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Page 1
Embedding Sustainable Value
into Every Aspect of Life

2025
Sustainability Report



  PT Bank Tabungan Negara (Persero) Tbk
Page 2

          
Page 3
                         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.




3      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




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



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4                 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




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



5               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




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



6             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




                                                          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


7               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




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.




8              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




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




9               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




     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




11                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




 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



12                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




     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.




13               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




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%



15              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




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.




17               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




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.




18            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                 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.




19            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




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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                                  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




                                                                                                                                                   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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                                                  Journey           Finance Ecosystem        Responsibly                  Potential and Well-Being   through Care and Inclusion   Financial Products and   the Foundation of Sustainability
                                                                                                                                                                                  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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                                 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




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




23             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




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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                                       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




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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                       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




26   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




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
Page 28
                       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




                                                                                  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.




28   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




     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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                                       Journey           Finance Ecosystem        Responsibly                Potential and Well-Being   through Care and Inclusion            Financial Products and   the Foundation of Sustainability
                                                                                                                                                                              Digitalization




                                             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.




30   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




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



31            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




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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                                     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 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.


33              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




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/.




34               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




     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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                                     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




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




36                 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




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




40              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 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




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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




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
                                                  Journey           Finance Ecosystem        Responsibly                 Potential and Well-Being      through Care and Inclusion        Financial Products and      the Foundation of Sustainability
                                                                                                                                                                                         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




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                                  Pendahuluan     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 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
Page 46
                                 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
                                                  Journey           Finance Ecosystem        Responsibly                     Potential and Well-Being   through Care and Inclusion   Financial Products and   the Foundation of Sustainability
                                                                                                                                                                                     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.




48            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




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
                                                  Journey           Finance Ecosystem        Responsibly                Potential and Well-Being   through Care and Inclusion      Financial Products and   the Foundation of Sustainability
                                                                                                                                                                                   Digitalization




                                                                                                      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
                                                 Journey           Finance Ecosystem        Responsibly                Potential and Well-Being   through Care and Inclusion       Financial Products and   the Foundation of Sustainability
                                                                                                                                                                                   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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                                     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




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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                                  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 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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                                  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




                                                                                                                                                                                         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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                                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




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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                       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




                                                                              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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                                  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




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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                                  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




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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                                   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




                                                                                      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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                                   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 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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                                  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 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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                                  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




                                                                                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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                                  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




     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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                                    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




                                                                                    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
                                                                                                                                                                                     Digitalization


                                                                                                                                                 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
                                                  Journey             Finance Ecosystem        Responsibly                  Potential and Well-Being        through Care and Inclusion   Financial Products and   the Foundation of Sustainability
                                                                                                                                                                                         Digitalization




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
                                              Journey           Finance Ecosystem        Responsibly                Potential and Well-Being   through Care and Inclusion   Financial Products and   the Foundation of Sustainability
                                                                                                                                                                            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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                            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




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
                                                 Journey           Finance Ecosystem        Responsibly                   Potential and Well-Being   through Care and Inclusion   Financial Products and   the Foundation of Sustainability
                                                                                                                                                                                  Digitalization




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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                                   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




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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                                   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




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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                                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




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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                                 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 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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                                 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




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.




75             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




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.



76                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




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




77                 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




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.




78             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




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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                                     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




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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                                   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




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


81               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




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.




83              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




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.



84             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




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
Page 86
                                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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                                  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




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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                                 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




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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                                        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




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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                                       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




                                             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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                                      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




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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                                    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




                                                            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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                                          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




                                                                                                                                                                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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                                            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




                                                                                                                                                                     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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                                      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




                                       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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                                                   Journey           Finance Ecosystem        Responsibly                     Potential and Well-Being   through Care and Inclusion   Financial Products and   the Foundation of Sustainability
                                                                                                                                                                                      Digitalization




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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                                                                                                                                                                                   Digitalization




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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                                                  Journey           Finance Ecosystem         Responsibly                  Potential and Well-Being        through Care and Inclusion           Financial Products and   the Foundation of Sustainability
                                                                                                                                                                                                Digitalization




      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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                                                           Journey                  Finance Ecosystem               Responsibly                  Potential and Well-Being       through Care and Inclusion           Financial Products and   the Foundation of Sustainability
                                                                                                                                                                                                                     Digitalization




          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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                                                                                                                                                                                           Digitalization




                   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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                                                 Journey           Finance Ecosystem        Responsibly                Potential and Well-Being   through Care and Inclusion   Financial Products and   the Foundation of Sustainability
                                                                                                                                                                               Digitalization




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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                                                     Journey           Finance Ecosystem        Responsibly                     Potential and Well-Being     through Care and Inclusion   Financial Products and   the Foundation of Sustainability
                                                                                                                                                                                          Digitalization




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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                                                   Journey           Finance Ecosystem        Responsibly                  Potential and Well-Being   through Care and Inclusion   Financial Products and   the Foundation of Sustainability
                                                                                                                                                                                   Digitalization




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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                                                  Journey              Finance Ecosystem              Responsibly                  Potential and Well-Being        through Care and Inclusion       Financial Products and   the Foundation of Sustainability
                                                                                                                                                                                                    Digitalization




                    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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                                                   Journey               Finance Ecosystem         Responsibly                  Potential and Well-Being    through Care and Inclusion       Financial Products and      the Foundation of Sustainability
                                                                                                                                                                                             Digitalization




      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




105              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




                                                                                 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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                                 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




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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                                               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




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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                                 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




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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                                 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 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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                                      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




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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                                         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




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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                                 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




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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                                    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




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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                                                                                                                                                                                   Digitalization




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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                                                                                                                                                                                        Digitalization




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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                                                                                                                                                                                        Digitalization




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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                                                                                                                                                                                        Digitalization




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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                                                                                                                                                                                   Digitalization




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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                                                                                                                                                                         Digitalization




                                                                                                              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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                                                                                                                                                                             Digitalization




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
                                                                                                                                                                                 Digitalization




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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                                                                                                                                                                                      Digitalization




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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                                                                                                                                                                                 Digitalization




 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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                                                                                                                                                                              Digitalization




 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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                                                                                                                                                                                   Digitalization




 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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                                                                                                                                                                              Digitalization




 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.




127          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




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




128              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




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


129            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




                                                  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

130                    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




            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




131               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




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




132               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




                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




133              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




                                                              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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                                     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




                                 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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                                                    Journey           Finance Ecosystem        Responsibly                  Potential and Well-Being     through Care and Inclusion   Financial Products and     the Foundation of Sustainability
                                                                                                                                                                                      Digitalization




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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                                                  Journey           Finance Ecosystem        Responsibly                Potential and Well-Being     through Care and Inclusion     Financial Products and   the Foundation of Sustainability
                                                                                                                                                                                    Digitalization




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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                                                 Journey           Finance Ecosystem        Responsibly                Potential and Well-Being   through Care and Inclusion   Financial Products and   the Foundation of Sustainability
                                                                                                                                                                               Digitalization




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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                                        Journey           Finance Ecosystem        Responsibly                Potential and Well-Being   through Care and Inclusion   Financial Products and   the Foundation of Sustainability
                                                                                                                                                                      Digitalization




                                                                                                               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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                                        Journey           Finance Ecosystem        Responsibly                Potential and Well-Being   through Care and Inclusion   Financial Products and   the Foundation of Sustainability
                                                                                                                                                                      Digitalization




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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




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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                                                 Journey           Finance Ecosystem        Responsibly                Potential and Well-Being   through Care and Inclusion     Financial Products and   the Foundation of Sustainability
                                                                                                                                                                                 Digitalization




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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                                                                Journey           Finance Ecosystem            Responsibly                  Potential and Well-Being       through Care and Inclusion         Financial Products and    the Foundation of Sustainability
                                                                                                                                                                                                              Digitalization




  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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                                                       Journey           Finance Ecosystem        Responsibly                     Potential and Well-Being   through Care and Inclusion   Financial Products and   the Foundation of Sustainability
                                                                                                                                                                                          Digitalization




     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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                                                   Journey           Finance Ecosystem        Responsibly                     Potential and Well-Being   through Care and Inclusion   Financial Products and   the Foundation of Sustainability
                                                                                                                                                                                      Digitalization




      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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                                                    Journey           Finance Ecosystem            Responsibly                  Potential and Well-Being        through Care and Inclusion      Financial Products and   the Foundation of Sustainability
                                                                                                                                                                                                Digitalization




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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                                              Journey           Finance Ecosystem        Responsibly                Potential and Well-Being   through Care and Inclusion   Financial Products and   the Foundation of Sustainability
                                                                                                                                                                            Digitalization




           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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                                                  Journey           Finance Ecosystem        Responsibly                         Potential and Well-Being        through Care and Inclusion                Financial Products and    the Foundation of Sustainability
                                                                                                                                                                                                           Digitalization




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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                                                                                                                                                                                    Digitalization




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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                                        Journey            Finance Ecosystem              Responsibly                Potential and Well-Being   through Care and Inclusion         Financial Products and   the Foundation of Sustainability
                                                                                                                                                                                   Digitalization




                                                   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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                                        Journey            Finance Ecosystem         Responsibly                Potential and Well-Being     through Care and Inclusion          Financial Products and      the Foundation of Sustainability
                                                                                                                                                                                 Digitalization




                                                        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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                                                                                                                                                                              Digitalization




                                                    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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                                        Journey           Finance Ecosystem        Responsibly                Potential and Well-Being   through Care and Inclusion   Financial Products and   the Foundation of Sustainability
                                                                                                                                                                      Digitalization




                                                   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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                                        Journey            Finance Ecosystem        Responsibly                Potential and Well-Being   through Care and Inclusion   Financial Products and   the Foundation of Sustainability
                                                                                                                                                                       Digitalization




                                                    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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                                                       Journey           Finance Ecosystem          Responsibly                   Potential and Well-Being   through Care and Inclusion         Financial Products and    the Foundation of Sustainability
                                                                                                                                                                                                Digitalization




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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                                                                                                                                                                                      Digitalization




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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                                                                                                                                                                                                         Digitalization




                                                                          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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                                  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




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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                                   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-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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                                      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




 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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                                 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




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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                                    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




                                                                              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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                                 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




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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                          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




  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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                                         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




                                                                                                     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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                          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




  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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                                                    Journey            Finance Ecosystem        Responsibly                Potential and Well-Being   through Care and Inclusion        Financial Products and   the Foundation of Sustainability
                                                                                                                                                                                        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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                                             Journey           Finance Ecosystem            Responsibly                Potential and Well-Being   through Care and Inclusion      Financial Products and       the Foundation of Sustainability
                                                                                                                                                                                  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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                                              Journey           Finance Ecosystem            Responsibly                Potential and Well-Being       through Care and Inclusion          Financial Products and   the Foundation of Sustainability
                                                                                                                                                                                           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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                                                 Journey           Finance Ecosystem            Responsibly                  Potential and Well-Being   through Care and Inclusion       Financial Products and    the Foundation of Sustainability
                                                                                                                                                                                         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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                                        Journey           Finance Ecosystem          Responsibly                Potential and Well-Being   through Care and Inclusion   Financial Products and   the Foundation of Sustainability
                                                                                                                                                                        Digitalization




                                                                               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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                                                  Journey           Finance Ecosystem        Responsibly                     Potential and Well-Being   through Care and Inclusion   Financial Products and   the Foundation of Sustainability
                                                                                                                                                                                     Digitalization




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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                                                      Journey           Finance Ecosystem        Responsibly                  Potential and Well-Being   through Care and Inclusion   Financial Products and    the Foundation of Sustainability
                                                                                                                                                                                      Digitalization




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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                                                      Journey           Finance Ecosystem        Responsibly                     Potential and Well-Being   through Care and Inclusion   Financial Products and    the Foundation of Sustainability
                                                                                                                                                                                         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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                                                        Journey           Finance Ecosystem        Responsibly                     Potential and Well-Being   through Care and Inclusion   Financial Products and    the Foundation of Sustainability
                                                                                                                                                                                           Digitalization




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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                                                  Journey           Finance Ecosystem        Responsibly                      Potential and Well-Being   through Care and Inclusion   Financial Products and   the Foundation of Sustainability
                                                                                                                                                                                      Digitalization




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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                                                    Journey           Finance Ecosystem        Responsibly                  Potential and Well-Being   through Care and Inclusion       Financial Products and   the Foundation of Sustainability
                                                                                                                                                                                        Digitalization




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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                                                  Journey           Finance Ecosystem        Responsibly                  Potential and Well-Being   through Care and Inclusion   Financial Products and   the Foundation of Sustainability
                                                                                                                                                                                  Digitalization




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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                                  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




                                                             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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                                                  Journey           Finance Ecosystem        Responsibly                     Potential and Well-Being   through Care and Inclusion   Financial Products and   the Foundation of Sustainability
                                                                                                                                                                                     Digitalization




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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                                                   Journey           Finance Ecosystem        Responsibly                Potential and Well-Being   through Care and Inclusion       Financial Products and   the Foundation of Sustainability
                                                                                                                                                                                     Digitalization




                                                                                     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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                                                    Journey           Finance Ecosystem        Responsibly                     Potential and Well-Being   through Care and Inclusion   Financial Products and   the Foundation of Sustainability
                                                                                                                                                                                       Digitalization




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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                                                  Journey           Finance Ecosystem        Responsibly                     Potential and Well-Being   through Care and Inclusion   Financial Products and   the Foundation of Sustainability
                                                                                                                                                                                     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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                                 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 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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                                                  Journey           Finance Ecosystem        Responsibly                  Potential and Well-Being   through Care and Inclusion   Financial Products and   the Foundation of Sustainability
                                                                                                                                                                                  Digitalization




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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                                                      Journey           Finance Ecosystem        Responsibly                      Potential and Well-Being   through Care and Inclusion        Financial Products and    the Foundation of Sustainability
                                                                                                                                                                                               Digitalization




                                                                  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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                                                    Journey           Finance Ecosystem         Responsibly                  Potential and Well-Being   through Care and Inclusion       Financial Products and   the Foundation of Sustainability
                                                                                                                                                                                         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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                                                            Journey           Finance Ecosystem        Responsibly                 Potential and Well-Being   through Care and Inclusion   Financial Products and   the Foundation of Sustainability
                                                                                                                                                                                           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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                                                         Journey               Finance Ecosystem              Responsibly                   Potential and Well-Being       through Care and Inclusion             Financial Products and   the Foundation of Sustainability
                                                                                                                                                                                                                  Digitalization




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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                                   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




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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                                              Journey           Finance Ecosystem        Responsibly                Potential and Well-Being   through Care and Inclusion   Financial Products and   the Foundation of Sustainability
                                                                                                                                                                            Digitalization




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
Page 192
                                 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 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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                                                                                                                                                                                            Digitalization




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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                                                                                                                                                                                            Digitalization




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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                                                                                                                                                                                        Digitalization




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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                                                                                                                                                                                                 Digitalization




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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                                                  Journey           Finance Ecosystem        Responsibly                  Potential and Well-Being        through Care and Inclusion   Financial Products and   the Foundation of Sustainability
                                                                                                                                                                                       Digitalization




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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                                                  Journey           Finance Ecosystem        Responsibly                Potential and Well-Being   through Care and Inclusion      Financial Products and   the Foundation of Sustainability
                                                                                                                                                                                   Digitalization




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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                                                                                                                                                                                       Digitalization




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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                                                                                                                                                                           Digitalization




                                                                                                              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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                                                  Journey                 Finance Ecosystem                              Responsibly                Potential and Well-Being       through Care and Inclusion      Financial Products and   the Foundation of Sustainability
                                                                                                                                                                                                                   Digitalization




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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                                                                                                                                                                                          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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                                   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




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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                                                 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
                                                  Journey           Finance Ecosystem        Responsibly                  Potential and Well-Being   through Care and Inclusion   Financial Products and   the Foundation of Sustainability
                                                                                                                                                                                  Digitalization




      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
                                                  Journey           Finance Ecosystem             Responsibly                  Potential and Well-Being     through Care and Inclusion       Financial Products and        the Foundation of Sustainability
                                                                                                                                                                                             Digitalization




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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                                  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




                                                                                                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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                                        Journey           Finance Ecosystem        Responsibly                  Potential and Well-Being       through Care and Inclusion   Financial Products and   the Foundation of Sustainability
                                                                                                                                                                            Digitalization




                                                                                                              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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                                  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 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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                                      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




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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                                  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 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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                                         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




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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                                   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




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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                                    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




                                                                                                                                  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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                                 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 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




219            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




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




220            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




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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                                    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




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).




222               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




      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).




223                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




      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.




225               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




                                                                                                              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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                                         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

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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                                         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

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.




231                   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




                                                                                                       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.




234                   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




                              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.




236                  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




                            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




237                  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




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.




238             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




                                 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.




239             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




                            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




240             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




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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                                     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




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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                                       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




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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                                  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




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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                                  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




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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                                                   Journey             Finance Ecosystem          Responsibly                  Potential and Well-Being    through Care and Inclusion     Financial Products and   the Foundation of Sustainability
                                                                                                                                                                                          Digitalization




                 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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                                                 Journey           Finance Ecosystem            Responsibly                  Potential and Well-Being   through Care and Inclusion     Financial Products and   the Foundation of Sustainability
                                                                                                                                                                                       Digitalization




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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                                                     Journey           Finance Ecosystem        Responsibly                     Potential and Well-Being   through Care and Inclusion        Financial Products and   the Foundation of Sustainability
                                                                                                                                                                                             Digitalization




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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                                                                                                                                                                                     Digitalization




                                                                                                                                                         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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                                                   Journey           Finance Ecosystem        Responsibly                  Potential and Well-Being   through Care and Inclusion        Financial Products and    the Foundation of Sustainability
                                                                                                                                                                                        Digitalization




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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                                                                                                                                                                                     Digitalization




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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                                                                                                                                                                                    Digitalization




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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                                                                                                                                                                                     Digitalization




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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                                                                                                                                                                                    Digitalization




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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                                                                                                                                                                                   Digitalization




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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                                                                                                                                                                                 Digitalization




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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                                                   Journey           Finance Ecosystem            Responsibly                   Potential and Well-Being   through Care and Inclusion         Financial Products and        the Foundation of Sustainability
                                                                                                                                                                                              Digitalization




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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                                                                                                                                                                                      Digitalization




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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                                                    Journey               Finance Ecosystem         Responsibly                  Potential and Well-Being        through Care and Inclusion         Financial Products and    the Foundation of Sustainability
                                                                                                                                                                                                    Digitalization




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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                                                        Journey           Finance Ecosystem            Responsibly                     Potential and Well-Being    through Care and Inclusion     Financial Products and   the Foundation of Sustainability
                                                                                                                                                                                                  Digitalization




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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                                                         Journey           Finance Ecosystem         Responsibly                  Potential and Well-Being                through Care and Inclusion                  Financial Products and           the Foundation of Sustainability
                                                                                                                                                                                                                      Digitalization




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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                                                                                                                                                                                 Digitalization




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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                                                                                                                                                                                  Digitalization




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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                                                                                                                                                                      Digitalization




                                                                      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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                                                                                                                                                                      Digitalization




      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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                                                                                                                                                                      Digitalization




      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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                                                                                                                                                                      Digitalization




      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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                                                                                                                                                                      Digitalization




      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.




271   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 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




272       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




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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                                                   Journey           Finance Ecosystem        Responsibly                    Potential and Well-Being    through Care and Inclusion   Financial Products and   the Foundation of Sustainability
                                                                                                                                                                                      Digitalization




                                                                                                                                                                         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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                                         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




                                                                                                                                                                              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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                                      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




                                                                                                                                                                         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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                                     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




                                                                                                                                                                          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




277              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




                                                                                                                                                                       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




278             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




                                                                                                                                                                          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




279              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




                                                                                                                                                                          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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                                      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




                                                                                                                                                                         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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                                   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




                                                                                                                                                                      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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                                 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




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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                         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




      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




284    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




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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                                   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




 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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                                  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




 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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                                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




 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




289           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




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

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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
Page 291

          
Page 292
PT Bank Tabungan Negara (Persero) Tbk


Menara BTN
Jl. Gajah Mada No. 1
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Tel.     : (+62) 6336789, 6332666
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linked org Bank Tabungan Negara (Persero) Tbk p.1 ×265
linked person Suryo Utomo p.24
linked person Dwi Ary Purnomo p.24
linked person Fahri Hamzah p.24
linked person Ida Nuryanti p.24
linked person Pietra Machreza Paloh p.24
linked person Panangian Simanungkalit p.24
linked person Didyk Choiroel p.24
linked org Jasa Raharja. p.24
linked person Oni Febriarto Rahardjo p.25
linked person Setiyo Wibowo p.25
linked person Hirwandi Gafar p.25
linked person Nofry Rony Poetra p.25
linked person Eko Waluyo p.25
linked person Tan Jacky Chen p.25
linked person Venda Yuniarti p.25
linked person Helmy Afrisa Nugroho p.25
linked person I Nyoman Sugiri Yasa p.25
linked person Rully Setiawan p.25
linked org PT Bank Syariah Nasional p.35 ×3
possible org Otoritas Jasa Keuangan p.61
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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