, 253,
260
404-3 Percentage of employees receiving regular performance and 110
career development reviews
Diversity and Equal Opportunity
GRI 3: Material Topics 3-3 Management of material topics 89, 111
2021
GRI 405: Diversity and 405-1 Diversity of governance bodies and employees 89-95
Equal Opportunity 2016
405-2 Ratio of basic salary and remuneration of women to men 111
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Omission
No. Ref. Standar
GRI Standard Disclosure Page Requirement
Reason Explanation Sektor GR
Omitted
Non-Discrimination
GRI 3: Material Topics 3-3 Management of material topics 95, 97
2021
GRI 406: Non 406-1 Incidents of discrimination and corrective actions taken 95, 97
Discrimination 2016
Freedom of Association and Collective Bargaining
GRI 3: Material Topics 3-3 Management of material topics 119
2021
Gri 407: Freedom 407-1 Operations and suppliers in which the right to freedom of 119
of Association and association and collective bargaining may be at risk
Collective Bargaining
2016
Child Labor
GRI 3: Material Topics 3-3 Management of material topics 95, 97
2021
GRI 408: Child Labor 408-1 Operations and suppliers at significant risk for incidents of child 95, 97
2016 labor
Forced or Compulsory Labor
GRI 3: Material Topics 3-3 Management of material topics 97, 111
2021
GRI 409: Forced or 409-1 Operations and suppliers at significant risk for incidents of 97, 111-112
Compulsory Labor 2016 forced or compulsory labor
Local Community
GRI 3: Material Topics 3-3 Management of material topics 122
2021
GRI 413: Local 413-1 Operations with local community engagement, impact 122-128
Community 2016 assessments, and development programs
413-2 Operations with significant actual and potential negative 187-189
impacts on local communities
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Omission
No. Ref. Standar
GRI Standard Disclosure Page Requirement
Reason Explanation Sektor GR
Omitted
Marketing and Labeling
GRI 3: Material Topics 3-3 Management of material topics 190
2021
GRI 417: Marketing and 417-1 Requirements for product and service information and labeling 190
Labeling 2016
417-2 Incidents of non-compliance concerning product and service 190
information and labeling
417-3 Incidents of non-compliance concerning marketing 190
communications
Customer Privacy
GRI 3: Material Topics 3-3 Management of material topics 177
2021
GRI 418: Customer 418-1 Substantiated complaints concerning breaches of customer 177, 184
Privacy 2016 privacy and losses of customer data
Sector disclosure
GRI G4 Financial FS1 Policies with certain environmental and social components 145-146
Services
FS2 Procedures for assessing and screening environmental and 145-146
social risks in business lines
FS3 Processes for monitoring client implementation and compliance 146
with environmental and social requirements included in
agreements or transactions
FS4 Processes for improving staff competency to implement 103-105
environmental and social policies and procedures as applied to
lines of business
FS5 Interactions with clients/ investments/business partners 146, 149
regarding environmental and social risks and opportunities
FS6 Portfolio percentage for business lines by specific area size (eg 129-135
micro/SME/large) and by sector
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Omission
No. Ref. Standar
GRI Standard Disclosure Page Requirement
Reason Explanation Sektor GR
Omitted
FS7 The monetary value of products and services designed to 131-135
provide specific social benefits for each line of business broken
down by purpose or objective
FS8 The monetary value of products and services designed to 132
provide specific environmental benefits for each line of business
broken down by purpose or objective
FS9 Scope and frequency of audits to assess implementation 145-146
of environmental and social policies and risk assessment
procedures
FS10 Percentage and number of companies held in the portfolio of 149, 225
institutions with which the reporting organization interacts on
environmental or social issues
FS11 Percentage of assets that are subject to positive and negative 225
environmental social issues
FS14 Percentage of assets that are subject to positive and negative 163
environmental social issues
FS15 Policies for the fair design and sale of financial products and 190
services
FS16 Initiatives to improve financial literacy by type or beneficiary 136-139
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Financial Service Authority (OJK) Reference [OJK G.4]
SEOJK Reference Code Disclosure Page
List of Disclosure Based on POJK No.51/ A.1 Explanation of the Sustainability Strategy 46, 48
POJK.03/2017 and SEOJK No.16/POJK.04/2021
B.1 Overview of Economic Performance 6, 37, 41, 42, 155
B.2 Overview of Environmental Performance 6, 7
B.3 Overview of Social Performance 7, 47
C.1 Vision, Mission and Sustainability Values 30
C.2 Company Address 28
C.3 Company Scale 28, 29, 36, 89-95,
98
C.4 Products, Services and Business Activities Conducted 34-35
C.5 Membership in Associations 39
C.6 Significant Organizational Changes 39
D.1 Board of Directors’ Statements 21-23, 59-60
E.1 Responsibility in the Implementation of Sustainable Finance 47-48, 56, 59-60
E.2 Competency Development Related to Sustainable Finance 103-107
E.3 Risk Assessment of Sustainable Finance Implementation 213-247
E.4 Stakeholder Engagement 48-51
E.5 Issues Related to the Implementation of Sustainable Finance 21-23
F.1 Activities to Build a Sustainability Culture 82-83, 84
F.2 Comparison of Targets and Performance in Production, Portfolio, Financing Targets, Investments, Revenue, and Profit/ 40
Loss
F.3 Comparison of Targets and Performance in Portfolios, Financing Targets, or Investments in Financial Instruments or 122, 156-170
Projects in Alignment
F.4 Environmental Costs 84
F.5 Use of Environmentally Friendly Materials 83
F.6 Amount and Intensity of Energy Used 71
F.7 Efforts and Achievements in Energy Efficiency and Renewable Energy Usage 72
F.8 Water Usage 79
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SEOJK Reference Code Disclosure Page
F.9 Impacts from Operational Areas Near or Located Conservation or Biodiversity Areas 77
F.10 Biodiversity Conservation Efforts 77
F.11 Amount and Intensity of Emissions Generated by Type 76-77, 79
F.12 Efforts and Achievements in Reducing Emissions 72, 77, 79, 82-83,
84
F.13 Amount of Waste and Effluent Generated by Type 80, 81
F.14 Waste and Effluent Management Mechanism 80-82
F.15 Spills that Occured 84
F.16 Number and Nature of Environmental Complaints Received and Resolved 84
F.17 Commitment of Financial Services Institutions (FSIs), Issuers, or Public Companies to Provide Equal Access to Products 190
and/or Services for Consumers
F.18 Equality of Employment Opportunities 89-95
F.19 Child Labor and Forced Labor 95, 97, 119
F.20 Regional Minimum Wage 111-112
F.21 Decent and Safe Working Environment 117
F.22 Employee Training and Development 103-107
F.23 Impact of Operations on Surrounding Communities 122-127
F.24 Public Complaints 187
F.25 Social and Environmental Responsibility (CSR) Activities 122-127
F.26 Innovation and Development of Sustainable Finance Products/Services 163-171
F.27 Products/Services Evaluated for Customer Safety 176, 190
F.28 Impact of Product/Service 190
F.29 Number of Products Recalled 190
F.30 Customer Satisfaction Survey on Sustainable Financial Products and/or Services 190
G.1 Written Verification from Independent Party 266, 267-272
G.2 Feedback Form 266, 290
G.3 Responses to Feedback on the Previous Year’s Report 266
G.4 List of Disclosures According to POJK 51/2017 283
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Sustainability Accounting Standard Board (SASB) Reference
Code Description Page
Data Security
FN-CB-230a.1 (1) Number of data breaches 177
(2) percentage involving personally identifiable information (PII)
(3) number of account holders affected
FN-CB-230a.2 Description of approach to identifying and addressing data security risks 177
Financial Inclusion & Capacity Building
FN-CB-240a.1 (1) Number and 130
(2) amount of loans outstanding qualified to programs designed to promote small business and community development
FN-CB-240a.2 (1) Number and 129
(2) amount of past due and nonaccrual loans qualified to programs designed to promote small business and community development
FN-CB-240a.3 Number of no-cost retail checking accounts provided to previously unbanked or underbanked customers 136
FN-CB-240a.4 Number of participants in financial literacy initiatives for unbanked, underbanked, or underserved customers 136
Incorporation of Environmental, Social, and Governance Factors in Credit Analysis
FN-CB-410a.1 Commercial and credit opening by industry 129-134
FN-CB-410a.2 Approaches to including environmental, social and governance (ESG) factors in credit analysis 145
Financed Emissions
FN-CB-410b.1 Absolute gross financed emissions, disaggregated by (1) Scope 1, (2) Scope 2 and (3) Scope 3 76-77
FN-CB-410b.2 Gross exposure for each industry by asset class 76-77
FN-CB-410b.3 Percentage of gross exposure included in the financed emissions calculation 77
FN-CB-410b.4 Description of the methodology used to calculate financed emissions 76-77
Business Ethics
FN-CB-510a.1 Total amount of monetary losses as a result of legal proceedings associated with fraud, insider trading, anti-trust, anti-competitive behaviour, market 120, 262
manipulation, malpractice, or other related financial industry laws or regulations
FN-CB-510a.2 Description of whistleblower policies and procedures 261
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Tabel Indeks Rating MSCI
No Pillar Indicator Sub Indicator Description Page
1 Environment Pillar Financing Environmental Impact ESG Risk Management Policies Scope of management system to assess ESG risks in financing activities 146-147
2 Environment Pillar Financing Environmental Impact Environmental credit policy Credit policy related to agriculture 150
3 Environment Pillar Financing Environmental Impact Environmental credit policy Credit policy related to biodiversity 154
4 Environment Pillar Financing Environmental Impact Environmental credit policy Credit policy related to power utilities 151
5 Environment Pillar Financing Environmental Impact Environmental credit policy Credit policy related to mining 152
6 Environment Pillar Financing Environmental Impact Environmental credit policy Credit policy related to oil and gas 153
7 Environment Pillar Financing Environmental Impact ESG Risk Management (ESRM) Involvement of group credit risk in ESG due diligence 217
Integration
8 Environment Pillar Financing Environmental Impact ESG Risk Management (ESRM) ESG due diligence triggers and risk escalation process clearly defined 217
Integration
9 Environment Pillar Financing Environmental Impact ESG Risk Management (ESRM) Conducts climate-related risk analysis 225-237, 240-244
Oversight
10 Environment Pillar Financing Environmental Impact ESG Risk Management (ESRM) Oversight of ESG risk management in financing activities 215
Oversight
11 Environment Pillar Financing Environmental Impact ESG Risk Management (ESRM) Evidence of board-level engagement on climate-related risks 225
Oversight
12 Environment Pillar Financing Environmental Impact ESG Risk Management (ESRM) Formal management systems to assess ESG risks in financing activities 217,218
Systems
13 Environment Pillar Financing Environmental Impact Environmental Finance Sustainability-related financial product development 155-159
Opportunities
14 Environment Pillar Financing Environmental Impact Environmental Finance Involvement in green financing and securities 156-157
Opportunities
15 Social Pillar Consumer Financial Protection Practices Employee training on consumer financial protection 175
16 Social Pillar Consumer Financial Protection Practices Debt collection policy 185-186
17 Social Pillar Consumer Financial Protection Practices Oversight of financial product or service reviews 172
18 Social Pillar Consumer Financial Protection Practices Fair advertising policy 173-174
19 Social Pillar Consumer Financial Protection Practices Financial product complaint handling process 188
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Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
No Pillar Indicator Sub Indicator Description Page
20 Social Pillar Consumer Financial Protection Practices Company offers loan modification options 186
21 Social Pillar Consumer Financial Protection Practices Financial education initiatives and stakeholder outreach 136-139
22 Social Pillar Consumer Financial Protection Practices Oversight of complaint resolution process 189
23 Social Pillar Human Capital Development Practices Scope of support for degree programs and certifications 102-105
24 Social Pillar Human Capital Development Strategy Extent of human resource-related grievance reporting or escalation procedures 115-116
25 Social Pillar Human Capital Development Strategy Employee satisfaction survey frequency 116
26 Social Pillar Human Capital Development Talent pipeline development Formal talent pipeline development strategy 102
strategy
27 Social Pillar Human Capital Development Talent pipeline development Graduate traineeship/apprenticeship 108-110
strategy program
28 Social Pillar Human Capital Development Talent pipeline development Partners with educational institutions to develop or deliver joint training programs for 102
strategy staff
29 Social Pillar Human Capital Development Programs & Initiatives Employee equity programs 112
30 Social Pillar Human Capital Development Programs & Initiatives Workforce eligible for non-pay benefits 111-112
31 Social Pillar Human Capital Development Programs & Initiatives Variable performance-based component to pay 111-112
32 Social Pillar Human Capital Development Programs & Initiatives Regular performance appraisals and feedback processes 110
33 Social Pillar Human Capital Development Programs & Initiatives Job-specific development training programs 107
34 Social Pillar Human Capital Development Programs & Initiatives Skills and knowledge development training 108-110
35 Social Pillar Access to Finance Products and Strategy Extent of involvement in microfinance/ microinsurance 129-136
36 Social Pillar Access to Finance Distribution and Outreach Innovation in mobile/online distribution channels for financial services 163, 164
37 Social Pillar Access to Finance Distribution and Outreach Points of reach of financial services 163
38 Social Pillar Access to Finance Distribution and Outreach Innovation in other alternative branchless distribution channels for financial services 163, 164
39 Social Pillar Privacy & Data Security Practices - Operations Scope of data protection policy 175-176
40 Social Pillar Privacy & Data Security Practices - Operations Rights provided to consumers regarding the control of their data 177
41 Social Pillar Privacy & Data Security Practices - Operations Measures to address data breaches 178-181
42 Social Pillar Privacy & Data Security Practices - Operations Frequency of audits of information security system 180
43 Social Pillar Privacy & Data Security Practices - Operations Responsibility for privacy and data security 176
44 Social Pillar Privacy & Data Security Practices - Operations Evidence of access control and protection of personal or sensitive data 180-181
45 Social Pillar Privacy & Data Security Practices - Operations Consent policy for use of consumer data for secondary purposes 183
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Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
No Pillar Indicator Sub Indicator Description Page
46 Social Pillar Privacy & Data Security Practices - Operations Collection, usage and retention of customer information 183-184
47 Social Pillar Privacy & Data Security Practices - Supply Chain Data protection programs covering suppliers and business partners 182
48 Social Pillar Privacy & Data Security Practices - Employees Scope of employee training on privacy and data security 178-179
49 Social Pillar Privacy & Data Security Practices - Certification Scope of information security management system certifications 180
50 Social Pillar Privacy & Data Security Practices - Certification Type of information security management system certification 180
51 Governance Pillar Corporate Governance Board - Audit Oversight Audit Board/ Committee Independence Disclosed in the
Annual Report
52 Governance Pillar Corporate Governance Board - Board Independence Executives on Board Disclosed in the
Annual Report
53 Governance Pillar Corporate Governance Board - Board Independence Related Party Transactions Disclosed in the
Annual Report
54 Governance Pillar Corporate Governance Board - Board Skills & Diversity Bank has 30% female directors 89-90
55 Governance Pillar Corporate Governance Board Attendance Attendance at Board meetings 194,195
56 Governance Pillar Corporate Governance Board - Pay Oversight Pay Committee Independence Disclosed in the
Annual Report
57 Governance Pillar Corporate Governance Pay -Non-executive Director Director Equity Policy 211
Pay
58 Governance Pillar Corporate Governance Pay - Pay Figures Executive Pay Disclosure 210
59 Governance Pillar Corporate Governance Pay - Pay Performance CEO Equity Policy 211
Alignment
60 Governance Pillar Corporate Governance Pay - Pay Performance Pay Linked to Sustainability 209
Alignment
61 Governance Pillar Corporate Governance Ownership & Control -Director Annual Director Elections 208
Elections
62 Governance Pillar Corporate Governance Ownership & Control - Director Proxy Access Disclosed in the
Elections Annual Report
63 Governance Pillar Corporate Governance Ownership & Control - One Government Intervention Concerns Disclosed in the
Share One Vote Annual Report
64 Governance Pillar Corporate Governance Ownership & Control - Controlling Shareholder Disclosed in the
Ownership Structure Annual Report
65 Governance Pillar Corporate Governance Ownership & Control - Controlling Shareholder Concerns Disclosed in the
Ownership Structure Annual Report
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Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
No Pillar Indicator Sub Indicator Description Page
66 Governance Pillar Corporate Governance Ownership & Control - Takeover Fair Bid Treatment Provisions 38
Provisions
67 Governance Pillar Corporate Behavior Business Ethics Policies & Responsibility for ethics issues 250
Practices
68 Governance Pillar Corporate Behavior Business Ethics Policies & Bribery and Anti-corruption Policy 252
Practices
69 Governance Pillar Corporate Behavior Business Ethics Policies & Regular Audits of Ethical Standards 249
Practices
70 Governance Pillar Corporate Behavior Business Ethics Policies & Whistleblower Protection 261
Practices
71 Governance Pillar Corporate Behavior Business Ethics Policies & Employee training on ethical standards 251
Practices
72 Governance Pillar Corporate Behavior Business Ethics Policies & Anti-Corruption Policy for Suppliers 37
Practices
73 Governance Pillar Corporate Behavior Business Ethics Policies & Anti-money Laundering Policy 257
Practices
74 Governance Pillar Corporate Behavior Tax Transparency Tax Transparency 42
75 Governance Pillar Corporate Behavior Business ethics controversies Corruption Risk Exposure & Controversies Disclosed in the
Annual Report
76 Governance Pillar Corporate Governance Accounting - Auditor Auditor Tenure Disclosed in the
Independence Annual Report
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Introduction BTN Profile and Building a Sustainable Managing the Environment Developing Employee Strengthening Communities Driving Innovation in Strengthening Governance as
Journey Finance Ecosystem Responsibly Potential and Well-Being through Care and Inclusion Financial Products and the Foundation of Sustainability
Digitalization
Feedback Sheet [OJK G.2]
Thank you for reading PT Bank Tabungan Negara (Persero) Tbk
Stakeholder Category
2025 Sustainability Report. To realize better reporting quality in the
coming year, we expect suggestions, criticisms and suggestions
Customer Employee Stakeholders Government and policy
from readers and users of this report. The Company is committed makers
to continuously improving sustainability performance and
providing the best for stakeholders. Mass media Partners, suppliers Society, local community Other, please specify
Profile
Please choose the appropriate answer by putting a √ in front of the available answers:
Name :
1. Does this report describe the Company’s Agree Disagree I don’t know
Institution/ performance in contributing to sustainable
Company : development?
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4. Is this report interesting? Agree Disagree I don’t know
Please write the answers according to your opinion?
We really appreciate the feedback you provide. For this, please
send this feedback sheet to: 1. Which piece of information is the most useful and interesting?
PT Bank Tabungan Negara (Persero) Tbk [GRI 2-3] 2. Which part of the information is not useful so it needs to be
Corporate Secretary Division improved?
BTN Tower 2 21st Floor
Jl. H. R. Rasuna Said No.1, 3. Is the data presented transparent, reliable, and balanced?
Jakarta Selatan 12980
Email: csd@btn.co.id
4. Suggestion/comment for future improvement of the report
290 PT Bank Tabungan Negara (Persero) Tbk
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PT Bank Tabungan Negara (Persero) Tbk Menara BTN Jl. Gajah Mada No. 1 Jakarta Pusat 10130 Tel. : (+62) 6336789, 6332666 E-mail : csd@btn.co.id www.btn.co.id
Names mentioned 45 people and organisations named in the text · linked when the evidence is strong
unresolved
org
Bank Organizer
p.11
unresolved
org
Ministry of Industry
p.12
unresolved
org
Bank BTN Tranche I
p.19
unresolved
org
PT Asuransi Kerugian Jasa Raharja.
p.24
unresolved
person
Vice
· President Director
p.25 ×2
unresolved
org
Business Sector Stock Exchange Limited
p.28
unresolved
org
Indonesia Stock Exchange
p.28
unresolved
org
Government of the Republic of Indonesia
p.28
unresolved
org
Learning & Partners
p.32
unresolved
org
Bank Syariah Steering
p.32
unresolved
person
Notary Ashoya Ratam
p.34
unresolved
org
Minister of Law No. AHU- AH.
p.34
unresolved
org
Financial Services Authority
p.34 ×3
unresolved
org
Bank Branchless Services
p.35
unresolved
org
Bank Guarantees
p.35
unresolved
person
Minister of SOE No. SE-
p.37
unresolved
org
Bank Auditors
p.39
unresolved
org
Developer Partners
p.50
unresolved
org
Business Partners / Suppliers
p.50
unresolved
org
Ministry of Energy and Mineral
p.71
unresolved
org
Directorate General of Electricity
p.76
unresolved
org
Ministry of Energy and Mineral Resources
p.76
unresolved
org
Yayasan KEHATI
p.78
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