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Employee Development and Welfare Support 106 Human Resource Management 108 Diversity, Equality, and Inclusion 122 Learning and Competency Development 137 Protection and Fulfillment of Employee Rights 146 Employee Health and Safety 148 Harmonious Industrial Relations 149 Social and Economic Compliance
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Employee Development
Sustainable Environmental and Welfare Support
About The Report BTN Profile
Management
Human Resource Management
BTN has a strategy to realize its vision through the BTN implements various human capital strategy
mission of “Becoming the Home of Indonesia’s Best initiatives as part of its strategy and initiatives, including:
Talent.” This strategy is implemented through short- 1. Aligning remuneration systems and incentive
and medium-term human resource (HR) development programs to attract, retain, and motivate
programs aligned with the BTN Corporate Plan for 2024- employees.
2029, as follows: 2. Implementing multi-sourcing strategies and
1. Ability to Attract Top Talents running orientation programs for new employees
Becoming a top-of-mind employer for external and internal transfers.
candidates from outside the Bank and leading 3. Activating the four pillars of Employee Value
universities in Indonesia. Proposition (EVP) —Learn, Grow, Contribute, and
2. Ability to Retain Top Talents Engage—to enhance BTN’s reputation.
Retaining top talent to grow and develop with BTN. 4. Managing succession planning to ensure the
3. Talents’ Capability Readiness fulfillment of critical/key positions and address
Equipping talent with the capabilities to achieve generational gaps.
the Bank’s current and future strategic goals. 5. Detailing dual career paths (specialist and
4. Employee Productivity general) for critical positions in alignment with
Achieving employee productivity levels above the BTN’s strategic goals.
average of prominent organizations. 6. Implementing predictive and productivity-based
workforce planning.
To achieve these aspirations, BTN has formulated the 7. Applying systematic productivity measurement
following strategies and initiatives: methodologies and metrics for business and
1. Become the top workplace choice for the best support segments.
talent. 8. Establishing integrated performance
2. Strengthen HR capabilities, productivity, and management principles and governance,
competitiveness through integrated employee including multi-source performance appraisals to
development programs aligned with current and ensure comprehensive objectivity.
future business needs and 9. Refining learning strategies, implementing
3. Focus on value creation and becoming a business consistent mentoring, and conducting
partner. interventions to foster a learning culture.
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Community Development Excellent Service for Sustainability
and Empowerment Customer Satisfaction Governance Integrity
Human Resource Development Framework
Becoming the Home of Indonesia’s Best Talent
BTN successfully attracts and retains Indonesia’s best talent with exceptional capabilities and high
productivity to achieve the Bank’s strategic goals and business targets.
Ability to attract Ability to retain Talents’ capability Employee
top talents top talents readiness productivity
Becoming the top workplace choice for the best talent Strengthening HR capabilities, productivity, and competitiveness
Focusing on value creation and becoming a business partner
Employee Value Proposition (EVP) Remuneration Performance Management
Activating the four EVP pillars—Learn,
Grow, Contribute, and Engagement—to Applying systematic productivity
enhance BTN’s branding. measurement methodologies and
matrices for business and support
segments.
Recruitment & Onboarding
Implementing integrated performance
Implementing multi-sourcing strategies management principles and governance, with
and onboarding programs for new hires multi-source performance appraisals to ensure Workforce Planning
and transfers. comprehensive objectivity.
Remuneration Implementing predictive and
productivity-based workforce
planning.
Aligning remuneration systems and
incentive programs to attract, retain,
and motivate employees.
Talent Management Learning and Development
Managing succession to ensure the fulfillment of critical/key
positions and addressing generational gaps.
Refining learning strategies, implementing consistent mentoring,
and supporting a learning culture through targeted investments.
Detailing dual career paths (specialist and generalist) for critical
positions aligned with BTN’s strategic objectives.
Organisational Alignment
Developing Human Capital Business Partner (HCBP) capabilities to align HC strategies with business needs.
Refining the HC organizational structure and designing a grading system aligned with business requirements.
Further improving operational excellence and HR management practices.
Digital Human Resource (HR) & Corporate Culture
Strengthening the internalization of BTN’s core values (AKHLAK) and the four pillars of BTN culture through optimizing the Change Agent
Network.
Implementing an integrated Human Capital Information System (HCIS) to support operational excellence, data-driven decision-making,
and provide a seamless employee experience.
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Sustainable Environmental and Welfare Support
About The Report BTN Profile
Management
Diversity, Equality, and Inclusion
Policies and Management Oversight
BTN upholds the fundamental principles of diversity, Labor Agreement. BTN ensures that diversity, equality,
equality, and inclusion for all employees following and inclusion are applied across all processes, including
Law Number 13 of 2003 concerning Labor. To ensure recruitment, training and competency development,
these principles are implemented concretely, BTN has career progression, employee remuneration, and
developed policies and regulations supporting respect welfare. BTN also guarantees that these processes are
for human rights. These principles are outlined in General carried out without discrimination based on gender,
Policy No.KU.3 on Human Capital and the Collective religion, ethnicity, or race. [GRI 3-3, 2-23] [OJK C.3, F.18]
Diversity in the Composition of the Board of Commissioners and
Directors [GRI 2-9]
Diversity within the Board of Commissioners and Although the members of the Board of Commissioners
Directors fosters inclusive management and ensures and Directors do not come from underrepresented
sustainable outcomes. Diverse backgrounds, including social groups, they remain committed to listening to
age, gender, education, work experience, and expertise their aspirations and acting as representatives for such
at the highest level of governance, enrich the strategic groups. This approach reflects efforts to foster inclusive
decision-making process. This diversity allows the governance. Below is a table reflecting the diversity of
Bank to assess issues and opportunities from various the composition of the Board of Commissioners and
perspectives, leading to more accurate and innovative Directors, showcasing their varied backgrounds and
decisions. It also supports creating an open and expertise:
inclusive environment where different viewpoints are
valued, ultimately enhancing the Bank’s long-term
performance and competitiveness.
Table of Diversity in the Composition of the Board of Commissioners [GRI 405-1]
Name Position Age Gender Education Work Experience Expertise
Chandra M. President 57 Male Bachelor of Law Experience in legal Law
Hamzah Commissioner/ affairs
Independent
Iqbal Latanro Vice President 66 Male • Master of Science (MSi.) Experience in Economics
Commissioner/ (Business Management) banking
Independent • Bachelor of Economics
Armand B. Independent 72 Male Master & Bachelor of Experience in Business
Arief Commissioner Business Administration banking Administration
Sentot A. Independent 67 Male • Master of Business Experience in civil Economics
Sentausa Commissioner Administration engineering
• Bachelor of Statistics at
Universitas Padjadjaran
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Name Position Age Gender Education Work Experience Expertise
Andin Commissioner 59 Male • Doctor of Philosophy Experience in Economics
Hadiyanto (Ph.D) government
• Bachelor of Economics
Herry Commissioner 57 Male Doctor & Bachelor of Civil Experience in civil Civil Engineering
Trisaputra Engineering engineering
Zuna
Himawan Commissioner 61 Male • Doctor of Management Experience in Civil Engineering
Arief Sugoto and Business property
• Master & Bachelor of
Civil Engineering
Adi Independent 57 Female Bachelor of Economic Experience in Economics
Sulistyowati Commissioner Management banking
Bambang Independent 61 Male • Bachelor of Accounting Experience in Accounting
Widjanarko Commissioner • Master of Business & banking
Finance
Table of Diversity in the Composition of the Board of Directors [GRI 405-1]
Name Position Age Gender Education Work Experience Expertise
Nixon L.P. President 55 Male Bachelor of Economics Experience in Economics
Napitupulu Director banking
Oni Febriarto Vice President 53 Male • Master of Management Experience in Engineering,
Rahardjo Director • Bachelor of Engineering banking Management
Andi Nirwoto Director of 54 Male • Master of Finance Experience in Engineering,
Information • Bachelor of Engineering banking Management
Technology
Elisabeth Director 57 Female Bachelor of Civil Law Experience in Law
Novie of Assets banking
Riswanti Management
Jasmin Director of 60 Male • Master of International Experience in Accounting,
Distribution & Business banking Business
Institutional • Bachelor of Economics
Funding
Hirwandi Director of 56 Male Bachelor of Civil Experience in Civil
Gafar Consumer Engineering banking Engineering
Setiyo Director of Risk 47 Male • MBA in Finance & Experience in Engineering,
Wibowo Management Banking banking Finance
• Bachelor of Electrical
Engineering
Nofry Rony Director of 56 Male • MBA in Business Experience in Economics
Poetra Finance • Bachelorofin Economics banking
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Sustainable Environmental and Welfare Support
About The Report BTN Profile
Management
Name Position Age Gender Education Work Experience Expertise
Eko Waluyo Director of 53 Male • Master of Economics Experience in Economics
Human Capital, • Bachelor of Economics banking
Compliance, &
Legal
Hakim Director of 47 Male • Bachelor of International Experience in International
Putratama Operations Relations banking Relations
& Customer • Master of International
Experience Business
Muhammad Director of SME 51 Male • Bachelor of Civil Experience in Engineering,
Iqbal & Retail Funding Engineering banking Management
• Master of General
Management
• Master of Business
Administration
Currently, the composition of female directors at A shareholder, in this case, the Ministry of State-Owned
Bank BTN is 9.09%, with one (1) female director out of Enterprises (BUMN), through the General Meeting of
11 (eleven) board members. This reflects Bank BTN’s Shareholders (GMS) agenda.
commitment to enhancing diversity and inclusivity in
leadership. Through Regulation of the Minister of State- To support women’s empowerment, Bank BTN has
Owned Enterprises Number PER-7/MBU/09/2022 of proposed 7 female candidates as BUMN Nominated
2022 regarding Amendments to the Regulation of the Talent to the Ministry of State-Owned Enterprises,
Minister of State-Owned Enterprises Number PER-11/ representing 28% of the total 25 Nominated Talent.
MBU/07/2021 on the Requirements, Procedures for the This initiative underscores Bank BTN’s commitment
Appointment, and Dismissal of Members of the Board to continuously encouraging female participation
of Directors of State-Owned Enterprises. the selection of in strategic positions within BUMN, fostering greater
BUMN directors is the prerogative of the Dwiwarna Series diversity, and supporting corporate sustainability.
Employee Demographic [GRI 2-7, 2-8] [GRI 405-1] [OJK C.3, F.18]
The employee information presented in this report is details about employees are provided in the following
sourced from the Human Capital Management Unit’s tables:
database, the accuracy of which can be verified. Further
Employee Demographics by Gender [GRI 2-7, 2-8] [OJK C.3.b]
2024 2023 2022
Gender
Total (%) Total (%) Total (%)
Male 6,576 51.06 6,288 52.20 6,261 52.80
Female 6,288 48.94 5,757 47.80 5,598 47.20
Subtotal 12,864 100.00 12,045 100.00 11,859 100.00
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Employee Demographics by Age Group, Gender, and Position Level [GRI 2-7, 2-8] [OJK C.3.b]
2024
Age Range (Year) Entry-level Mid-level Senior-level Executive-level
Subtotal
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
2023
Age Range (Year) Entry-level Mid-level Senior-level Executive-level
Subtotal
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
Total 3,329 4,208 2,528 1,457 431 92 14 1 12,060
*M= Male/ F= Female
2022
Age Range (Year) Entry-level Mid-level Senior-level Executive-level
Subtotal
M F M F M F M F
18-25 335 791 88 126 - - - - 1,340
25-35 2,757 2,883 1,266 684 1 - - - 7,591
35-45 241 390 517 277 41 16 3 - 1,485
45-55 36 29 529 229 350 64 6 1 1,244
>55 - - - 1 2 - 4 - 7
Total 3,369 4,093 2,400 1,317 394 80 13 1 11,667
*M= Male/ F= Female
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Management
Employee Demographics by Position Level and Gender [GRI 2-7, 2-8] [OJK C.3.b]
2024
Male Female
Position Level
Number of Percentage of Number of Percentage of
Employee employees (%) Employee employees (%)
Entry-level 3,607 54.85% 4,636 73.73%
Mid-level 2,549 38.765 1,551 24.67%
Senior-level 404 6.14% 100 1.59%
Executive-level (Including Directors and
16 0.24% 1 0.02%
SEVPs)
Subtotal 6,576 100.00% 6,288 100.00%
Employee Demographics by Employment Status and Work Area [GRI 2-7, 2-8] [OJK C.3.b]
2024
Employment
Headquarters Regional Office Branch Office Total
Status
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
Subtotal 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
**Excluding Directors and SEVPs
2023
Employment
Headquarters Regional Office Branch Office Total
Status
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
Subtotal 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
**Excluding Directors and SEVPs
2022
Employment
Headquarters Regional Office Branch Office Total
Status
M F Total % M F Total % M F Total % M F Total %
Permanent 1,944 865 2,814 89.28 386 169 555 97.03 3,848 3,858 7,342 90.25 5,819 4,892 10,711 90.32
Contract 141 197 338 10.72 5 12 17 2.97 296 497 793 9.75 442 706 1,148 9.68
Subtotal 2,090 1,062 3,152 100.00 391 181 172 100.00 3,780 4,355 8,135 100.00 6,261 5,598 11,859 100.00
*M= Male/ F= Female
**Excluding Directors and SEVPs
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2023 2022
Male Female Male Female
Percentage Percentage Percentage Percentage
Number of Number of Number of Number of
of employees of employees of employees of employees
Employee Employee Employee Employee
(%) (%) (%) (%)
3,329 52.82% 4,208 73.08% 3,369 54.55% 4,093 74.55%
2,528 40.11% 1,457 25.30% 2,400 38.86% 1,317 23.99%
431 6.84% 92 1.60% 394 6.38% 79 1.44%
14 0.22% 1 0.02% 13 0.21% 1 0.02%
6,302 100.00% 5,758 100.00% 6,176 100.00% 5,490 100.00%
Employee Demographics by Education Level and Gender [GRI 2-7, 2-8] [OJK C.3.b]
2024 2023 2022
Education
Level
M F Total (%) M F Total (%) M F Total (%)
Postgraduate 373 189 562 4.37 367 168 535 4.44 348 159 507 4.28
Bachelor 5,574 5,212 10,786 83.96 5,254 4,627 9,881 82.03 5,154 4,353 9,507 80.17
Diploma 511 706 1,217 9.47 539 734 1,273 10.57 604 796 1,399 11.80
High School 102 180 282 2.20 128 228 356 2.96 156 290 446 3/76
Subtotal 6,560 6,287 12,847 100.00 6,288 5,757 12,045 100.00 6,261 5,598 11,859 100.00
*M= Male/ F= Female
**Excluding Directors and SEVPs
Employee Demographics by Employment Status and Gender, Including Outsourced Employees
[GRI 2-7, 2-8] [OJK C.3.b]
2024 2023 2022
Employment
Status
M F Total (%) M F Total (%) M F Total (%)
Permanent 6,485 6,214 12,699 61.69 5,984 5,286 11,270 55.98 5,819 4,892 10,711 53.43
Contract 75 73 148 0.72 304 471 775 3.85 442 706 1,148 5.73
Without
6,560 6,287 12,847 62.41 6,288 5,757 12,045 59.83 6,261 5,598 11,859 59.16
Outsourced
Outsourced 6,551 1,187 7,738 37.59 6,930 1,157 8,087 40.17 7,093 1,094 8,187 40.84
Subtotal
(Including 13,111 7,474 20,585 100.00 13,218 6,914 20,132 100.00 13,254 6,692 20,046 100.00
Outsourced)
*M= Male/ F= Female
**Excluding Directors and SEVPs
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Sustainable Environmental and Welfare Support
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Management
Employee Demographics by Years of Service and Gender [GRI 2-7, 2-8] [OJK C.3.b]
Years of 2024 2023 2022
Service
(Years) M F Total (%) M F Total (%) M F Total (%)
>30 124 80 204 1.59 50 58 108 0.90 63 63 127 1.07
25 – 30 584 142 726 5.65 642 179 821 6.82 533 218 751 6.33
20 – 25 - - - - 129 21 150 1.25 332 43 375 3.16
15 – 20 213 306 519 4.04 112 231 343 2.85 109 232 341 2.88
10 – 15 1,473 1,519 2,992 23.29 1,046 1,345 2,391 19.85 749 1,008 1,757 14.82
5 – 10 2,733 2,043 4,776 37.18 2,672 1,758 4,430 36.78 2,377 1,653 4,030 33.98
0–5 1,1433 2,197 3,630 28.26 1,637 2,165 3,802 31.56 2,097 2,381 4,478 37.76
Jumlah 6,560 6,287 12,847 100.00 6,288 5,757 12,045 100.00 6,261 5,598 11,859 100.00
*M= Male/ F= Female
**Excluding Directors and SEVPs
From the series of tables above, several key points can discrimination. Through this policy, BTN ensures that
be observed: First, the ratio of male to female employees all employees are fairly compensated according to
is quite balanced, indicating no gender discrimination their contributions, regardless of gender. Additionally,
in the recruitment process. Next, the data shows that the BTN ensures that all employees work within the hours
Bank does not employ individuals below the minimum stipulated in their employment contracts and provides
age as regulated, that means means BTN complies with overtime compensation by job level for employees who
labor regulations and ensures no child labor is involved work beyond the set hours. These policies demonstrate
in its operations. Third, BTN establishes no difference in BTN’s commitment to creating a fair, inclusive work
the base salary and remuneration ratio between male environment aligned with the principles of equality. [GRI
and female employees as part of its commitment 3-3, 405-1, 406-1, 408-1, 409-1] [OJK F.19]
to applying the principles of equal pay and anti-
Respectful Workplace Policy
BTN has established guidelines to create a safe work inclusion. This includes avoiding all forms of
environment that respects and protects human differentiation, marginalization, restriction, and/
dignity, emphasizes mutual respect, and is free from or exclusion, whether directly or indirectly. The
discrimination, exclusion, harassment, and physical or mentioned discriminatory actions can be based
mental violence for all employees and stakeholders. on various factors such as religion, ethnicity,
These guidelines are outlined in Special Policy Number race, group, social class, and social status,
KK.3-C, on Employment Regulations and Administration. including marital status, economic status, gender,
The primary aim of this policy is to create an inclusive, language, political preferences, and disabilities.
conducive, and productive work environment that All forms of discrimination can negatively impact
promotes the Bank’s sustainability and upholds human or even eliminate the recognition of individuals’
rights. To achieve this, the policy includes preventive human rights and fundamental freedoms. As a
measures designed to avoid various issues related to result, it may create inequality in opportunities and
unfair treatment or employee harm, covering: differential treatment toward specific individuals
1. Discrimination or groups within the Bank’s activities. Therefore,
BTN is fully committed to implementing an anti- BTN is committed to avoiding all forms of injustice
discrimination policy by adopting principles, in social interactions and all activities involving
policies, and practices of diversity and gender employees in the workplace.
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2. Violence actions may pose serious risks to employee
Acts of violence include any actions, behaviors, or safety, health, and well-being, both physically and
conduct that involve threats, coercion, violence, or mentally.
arbitrary deprivation of another person’s rights in
the workplace. These actions may occur publicly or BTN launched a series of webinars in 2024 on Respectful
privately and can result in physical, psychological, Workplace Policy as part of the Bank’s commitment to
sexual, or economic harm or damage to the fostering mutual respect in the workplace. This policy
targeted individual. Such behavior has the ensures that everyone at BTN, including the Board of
potential to create an unsafe work environment Commissioners, the Board of Directors, and employees,
and negatively affect employee well-being. contributes to creating a dynamic, friendly, productive,
and discrimination-free work environment, free from
3. Harassment violence and harassment. The policy seeks to establish
Harassment encompasses any attitudes, words, an inclusive workplace atmosphere, value differences,
actions, behaviors, or gestures that occur directly in and equality, and uphold human rights. In doing so, BTN
the workplace or through various communication encourages performance, growth, and sustainability
channels contrary to laws or regulations related through:
to human rights. This behavior is typically aimed 1. Appreciating and respecting diversity in the
at intimidating or adversely affecting the physical, workplace, which compromises individuals
psychological/mental, sexual, or economic from various ethnic, racial, national, skin color,
aspects of the victim. Its impacts may cause age, religion, gender, disability, and individual
someone to feel threatened, humiliated, offended, characteristic backgrounds, to create a productive
degraded, or embarrassed, creating a sense work atmosphere.
of insecurity or stress in the work environment. 2. Ensure that every Bank employee is treated equally,
Consequently, individuals who experience such regardless of their characteristics, and has fair
behavior may struggle to perform their duties and equal access to facilities and infrastructure.
and feel they are working in an unconducive or
unsupportive atmosphere. Furthermore, such
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Management
3. Creating and fostering a respectful work All BTN policies have a positive impact. This achievement
environment free from discrimination, violence, or is evidenced by the absence of incidents or reports
harassment. related to discrimination, human rights, or forced labor
during this reporting year. [GRI 3-3, 405-1, 406-1, 408-1, 409-1] [OJK
F.19]
General Banking Throughout the reporting year, BTN successfully organized the
General Banking Staff Training program, involving 622 participants
Staff Training by divided into 8 batches. The training was attended by various
Applying Diversity, participants, including fresh graduates and/or individuals with
Equity, and Inclusion work experience in the banking sector. Through this program, BTN
also provided equal opportunities for individuals with disabilities
Principles to participate in the General Banking Staff Training program as
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part of its commitment to applying Diversity, Equity, and Inclusion
(DEI) principles. These principles ensure that every individual,
regardless of background or physical condition, has the same
rights to contribute to the Bank’s progress and sustainability. In this
way, BTN not only prioritizes employee competency development
but also creates an inclusive and equitable work environment.
Recruitment of New Employees and Employee [GRI 401-1]
To meet workforce needs, BTN conducts recruitment 2. Candidate Assessment
through two channels: internal and external. The This process may consist of one or several
internal channel includes recruiting and selecting methods, including but not limited to:
employees who meet specific criteria and are ready • Speed dating interview, brief interviews with
to fill certain positions. Meanwhile, external recruitment candidates
involves candidates who may be pre-graduates, fresh • Paper-based test, written questions related to
graduates, or individuals with professional experience psychometrics, scholastics, knowledge, and/or
(experienced & professional hires). BTN prioritizes local specific skills
employees, namely those of Indonesian nationality. All • Skills-based approaches, validation of
employees, including senior management, are part of candidates’ skills through demonstrations or
the local community. Additionally, BTN has targeted presentations of their knowledge or abilities
recruitment initiatives for vulnerable groups such • Gamification, selection in the form of game
as women, minorities, indigenous communities, and simulations to assess candidate alignment
persons with disabilities. with the Bank’s required values
• Competency/hackathons, competition skills
To support this policy, BTN refers to Special Policy relevant to the Bank’s needs
Number KK.3-A on Human Capital Cycles states that • Job audition, candidates complete specific
the selection process must include clear and structured projects assigned by the Bank
stages to ensure recruitment is conducted fairly, • Case study, candidates solve case studies
transparently, and by applicable standards. The stages based on their capabilities
are as follows: [GRI 3-3, 202-2] • Pre-employee screening, profile screening
1. Application Screening based on the Know Your Employee (KYE)
Applications are managed, structured, and principle to mitigate operational risks
straightforward, enabling candidates to
navigate the recruitment process efficiently. The BTN has a specific mechanism for appointing new
requirements for this stage include: employees as permanent staff. New employees who
• Fulfillment of criteria pass the selection stages and are appointed permanent
• Completeness of documents employees receive remuneration by applicable
• Verification of application data authenticity labor regulations. BTN also encourages persons with
disabilities to participate in its recruitment programs as
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Management
part of an initiative under the Ministry of SOEs through recruitment reached 1,231 employees, reflecting BTN’s
the Forum Human Capital Indonesia (FHCI). commitment to providing career opportunities and
strengthening organizational capacity to face business
Employee Recruitment and Turnover challenges while creating positive societal impacts. For
2025, BTN has set a recruitment target of 618 employees.
In 2024, BTN aimed to recruit 1,000 employees as part Below is the data for new employees recruited through
of its human resource development strategy to support the Human Capital Management Unit:
long-term growth and sustainability. By year-end, the
Composition of New Employees by Age Group and Gender [GRI 401-1]
2024 2023 2022
Age Group
M F Total M F Total M F Total
≥ 51 4 0 4 1 2 3 2 1 3
31 – 50 20 16 36 22 8 30 44 10 54
≤ 30 463 728 1,191 237 425 662 368 649 1,107
Subtotal 487 744 1,231 260 435 695 414 660 1,074
*M=Male/ F=Female
Composition of New Employees by Work Area and Gender [GRI 401-1]
2024 2023 2022
Work Area
M F Total M F Total M F Total
Headquarters 135 134 269 70 75 145 135 194 329
Regional Office 13 8 21 8 1 9 3 10 13
Branch Office 339 602 831 182 359 541 276 456 732
Subtotal 487 744 1,231 260 435 695 414 660 1,074
*M=Male/ F=Female
The workforce also decreases due to retirement, Policy Number KK.3-A on the Human Capital Cycle. This
resignations, contract expiration, death, and other policy includes clear procedures for handling various
reasons. BTN manages employee termination termination situations to ensure smooth operational
processes based on the guidelines outlined in Special activities and fair processes for all employees.
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Employee Turnover Rate [GRI 401-1]
Description 2024 2023 2022
Total New Employees 1.231 695 1.074
Total Employees Leaving 164 187 246
Total Employees at Year Start 12.045 11.745 11.192
Total Employees at Year End 12.847 12.045 11.859
Turnover Rate (%) 1.27% 1.55% 2.07%
Employee Turnover Composition by Age Group and Gender [GRI 401-1]
2024 2023 2022
Age Group
M F Total M F Total M F Total
≥ 51 6 1 7 5 2 7 4 2 6
31 – 50 24 34 58 43 55 98 27 52 79
≤ 30 28 71 99 25 57 82 75 86 161
Subtotal 58 106 164 73 114 187 106 140 246
*M=Male/ F=Female
Employee Turnover Composition by Work Area and Gender [GRI 401-1]
2024 2023 2022
Work Area
M F Total M F Total M F Total
Headquarters 20 16 36 21 21 42 34 22 56
Regional Office 4 1 5 3 2 5 4 - 4
Branch Office 34 89 133 49 91 140 68 118 186
Subtotal 58 106 164 73 114 187 106 140 246
*M=Male/ F=Female
Enhancing Workforce Diversity
To enhance workforce diversity, BTN has established the foundation for BTN’s commitment to creating an
equal employment opportunity and gender diversity inclusive work environment. The policy is fully supported
policies outlined in Special Policy Number KK.3-C on by BTN’s board of directors through direct oversight to
Personnel Regulations and Administration. This is ensure its integration into all business processes and
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Sustainable Environmental and Welfare Support
About The Report BTN Profile
Management
operations. BTN has set long-term recruitment targets 16 TKPD candidates who passed the selection process,
as part of this commitment, including hiring employees surpassing the initial target of 10. The demographics of
with disabilities (TKPD). In 2024, BTN successfully recruited BTN’s TKPD employees for 2024 are as follows:
Composition of Employees with Disabilities (TKPD)
Employees with Disabilities Total Employees Percentage of
(TKPD) TKPD
male 11 6.560 0,17%
female 12 6.287 0,19%
Diversity Recruitment
Goals
As part of its sustainability commitment, BTN has
set quantitative diversity targets in recruitment,
with the goal of having 0.5% of new employees from
underrepresented groups by 2025, 1% by 2026, and
2% by 2028. These targets include individuals with
disabilities and other underrepresented groups,
in line with the Bank’s efforts to create a more
inclusive and diverse work environment.
To support this diversity, BTN provides various facilities they have a shared understanding and can
to meet the needs of individuals from different contribute optimally in the workplace.
backgrounds. Some steps include inclusive training, 2. Inclusive Management Training for Managers:
infrastructure adjustments to create an accessible Aimed at increasing awareness and applying
work environment, and mentoring programs to ensure diversity principles within teams.
career success for employees from these groups. BTN 3. Periodic Assessments of Diversity Targets: Involves
has launched several programs aimed at accelerating transparent monitoring and cross-functional
diversity implementation through various initiatives: collaboration.
1. Induction Training for All New TKPD Employees: This
training covers product knowledge, the Code of BTN is committed to providing equal opportunities
Conduct, banking business processes, rights and for individuals with disabilities to contribute to the
responsibilities, and company culture, ensuring company’s operations by adjusting tasks and
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responsibilities to individual skill levels. Recruitment Through these steps, BTN aims to create an inclusive
programs for employees with disabilities are carried workplace where every individual from diverse
out through regular channels, as well as the annual backgrounds has equal opportunities to grow and
Joint Recruitment Initiative by FHCI BUMN. As part contribute their best.
of its inclusion efforts, BTN collaborates with various
foundations, associations, and disability communities
to ensure that individuals with disabilities have broader
access to employment opportunities at the Bank.
Employee Training on Diversity
To enhance workforce diversity, BTN implements a The BTN Board of Directors fully supports this program
strategy that includes training and socialization for through direct oversight by top management to ensure
all employees, from junior staff to senior executive that the diversity policy is integrated into every aspect
vice presidents, to ensure the understanding and of the Company’s business and operational processes.
implementing of these principles across the organization. The main objective is to create an inclusive, respectful
As part of this initiative, BTN organizes training sessions work environment while reinforcing the values of
with external speakers to instill the principles of diversity, diversity within the Company. Below are some of the
equality, and inclusion. This training aims to ensure training sessions conducted:
the effective implementation of these principles at all
organizational levels.
Number of
Training Name Month Method Employees
Attending
KPMG Ethicsline Seminar: Establishing a February Classroom / Virtual 2
Respectful Workplace Environment Classroom
Internalization of Respectful Workplace (RWP) March Online / Self Learning 10,974
2024
Expert Talk Session: "Empowering Women in April Classroom / Virtual 212
Leadership with Purpose and Impact" Classroom
CHRO Masterclass - Women Leadership in the May Classroom / Virtual 10
New World of Work Classroom
Indonesia Women Leaders' Forum 2024 May Classroom / Virtual 4
Classroom
SOE Women Leadership Program June Classroom / Virtual 1
Classroom
Empowering the Future Workforce: Innovation, September Classroom / Virtual 1
Resilience & Employee Well-being to make a Classroom
Respectful Workplace
OJK Webinar "Empowering Leadership: How October Classroom / Virtual 34
Women Leaders Drive Company and Institution Classroom
Performance"
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Employee Development
Sustainable Environmental and Welfare Support
About The Report BTN Profile
Management
Learning and Competency Development
In human resource management, competency themselves to perform tasks more effectively, be
development, both in technical skills (hard skills) and prepared for change, and prepare for higher positions.
non-technical skills (soft skills), is a crucial element. To support competency development, BTN applies a
Efforts to develop competencies are also outlined in systematic approach through the concept of analysis,
Special Policy Number KK.3-A regarding the Human design, development, implementation, and evaluation
Capital Cycle. This policy emphasizes that employees (ADDIE), which allows for the design and implementation
must continuously develop competencies to perform of measurable development programs. Learning
their work more effectively and efficiently. Of course, management is also aligned with the Bank’s job and
the Bank provides training and development based on business needs using the 70:20:10 approach, where 70%
each employee’s role and responsibilities. Furthermore, of learning is obtained through practical experience,
competency development is also intended to prepare 20% from interactions with others, and 10% from formal
employees to face potential challenges and changes in education.
the workforce and prepare them for higher or strategic
positions. BTN also firmly upholds the principle of equality BTN runs an ongoing human resources development
to ensure that all employees, both men and women, program to meet the growing competency and
have equal opportunities to learn and develop their expertise needs. This program is designed with various
competencies. Therefore, human capital management approaches, including education, training, special
focuses on improving technical skills and developing assignments, and transfer and promotion programs.
character and interpersonal abilities necessary to face All these efforts aim to enhance employees’ skills and
career challenges and opportunities in the future. [GRI 3-3] experience to adapt to changes and increasingly
complex job demands. The following table provides
To support competency development, BTN has program detailed information on the distribution of program
focuses on three main elements: knowledge, skills, and implementation from January to December 2024 at
attitude. By making the Bank a learning organization, various levels within the organization.
BTN encourages employees to continuously improve
Employee Talent Development Strategy
In 2024, BTN reaffirmed its commitment to talent and expertise in relevant fields. As part of this
development through strategic initiatives by commitment, BTN has also partnered with several
collaborating with third parties to support employee leading universities, both domestically, such as the
competency development. In addition to enhancing University of Indonesia (UI), Master of Management
competencies, innovation, and creativity, external at Gadjah Mada University (MM UGM), and the
development also broadens professional networks, School of Business and Management at Bandung
meets standards and regulations, and increases Institute of Technology (SBM ITB), as well as
knowledge of industry developments. Below are the internationally such as: The University of Sydney,
strategies and programs implemented by the Bank for Monash University, International Institute of
employee development in 2024: Management Development (IMD), The University
1. Employee Scholarship Program of Melbourne, The University of Edinburgh, serta
BTN has an outstanding scholarship program open University of Bistol.BTN hopes to provide quality
to all employees to support the development of education access through this collaboration for
human resources competencies and capacities. employees who wish to further their development.
This scholarship is aimed at undergraduate and Below is data on employees who received
postgraduate programs, both domestic and scholarships:
abroad, to broaden employees’ perspectives
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Implementation of the Employee Scholarship Program
2023 2024
2023 9
14 39
Undergraduate
Scholarships
2024 16
Domestic 2023 2
Postgraduate
Scholarships 2024 10
Growth
179%
International 2023 3
Postgraduate
Scholarships 2024 13
2. Human Resource Capability Development 4. Certification
BTN is committed to continuously developing To support formal recognition of employee
human resource capabilities through advanced competencies, BTN collaborates with
training programs and leadership development. professional certification bodies, including
In this regard, BTN collaborates with several the Risk Management Certification Agency
leading institutions. These collaborations aim (BSMR), the Banking Professional Certification
to provide training relevant to industry needs Institute (LSPP), the Islamic Finance Professional
while sharpening leadership skills to prepare Certification Institute (LSP KS), the Indonesian
employees for increasingly complex challenges Capital Market Financial Industry Professional
in the banking sector. With the support of these Certification Institute (LSP IKEPAMI), and the ACI
institutions, BTN ensures employees gain quality Financial Markets Association (ACIFMA). Through
learning experiences and continuously improve these certifications, BTN provides employees the
their competencies through structured and opportunity to validate their professional abilities
practical programs. in line with industry standards, thus enhancing the
overall quality of human resources to meet the
3. BUMN School of Excellence dynamics of the financial industry.
BTN plays an active role in the BUMN School
of Excellence program, which aims to prepare The Bank monitors and evaluates these programs
employees as potential candidates for future regularly through the senior management team to
Directors. This program is designed to identify and ensure their effectiveness and alignment with the
develop the best potential among BTN employees, Company’s business strategy. With this initiative, BTN
allowing them to attend intensive leadership aims to build a strong and sustainable talent pipeline,
training and development. Through participation which will be the foundation for the Company’s
in this program, BTN ensures that employees growth and sustainability in the future. This effort
are technically prepared and possess strong also represents BTN’s contribution to supporting the
leadership capacities to lead the Company. Sustainable Development Goals (SDGs), particularly in
quality education, decent work, and economic growth.
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Sustainable Environmental and Welfare Support
About The Report BTN Profile
Management
Synergy in Preparing Competent Human Resources
in the Digital Era
As part of its commitment to enhancing human particularly in the banking and property sectors.
resources (HR) quality and supporting the This collaboration supports BTN’s mission to
sustainable housing sector, BTN is also actively “Become the Home for Indonesia’s Best Talents”
engaged in providing literacy to students through while also contributing to the achievement of the
public lectures on addressing the economic and target of building three million houses annually.
digital disruptions currently taking place. In 2024, BTN also provides banking services to advance
these literacy activities were conducted at several education, including tuition fee payments,
universities, including Bina Nusantara University internships for students, public lectures, and other
(Binus), Semarang State University (Unnes), collaborations. Through this partnership, BTN
Andalas University (Unand), Tanjungpura University has supported the provision and use of banking
(Untan), HKBP Nommensen University (UHN), and services and contributed to the development
Islamic University of Indonesia (UII). of the academic community. This strategic
move reaffirms BTN’s commitment to building
During the same event, a Memorandum of superior human resources that will support the
Understanding (MoU) was signed, marking a development of a sustainable housing sector,
strategic step for BTN to expand its involvement contributing to Indonesia’s Golden Years in 2045.
in the development of Indonesia’s young talent,
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Competency Development Based on Job Level [GRI 2-17, 404-2] [OJK E.2, F.22] [FS4]
Board of Commissioners Competency Development
Throughout this reporting year, BTN’s Board of conferences, and seminars related to ESG aspects, as
Commissioners has participated in various competency outlined in the following table.
enhancement programs, including training, workshops,
Training Attended by the Board of Commissioners
Type of Training and
Name Position Competency Development Date and Location Organizer
Material
Chandra M. President Risk Management Certification January 27, 2024 Bogor Indonesian Banking
Hamzah Commissioner / Training– Indonesian National Development Institute
Independent Qualification Framework (KKNI) (LPPI)
Level 6
Risk Management Certification June 27–28, 2024 Jakarta Indonesia Risk
Alignment – KKNI Level 6 Professional
Association (IRPA)
ASEAN Global Leadership Program November 4–8, 2024 SRW&Co
– CGKSB Beijing
Iqbal Latanro Vice President Risk Management Certification January 27, 2024 Bogor LPPI
Commissioner / Training – KKNI Level 6
Independent
SMR Alignment – KKNI Level 7 June 11–12, 2024 Jakarta Indonesia Risk
Professional
Association (IRPA)
Armand B. Independent Risk Management Certification January 27, 2024 Bogor LPPI
Arief Commissioner Training – KKNI Level 6
Risk Management Certification June 27–28, 2024 Jakarta IRPA
Alignment – KKNI Level 6
Executive Risk Management February 23 – March 3, LPPI
Refresher Program Batch 5: ESG & 2024 Europe (Vienna,
Business Sustainability Budapest, Prague)
Risk Management Certification March 19, 2024 Jakarta LSPP
Competency Assessment – KKNI
Level 6
ASEAN Global Leadership Program 4 - 8 November 2024, SRW& Co
- CGKSB Beijing
Sentot A. Independent Risk Management Certification January 27, 2024 Bogor LPPI
Sentausa Commissioner Training – KKNI Level 6
Executive Risk Management February 23 – March 3, LPPI
Refresher Program Batch 5: ESG & 2024 Europe (Vienna,
Business Sustainability Budapest, Prague)
Risk Management Certification March 19, 2024 Jakarta LSPP
Competency Assessment – KKNI
Level 6
Risk Management Certification May 21–22, 2024 Jakarta IRPA
Alignment – KKNI Level 7
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Employee Development
Sustainable Environmental and Welfare Support
About The Report BTN Profile
Management
Type of Training and
Name Position Competency Development Date and Location Organizer
Material
Andin Commissioner Risk Management Certification January 27, 2024 Bogor LPPI
Hadiyanto Training – KKNI Level 6
Risk Management Certification June 27–28, 2024 Jakarta IRPA
Alignment – KKNI Level 6
Herry Commissioner Risk Management Certification January 27, 2024 Bogor LPPI
Trisaputra Training – KKNI Level 6
Zuna
Risk Management Certification July 18, 2024 Jakarta BSMR
Competency Assessment – KKNI
Level 4
Risk Management Certification July 23 – 25, 2024 Jakarta IRPA
Alignment –KKNI Level 6
Risk Management Certification August 17, 2024 Bogor LPPI
Training – KKNI Level 6
Himawan Arief Commissioner Risk Management Certification January 27, 2024 Bogor LPPI
Sugoto Training – KKNI Level 6
Risk Management Certification July 18, 2024 Jakarta BSMR
Competency Assessment – KKNI
Level 4
Risk Management Certification July 23 – 25, 2024 Jakarta IRPA
Alignment –KKNI Level 6
Risk Management Certification August 17, 2024 Bogor LPPI
Training – KKNI Level 6
ASEAN Global Leadership Program 4 - 8 November 2024, SRW&Co
- CGKSB Beijing
Adi Independent Risk Management Certification May 14, 2024 Jakarta PT Garda Multi Talenta
Sulistyowati Commissioner Training – KKNI Level 7
Risk Management Certification June 7, 2024 Jakarta LPPI
Competency Assessment – KKNI
Level 7
Risk Management Certification June 11 – 12, 2024 Jakarta IRPA
Alignment – KKNI Level 7
Bambang Independent Risk Management Certification May 6, 2024 Bogor LPPI
Widjanarko Commissioner Training – KKNI Level 6
Risk Management Certification May 23 – 25, 2024 Jakarta IRPA
Alignment – KKNI Level 6
Board of Directors Competency Development
Throughout 2024, BTN’s Board of Directors members and seminars related to ESG aspects, as outlined in the
have participated in various competency enhancement following table.
programs, including training, workshops, conferences,
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Training Attended by the Board of Directors
Type of Training and
Name Position Competency Development Date and Location Organizer
Material
Nixon L.P. President Director Risk Management Certification May 15–16, 2024 Jakarta IRPA
Napitupulu Alignment – KKNI Level 7
Executive Course on Strategic July 3–16, 2024 Jakarta Defense University
Management and Leadership of Indonesia
Cohort
Global Leadership Program by September 2–6, 2024 SRW&Co - IESE
SRW&Co – IESE Business School Barcelona, Spain Business School
Oni Febriarto Vice President Risk Management Certification February 7, 2024 Jakarta PT Garda Multi
Rahardjo Director Refreshment – KKNI Level 7 Talenta
Strategic Decision-Making for October 7–9, 2024 Cambridge Judge
Leaders Cambridge, United Kingdom Business School
Andi Nirwoto Director of Risk Management Certification February 7, 2024 Jakarta PT Garda Multi
Information Refreshment – KKNI Level 7 Talenta
Technology
Elisabeth Director of Assets Risk Management Certification January 27, 2024 Jakarta PT Garda Multi
Novie Riswanti Management Refreshment – KKNI Level 7 Talenta
Executive Risk Management November 9–18, 2024 Milan, La LPPI
Program – Europe Spezia, Rome, Italy
Jasmin Director of Risk Management Certification February 7, 2024 Jakarta PT Garda Multi
Distribution & Refreshment – KKNI Level 7 Talenta
Institutional
Risk Management Certification May 15 – 16, 2024 Jakarta IRPA
Funding
Alignment – KKNI Level 7
Strategic Decision-Making for October 7–9, 2024 Cambridge Judge
Leaders Cambridge, United Kingdom Business School
Hirwandi Director of Risk Management Certification January 12, 2024 Jakarta PT Garda Multi
Gafar Consumer Refreshment – KKNI Level 7 Talenta
Banking
Risk Management Certification May 12 – 13, 2024 Jakarta IRPA
Alignment – KKNI Level 7
Executive Risk Management November 9–18, 2024 Milan, La LPPI
Program – Europe Spezia, Rome, Italy
Setiyo Wibowo Director of Risk Risk Management Certification February 7, 2024 Jakarta PT Garda Multi
Management Refreshment – KKNI Level 7 Talenta
Ideas Asia Pacific by UID-MIT Sloan March 21, 2024 Manila, Unity in Diversity
Philippines
Ideas Asia Pacific 2024 – “Co- April 23–26, 2024 Boston, USA UID Bali
Initiating Module Orientation
Workshop”
Ideas Asia Pacific – MIT Sloan June 10–14, 2024 Cambridge, MIT Sloan Business
Business School Massachusetts, USA School
Ideas Asia Pacific - in person August 7 – 12, 2024 Bali UID Bali - MIT Sloan
workshop - DEEP DIVE MODULE USA
Risk Management Certification September 4 – 5, 2024 IRPA
Alignment – KKNI Level 7 Jakarta
Nofry Rony Director of Risk Management Certification February 24, 2024 Jakarta PT Garda Multi
Poetra Finance Refreshment – KKNI Level 7 Talenta
Risk Management Certification May 15 – 16, 2024 Jakarta IRPA
Alignment – KKNI Level 7
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Employee Development
Sustainable Environmental and Welfare Support
About The Report BTN Profile
Management
Type of Training and
Name Position Competency Development Date and Location Organizer
Material
Eko Waluyo Director of HC Certification Assessment – March 22, 2024 Jakarta Forum Human
Human Capital, Director of HR Scheme Capital Indonesia
Compliance & (FHCI)
Legal
Risk Management Certification March 27–28, 2024 Jakarta IRPA
Alignment – KKNI Level 7
Risk Management Certification March 28, 2024 Jakarta LPPI
Competency Assessment – KKNI
Level 7
Seminar: "Investment Funds and April 25, 2024 Jakarta Indonesian Pension
Pension in Addressing Interest Rate Fund Association
Dynamics"
Empowering the Future Workforce: September 19–20, 2024 Bali Forum Human
Innovation, Resilience & Employee Capital Indonesia
Well-being to Foster a Respectful (FHCI)
Workplace
Hakim Director of Risk Management Certification February 24, 2024 Jakarta PT Garda Multi
Putratama Operations Refreshment – KKNI Level 7 Talenta
& Customer
Risk Management Certification May 15 – 16, 2024 Jakarta IRPA
Experience
Alignment – KKNI Level 7
Muhammad Director of SME & Leading with Finance – Harvard May 15–26, 2024 Jakarta Harvard Business
Iqbal Retail Funding Business School School
Corporate Governance Program: September 10–13, 2024 New Columbia Business
Developing Exceptional Board York City, USA School
Leaders
Employee Competency Development
BTN has provided training and development programs the Company’s operations. Throughout 2024, BTN
for all employees, including permanent staff, contract employees have participated in various competency
employees, part-time workers, and outsourced enhancement programs, including training sessions,
personnel. With this inclusive approach, Bank BTN workshops, conferences, and seminars related to ESG
aims to foster a work culture that supports continuous aspects. Below is a list of training programs attended
development for all workforce members involved in by employees:
ESG Training Attended by Employees
Jumlah
No. Training Name Month Method
Peserta
1 Aligning Strategy Execution with ESG April Classroom Training 7
2 Certified Anti-Fraud & Legal (CAFP) February Classroom Training 1
3 Climate Risk Integration in the Banking October Classroom Training 3
4 Financial & Capital Market Based on ESG May Classroom Training 29
5 Internalization of ESG (Environment, Social & May Classroom Training 11,448
Governance) Awareness
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Jumlah
No. Training Name Month Method
Peserta
6 Internalization of APUPPT & PPPSPM January, February, Classroom Training 221
Management June
7 National Anti-Fraud Conference September Classroom Training 3
8 Training on APU, PPT & PPPSPM January, May Classroom Training 431
9 ESG Audit Training February Classroom Training 62
10 Workshop on Internal Auditor Professional February Classroom Training 26
Standards and Code of Conduct
11 Climate Risk Stress Test Training August Classroom Training 17
12 Premium ESG Investment Training August Classroom Training 1
13 APUPPT & PPPSPM Refreshment August Classroom Training 266
14 Refreshment Program for High-Risk August Self-Learning 261
Customers' APU, PPT, and PPPSPM
15 Anti-Corruption Facilitator Certification September Classroom Training 37
(PAKSI)
16 Digital Risk Awareness & Cyber Trend October Self-Learning 7,361
Socialization
17 Webinar: "Climate Risk Awareness & GHG" August Classroom Training 297
18 OJK Webinar: "Personal Data Protection" May Classroom Training 59
19 Personal Data Workshop (ROPA) June Classroom Training 67
20 Cyber Security Management Workshop May Classroom Training 1
Number of Employees Receiving Training by Employment Status
Description 2024 2023 2022
Permanent Employees 12,699 11,270 10,628
Contract Employees 148 775 1,026
Total Employees 12,847 12,045 11,654
Job-Specific Development Programs
In addition to supporting general competency and specific positions. As flagship initiatives, these programs
performance development, BTN is committed to aim to produce professionals who are not only
providing training programs tailored for specific job competent but also adaptable to the rapidly evolving
functions. These job-specific development programs industry.
are an integral part of the Bank’s strategy to create skilled
human resources capable of tackling the increasingly In 2024, BTN introduced 418 virtual training programs
complex challenges of the industry and contributing covering business, credit risk, leadership, and sales
maximally to achieving the Bank’s objectives. These and service. This initiative ensures all employees can
programs enhance technical skills and knowledge access technical, managerial, and technology-based
relevant to employees’ tasks and responsibilities in innovation training tailored to their needs.
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Employee Development
Sustainable Environmental and Welfare Support
About The Report BTN Profile
Management
Implementation of the Specific Job Development Program
Number of
Number of Training
Training Training Method
Participants Hours
Types
Commercial Banking Academy 30 2,838 Face-to-face & Virtual Classroom 34,008
Consumer Banking Academy 70 7,618 Face-to-face & Virtual Classroom 142,232
GRC Academy 76 7,936 Face-to-face & Virtual Classroom 94,756
IT & Digital Academy 20 113 Face-to-face & Virtual Classroom 3,432
Leadership Academy 51 2,090 Face-to-face & Virtual Classroom 35,548
Operations & Finance Academy 96 7,652 Face-to-face & Virtual Classroom 116,916
Sharia Business Academy 55 359 Face-to-face & Virtual Classroom 40,392
Treasury & Capital Market Academy 14 359 Face-to-face & Virtual Classroom 3,016
Wholesale Banking Academy 1 21 Face-to-face & Virtual Classroom 504
BTN also provides employee certifications as part of development while enhancing the Company’s
its efforts to support competency development in competitiveness in addressing industry challenges.
specific job fields. By offering relevant certifications, Below are the types of certifications held by BTN
BTN is committed to facilitating employees’ career employees in the banking sector:
Number of Employee Certification Types by Banking Sector
Certification 2024 2023
Risk Management System (SMR) Certification 3,297 2,555
Mutual Fund Selling Agent Representative (WAPERD) Certification 175 110
Treasury Certification 40 40
Competency Development Budget
Competency development remains one of BTN’s focal efficiency without compromising the programs’
points. In 2024, the Bank allocated a larger budget quality and effectiveness. BTN focuses on technical
for employee competency development, reflecting a competency development through this strategy and
10% increase compared to 2023. To optimize training ensures employees are equipped to meet future
implementation, BTN adopts a blended learning Further details on the budget allocated for employee
approach that combines various methods, such as competency development can be found in the following
online learning, virtual classes, and self-learning. table.
This approach aims to enhance educational delivery
Total and Growth of Competency Development Costs
Competency Development Costs (in Rp million) Growth
2024 2023 in Rp million in percent
105,530 95,928 9,602 10%
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Education and Training Hours by Gender [GRI 404-1]
2024 2023 2022
Description
Male Female Male Female Male Female
Total Employees 6,560 6,287 6,288 5,757 6,396 5,727
Total Participants in Training
16,941 15,630 17,342 14,086 15,842 13,607
and Education
Total Training and Education
344,376 322,746 393,096 349,610 342,379 313,909
Hours
Average Training and
Education Hours per 20.33 20.65 22.67 24.82 21.61 23.07
Participant
Average Training and
Education Hours per 52.50 51.34 65.52 60.73 53.53 54.81
Employee
Total Participants in
32,571 31,428 29,449
Training and Education
Percentage of employees
who receive education and 100% 100% 100%
training
Total Training and
667,122 742,706 656,288
Education Hours
In 2024, self-learning through LinkedIn Learning is more as the modules consist of short videos, making each
intensive than face-to-face or two-way virtual learning, course only take one hour.
Number and Average Training Hours of Employees by Job Level [GRI 404-1]
2024 2023 2022
Job Level Total Average Total Average Total Average
Number of Number of Number of
Training Training Training Training Training Training
Participants Participants Participants
Hours Hours Hours Hours Hours Hours
Level 5B (22) 20 386 19 13 290 22 13 250 19
Level 4C-5A
482 8,244 17 599 13,874 23 438 5,626 13
(19-21)
Level 3C-4B
5,786 96,066 17 5,792 111,066 19 4,424 79,743 18
(15-18)
Level 3A-3B
8,676 164,066 19 9,061 317,128 35 9,088 183,582 20
(13-14)
Level 2D-2F
13,020 280,402 22 12,395 234,147 19 11,961 310,976 26
(11-12)
Level 2A-2C
4,587 118,002 26 3,568 66,201 19 3,449 75,048 22
(8-10)
22= Executive Vice President 18= Assistant Vice President 14= Assistant Manager 10= Staff
21= Senior Vice President 17= Senior Manager 13= Assistant Manager 9= Staff
20= Vice President 16= Manager 12= Senior Staff 8= Junior Staff
19= Vice President 15= Manager 11= Senior Staff
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Employee Development
Sustainable Environmental and Welfare Support
About The Report BTN Profile
Management
The Bank’s commitment to developing outstanding responsive workforce tailored to the needs and
human resources goes beyond education and training developments in the banking industry. Additionally, BTN
programs. Selected permanent employees are also ensures that training is provided for active employees
given opportunities to pursue higher education. This and those nearing retirement. Training programs aim
initiative is implemented in line with General Human to equip employees preparing for retirement with the
Capital Policy KU.3 on Learning and Development skills and readiness to transition into a productive and
Management, designed to enhance employee meaningful post-retirement phase. [GRI 404-2]
competencies and create a skilled, resilient, and
BUMN Learning Festival 2024
BTN hosted the 2024 BUMN Learning Festival
(BLF) grand event with the theme “Be Agile, Be a
Lifelong Learner,” held at Menara BTN. This event
encouraged sustainable practices through
learning, skill enhancement, and adaptation
to the latest business trends. Over 116 BUMNs
participated, with a total of 2,500 attendees. The
event also featured digital learning exhibitions
from each BUMN.
improve living standards and contribute Rp2.46
The BLF reflects BTN’s commitment to developing trillion to Indonesia’s economy.
exceptional human resources grounded in the
strong foundation of AKHLAK (Accountable, BLF 2024 also reinforced the importance of investing
Knowledgeable, Harmonious, Adaptive, Kinship). in personal development as a sustainable effort
During the event, BTN emphasized the importance to create resilient human resources capable of
of quality human resources in supporting the facing VUCA (Volatility, Uncertainty, Complexity,
housing sector—one of the nation’s strategic Ambiguity) challenges. With the commitment
programs—while also contributing positively to to becoming Super Learners, employees are
the national economy. Research by BTN’s Housing expected to contribute to achieving Indonesia
Finance Center highlights that housing loans Emas Vision 2045.
LinkedIn Top Companies 2024
BTN’s success in developing human resources is reflected in winning the LinkedIn Talent Awards and ranking
3rd in the LinkedIn Top Companies 2024. This award positions BTN as one of the best career development
platforms in Indonesia and solidifies the Bank’s commitment to building an adaptive and sustainable
development ecosystem.
BTN’s human capital development strategy focuses on strengthening employee competencies through
technology and globally standardized learning platforms. The Bank also implements various leadership
development programs, such as the Leadership Development Program across multiple levels, and
strategic partnerships like the ASEAN Global Leadership Program (AGLP), which provide BTN leaders with a
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global leadership perspective.
As a state-owned bank (BUMN) with a critical role in Indonesia’s
economy, BTN ensures that its human capital development aligns
with the core values of BUMN: AKHLAK (Trustworthy, Competent,
Harmonious, Loyal, Adaptive, and Collaborative). The application of
these values serves as the foundation for sustainable human capital
transformation and corporate culture, paving the way for the next
phase—the Global Playership Period.
BTN’s recognition from LinkedIn further motivates the bank to continue
providing opportunities for top talent to grow, learn, and contribute at
their fullest potential. With a continuously evolving learning culture, BTN
is well-positioned to become a global player, ready to address future
challenges and meet the needs of society.
Career Development
BTN has provided various career development considering performance and potential for the
paths designed to offer different advancement future. This matrix provides a clear picture of an
opportunities for each employee based on their employee’s career development and helps the Bank
individual needs and potential. Each employee design appropriate development steps. Below is
is identified within a potential matrix created by BTN’s career development matrix.
BTN Career
Development 7 NEED TO
High
E
8 POTENTIAL 9 STAR
Matrix DEVELOP
CN
A M
Medium
4 SLOW
5 AVERAGE 6 POTENTIAL
STARTER
R
F O
RE
Low
2 SLOW 3 NEED TO
1 UNFIT
P
STARTER DEVELOP
Low Medium High
P O T E N T I A L
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Management
In addition to potential mapping, BTN also implements a for specific positions. This process aims to provide broad
Job Posting program and an open recruitment process opportunities for employees to develop their careers.
Implementation Process of the Job Posting Program
BTN will conduct a
selection process
based on the
alignment of The Board of
The Bank will position criteria Directors will The selected
ANNOUNCEMENT
announce job with the applicants. decide on employee will
vacancies to all The selection the selected be placed in
PLACEMENT
SELECTION
employees, along process may be employee based the designated
with the desired conducted through DECISION on the results of position.
candidate criteria. desk assessments the selection to fill
or face-to- the position.
face interviews,
simulations, etc.
BTN also involves a succession planning process for potential employees through a clear set of stages as
strategic positions within the organization. This process follows:
is based on the nomination and selection of high-
Successor Planning Process for Strategic Positions
Development Programs
• Communicating development
programs to successors
• Implementing the development
programs
Supervision and
Evaluation
• Supervision Identifying Successors
• Evaluation • Defining success criteria for the target
position
• Assessing profile suitability and
successor readiness
• Identifying and appointing successors
Integration with Other HR
Start Identifying Key Positions
Processes:
• Key position criteria • Learning and development
• Identification methods and • Performance management
finalizing key positions • Employee mobility
BTN already has a Talent Acceleration Program (TAP) high-potential talent who can meet the Bank’s future
to accelerate employee career development and needs. TAP is implemented through two main tracks: the
prepare them for key positions at BOD-1, BOD-2, and fast-track program and the BTN Millennials Program.
BOD-3 levels. This program is designed to fast-track The fast-track program targets employees under 40,
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providing them opportunities to advance to strategic under 26 years old nd existing employees under 30
positions through a quicker development process. The with a strong ambition to become future leaders and
BTN Millennials Program is intended for new employees actively contribute to the Bank.
Number of Participants in the TAP Program, BTN Millennials Program, and RLDP in
2024
BTN Millennial Regional Leader Development Program
TAP Batch 1 TAP Batch 2
Leader (RLDP)*
Person Grade
Number of Number of Number of
Number of Participants
Participants Participants Participants
2E - - - 17
3A - - 3 -
3B 1 3 18 -
3C 16 40 - -
3D 34 23 - -
3E/4A 23 6 - -
4B 3 - - -
Total 77 72 21 17
*) RLDP is a recruitment program aimed at finding potential regional leaders.
The Talent Acceleration Program (TAP) focuses on The Bank has designed a career ladder structure
leadership aspects, increasing exposure, providing to create clear growth opportunities and motivate
experiences, and strengthening employees’ technical employees to develop optimally. This ladder considers
competencies. Employee rotation between different job categories, job families, and individual career
roles is implemented with a “dual path” approach, planning, all based on core competencies, leadership,
which includes fulfilling the Bank’s needs for positions and job families. In addition, relevant learning curricula
requiring specific expertise (functional) and managerial are also integrated into the development planning.
roles. Employees are allowed to develop in both paths,
either in managerial or functional positions. The path In 2024, the Bank provided employee coaching
selection is based on factors such as the Bank’s needs, programs for career development. Through this
employee competencies and capabilities, and personal program, employees are trained to enhance skills
aspirations, ensuring placements align with career and abilities relevant to their field. Employees also
development goals. acquire non-technical skills to develop leadership
qualities, overcome challenges and obstacles, improve
communication skills, achieve work-life balance, and
strengthen motivation and engagement.
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Management
Routine Performance Appraisal and Feedback
In reviewing and evaluating employee performance, through semi-annual and annual reviews, using Key
BTN follows the General Policy on Human Resources Performance Indicators (KPIs) to assess individual
(Human Capital) Number KU.3 regarding Career and team performance. The Continuous Professional
Management. This policy includes aspects of planning Development (CPD) program is also implemented to
and developing employee careers within the Bank. support open communication about achievements,
In determining performance evaluation indicators, areas for development, and future career plans. [GRI 404-3]
BTN does not prioritize subjectivity or differentiate
employees based on gender but focuses on everyone’s BTN upholds the principles of equality and inclusion
competencies, performance, and potential. The results by integrating a performance-based compensation
of these evaluations are an essential factor the Bank strategy (performance-driven culture), ensuring
considers when formulating career development salary increases based on merit (merit increase),
policies, including decisions related to promotions, and providing incentives and bonuses as rewards for
transfers, or further development opportunities for the individual and team achievements. This policy also
employees concerned. ensures the equal career development of female
workers and adjusts compensation based on position,
In 2024, BTN committed to providing performance length of service, workload, and performance. With
evaluation feedback to 100% of employees at all comprehensive performance evaluations, the CPD
levels of positions without exception, objectively, program, and performance-based compensation
and without gender discrimination. This process is policies, BTN supports career development and
carried out with structured performance evaluations employee engagement while preparing for professional
growth in line with the company’s future strategic needs.
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Protection and Fulfillment of Employee Rights
BTN is fully committed to protecting employee In addition to this, BTN is also firmly committed to
rights, as fulfilling these rights is believed to enhance preventing forced labor practices in its workplace.
employee satisfaction. High satisfaction will drive better This commitment is implemented through the Human
performance, ultimately contributing to sustainable Capital Policy Number KU.3 on Workdays and Hours,
business outcomes and long-term success. clearly defining the Bank’s operational days and hours.
This policy ensures that employees can work, attend,
The Bank regularly negotiates with the Employee Union and rest according to the established schedule, with
to fulfill employee rights. These negotiations aim to attention to the balance between work and rest time.
draft and agree on the Collective Labor Agreement Suppose an employee is asked to work beyond the
(CLA), valid for two years with the option of a maximum designated hours. In that case, the Bank will provide
one-year extension. BTN has also registered this CLA overtime pay by the provisions outlined in the Human
with the Ministry of Manpower and Transmigration of Capital Policy Number KU.3 on Compensation and
the Republic of Indonesia, the authority responsible for Benefits Management. [GRI 409-1]
ensuring business compliance with labor issues, by the
Decree of the Director-General of Industrial Relations The Bank actively communicates with employees to
and Social Security Decision Number Kep. 4/ 032/PKB- foster good and transparent working relationships. This
PPJ/HI.00.01/X/2024 The currently applicable CLA is for communication includes information on changes in the
the period 2024-2026. [GRI 2-30] [OJK F.19] organizational structure, the addition of business units,
and matters related to personnel management, such
Although the CLA does not yet comprehensively cover as policies, procedures, and career development. All
the provisions of the Minister of Manpower Regulation relevant information is easily accessible to employees
No. 28 of 2014 concerning the Procedure for the through LApS, an internal application designed to
Establishment and Ratification of Company Regulations manage and deliver provisions, rules, and updates
and the Creation and Registration of Collective Labor applicable to the Bank. This ensures that employees are
Agreements, BTN ensures that all employees (100%) always up-to-date and can actively participate in the
are protected through the CLA and are members of the organization’s development.
Employee Union.
Employee Remuneration
BTN defines remuneration as providing rewards to of the position held. To ensure this, BTN has a system
employees that must be carried out fairly without regulated in Special Policy 3-B on Remuneration. This
discriminatory practices based on gender, ethnicity, policy refers to regulations set by the Financial Services
race, religion, skin color, or other forms of diversity. Authority (OJK), such as OJK Regulation Number 45/
In this regard, the Bank has ensured no difference POJK.03/2015 on the Implementation of Governance
in the basic salary and remuneration received by in Providing Remuneration for Commercial Banks
female and male employees at the same job level. and the OJK Circular Letter Number 40/SEOJK.03/2016
The amount of remuneration provided is based on on the Implementation of Governance in Providing
performance achievements and the responsibilities Remuneration for Commercial Banks. [GRI 3-3, 405-2]
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Management
In addition to retaining the best talent, applying the salaries are reviewed at least once a year. BTN also
Bank’s remuneration system also aims to meet the strives to maintain competitive wages by ensuring
needs for human capital. This remuneration serves as the salary percentile is above P60 at all job levels. This
a reward and encourages optimal and sustainable remuneration policy aims to retain the best talent and
performance in line with the Bank’s strategic objectives. encourage optimal performance in line with the Bank’s
With a performance and risk-based approach, BTN strategic achievements. [GRI 202-1] [OJK F.20]
ensures that remuneration is directly linked to the
employee’s work results, whether individually, within a With a performance and risk-based approach, the
work unit, or at the Bank’s overall performance level. In remuneration is directly linked to employee work results,
line with this approach, the wage structure and scale whether at the individual level, work unit level, or the
implementation are adjusted according to applicable Bank’s overall performance. The wage structure and
regulations. All these factors are then aligned with scale are adjusted according to applicable regulations
the Bank’s financial capacity to ensure that the and the Bank’s financial capacity. BTN also emphasizes
remuneration provided is in balance with the Bank’s that the remuneration policy does not differentiate
financial ability. based on gender, race, ethnicity, religion, or other
backgrounds and provides remuneration based on
BTN is committed to ensuring employee welfare through a person’s grade, performance, and position without
a fair, transparent, performance-based remuneration discrimination.
policy. The salary structure ensures that employees’
minimum salary remains above the Regional Minimum In line with the Bank’s principle of promoting gender
Wage while adhering to government policies by the Job equality in wage management, the average salary
Creation Law Number 6 of 2023 on the Establishment between men and women is the same. The median
of Government Regulations in Lieu of Law No. 2 of 2022 salary comparison between male and female
on Job Creation on Minimum Wage by consistently employees is 1:1. This represents the Bank’s commitment
adjusting employee salaries. Additionally, employee to providing equal pay without gender discrimination.
Composition of Male and Female Employee Salaries
Gender Total Total Salary Average Salary Median Salary
Male 6,560 96,815,580,530 14,758,473 9,661,401
Female 6,287 65,950,377,942 10,493,298 8,442,875
Total 12,847 162,765,958,472 12,671,542 8,915,991
BTN also monitors fairness in providing compensation for men being Rp14.7 million and women Rp10.4 million.
to all its employees. Based on the table, there is a This policy demonstrates BTN’s efforts to oversee the fair
balance in the distribution of salaries between male distribution of compensation, whether for employees
and female employees, with the total salary for each with the highest salaries or most other employees, to
being Rp96.8 trillion and Rp65.9 trillion, respectively. create an inclusive and equitable working environment.
Furthermore, the average and median salaries also
reflect a balanced approach, with the average salary
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Employee Remuneration Components
Permanent Contract Employees
Remuneration Component and Benefits
Employees
Basic Salary
Holiday Allowance
Leave Money
Clothing Allowance
Allowances (position, housing, vehicle, skills, fuel, location, tax)
Performance Bonus
Housing Loan
Pension
BPJS
Regular Health Maintenance Facilities
Medical Assistance Only BPJS Health
Funeral Assistance
As part of the remuneration policy implementation, Under Special Policy Number KK.3.B on Remuneration, BTN
BTN provides various employee benefits, including regulates the provision of Long-Term Incentives (LTI) to
salary, annual salary adjustments, holiday allowances improve performance and retain employees. These LTIs
(THR), annual leave allowance, and long-term leave can be in the form of shares, cash, or other forms set by
allowance, provided every three years of service. the Board of Directors and are designed to link employee
In addition, the Bank also provides health facilities rewards to the Company’s strategic achievements.
for employees and their family members, covering BTN also pays special attention to employees’ housing
inpatient and outpatient care, maternity expenses, and transportation needs by providing special credit
dental care, general check-ups, eyeglass purchases, facilities to help employees meet these needs. The Bank
among others. BTN is committed to providing equal ensures that all remuneration and benefits are aligned
non-salary benefits for all employees, including contract with employment status and that contract employees’
employees, to improve their quality of life. Remuneration rights align with the Company’s standards. [GRI 401-2]
is also variable and can be adjusted under certain
conditions, including overtime pay, clothing allowance,
sales incentive bonuses, annual bonuses, and location
and position allowances for employees in certain
organizational positions.
Employee Equity Programs
The MESA (Management Employee Stock Allocation) and them to acquire shares. However, since completing
MESOP (Management and Employee Stock Option Plan) the MESA and MESOP programs in 2016, BTN has not
programs were completed in 2016. These programs were continued or introduced similar programs for the Board
initially designed as stock-based incentives to increase of Directors, Board of Commissioners, executive officers,
employee, Board of Directors, Board of Commissioners, or other employees. BTN decided to reassess the stock-
and executive engagement and motivation by allowing based incentive policy and shift its focus to other
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Management
incentives or rewards that align with the Company’s and incentive strategies to align programs with market
current goals and strategies. This decision reflects a conditions and business developments.
change in the Bank’s human resource management
Employee Well-Being Program
As part of the implementation of the Employee Value well-being program through a series of initiatives
Proposition (EVP) and the enhancement of corporate focusing on both physical and mental health:
culture programs, in 2024, BTN launched the employee
No Program Name Description Goal
1 Employee A program to improve the physical and Improve BTN employees' health to enhance
Wellness mental health of employees by providing a work performance and support their well-
Program (EWP) consultancy platform with experts. being.
2 Employee A challenge program for employees to Employees can develop a more consistent
Challenge improve their physical health through healthy lifestyle and achieve a healthier and
the Step Challenge and Get Fit Challenge fitter body.
programs..
3 Health Week and A program to improve employees' health • Employees can develop a more
Health Seminars through mini MCU tests and health seminars consistent healthy lifestyle and gain
over a week with the theme "Enhancing insights on healthy living from experts.
Work-Life Harmony through BTN’s Wellbeing • Employees will get the latest health
Program." results from the tests.
4 Sport Together A fitness training program conducted in Employees can improve their fitness and
(Sport – Gether) groups through sessions like Poundfit and physical health, leading to a healthier and
Cardio Boxing. fitter body.
5 Blood Donation This program is a routine activity conducted To facilitate BTN employees in maintaining
every three months throughout 2024 and their health.
has expanded its coverage by involving
implementation at Regional Offices.
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Additionally, as part of the employee experience, BTN including co-working areas, daycare facilities, a nursery
also provides various facilities to support productivity, room, and the revitalization of the gym center.
BTNers Club
BTNers Club is a platform that coordinates various
sports, arts, and spiritual communities for all BTN
employees. Currently, BTNers Club oversees 26
communities designed to accommodate the
interests and hobbies of BTN employees, fostering a
balance between personal life and work (work-life
harmony). This initiative is expected to encourage
innovation, creativity, and collaboration, ultimately
enhancing productivity and sustainable
performance at BTN.
As part of the Employee Wellbeing Program (EWP),
BTNers Club aligns with the Employee Wellbeing
policy implemented at state-owned enterprises
(BUMN). Through this club, the bank strives to
create a more collaborative work environment that
supports the wellbeing of all employees, fostering
a productive and harmonious atmosphere.
BTNers Club plays a key role in driving the social
pillar of the EWP program by providing a platform
for employees to develop skills, collaborate, and
engage in beneficial activities outside of work. The
available communities offer a space for exploring
interests and personal development, which is
expected to improve overall wellbeing and inspire
individuals to innovate in their work.
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Management
BTN Jakarta International
Marathon
As part of BTN’s commitment to achieving its
vision of ‘Become The ESG Champion’ in 2024,
the bank has integrated ESG principles through
various initiatives focused on environmental
sustainability, social impact, and governance. One
of the key manifestations of BTN’s commitment is
the ESG Program, which is an integral part of BTN’s
Employee Value Proposition. This program provides
employees with the opportunity to actively
contribute to supporting the bank’s sustainability
efforts through various ESG-related activities.
A key activity supporting this initiative is the BTN
Jakarta International Marathon (JAKIM) 2024, which
serves as a platform to promote the ESG campaign.
In this event, BTN involved internal employees as
volunteers to maintain environmental cleanliness
along the marathon track, and set up an ESG
Corner Booth to provide information on BTN’s
sustainability programs and support local MSME
empowerment. BTN also collaborated with several
foundations to distribute donations that align with
the Sustainable Development Goals (SDGs), such
as health, education, and the environment.
BTN further demonstrated its commitment to social
equality by providing opportunities for disabled
runners to participate in the event. Through
these efforts, BTN not only shows an active role
in environmental conservation but also focuses
on social empowerment and inclusivity. The BTN
JAKIM 2024 event stands as a tangible example of
BTN’s efforts in fulfilling its social and environmental
responsibilities in line with ESG principles, while
also supporting the company’s goals to create
a positive impact on society and contribute to a
more sustainable world.
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Maternity Leave
BTN provides maternity leave for all employees who Additionally, BTN also provides miscarriage leave
undergo or accompany the birth process. This provision for female employees for 45 days, calculated from
is outlined in Special Policy 3. C regarding Regulations the date of miscarriage, to support physical and
and Administration. Female employees are entitled emotional recovery. Furthermore, BTN sets provisions
to apply for maternity leave for 3 (three) months. for childbearing leave that can be granted for up to 30
Meanwhile, male employees accompanying their wives days, with certain conditions. [GRI 401-3]
during childbirth are entitled to 5 (five) days of paternity
leave.
Maternity Leave Table
2024 2023 2022
Information
M F M F M F
Eligible employees for maternity leave 4,597 3,593 4,506 3,520 4,431 3,489
Employees taking maternity leave 337 384 514 564 576 613
Returned after maternity leave 332 350 506 472 573 533
* M=Male/ F=Female
Retirement Preparation Program
As a manifestation of BTN’s concern for the welfare The training under the MPP is conducted using
of employees approaching retirement, the Bank has various methods specifically designed to ensure that
a Retirement Preparation Program (MPP). The MPP is the benefits provided are achieved effectively and
carried out over 12 months and is designed to provide optimally. Some of the methods used include:
skills training and comprehensive mental preparation 1. Experimental Learning
so employees can face life after retirement more This method focuses on forming understanding
effectively. The training offered not only focuses on and insight through simulation experiences and
technical or professional aspects but also involves interaction with other participants. It is expected
developing emotional, spiritual, and intellectual aspects. to inspire and provide insights to change attitudes
With an approach that includes spiritual quotient (SQ), and behaviors toward more effective and
emotional quotient (EQ), and intelligence quotient (IQ), productive directions.
this program aims to create a retirement experience
that offers happiness, health, and well-being. This 2. Quantum Learning
program is intended for permanent employees who This method focuses on participants’ aspirations
have reached age 55 as a form of appreciation and and two-way communication, supported by a
recognition for their contributions during their tenure at comfortable and enjoyable training environment.
BTN. [GRI 404-2] This is intended to encourage participants to
change their attitudes and behaviors positively.
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Management
3. Technical Methods of Employment Termination. Based on this policy,
This method focuses on various technical permanent employees aged 56 are entitled to
approaches, including lectures, games, role- receive pension benefits as part of recognizing their
playing, discussions, independent tasks, case contributions during their tenure at BTN. The following
studies, and multimedia presentations. are the pension benefits provided:
• Define Benefit Program, providing retirement benefits
Retirement benefits are rights the Bank gives to based on a formula set by the Pension Fund;
permanent employees who meet the retirement age • Defined Contribution Program, providing retirement
requirements, which are 56 years for general employees benefits from the accumulation of the permanent
and 36 years for employees in specific positions such as employee’s contribution balance, consisting of 2.5%
tellers, customer service staff, and secretaries. from the employee’s salary, 7.5% from the Bank, and
the development results;
The Bank emphasizes the welfare of employees • Referring to the Director’s Decree regulating the
nearing retirement by providing preparation and Pension Fund Regulations of PT Bank Tabungan
special incentives. This is outlined in the General Policy Negara (Persero) Tbk, the maximum pension benefit
on Human Number KU.3 regarding the Management is 80% of the basic pension income. [GRI 201-3]
Employee Complaint Handling
Complaint Management
BTN recognizes that a harmonious and open relationship • The WBS process and mechanism are the
between employees and management is key to responsibility of the President Director and the WBS
creating a healthy and conducive work environment. Manager, which consists of the WBS Committee
Therefore, BTN is committed to ensuring the presence and the WBS Monitoring Committee;
of effective and transparent communication channels. • The WBS Committee consists of several divisions
As a concrete step, the Bank has developed a digital and the WBS management unit, while the WBS
employee platform called BTNBest designed to facilitate Monitoring Committee consists of the President
employees’ access to all information and personnel Commissioner and other commissioners at the
matters. Additionally, BTN provides a whistleblowing Bank;
system (WBS) facility managed by an independent third • Unless the reported party is a member of the
party. This system is a secure channel for employees to Board of Directors or a person with a special
report potential violations or fraudulent actions, as the relationship with the board and/or members of
Bank guarantees the whistleblower’s confidentiality. This the WBS committee, the report may be submitted
facility allows employees to report violations without to the WBS Monitoring Committee; and
fear of retaliation, such as termination, demotion, • If the reported party is a member of the Board
or intimidation. BTN also uses the WBS to manage of Commissioners or someone with a special
employee complaints regarding labor practices and relationship with the Commissioner, the report
human rights issues by Technical Guidelines Number may be submitted to the President Director.
7-B.2 on the Management of the Whistleblowing System.
The whistleblowing system (WBS) facility is accessible Throughout the reporting year, BTN did not receive any
to all employees flexibly, with access available 24 hours complaints about the work environment, indicating the
a day, 7 days a week. effectiveness of the Company’s policy in creating a
healthy, safe, and harmonious work environment for all
In Technical Guidelines Number 7-B.2 regarding the employees.
Management of the Whistleblowing System, the
employee complaint mechanism is outlined as follows:
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In addition, BTN also provides Legal Clinic, an online employees can easily obtain the legal information
consultation platform that can be utilized by all BTN they need without having to worry about complicated
employees to ask questions about simple legal issues processes or limited time.
related to their daily work. Through the Legal Clinic,
Employee Engagement Survey
As a proactive step to identify existing issues, BTN 4. Talent Management;
conducts an employee engagement survey annually, 5. Learning and Development;
covering all employees (100%). This survey aims to 6. Leadership;
measure employee engagement levels and identify 7. Empowerment;
areas for improvement. 8. Supervision;
9. Collaboration and Teamwork;
The results of the 2024 Employee Engagement Survey 10. Customer Focus;
showed an average score of 93 on a scale of 100. The 11. Efficiency;
survey reflects an excellent level of engagement with 12. Competitiveness;
key indicators including: 13. Change;
14. Wellness and Stress;
1. Benefit; 15. Innovation;
2. Pay; 16. Sustainable Engagement; and
3. Performance Management. 17. Retention.
Employee Satisfaction Index Table
Description Unit 2024 2023 2022
Satisfaction Index (shows average score) # 93 86 89
Total response rate % 91% 93% 92%
BTN utilizes the employee engagement survey findings award. These steps aim to improve productivity and job
to develop strategic programs, such as improving well- satisfaction, reduce employee turnover, and improve
being services, enhancing benefits, improving talent communication between employees and management
management programs, enhancing internal company to support policy improvements and create a positive
communication, and implementing an innovation work culture.
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Management
Employee Health and Safety
Employee Health and Safety Management Program
To realize its “Becoming One of the Homes of Indonesia’s implementing procedures, training, and risk mitigation
Best Talent” mission, BTN creates a safe and healthy actions related to safety and health at the workplace.
work environment for all its employees. In line with this This policy is documented in several documents,
commitment, the Bank ensures that all employees including [GRI 403-1]
receive adequate protection, particularly concerning a. Special Policy Number 9-AG on Occupational
occupational health and safety (OHS). BTN always Health and Safety Management System; and
strives to maintain high standards regarding workplace b. Technical Guide Number 9-AG.1 on the
safety, with the primary goal of achieving zero work Implementation Guidelines for Occupational
accidents and zero occupational diseases. BTN Health and Safety Management System (OHSMS).
also recognizes that workplace security and health
are essential for protecting employees and directly According to the Indonesian Ministry of Health Regulation
impacting productivity. A safe and healthy environment Number 48 of 2016, implementing OHS in office
boosts motivation and a sense of security among environments begins with forming and developing the
employees, which fosters their trust in the Bank. [GRI 3-3] occupational health and safety management system
[OJK F.21] (OHSMS). OHSMS development can be tailored to the
office’s needs and relevant OHS standards. Aspects to
BTN is obligated to protect employees’ welfare, be addressed in the office OHSMS include establishing
safety, and health, both mentally and physically, as OHS policies, planning OHS, implementing OHS plans,
regulated in Law No. 13 of 2003 on Manpower. BTN has monitoring and evaluating OHS, and reviewing and
established a policy governing the occupational health improving OHSMS performance. By OHSMS principles,
and safety management system (OHSMS) to fulfill this Bank implements several programs related to employee
obligation. This policy serves as a guide to creating a safety and health as follows: [GRI 403-1]
safe and healthy work environment and as a basis for
Employee Health Management Program
To improve employee health quality, BTN provides b. Services to improve employees’ health quality,
various health facilities that meet quality standards including reimbursement for hospitalization,
and have valid practice licenses. These health facilities outpatient care, childbirth expenses, dental care,
include various medical services that employees eyeglasses replacement, hearing aids, laboratory
can directly access to maintain their overall health. tests, and other medical costs;
Additionally, BTN collaborates with external healthcare c. Polyclinics and doctors are available to employees
providers or third parties to give access to medical and their families at any time;
services that cannot be provided within the bank. The d. Organizing educational seminars on anti-drug,
following are health facilities and services accessible to AIDS, and other health-related topics in the
employees: [GRI 403-1, 403-3, 403-6] workplace; and [GRI 403-5]
a. Periodic medical checkup facilities and treatment e. BPJS Health insurance services for employees and
services to detect and address specific developing their families.
or epidemic diseases;
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Employee Safety Management Program [GRI 403-5]
a. All operational offices are equipped with Provincial Employment and Transmigration Office
workplace safety equipment such as fire of DKI Jakarta;
extinguishers (APAR), smoke detectors, diesel d. BTN installs fire evacuation plans and fire safety
pumps, and emergency ladders to ensure the procedures for all rooms and floors of the
safety of the office environment and employees. building. This facility serves not only as a tool to
The provision of such equipment follows the warn employees in emergencies but also as an
standards set by the government in the Ministry of educational means for employees on how to
Public Works Regulation Number 26/PRT/M/2008 handle fires;
on the Technical Requirements for Fire Protection e. Conducting training and simulation exercises
Systems in Buildings and Environments; to prepare for emergency situations caused
b. BTN regularly inspects, maintains, and replaces all by disasters and fires in the office environment,
safety equipment. This program aims to monitor including organized evacuation procedures and
and control the safety equipment’s feasibility in safe workplace exit protocols to minimize risks and
the Bank’s environment; ensure employee safety; and
c. All operators of safety equipment (e.g., lifting f. Employees are certified through the “Safety and
and transporting machines) are certified by the Health Expert Certification Training (AK3U)” held
by BPJS Health.
Occupational Health and Safety Management System (OHSMS) and
Standard Operating Procedures (SOP)
According to the Indonesian Ministry of Health Regulation Some BTN employees have been certified as General
No. 48 of 2016 on Office Health and Safety Standards, Occupational Safety and Health Experts (AK3U)
OHSMS is “a part of the office building management since 2020. Employees who have obtained AK3U
system as a whole for controlling risks related to work certification are primarily responsible for ensuring
activities to create a safe, efficient, and productive the proper implementation of OHSMS and office OHS
workplace.” Implementing OHSMS is designed to standards in the Bank. Additionally, these employees
protect employees’ safety and health through planned, are responsible for identifying hazards by applying the
structured, and integrated procedures. Its main goal is hierarchy of controls, conducting risk assessments, and
to prevent work accidents and occupational diseases investigating reported hazardous situations or incidents
that may disrupt productivity and employee welfare. in the Bank’s operational area to preventrecurrence.
AK3U certification is a program from the Ministry of
Comprehensively, BTN has implemented OHSMS along Manpower that prepares OHS experts in BTN. Some of
with OHS policies that involve all parties engaged in the safety and health training topics that have been
its operational activities, including 100% of employees, conducted include: [GRI 403-2, 403-4, 403-5]
customers, suppliers, and others active in operational a. Support facilities for building operations, such
areas. All data on implementing this policy is recorded as elevators, generators, air conditioning, and
in the Human Capital Management Division’s database lighting;
to ensure that all parties involved receive appropriate b. Routine medical checkups for employees;
protection. In line with this, BTN also develops and c. Work support equipment that should not
implements standard operating procedures (SOPs) negatively affect health; and
to ensure the health and safety of employees and d. Periodic employee rotation to avoid psychological
stakeholders in the Bank’s operational areas. [GRI 403-1, disruptions.
403-7, 403-8]
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The Bank has also implemented other policies related and health. This encouragement is realized by providing
to OHS, including: various facilities, such as consultation services,
a. Prohibition of drug abuse, psychotropic reporting channels for risks and potential hazards, and
substances, and addictive substances (narcotics); transparent communication regarding implementing
b. Prevention of the spread of infectious diseases; OHSMS and applicable OHS standards. However, BTN
and has not yet established a formal committee involving
c. Management of third-party partners related to management and employee representatives to handle
OHS. occupational health and safety issues in a more
structured manner.
BTN remains committed to creating a safe and
comfortable working environment for all employees Consistent and well-planned implementation of OHSMS
by taking preventive measures to maintain their has yielded positive results, with BTN successfully
welfare. One of the efforts is to consistently comply maintaining a workplace free from accidents and
with all applicable regulations and standards, both occupational diseases. This success reflects the
government-mandated and internally adopted by the effectiveness of the safety policies applied by BTN. [GRI
Bank. Additionally, BTN encourages every employee to 403-2, 403-4, 403-9, 403-10]
actively participate in maintaining workplace safety
Harmonious Industrial Relations
BTN highly values the rights and freedoms of its International Labour Organization (ILO) Convention
employees to associate and assemble, which is in line Number 87 of 1948 on Freedom of Association and
with the Indonesian government’s policy of ratifying 19 Protection of the Right to Organize. [GRI 3-3]
International Labour Organization (ILO) Conventions.
This ratification reflects the country’s commitment BTN has complied with these regulations by establishing
to international standards protecting workers’ rights. a workers’ union on the 24 June 1999. This workers’ union
Based on the regulations derived from this ratification, is officially registered with the DKI Jakarta Department
BTN provides space for employees to negotiate and of Manpower with number Kep-2241/W.26/K.2/1000,
actively participate in finding solutions to potential indicating that BTN legally supports and recognizes
issues that may arise, including working conditions, employees’ rights to associate. Furthermore, the Bank
welfare, and other matters. This provision aims to foster ensures that the existing workers’ union operates
and maintain a harmonious relationship between the effectively and according to government mandates,
Bank and its employees. as stipulated in the Ministry of Manpower Regulation
No. 28 of 2014 on Procedures for the Establishment and
BTN is committed to various regulations protecting Ratification of Company Regulations and the Creation
workers’ associate and organization rights. One of these and Registration of Collective Labor Agreements.
is Article 28E Paragraph (3) of the 1945 Constitution of The Bank provides freedom of association to all BTN
the Republic of Indonesia, which asserts that freedom employees, which includes: [GRI 407-1]
of association, assembly, and expression is a human a. The freedom to become a member of the BTN
right; Law Number 21 of 2000 on Trade Unions, which Workers’ Union;
states that in realizing freedom of association, workers b. The freedom to express aspirations through the
have the right to form and develop trade unions; and BTN Worker’s Union and
c. The freedom to gather in BTN Workers’ Union
activities.
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Social and Economic Compliance
Social and economic compliance is essential in carrying BTN is committed to complying with applicable labor
out BTN’s responsibilities. As part of this commitment, regulations and established occupational health and
the Bank is determined always to respect and adhere safety (OHS) standards to ensure social compliance.
to various ethical standards and applicable legal In this regard, BTN implements policies that support
regulations to ensure that all operational activities are employee welfare and fair operational sustainability,
carried out responsibly. By maintaining compliance, such as employing workers with transparent and
BTN protects the business from potential legal risks and regulated contracts, prohibiting forced labor or underage
non-monetary sanctions and strengthens the trust of workers, and upholding equal treatment for employees
stakeholders, including customers, employees, partners, and customers without discrimination. Additionally, the
and the public, in the Bank’s integrity and credibility. Bank strives to create a safe, comfortable, and healthy
work environment by applying OHS principles in its
BTN has a Special Number KK9-AG on the Occupational operations. On the other hand, BTN also prioritizes the
Health and Safety Management System (OHSMS) to economic sector, which is reflected in the application
ensure social compliance. Through this policy, BTN is of healthy competition, the prohibition of monopoly
fully committed to: practices, and an anti-corruption stance. The Bank
1. Preventing and reducing work-related accidents also ensures that the wages given to employees meet
and occupational diseases by involving reasonable standards and reflect the value of their
management, bank employees, and/or trade contributions. [GRI 3-3] [SASB FN-CB-510a.1]
unions;
2. Creating a safe, comfortable, and efficient BTN’s commitment to implementing best practices
workplace to promote productivity; and adhering to social and economic regulations
3. Supporting the creation of added value for the and provisions is evident in the absence of fines or
Bank; and non-monetary sanctions. Furthermore, BTN has not
4. Enhancing independence, responsibility, and reported any cases to Indonesia’s dispute resolution
professionalism. mechanisms. These mechanisms include labor, product
legality, and other disputes. [GRI 2-27, 419-1]
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BTN recognizes that its presence within
society must contribute to the well-being of
the surrounding communities.
To this end, the Bank actively participates in developing BTN has developed various initiatives that align with
and empowering communities to address various sustainable development goals. This commitment is in
social, economic, and environmental challenges. This accordance with Minister of State-Owned Enterprises
initiative underscores BTN’s commitment to managing Regulation Number PER-1/MBU/03/2023, which
its impact on individuals, communities, and society mandates special assignments and CSR programs for
at large. The Bank’s commitment is reflected in the state-owned enterprises. Through this initiative, BTN
inclusion of people and community as a key component consistently strengthens its social and environmental
in its ESG Roadmap, serving as a guide to ensure that responsibility efforts, integrating the Sustainable
its business activities are not only financially profitable Development Goals (SDGs) into the implementation
but also create a positive social impact. This approach of its CSR programs. These initiatives aim to support
aligns with global trends that increasingly emphasize poverty reduction, quality education, gender equality,
the importance of sustainability and Corporate Social and environmental protection.
Responsibility (CSR) in business operations.
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Corporate Social Responsibility (CSR)
[GRI 203-1, 203-2, 413-1] [OJK F.23, F.25, F.3]
BTN is committed to creating a positive impact on Responsibility. Through this framework, the Bank
people’s lives and the surrounding environment develops measurable and tangible strategies that
through its CSR programs. These have been designed contribute to a communities well-being while also
not only to empower communities but also to improve generating benefits for the Bank. With this approach,
their quality of life sustainably while preserving the BTN continues to play a strategic role in supporting
ecosystem around the Bank. Within the framework of sustainable development, encompassing social,
the Sustainable Finance Action Plan (SFAP), CSR serves economic, and environmental aspects. [GRI 3-3]
as a key pillar driving the Bank’s continuous innovation
and growth alongside society. [GRI 3-3] In this reporting year, BTN has allocated Rp88.97 billion
for CSR programs.
To ensure the program’s success, BTN aligns its
CSR initiatives with ISO 26000 standards on Social
CSR Program Realization
2024 2023 2022
SDGs
Total (Rp) Total (Rp) Total (Rp)
Social Pillar
1. No Poverty 11,045,972,420 10,505,377,274 5,679,495,611
2. Zero Hunger 21,159,374,300 14,798,413,813 12,719,690,723
3. Good Health and Well-being 14,845,051,673 12,348,435,325 9,409,466,565
4. Quality Education 8,645,104,300 12,635,697,919 4,894,798,719
5. Gender Equality 220,000,000 - 30,000,000
Economic Pillar
6. Clean Water and Sanitation 95,000,000 270,000,000 660,166,447
7. Affordable and Clean Energy 1,205,465,000 50,000,000 971,740,516
8. Decent Work and Economic Growth 5,278,260,444 4,361,935,431 3,461,216,148
9. Industry, Innovation, and Infrastructure 6,236,867,228 2,270,000,000 6,455,431,482
10. Reduced Inequality 1,445,294,797 5,734,719,287 4,241,653,236
11. Sustainable Cities and Communities 14,900,539,959 14,993,831,355 9,963,739,700
12. Responsible Consumption and Production 1,079,576,859 - -
13. Climate Action 295,078,954 - 800,571,140
14. Life Below Water 375,120,000 - 367,500,000
15. Life on Land 1,592,977,380 1,184,084,000 1,725,839,800
17. Partnerships for the Goals 495,017,300 943,694,328 604,739,600
Legal and Governance Pillar
16. Peace, Justice, and Strong Institutions 50,000,000 - -
Total 88,964,700,614 79,996,188,732 61,986,049,687
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Social Pillar BTN’s primary objective is to grow alongside the community through a
series of initiatives that contribute to improving social, cultural, religious,
and social welfare aspects. These efforts align with Sustainable
Development Goals 1, 2, 3, 4, and 5.
1.
Rehabilitation of Uninhabitable and Healthy Homes
BTN provides better housing access for underprivileged
communities through a livable home rehabilitation
project implemented in Bekasi on October 30, 2024.
2.
Establishment of a Reading Park for Illiteracy
Eradication
As part of its initiative to support education and
eradicate illiteracy, BTN Lampung Branch Office has
provided CSR assistance in the form of the construction
of a Reading Park in Lampung on October 14, 2024.
3.
Scholarships for Students from Low-Income Families
On January 11, 2024, BTN provides educational assistance
to outsourced workers at the Credit Restructuring,
Collection, and Settlement Unit, as part of its corporate
social responsibility to support welfare in the education
sector.
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Economic Pillar BTN carries out activities to enhance job and business opportunities in
order to achieve quality and sustainable economic growth that benefits
the public. These efforts are in line with the Sustainable Development
Goals, specifically goals 7, 8, 9, 10, and 17.
1.
Implementation of Mini MBA in Property and School
Property of Developer
BTN has implemented the Mini MBA in Property programs
for Batch 20, Batch 21, and Batch 22 as part of its property
business training for aspiring property developers. This
program, conducted in 2024, aims to enhance human
resource capacity in the property sector. Additionally,
BTN, in collaboration with BPD HIPMI East Java, organized
the Mini MBA in Property for HIPMI from September 11-13,
2024.
2.
BTN Santri Developer Kebangsaan Program
From August 23-30, 2024, BTN successfully implemented
the BTN Santri Developer Kebangsaan Batch 4 program.
This program, which took place at Pondok Dar El Hikmah
in Pekanbaru, Riau, was attended by 80 participants. The
goal is to enhance the knowledge and competencies of
Santri alumni in the field of property business.
3.
Seminars / Public Lectures / Workshops
The purpose of these activities is to provide understanding
and knowledge to the audience regarding the business
in the property sector, digitalization in the banking sector,
and several topics relevant to current developments.
Several seminars, public lectures, and workshops
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were conducted in 2024, including the Market Outlook at Universitas Andalas (Unand) on August 29, 2024,
Property Seminar and the Impact of PPN-DTP on the Mini Public Lecture at Universitas Negeri Semarang (Unnes)
MBA in Property Graduation Event, as well as the Alumni on October 23, 2024, Universitas Tanjungpura (Untan)
Gathering on January 27, 2024, Public Lecture at Institut on November 7, 2024, and Seminar at Universitas HKBP
Sepuluh Nopember (ITS) on May 30, 2024, Public Lecture Nommensen (UHN) on November 29, 2024.
4.
Support for MSME Training to Go Digital
The UMKM Go Digital program has been implemented
in Jember on March 18, 2024, providing training and
support to MSME owners to help them leverage digital
technology in developing their businesses.
5.
Millennial Training to Become Young Developers BTN
Jember on March 18, 2024, implemented the Young
Developer BTN (DMB) program as a continuation of the
Millennial Developer BTN program that started in 2022.
This program aims to enhance the skills of the younger
generation in the property sector.
6.
Support and Collaboration with Partners for the
Development of Mini Banks
BTN is developing a BTN Mini at SMKN Kalibaru,
Banyuwangi, East Java on January 17, 2024. This initiative
is part of the Company’s support for educational and
training facilities for students to deepen their skills in the
banking sector.
7.
Training and Provision of Facilities for MSME
Empowerment
As part of efforts to enhance the competitiveness of
MSME products, on May 5, 2024, BTN provides halal
certification assistance to 500 MSME actors under the
guidance of Muhammadiyah-NU and the PPM-HS MSME
Development Institute.
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Environmental BTN is committed to environmental preservation through activities
focused on the management of natural resources and the environment.
Pillar These efforts are aligned with the Sustainable Development Goals,
specifically goals 6, 11, 12, 13, 14, and 15.
1.
Development of Green Parks and Play Areas Around
the BTN Tower
On January 26, 2024, BTN successfully implemented
tree planting at the Green BTN Educational Park, located
behind the BTN Tower. This park is expected to enhance
the quality of the environment while serving as an
educational space for the surrounding community.
2.
Socialization and Waste Sorting in BTN Housing Areas
As a form of environmental and community care, on
August 21, 2024, BTN implemented the Waste Bank
CSR program in Banten. In this program, BTN conducts
socialization and waste sorting activities to raise
awareness within BTN housing areas, reduce waste, and
maintain a clean environment.
3.
Development of Clean Water Facilities, Public Toilets,
and Sanitation
In support of public health, on June 7, 2024, BTN has
constructed clean water facilities, public toilets (MCK),
and proper sanitation. A healthy MCK facility has been
built in Padang City, West Sumatra.
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4.
Tree Planting in Green Open Spaces and Public
Facilities
On July 26, 2024, BTN collaborated with JEJAKIN in
a tree planting activity, where 200 mangrove trees
were planted at Angke Wildlife Park, Pantai Indah
Kapuk, Jakarta. This program aims to preserve coastal
ecosystems and enhance the environmental quality in
green open spaces.
5.
BTN Kediri Strengthens Local Community through CSR
Assistance for Social and Environmental Development
On November 14, 2024, BTN organized the handover
of Corporate Social Responsibility assistance. This
assistance was provided to various social, disability,
and environmental groups in Kediri Regency, including
the Kediri Disability Association (PDKK), the Srikandi
Putri Jambean Women’s Farmers Group, and the Insani
Bangsa Kediri Association.
The CSR assistance handover is a routine activity for
BTN, demonstrating the Company’s commitment to
social issues, human rights, inclusivity, and financial and
infrastructural support for community development
at its branch offices. This assistance is expected to
contribute to the development and progress of Kediri’s
growth, while also fostering closer connections between
BTN and the community in efforts to enhance the
housing ecosystem.
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In order to measure the social impact of the various ensures that each resource used has a broad positive
sustainability initiatives implemented, BTN conducted a impact on society, the environment and stakeholders.
Social Return on Investment (SROI) study. Through SROI, Below is an SROI table showing the results of the
the bank is able to assess not only the financial benefits, assessment of several sustainability programs that
but also the social and environmental contributions of have been implemented. [413-1]
each program implemented. Through this study, BTN
Location and Time SROI
Name of Program Program Objective Target
of Implementation Ratio
Training for Young Property literacy to the Students, public Surabaya 3.55
Developers public, creating young developers, REI September 9, 2024
developers as part of the members
future market of BTN's
business.
Coastal Area Conservation Realizing commitment to Tanjung Benoa Bali 9.69
in an Effort to Preserve the environmental sustainability coastal community October 10, 2024
Environment and real synergy between
business entities and state
institutions
Uninhabitable Homes Providing a decent Community of Central Tapanuli 1.91
quality of life for extreme Central Tapanuli Regency
disadvantaged families Regency May, June,
September,
December 2024
Waste Bank Maintaining the Residential Makassar, Ambon, 1.46
environmental balance of communities Serang, Banjarbaru
waste reutilization in BTN- of Tamalanrea, Throughout 2024
financed housing areas Waiheru, Banten
Indah Permai, and
Permata Golf Satu
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Financial Inclusion and Literacy [FS6] [SASB FN-CB-240A.2]
Micro and Small Business Funding Program (PUMK)
The Bank has a strategy to support the development of The Bank provides funding through the Micro and Small
capacity and potential for micro and small businesses Business Funding Program (PUMK). PUMK is a type
through the Micro and Small Business Funding Program of loan offered by the Bank to small businesses that
(PUMK). This program is a key component of the CSR have not met the requirements to obtain financing
initiative. The main focus is to enhance the competence from traditional banking institutions (unbankable). The
and capability of small businesses, making them distribution of these funds is carried out by considering
more independent and competitive, thus contributing the business sector and the geographical area in which
positively to the local economy and the well-being of the businesses operate, ensuring that the funds are
surrounding communities. Additionally, the program targeted and can provide the maximum impact. During
aims to assist small businesses with potential but facing this reporting period, the Bank disbursed Rp14.85 billion
difficulties in accessing financing through conventional in loans to 498 partners managed by Bank BTN. These
banking channels. funds were distributed through a collaboration with
third parties responsible for managing and disbursing
the funds to beneficiaries, with a fund allocation of Rp10
billion.
Table of Number of Partners (Business Activities) and Funds Disbursed
Description 2024 2023 2022
Number of Partners 498 170 378
Amount of Funds Disbursed (Rp million) 14,850 9,162 18,386
Table of Disbursement Realization of the Micro and Small Business Funding
Program by Business Sector [SASB FN-CB-410a.1]
2024 2023 2022
No Business Sector
Amount Amount Amount
% %
(Rp million) % (Rp million) (Rp million)
1 Industry 601 4.05 170 1.85 904 4.92
2 Trade 6,014 40.50 6,539 71.27 12,706 69.07
3 Agriculture 45 0.30 95 1.04 50 0.27
4 Plantation - - 550 6.00 25 0.14
5 Livestock 226 1.52 95 1.04 410 2.23
6 Fisheries 190 1.28 100 1.09 108 0.59
7 Services 2,347 15.80 1,622 17.70 4,184 22.78
8 Others 5,427 36.54 - - -
Total 14,850 100.00 9,162 100.00 18,386 100.00
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Table of Disbursement Realization of the Micro and Small Business Funding
Program by Region [SASB FN-CB-410a.1]
2024 2023 2022
No Region
Amount Amount Amount
% %
(Rp million) % (Rp million) (Rp million)
1 Sumatera - 935 10.20 3,070 16.72
2 DKI Jakarta - - 788 8.60 2,576 14.03
3 DI Yogyakarta 781 5.26 115 1.26 281 1.53
4 West Java and Banten 2,935 19.77 1,882 20.63 4,595 25.02
5 Central Java 1,760 11.86 1,002 10.94 1,864 10.15
6 East Java 1,517 10.22 980 10.70 2,290 12.47
7 Bali 410 2.76 60 0.65 105 0.57
8 East Nusa Tenggara - - 880 9.60 146 0.79
9 West Nusa Tenggara - - 525 5.73 313 1.70
10 Kalimantan 480 3.23 780 8.51 1,321 7.19
11 Sulawesi 6,966 46.91 970 10.59 1,159 6.20
12 Maluku - - 245 2.67 642 3.50
13 Papua - - - - 25 0.14
Total 14,850 100.00 9,162 100.00 18,386 100.00
Micro, Small, and Medium Enterprise (MSME) Credit
BTN is committed to providing access to capital for working capital and/or investment financing. With a
all segments of society, with a primary focus on the limit of up to Rp5 billion, this program supports the
development of MSMEs that possess potential and operational and capacity development of MSMEs,
viability across various economic sectors. The primary ultimately contributing to job creation and community
objective of this funding is to support investment and/ empowerment. Through this program, BTN aims to
or working capital financing, while also contributing strengthen the local economy sustainably. [SASB FN-CB-
to the achievement of sustainable development. 240a.1]
In this context, BTN plays a role in enhancing the
competitiveness of MSME clients, encouraging them In the reporting year, BTN developed strategies to
to become more productive, competitive, and globally expand the distribution of MSME credit, including:
aware through the provision of business capital. 1. Enhancement of High Yield Loan (Eagle Project)
distribution through:
As a responsible economic development agent, BTN • Establishment of MSME Partner Units at Sub-
facilitates financing for MSME players with the hope of Branch Offices (KCP) for the distribution of
fostering growth in this sector. Through this initiative, the People’s Business Credit (KUR) and Micro SME
Bank also creates a positive impact on the local and Credit;
national economy, improving community welfare. The • Segmenting MSME sales to ecosystems or
MSME Program, one of the Bank’s flagship initiatives, is communities based on regional potential
specifically designed to support MSMEs by providing through BPI SME.
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2. Digitization of MSME credit applications (BTN Laku) 3. MSME “Class Upgrade” mentoring through
used to process MSME credit applications. This sustainable business practices by utilizing BTN’s
development can have a positive environmental digital channels.
impact by increasing the efficiency of paper use in
the credit application process;
UMKM BerKRIYAsi
Bazaar
BTN supports the development
of MSMEs through various
initiatives, including financing and
promotion. One of these initiatives
is participation in the UMKM BUMN
BerKRIYAsi Bazaar held at Sarinah,
Jakarta, from October 17-20, 2024.
This event, initiated by the Ministry
of State-Owned Enterprises, aims
to empower MSMEs and encourage
national economic growth. The
bazaar showcases a variety of
innovative products from MSMEs, MSMEs through financing, mentoring, and promotion. Additionally,
including batik, accessories, BTN offers discounts of up to 74% for transactions using BTN Mobile.
recycled plastic woven items, and As part of its efforts, BTN also distributes People’s Business Credit
furniture. (KUR) to support MSME development. The “BerKRIYAsi” Bazaar will
also be held in Makassar from October 24-27, 2024. To facilitate
Through this event, BTN reaffirmed online transactions for visitors, all participating MSMEs have been
its commitment to supporting registered on the marketplace platform www.padiumkm.id.
The following is BTN’s MSME Distribution Portfolio:
MSME Lending Portfolio (Rp Million)
2022 2023 2024
3,505,937 3,431,071 4,404,263
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Disbursement of MSME Credit by Economic Sector [FS6] [FS7] [SASB FN-CB-410a.1]
Disbursement (Rp million)
Economic Sector
2024 2023 2022
Agriculture, Hunting, and Forestry 17,777 12,700 47,250
Fisheries - - 770
Mining and Quarrying - - 180
Manufacturing Industry 47,499 27,809 54,662
Electricity, Gas, and Water 8,015 22,063 29,973
Construction 2,833,438 2,465,069 2,716,379
Wholesale and Retail Trade 1,049,866 582,679 389,701
Accommodation and Food Services 44,881 30,175 5,155
Transportation, Warehousing, and Communications 24,418 32,381 46,134
Real Estate, Rental Business, and Corporate Services 153,945 85,942 117,216
Education Services 700 1,500 1,000
Health Services and Social Activities - - -
Community, Social Culture, Entertainment, and Other
158,791 124,528 68,761
Personal Services
Unspecified Activities 65,532 45,864 28,756
Total 4,404,263 3,431,071 3,505,937
Disbursement of MSME Credit by Province [FS6] [FS7]
Disbursement (Rp million)
Province
2024 2023 2022
Nanggroe Aceh Darussalam 112,768 - -
North Sumatra 112,768 - -
West Sumatra 49,630 110,036 127,769
Riau 35,670 35,333 46,216
Jambi 91,963 36,113 61,717
South Sumatra 111,483 75,955 61,541
Bengkulu 22,218 85,007 97,350
Lampung 92,584 28,955 24,406
Riau Islands 55,621 5,621 45,423
Bangka Belitung 73,286 42,869 69,414
DKI Jakarta 579,815 29,874 30,899
West Java 938,274 489,751 503,663
Central Java 404,100 748,559 757,397
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Disbursement (Rp million)
Province
2024 2023 2022
Yogyakarta 31,866 275,130 269,626
East Java 678,309 38,428 38,545
Banten 506,216 411,762 496,018
Bali 55,715 360,785 321,310
West Nusa Tenggara 39,345 49,555 58,305
East Nusa Tenggara 25,684 40,670 43,517
North Kalimantan - 29,245 23,048
West Kalimantan 23,469 9,225 3,375
Central Kalimantan 15,807 32,507 39,570
South Kalimantan 50,985 20,087 18,522
East Kalimantan 47,053 77,177 92,267
North Sulawesi 5,085 47,323 51,139
West Sulawesi 26,020 30,546 24,965
Central Sulawesi 45,489 10,172 2,137
South Sulawesi 157,894 37,041 28,638
Southeast Sulawesi 51,004 132,119 88,959
Gorontalo 21,580 53,022 30,310
Maluku 27,606 12,967 3,696
North Maluku 6,912 913 4,290
Papua 7,185 5,274 18,070
Total 4,404,263 3,431,071 3,505,937
People’s Business Credit (KUR)
Since 2017, BTN has supported government policies not only intended for individual entrepreneurs and small
aimed at enhancing business capital access to businesses but also for business entities and productive
accelerate real sector development. In line with this, business groups that meet eligibility criteria.
the Bank has placed a strong focus on empowering In the reporting year, BTN has implemented several
MSMEs by distributing People’s Business Credit (KUR), strategies to enhance the distribution of People’s
including Micro KUR and Small KUR. This program is Business Credit (KUR), including:
designed to provide capital access to micro, small, 1. Enhancing High Yield Loan Distribution (Eagle
and medium enterprises, particularly those operating Project)
in the construction, housing, and other supporting • Increasing KUR realization through direct
sectors. Through KUR, BTN offers financing options that selling to mortgage (KPR) and consumer loan
can be used for working capital and/or investment, debtors.
strengthening the operational capacity of debtors. • Segmenting KUR sales by targeting ecosystems
The program also provides opportunities for debtors and communities based on regional potential
without additional collateral to obtain financing. KUR is through BPI SME.
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2. Raising awareness through outreach activities to Throughout 2024, BTN has provided Micro and Small
enhance public understanding of the KUR product KUR to 13,010 debtors, with a total plafond reaching Rp 1.7
and strengthen engagement with BTN. trillion. The overall KUR portfolio distribution is as follows:
KUR Lending Portfolio (Rp Million)
2022 2023 2024
599,832 1,807,673 1,799,621
KUR Distribution by Loan Type [FS8]
Realization 2024 Realization 2023 Realization 2022
KUR Type
Plafond (Rp Plafond (Rp Plafond (Rp
Debtors Debtors Debtors
Million) Million) Million)
Micro KUR 543,593 9,067 249,906 3,965 49,974 843
Small KUR 1,265,028 3,943 1,557,767 4,249 549,858 1,598
Total 1,799,621 13,010 1,807,673 8,214 599,832 2,441
Distribution of KUR (People’s Business Credit) by Economic Sector [FS6] [FS7] [SASB FN-CB-410a.1]
Amount of Distribution
2024 2023 2022
Economic Sector
Plafond (Rp Plafond (Rp Plafond (Rp
Debtors Debtors Debtors
Million) Million) Million)
Agriculture, Hunting, and
11,660 36 39,298 118 9,706 42
Forestry
Fisheries 1,515 7 6,560 36 3,370 18
Mining and Quarrying 830 5 - - 1 3
Manufacturing Industry 27,443 207 37,124 204 17,465 76
Electricity, Gas, and Water
3,663 31 6,100 37 2,469 12
Supply
Construction 191,400 452 511,569 1,097 167,151 372
Wholesale and Retail Trade 1,104,183 8,729 811,480 4,592 271,605 1,307
Accommodation and Food
199,297 1,574 147,147 926 40,193 197
Services
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Amount of Distribution
2024 2023 2022
Economic Sector
Plafond (Rp Plafond (Rp Plafond (Rp
Debtors Debtors Debtors
Million) Million) Million)
Transportation, Warehousing,
20,354 77 17,862 64 8,500 27
and Communication
Real Estate, Leasing, and
24,010 102 30,976 123 14,970 53
Business Services
Financial Intermediation - - - - - -
Education Services 5,360 36 4,750 26 1,040 3
Health and Social Work
- - - - - -
Activities
Community, Social, Cultural,
Entertainment, and Other 137,450 1,132 112,124 586 40,717 210
Personal Services
International and Extra-
- - - - - -
International Bodies
Household Services - - - - - -
Unspecified Activities 72,456 622 81,284 402 22,297 123
Total 1,779,621 13,010 1,807,673 8,214 599,832 2,441
Distribution of KUR (People’s Business Credit) by Province [FS6] [FS7]
Amount of Distribution
2024 2023 2022
Province
Plafond (Rp Plafond (Rp Plafond (Rp
Debtors Debtors Debtors
Million) Million) Million)
Bali 45,550 350 26,200 141 7,820 34
Bangka Belitung 27,572 101 26,387 80 7,125 27
Banten 123,974 1,178 147,576 907 53,622 284
Bengkulu 22,251 106 19,293 67 9,630 27
D.I. Yogyakarta 49,264 323 31,116 176 8,657 45
DKI Jakarta 160,266 1,349 165,798 921 70,480 277
Gorontalo 17,203 100 11,416 92 3,130 30
Jambi 40,730 127 53,880 114 13,910 30
West Java 337,849 3,021 422,064 1,879 120,645 462
Central Java 192,144 1,439 148,096 731 50,736 277
East Java 222,843 1,800 230,475 1,093 66,665 268
West Kalimantan 25,739 135 19,649 56 8,120 19
South Kalimantan 17,070 180 53,781 164 13,286 52
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Amount of Distribution
2024 2023 2022
Province
Plafond (Rp Plafond (Rp Plafond (Rp
Debtors Debtors Debtors
Million) Million) Million)
Central Kalimantan 14,468 97 9,526 46 5,475 15
East Kalimantan 15,455 117 17,364 110 12,198 50
North Kalimantan 9,675 71 9,690 82 5,630 38
Riau Islands 48,185 217 36,322 133 11,130 48
Lampung 20,332 124 17,775 110 7,724 25
Maluku 12,848 71 13,023 78 6,342 61
North Maluku 12,050 79 12,610 85 8,008 27
Nanggroe Aceh Darussalam - - - - - -
West Nusa Tenggara 20,495 216 16,180 78 6,855 36
East Nusa Tenggara 14,587 133 8,796 42 8,565 29
Papua 8,965 93 16,212 121 4,275 28
Riau 33,470 169 63,280 130 12,250 26
West Sulawesi 20,975 67 14,066 52 2,601 7
South Sulawesi 83,899 380 40,980 217 20,000 55
Central Sulawesi 12,398 71 11,860 38 7,250 24
Southeast Sulawesi 25,800 90 15,500 44 4,515 14
North Sulawesi 8,071 72 9,349 56 2,725 11
West Sumatra 23,890 116 21,860 55 8,461 27
South Sumatra 24,717 123 40,980 109 15,408 34
North Sumatra 106,887 495 63,641 207 16,595 54
Total 1,799,621 13,010 1,807,673 8,214 599,832 2,441
Financial Inclusion Products of the Sharia Business Unit
Portfolio (Rp Million)
Target
Product Description
Market
2024 2023 2022
TabunganKu iB A savings product based on the wadi’ah (safekeeping) General
contract, offering attractive bonuses. Jointly issued by public 15,039 13,532 10,451
banks across Indonesia, it aims to promote a savings
culture and enhance community welfare.
Tabungan BTN A savings product specifically for students under 17 Students
SimPel iB years old who do not yet have an ID card (KTP), with a under 17 7,732 6,489 4,738
low initial deposit and attractive bonuses. years old
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BTN Agents [FS16]
BTN Agents is an implementation of opening, bill payments, cash deposits,
the Branchless Financial Services for withdrawals, fund transfers, balance
Financial Inclusion (Laku Pandai), an inquiries, mini statements, PIN changes,
agency banking program initiated by and product purchases. Additionally, BTN
the Financial Services Authority (OJK). encourages community empowerment
This program aligns with the Indonesian within the banking sector by increase
government’s National Strategy for their income in the form of participating
Financial Inclusion (SNKI), introduced in becoming an agent.
in June 2012, in order to expand public
As of 2024, there are
access to formal financial services, General Requirements to Become a BTN
particularly for those without banking Agent:
5,000
access. Additionally, the program
seeks to protect communities from 1. Registration can be completed at
burdensome lending practices, which the nearest BTN branch or sub-
are often prevalent in the informal sector. branch. BTN Agents spread
2. Have become a BTN customer and across Indonesia.
BTN Agents provide Laku Pandai services have an active savings account
for individuals who are unfamiliar to accommodate deposits,
with banking or lack access to formal commission payments, and fees.
financial services (unbanked). This 3. Must have operated a business for
program also serves as an opportunity at least one year.
for communities to learn about banking, 4. Must possess valid business
financial products, and common permits and licenses (at least a
banking transactions, with easier letter of recognition from the local
access and closer proximity to their RT authority).
residences, including in remote areas. 5. Must not be listed on Bank
Through this service, both new and Indonesia’s national blacklist.
existing customers can access various 6. Must pass the Bank’s due diligence
banking transactions, such as account process.
SimPel [FS16]
SimPel is one of BTN’s flagship programs designed to In 2024, BTN successfully reached over 824,069
support financial inclusion by providing easy access participants in both rural and urban areas across
to financial services and enhancing financial literacy Indonesia. The program focuses on digital financial
among students. The program targets students from training for students, equipping them with a better
elementary (SD), middle (SMP), and high school (SMA) understanding of banking products and financial
levels, aiming to educate them on the importance of management. Additionally, BTN collaborates with
saving and financial planning from an early age. With educational institutions and local communities to
simple account opening and transaction requirements, expand the program’s reach and support financial
SimPel seeks to raise financial awareness among inclusion efforts nationwide.
school-aged children, helping them understand and
manage financial products wisely. As part of BTN’s BTN continues to strengthen financial literacy,
commitment to financial inclusion, this program particularly in remote areas with limited access to
empowers Indonesia’s younger generation to prepare financial services. Through this educational initiative,
for a more financially secure future. BTN helps communities gain better financial knowledge,
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enabling them to utilize banking products and services advanced banking products and expand its user base
wisely. By empowering customers with financial across Indonesia.
knowledge, BTN aims to encourage greater adoption of
Account Ownership Proportion [SASB FN-CB-240a.4]
Description 2024 2023 2022
Total Savings Accounts 6,139,468 7,099,737 7,284,386
SimPel Accounts
Total Accounts 824,069 795,592 743,308
Percentage of Total Accounts 13.42% 11.00% 10.20%
*)Excluding Directors and SEVPs
The decline in total savings accounts was due to the One of the key strategies includes introducing SimPel
mass closure of inactive social assistance (bansos) accounts in more schools across Indonesia, with the goal
accounts. However, considering the success of financial of reaching a wider student demographic in both urban
literacy initiatives in 2024, BTN plans to expand and and rural areas. BTN also plans to launch digital-based
enhance similar programs in 2025. financial literacy programs, leveraging technology to
reach underserved communities in remote locations.
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Housing Finance Center (HFC) [FS16]
the increasing number of new families and improved
accessibility to homeownership. This opportunity is
leveraged by the Housing Finance Center (HFC) to
address the potential in Indonesia’s housing sector. BTN
established the Housing Finance Center (HFC), officially
launched on October 16, 2014. To further enhance
human resource development in the property sector,
The large number of households in Indonesia that have HFC has also set up a training center at BTN KCP UGM
yet to own a home indicates that the housing sector Yogyakarta.
still has significant growth potential, supported by
Vision, Mission, and Pillars of the HFC Program
Vision Mission
To become a leading center for research, To provide excellent, innovative, and integrated
education, and consultancy related to housing services in housing finance research, education,
finance. and consultancy for clients.
HFC Functions
Through HFC, BTN is committed to supporting housing sector. This effort is realized through three core functions
supply and fostering new developers in the housing of HFC, which are outlined within three business pillars:
1. Learning The Indonesian Housing Finance Education Center offers a range of
educational and training programs.
2. Advisory The Indonesian Property and Housing Finance Consultation
Center supports stakeholders (including the public, developers, and
government) in the decision-making process.
3. Research The Indonesian Housing Finance Information and Innovation Center
provides insights through various scientific studies on the market,
industry players, and housing sector trends.
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From these three main activities, there are several derivative programs:
Main Activities of HFC
Learning Mini MBA in The Mini MBA in Property program is a collaboration between HFC and the School of
Function Property Business and Management at the Bandung Institute of Technology (SBM-ITB). It is
held regularly to create new entrepreneurs in the property industry. Since its launch in
October 2016, the program has conducted 22 batches and produced over 700 alumni.
In 2024, 3 (three) additional batches (Batch 20, 21, and 22) were held. Additionally, the
Mini MBA in Property is designed for members of the Indonesian Young Entrepreneurs
Association (HIPMI), with previous sessions held in Surabaya.
BTN Santri This initiative is a joint program between BTN and NU Circle (NUC), offering property
Developer development business training for alumni of Islamic boarding schools (pesantren),
Kebangsaan interfaith organizations, and pesantren alumni located in program implementation
Program areas. To date, the BTN Santri Developer Kebangsaan program has conducted 4 (four)
batches and graduated over 300 alumni. In 2024, the program successfully took place
at Pesantren Dar El Hikmah in Pekanbaru.
Seminars/ HFC actively organizes seminars, public lectures, and workshops in collaboration with
Public Lectures/ institutions, universities, organizations, and associations. These events aim to provide
Workshops insights and knowledge to audiences on banking business, digitalization in the banking
sector, and other relevant topics aligned with current industry developments. In 2024,
seminars and public lectures were held at Sepuluh Nopember Institute of Technology
(ITS), Andalas University (Unand), Semarang State University (Unnes), Tanjungpura
University (Untan), and HKBP Nommensen University (UHN). Additionally, a Market
Outlook Property Seminar and the Impact of PPN-DTP Implementation was conducted
during the Mini MBA in Property Graduation Ceremony & Alumni Gathering.
Fungsi Advisory Alumni of the BTN Santri Developer Kebangsaan Program have established the NU
Advisory Support for Santri Developer Association (ASANU) as a business platform and incubator for
ASANU's Housing program alumni, ensuring its continuity and sustainability. ASANU also plays an active
Development role in facilitating land availability and acquisition for alumni projects. Additionally,
Program BTN supports these alumni by providing access to construction financing and home
sales through KPR BTN. In 2024, ASANU Riau Regional Board (DPD ASANU Riau) was
successfully established. The planned ASANU projects are located in Banjarnegara
and Banyumas.
Development BTN PAS is a mobile-based application designed as a consultation, mentoring, and
of BTN Property communication platform between mentors (instructors) and mentees (participants/
Advisory System alumni of training programs) conducted by the Housing Finance Center (HFC) BTN.
(BTN PAS) Through this platform, mentors and mentees can conduct online consultations on
Application property-related topics. The application serves as a tool for BTN to cultivate new
housing developers and strategize business potential.
ABCG As an initiative to provide housing solutions for informal MBR (Low-Income
Collaboration Communities), the ABCG Program is a collaborative framework between Academia
Program (Universities), Business (BTN), Community (Community-Based Organizations), and
(Academic, Government (Ministry of Housing and Settlement, Ministry of Agrarian Affairs and
Business, Spatial Planning/National Land Agency, and Local Governments). This collaboration
Community, and aims to support informal sector workers in owning self-built and community-based
Government) housing.
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Main Activities of HFC
Research BTN HPI (House The BTN House Price Index provides data on housing price changes at national,
Function Price Index) regional, provincial, and district/city levels. The index is derived from realized housing
loan data, based on quality and similar characteristics, both at the national scale and
in specific regions, including non-subsidized mortgage transaction prices. The data
covers various housing types, from 21–36, 37–45, 46–70, and the price index of multiple
districts/cities. This data is published quarterly, with monthly reports calculated using
the matched sales approach.
National HFC research findings are published through annual national scientific forums
Economic Forum organized by Bank Indonesia (BI), the Financial Services Authority (OJK), the Indonesian
Publications Economic Scholars Association (ISEI), and the National Banking Association (Perbanas).
The research publications are aligned with the themes presented in each event.
Implemented The following research and studies have been conducted by HFC in 2024:
Research • Market Share Analysis of BTN KPR (Mortgage Loans)
• Market Share Analysis of BTN Third-party funds (DPK)
• Social and Economic Impact of Housing Industry Development in Indonesia
• Analysis of Priority Industrial Sectors
• Gen Z Preferences in Homeownership
• Prospective ESG Sector Analysis
• Potential Funding for Housing Finance
• Banking Sector Development Analysis
• Community Savings Fund Study
Research Collaboration with researchers, academics, and practitioners from universities and
Fellowship other research institutions for knowledge transfer as part of efforts to enhance the
competence, capacity, and capability of researchers at HFC in conducting research
related to economic development and BTN’s business growth.
Through its Learning Program, HFC offers a comprehensive understanding of the four key pillars of knowledge required
to become a housing developer, which include:
Land and Environment Capital Legal Skill Set
Relates to the acquisition or Involves obtaining and Concerns permits, legal Focuses on expertise
control of land designated managing financial compliance, and land and skills in initiating,
for housing projects. resources for housing certification for housing constructing, developing,
project development, as projects. and marketing housing
well as strategies to secure projects.
funding.
Other Financial Literacy Programs [FS16]
As part of its commitment to promoting financial among university students and academic communities.
literacy, BTN continues to expand its collaborations Through this program, BTN seeks to reach unbanked
with educational institutions, government agencies, populations by partnering with universities and higher
and local communities to implement financial training education institutions to provide training and awareness
programs. These initiatives aim to enhance financial sessions on personal financial management, financial
literacy and broaden public access to the financial planning, and the importance of financial literacy.
sector, particularly in property and banking. One of BTN’s
flagship initiatives is the Financial Inclusion Program, Additionally, BTN has expanded its outreach efforts
designed to improve financial knowledge and skills by introducing payroll services to government
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institutions through mentorship-based engagement in Indonesia while supporting economic empowerment,
approaches. These programs equip students and the particularly among young generations who have the
wider community with essential financial knowledge, potential to drive local and national economic growth.
enabling them to manage their finances wisely—both in The Financial Inclusion Program is a concrete step in
their personal lives and in developing future small and expanding access to banking services and building a
medium-sized enterprises (SMEs). BTN believes that this more inclusive and sustainable economic future.
approach will accelerate and expand financial inclusion
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Excellent Service for Customer Satisfaction 177 BTN Service Roadmap 2023 – 2025 180 BTN Portfolio Guideline 187 ESG-Based Products 194 Digital Innovation for Modern Services 203 Fair Advertising Policy 204 Oversight Of Financial Products 205 Customer Data Privacy and Security 217 Responsible Debt Collection Policy 218 Financial Product Complaints Handling 222 Customer Satisfaction
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Management Welfare Support
As a financial institution
with a primary focus
on the housing sector, To accelerate this transformation, BTN has established
a strong partnership with the Green Building Council
BTN is committed to Indonesia. This collaboration not only aims to
enhance employee knowledge and understanding
fostering a sustainable of sustainability practices, but also to improve
housing financing competencies. Through various initiatives, BTN aspires
not only to be a leader in the housing sector but also
ecosystem. To achieve a pioneer in creating lasting positive impacts—both
environmentally and socially—that bring long-term
this goal, the Bank benefits and contribute to environmental sustainability.
recognizes that green
mortgages are a
strategic initial step.
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Community Development Customer Satisfaction Sustainability
and Empowerment Governance Integrity
BTN Service Roadmap 2023 – 2025
In order to realize BTN’s vision of becoming the “Primary of Customer (VoC) insights through Customer
Partner in Empowering Indonesian Families Financially” Experience Index (CEI) measurements. To follow up
and to fulfill one of its missions to “Provide the Best on the established BTN Service Roadmap 2023-2025
Customer Experience through Integrated Digital and strategy, the Customer Experience Division conducted
Financial Services,” the Bank has established a service a workshop attended by the Board of Directors, SEVPs,
vision: “To deliver a reliable, uniquely differentiated, and relevant Division Heads (including product and channel
convenient service beyond customer expectations,” owners), Regional Office Heads of Regions 1 and 2, and a
along with 19 key initiatives. Based on this, BTN has team of consultants. This workshop served as a platform
developed a Service Roadmap that will serve as a guide for socialization, discussion, and obtaining guidance
in achieving BTN’s Service Vision. and approval from the Board of Directors regarding the
proposed Service Roadmap.
The development process of the 2023-2025 Service
Roadmap began with a survey to gather Voice
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Management Welfare Support
The BTN Service Mission was formulated as a detailed 3. Becoming a trusted financial partner and housing
elaboration of the Service Vision following the workshop advisor by providing signature services that reflect
and consists of the following: the authenticity of the organization.
1. Fostering an integrated service culture within 4. Delivering the best service experience, focused
the organization by adopting a solution-driven on customer expectations, treating them with
approach to achieve service excellence. warmth and care as if they were part of the BTN
2. Establishing consistent service standards across family.
all service channels and customer touchpoints to
ensure a seamless and exceptional experience in In addition to the Service Vision and Mission, Service
every interaction. Values have been established as a foundation for
support:
Reliable Uniquely differentiated Convenient Services
F A M I L Y
Fostering Assurance Meaningful Inspire Light-hearted Yearning
This value
This value This value
component
This value component component This value
highlights BTN’s
component This value illustrates BTN’s demonstrates component
commitment to
represents BTN’s component commitment to BTN’s commitment represents
inspiring beyond
Meaning
commitment reflects BTN’s providing services, to sincerity and ambition and
just financial
to building commitment interactions, and generosity, internal motivation
solutions,
relationships and to delivering experiences that creating a to provide
becoming a
providing comfort certainty, security, are meaningful, pleasant customer high service
catalyst for
in services that and trust reliably to personalized, and experience standards that
improvement
align with the all customers. impactful, aligning throughout their exceed customer
and progress
family concept. with customer financial journey expectations.
within the banking
needs and with warm and
ecosystem.
aspirations. heartfelt service.
Fostering Inspiration for
Assuring Reliable Meaningful Light-hearted Yearn for
Longterm Achieving the
Support Personalization Atmosphere Excellence
Relationship Dream
Point Details
Fostering Yearn for
Assuring Solution- Meaningful Inspiration for Light-hearted
Incremental Customer
Centric Services Experience Your Home Assistance
Service Excellence Satisfaction
Meaningful
Fostering Digital Assuring Ethical Inspiration for Light-hearted Yearn for
Longterm
Transformation Practices Excellence Approach Integration
Impact
The term FAMILY was chosen as the service value as As a foundation to support the Service Mission and
it reflects reliable service (fostering and assurance), enhance customer acquisition and loyalty, the Bank has
a uniquely differentiated approach (meaningful and established core values. BTN’s core values are defined
inspiring), and a convenient experience (lighthearted as Solution-centric, providing added value to customers
and yearning). The concept embodies BTN’s through basic advice for new customers and advanced
commitment to engaging with customers as part of a advice for existing and churning customers.
family.
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In accordance with the Service Blueprint, improvements standard, and development of a service recovery
will focus on the aspects of People, Process, and Physical room for customers submitting hard complaints.
Evidence to establish new standards across all service
channels. 2. Service-focused Squad
Formation of a Service-Focused Squad to assist
The implementation plan for the BTN Service Roadmap customers without requiring direct interaction
2023-2025 is divided into: with Customer Service (CS) and tellers, and
1. Quick Win establishment of a service organization to
• Solution-Centric Response Mechanism implement service standards and foster a learning
• Service-focused Squad culture and environment.
• FinEase Acceleration
• BTN Care 3. FinEase Acceleration
Acceleration of the account opening process,
2. Mid-Term improvements in consumer credit agreement
• Service Competency Enhancement Program service standards, standardization of branch
(S-CEP) office premises (layout adjustments, queue
• BTN Mobile Advancement machines, and Loan Services uniforms), and script
• CRM Empowerment development.
• BTN Housing & Mortgage Advisory
4. BTN Care
3. Long-Term Ensuring the availability of facilities for people with
• Hackathon disabilities, the elderly, pregnant/nursing mothers,
• BTN Heritage and children, such as disability ramps, handrails,
wheelchairs, walking aids, priority seats, kids’
Based on the Service Programs Prioritization established corners, baby-feeding rooms, accessible toilets,
during the BTN Service Roadmap 2023-2025 Workshop, guiding blocks, and other necessary amenities.
four Quick Win service programs have been agreed
upon for execution under the Roadmap’s Pilot Project, The Pilot Project has been approved for implementation
namely: at five (5) branch offices (both Conventional and
1. Solution-Centric Response Mechanism Sharia), namely the Bekasi Branch Office, Tangerang
Implementation of service recovery procedures Branch Office, Karawang Branch Office, Bandung Sharia
when BTN provides services below the required Branch Office, and Yogyakarta Sharia Branch Office.
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BTN Portfolio Guideline
As a financial institution, BTN is committed to allocation to priority sectors with sustainable growth
continuously strengthening credit risk management prospects. This initiative not only supports business
in line with economic growth and prevailing monetary growth but also contributes to Environmental, Social,
policies. BTN has implemented the Portfolio Guideline and Governance (ESG) risk mitigation. BTN ensures that
(PG) to support business and financial stability. The the Portfolio Guideline is implemented in an integrated
Portfolio Guideline is a strategic tool aimed at effectively and consistent manner with its credit risk management
managing credit concentration risks through measured strategy. As a result, the Portfolio Guideline has become
portfolio diversification. a key component in balancing credit growth and
risk management, aligning with BTN’s sustainability
Through the implementation of the Portfolio Guideline, principles.
BTN seeks to maintain asset quality by directing credit
Objectives of the Portfolio Guideline
Industry Sector Allocation Limit (Priority) With the following objectives:
Restrictive Industry Subsectors Managing credit concentration
risks through measured portfolio
diversification based on industry
research, ESG risk analysis, and
sector risk assessment.
1 Research on 2
Priority Industry 5
ESG Risk Analysis
Sectors Encouraging diversified and
sustainable credit growth by aligning
allocations with priority industries.
RAC
4 3 Providing clear guidelines for priority
Business Industry Sector sectors to support responsible credit
Potential (Pipeline) Risk Analysis growth.
Monitoring and managing sectoral
risks within the prioritized industries.
Governance & Technical Guidelines for Portfolio Guideline
1. In implementing ESG principles, the Portfolio between ESG aspects. The designated sectors
Guideline aligns with Technical Guidance Number include:
PT. 8-H.3. The issuance of the Portfolio Guideline a. Environmentally friendly transportation,
serves as a tool to manage credit concentration public transportation, warehousing, and
risk. BTN has identified several industrial sectors as communications;
a reference for credit allocation, considering ESG b. Financial intermediaries;
aspects, prudential principles, and sound credit c. Healthcare services and social activities;
management. This approach ensures alignment d. Educational services;
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e. Wholesale and retail trade; internal data, national banking indicators, such as
f. Construction; Non-Performing Loan (NPL) ratios, credit yield, and
g. Real estate, leasing businesses, and corporate contribution to Corporate Budget and Business
services; Plan (RKAP) targets. This evaluation covers sector
h. Agribusiness; and and subsector performance, identifying business
i. Renewable energy. potential (pipeline) with high-risk exposure,
2. Furthermore, BTN conducts industry selection while ensuring these risks remain manageable.
based on ESG risk analysis criteria. These risks are The analysis integrates ESG aspects to ensure
determined by referring to applicable regulations alignment with sustainability principles.
and best practices, including OJK’s Climate Risk
Stress Test guidelines, Morgan Stanley Capital 4. As a form of prudential principle implementation
International (MSCI) ESG Industry Risk, and OJK and risk management inherent in each priority
Regulation (POJK) Number 51/POJK.04/2017. The industry, BTN applies the Risk Acceptance Criteria
ESG risk analysis aims to evaluate industry sectors (RAC) to evaluate the eligibility of prospective
based on their impact. The process includes debtors. BTN has established two types of RAC,
key steps outlined in the Portfolio Guideline (PG) namely General RAC and Specific RAC. General
Composite Rating Matrix, which maps industry RAC serves as the fundamental criteria that must
sectors based on business prospects and ESG risk be met by all prospective debtors across all
levels, such as emission intensity, social impact business sectors, while Specific RAC is designed to
governance quality, and others. The sectors of assess prospective debtors based on the unique
concern include: [FS5] [FS10]: characteristics of their business activities. Both
a. Transportation, warehousing, and types encompass three key aspects, namely
communications Debtor, Technical, and Financial A, each of which
b. Mining and quarrying has a different evaluation focus. The following
c. Electricity, gas, and water outlines the key differences between General
d. Agribusiness RAC and Specific RAC as a guide in the financing
e. Manufacturing industry decision-making process.
f. Construction
3. In the next stage, BTN conducts an industry BTN has established RAC for each industrial sector,
sector risk analysis to evaluate risk potential covering debtor aspects, technical aspects, and
and opportunities across sectors, supporting the financial aspects. These criteria serve as guidelines for
management of a healthy and sustainable credit BTN in marketing and distributing its wholesale credit.
portfolio. Credit allocation is determined based on
Credit Policy for High ESG Risk Sectors
As part of BTN’s commitment to support sustainability, Although BTN did not extend credit to the coal and
the Terms & Conditions of the Portfolio Guideline (PG) mining sectors throughout 2024, the Bank remains
is designed to manage credit risks related to ESG. This committed to establishing specific terms and conditions
policy ensures that credit distribution is carried out for these sectors as part of its ESG-based credit risk
selectively, particularly in priority sectors with high management. The terms and conditions for industry
ESG risks, based on conducted ESG risk assessments. sectors with high ESG risk are outlined as follows:
Through this guideline, BTN has established clear
standards to identify, evaluate, and limit exposure to
sectors that have the potential to cause significant
negative environmental and social impacts.
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Agriculture
(Agriculture,
Forestry, and
Fisheries)
The Bank establishes credit policies that require other equivalent documents recognized by
customers in this sector to: the Bank.
A. Hold a PROPER Gold or Green rating. c. Have Standard Operating Procedures (SOPs)
B. Credit will not be granted to new companies for fire prevention and fire control, standard
involved in land clearing. fire suppression equipment according to land
C. Have a Wastewater Treatment Plant (WWTP), with criteria, fire monitoring towers, and a trained
an assessment related to the availability of WWTP fire-fighting team following the Directorate
operations and compliance with established General of Plantations’ standards.
quality standards. d. Hold a Plantation Business Permit (IUP),
D. For public companies, they must have a including applicable location permits such
sustainability report. as IUP Cultivation (IUP-B), IUP Processing
E. Commit to No Deforestation, No Peat, No (IUP-P), and Plantation Business Registration
Exploitation (NDPE), covering land clearance, land Certificate (SPUP).
release, and conservation of High Conservation H. Have no social/environmental conflicts within the
Value (HCV)/High Carbon Stock (HCS) areas and past three years.
peatlands. I. For the SME segment, ISPO requirements apply
F. For the Palm Oil Plantation subsector, companies as an affirmative covenant, with compliance to
must have an ISPO and/or RSPO certification, or at be periodically monitored by the Relationship
least proof of registration in the form of a receipt Manager and subject to internal bank audits.
from a certification body. J. Hold permits for industrial forest management,
G. For the Palm Oil Plantation subsector without ISPO such as Forest Product Utilization Business Permit
and/or RSPO certification, the following criteria (IUPHHK) for Timber and/or Non-Timber Products
must be met: (IUPHHBK), and Forest Management Work Plan
a. Have a Code of Conduct, Environmental & (RKU) approved by the Ministry of Environment
Labor Policies (including Occupational Safety and Forestry.
& Health - K3). K. Not engage in business activities in areas
b. Have Environmental Management System designated as biodiversity conservation zones.
certifications, such as ISO 14001/ISO 45001 or
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Energy
The Bank establishes credit policies that require with the coal phase-out strategy according to the
customers in this sector to: valid PLN Electricity Supply Business Plan (RUPTL).
A. Credit financing in the Energy sector is limited only D. For operational power plants, companies must
to companies with good ESG implementation. have Environmental Management System
B. Hold a PROPER rating and/or at least have an certifications such as ISO 14001/ISO 45001 or other
Environmental Impact Assessment (AMDAL) equivalent documents recognized by the Bank.
report or Environmental Management and E. For operational power plants, companies must
Monitoring Effort Report (UKL-UPL) approved by have a code of conduct, policies related to
the Environmental Agency (BLH). environmental management (carbon emissions,
C. For financing new coal-fired power plant (PLTU) coal ash, water and waste management) and
projects with PLN as the offtaker, the suitability labor standards.
of the financing period must be assessed in line F. Have no social/environmental conflicts.
Coal*
The Bank establishes credit policies that require equivalent documents recognized by the Bank.
customers in this sector to: D. For financing in the coal mining sector as a
A Credit financing in the Coal sector is limited supplier for PLTU, the suitability of the financing
only to Top-Tier Corporations with good ESG period must be assessed in line with the coal
implementation. phase-out strategy according to the valid PLN
B. Hold a minimum PROPER Green rating and/or at Electricity Supply Business Plan (RUPTL).
least have an Environmental Impact Assessment E. Have a roadmap for reducing Greenhouse Gas
(AMDAL) report or Environmental Management (GHG) Emissions.
and Monitoring Effort Report (UKL-UPL) (including F. Borrowers must comply with loan agreement
reclamation and post-mining guarantees) clauses, including adherence to all applicable
approved by the Environmental Agency (BLH). environmental regulations and required
C. Hold Environmental Management System documentation. Failure to comply will impact
certifications such as ISO 14001/ISO 45001 or other loan sustainability.
*Solely as a reference for the Bank, and currently, the Bank has no financing in this sector.
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Construction
The Bank establishes credit policies that require B. Have no social/environmental conflicts within
customers in this sector to: the past four years that could impact business
A. Hold an Environmental Impact Assessment sustainability.
(AMDAL) report.
Mining*
The Bank establishes credit policies that require C. Hold Environmental Management System
customers in this sector to: certifications such as ISO 14001/ISO 45001 or other
A. Credit financing in the mining sector is limited only equivalent documents recognized by the Bank.
to corporations with good ESG implementation. D. Implement Good Mining Practice (GMP) in
B. Hold a minimum PROPER Green rating and/or at compliance with applicable laws and regulations,
least have an Environmental Impact Assessment including submission of an Annual Work Plan &
(AMDAL) report or Environmental Management Budget (RKAB) approved by the Ministry of Energy
and Monitoring Effort Report (UKL-UPL) (including and Mineral Resources (ESDM), and/or any other
reclamation and post-mining guarantees) required documents related to Good Mining
approved by the Environmental Agency (BLH). Practice.
E. Have an internal policy (code of conduct) related
to environmental and labor standards.
*Solely as a reference for the Bank, and currently, the Bank has no financing in this sector.
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Oil and Gas
The Bank establishes credit policies that require D. Implement energy efficiency measures and GHG
customers in this sector to: emissions reduction efforts in accordance with
A. Credit financing in the oil and gas sector is regulatory requirements at the business location.
limited only to corporations with good ESG For public companies, hold a Sustainability Report
implementation. or other equivalent documents.
B. Hold Environmental Management System E. Oil and gas business activities must have
certifications such as ISO 14001/ISO 45001 or other documents confirming compliance with all Oil
equivalent documents recognized by the Bank. and Gas Safety requirements (including facilities,
C. Have an Environmental Impact Assessment equipment, workers, general, and environmental
(AMDAL) report or Environmental Management safety standards), specifically proven through the
and Monitoring Effort Report (UKL-UPL) (including Supporting Business Certificate (SKUP).
reclamation and post-mining guarantees) F. No deforestation practices, including land
approved by the Environmental Agency (BLH). clearing, and no exploitation.
Transportation
The Bank establishes credit policies that require equivalent documents recognized by the Bank.
customers in this sector to: B. For public companies, they must have a
A. Hold Environmental Management System sustainability report.
certifications, such as ISO 14001/ISO 45001 or other C. Implement energy efficiency measures and
efforts to reduce emissions, with adequate
electricity and water supply availability.
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Pulp & Paper
The Bank establishes credit policies that require customers Forest Management Work Plan (RKU) approved by the
in this sector to: Ministry of Environment and Forestry.
A. Hold Environmental Management System certifications, G. Not engage in business activities in areas designated
such as ISO 14001/ISO 45001 or other equivalent as high biodiversity conservation zones.
documents recognized by the Bank. H. For pulp & paper trading, companies must provide
B. Hold a minimum PROPER Blue rating and/or at least self-declaration statements to fulfill principles and
have an Environmental Impact Assessment (AMDAL) commitments, including:
report or Environmental Management and Monitoring 1) Selling products or services that do not harm the
Effort Report (UKL-UPL) (including reclamation and environment.
post-operations guarantees) approved by the 2) Implementing more environmentally friendly,
Environmental Agency (BLH). efficient, cost-effective, and energy-saving
C. For public companies, they must have a sustainability distribution processes.
report. 3) Allocating budgets for environmentally friendly
D. Implement energy efficiency measures and efforts to marketing efforts.
reduce emissions, with adequate electricity and water 4) Avoiding excessive resource consumption.
supply availability. 5) Holding sustainability certifications, such as
E. Have a Wastewater Treatment Plant (WWTP), Industrial Forest Stewardship Council (FSC), Programme for
Waste Treatment Plant (IPLC), and Hazardous and the Endorsement of Forest Certification (PEFC),
Toxic Waste (B3) treatment facilities, proven through or equivalent environmental sustainability
documents recognized by the Bank. certifications.
F. Hold permits for industrial forest management, such 6) No deforestation practices, including land clearing,
as Forest Product Utilization Business Permit (IUPHHK) and no exploitation.
for Timber and/or Non-Timber Products (IUPHHBK) and
Biodiversity
In the industrial forest sector, Bank BTN has established a approved Business Work Plan (RKU) from the Ministry
binding credit policy for customers in this sector to: of Environment and Forestry.
1. Have documents for the management of industrial
forest permits such as Business Permit for Forest 2. Not engage in business activities in areas declared
Timber Product Utilization and/or Business Permit to have high biodiversity, including RAMSAR land
for Non-Timber Forest Product Utilization, and an material sites and IUCN Cat.1&2 sites.
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ESG-Based Products
BTN recognizes that stakeholder expectations continue while simultaneously generating positive social and
to evolve, particularly in fulfilling sustainable financial environmental impacts across its operational areas.
needs. Therefore, BTN has strategically integrated ESG Several ESG-based product innovations developed by
(Environmental, Social, and Governance) principles BTN include: [OJK B.1]
into every decision and investment transaction. This
approach allows the Bank to achieve financial gains
Low-Emission Housing
BTN is committed to contributing to the achievement with various parties to develop technological solutions
of the Sustainable Development Goals (SDGs) by that enhance energy efficiency and reduce water
developing 150,000 low-emission houses by 2029. This consumption in these houses.
initiative is a major step in BTN’s efforts to support the
transformation of Indonesia’s housing sector into a more The low-emission housing initiative is expected to
environmentally friendly and sustainable industry. In have a significantly positive environmental impact.
addition, this program aligns with government policies By using eco-friendly materials and energy-efficient
aimed at providing not only livable and healthy housing solutions, BTN estimates that it can reduce more than 1.7
but also environmentally friendly homes, considering million kilograms of plastic waste that would otherwise
the increasing urgency of climate change as a global become landfill waste and cut carbon emissions by 2.42
challenge. tons of CO2. This impact is equivalent to planting 110,000
trees, which will help absorb carbon dioxide from the
Through the low-emission housing project, BTN aims to atmosphere and improve environmental quality around
develop housing solutions that integrate sustainability the housing area.
principles, utilizing eco-friendly materials and applying
green and smart technology solutions. Based on Furthermore, this initiative is expected to absorb carbon
global housing development standards, BTN hopes to emissions across an area of 323 hectares, providing
maximize its contribution to addressing the ongoing significant benefits for local ecosystem sustainability.
global climate crisis. In addition, BTN is committed to prioritizing efficient
and sustainable resource management principles,
As part of its long-term plan, BTN targets the use of 30% encouraging housing developments to meet the
environmentally friendly materials in these housing following standards:
projects by 2029. In 2024, BTN initiated a pilot project • Energy Efficiency
incorporating a minimum of 10% eco-friendly materials. Houses constructed must have proper ventilation,
These materials include innovative components such high ceilings, and a window-to-wall ratio of 15% to
as floor decking containing 3.6 kg of plastic waste and 30%. This aims to enhance natural lighting and air
paving blocks containing 2 kg of plastic waste per square circulation, thereby reducing energy consumption
meter. This innovation not only helps reduce plastic for cooling and artificial lighting.
waste but also enhances the durability and efficiency of
construction materials used in these houses. • Water Usage
BTN applies efficient water usage equipment,
The pilot project demonstrates BTN’s commitment to such as low-flow faucets and improved sanitation
circular economy principles, where materials previously systems, which help reduce water wastage and
considered waste are now repurposed into high-value support better water resource management.
construction materials. Additionally, BTN collaborates
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• Waste Management middle-income communities. This means that BTN not
Each housing unit is required to provide waste only acts as a financial provider but also as a driver of
separation facilities, making it easier to recycle and change in creating affordable, healthy, and sustainable
manage waste efficiently. housing for all social groups.
• Green Open Spaces Collaboration between BTN and various stakeholders,
A minimum of 10% of the total residential area must including the government, developers, and communities,
be allocated for green open spaces. This is intended will ensure that low-emission housing developments
to create recreational areas that enhance residents’ not only support environmental sustainability but also
quality of life while also functioning as rainwater generate significant social and economic benefits. As
absorption zones and reducing the urban heat part of its Corporate Social Responsibility (CSR) efforts
effect. and sustainability principles, BTN remains committed
to promoting a circular economy, reducing negative
BTN prioritizes sustainability in all aspects of its operations, environmental impacts, and enhancing community
including providing financing for environmentally well-being by providing healthier and more sustainable
friendly housing developments. In addition to focusing housing. This program is also aligned with the
on environmental aspects, BTN is committed to ensuring Sustainable Development Goals (SDGs).
that the homes that are built are accessible to low- and
Green Bond
BTN has developed an ESG-based Green Bond Rp125.944 billion. Additionally, BTN has issued social
Portfolio. ESG-based green bonds are issued to finance bonds through the Sustainable Bonds VI SMF Phase I
projects that support environmental sustainability and II (2021), each valued at Rp25 billion.
while integrating Environmental, Social, and
Governance (ESG) principles. In addition to focusing As part of its ongoing commitment, BTN continues to
on environmental aspects, such as carbon emission strengthen its role in green financing by developing
reduction and renewable energy, these green bonds sustainable financial products, expanding partnerships
also consider social impacts, including community with the public and private sectors, and integrating ESG
empowerment and job creation, while ensuring that principles into every investment decision. In 2025, BTN
issuers maintain good and transparent governance. aims to issue sustainability/social bonds, which are
Projects financed through these bonds must comply expected to support sustainable projects that have a
with strict ESG standards, with transparent reporting on positive impact on the environment or society.
fund utilization and impact.
As a concrete step in supporting the development of
As of 2024, BTN has established several ESG-based sustainable financial products, BTN has also released
green bond portfolios with a total value of IDR 941.211 its Sustainable Finance Framework and successfully
billion, consisting of green bond instruments such as received the highest “Excellent” rating from the Second
SBSN amounting to Rp765.267 billion and SUKBI totaling Party Opinion (SPO) provided by Sustainable Fitch. This
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recognition signifies that BTN’s framework aligns with Through this approach, BTN is committed to identifying
the International Capital Market Association (ICMA) climate-related risks and opportunities, establishing
standards. In addition, BTN will continue to improve a clear green development strategy, and aligning its
transparency in reporting the environmental impact of business model with the promotion of a low-carbon
funded projects, in line with the principles of the Task economy to support the achievement of sustainable
Force on Climate-related Financial Disclosures (TCFD). environmental impacts.
ESG Mutual Funds
As a mutual fund sales agent, BTN has established a Through this product, BTN offers investors the opportunity
strategic partnership with Batavia Prosperindo Aset to participate in investments that are not only financially
Manajemen, one of Indonesia’s leading investment profitable but also contribute directly to achieving
managers, to market ESG-based mutual fund products. Sustainable Development Goals (SDGs). By focusing
This collaboration is part of BTN’s commitment to on companies with strong sustainability practices,
supporting the development of sustainable and socially BTN encourages investors to choose instruments that
responsible financial products, offering investment prioritize not only short-term financial gains but also
options that are not only profitable but also contribute long-term positive environmental and social impacts.
to sustainability goals.
As part of BTN’s long-term strategy, this partnership
Some of the flagship products marketed through this aims to enhance sustainable financial literacy among
partnership include Batavia Global ESG Sharia Equity domestic investors, educating them on the importance
USD, Mandiri FTSE Indonesia ESG, and Batavia Saham of responsible and sustainable investments. BTN will
ESG Impact. All three are mutual funds that integrate continue to expand ESG-based mutual fund product
ESG principles in their investment portfolios and comply offerings in the future, aligning with the growing
with sharia principles. This product focuses on stocks of awareness and commitment to sustainability in the
companies with a strong track record in environmental investment sector.
sustainability, social responsibility, and transparent
corporate governance. By prioritizing companies that
meet ESG criteria, this product promotes impact-
driven investments that benefit both society and the
environment.
Sustainable Business Activity Loan (KKUB)
As part of its commitment to sustainability and support 5. Development of Transit-Oriented Development
for the ESG roadmap, BTN has developed a Sustainable (TOD) housing integrated with transportation
Business Activity Loan (KKUB) scheme. In 2024, BTN infrastructure and public facilities.
successfully disbursed KKUB with a total loan portfolio
of Rp183.93 trillion. These loans are allocated to support Support for sustainable finance is also implemented by
various sustainability-focused sectors, including: BTN by channeling financing across various categories,
1. Development of the renewable energy sector; including construction loans, investment loans, working
2. Construction of factories utilizing renewable capital loans, corporate loans, and short-term loans.
technology through energy efficiency; All loans provided by BTN are based on a corporate
3. Sustainable management of biological resources lending scheme that prioritizes projects with positive
and land use; environmental and social impacts, such as:
4. Drinking Water Supply System (SPAM) projects;
and
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1. Corporate lending to support the operational 3. Corporate lending to accelerate electricity
needs of sustainable biological resource infrastructure development, excluding coal and its
management and land use sectors. derivatives.
2. Corporate lending to support the development of 4. Corporate lending to support drinking water
renewable energy projects. supply system (SPAM) projects.
Sustainability Linked Loan (SLL)
As part of its efforts to strengthen its commitment to • Pricing Incentive - Step Up: An incentive
sustainability and support the ESG roadmap, BTN has provided at the beginning of the SLL facility
initiated the development of policies related to the period. If the borrower fails to meet the KPIs
Sustainability Linked Loan (SLL) scheme, to support and SPTs, the incentive will be revoked, and the
BTN’s ESG goals, which align with the Sustainable borrower will be subject to an increased loan
Development Goals (SDGs) and the transition toward interest rate until the end of the loan term.
a low-carbon economy. The SLL scheme provides • Pricing Incentive - Step Down: A tiered incentive
incentives for companies to achieve their sustainability structure, where borrowers receive progressive
targets, while ensuring that projects financed by BTN interest rate reductions upon achieving the
generate positive social and environmental impacts. KPIs and SPTs targets.
Incentives are granted to borrowers upon meeting the 2. All in Fee Incentive
Key Performance Indicators (KPIs) and Sustainability This incentive is provided at the beginning of the
Performance Targets (SPTs) agreed upon in the Loan SLL facility period in the form of a reduction in fees,
Agreement (PK). The types of incentives provided by calculated as a percentage determined by the
BTN include: Bank. However, if the KPIs and SPTs are not met, the
1. Pricing Incentive Incentives may be revoked, and the debtor will be
Pricing incentives are offered to borrowers through required to pay the difference in the All-in Fee that
an interest rate reduction mechanism, with a was previously reduced if KPIs and SPTs are not
specific percentage determined by the Bank’s achieved.
calculations. These incentives are granted through
two mechanisms:
KPR Subsidies - An Outstanding Social Product
BTN is committed to supporting the government’s efforts contributes to achieving the Sustainable Development
to improve public access to banking and financial Goals (SDGs) in Indonesia.
services by providing inclusive and sustainable financial
products. A concrete example of this commitment is the As part of its efforts to support sustainable housing
development of the Subsidized Home Ownership Loan development, BTN continues to develop ESG-based
(KPR Subsidized), specifically designed for low-income financial products focused on green housing financing.
households (MBR) with low-interest rates and affordable These products include financing for energy-efficient
financing. BTN also runs financial literacy and inclusion and green building-certified homes, ensuring comfort
programs, aligned with recommendations from Bank for residents while maintaining environmental
Indonesia and the Financial Services Authority (OJK), to sustainability. BTN also ensures that environmental,
enhance public understanding of sustainable financial social, and governance (ESG) aspects are integrated
planning. By prioritizing sustainability principles, BTN into every housing loan (KPR) product, fostering a more
not only expands access to financial services but also sustainable housing ecosystem.
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Throughout 2024, BTN successfully disbursed subsidized In terms of gender, loan disbursement for female
housing loans for 118,665 units, with a total value homebuyers reached 42,114 subsidized KPR units worth
reaching Rp19.4 trillion. Among these, 102,849 units worth Rp6.9 trillion, while for male homebuyers, it reached
Rp16.8 trillion were allocated to the millennial segment, 76,551 units worth Rp12.5 trillion. BTN’s commitment
reflecting the enthusiasm of younger generations in to providing affordable housing access for diverse
homeownership. BTN also expanded its loan coverage communities reflects its efforts to promote financial
to underserved and informal sectors, with 15,192 units inclusion and equitable housing development across
worth Rp2.5 trillion disbursed to street vendors, ride- all social groups in Indonesia.
hailing drivers, and workers with irregular incomes.
Value of Subsidized Mortgage Disbursement (Rp Billion)
2022 2023 2024
19,941 20,115 19,451
Mortgage Disbursement by Gender Mortgage Disbursement by Occupation Type
35.5% 64.5% 87.2% 12.8%
Female Male Formal Workers Informal Workers
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Inclusive Mortgage Loan
1. KPR BTN Sejahtera FLPP units (flats/apartments). This program serves as a
KPR BTN Sejahtera FLPP is a homeownership follow-up to the regulations of the Public Housing
program offered by the Ministry of Housing and Savings Management Agency under the State
Residential Areas for low-income communities Public Housing Savings Bank Regulation (Perban
(MBR). This program provides low-interest rates Tapera) No. 9 of 2021, concerning homeownership
and affordable installments, making it accessible financing through the Housing Liquidity Facility.
for purchasing landed houses or public housing
Product Debtor
Description Income Limit Provisions
Name Segmentation
KPR BTN The Housing Fixed Income Unmarried: < 1. The maximum mortgage amount corresponds to the
Sejahtera Liquidity Facility – Non-Civil Rp7,000,000 house or apartment selling price, minus the down
FLPP (FLPP) is a financial Servants Married: up to payment prepared by the low-income communities
support program Rp8,000,000 (MBR). Through this program, MBR is eligible for
providing liquidity a Down Payment Assistance Subsidy (SBUM) of
for financing Rp4 million (for Java, Sumatra, Kalimantan, and
landed houses or Sulawesi) and Rp10 million (for Papua) provided by
apartment units the government.
for low-income 2. The mortgage interest rate paid by the borrower is
communities. 5% per year, which already includes life insurance,
fire insurance, and credit insurance premiums. The
interest rate, as mentioned in point (1), remains fixed
throughout the loan tenure (fixed rate), using an
annuity-based annual interest calculation method.
3. FLPP program funding sources consist of 75% from the
government and 25% from the Bank. BTN collaborates
with PT Sarana Multigriya Finansial to provide funding
allocations for the FLPP program.
4. The mortgage tenure is agreed upon by BTN and
the MBR, adjusted according to the borrower’s
repayment capability, with a maximum term of 20
years.
2. KPR BTN Tapera Savings Program (Tapera). This program aims to
KPR BTN Tapera is a homeownership loan facility assist ASN in purchasing their first home under
specifically designed for Civil Servants (ASN) favorable terms and conditions.
registered as participants of the Public Housing
Product Debtor
Description Income Limit Provisions
Name Segmentation
KPR BTN KPR Tapera is Fixed Income – Unmarried or 1. The maximum mortgage amount corresponds to
Tapera a housing loan Civil Servants married with the house or apartment selling price, minus the
facility provided by (PNS) income up to down payment prepared by the borrower (MBR),
BTN to low-income Rp8,000,000 who must have been a Tapera participant for at
households (MBR) least 12 months.
participating 2. The mortgage interest rate paid by the borrower is
in Tapera, for 5% per year, which already includes life insurance,
purchasing fire insurance, and credit insurance premiums. The
landed houses or interest rate, as mentioned in point (1), remains fixed
apartment units. throughout the loan tenure (fixed rate), using an
annuity-based annual interest calculation method.
3. KPR Tapera funding sources come from participant
contribution savings.
4. The mortgage tenure is agreed upon by BTN and MBR,
adjusted according to the borrower’s repayment
capability, with a maximum term of 30 years.
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In addition to BTN Tapera Mortgage (KPR BTN Tapera), housing. By offering inclusive financial solutions, BTN
the bank also offers Tapera Home Renovation Loan strengthens its role in supporting the government’s
(KRR Tapera) and Tapera Home Construction Loan (KBR Tapera Program while aligning with its sustainability
Tapera). These products provide affordable financing commitment to enhance housing access and promote
access for the public to renovate or build decent sustainable finance practices.
Electric Vehicle Credit Disbursement
BTN has provided electric vehicle loans to facilitate Additionally, BTN ensures that electric vehicle credit
public access to eco-friendly transportation with financing aligns with ESG principles, promoting green
various benefits, including affordable installments, technology and encouraging the adoption of cleaner
unconditional discounts, 0% down payment (DP), flexible and more efficient transportation solutions. This
loan terms, and waived provisioning and administrative product not only improves public access to electric
fees. Throughout 2024, BTN financed 52 electric vehicle vehicles but also contributes to long-term sustainability
units, with a total credit value of Rp877,412,000. This by accelerating the shift to clean energy-based
initiative is part of BTN’s strategy to support the transition transportation in Indonesia.
to sustainable mobility and reduce the carbon footprint
in the transportation sector.
Green Initiative Program
BTN is committed to supporting environmental
conservation through various initiatives involving
active customer participation. One of the flagship
programs is “Flash Sale balé Poin Peduli Lingkungan”,
where customers can exchange their balé points for
mangrove tree planting contributions in Mangunharjo,
Semarang. This program offers customers the choice
to redeem points for various rewards, including the
opportunity to participate in environmental activities
through mangrove tree planting. By the end of 2024, the
program successfully collected a total of 775 mangrove
trees from balé point redemptions by customers. BTN
targets to reach 1,000 mangrove trees by March 2025
as part of its ongoing sustainability efforts to support
coastal ecosystems and mitigate climate change
impacts.
Additionally, BTN has introduced the “Tabungan BTN
Siap! Dapat Pohon” program, wherein every opening
of a Tabungan BTN Siap! account with a minimum As of now, 22 accounts have been registered under
deposit of Rp105,000 and a tenure of at least 12 months this program, resulting in the planting of 22 additional
will contribute to the planting of one mangrove tree. mangrove trees in the Mangunharjo area, Semarang.
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Digital Innovation for Modern Services [OJK F.26]
As a leader in financial inclusion in Indonesia, BTN is also strengthened its digital service channels, allowing
committed to continuously expanding financial access customers to access banking services without location
through strategic, innovative, and technology-driven constraints. The balé by BTN platform, with a user base
service channels. As of 2024, BTN has introduced various of 2,220,256, caters to a diverse range of customers.
initiatives to address Indonesia’s geographical and BTN also offers alternative payment channels, including
demographic challenges, ensuring that all segments of 3,389 EDC merchants and 125,082 QRIS BTN points
society, particularly those in remote areas, can benefit strategically distributed to facilitate seamless digital
from broader financial inclusion. Through a technology- and banking transactions. Furthermore, BTN has
driven approach, BTN not only provides access to 5,000 agents across Indonesia, playing a crucial role
banking services but also empowers communities to in extending financial services, particularly in areas
manage their finances more independently. previously underserved by traditional banking.
As part of this commitment, BTN has expanded financial As part of its sustainable financial inclusion strategy,
access to more than 20 million Indonesians, including BTN remains committed to continuous technological
those in underserved segments. Throughout 2024, innovation. One key initiative is the development of
BTN successfully operated 82 Branch Offices and 536 an AI-powered mobile banking application, designed
Conventional Sub-Branch Offices, along with 35 Sharia to offer a faster, more secure, and more convenient
Branch Offices and 75 Sharia Sub-Branch Offices, banking experience. This application enables customers
serving as financial service points across Indonesia. to manage their finances more efficiently, from daily
These financial service points are strategically located transactions to housing loan applications, with a user
and offer personalized, adaptive banking services to experience tailored to individual needs.
meet the needs of customers in both urban and rural
areas, including housing financing. Through these strategic initiatives, BTN is not only
expanding its financial service reach but also ensuring
Additionally, BTN provides self-service banking that all societal segments, whether in cities or remote
through 1,053 ATMs, 1,018 CRMs, and three digital areas, can access the banking services they need. By
branch stores operating 24/7, enabling customers continuously innovating and leveraging technology,
to conduct transactions at any time without visiting BTN plays an active role in fostering more inclusive and
a physical branch. Beyond ATMs and CRMs, BTN has sustainable financial accessibility across Indonesia.
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balé by BTN
balé by BTN is a super app developed as a
transformation of the BTN Mobile application. This
app is designed to simplify financial transactions for
Indonesians, including banking and financial services.
balé by BTN emphasizes easy financial management
and practical transactions, offering customers
greater convenience in managing their daily financial
activities. Moreover, this service is a strategic initiative
to overcome geographical challenges, ensuring that
all segments of society, particularly those in remote
areas, can experience the benefits of broader financial
inclusion. In 2024, the service successfully reached
communities in underserved areas, covering 20,183
users, in line with Presidential Regulation of the Republic
of Indonesia Number 63 of 2020.
The advantage of balé by BTN lies in its ability to
integrate with various other BTN services, such as BTN
Properti, BTN Smart Residence, BTN Merchant, and more.
This application also supports recurring payments for
various household or business needs, including utilities
(electricity, clean water/PDAM, mobile credit and data
packages), environmental management fees (IPL), as
well as security, parking, and property maintenance
services. Additionally, balé by BTN offers exclusive
features, including:
1. Online Account Opening, customers can open
an account easily and quickly without visiting a
branch, anytime and anywhere.
2. Single Sign-On, a unified login system that allows
seamless access to all BTN services without
switching platforms.
3. Cardless Transactions, this feature enables
customers to withdraw cash from BTN ATMs
without a physical card, using only the application.
4. Auto Debit System, customers can schedule
recurring bill payments automatically, ensuring
timely payments without manual intervention.
5. Auto Transfer, this feature simplifies scheduling
periodic fund transfers to other accounts, both
within BTN and to other banks, as needed.
6. Cashflow Tracker, customers can easily monitor
their income and expenses, helping them manage
personal finances more effectively.
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7. Split Bill, this feature allows customers to services and conducting business activities. With
conveniently split payments with friends or branchless banking services, customers can
family via the application. access banking services anytime and anywhere,
bringing the services closer to customers while
The balé by BTN application also serves as creating new opportunities for business growth.
a comprehensive solution for MSME (Micro, The service allows MSME customers to manage
Small, and Medium Enterprises) players who their businesses more easily and handle various
require greater flexibility in accessing banking routine obligations efficiently.
Transactions Using balé by BTN
Description Unit 2024 2023
Number of Transactions (Financial and Non-Financial) Transactions 1,236,560,040 414,881,411
Transaction Value Rp Billion 81,110,667 57, 542,089
Registered Users Users 2,220,256 2,690,546*
Number of Acquisitions Acquisitions 1,248,573 1,138,653
* In 2023, the migration process took place from BTN Blue Mobile Banking to the superapp balé by BTN.
As part of BTN’s commitment to supporting digital users reflects the Bank’s success in providing easy,
transformation and promoting financial inclusion, secure, and inclusive digital payment solutions.
the adoption of QRIS (Quick Response Code
Indonesian Standard) has become a key feature of Below is data on QRIS transaction volume and
balé by BTN. The increase in QRIS transactions and users in 2024:
Transactions Using QRIS
Description Unit 2024 2023
Number of Merchants Merchants 125,082 15,602
Number of Transactions Transactions 17,397,145 3,522,542
Transaction Value Rp Billion 1,347 302
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BTN Digital Branch
The Bank continues to transform to enhance networks, including the exclusive authority of BTN
sales capacity and customer-oriented services. Digital Store services.
Currently, a crucial role in providing direct services
to customers is offered through branch offices, sub- There are three types of BTN Digital Store branches:
branch offices, and other networks. As technology
evolves, the Bank’s services must also adapt and 1. Flagship Branch
shift toward digital banking solutions. One form of Flagship Branch is the most comprehensive
transformation is integrating digital services into type of BTN Digital Store, designed to attract
branch offices through the implementation of BTN customers to the bank while reinforcing BTN’s
Digital Store. brand image as a modern and innovative
bank.
BTN Digital Store aims to offer customer-centric
services. The implementation is expected to deliver a 2. Digital Oriented Branch
unique service experience, focusing on transaction Digital Oriented Branch is a type of BTN Digital
convenience, effectiveness, and efficiency, ensuring Store designed to introduce digitalization to
a practical and secure experience. Additionally, BTN selected branch locations.
Digital Store is helping to increase sales capacity
and enhance employee productivity in service and 3. Digital First Branch
sales activities. To support the implementation Digital First Branch is a type of BTN Digital
of BTN Digital Store, adjustments will be made to Store designed to provide banking services
organizational structures, roles, and responsibilities to customers in strategic locations such as
within branch and sub-branch offices, and other shopping centers, transit hubs, central business
districts, campuses, and so on.
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BTN Smart Residence
BTN Smart Residence is a platform designed to connect
residents and property managers for bill payments,
fees, information exchange, and complaint resolution.
• Web-based platform for Residence Admin/Property
Management
• Mobile-based platform (Android and iOS) for
Residents (End Users)
Benefits of BTN Smart Residence
Benefits for Property Managers
• Easy
Simplifies bill reconciliation for property managers.
• Prosper
Provides economic benefits for property developers/
managers.
• Communication Platform
Facilitates information updates related to the
residence.
Benefits for Residents
• Convenient bill payments
Enables residents to pay bills anytime, anywhere.
• Complaint submission platform
Allows residents to quickly report complaints to the
property manager.
• Residence maintenance fee payments
Facilitates payments for management fees, parking
fees, and other residential maintenance costs.
Features of BTN Smart Residence
• Residence and Tenant Management
Property managers can organize residents based
on clusters/towers, blocks/floors, and unit numbers.
• Billing Management
Property managers can input and manage
individual residents’ bills.
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• Information Management • Complaint Management
Property managers can distribute updates Property managers can track and manage
and important announcements related to the reported complaints from residents.
residence.
Transactions in the BTN Smart Residence Application
Description Unit 2024 2023 2022
Registered Users People 13,945 8,915 5,605
Number of Transactions Transactions 43,602 16,973 16,053
Transaction Volume Rp Million 11,830 7,458 2,762
Mobile Interface of BTN Smart Residence
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BTN Properti
BTN Properti is a platform designed to facilitate • Loan Simulation
home purchases, property searches, and access Consumers can calculate their loan
to 3D viewing features through the latest digital application to determine the estimated
technology. BTN Properti offers a diverse selection installment amount.
of properties from developers that have partnered • Online Loan Application
with BTN across Indonesia. Consumers can submit loan applications
online.
Key Features of BTN Properti • Loan Application Tracking
• Search Consumers can monitor the status of their
Consumers can search for properties based loan applications.
on location, developer name, or housing • 4D Tour Service
complex name. Consumers can virtually visit show units using
a four-dimensional (4D) tour feature.
Number of Registered Users on the BTN Properti Platform
2022 2023 2024
309,429 515,339 747,456
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balé Bisnis
balé Bisnis is the rebranding of BTN Internet Banking • High transfer limits
Business services, designed to facilitate MSME • Registration SLA of 1 x 24 hours
(Micro, Small, and Medium Enterprise) customers • Scheduled transactions
who have a BTN Business Savings Account to • Bulk transfer
manage and grow their businesses. Its unique • Payroll services
selling points include: • Cash flow tracker
• Soft token in Balé by BTN • Account statement in XLS, PDF, and MT940
• Single / multiple authorization formats
Transactions of balé business (Financial and Non-financial transactions)
Description Unit 2024
Total Transactions (Financial and Non-Financial) Transactions 3.751
Transactions Value Rp Billion 59,962
Registered Users Users 843
Number of Acquisitions Acquisitions 732
*2024 is the migration process from BTN Internet Banking Business to balé business
balé bisnis display
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BTN Cash Management
BTN Cash Management is a service that enables Features of BTN Cash Management include:
institutional customers to conduct various financial • Account information
and banking transactions via the internet. These • Funds transfer
transactions can be performed online and in real- • Payment
time, without time or location constraints, in a • Purchase
secure and convenient manner. • Liquidity Management
• MPN Payment Management
• Pertamina Service
Corporate Internet Banking Transactions
Description Unit 2024 2023 2022
Total Transactions (Financial Transactions 1,552,528 4,060,849 2,206,654
and Non-Financial)
Transaction Value Rp Billion 218,317,614 164,172,574 88,204,540
Registered Users Users 17,585 14,663 11,922
Total Acquisitions Acquisitions 3,917 3,034 2,361
BTN CRM (Cash Recycle Machine)
Unlike ATMs, which only provide cash withdrawal disabilities. This commitment is demonstrated
services, CRM (Cash Recycling Machine) enables through the provision of inclusive facilities and
customers to conduct both cash withdrawals and infrastructure, such as ATMs and designated lanes
deposits, facilitating transactions that are more equipped with Braille features for visually impaired
convenient, efficient, and real-time. In delivering customers, as well as dedicated access routes
these services, BTN is fully committed to ensuring for customers using wheelchairs. Thus, Bank BTN
equitable service quality for all customers, including ensures that all customers, without exception, can
those with specific needs, such as individuals with enjoy services comfortably and easily. [FS14]
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Fair Advertising Policy
As part of its commitment to good corporate there are hidden costs. Information related to money-
governance and sustainable business practices, back guarantees must be explained transparently, and
BTN implements a fair advertising policy (KK.9-Y) on consumer testimonials may only be used if they have
Marketing Communication Activities to build trust been verified with a written statement.
with consumers and maintain business integrity.
Transparent, accurate, and non-deceptive advertising In the advertising process, BTN considers the appropriate
is a top priority in marketing communications. audience, selects suitable media, and chooses strategic
The bank ensures that all information conveyed in airing times to avoid negative impacts on consumers.
advertisements is accurate, clear, and not exaggerated Regular evaluations are conducted to measure the
without accountable evidence. The language used effectiveness of campaigns and ensure compliance
must be easy to understand by consumers and free of with applicable policies. The results of these evaluations
superlative claims without valid data. Additionally, the serve as the basis for improvements and innovations in
company is committed to not displaying content that is future marketing communication strategies. To ensure
discriminatory or harmful to specific groups in society. transparency and accuracy, BTN routinely evaluates
advertising content to prevent the spread of misleading
To ensure fair advertising, the company sets or biased information. Additionally, the bank provides
communication standards that include the use of training to marketing and communication teams to
language in accordance with the Enhanced Spelling ensure a deep understanding of ethics and integrity
System (EYD) and prohibits terms such as “free” if in conveying information. This training includes topics
such as marketing ethics, advertising regulations, and
corporate social responsibility.
Employee Training on Advertising and Marketing
Number of Employees
Training Name Total Training Hours
Trained
Becoming Effective Sales & Service Leader 81 648
Business Advisory for Corporate Clients 132 3.168
Business Advisory for Industrial Clients 30 720
Credit Process Consumer Loan Training 299 2.392
Selling Skill Training: Sales Strategy 63 1.008
Service Communication Loan Off Training 146 1.168
Sustainable Finance & Business Opportunities 21 168
Syndicated Credit Sustainable Finance 42 672
Bankruptcy Resolution & Debt Postponement 41 328
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Oversight Of Financial Products
BTN is committed to ensuring that all financial products 3. Determining corrective actions related to product
and services meet high standards in terms of fairness, development and reporting them to the Board of
security, and compliance, while also mitigating Directors.
potential risks. Every product and service, whether
new or updated, is designed with customer needs in With strict supervision, the Business Committee ensures
mind, including features, convenience, reliability, and that both the development and discontinuation
regulatory compliance. Before launch, all products and of products consider risk management, customer
services undergo a comprehensive testing process satisfaction, and BTN’s long-term strategic
to ensure customer data privacy protection and objectives. Additionally, BTN also focuses on the
transaction security in accordance with established social, environmental, and economic impact of its
standards. This is part of BTN’s risk mitigation efforts to products and services by conducting regular impact
prevent service disruptions and maintain data integrity. assessments through a systematic approach. This
ensures that products not only meet quality standards
The evaluation process for financial products and but also provide positive benefits for customers and
services is conducted regularly to ensure compliance society.
with security standards and applicable regulations, as
well as to identify and mitigate risks that may arise during The assessment process includes input from reviewers
product and service development. Supervision of this and control owners, historical evaluation reports,
process is carried out by the Business Committee, which alignment analysis based on internal and external
consists of Board of Directors and SEVP members. The standards, and follow-up reports related to impact
Business Committee is responsible for the formulation, and regulatory compliance. These assessments are
decision-making, oversight, monitoring, and evaluation conducted at least once a year, or more frequently if
of policy implementation and strategic planning significant changes occur in products or regulations. The
related to products and activities launched by BTN. The results of these assessments are used to refine policies
committee also monitors business developments and and procedures to improve the quality of inclusive and
provides recommendations for improvements. The sustainable financial services.
Business Committee operates based on Special Policy
No. KK.9-D on the Governance Procedures of the Board In 2024, product supervision effectiveness was measured
Committees and plays a key role in product and service through regulatory compliance, customer satisfaction,
oversight and decision-making. and financial inclusion achievements. BTN utilizes a
1. Responsible for decisions made during Business customer feedback loop to improve product quality.
Committee Meetings and Board of Directors Regular evaluations ensure that products meet security
Meetings; and compliance standards while delivering maximum
2. Responsible for reporting significant decisions to benefits and considering social and environmental
the Board of Directors at least once a year; impacts. A structured oversight system at the board
and committee level reinforces BTN’s commitment to
risk management, ensuring reliable, secure products
that contribute to sustainability and data integrity.
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Customer Data Privacy and Security
In managing the implementation of information 12. Technical Guideline Number PT.8-C.1 regarding
technology (IT), BTN has established IT governance from Technical Guidelines for the Implementation of
the management, planning, development, operational Business Impact Analysis (BIA).
infrastructure, and security levels of its information 13. Technical Guideline Number PT.8-C.2 concerning
technology systems. The bank also conducts regular Technical Guidelines for Implementing the
periodic reviews of IT governance by disclosing them Business Continuity Plan (BCP).
in the General Policy on Information Technology, Data 14. Technical Guideline Number PT.8-C.3 concerning
Management, and Digitalization. This policy regulates IT Technical Guidelines for Implementing the Disaster
governance at a high level. Recovery Plan (DRP).
15. Technical Guideline Number PT.5-D.1 concerning
BTN has also developed derivative policies in the Technical Guidelines for IT Standardization.
form of specific policies that focus more on technical 16. Technical guidelines Number PT.8-E.1 concerning
aspects and provide detailed guidelines for policy Technical Guidelines for the Implementation of IT,
implementation. These specific policies aim to provide Digital and Cyber Risk Management.
more structured implementation and supervision
guidance according to operational needs. They cover BTN recognizes the importance of information
the business unit and subsidiaries of BTN, including the technology (IT) as a key element in ensuring smooth
entire data cycle, from collection, processing, storage, and efficient business operations. Given that IT policies
to data disposal. By 2024, BTN will have the following IT cover a broad and complex range of aspects, the Bank
policies and technical guidelines in place: divides IT governance into three main domains, each
1. General Policy Number KU.5 on IT, Data with a distinct role and focus. First, “Change the Bank”,
Management and Digital General Policy. which focuses on IT system planning and development.
2. Specific Policy Number KK.5-A on Specific Policy Second, “Run the Bank”, which focuses on IT operations
for IT Procedures. and ensuring the reliability of the infrastructure and
3. Special Policy Number KK.5-B on IT Security Special systems used by both the bank and customers. Lastly,
Policy. “Secure the Bank”, which focuses on maintaining the
4. Special Policy Number KK.5-D concerning IT security of the Bank’s systems and applications to
Standardization Special Policy. protect them from IT security threats. [GRI 3-3]
5. Special Policy Number KK.8-C concerning Business
Continuity Management (BCM) Special Policy. With the rapid advancement of information technology
6. Special Policy Number KK.8-E concerning Special and increasing customer demand for more practical
Policy on IT, Digital and Cyber Risk Management banking transactions through digitalization, significant
Procedures. challenges have emerged in maintaining security
7. Special Policy Number KK.9-D regarding within the “Secure the Bank” domain. One of the
Special Policy on Board of Directors Committee biggest challenges is ensuring that digital services
Governance Procedures. remain secure from increasingly complex threats,
8. Special Policy Number KK.5-2 regarding Special such as cyberattacks. BTN acknowledges that while
Policy on Electronic System Deployment. digitalization enhances customer convenience, it also
9. Technical Guideline Number PT.5-A.1 concerning makes services more vulnerable to potential threats due
Technical Guideline for IT SOP. to the shift in customer preferences from conventional
10. Technical Guideline Number PT.5-B.1 regarding banking channels (such as branches or face-to-face
Technical Guidelines for Implementation of services) to digital platforms.
Information Security Management System (ISMS).
11. Technical Guideline Number PT.5-B.2 regarding Responding to this, BTN has taken the initiative to
Technical Guidelines for Information Technology strengthen digital security systems through various
Security Baseline. proactive and reactive approaches to data breaches
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and cyber threats. In delivering digital services, the Excellence Program: Strategies for Driving
Bank remains committed to continuous adaptation High Performance, Training and Certification
and security enhancements by implementing a three- in Banking Risk Management, Certified Chief
pillar approach designed to protect customer data and Information Security Officer (CCISO) Training,
transactions from potential threats. This approach aims ISMS Lead Auditor/Lead Implementer ISO
to ensure that digital services remain secure, reliable, 27001:2022 and Microsoft 365 Administrator.
and protected from cyber risks. The three pillars include: In addition, the Bank also conducted forums
1. People and workshops including BSSN National
Strengthening information security from the Cyber Exercise 2024, Managing Cyber Security
people aspect includes activities such as: Workshop, CISO Forum, External National Cyber
a. Security Awareness Exercise, AI Technology Workshop, Stamp Duty
BTN has conducted regular security awareness Regulation Implementation Workshop and AI
programs for all employees, customers, and Knowledge Based Project.
third parties collaborating with the Bank.
Various media are used to deliver security 2. Process
awareness messages to employees, such To ensure good governance in compliance with
as emails, bulletins, desktop wallpapers on applicable standards and regulations, BTN’s
employee work devices (updated monthly), work processes are based on the latest SOPs,
as well as online and offline socialization. which have been disseminated and consistently
Educating customers on information security implemented by all stakeholders. In line with these
is a priority, ensuring they can conduct standardized operational processes, the Bank has
transactions securely and remain vigilant undertaken the following initiatives:
against cybercrime to protect their personal a. Establishment of the Computer Security
information. Regular training is also provided Incident Response Team (CSIRT) has
for customers working with BTN to ensure they collaborated with regulators and is supported
safeguard both their company’s and BTN’s data. by the latest technology and a monitoring
Socialization efforts for customers and third system through Security Incident and Event
parties collaborating with BTN are carried out Management (SIEM)
through BTN’s e-channels, BTN’s social media b. Regular cybersecurity testing processes
platforms (Instagram, X, Facebook, etc.), and on network, system, and data security in
various offline events or marketing activities accordance with regulatory requirements,
organized by the Bank. BTN continuously including
enhances employee professionalism and • Cybersecurity testing based on vulnerability
cybersecurity competency as customer analysis, such as conducting vulnerability
partners through various training programs assessments and penetration tests for new
and cybersecurity certifications. applications, application development,
b. Competency Development and regular applications. These tests are
Throughout 2024, the Bank has conducted IT performed based on application criticality
Security-related training and certifications to levels by independent external parties
strengthen both soft skills and technical skills, certified under international penetration
including Certified in Risk and Information testing standards and registered with the
Systems Control (CRISC), CompTia Security+, Indonesian Payment System Association
Security Tools on DevSecOps Toolchain, (ASPI).
Coaching & Strategic Business Leaders for • Cybersecurity testing based on scenario-
Department Head, Business Performance based exercises, including tabletop
Through Effective Coaching for Leaders, BUMN exercises, social engineering exercises
School of Excellence (BSE) - CTO Masterclass using phishing techniques via email, and
Year 2024, Leadership Development: Adversarial Attack Simulation Exercises
Performance Management Strategies, Problem (AASE). Tabletop exercises are conducted by
Solving & Decision Making, Performance CSIRT, comprising multiple working units, to
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perform regular attack scenario tests aimed include Network Access Control (NAC), Endpoint
at reviewing the attack scenario playbook, Protection improvements for servers, Network
response, and recovery. Topics covered Time Protocol (NTP) improvements, Data Loss
include: Prevention (DLP), Cyber Threat Intelligence and
• Data Breach Guidelines Digital Right Protection, Mobile Application Security
• Snapshot Server DFIR enhancements, DNS Security improvements,
• Chain of Custody Internet Access Control and Proxy Outbound
• Forti-VPN-User Geography Change improvements, email security improvements,
(Velocity) transaction infrastructure availability and resilience
• Server Forensics improvements with active-active security
• Insider Threats implementation, API security improvements,
• Social Engineering Internet Banking Business security enhancements,
• Data Breach Incidents application security improvements through
• Ransomware managed digital application protection services,
• Operational/Management Incidents database security improvements, and IT system
• Web Application Attacks security enhancements based on Microsoft
technologies.
c. During the second quarter of 2024, BTN a. Implementation of Network Access Control
conducted a Cyber Security Maturity Re- (NAC)
assessment by the National Cyber and Crypto This technology functions to regulate, verify,
Agency (BSSN) to evaluate the maturity level and monitor device access to networks based
of IT security. The assessment resulted in a on security policies, ensuring data protection
maturity level of 5 (Optimal Implementation), from unauthorized access and potential
indicating that security measures are highly threats.
effective and fully implemented across the b. Improvement of Endpoint Protection
organization. technology for servers
d. BTN conducted the ISO 27001:2013 Surveillance This enhancement is designed to identify,
Audit in the second quarter and transitioned prevent, and respond to threats affecting
to ISO 27001:2022 in the third quarter of 2024. network-connected devices, such as malware,
As of now, the Bank is certified under the ISO ransomware, and other harmful activities,
27001:2022 security standard. Data protection ensuring data protection against leaks,
has been fully integrated into the development damage, or theft through real-time detection
of products and services to ensure customer and protection.
security and trust. c. Improvement of Network Time Protocol (NTP)
e. In support of government and regulatory This measure ensures accurate time
programs aimed at combating online gambling synchronization across networks, helping
and fraudulent transactions involving accounts maintain correct timestamps for audit logs,
falsely claiming to represent BTN customers, preventing data manipulation, and supporting
the Bank has implemented cyber patrols using system security by ensuring time consistency in
its Cyber Threat Intelligence (CTI) tools. customer data encryption and authentication
protocols.
3. Technology d. Improvement of Data Loss Prevention (DLP)
Throughout 2024, BTN continuously enhanced IT technology
security capabilities by optimizing defense-in- As part of its commitment to protecting
depth strategies This consists of multiple security customer data, BTN has implemented Data
layers, including endpoint security, application Loss Prevention (DLP) technology to mitigate
security, network security, IT infrastructure the risk of customer and corporate data
security, and data security. These enhancements breaches.
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e. Improvement of Cyber Threat Intelligence and k. Improvement of API Security
Digital Right Protection technology As open banking adoption increases, so does
To enhance IT security visibility, BTN has the risk of API-based cyber threats. Therefore,
implemented Cyber Threat Intelligence API security enhancements have been
(CTI) technology, which actively monitors implemented to detect and prevent API-based
cybercriminal behavior and activities, allowing attacks.
the Bank to anticipate potential threats. l. Improvement of Internet Banking Business
The Cyber Threat Intelligence (CTI) system (IBB)Security
is equipped with Digital Right Protection To support business banking services for
capabilities, enabling the takedown of MSMEs, BTN has introduced a web-based
harmful content that may damage the Bank’s Internet Banking Business platform. As part
reputation and negatively impact customers. of this, web application security has been
f. Improvement of Mobile Application Security enhanced, and content delivery network (CDN)
To protect mobile applications used by technology has been integrated to improve
customers, BTN has adopted a security- website performance.
by-design approach in its application m. Improvement of Application Security through
development process. Strengthening the Manage Service Digital Application Protection
security of customer access devices has also With increasing digital transactions via mobile
been prioritized through the implementation of banking, comprehensive security measures
Mobile Application Security measures. have been implemented to protect both
g. Improvement of DNS Security and IP Address the technology and operational monitoring
Management aspects of mobile banking applications.
As a mitigation measure to protect internal n. Improvement of Database Security
IT systems accessing online resources, DNS As digital transactions grow, so does database
Security has been enhanced to prevent access activity. Therefore, specific security
access to unsafe websites. The optimization measures have been put in place to limit and
of DNS security is combined with IP address prevent database exploit-based cyberattacks.
management, ensuring traceability of o. Improvement of IT System Management and
endpoints accessing these IT resources. Security Based on Microsoft Technologies
h. Improvement of Internet Access Control and Due to the extensive use of Microsoft
Proxy Outbound technologies in BTN’s operations, including
To separate and identify data communications Windows operating systems, Active Directory,
between transactional business activities and MSSQL databases, Microsoft Office productivity
internal office productivity communications, applications, and Office 365 cloud services,
improvements have been made to Internet security risks can arise if these systems are not
Access Control by implementing separate managed according to best practices. Through
internet access and outbound proxy solutions. collaboration with Microsoft professional
i. Improvement of Email Security services, BTN has implemented the latest
To protect devices and email systems from security measures, enhanced operational
cyber threats, security measures have been support, and gained access to cutting-edge
strengthened against spam, phishing, and technology from Microsoft.
malicious email attachments.
j. Enhancement of Infrastructure Availability and In its efforts to safeguard customer privacy and
Resilience information security, BTN adheres to two fundamental
By implementing active-active security principles of utmost importance. First, all customer data
infrastructure, BTN ensures the reliability of its obtained through the services provided are considered
transactional banking services. confidential, meaning that the Bank must ensure this
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information is meticulously protected and not disclosed 4. Financial Services Authority Regulation (POJK)
without consent. Second, with the rapid advancement Number 44 of 2024 on Bank Secrecy;
of technology, more data is processed through digital 5. Law No. 27 of 2022 on Personal Data Protection;
applications, increasing the potential risk of cyber 6. Special Policy No. KK.9-M on Data Governance
threats that could compromise data security. Guidelines; and
7. Special Policy No. KK.9-Z on Customer and
To mitigate the risk of data breaches, BTN has Community Protection.
developed a highly secure internal storage system, with
stringent controls to ensure the protection of customer In line with these regulations, BTN has issued Special
information. Additionally, BTN not only relies on security Policy on Information Technology Security No. KK5-B
systems to protect data but is also committed to and Special Policy on Personal Data Protection No.6-K.
ensuring that customer data will not be used for any This policy regulates various aspects to ensure that all
purpose beyond the explicit consent of the customer or information regarding personal data and customer
in compliance with applicable laws. [OJK F.27] data is maintained in accordance with the principle
of confidentiality, integrity, and availability, supporting
To ensure customer data security, BTN has established business success. Through this policy, the Bank aims to
an Operational and Digital Risk Management Unit enhance necessary data protection efforts to ensure
focused on managing operational, information smooth operations and create safer, more organized,
technology (IT) and digital risks. This Unit ensures that well-managed, and auditable activities to uphold the
all technology services provided by the Bank are secure company’s reputation. [SASB FN-CB-230a.2]
and reliable by managing risk for each technological
solution developed by the Bank. The Bank also identifies data security risks through:
1. Policies in Record Security Management;
BTN’s commitment to customer privacy and data 2. Retention of sensitive information;
security also reflects compliance with the following 3. Identification of critical records;
regulations: [GRI 418-1] 4. Storage of critical records;
1. Law No. 10 of 1998 on Amendments to Law No. 7 of 5. Storage of business source documents;
1992 concerning Banking; 6. Storage of application transaction data;
2. Financial Services Authority (OJK) Regulation No. 7. Destruction of information;
1/POJK07/2013 on Consumer Protection in the 8. Storage of sensitive information; and
Financial Services Sector; 9. Storage of security violations and issue information.
3. OJK Circular Letter No. 14/SEOJK/2014 on
Confidentiality and Security of Consumer Data
and/or Personal Information;
Responsibilities and Oversight of Data Privacy and Security
To ensure effective information security management, 5. Information Asset Owner (IAO).
BTN has established a dedicated organizational 6. Information Asset Custodian (IAC).
structure with clear roles, responsibilities, and authorities, 7. Head of Working Unit.
while implementing a dual control system to separate 8. Information Security Management System (ISMS)
duties and accountability in IT operations. Team.
9. Cyber Security Incident Response Team (CSIRT).
The Information Security Organization consists of: 10. Compliance Working Unit.
1. Board of Commissioners. 11. Operational & Digital Risk Management Working
2. Information Technology Steering Committee Unit.
(KPTI). 12. Employees.
3. Director in Charge of Information Technology. 13. Third Parties.
4. Information Security Manager (ISM).
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Financial Protection Training
As an additional measure for customer financial of security awareness initiatives in mitigating
protection, the Bank has undertaken various initiatives, cybersecurity and information security risks. This
including training users on IT security, installing authorized program is delivered monthly by Top Management,
and regularly updated software, and implementing emphasizing that information security is a critical
password management or standardization to ensure aspect of maintaining customer trust and Bank’s
that protected data remains secure. Additionally, the reputation.
Bank conducts regular evaluations to ensure that its
data security architecture is highly effective in protecting 2. Awareness Campaigns Through BTN Digital
customer data. The effectiveness of these efforts are Platforms
evidenced by the absence of any customer data a. Official BTN website
security complaints, such as loss, theft, or unauthorized b. Podcasts
disclosure, throughout 2024. [GRI 418-1] [SASB FN-CB-230a.2, FN- c. Learning Management System
CB-230a.1] d. Email Blast Security Awareness
e. Security Awareness Desktop Wallpaper
BTN has implemented an IT Security Awareness f. Security Awareness Screen Saver
Program aimed at enhancing employee awareness g. Security Awareness Bulletin
and understanding of information security, particularly h. Security Awareness Understanding Survey
regarding personal and corporate data protection. The
activities conducted throughout 2024 include: 3. Training and Workshops
1. Top Management Communication BTN has conducted both offline and online
One of the strategies to foster a security culture awareness activities for all employees. In this
among all employees across the Bank’s business reporting year, the Bank has also organized
units is the implementation of the IT Security training programs to enhance employee
Index Program, which monitors the effectiveness capabilities in data privacy, cybersecurity, and
financial protection, including:
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Employee Training on Data Privacy and Cybersecurity
Training Program Date Participants Training Hours
CRISC March 25-28, 2024 2 64 hours
ISMS Lead Auditor/Lead Implementer ISO 27001:2022 August 26-30, 2024 2 80 hours
Comp Tia Security+ March 18-21, 2024 6 192 hours
April 1-4, 2024
Certified Chief Information Security Officer (CCISO) July 1-4, 2024 2 64 hours
Training
BSSN National Cyber Exercise 2024 March 18-21, 2024 3 96 hours
Cyber Security Management Workshop May 7-8, 2024 1 16 hours
CISO Forum January 2024 4 24 hours
External National Cyber Exercise September 9-12, 2024 2 64 hours
Product Development & Digital Life Cycle April 2024 7 112 hours
Webinar: "Strengthening Financial Integrity" November 2024 137 1,096 hours
The Importance of Financial & Operational Security January 2024 2 16 hours
Navigating Consumer Financing Challenges March 2024 31 248 hours
Number of Training Sessions and Participants on Data Privacy and Cybersecurity
Description 2024 2023
Number of Trainings 12 6
Number of Participants 199 13
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BTN actively conducts awareness campaigns to ensure information security for customers and third-
parties through onsite and online workshops or training, the Bank’s official social media channels, email
blast security awareness, and by providing information on electronic transaction vigilance during financial
inclusion initiatives.
Consumer and Community Protection
BTN has established Special Policy No. KK.9-Z regarding 4. Protection of assets, privacy, and customer data;
Customer and Community Protection. This policy 5. Effective and efficient complaint handling and
ensures maximum protection for customers and the dispute resolution;
public by providing clear, accurate, and transparent 6. Compliance enforcement; and
information regarding products and/or services offered 7. Healthy competition.
by the Bank. It includes explanations of all potential
consequences and risks that customers or the public BTN is committed to protecting customer rights as
may face when deciding to use or benefit from the subjects of personal data in accordance with applicable
Bank’s products and/or services. By implementing regulations, such as the Personal Data Protection Law.
this policy, customers and the public will not only be Customers have essential rights, including the right
protected from potential financial losses that may arise to receive clear information regarding the collection
from using a product or service but also from legal and use of their personal data, the right to correct
risks that could emerge in connection with such use. or update data if there are errors or omissions, and
This policy aims to create a sense of security and trust the right to access and obtain copies of their stored
among customers and the public in every transaction personal data. Additionally, customers have the right to
or engagement they have with the Bank. terminate, delete, or erase their personal data if it is no
longer needed or if they withdraw their previously given
BTN upholds fundamental principles of consumer and consent.
community protection to safeguard customers and the
public, including: BTN considers the Product Life Cycle in managing
1. Adequate education; its products and services to support consumer and
2. Transparency and openness of information; community protection principles through the following
3. Fair treatment and responsible business conduct; stages:
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1. Product and service design; consumer protection principles.
2. Provision of product and/or service information 2. Developing a strategic planning cycle for financial
(RIPLAY); literacy and inclusion education. In terms of
3. Delivery of product and/or service information; education and inclusion, BTN has an education,
4. Marketing of products and/or services; literacy, and inclusion stream to plan activities that
5. Drafting agreements related to products and/or directly impact consumers and the community,
services; conducted periodically each year to strengthen
6. Providing services for product and/or service digital inclusion development.
usage; and 3. Internal consumer and community protection
7. Handling complaints and dispute resolution regulations adopting external regulations related
regarding products and/or services. to consumer protection (customer protection,
education and inclusion, personal data protection)
In implementing consumer protection principles, BTN into BTN’s internal policies as guidelines for the
includes: Bank’s activities.
1. Strengthening human resources and consumer 4. Enhancing complaint handling services by
protection infrastructure by establishing a providing easily accessible complaint channels for
structure that carries out the consumer protection consumers and ensuring that complaint handling
function at each BTN representative branch office, complies with the applicable SLA.
demonstrating its commitment to enforcing
Data Protection for Vendors and Business Partners
As part of the Bank’s commitment to data protection, parties in accordance with the applicable
BTN ensures that the level of data protection change procedures. Identification and review
implemented also applies to suppliers and business of information security requirements must be
partners who handle the Bank’s data or have access conducted for any changes in the agreed scope
to its network. To safeguard data security and privacy, of work.
BTN has established measures to ensure that business 3. The Bank conducts supervision and inspections
partners and suppliers comply with information security through regular monitoring of provided services,
standards by implementing the following key actions: ensuring that suppliers and business partners
1. The Bank manages information security and submit regular reports on service delivery and
cybersecurity risks throughout the service remain available to support and provide necessary
provision process by suppliers and business information for internal audit processes.
partners, applying comprehensive processes 4. Upon termination of cooperation, the Bank also
and procedures to ensure security, integrity, implements an exit strategy to ensure that data
and confidentiality of information during IT remains protected even after the relationship with
solution implementation. Suppliers and business the supplier or business partner has ended.
partners are also required to comply with
information security requirements as stipulated The regulation of IT security aspects has also been
in the cooperation agreement or Non-Disclosure implemented in Special Policy (KK) 5-B on Information
Agreement (NDA). Technology Security, ensuring that Third Parties comply
2. The Bank ensures that any amendments to with security procedures in accordance with BTN’s
cooperation agreements with suppliers and internal policies.
business partners must be approved by both
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Personal Data Protection
Personal data protection refers to a series of steps and • Technical Guidelines (PT) 6-K.1 on Consent of
procedures for managing personal information by Personal Data Subjects
ensuring that the data is securely protected according • Technical Guidelines (PT) 6-K.2 on Personal Data
to its classification level. Protection also emphasizes the Collection Records
importance of transparency in every stage of personal • Technical Guidelines (PT) 6-K.3 on Impact
data management, meaning that all involved parties Assessment of Personal Data Protection
must clearly understand how their data is collected, • Technical Guidelines (PT) 6-K.4 on Handling Personal
used, and safeguarded. Personal data protection Data Protection Failures
includes establishing obligations that must be fulfilled • Technical Guidelines (PT) 6-K.5 on Cooperation with
by entities managing the data, such as the Bank, as well Third Parties Regarding Personal Data Protection
as the rights of individuals whose personal data is being • Technical Guidelines (PT) 9-J.1 on the Implementation
processed to protect their interests. of Archival Management
BTN has implemented personal data protection As part of its compliance efforts, the Bank ensures the
practices with the primary goal of building and confidentiality and security of personal information
maintaining customer trust, while ensuring compliance through:
with Law No. 27 of 2022 on Personal Data Protection. In 1. Personal Information Retention
terms of personal data protection, BTN has established a Personal information stored by the Bank must be
Data Privacy Department, which serves as the Personal deleted when it is no longer required for business
Data Protection Officer under the Compliance Unit, within operations or to fulfill legal and regulatory
the Directorate of Human Capital, Compliance & Legal. obligations.
This department is actively supervised by the Board of
Directors through the Information Technology Steering 2. Disclosure of Personal Data
Committee (KPTI), Risk Management Committee, Personal data may only be shared with third
and Personal Data Protection Implementation Project parties if explicit permission or consent has been
Steering Committee. The Data Privacy Department is obtained from the data owner or if required by an
responsible for developing frameworks and policies authorized official in accordance with applicable
and implementing personal data protection programs laws and regulations. The disclosure of personal
to ensure comprehensive, bank-wide implementation data by the Bank is strictly permitted only when
of data protection controls. it complies with the relevant legal and regulatory
provisions.
The personal data protection and management
practices applied by BTN are reflected in policies As the entity responsible for managing personal data,
regulating various aspects of personal data governance, BTN has fulfilled its obligations by undertaking the
from collection and usage (sharing) to data storage following actions:
and retention. Below is a list of documents and policies 1. Commitment to Collecting and Processing
detailing these practices: User Data for Limited Purposes. In the process
• Special Policy (KK) 6-K on Personal Data Protection of collecting and processing personal data, BTN
• Special Policy (KK) 5-B on Information Technology prioritizes the principle of data minimization,
Security meaning that only data that is strictly necessary
• Special Policy (KK) 9-Z on Consumer and Community and relevant for a specific purpose is collected.
Protection The Bank also documents the purpose of data
• Special Policy (KK) 9-J on Archival Management processing in written form, which serves as one of
Procedures the pieces of information that must be approved
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by the data subject before their data is processed. properly managed. Furthermore, the Bank has
This principle and practice are clearly regulated in established compliance and security standards
Special Policy No. 6-K on Personal Data Protection that third parties must adhere to in order to
and Technical Guidelines No. 6-K.1 on Personal protect the data and information involved in their
Data Subject Consent. business engagements. These security standards
2. Commitment to Implementing Leading Data align with the procedures established by the Bank,
Protection Standards. BTN has implemented as stipulated in Special Policy No. 6-K on Personal
data protection mechanisms that comply with Data Protection and Technical Guidelines No.
standards outlined in Special Policy (KK) 6-K 6-K.5 on Third-Party Cooperation in Personal Data
on Personal Data Protection and Special Policy Protection.
(KK) 5-B on Information Technology Security.
These policies include procedures and security BTN does not sell, provide, or lease personal data
measures designed to ensure data is protected belonging to data subjects associated with BTN,
and managed securely. Additionally, BTN has except for transaction processing purposes, provision
adopted international information security of financial services, regulatory reporting, fulfillment
standards, namely ISO 27001:2022 for the of requests from law enforcement authorities, and
Information Security Management System, which other exceptions as stipulated by applicable laws and
provides the best framework for managing and regulations. Processed personal data is minimized, as
protecting information. long as it does not conflict with prevailing regulations.
3. Commitment to Notifying Data Subjects Promptly
in the Event of Data Changes or Breaches. BTN As a form of transparency to personal data subjects, BTN
has established a policy requiring notifications has published a privacy policy that can be accessed
to be sent to data subjects if there is a change in at www.btn.co.id/privacy-policy and other BTN digital
data processing regulations or a data protection platforms. BTN is committed to upholding the rights of
failure. This is regulated in Special Policy No. 6-K on personal data subjects in accordance with applicable
Personal Data Protection and Technical Guidelines laws and regulatory requirements.
No. 6-K.4 on Handling Personal Data Protection
Failures, which provides guidelines for responding To address customer concerns related to personal data
to incidents related to data protection failures. subject rights, BTN provides multiple channels, including
4. Commitment to Obtaining User Data in a Legal, BTN Mobile/app, BTN call center, and customer service
Transparent Manner with Explicit Consent When at bank branches. The following are the available
Required. BTN ensures that data processing is channels related to personal data subject rights:
carried out in accordance with applicable laws and • To obtain information related to customers’ personal
with transparency, as stated in Special Policy No. data, accessible via BTN Mobile/app and customer
6-K on Personal Data Protection. Additionally, the service;
Bank has implemented processes to ensure that • To request modifications and corrections to
explicit and clear consent is obtained from personal customers’ personal data, available through
data subjects, whether individuals or corporations. customer service; and
Consent is given for data management based on • To terminate data processing and delete personal
a previously communicated purpose to the data data, available through customer service.
subject, including in any activities involving third
parties. This consent must be documented in the Additionally, BTN has initiated a periodic evaluation
Personal Data Processing Record (ROPA). process regarding the implementation of personal data
5. Commitment to Requiring Third Parties Sharing protection. This evaluation is conducted by the internal
Data to Comply with the Bank’s Policies. In team, but it also involves third parties appointed by the
addition to business agreements, BTN applies Bank to support this process.
risk management practices related to third-party
data handling to ensure all potential risks are
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During the reporting year, BTN’s Internal Audit Unit During this reporting period, BTN did not record any
conducted an audit focused on system and application incidents of personal data protection failure. This
security aspects through the Information Technology serves as tangible evidence of BTN’s commitment to
(IT) Audit activities. This audit is mandatory and maintaining privacy and protecting customer data
thematic, carried out according to the schedule outlined to the highest standards. Furthermore, BTN did not
in the Bank’s Annual Audit Plan. receive any similar complaints, either from regulatory
authorities or institutions responsible for monitoring and
overseeing banking sector regulations. [GRI 418-1]
Deletion of Personal Data
In an effort to comply with applicable legal provisions, on the data categories owned. Each data category,
particularly those related to personal data protection, including products, services, and specific types of data,
BTN adheres to the regulations set out in Law No. 27 is managed by the responsible division owner, who
of 2022 on Personal Data Protection. Although this law determines the appropriate storage duration.
outlines the obligation to delete and destroy personal
data, it does not explicitly establish a retention period As part of our commitment to transparent and
for personal data. Therefore, BTN refers to more sustainable governance, BTN is also committed to not
detailed internal policies, such as those outlined in KK obtaining or using customer personal data from other
9-M on Data Governance Guidelines, which stipulate sources without the explicit consent of the customer.
that determining the data retention period is the This measure is taken to ensure the security and
responsibility of each data owner. Additionally, BTN also confidentiality of customer personal data, as well as to
has PT 9-J1 on Archive Management Implementation, strengthen public trust in the responsible management
which regulates the Archive Retention Schedule based of personal data.
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Responsible Debt Collection Policy
As part of BTN’s commitment to ensuring responsible professionally, respects debtor privacy and conditions,
and sustainable banking practices, BTN has developed and remains accessible to all relevant stakeholders.
and implemented the Standalone Debt Collection Policy,
which includes clear and transparent debt collection BTN also provides comprehensive training for
procedures. This policy is designed to protect consumer employees regarding this policy to enhance their
rights while supporting business continuity by upholding understanding, including specialized training programs
high standards of Sustainable Governance (LST). Every such as Leading Collection with Negotiation Skills and
employee or authorized party representing the bank Optimizing Collection with Negotiation. The training
in debt collection is required to adhere to high ethical is designed to develop effective communication
standards and respect debtor rights, ensuring that the skills, conflict management, and guidance on fair
collection process is conducted professionally and in treatment of customers. This policy also emphasizes the
compliance with applicable regulations. importance of a constructive communication approach
in debt collection, focusing on providing solutions
The Standalone Debt Collection Policy refers to the to customers facing financial difficulties, such as
Consumer Collection Recovery and Asset Sales Policy, restructuring or refinancing options. Through this policy,
which covers the management of non-performing BTN is committed to ensuring that debt collection is not
loans and debt collection procedures. This policy sets only effective but also fair, inclusive, and sustainable.
out specific steps for managing and collecting debts, Oversight of policy implementation is carried out by the
including early notification to debtors, transparent CSRD Division, which is responsible for ensuring that all
communication arrangements, and a structured debt collection activities are conducted in accordance
escalation mechanism. All these steps are designed with the principles established in the policy.
to ensure that the collection process is conducted
Loan Modification Options
As part of BTN’s commitment to consumer protection, BTN’s restructuring options refer to POJK No. 40 of 2019,
the Bank offers loan modification options for customers which includes:
experiencing financial difficulties. This restructuring 1. Adjustment of Payment Schedule
program includes adjustments to the payment 2. Temporary Reduction of Loan Interest Rates
schedule, temporary interest rate reductions, or 3. Deferral of Principal Installments
principal installment deferment, aiming to provide a fair
solution for both parties. The application process begins with a debtor’s request,
which is then reviewed by the Bank’s risk management
The restructuring process begins with a discussion team. Once approved, the debtor will receive an
between the debtor and the account manager. agreement letter detailing the agreed upon scheme,
Debtors can also access information regarding loan providing extended repayment flexibility and reducing
restructuring through OJK (Indonesia’s Financial credit risk.
Services Authority). Once approved, the debtor will
receive a Loan Restructuring Agreement Letter outlining
the scheme, terms, and applicable conditions.
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Financial Product Complaints Handling [GRI 413-2] [OJK F.24]
BTN recognizes the importance of transparent and open Through a consistent commitment to these efforts, BTN
communication in building trust with all stakeholders. aims to foster positive relationships with stakeholders
Therefore, the Bank prioritizes accessible, responsive, while ensuring that every perspective is acknowledged
and effective communication channels, allowing and addressed appropriately. BTN also ensures that
stakeholders, particularly local communities, to submit every operational decision’s impact is well-managed
feedback, suggestions, or complaints related to the to avoid significant issues or complaints. During the
Bank’s operations. These complaint channels serve not reporting period, BTN did not receive any complaints
only as a means for stakeholders to express concerns or related to operational activities or negative impacts
dissatisfaction but also as a dialogue platform enabling caused, demonstrating the Bank’s commitment to
the Bank to respond to issues quickly and collaboratively, maintaining effective and responsive communication.
seeking the best solutions for all parties. [F.24]
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and Empowerment Governance Integrity
Customer Complaint Mechanism
BTN understands that prompt and effective resolution this policy, the Bank has set up accessible complaint
of customer complaints is crucial in providing the best channels across all operational units, ensuring that
service experience and serves as a key factor in service customers can submit complaints or feedback anytime
excellence. As part of its commitment to service quality and from anywhere, without being restricted to the
enhancement, BTN has established a Special Policy No. branch where they first registered. Customers can
KK.9-K on Customer Complaints. In accordance with submit complaints both verbally and in writing through
the available media channels, including:
Customer Complaint Media Channels
1 2 3
Complaints via the Contact Complaints submitted
Complaints can be
Center at 150286 or through the Financial
submitted directly to BTN
through BTN’s official email: Services Authority (OJK),
through Regional Offices,
btncontactcenter@btn.co.id. Bank Indonesia, and other
Branch Offices, Sub-Branch
(For complaints via Live Chat, regulatory institutions.
Offices, and divisions at the
electronic media, or social
Head Office and Board of
media, they will be redirected
Directors.
to the official email or contact
center).
Complaint Customer Submits Customer Receives Complaint Resolution
a Complaint Complaint Number Completed
Handling Customers submit BTN records and If the customer agrees
Process their complaints provides the with the resolution, the
through the customer with a complaint is considered
channels provided ticket number for resolved.
by BTN. their complaint.
1 2 3 4 5 6
Customer Data Follow-Up Process Customer Dissatisfied
Verification by Bank BTN & Escalates to LAPS SJK
BTN verifies BTN processes If the customer
customer data and resolves the disagrees with the
according to customer complaint resolution, they can
the established within the designated escalate the complaint
procedures. timeframe. to LAPS SJK
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Management Welfare Support
Customer Complaint Data
2024
Complaint Category Resolved In Process
Total
Complaints
Total % Total %
Fund Collection 1,064 654 61.47 410 38.53
Fund Distribution 461 324 70.28 137 29.72
Partnership Products 15 12 80.00 3 20.00
Other Products 1,259 808 64.18 451 35.82
Payment System 90,198 89,385 99.10 813 0.90
Total 92,997 91,183 98.05 1,814 1.95
Resolution Rate 98.45%
Remarks:
• Fund Collection Category: Savings, deposits, giro, etc.
• Fund Distribution Category: Subsidized credit, non-subsidized credit, working capital loans, etc.
• Partnership Products Category: Bancassurance, mutual funds, ORI, etc.
• Other Products Category: Officer services, foreign bank services, facility provision, etc.
• Payment System Category: ATM, mobile banking, internet banking, etc.
Oversight of Customer Complaint Management
The BTN Risk Monitoring Committee, operating at the such as arbitration, mediation, or court proceedings,
Board of Commissioners level, oversees customer in accordance with applicable regulations. This
complaint management as part of operational approach reflects BTN’s commitment to maintaining
risk management. In this process, the Committee its integrity and credibility, as well as managing legal
collaborates with the Director of Operations to receive and reputational risks that may arise from unresolved
performance reports on complaints handling from the disputes.
Experience Division Unit. This initiative aims to identify
potential risks and ensure appropriate follow-up actions Through this structured approach, BTN remains
to improve processes and mitigate emerging risks, committed to managing customer complaints with
enabling effective and efficient customer complaint prudence and continuous improvement, aiming
management. to enhance customer satisfaction and loyalty. This
commitment underscores the Bank’s dedication to
If a complaint cannot be resolved directly and escalates providing fair and transparent solutions for customers
into a dispute, customers are given the opportunity while continuously improving overall service quality.
to escalate their case to a dispute resolution body,
Customer Complaint Handling Process
To further enhance the quality of customer complaint Through this partnership, BTN has implemented an
management, BTN collaborates with external parties, Ombudsman-based complaint handling system, which
such as the Ombudsman and the National Consumer includes:
Protection Agency (BPKN), to accelerate the complaint 1. Integrated Complaint Channels: BTN provides
resolution process. This collaboration aims to ensure that multiple complaint submission channels,
each complaint is resolved promptly and accurately, including the BTN Mobile application, call center,
while maintaining the Bank’s credibility in delivering the and physical branches, with service standards
best solutions for customers. aligned with OJK regulations.
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2023 2022
Resolved In Process Resolved In Process
Total Total
Complaints Complaints
Total % Total % Total % Total %
318 318 100.00 0 0.00 94 94 100.00 - 0.00
208 206 99.04 2 0.96 184 184 100.00 - 0.00
8 8 100.00 0 0.00 5 5 100.00 1 20.00
812 706 86.95 106 13.05 444 444 100.00
61,261 61,261 100.00 0 0.00 51,804 51,804 100.00 34 0.07
62,607 61,137 97.64 108 0.17 51,804 51,804 100.00 49 0.09
99.83% 100.00%
2. Clear Escalation Procedures: Complaints that resolution time of (3 working days) while also increasing
cannot be resolved at the operational level public trust in the Bank’s services.
are evaluated to ensure an independent and
accountable resolution process. BTN is committed to ensuring that all customer personal
3. Specialized Employee Training: BTN conducts data is processed in accordance with the customer’s
training programs for employees on effective explicit consent. The data will not be used for purposes
complaint handling. other than the primary transaction without prior notice
4. Enhanced Transparency: BTN is committed to or additional consent from the customer.
regularly reporting customer complaint statistics,
resolution rates, and customer feedback as a form This is reflected in the attainment of the ISO 9001:2015
of transparency. Certificate regarding Contact Center Service Quality
Standards as a form of validation that BTN’s contact
This is proven by BTN receiving an award from the center services are standardized and serve as one of
Ombudsman of the Republic of Indonesia as the most the channels for customer complaints.
cooperative and responsive Association of State-
Owned Banks (HIMBARA) in encouraging the completion Additionally, BTN provides a privacy notice accessible
of mortgage certificate fulfillment for debtors on on the Bank’s official website, offering transparency on
December 19, 2024. how customer data is used and protected. In line with
this commitment, BTN does not sell, disclose, or provide
In 2024, BTN successfully improved customer customer data to third parties without the customer’s
satisfaction, achieving a faster average complaint consent.
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Customer Satisfaction
BTN considers customer satisfaction one of its top innovations. This allows customers to make informed
priorities. Each year, the Bank strives to improve customer and confident decisions. The information covers various
satisfaction levels by offering high-quality products and essential aspects, including the purpose and type of the
services that are not only superior in quality but also product, offered benefits, potential risks, pricing, usage
equitably accessible to all customers without exception. procedures, related fees, and other relevant details that
Additionally, the Bank establishes policies and service help customers understand the Bank’s products and
standards designed not only to maintain existing levels services. [GRI 3-3, 417-1] [OJK F.27]
of satisfaction but also to strengthen and enhance
customer trust in the Bank. [OJK F.17] Furthermore, all marketing and promotional activities
conducted by the Bank comply fully with applicable
Several initiatives undertaken by BTN to ensure customer regulations, ensuring that all promoted products and
satisfaction include: services meet the standards set by relevant authorities.
1. Offering products and services that meet As a result of this approach, during the reporting
established quality standards; year, no negative impacts were recorded due to the
2. Providing the best services to all customers and Bank’s products or services. No products or services
addressing every customer complaint fairly and had to be withdrawn due to safety concerns, and no
without discrimination; non-compliance issues were identified regarding
3. Conducting service promotions that are ethical, information or labeling of the Bank’s products and
fair, honest, and non-misleading, while adhering services. Additionally, BTN did not receive any reports
to commonly accepted social norms; of violations related to marketing communications
4. Promoting fair trade practices in accordance with throughout 2024. [GRI 3-3, 417-2, 417-3] [OJK F.28, F.29]
BTN’s policies, including:: [FS15]
a. Special Policy No. 2-L on Retail Funding Service BTN continuously strives to enhance customer
Products; satisfaction, and the success is reflected in various
b. Technical Guidelines PT.2-C.1 on Foreign external assessments. Notably, BTN secured first place
Currency Transfer Service Fees; in the Net Promoter Score (NPS) category for the Bank
5. Ensuring that all employees support the Bank’s Group (KBMI 3) in the Satisfaction Loyalty Engagement
efforts to achieve customer satisfaction and trust. (SLE) survey conducted in 2024, achieving a score of
50.00. This achievement represents an 8.5% increase
Besides providing information on existing products from the previous year, underscoring high levels
and services, BTN is also committed to offering clear of customer satisfaction and loyalty towards BTN’s
and accurate information on new products and services. [OJK F.30]
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Governance
Integrity
226 BTN Sustainability Governance Structure
232 Commitment to Governance Implementation
235 Governance Strategy
236 Governance, Risk, and Compliance Roadmap
242 Nomination Process for the Highest Governance
Body
247 Evaluation of the Performance of the Highest
Governing Body
248 Risk Management
277 Code of Conduct and Business Ethics
282 Anti-Fraud and Conflict of Interest
287 Implementation of the Prudence Principle
290 Compliance in Environmental and Social
Management
291 Internal Control
291 Gratification Control
292 Whistleblowing System
296 Complaint Handling System
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Management and Welfare Support
BTN Sustainability Governance Structure [GRI 2-9, 2-10, 2-11, 2-12, 2-13, 2-18]
BTN has established a governance structure in a checks-and-balances mechanism. In operational
accordance with the provisions set out in Law No. 40 of practices, the GMS, the Board of Commissioners, and
2007 on Limited Liability Companies, which stipulates the Board of Directors carry out their respective roles
that the “Corporate Organs consist of the General while respecting the boundaries of authority as defined
Meeting of Shareholders (GMS), the Board of Directors, by statutory regulations and the Company’s Articles
and the Board of Commissioners.” The formation of of Association. This structure not only reflects BTN’s
these corporate organs is designed to support the compliance with applicable laws and regulations but
implementation of Good Corporate Governance also emphasizes the strategic roles of each corporate
principles through a structured division of roles and organ in supporting the effective implementation of
responsibilities, as well as the effective execution of governance practices.
BTN Governance Structure
General Meeting of
Shareholders (GMS)
Board of Sharia Supervisory
Board of Directors
Commissioners Board
Secretary of
the Board of Corporate Secretary
External Audit
Commissioners
Risk Management
Audit Committee Internal Audit Unit
Committee
Asset and Liability
Committee (ALCO)
Risk Oversight
Committee Risk Management Unit
Credit Committee
Credit Policy
Committee
Remuneration Compliance Unit
and Nomination (SKK)
Committee Information Technology
Steering Committee
Other Working Units
Human Capital
Committee Sharia Business Unit
(UUS)
Business Committee
Transformation
Steering Committee
ESG Committee
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General Meeting of Shareholders (GMS) [GRI 2-11]
The General Meeting of Shareholders (GMS) is the applicable regulations, shareholders do not participate
highest organ within the Bank’s structure, functioning as in the Bank’s operational activities, which are entirely the
a forum for shareholders to exercise their rights, whether responsibility of the Board of Directors. Furthermore, the
to obtain information or provide insights related to the GMS plays a critical role in making strategic decisions
Company’s strategic policies. Under Law No. 40 of 2007 that directly impact the sustainability of the Bank’s
on Limited Liability Companies, the GMS is defined as “a operations and strategic direction. [GRI 2-11]
corporate organ with authority not granted to the Board
of Directors or the Board of Commissioners, within the The Bank holds two types of General Meetings of
limits determined by this Law and/or the Company’s Shareholders: the Annual GMS and the Extraordinary
Articles of Association.” GMS. The Annual GMS must be conducted no later than
six months after the fiscal year ends. Meanwhile, the
As the highest governance body, the GMS is not part Extraordinary GMS, also referred to as a Special GMS,
of the Company’s executive branch but serves as a may be convened at any time based on the Bank’s
platform where the Board of Directors and the Board needs and interests. During the reporting period, the
of Commissioners present performance reports and Bank held X Annual GMS and X Extraordinary GMS, as
accountability for the duties they have carried out. detailed below:
In accordance with BTN’s Articles of Association and
Conducting BTN GMS
Description Annual GMS Extraordinary GMS
Date March 6, 2024 -
Time at 14.31 WIB - 17.13 WIB -
Location Menara BTN Building, 6th Floor, Jl. -
Gajah Mada No. 1, Central Jakarta
10130
Board of Commissioners
The Board of Commissioners is a governance In performing its supervisory duties, the Board of
organ of the Bank responsible for carrying out both Commissioners is authorized to establish committees
comprehensive and specific supervision in accordance composed of members of the Board of Commissioners.
with the provisions of the Articles of Association. These committees report directly to the Board of
Additionally, the Board of Commissioners plays a role in Commissioners. The functions and duties of the Board
providing recommendations to the Board of Directors. of Commissioners are further regulated by Law No. 40
Its primary function is to ensure the interests of the Bank of 2007 on Limited Liability Companies, Law No. 7 of 1992
and its shareholders are fulfilled while supporting the on Banking, and other relevant regulations, including
achievement of BTN’s goals, taking into account the provisions set by OJK, Bank Indonesia, and BTN’s Articles
interests of all stakeholders. of Association.
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Composition of BTN Board of Commissioners
Name Position Appointer Basis of Appointment Effective Date
Chandra M. Hamzah President Financial Services Extraordinary GMS on May 4, 2020
Commissioner/ Authority November 27, 2019
Independent
Iqbal Latanro Vice President Financial Services Annual GMS on March 10, September 6, 2021
Commissioner/ Authority 2021
Independent
Armand B. Arief Independent Financial Services Extraordinary GMS on May 14, 2020
Commissioner Authority November 27, 2019
Sentot A. Sentausa Independent Financial Services Annual GMS on March 2, August 8, 2022
Commissioner Authority 2022
Andin Hadiyanto Commissioner Financial Services Extraordinary GMS on July 10, 2020
Authority November 27, 2019
Herry Trisaputra Commissioner Financial Services Annual GMS on March 2, October 11, 2022
Zuna Authority 2022
Himawan Arief Commissioner Financial Services Annual GMS on March 2, October 3, 2022
Sugoto Authority 2022
Adi Sulistyowati Independent Financial Services Annual GMS on March 6, October 7, 2024
Commissioner Authority 2024
Bambang Independent Financial Services Annual GMS on March 6, October 7, 2024
Widjanarko Commissioner Authority 2024
As part of a good governance mechanism, BTN an attendance list, reflecting members’ participation in
holds regular meetings to ensure that the Board of strategic decision-making and oversight of the Bank’s
Commissioners can effectively carry out its supervisory operations.
function. Each Board of Commissioners meeting records
Percentage of Attendance at Board of Commissioners Meetings
Number of Board of Commissioners Meetings Average Attendance Percentage
53 97.29%
Board of Directors
The Board of Directors is the primary organ in Each member of the Board of Directors must have at
governance, fully responsible for managing the Bank least five years of experience in operational functions,
to achieve its established objectives and interests. holding a position no lower than an executive officer
The responsibilities of the Board of Directors include in a bank, and must meet the criteria for integrity,
operational management, strategic formulation, and competence, and financial reputation as stipulated by
the management and protection of the Bank’s assets. the Financial Services Authority (OJK). The criteria for
In practice, the Board of Directors is required to report prospective Board members are outlined in the Board of
its performance results to the Board of Commissioners. Directors’ Work Guidelines and Rules of Procedure. The
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appointment of members of the Board of Directors is term. Their appointment is formalized through a GMS
conducted through the General Meeting of Shareholders resolution and takes effect on the date specified in
(GMS) and becomes effective upon the conclusion of the GMS resolution until the conclusion of the fifth
the GMS. Proposals for the appointment or replacement Annual GMS following their appointment. This provision
of Board members by the Board of Commissioners complies with applicable laws and regulations in the
to the GMS are based on recommendations from the capital market sector. Nevertheless, the GMS holds the
Remuneration and Nomination Committee. authority to dismiss members of the Board of Directors
before their term ends, provided it adheres to the
Members of the Board of Directors serve a term of five prevailing legal provisions in the capital market sector.
(5) years, which may be extended for one (1) additional
Composition of BTN Board of Directors
Name Position Appointer Basis of Appointment Effective Date
Nixon L.P. Napitupulu President Director Financial Services Annual GMS on March 16, 2023 June 7, 2023
Authority
Oni Febriarto Vice President Director Financial Services Annual GMS on March 16, 2023 June 7, 2023
Rahardjo Authority
Andi Nirwoto Director of Information Financial Services Annual GMS on March 23, 2018 September 7, 2018
Technology Authority
Elisabeth Novie Director of Assets Financial Services Extraordinary GMS on August June 26, 2020
Riswanti Management Authority 29, 2019
Jasmin Director of Distribution Financial Services Extraordinary GMS on May 4, 2020
& Institutional Funding Authority November 27, 2019
Hirwandi Gafar Director of Consumer Financial Services Extraordinary GMS on August 28, 2020
Authority November 27, 2019
Setiyo Wibowo Director of Risk Financial Services Extraordinary GMS on July 3, 2020
Management Authority November 27, 2019
Nofry Rony Poetra Director of Finance Financial Services Annual GMS on March 10, 2021 August 9, 2021
Authority
Eko Waluyo Director of Human Financial Services Annual GMS on March 10, 2021 August 9, 2021
Capital, Compliance & Authority
Legal
Hakim Putratama Director of Operations Financial Services Annual GMS on March 16, 2023 July 26, 2023
& Customer Experience Authority
Muhammad Iqbal Director of SME & Retail Financial Services Annual GMS on March 6, 2024 August 8, 2024
Funding Authority
The Board of Directors is responsible for executing all of Directors is led by the President Director, who acts as
management actions and overseeing BTN’s operations the primary coordinator. The President Director ensures
in alignment with the Bank’s objectives and goals. The effective leadership and strategic decision-making at
Board represents the Bank both in and outside the the Board level to support the Bank’s vision, mission,
court while adhering to applicable laws, the Articles of and long-term objectives. The President Director’s key
Association, and resolutions from the General Meeting responsibilities include:
of Shareholders (GMS). In managing the Bank, the Board
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Management and Welfare Support
1. Leading Board of Directors meetings. To enhance effectiveness in carrying out its duties, the
2. Fostering a culture of transparency and facilitating Board of Directors is supported by various committees,
constructive discussions. including:
3. Providing guidance to Board members on the 1. Risk Management Committee
effectiveness of management duties. 2. Asset and Liability Management Committee
4. Maintaining strong relationships and cohesion (ALCO)
among Board members in executing their 3. Credit Policy Committee
responsibilities. 4. Credit Committee
5. Ensuring effective and healthy collaboration with 5. Human Capital Committee
the Board of Commissioners. 6. Information Technology (IT) Steering Committee
7. Transformation Steering Committee
As part of collective responsibility, each Board member 8. Business Committee
is jointly and fully liable for any losses resulting from 9. Environmental, Social, and Governance (ESG)
errors or negligence in carrying out their duties. However, Committee
a Board member may be exempt from liability if they
can demonstrate that: Furthermore, the Board of Directors is also supported
1. The loss was not due to their error or negligence. by key functional units, including the Corporate
2. They performed their duties in good faith, Secretary, Internal Audit Unit, and Risk Management
responsibly, and with due diligence in the best Unit, to ensure more effective and integrated Bank
interest of the Bank. management. To uphold good governance practices,
3. They had no direct or indirect conflict of interest in BTN conducts scheduled meetings to ensure that
the management actions that led to the loss. the Board can efficiently carry out its management
4. They took necessary measures to prevent or duties. The attendance records from each Board
mitigate the loss. meeting reflect the active participation of members in
strategic decision-making and oversight of the Bank’s
operational performance.
Percentage of Attendance at Board of Directors Meetings
Number of Board of Directors Meetings Average Attendance Percentage
191 86.64%
ESG Committee
BTN has established ESG Committee, a board-level focusing on environmental, social, and governance
Committee, by the President Director, with membership impacts. Additionally, the committee is responsible
comprising the Board of Directors and SEVP. The for overseeing ESG-related risks and opportunities
committee aims to support the achievement of the and making strategic decisions regarding ESG and
Company’s Sustainable Development Goals (SDGs) CSR program implementation. Regular meetings are
and climate targets. The ESG Committee plays a critical conducted annually. [GRI 2-18] [FS2]
role in ensuring that the Bank’s sustainability policies
encompass Environmental, Social, and Governance The duties and responsibilities of the ESG Committee
aspects aligned with the Company’s strategic objectives. are as follows: [GRI 2-9, 2-12, 2-13]
The responsibilities of the ESG Committee include 1. Establishing corrective measures related to the
formulating policies, strategies, and objectives for ESG ESG and Corporate Social and Environmental
and Corporate Social Responsibility (CSR) programs, Responsibility (TJSL) programs, including
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Community Development, Micro and Small 5. Monitor, evaluate, and provide recommendations
Business Funding (PUMK), the Sustainable Finance on ESG reports, investor concerns, or third-party
Action Plan, and business activities as part of evaluations regarding ESG implementation.
the Bank’s responsibility to society for business- 6. Make decisions related to:
related risks. These measures are reported to the a. Objectives and guidelines for implementing
Board of Directors. CSR Programs.
2. Make decisions on the Bank’s strategies impacting b. Mapping and formulation of CSR
the environment, society, and communities c. Programs.
through the ESG Program and Roadmap. d. Evaluation of CSR Program implementation.
3. Oversee the monitoring and implementation of
the Bank’s ESG Strategy and Roadmap. The ESG Committee is regulated under Special Policy
4. Provide information to the Bank’s management No. KK.9-D regarding the Governance Committee of
on all ESG-related issues, including regulatory the Board of Directors, with the following committee
updates, government programs, international structure:
developments, future business trends, and climate
change.
BTN ESG Committee Structure
Structure Position
Chairperson President Director
(concurrently serves as permanent
member)
Board of Directors • Vice President Director (*)
(concurrently serves as permanent • Director under Risk Management (**)
member) • Director under Human Capital, Compliance & Legal
• Director under Asset Management
• Director under Finance
Direksi/SEVP • SEVP Wholesale Banking (Permanent Members)
• Other Directors/SEVP based on the subject matter discussed (Non-
Permanent Member)
• SEVP under Compliance and Legal (Non-Permanent Member)
*) First Alternate Chairperson
**) Second Alternate Chairperson
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Commitment to Governance Implementation
BTN is fully committed to integrating the principles • OJK Regulation No. 21/POJK.04/2015 on the Corporate
of Good Corporate Governance (GCG) into all Governance Guidelines for Public Companies;
operational aspects. GCG serves as a key foundation • OJK Regulation No. 31/POJK.04/2015 on Disclosure
for BTN’s management, not only as a means of of Information or Material Facts by Issuers or Public
fulfilling legal obligations but also as a shared form of Companies;
accountability to safeguard the Bank’s business. BTN • OJK Regulation No. 55/POJK.04/2015 on the
views the implementation of GCG as a strategic step to Formation and Implementation Guidelines for Audit
enhance performance, competitiveness, and business Committees;
sustainability in the long term. • OJK Regulation No. 56/POJK.04/2015 on the Formation
and Implementation Guidelines for Internal Audit
In the dynamic landscape of the banking sector, Charters;
BTN continuously strengthens the implementation of • OJK Regulation No. 60/POJK.04/2015 on the
GCG to create a balance of control within the Bank. Disclosure of Certain Shareholder Information;
Through effective implementation, GCG helps mitigate • OJK Regulation No. 5/POJK.03/2016 on Bank Business
risks of fraud and minimizes errors in organizational Plans;
management. Additionally, BTN’s ability to meet • OJK Regulation No. 29/POJK.03/2016 on Annual
stakeholder expectations, both internally and externally, Reports of Issuers or Public Companies;
becomes an essential asset to sustain business • OJK Regulation No. 11/POJK.03/2016 on Ownership
continuity, in alignment with prevailing regulations and Reports or Changes in Ownership of Public
recognized international best practices. Companies;
• OJK Regulation No. 15/POJK.03/2019 on Plans and
In implementing GCG, BTN refers to various laws, Implementation of GMS for Public Companies;
regulations, and relevant GCG guidelines at both • OJK Regulation No. 16/POJK.03/2019 on Conducting
national and international levels. The basis for BTN’s GMS for Public Companies Electronically;
GCG implementation includes: • OJK Regulation No. 17/POJK.03/2019 on Material
• Law of the Republic of Indonesia No. 10 of 1998 on Transactions and Changes in Business Activities;
Amendments to Law No. 7 of 1992 on Banking; • OJK Regulation No. 42/POJK.03/2019 on Transparency
• Law No. 40 of 2007 on Limited Liability Companies; and Publication of Bank Reports;
• OJK Regulation No. 17/POJK.03/2014 on the • OJK Regulation No. 17 of 2023 on GCG Implementation
Implementation of Integrated Risk Management in for Commercial Banks;
Financial Conglomerates; • OJK Regulation No. 2 of 2024 on GCG Implementation
• OJK Regulation No. 18/POJK.03/2014 on the for Commercial Banks and Sharia Business Units;
Implementation of Integrated GCG for Financial • Circular Letter of OJK No. 14/SEOJK.03/2015
Conglomerates; on Integrated Risk Management for Financial
• OJK Regulation No. 33/POJK.04/2014 on the Board of Conglomerates;
Directors and Board of Commissioners of Issuers or • Circular Letter of OJK No. 15/SEOJK.03/2015 on GCG
Public Companies; Implementation for Financial Conglomerates;
• OJK Regulation No. 34/POJK.04/2014 on the • Circular Letter of OJK No. 32/SEOJK.04/2015 on GCG
Nomination and Remuneration Committee of Issuers Guidelines for Public Companies;
or Public Companies; • Circular Letter of OJK No. 25/SEOJK.03/2016 on Bank
• OJK Regulation No. 34/POJK.04/2014 on the Business Plans;
Corporate Secretary of Issuers or Public Companies; • Circular Letter of OJK No. 43/SEOJK.03/2016 on
• OJK Regulation No. 8/POJK.04/2015 on the Websites Transparency and Publication of Conventional Bank
of Issuers or Public Companies; Reports;
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• Circular Letter of OJK No. 13/SEOJK.03/2017 on 1. Corporate governance principles developed by
Governance Implementation for Commercial Banks; the Organization for Economic Cooperation and
• Regulation of the Ministry of State-Owned Enterprises Development (OECD);
(SOEs) No. PER-1/MBU/03/2023 dated March 3, 2023, 2. ASEAN Corporate Governance Scorecard
regarding Special Assignments and Corporate published by the ASEAN Capital Market Forum
Social Responsibility Programs for State-Owned (ACMF);
Enterprises; 3. Indonesian Corporate Governance Guidelines
• Regulation of the Ministry of State-Owned Enterprises (PUGKI) developed by the National Committee on
(SOEs) No. PER-2/MBU/03/2023 regarding Guidelines Governance Policy (KNKG);
on Governance and Significant Corporate Activities 4. Banking GCG Guidelines for Indonesia developed
of State-Owned Enterprises; by the National Committee on Governance Policy
• Regulation of the Ministry of State-Owned Enterprises (KNKG); and
(SOEs) No. PER-3/MBU/03/2023 dated March 3, 2023, 5. Principles for Enhancing Corporate Governance
regarding the Organization and Human Resources published by the Basel Committee on Banking
of State-Owned Enterprises; and Supervision.
• The Bank’s Articles of Association, as most recently
amended by the Deed of Statement of Resolutions The implementation of GCG has become a strategic
of the Annual General Meeting of Shareholders No. element in achieving the goal of moving beyond
8 dated March 6, 2024, approved by the Minister of corporate governance to true business value. BTN
Law and Human Rights of the Republic of Indonesia has shifted its governance focus from a compliance-
through Ministerial Decision No. AHU-0022194. driven approach to a value-driven approach across
AH.01.02 of 2024 dated April 5, 2024. all business lines. This step aligns the Bank’s values
with strengthening sustainable GCG practices. Since
In addition, the Bank adopts various best governance 2014, the Corporate Governance Perception Index
standards at regional and international levels and (CGPI) score and the ASEAN Corporate Governance
continues to enhance the scope of GCG implementation, Scorecard (ACGS) have shown significant growth,
including: reflecting consistency in enhancing performance and
governance practices at the Bank.
Governance Commitment
BTN is committed to continuously integrating the The implementation of GCG is a key element in
principles of GCG into all operational aspects, adhering assessing BTN’s performance by shareholders while
to applicable regulations, and maintaining openness ensuring that the Bank is managed transparently
to improvements in achieving alignment with the best and professionally, safeguarding the interests of all
practices. This commitment aims to support BTN’s shareholders. As a State-Owned Enterprise (SOE) and
vision and create optimal value for shareholders and public company, BTN is determined to continuously
other stakeholders. enhance GCG implementation to meet the expectations
of all stakeholders.
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Governance Principles
BTN recognizes that business sustainability is not Governance (GCG) at every level of the organization.
solely measured by financial performance or The implementation of GCG is based on POJK Number 17
profitability growth but also through good internal of 2023 concerning the Implementation of Governance
management, including adherence to GCG principles. for Commercial Banks as the primary guideline. The
By prioritizing GCG principles, the Bank aims to create key corporate governance principles applied by BTN
a comprehensive balance in business governance. This include:
encompasses the interests of business and society, 1. Transparency
both at the group and individual levels, internally and Transparency refers to openness in the decision-
externally, in the short and long term, to provide optimal making process and the availability of relevant
benefits for shareholders and other stakeholders. information regarding the Bank to stakeholders.
The effective application of GCG principles is key to 2. Accountability
ensuring the Bank’s resilience in facing the increasingly Accountability entails clarity in the roles and
complex dynamics of competition. For this reason, BTN responsibilities of the Bank’s organs, ensuring
continues to adopt and adjust the best GCG practices BTN’s performance operates transparently, fairly,
at national, regional, and international levels to ensure effectively, and efficiently.
relevance and effectiveness in meeting the Bank’s
needs and industry challenges. 3. Responsibility
Responsibility is the alignment of the Bank’s
BTN’s objectives in implementing GCG principles include: management with legal and regulatory
requirements in the financing sector, as well as
1. Supporting BTN’s vision of “Becoming the Best with ethical values, standards, principles, and
Mortgage Bank in Southeast Asia by 2025.” healthy business practices.
2. Supporting BTN’s mission, namely:
a. Actively supporting the government in 4. Independence
promoting the welfare of Indonesian society Independence represents the state of the Bank
through home ownership. being managed independently and professionally,
b. Realizing the dreams of millions of Indonesians free from conflicts of interest or undue influence
by providing access to decent housing. and pressure from any party, in compliance with
c. Becoming “The Home of Indonesia’s Best Talent.” legal and regulatory provisions in the financing
d. Enhancing shareholder value by focusing on sector and ethical values, standards, principles,
profitability growth and sustainability as a blue- and healthy business practices.
chip company with robust risk management
principles. 5. Fairness
e. Becoming a financial partner for stakeholders in Fairness refers to equity, balance, and justice
the housing ecosystem by providing integrated in fulfilling the rights of stakeholders based on
solutions and superior services through digital agreements, legal and regulatory provisions, and
innovation. ethical values, standards, principles, and healthy
3. Providing benefits and added value for business practices.
shareholders and stakeholders.
4. Maintaining and enhancing the sustainability of GCG serves as a fundamental guideline for improving the
a healthy and competitive business over the long Bank’s performance and accountability, aiming to create
term. long-term value for shareholders while considering the
5. Increasing investor trust in BTN. interests of all stakeholders. Its implementation is based
on applicable laws and ethical business practices. As
In conducting business and operational activities, BTN risk complexities increase, the need for good corporate
consistently applies the principles of Good Corporate governance becomes essential to ensure business
sustainability and resilience.
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Additionally, the implementation of GCG is a sustainable professionally and responsibly, guided by GCG
effort to address the growing need for genuine principles. This initiative is supported by a competitive,
business governance. BTN is committed to becoming a integrated, and innovative human resource system.
leading SOE Bank that manages its business activities
Governance Strategy
By implementing a holistic GCG paradigm, BTN ensures a roadmap encompassing four main pillars. The first
alignment between the Bank’s goals and interests with pillar is the commitment to governance (Commitment
those of its stakeholders. This alignment is expected on Governance), which serves as the foundation for
to support BTN’s long-term sustainability. To maintain the subsequent three pillars: Governance Structure,
consistency in GCG implementation, BTN has developed Governance Process, and Governance Outcome.
BTN GCG Pillars
Governance Governance Governance
Structure Process Outcome
Commitment on Governance
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Governance, Risk, and Compliance Roadmap
As part of its commitment to holistic governance, BTN support sustainable business growth while ensuring
has designed a Governance, Risk, and Compliance operational efficiency, profitability, and improved digital
(GRC) Roadmap for the 2025–2029 period to service delivery. The developed framework, a guide for
enhance corporate governance, risk management, formulating the GRC Roadmap, is as follows:
and regulatory compliance. This initiative aims to
BTN Governance, Risk, and Compliance (GRC) 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
Stream Analysis Diagnostic Gap Analysis
Results Result
Phase 1: Diagnostic Process
Strategic Business Process
Funding
Directions SWOT
Gap Analysis Governance & Analysis
Gaps Between Organizational (Result)
Lending External Analysis Existing Conditions Structure
(Business and Ideal
Trends), Conditions, Infrastructure, IT, &
Regulation, Constraints, Data
Operational Key
and/or Internal or Obstacle
Analysis Best Watch-Out
Encountered People Capabilities
Practices/ & Strategy
Risk Design
Benchmarking
Interconnectivity GRC Culture
Strategic Postures for GRC Roadmap
Strategic
Postures
Phase 2:
To Drive Resilience & Secure
To Support Business Growth and To Ensure Competency of GRC
Operational For Business
Sustainability Talent and Strong GRC Culture
Continuity
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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The GRC Roadmap is designed to provide a strategic 2. Delivering the best customer experience through
framework that enables BTN to address regulatory, risk, integrated digital and financial services.
and governance challenges in an integrated manner. 3. Enhancing shareholder value through sustainable
Through a proactive approach, the roadmap ensures profitability growth.
that the organization can identify, evaluate, and 4. Becoming the home of Indonesia’s best talents.
mitigate risks effectively to maintain operational and 5. Implementing effective governance practices
financial stability. and sustainable business innovations to
improve community welfare and environmental
Additionally, the roadmap integrates compliance sustainability.
with evolving regulatory requirements, enabling
BTN not only to fulfill legal obligations but also to In addition to its mission, BTN has outlined the 2029
leverage opportunities presented by policy changes to Aspiration to Achieve BTN’s Vision, including the following
enhance competitiveness. By strengthening corporate objectives:
governance structures, the roadmap promotes 1. Developing a Sustainable Savings Engine to
transparency, accountability, and efficiency, which Accumulate Total Savings of Rp120 Trillion
serve as the foundation for sustainable business growth. Capturing 3% of savings from the 20 largest
provinces, launching innovative propositions for
As part of the GRC Roadmap, BTN formulated its payroll, first-time homebuyers, and professional
Corporate Plan 2025–2029, comprising four key entrepreneurs, and becoming the transactional
interconnected elements that provide clear direction bank for customers and businesses by enhancing
for developing the Bank’s performance. These elements banking transaction capabilities.
are designed not only to strengthen BTN’s position in 2. Empowering Indonesian Families through
Indonesia’s housing market but also to contribute to Housing Loan Distribution to Realize the Dream of
inclusive and sustainable economic growth. The four Homeownership with a Target of Rp450 Trillion
elements are: Supporting approximately 1.2 million subsidized
mortgage (KPR) customers and 290,000 non-
• Vision, Mission, and Values that reflect BTN’s subsidized mortgage customers, as well as
fundamental goals and core principles; empowering around 27,000 SMEs related to
• BTN 2029 Aspiration to Achieve the Vision, which housing through propositions that cover the entire
outlines the Bank’s aspirations and ambitions for the business lifecycle.
next five years; 3. Becoming a Financial Partner for Consumers
• BTN Plan: 1+3+5 Strategic Initiatives, which detail a and Businesses by Providing a Comprehensive
structured approach and key priorities for achieving Range of Everyday Banking Solutions
the vision; and Increasing consumer product ownership through
• Strategic Initiatives, which describe specific high-margin credit (with a target of 8% of the loan
initiatives implemented to support the Bank’s portfolio), investment and payment solutions,
strategy. expanding the portion of non-housing loans
(with a target of 20% of the loan portfolio), and
BTN has established a clear vision and mission to increasing fee-based income (FBI) (~20% of
strengthen its strategic foundation and achieve its revenue); enhancing the conversion of mortgage
long-term objectives. BTN’s new vision for 2025 is to customers to full-service banking users (largely as
become Indonesia’s primary financial empowerment primary bank customers).
partner for families. This reflects a commitment to 4. Building a High-Quality Portfolio with Operational
helping Indonesian families manage their finances Efficiency
better, providing greater access to financial services, Developing efficient and digital operations (target
and promoting family economic empowerment. To CIR <50%) while strengthening a customer-centric
realize this vision, BTN has outlined five key missions as culture across the bank; maintaining low NPL
strategic guidelines: levels (target NPL <2.3%) across various credit
1. Becoming a government partner in promoting segments, supported by AI-driven underwriting
housing and financial inclusion. and collection processes.
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5. Expanding Service Coverage through Three 2. Sales model
Subsidiaries Restructure sales and operating models for cross-
Building a Sharia Bank business ranked #2 in collaboration (one CST model) and effectiveness
Indonesia; launching and developing a multi- (in several mono-lines).
finance company (with loan distribution > Rp2.5
trillion) and insurance companies (Gross Written 3. Upskilling
Premium/GWP > Rp2 trillion). Conduct bank-wide capability building focused
on customer-centric sales.
This aspiration reflects BTN’s commitment to integrating
innovation, operational efficiency, and sustainability into 4. Tech & data
all aspects of its business. To support this aspiration, BTN • Accelerate modernization of banking
has developed the BTN Plan: 1+3+5 strategic initiatives. platforms.
• Develop and adopt advanced AI assets.
Core strength
1. Funding 5. Risk Management
• Increase low-cost transactional savings Strengthen risk underwriting and revamp
through payroll (5% penetration) and mobile collections and recovery strategies to maintain
banking/balé (3 million customers). CoC <1.2%.
• Develop tailored propositions for 70k+ cash-
rich self-employed professionals. BTN has also developed integrated strategic initiatives
• Promote full-transaction banking for SME and to achieve sustainable growth and strengthen its
wholesale segments (20% utilization). position in the banking industry. These strategies focus
on enhancing funding engines, monetizing the housing
Holistic Banking Propositions ecosystem, transforming banking services, developing
1. Housing ecosystem subsidiaries, and strengthening digital infrastructure
• Add new customers through cumulative and human resources. Below is a summary of BTN’s
mortgages (1.5 million+) and build strategic steps to achieve its long-term aspirations:
comprehensive banking partnerships.
• Improve value chain penetration through 25+ Strengthen Engine for Sustainable Funding
anchor clients. (2025)
2. Full banking offering These targets focus on developing a sustainable
• Cross-sell HYL (5% penetration) and fee-based funding engine and leveraging the housing ecosystem
income to ETB (Existing to Bank) consumers. to deepen market penetration and enhance product
• Expand new sectors for SME loans (KUR, offerings. The key strategic initiatives include launching
KUMKM). an integrated payroll product as part of BTN’s efforts
to strengthen competitiveness and expand market
3. Financial group share, offering housing products tailored for millennials,
• Become the #2 player in Sharia banking and enhancing customer acquisition and transactions
through partnership development and through BTN Mobile/Balé. Additionally, there is a strong
footprint expansion. emphasis on boosting retail fund sales, targeting high-
• Establish new subsidiaries in life insurance and volume and high-growth potential segments.
multi-finance.
To monetize the housing ecosystem, the strategy
Capabilities to deliver at scale includes allocating 60% to subsidized housing schemes
1. Digitization and strengthening relationships with 50 key developers.
• Digitize end-to-end customer journeys to BTN also plans to diversify its banking product portfolio,
accelerate processes and efficiency. increase higher-yield returns, and build a solid Sharia
• Drive branch efficiency through automation to banking business post-spin-off.
achieve CIR <50%.
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As a key enabler, the digitalization strategy aims to funding engine, BTN will target cross-selling to capture
minimize manual processing in lending and funding the end-to-end value chain of the housing sector, while
operations, enhance transaction banking capabilities, expanding the ecosystem to include affluent residential
and expand the sales organization with sharper KPIs. customers, key industries, and top government
Furthermore, BTN is set to enhance its underwriting institutions. Another goal is to increase TB account
model using advanced data analytics and recruit IT registrations and utilization from 9% to 20% through a
and digital talent to support the development of a more single integrated platform.
modern and reliable banking platform.
In monetizing the housing ecosystem, the strategy will
Broaden Product Propositions and Cross- emphasize reducing churn and optimizing repayment
Selling (2026–2027) processes via centralized counteroffer teams. BTN also
plans to enhance the value and profitability of joint
The strategic targets for the 2026-2027 period focus on finance (B2B) schemes and channeling partnerships to
developing a sustainable funding engine, monetizing expand its offerings. For diversification, BTN intends to
the housing ecosystem, and expanding product launch a multi-finance subsidiary to support product
offerings while enhancing cross-selling opportunities. and service development.
Key initiatives include increasing market penetration
for wealth products targeted at cash-rich and hidden As an enabler, the focus will be on developing holistic
affluent customers, launching need-based financial service tools, including RM workbench and CRM systems,
solutions for self-employed professionals, and and deploying advanced technology platforms and
introducing merchant products for the retail food and analytics to support large-scale operations. Additionally,
restaurant sectors. strengthening the sales organization and service teams
across all products and segments will be accompanied
In monetizing the housing ecosystem, BTN aims to by the development of personalized customer journeys
strengthen acquisition channels through agents for through analytics and digitalization.
secondary home sales, deepen engagement with
anchor corporate clients, and launch bundled products To achieve these strategic initiatives, BTN has also
tailored to the construction and real estate sectors. developed a roadmap for these steps. The aim is to
Additionally, BTN will focus on expanding fee-based ensure that all objectives are met according to the
products and extending KUMK financing to high-growth designated timeline, resources, and priorities. With
sectors with low non-performing loan (NPL) risks. To a systematic roadmap, BTN can identify potential
further diversify its services, the Bank plans to establish challenges and plan appropriate mitigation measures
a joint venture insurance subsidiary offering both life to ensure effective and efficient implementation in
and general insurance. achieving the BTN Corporate Plan 2025–2029.
As a key enabler, the Bank’s digitalization strategy will Building a Holistic Framework / Actions for
be strengthened by enhancing digital marketing tools Sustainable Growth (2025)
and capabilities to drive cross-selling, alongside the
development of technology and data infrastructure to In 2025, BTN will implement a strategy divided into three
support more advanced analytics. Furthermore, BTN will parts: Support Business Growth & Sustainability, which
revitalize its underwriting and collection infrastructure optimizes the ALM Bank structure to support sustainable
to enhance advanced functionalities and optimize growth and enhance the bank’s profitability; Drive
omnichannel orchestration. Resilient & Secure Operational for Business Continuity,
which focuses on ensuring strong and secure operations
Deliver Full Banking Offerings with Superior to mitigate cyber risks, improve Service Level Agreement
Customer Experience (2028–2029) (SLA) effectiveness, and prevent fraud; and Ensure
Competency of GRC Talent and Strong GRC Culture,
The targets for the 2028–2029 period focus on which aims to develop employee talent and instill a
delivering comprehensive banking offerings with strong GRC culture to drive organizational integrity and
superior customer experiences. To build a sustainable high performance.
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The targets focus on balance sheet optimization, data. ESG initiatives will be integrated into core banking
strengthening risk management, and improving operations, and the governance of subsidiaries will be
operational efficiency. The focus areas include the aligned with global standards. BTN will also continue
development of the Risk Management Framework digitizing processes with data-driven decision-making
for asset and liability risks, integrating credit risk and enhance model risk management using digital
management with external data, and applying tools. Operational efficiency will be improved with digital
proactive approaches to strategic risks. The ESG file processing and sector prioritization mechanisms.
initiative aims to integrate ESG principles and eliminate
manual processes through digitalized underwriting For operational resilience, BTN will strengthen third-party
and verification. Strengthening operational resilience, oversight, data security, and fraud detection systems.
fraud detection systems, regulatory compliance, and Risk management systems and regulatory compliance
data protection are also priorities. Talent development will also be optimized. BTN will enhance leadership
and the GRC culture are prioritized through leadership capabilities and the GRC culture through leadership
development, professional certifications, and the forums, dual career path management, and GRC
adoption of a GRC culture across the organization. This capacity-building, as well as establish a Risk Academy
initiative supports sustainable growth with a focus on to address skill gaps. GRC will also be integrated into
high performance and robust corporate governance talent management.
practices.
The 2026–2027 target aims to develop an asset and
The 2025 target aims to build a holistic framework liability risk management framework focusing on
to support sustainable growth, focusing on the balance sheet optimization, cost reduction, and credit
development of asset and liability risk management, risk strengthening through the application of core/non-
balance sheet optimization, strengthening credit risk core models and ESG principle integration in banking
management through external data integration, and operations. BTN will also strengthen governance and
applying proactive strategic risk approaches. BTN will risk management in subsidiaries by aligning global
strengthen ESG initiatives in banking operations and standards and enhancing governance and risk
build governance and integrated risk management management capabilities. To improve operational
in subsidiaries. Additionally, BTN will improve effectiveness, BTN will eliminate manual processes
operational effectiveness through the digitization of by implementing data-driven analytics, intelligent
underwriting and verification, reducing paper usage. decision-making systems, and process digitization.
Strengthening operational resilience will include digital Additionally, BTN will strengthen operational resilience
risk management, cybersecurity, fraud detection, and through third-party control oversight, fraud detection
regulatory compliance. BTN will also develop high- systems, and system optimization for regulatory
performing talents and embed a strong GRC culture compliance. BTN will also promote the GRC culture
across the organization, focusing on leadership by enhancing leadership, improving certifications,
development, critical GRC skills, and workforce GRC establishing the Risk Academy to close capability gaps,
awareness to elevate organizational integrity. These and integrating GRC into talent management systems.
initiatives will strengthen BTN’s position in achieving
sustainable growth. Accelerate iGRC (Integrated Governance, Risk,
and Compliance) Excellence (2028–2029)
Driving Transforming and Effectivity through
Advanced Analytics (2026–2027) The targets for the 2028–2029 period focus on balance
sheet optimization, risk management, and operational
The targets for the 2026–2027 period focus on efficiency. BTN will implement market and liquidity
transformation and effectiveness through advanced risk management systems, integrating credit risk
analytics. In balance sheet optimization, BTN will with advanced collection scores in iLoan. BTN will also
implement optimization models and FTP systems, as well strengthen BWMK (Individual Wealth Management
as strengthen credit risk analytics with ESG and external Bureau) through Credit Decision Certification. For
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strategic risks, BTN will apply risk-based capital using the Risk-Adjusted Return on Capital (RAROC)
allocation strategies and accelerate ESG initiatives to method for performance and capital efficiency. BTN will
become an ESG Champion. At the subsidiary level, BTN accelerate ESG initiatives to become an ESG Champion
will enhance governance and risk-related employee and expand ESG integration into banking operations
competencies by automating Early Warning, Stop & while strengthening governance and risk management
Go Mechanism, and Risk Management Models using in subsidiaries to enhance employee integrity and
iLoan. Operational resilience will be strengthened capabilities. In operations, BTN will automate processes
with AI-based cybersecurity and improved data and such as early warnings and the Stop & Go mechanism
IT compliance. BTN will further enhance AML, CFT, in iLoan and enhance operational resilience through
and PPPSPM governance and ensure GRC roadmap strengthened zero-trust architecture and cybersecurity
implementation across all subsidiaries. for AI-, mobile-, and cloud-based applications. Fraud
detection systems using AI and improved compliance
The 2028–2029 targets focus on developing an asset with regulatory, data privacy, and IT security standards
and liability risk management framework through will remain priorities, along with strengthening the GRC
market and liquidity risk management, strengthening culture by ensuring GRC roadmap adoption across
credit collection scores via iLoan integration, and subsidiaries and enhancing GRC capabilities.
applying risk-based capital allocation strategies
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Nomination Process for the Highest Governance
Body [GRI 2-10]
In the nomination process for members of the highest a. Integrity;
governance body, the Bank involves shareholders b. Competence; and
through the GMS mechanism. The appointment c. A good reputation.
and dismissal of each member of the Board of 5. Independent Commissioner candidates must
Commissioners and Directors are conducted based have:
on GMS resolutions. The selection and nomination a. Adequate knowledge and experience relevant to
processes are carried out transparently, taking into their position as Independent Commissioners;
account recommendations from the Remuneration and and
Nomination Committee. When evaluating candidates b. Experience in banking and/or financial services.
for the Board of Commissioners and Directors, the 6. Former members of the Board of Directors or
Bank considers criteria such as integrity, honesty, executive officers from entities with ties to the
professionalism, leadership experience, loyalty, and time Bank must observe a cooling-off period of at
availability to support the Bank’s progress. Additionally, least one (1) year before serving as Independent
aspects of diversity, expertise, and experience in the Commissioners.
fields of economics, environment, and social issues are 7. Cooling-off periods are also required for:
also important considerations. The Bank ensures that a. Former Chief Executive Officers of the Bank;
candidates have no financial, familial, or business ties and
with members of the Board of Commissioners, Directors, b. Former Directors or executive officers
or Controlling Shareholders that could compromise overseeing supervisory functions within the
their independence. [GRI 2-10] Bank, requiring a minimum of six (6) months
before serving as Independent Commissioners.
Based on the Guidelines and Rules of Procedure for 8. Independent Commissioners must not have
the Board of Commissioners No. 18/KOM/BTN/2024, financial, managerial, ownership, affiliated, or
regarding the Guidelines and Rules of Procedure for family relationships with other members of the
the Board of Commissioners of PT Bank Tabungan Board of Commissioners, Directors, or Controlling
Negara (Persero) Tbk, the Bank has established criteria Shareholders that could affect their independence.
and requirements for candidates for the Board of 9. Independent Commissioners must not have direct
Commissioners, which include the following: [GRI 2-10] or indirect business relationships with the Bank.
1. Candidates eligible to be appointed as members 10. Independent Commissioners must not own shares
of the Board of Commissioners must meet the in the Bank, directly or indirectly.
requirements at the time of appointment and 11. Independent Commissioners transitioning
during their tenure following the provisions of from affiliated commissioners must meet the
the Bank’s Articles of Association and applicable requirements for Independent Commissioners.
regulations. 12. Independent Commissioners transitioning from
2. Members of the Board of Commissioners must affiliated commissioners must observe a cooling-
meet the capability and integrity assessment off period of at least one (1) year.
requirements under the regulations of the 13. The transition of commissioners to Independent
Financial Services Authority regarding the Fit Commissioners must obtain approval from
and Proper Test for the Main Parties of Financial the Financial Services Authority by meeting the
Services Institutions and must obtain approval requirements set by regulations for Financial
from the Financial Services Authority. Services Institutions.
3. At least one (1) member of the Board of
Commissioners must reside in Indonesia. The term of office for members of the Board of Directors
4. Members of the Board of Commissioners who and the Board of Commissioners is set at five (5)
have fulfilled the Fit and Proper Test requirements years and may be renewed for one additional term.
must have: Members of the Board of Directors are appointed for
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a period starting from the date of the closing of the The position of a Director ends under specific
General Meeting of Shareholders (GMS) that appoints circumstances, including death, expiration of the term,
them, or from a date determined by the GMS, and resignation, dismissal by a GMS resolution, or failure
ending at the closing of the fifth Annual GMS following to meet the requirements outlined in the Articles of
their appointment. However, the term of office may not Association and applicable laws and regulations. Upon
exceed five (5) years, while remaining compliant with the completion of their term, members of the Board of
capital market regulations. The GMS holds the authority Commissioners may be reappointed by the GMS for one
to dismiss a member of the Board of Directors before additional term.
the end of their term.
Remuneration Policy for the Board of Commissioners and Directors
[GRI 2-19]
The determination of remuneration for the Board of Directors, Board of Commissioners, and Supervisory
Commissioners and Directors refers to Minister of State- Board of State-Owned Enterprises. Additionally, the
Owned Enterprises Regulation No. PER-13/MBU/09/2021, remuneration for the Board of Commissioners and
regarding the Sixth Amendment to Minister of State- Directors is also determined based on the achievement
Owned Enterprises Regulation No. PER-04/MBU/2014 of their objectives and performance in managing the
concerning Guidelines for Setting the Income of Bank’s impact on economic, environmental, and social
aspects. [GRI 2-19]
Procedure for Determining the Remuneration of the Board of Commissioners
and Board of Directors [GRI 2-20]
The RNC drafts
The Board of The Board of
recommendations for the
Commissioners assigns Commissioners submits
Board of Commissioners
the Remuneration and the remuneration
and Directors’
Nomination Committee proposal to the General
remuneration to be
(RNC) to conduct a Meeting of Shareholders
submitted to the Board of
remuneration review. (GMS).
Commissioners.
1 3 5
2 4 6
The Human Capital The GMS authorizes the
Management Division The Board of Board of Commissioners
(HCMD) and related units Commissioners discusses to determine
prepare a remuneration the remuneration remuneration after
proposal for the Board proposal provided by the obtaining prior approval
of Commissioners and RNC. from the Series A
Directors. Dwiwarna Shareholders.
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In the remuneration determination process, BTN Key Performance Indicators (KPIs). These KPIs serve
collaborates with Willis Towers Watson to conduct as metrics to assess the extent to which strategic and
benchmarking and/or salary surveys. The Bank has a operational corporate goals are achieved. One of the
policy to defer variable remuneration (Malus) or claw key parameters in the KPIs for Directors is the aspect of
back variable remuneration already paid to officials sustainability, which focuses on achieving long-term
categorized as Material Risk Takers (MRT) by considering goals that support the company’s social, economic, and
various factors, including: [GRI 2-19] environmental continuity. The remuneration package
1. The magnitude of losses or damage to the Bank’s and facilities received by the Board of Commissioners
reputation. and Directors include a remuneration structure
2. The direct or indirect involvement of the relevant comprising salary, short-term incentives, long-term
employee in actions or transactions conducted. incentives, pensions, benefits, and one-off payments
(such as recruitment or retention bonuses). [GRI 2-19]
The salaries or honorariums for the Board of
Commissioners and Directors are determined based on BTN provides short-term incentives as immediate
several factors, including: rewards for employee performance achievements
1. The scale of the business; within a short period, typically one year or less. These
2. Business complexity factors; incentives are governed by Special Policy No. 3-B, on
3. Inflation rate; Remuneration, which refers to POJK No. 45/POJK.03/2015.
4. Financial condition and capability of the Bank; The short-term incentive program includes various
5. Relevant factors, which must align with applicable forms of rewards, such as cash bonuses, performance-
laws and regulations; and based salary increases, profit-sharing, and other
6. The composition of the salaries or honorariums financial incentives designed to motivate employees to
for the Directors and the Board of Commissioners, achieve corporate targets within a relatively short time
which are determined as follows: frame.
a. The salary of the President Director is
determined based on internal guidelines set In addition to short-term incentives, BTN also offers
by the minister; long-term incentives as a recognition of employees’
b. The salary of the Vice President Director is set sustained contributions over multiple years. These
at 95% of the President Director’s salary; incentives are regulated under KK.3-D, on Compensation
c. The salaries of other Directors are set at 85% of for the Board of Directors, Board of Commissioners,
the President Director’s salary; Senior Executive Vice Presidents (SEVP), and Supporting
d. The honorarium for the President Commissioner Organs of the Board of Commissioners, as well as
is set at 45% of the President Director’s salary; Special Policy KK.3-B, on Remuneration, which aligns
e. The honorarium for the Vice President with Minister of SOEs Regulation No. Per-13/MBU/09/2021,
Commissioner is set at 42.5% of the President and POJK No. 45/POJK.03/2015. Long-term incentives
Director’s salary; and may include shares, cash rewards, and other forms of
f. The honorarium for other Commissioners is recognition aimed at encouraging employees to focus
set at 90% of the President Commissioner’s on the company’s long-term objectives while ensuring
honorarium. their retention and loyalty to the organization.
The determination of remuneration at BTN is not only The following is the table of remuneration types and
based on individual roles and responsibilities but is other facilities provided for the Board of Commissioners
also influenced by the achievement of predefined and Directors. [GRI 2-19]
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Components of the Board of Commissioners and Board of Directors’ Remuneration
Board of Board of
Types of Remuneration and Other Facilities
Commissioners Directors
Remuneration
Honorarium/Salary
Routine Allowances (Clothing Allowance and Income Tax Allowance)
Holiday Allowances
Tantiem
Other Facilities in Kind (Housing, health insurance, and others) which:
a. Facilities That Can Be Owned
Post-Service Insurance
b. Facilities That Cannot Be Owned
Housing Allowance
Health Allowance
Transportation Allowance
Communication Allowance
Ratio of Highest to Lowest Salary [GRI 2-21]
BTN strives to distribute remuneration proportionally according to government regulations. The remuneration
and to avoid creating significant gaps. The Bank does policy is routinely reviewed and updated to align with
not implement an unconditional variable remuneration industry dynamics and the Bank’s business strategies.
policy (RBV), as such policies do not consider employees’ Additionally, compliance with banking regulations
length of service. As part of its commitment, BTN applies a related to remuneration is implemented The ratios of
competitive, fair, and proportional remuneration system the highest to the lowest salaries over the last three
to ensure that all employees receive compensation years are as follows: [GRI 2-21]
Ratio of Highest to Lowest Salary
Description 2024 2023 2022
Highest to lowest employee salary ratio 25.00 : 1 22.44 : 1 22.34:1
Highest to lowest Directors’ salary ratio 1.18 : 1 1.18 : 1 1.18:1
Highest to lowest Commissioners’ salary ratio 1.11 : 1 1.11 : 1 1.11:1
Board of Directors’ to employees’ highest salary ratio 2.89 : 1 2.92 : 1 2.90:1
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Management and Welfare Support
Annual Compensation Comparison
Description Unit 2024 2023 2022
Total annual compensation for the individual Rupiah 23,977,998,581 18,933,904,119 14,001,936,005
with the highest pay in the organization
Median annual compensation for all Rupiah 189,655,513 184,671,636 177,921,128
employees, excluding the individual with the
highest pay
Increase in total annual compensation for the % 26.64% 35.22
highest-paid individual in the organization
Increase in the median annual compensation % 2.70% 3.79
for all employees, excluding the highest-paid
individual
*)Data on annual compensation is obtained from the Human Capital Division.
Share Ownership Policy by Members of the Board of Directors and Commissioners
The Board of Commissioners and Directors have Regulation No. I-E on Information Disclosure Obligations,
disclosed information regarding their share ownership and the Bank’s Articles of Association. Members of
and/or that of their families, amounting to 5% or the Board of Directors and Board of Commissioners
more in BTN or other companies, both domestically are required to report their share ownership and any
and internationally. This measure is taken to ensure changes thereof to OJK—whether direct or indirect—no
transparency and minimize potential conflicts of interest later than 10 days after the transaction occurs.
that could affect corporate governance. Additionally, it
reflects BTN’s commitment to adhering to the principles As of December 31, 2024, none of BTN’s Board of
of Good Corporate Governance, which is a critical Commissioners or Directors held shares with total
component in implementing sustainability principles. ownership of 5% or more, either in BTN or other companies.
This demonstrates that there is no significant influence
Regarding share transactions by the Board of Directors from share ownership on their independence in carrying
and Board of Commissioners, BTN adheres to Financial out their duties and responsibilities, including during
Services Authority (OJK) Regulation No. 11/POJK.04/2017 strategic decision-making processes. This transparency
on the Reporting of Share Ownership or Any Changes serves as concrete evidence of BTN’s commitment to
in Share Ownership in Public Companies, as well as PT maintaining integrity and ensuring the Company is
Bursa Efek Indonesia (IDX) Board of Directors’ Decision managed free from conflicts of interest.
No. KEP-00066/BEI/09-2022 concerning Amendments to
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Evaluation of the Performance of the Highest
Governing Body [GRI 2-18]
The evaluation of corporate governance performance year, specifically at the end of June and December,
is a critical step to ensure the Bank consistently without involving third parties. The evaluation includes
meets the highest standards and adapts to business the Board of Commissioners, the Board of Directors, and
developments. The evaluation of the highest governing relevant work units, assessing the factors established to
body’s performance, related to the implementation determine the extent to which GCG implementation has
of Good Corporate Governance (GCG) and the been achieved. The results of the corporate governance
management of economic, environmental, and social performance evaluation over the past three years are
impacts, is conducted through a self-assessment as follows:
process. This evaluation is performed routinely every
Results of Self-Assessment of Corporate Governance Implementation for 2022–2024
2024 2023 2022
2 2 2
The self-assessment results with a score of 2 indicate commitment to excellent corporate governance
that the Bank’s management successfully implements practices and demonstrates that the Bank can be
corporate governance and that it is generally deemed trusted in governance matters.
good. This assessment reflects the fulfillment of
adequate corporate governance principles. Although Apart from the GCG and CGPI evaluations, BTN also
there are some minor shortcomings in implementing actively participates in other assessments through
governance principles, overall, these issues are not the ASEAN Corporate Governance Scorecard (ACGS).
considered significant and can be improved through ACGS is an international assessment tool that aligns
appropriate management actions. Detailed information corporate governance practices with standards set
on assessment criteria, evaluation recommendations, by the Organization for Economic Cooperation and
and follow-up actions based on the self-assessment Development (OECD) based on the OECD Principles,
results can be found in BTN’s Annual Report. [GRI 2-18] with the aim of supporting Good Corporate Governance
practices at BTN.
In addition to GCG evaluations, BTN actively participates
in the Corporate Governance Perception Index (CGPI) The ACGS seeks to promote companies in ASEAN
survey organized annually by the Indonesian Institute countries with high-quality governance, thereby
for Corporate Governance (IICG). CGPI is a research increasing investor trust in companies across the
and rating program that evaluates the quality of region. Each ASEAN member appoints representatives
corporate governance. In 2024, the Bank successfully for the Domestic Ranking Body (DRB) and Corporate
achieved a CGPI score of 91.52 with the predicate of Governance (CG) Experts to conduct assessments
“Most Trusted Company.” This result reflects BTN’s under the ACGS framework. In Indonesia, DRB and CG
Experts are represented by PT RSM Indonesia.
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Management and Welfare Support
Risk Management [GRI 2-23] [OJK E.3]
As a bank focused on providing credit and financing and procedures are conducted with transparency,
for housing, BTN’s portfolio of assets primarily consists accountability, and optimal sustainability. This
of Mortgage Loans (KPR). The Bank recognizes that approach not only supports strategic decision-making
various internal and external factors, such as changes but also ensures that all risk management processes
in the business climate, inflation rates, and interest are carried out according to high ethical and integrity
rate fluctuations, can impact this portfolio. Therefore, standards.
to minimize potential negative effects, sustainable
risk management has become one of the Bank’s top To control risks and ensure the Bank’s healthy
priorities. performance and achievement of objectives, BTN
applies a comprehensive risk management system.
The risk management implemented by BTN is grounded The Bank’s risk management system is supported
in the principles of Good Corporate Governance, which by four main pillars, which form the foundation for
serve as the foundation for every risk management implementing risk management across all operational
policy and procedure. Through the application of lines of the Bank, namely:
GCG, the Bank ensures that risk management policies
Risk Management System Pillars of BTN
Active oversight by the Adequacy of policies,
Board of Commissioners procedures, and limit-
and Directors setting
Risk
Management
Scope
Adequacy
of processes for
identifying, measuring,
Comprehensive internal
monitoring, and
control systems
controlling risks within
the risk management
information system
Active Oversight by the Board of Commissioners and Directors
The Board of Commissioners, the Sharia Supervisory This support ensures that every strategic decision
Board, and the Directors are supported by several made aligns with Good Corporate Governance
committees in carrying out banking activities, in practices. Subsequently, operational responsibilities
accordance with applicable regulatory provisions. are delegated to work units under the Board of
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Commissioners and Directors, including the Risk of Commissioners, Sharia Supervisory Board, Directors,
Management Unit, Compliance Unit, Internal Audit Unit, and the Risk Management Unit, as described in the
and Policy and Procedures Unit. Risk management is following organizational chart:
implemented through the active oversight of the Board
Oversight of Risk Management
Board of Commissioners and Directors Bodies Risk Management Work Units
Board of Sharia Supervisory
Directors
Commissioners Board
Risk Management Unit: Identifies,
1. Risk Monitoring 1. Asset and Liability
measures, monitors, and controls
Committee Committee (ALCO)
risk to assist the Directors in
executing their duties and
2. Audit responsibilities.
2. Technology Steering
Committee Committee
3. Remuneration 3. Risk Management
and Committee Compliance Unit, Carries out
Nomination compliance functions and
Committee preventive measures to support the
4. Human Capital
Directors’ tasks and responsibilities.
Committee
5. Credit Policy
Committee Internal Audit Unit, Ensures internal
controls to assist the Directors
in performing their duties and
6. Credit Committee responsibilities.
7. Business Committee
Policy and Procedures Unit,
Manages policies and procedures
to support the Directors in fulfilling
8. Transformation
Steering Committee their tasks and responsibilities.
9. ESG Committee
Risk Management Work Unit (SKMR)
The Risk Management Work Unit serves as a unit directly The Board of Commissioners, through the Risk
under the responsibility of the Director overseeing Monitoring Committee meetings, and the Directors,
the Risk Management function. This unit leads risk through Risk Management Committee meetings, bear
management operations and operates independently the responsibility to ensure that risk management
from the Operational Work Unit, functioning as a implementation in the Bank aligns with its characteristics,
risk-taking unit, the Internal Audit Work Unit, and the complexities, and risk profiles. Both committees
Compliance Work Unit. The implementation of the actively participate in managing risks to mitigate those
Bank’s risk management is based on GCG principles, faced by the Bank, adhering to the Risk Management
achieved through full participation across the Implementation Quality Standards (KPMR). These
organization in managing risks, reflected within the risk standards include aspects such as risk governance, risk
management organization structure. Additionally, the management framework, risk management processes,
Risk Management Director is responsible for supervising information management systems adequacy, and
ESG risks during financing processes, ensuring effective adequacy of internal control systems.
management of these risks in accordance with
established policies and procedures.
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Management and Welfare Support
The Risk Management Work Unit (SKMR) is led by a and continuously evaluates the Bank’s defined ESG
Division Head who reports directly to the Director of Risk strategies. Thus, this unit plays a crucial role in ensuring
Management. Currently, SKMR consists of four divisions: that ESG principles are effectively and consistently
the Enterprise & ESG Risk Management Division, the integrated into Bank activities.
Digital & Operations Risk Management Division, the
Wholesale Credit Risk Division, and the Retail Credit Risk The Enterprise & ESG Risk Management Division
Division. encompasses several departments, including the ESG
Department, Integrated Risk Management Department,
The Risk Management & ESG Work Unit, chaired by BOD- Credit Portfolio Risk Management Department,
1, acts as a control tower with directive, controlling, and Market & Liquidity Risk Management Department,
supportive roles in the implementation of ESG principles. and Model Validation Department. Below is the
As a control tower, the Risk Management & ESG Work organizational structure of the Enterprise & ESG Risk
Unit not only serves as a second line of defense in Management Division, which has been approved by
oversight but also plays a 1.5-line role in formulating the Board of Commissioners and Directors, reflecting
strategies, initiatives, and ESG roadmaps. This work BTN’s commitment to building reliable governance
unit monitors the implementation of the ESG roadmap capabilities.
Organizational Structure of the Enterprise & ESG Risk Management Division
Director of Risk Management
Enterprise & ESG Risk Management (ERMD)
Secretary
Environmental, Model
Integrated Risk Credit Portfolio Risk Market & Liquidity
Social & Validation
Management Management Risk Management
Governance
Framework Market &
Credit Risk
& Strategy Strategic Risk Liquidity Risk
Development
Development Dev
Market &
Policy & Credit Risk
Risk Culture Liquidity Risk
Implementation Assessment
Assessment
Data Reporting & Commercial & Market Middle
Sharia Risk
Communication SME Risk Office
Consumer Risk
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Organizational Structure of the Digital & Operations Credit Risk Division and Retail Credit Risk Division are
Risk Management (DORD) / Digital & Operations part of the four eyes principle and fall under the 1.5 line
Risk Management (DORD) consists of the Fraud Risk of model. The establishment of the Digital & Operations
Management Department, Digital Risk Management Risk Management Division Organizational Structure
Department, Operational Risk Management Department, is aligned with the IT & Digital Risk Roadmap and the
Regional Operational Risk Control Department, and increasing trends in IT and operational risk in the digital
Operational Risk Control Department. The Wholesale era, the structure is outlined as follows:
Organizational Structure of the Digital & Operations Risk Management Division
Director of Risk Management
Digital & Operations Risk Management (DORD)
Regional Office
Secretary
Regional
Fraud Risk Digital Risk Operational Risk Operational Risk Regional Business
Operational Risk
Management Management Management Control Control
Control
Digital Risk, Regional Regional
Fraud Strategy Operational Operational
Governance, Operational Business Control
& Prevention Risk Risk Control
Monitoring and Risk Control Supervisor
Development Analyst
Reporting Analyst
Branch
Fraud Digital Risk,
Digital Risk Business
Operational, Governance,
Assessment Control
Detection & Monitoring and
Investigation Reporting
CBC
Fraud Business
Monitoring & Control
Recovery
RLPC
Business
Control
Regional
Business
Control
Officer
Integration of ESG Risk Management
BTN has integrated Environmental, Social and ensures that all risks arising from business activities,
Governance (ESG) principles into the credit due including credit risk and ESG-related risks, are identified,
diligence process by directly involving the Credit Risk measured, monitored and reported transparently. The
Management team in the assessment of ESG issues. assessment report is submitted to the Board of Directors
Through the Risk Management Unit (SKMR), the bank to ensure responsible risk management.
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Management and Welfare Support
The ESG assessment process is conducted according 4. Credit Committee Meeting (CCM)
to the Four Eyes Principle, which involves a joint analysis The CCM is the final decision-making forum for
at each stage of the credit application process. These credit proposals. It is where the credit analysis
stages include: that also considers ESG aspects as agreed in
1. Initial Analysis under the Four Eyes Principle the Pre-CCM, is presented. Decisions are made
The Four Eyes Principle ensures that credit analysis, by consensus, and in the absence of consensus,
including ESG considerations, is conducted by by majority vote. The results of the decision are
two independent units: the business unit and the documented in the meeting minutes and serve as
risk unit. The business unit evaluates prospective the basis for issuing the Letter of Credit Approval
borrowers and collects supporting documentation, (SP2K).
while the risk unit assesses potential credit risk
considering ESG aspects and provides mitigation BTN also identifies ESG risk triggers, such as situations
recommendations if necessary. or indicators that require further evaluation before
financing decisions are made. If material risks are
2. Credit Proposal Preparation identified, such as significant environmental impacts,
After the ESG analysis is conducted by both the case will be escalated to the ESG Committee for the
units, the results are integrated into a credit development of appropriate mitigation measures. Once
proposal document. This document covers credit these measures are formulated, they are presented
risk assessment that considers ESG aspects, to the Board of Directors for approval and necessary
mitigation recommendations, and a conclusion follow-up.
on the borrower’s creditworthiness.
This escalation process ensures that significant ESG
3. Pre-Credit Committee Meeting (Pre CCM) risks are managed carefully and responsibly, in line
During this phase, both the business and risk units with BTN’s commitment to sustainability and good
present the results of the credit analysis that also governance principles.
considers ESG aspects. The compliance and legal
units provide regulatory and legal input.
Adequacy of Risk Management Policies and Procedures and Risk
Limit Setting
Risk Management Policies and Procedures and Risk Limit Setting
To mitigate the negative impact of various risks, BTN has As part of efforts to support effective risk management,
developed risk management policy guidelines designed the Bank has also implemented internal controls by
to anticipate potential impacts from various risks. As transforming the policy architecture and governance
part of compliance with Financial Services Authority procedures. This restructuring is aimed at ensuring
(OJK) Regulation No. 18/POJK.03/2016 concerning Risk the policies and procedures adopted are aligned with
Management Implementation for Commercial Banks, operational needs and prevailing regulations. The policy
BTN applies effective risk management in handling structure is designed hierarchically, encompassing
various types of risks. To meet regulatory requirements, three levels: general policies, specific policies, and
BTN has drafted formal risk management policies technical regulations. With this structure, the Bank
documented and reviewed at least annually to ensure ensures that the policies implemented are not only
effectiveness. This review process aims to ensure all regulatory-compliant but also support sustainable
relevant parties involved in risk management, including business operations and sound corporate governance.
risk owners and risk managers, understand and apply
risk management policies effectively.
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Policy updates undertaken include adjustments and activities in risk policy implementation, from strategy to
enhancements to ensure optimal risk management. operational management. Mapping of the General Risk
BTN is currently improving its General Risk Management Management Policy is illustrated from risk management
Policy as the highest-level policy in risk management strategy, risk governance, and targeted objectives,
implementation. The policy framework includes all including achieving good health levels (TKB).
BTN Risk Management Framework
Output
Corporate Soundness Level of
Strategy a Well-Performing
Bank
Management of Risk Types in
Risk Management Strategy Banks
Risk Credit Risk Credit Risk Management
Appetite/ Risk Risk Management Limit
Tolerance
Market Risk
Market and Liquidity Risk
Management
Liquidity Risk
Credit Risk Operational Risk
Capital
g Iden Strategy • Operational, Legal,
Recovery & tin tifi Operational Risk
Market Risk or ca Environmental Risk Compliance, and
Resolution ep
Reputation Risk
tio
R
Plan (RPP)
n
Management
Legal Risk
re m e nt
Risk • IT, Cyber, and Digital
Legal Risk Reputation Risk
Management Risk Management
trol
Process Compliance • New Activities
Con
asu
Risk and Products Risk
Strategic Risk Compliance Risk
Me
Management
• Business Continuity
M o n it r i n g Reputation Risk Management
o
Risk Return Risk Investment Risk
Management
Organization
• Strategic Risk
• Business Management
Strategic Risk
Risk Management Information System Continuity • Recovery Plan &
Management Resolution Plan
• Contingency
Plan
Risk Culture
• MR
Investment Risk
Internal implementation
Control for each risk Sharia Risk Management
Risk Management Guidelines Investment Risk
In addition to ensuring solid policies and procedures, regulatory requirements. This approach aims to ensure
the Bank has also established a risk limit-setting measurable risk management that is in line with the
process. This process is conducted by taking into Bank’s business strategy. Below is a brief overview of the
account the company’s work plan and budget (RKAP) risk limit-setting process:
as well as the recovery plan, aligned with applicable
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Limit Implementation Process
RKAP
RKAP
The Work Plan and Budget of the Company, prepared
Business as Usual for the upcoming year.
Risk Appetite
Risk Appetite (RA)
Contingency Actions
Risk Appetite is the level of risk the Bank is willing to
Risk Tolerance
take in order to achieve its objectives.
Recovery Plan Actions
Prevention Recovery Plan Risk Tolerance (RT)
Risk Tolerance is the maximum level of risk
Recovery Plan Actions
established by the Bank.
Restoration Recovery Plan
Recovery Plan
Recovery Plan Actions
Improvement Recovery Plan Recovery Plan is an action plan designed to address
potential financial issues that may arise.
Risk Management Policies and Procedures
BTN has established policy guidelines in the area of risk 16. Guidelines for Risk Profile Assessment of Branch
management, known as General Risk Management and Syariah Branch Offices
Policy (KUMR), which meet the minimum requirements 17. Internal Credit Rating Process (ICR)
mandated by Bank Indonesia Regulations/Financial 18. Guidelines for the Credit Scoring Model Process
Services Authority (OJK). (CSM)
19. Authority Limits for Commercial and Consumer
As part of the implementation of KUMR, BTN has also Credit
developed more detailed internal policies, including: 20. Guidelines for Calculating Allowance for
1. Guidelines for Reporting and Assessing the Bank’s Impairment Losses (CKPN)
Risk Profile 21. Policies for Debtors Affected by the Covid-19
2. Implementation of Reporting and Assessment of Pandemic
Bank Soundness Level 22. Business Continuity Management (BCM)
3. Risk Model Validation Procedures 23. Standard Operating Procedure (SOP) for Business
4. Guidelines for Risk Data Collection for the BTN-Loss Continuity Plan (BCP)
Event Database (BTN-LED Tool) Application 24. Standard Operating Disaster Recovery Plan (DRP)
5. Guidelines for the Liquidity Risk Measurement 25. Standard Operating Business Impact Analysis
Process (BIA)
6. Guidelines for Calculating and Reporting the
Liquidity Coverage Ratio (LCR) The policies also include ESG risks related to the
7. Guidelines for the Market Risk Measurement financing provided. As part of risk management,
Process BTN ensures that every financing decision considers
8. Interest Rate Risk Management in the Banking ESG aspects. This includes environmental impacts,
Book compliance with human rights, and adherence to Good
9. Guidelines for Conducting Stress Testing Corporate Governance. This aims to mitigate potential
10. Risk Model Validation Procedures risks stemming from financing that do not align with
11. Liquidity Monitoring Guidelines sustainability principles and social responsibility.
12. Risk Management Policy Guidelines (PKMR)
13. Risk & Control Self-Assessment The implementation of ESG risks in financing is essential
14. Guidelines for Implementing Recovery Plan Actions to ensure that loans provided by BTN not only deliver
15. Risk Culture financial benefits but also have a positive impact on
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society and the environment. Consequently, BTN is In addition, BTN remains focused on improving its risk
committed to applying these principles in every stage management information system. This initiative aims to
of financing, from risk analysis to impact evaluation. enhance the quality of the existing risk database, with
the expectation that the risk management information
BTN conducts regular reviews of its internal policies to system can be continuously developed and gradually
ensure they remain consistent with the latest regulatory implemented. The primary objective of this improvement
requirements. This process includes gap analysis and is to ensure that risk measurement and monitoring
adjustments to best practices commonly applied in the processes can be conducted in an integrated manner
banking industry, with the goal of improving the quality and presented accurately and promptly.
of risk management practices.
Strengthening Risk Management Policies and Procedures
To strengthen risk management policies and procedures, employees adhere to four cultural pillars in their work
BTN integrates risk management as one of the pillars of activities within their respective units. One of the priority
BTN’s culture, namely governance and risk culture. This pillars is governance and risk culture, which functions
pillar plays a strategic role in ensuring that all business to ensure that business implementation is conducted
processes are carried out prudently and in compliance carefully and in full compliance with regulations.
with applicable standards. The Bank ensures that all BTN
BTN Governance and Risk Culture Framework
BTN AKHLAK
Leading partner in empowering the financials of Indonesian families
To become the Premier
Partner in Empowering
4 Pillars of Culture
Financial Well-being
for Indonesian Families,
Grow and Meet Customer Deliver Outstanding all BTN employees
Clean and Trusted Keep Learning
Expectations Performance
(BTNers) must uphold
the four cultural pillars in
Sales & Service Culture Governance & Risk Culture Performance Culture Learning Culture carrying out their work
activities within their
8 Key Behaviours of BTNers
respective units.
The governance and
1 2 3 4 5 6 7 8 risk culture pillar is
the most critical to
Adhere firmly Continuously
to moral values learn, improve,
Be disciplined,
Take Be responsive
strengthen, ensuring all
consistent, Show mutual Be proactive,
and business and uphold
and thorough respect,
responsibility
effective,
to changes Be open to business processes are
ethics, fulfilling intrapreneurship and always and provide collaborations
commitments to enhance self-
in completing appreciation,
prioritize the
and efficient
opportunities that create conducted prudently
tasks with the and openness to in meeting
in compliance competence
best quality differences.
interests of the
customer needs.
for continuous added value. and in compliance with
with applicable and that of company. improvement
regulations. others.
outcomes. regulations.
AKHLAK: Core Values & 18 Behavioral Guidelines
Trustworthy Competent Harmonious Loyal Adaptive Collaborative
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Management and Welfare Support
Based on the above illustration, to support BTN’s 4. Learning Culture – Keep Learning
objectives founded on BTNers’ Core Values of AKHLAK, Foster a learning spirit to improve critical
eight primary behaviors are emphasized. These form competencies such as Sales, Digital Analytics,
four cultural pillars form the foundation of the 2023– Risk, and Collection, while strengthening BTNers’
2024 Bank Culture Program with the following objectives: understanding of the importance of AKHLAK values
1. Sales & Service Culture – Grow and Meet in their daily activities.
Expectations
Focus on achieving the end state of customer The strengthening of risk management policies is a key
satisfaction by increasing sales of funding, lending, element in ensuring the resilience of the Bank amidst
and digital products, as well as improving service the increasingly complex challenges of the banking
quality to drive BTN’s business and performance industry. BTN regularly reviews its internal policies
growth. as a step to ensure the adequacy of policies, risk
management procedures, and risk limits. Additionally,
2. Risk & Governance Culture – Clean and Trusted this process ensures that policies are consistently
Build awareness and understanding of risks aligned with the latest regulatory requirements. The
and their mitigation while implementing risk reviews include gap analysis, and the adoption of best
management principles consistently and practices commonly applied in the banking industry to
comprehensively. improve the quality of risk management. Internal policy
reviews are conducted at least annually, involving both
3. Performance Culture – Deliver Outstanding the Board of Commissioners and the Board of Directors.
Performance
Efforts to enhance performance to achieve set
goals.
Adequacy of Risk Identification, Measurement, Monitoring, and Control
Processes, as well as the Risk Management Information System
Risk Identification
In managing risk comprehensively, the risk identification from credit and financing activities but also include
process is a critical initial step in recognizing potential financial instruments such as securities, interbank
risks that may impact the achievement of business transactions, trade financing, currency exchange,
objectives. As a follow-up to this process, BTN has derivatives, as well as commitments and contingencies.
created a Risk Appetite Statement (RAS) as a framework To manage credit risk, BTN applies the Credit and
that defines the acceptable level of risk. The RAS helps Financing Policy Guidelines, monitors credit exposure,
ensure that every business decision and operational and ensures that credit risks remain within the defined
activity is based on an understanding of identified risks Risk Appetite and Risk Tolerance levels.
and remains within the defined risk tolerance limits.
Below are the 9 (nine) main risk categories covered in As part of effective risk management efforts, BTN
the RAS: regularly conducts Forum Portfolio Quality Reviews to
monitor credit quality and communicate the results to
Credit Risk the Board of Directors and related units. The Bank has
established a Credit Committee and implemented
Credit risk represents a potential loss due to the failure centralized systems such as the Commercial Banking
of counterparties to fulfill their obligations. BTN faces Center (CBC) for the commercial segment and the
various types of credit risks, such as risks arising from MSME Processing Centers (SPU) for the MSME segment.
debtor defaults, credit concentration, counterparty risk, To control credit concentration risks, the Bank uses
settlement risk, and country risk. Credit risk sources stem Portfolio Guidelines to mitigate overexposure in certain
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sectors. Additionally, BTN has developed the SME Credit The Bank regularly monitors daily, weekly, monthly, and
Scoring Model and an Early Warning System (EWS) to quarterly liquidity risks, evaluating exposures against
enhance credit risk monitoring. internal limits, including Risk Appetite, Risk Tolerance,
and Trigger Level Recovery Plans. Early Warning
To strengthen resilience against credit risk, BTN applies Indicator (EWI) monitoring is also conducted to identify
credit risk measurement in alignment with the Basel potential liquidity risks early. In accordance with POJK
III Reforms through a standardized approach as No. 5 of 2024, dated March 27, 2024, regarding the
stipulated in SE OJK No. 24/SEOJK.03/2021 on Risk- Determination of Status and Resolution of Commercial
Weighted Asset Calculation (ATMR). Decision-making Bank Issues, BTN monitors the Liquidity Coverage Ratio
authority regarding credit approval aligns with the (LCR) and the Net Stable Funding Ratio (NSFR), as
Credit Committee’s policies based on Special Policy regulated under POJK 19 in the year 2024 and POJK 20
Guidelines KK.9-D and the Governance Rules of the in the year 2024 These steps ensure that the Bank has a
Board of Directors and Commissioners, including KK- robust and appropriate liquidity management strategy
1.Q on Authority to Approve Credit Decisions. The Bank that aligns with the latest regulatory requirements.
also implements the Four Eyes Principle as a prudential
measure by separating business and risk functions. Market Risk
Furthermore, credit analysis in the commercial and
corporate segments has integrated ESG aspects Market risk represents a potential loss from the balance
to ensure a healthy and sustainable portfolio sheet and administrative account positions, including
management, aligned with macroeconomic dynamics. derivative transactions, due to overall market condition
changes, such as interest rate risk, currency exchange
Liquidity Risk rate risk, equity risk, and commodity risk. This risk may
originate from both trading book and banking book
Liquidity risk arises when a bank fails to meet its maturing positions. To manage market risk, BTN involves business
obligations from funding sources, either through cash units as well as the Enterprise & ESG Risk Management
flow or high-quality liquid assets, without disrupting Division in the processes of identification, measurement,
operational activities or financial conditions. This risk monitoring, and control of risk. Identification is
can result from the inability to generate cash flow from conducted for each new product or activity that has the
productive assets, asset sales, fundraising activities, potential to generate market risk. Additionally, market
interbank transactions, or received loans. Therefore, risk management is regularly discussed in the Assets
managing liquidity risk is a critical aspect of maintaining and Liabilities Committee (ALCO), focusing on banking
the Bank’s operational and financial stability. book risks, particularly interest rates and exchange
rates.
In managing liquidity risk, the Bank refers to the Liquidity
Risk Management Policy Guidelines, which are part of BTN measures interest rate and exchange rate risks
the broader Bank Risk Management Policy Guidelines. through sensitivity analysis to assess the impact of
These guidelines encompass active oversight by market changes on profit (loss) and equity. For banking
the Board of Commissioners and Directors, liquidity book positions, interest rate risk measurement uses
risk management processes, and the formulation of the repricing gap method, as stipulated in Technical
policies, procedures, and risk limit settings. Liquidity risk Guidelines No. PT.8-F.I, on Interest Rate Risk Management
measurement is carried out by the Treasury Division in the Banking Book (IRRBB). Additionally, in accordance
and the Risk Management & ESG Division following with SE OJK No. 12/SEOJK.03/2018, BTN submits quarterly
Technical Guidelines No. PT.8-F.4. The Bank employs four reports on IRRBB. To complement these measurements,
main methods to measure liquidity risk: stock-based BTN also conducts stress testing to evaluate resilience
analysis, maturity profile analysis, cash flow projections, under extreme market changes. Stress testing results
and stress testing. Stress testing is conducted using are formulated at the beginning of each year by
Bank-Specific Crisis (BSC) and General Market Crisis the Enterprise & ESG Risk Management Division in
(GMC) scenarios to measure the adequacy of available collaboration with the Working Group Stress Testing
liquid assets. within the Risk Division, referencing both regulatory and
internal Bank scenarios.
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Market risk control is performed by evaluating exposure Bank can quickly identify early warnings related to
against Risk Appetite and Risk Tolerance, which are risks and take necessary preventive actions.
periodically revised. To manage exchange rate risk
exposure, the Bank sets various limits, including the BTN also implements Business Continuity Management
Net Open Position (NOP), in compliance with PBI No. (BCM) to ensure the continuity of operations in response
17/5/PBI/2015. The Bank also implements SEOJK No. to external disruptions such as disasters or IT system
23/SEOJK.03/2022 related to risk-weighted asset failures. The BCM policy encompasses preparedness,
(RWA) calculations for market risk, which has been disaster response, and operational recovery, with
effective since January 2024. In line with the Basel III regular simulations and evaluations conducted.
implementation, the Bank submits monthly Liquidity
Coverage Ratio (LCR) reports and quarterly Net Stable Additionally, to ensure effective control implementation,
Funding Ratio (NSFR) reports through the OJK Online BTN has established the Business Control Organization,
Reporting Application (APOLO), in accordance with which functions as part of the 1.5th line of defense. This
POJK 19 in the Year 2024 and POJK 20 in the Year 2020, to organization focuses on operational risk control for daily
ensure compliance with liquidity and funding adequacy activities in various units, such as branch offices (KC),
standards set by the regulator. Syariah branch offices (KCS), the Commercial Banking
Center (CBC), and the Regional Loan Processing
Operational Risk Center (RLPC). This organization comprises various
sections, including the Regional Business Control (RBC),
In implementing operational risk management Branch Business Control (BBC), and the Commercial
processes, the Bank has established Operational Risk Banking Centre Business Control (CBC-BC), tasked with
Tools designed to identify, measure, and control risks monitoring and managing risks within their respective
that may impact operations and the achievement of work units in an integrated and systematic manner.
objectives. The Operational Risk Tools include:
1. Risk and Control Self-Assessment (RCSA) Legal Risk
RCSA is conducted in each Bank unit to identify
and measure operational risks inherent in daily BTN identifies legal risks that may arise from factors
activities. Each unit is required to evaluate the such as lawsuits, legal deficiencies, and vulnerabilities
potential risks associated with their tasks and how in legal aspects attached to various functional activities,
these risks might affect the achievement of their including credit, treasury, investments, operations,
objectives. RCSA serves as an early mechanism to information technology, and human resource
ensure that identified risks are properly managed. management. Legal risk measurement is conducted by
the Risk Management Division in collaboration with the
2. Loss Event Database (LED) Legal Division. This process results in evaluation reports
The LED is used to collect data on operational risk that include analysis of legal cases, contingencies
incidents occurring in branch offices. Using the arising from lawsuits, and the quality of legal agreements
criteria set by Basel II, the LED records various types in credit documentation.
of losses such as actual losses, near losses, and
potential losses for each risk incident. This data Legal risk monitoring is performed regularly by evaluating
is critical for analyzing patterns and trends in risk the effectiveness of policy, procedure, and compliance
events, helping to design mitigation measures to implementation in accordance with regulations and
prevent similar incidents in the future. Bank standards. The Legal Division provides legal input
and recommendations to all divisions conducting
3. Key Risk Indicator (KRI) contract reviews with third parties. To support legal
KRIs are used to monitor and analyze risk trends risk monitoring, the Bank utilizes the Legal Application
that may indicate potential operational issues in System (LApS), which functions to monitor the progress
the future (predictive) or confirm incidents that of legal cases, both criminal and non-criminal, occurring
have already occurred (lagging). With KRIs, the at branch offices or headquarters.
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Additionally, the Bank assigns Regional Legal operations, and services, outlined in the business plan
Representatives (RLR) to each regional office to provide by the Corporate Strategy & Planning Division, based on
legal assistance in litigation cases, represent the Bank general policies established by the Board of Directors.
in legal proceedings, offer legal opinions, and conduct Strategic risk measurement is conducted by comparing
legal watch activities in accordance with Bank Indonesia actual results against predetermined performance
regulations. RLRs are also responsible for managing targets, monitored through Key Performance Indicators
and mitigating legal risks within their regions to ensure (KPIs). Monitoring also involves the Risk Management &
effective legal risk mitigation efforts. ESG Division, which evaluates risk exposures relative to
the Bank’s Risk Appetite and Risk Tolerance limits.
Reputation Risk
Strategic risk control is carried out by analyzing
BTN manages reputation risk through identification, discrepancies between actual reports and business
measurement, monitoring, and control involving all plan targets. The Corporate Strategy & Planning Division
business units. Each unit acts as the first line of defense regularly submits improvement actions to the Board
in managing customer relationships. of Directors. The Board of Commissioners, Board of
Directors, and relevant divisions review fundamental
To identify risks, BTN monitors customer complaints and strategies, business transformations, infrastructure, and
negative publicity through the Customer Complaint human resource management. Reviews of Risk Appetite
System (SPN), which integrates with branch offices and Risk Tolerance are conducted at least annually
and the Contact Center. Risk measurement includes to ensure the Bank’s strategies remain relevant and
assessing factors that affect reputation, such as adaptive to the dynamics of the business environment.
negative publicity and customer complaints.
Compliance Risk
Monitoring is conducted by the Risk Management
Division, which provides recommendations for The Bank manages compliance risk through the
improvements based on reputation risk evaluations. Compliance Regulatory Management System (CRMS)
Control is handled by the Corporate Secretary Division application, which enables employees to access external
and the Customer Service Division, which resolve regulations and provides alerts for reporting obligations
customer complaints in line with SLA targets to ensure to regulators. The Compliance and Governance Division
effective mitigation of reputation risks. (CMGD) is responsible for monitoring compliance risks,
preparing a list of external obligations, and ensuring that
Strategic Risk internal policies comply with applicable regulations.
Strategic risk refers to the potential loss arising from For enhanced oversight, Regional Compliance
inaccurate or inappropriate strategic decisions, as well Supervisory Officers (RCSO) in regional offices evaluate
as the failure to anticipate changes in the business branch compliance with regulations and standard
environment. This risk may occur due to strategies operating procedures (SOPs). Compliance risks are
that are not aligned with the Bank’s vision and mission, reported to the Board of Directors regularly or as
incomplete or inadequate strategic plans across required.
organizational levels, or failure to anticipate changes
in technology, macroeconomic conditions, competitive Compliance risk measurement is conducted by
dynamics, or policy changes from the government and evaluating the potential impact of non-compliance
regulators, such as Bank Indonesia and the Financial with regulations. Parameters used include types of
Services Authority (OJK). These factors contribute to breaches, frequency, and compliance history. The
strategic risk. Risk Management Division coordinates with the
Compliance Division to ensure effective compliance risk
BTN identifies strategic risks through the analysis of management and mitigation actions are implemented
functional activities, such as credit, treasury, investments, when necessary.
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ESG Risk those whose businesses are directly affected by
climate change. Therefore, BTN establishes specific
Climate Change Risks and Opportunities environmental criteria before disbursing credit to ensure
Climate change can have a significant impact on funds are not allocated to projects or activities that may
the banking sector. One of the consequences is the harm the environment. This step is crucial in mitigating
increased risk of loan defaults by debtors, especially risks associated with financing activities that contribute
to environmental degradation.
Description of Estimated Impact on Various
Risks and Opportunities
Material Topic Sustainability Risks/ Financial Aspects of the
Related to Sustainability
Opportunities Company
Sustainability Risk
Climate Change Risk - Physical
Climate Change & Risks from Water Crisis & As a bank with a dominant 1. Decline in Collateral Value &
Ecosystem, Natural Resource Flooding portfolio in the housing Stranded Assets: Properties
Utilization & Environmental sector, BTN faces risks from in water crisis- or flood-
Management water crises, including prone areas risk devaluation,
droughts, declining water reducing BTN's credit
quality, and flooding. These collateral quality.
factors can reduce the value 2. Increase in Non-Performing
of financed assets, increase Loans (NPL): Water crisis and
credit risk, lower property flooding raise developers'
appeal, and impact the operational costs and lower
long-term stability of BTN's property appeal, increasing
financing portfolio. BTN's debtor default risk.
3. Decline in Mortgage Demand:
Consumers avoid high-water
and flood risk areas, slowing
BTN's mortgage portfolio
growth."
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BTN has also mapped the risks and opportunities arising Below are the identified climate change risks and
from climate change in order to comply with IFRS S1 and opportunities mapped by the Bank: [GRI 201-2] [FS10, FS11] [TCFD
S2 standards. This risk and opportunity map has been Stratg.a,b] [TCFD Risk.a,b,c]
adjusted to the recommendations of the Task Force on
Climate-related Financial Disclosure. Furthermore, BTN
has identified the financial impacts resulting from these
climate-related risks and opportunities. [TCFD Gov.b]
Short Term Medium Term Long Term Mitigation Measures
Regulatorily, OJK mandates If significant rainfall increases Over the next 10 years, water BTN has conducted Climate Risk
banks to conduct climate cause flooding or droughts crises and rising flood risks Stress Testing (CRST) to assess
risk stress tests, including occur in BTN-financed may tighten government the impact of climate risks on its
portfolios in flood- and housing areas within the next regulations on water loan portfolio in flood- and fire-
fire-prone areas, posing a 3-5 years, it may result in: management, creating new prone areas.
compliance risk. risks for BTN:
From a profit perspective, 1. Higher NPL Risk in affected
water crises are not an areas 1. Financing Restrictions:
immediate risk for BTN, as its 2. Decline in property loan Regulations may ban
financed housing is currently demand in impacted housing development in
outside water crisis. regions high-risk areas, limiting
3. Disruptions to ongoing BTN's opportunities.
projects 2. Water Efficiency
4. Collateral devaluation & Requirements: Water
stranded assets conservation and green
drainage systems may
increase costs and slow
projects.
3. Water Risk Integration:
OJK may require banks to
assess water risks in credit
decisions, impacting
property financing.
4. Higher Insurance
Premiums: Increased
water risks may increase
insurance costs and
reduce BTN mortgage
demand.
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Description of Estimated Impact on Various
Risks and Opportunities
Material Topic Sustainability Risks/ Financial Aspects of the
Related to Sustainability
Opportunities Company
Climate Change Risk - Transition
Climate Change & Regulatory Risk: Carbon Tax Bank BTN faces risks from 1. Increase in NPLs: The carbon
Ecosystem Implementation the implementation of the tax increases debtor costs,
carbon tax as regulated in increasing the risk of default
Law No. 7 of 2021. This tax and deteriorating credit
will take effect on coal-fired quality.
power plants in 2025 at a 2. Stranded Assets: High-
rate of Rp30 per kg CO2e and emission assets may lose
may potentially be expanded value, reducing the collateral
to other sectors, including value for BTN loans.
construction. 3. Decline in ESG Rating:
Financing high-emission
projects may hinder access
to green funding.
4 Tax Risks for the Bank: If BTN
is subject to the carbon tax,
operational costs will rise,
profitability will decline, and
financing for high-emission
sectors may decrease.
Other Sustainability Risk
Sustainable Products & Risk of sustainable This risk may harm the The bank will fail to obtain profits
Services products/services losing bank if it is late in adopting or low-cost funding, such as
competitiveness sustainability principles. green, social, or sustainability
With the world increasingly bonds, which have already been
focused on ESG, companies issued by other companies.
that offer sustainable
products and services
receive greater support from
investors and are considered
more equitable.
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Short Term Medium Term Long Term Mitigation Measures
There is no short-term risk as If the carbon tax is expanded If BTN continues to provide 1. Exclusion List and Sustainable
BTN does not provide loans to BTN's debtor sectors, the loans to sectors subject Finance Framework: BTN
to the coal-fired power plant risk of NPLs will increase. If to the carbon tax after its has an exclusion list and
industry. the bank is also subject to implementation, the potential a sustainable finance
the tax, BTN will face higher impacts include: framework that serves as
operational costs, pressured portfolio guidelines to reduce
profitability, and reduced 1. Stranded Assets and exposure to high-emission
financing for high-emission Declining Collateral Value sectors by allocating more
sectors. due to stricter regulations. financing to low-carbon
2. Decline in ESG Rating and projects.
Difficulty Accessing Green 2. Development of Green
Financing. Financing Products: BTN has
developed green financing
products to diversify its
portfolio, including Green
Mortgage Loans (KPR
Hijau), green bonds, and
other sustainable financing
schemes.
3. Focus on Low-Emission
Housing: Given that the
majority of BTN's portfolio is
in the mortgage sector. BTN
began financing low-emission
homes that meet at least
1 green building standard,
such as the use of recycled
/ ecofriendly materials and
energy efficiency, supporting
the transition to a sustainable
property sector.
4. Climate Risk Stress Testing
(CRST): BTN has conducted
Climate Risk Stress Testing to
assess the impact of climate
risks on its credit portfolio,
including transition risks
arising from the carbon tax
and stranded assets.
Lost opportunities in: - The bank will fail to The bank has implemented
1. Having sustainable become a pioneer in ESG Low-Emission Housing, financing
products; implementation and will and funding instruments that
2. Getting sustainable have a poor ESG rating, support ESG aspects, such as
funding. making it less attractive to sustainability-linked loans and
investors. green bonds (planned for 2025),
as well as launched the super
app BALE by BTN and BTN Digital
Store.
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Description of Estimated Impact on Various
Risks and Opportunities
Material Topic Sustainability Risks/ Financial Aspects of the
Related to Sustainability
Opportunities Company
Governance Risk of reputation and trust The risk may harm the bank 1. Losses such as failing to
if its governance is poor, secure investment funds
leading to negative public from investors.
and investor perception, 2. The public will lose trust in the
which in turn damages its bank, leading to a bank run
reputation. In the worst-case and ultimately causing the
scenario, this could trigger a bank to collapse.
bank run by debtor.
Information Security Risk of customer data Another risk that could harm Financial losses may include
security and banking IT the bank arises from data ransom payments to recover
systems breaches or hacker attacks frozen data due to malware,
caused by inadequate IT lawsuits from customers if their
security systems. data is leaked, and damage
to the bank's reputation, which
could lead to a bank run and
ultimately cause the bank to
collapse.
Sustainability Opportunity
Climate Change & Opportunities from carbon The government has 1. Increased Income: BTN can
Ecosystem credit stipulated Presidential earn income from selling
Decree no. 98/2021 carbon credits.
concerning the Economic 2. Strengthening ESG
Value of Carbon (NEK) and & Competitiveness:
POJK no. 14/2023 concerning Participation in carbon
Carbon Trading through trading improves ESG ratings
the Carbon Exchange (IDX and attracts investors.
Carbon). With this regulation, 3. Green Product Diversification:
BTN has the opportunity BTN can develop carbon
to sell carbon credits both credit-based products.
domestically and abroad 4. NZE 2060 support: Utilization
from low-emission homes of carbon credits helps the
that meet sustainability transition to a low-carbon
standards. economy.
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Short Term Medium Term Long Term Mitigation Measures
- Investor and public trust will - The bank has strengthened
decline, potentially leading to anti-corruption, anti-fraud, and
significant losses. anti-bribery measures, as well as
developed digital applications
to support more efficient and
paperless business processes.
Financial losses may include The bank's reputation will be - The bank is committed to
ransom payments to recover damaged, causing the public Personal Data Protection,
frozen data due to malware to initiate a bank run, which including strengthening IT
and lawsuits from customers could ultimately lead to the security and establishing a
in the event of a data breach. bank's collapse. dedicated PDP department
under the Compliance &
Governance unit.
BTN will be able to increase 1. As the number of low- 1. With the number of low- 1. BTN has carried out a
income from carbon trading emission homes increases emission houses reaching feasibility study with
through the Indonesian to 150,000 units, BTN has 150,000 units, BTN can consultants as a basic basis
Carbon Exchange (IDX more carbon credits to significantly increase for selling carbon credits from
Carbon) as well as sell, increasing carbon income from carbon low-emission homes.
international carbon markets trading volume and bank trading as a stable source 2. As the next stage, BTN will
that are already operating. income. of income. collect data on assets that
2. Expansion of the 2. Carbon credit prices have the opportunity to
domestic carbon are likely to increase as store carbon and drafting
market is increasingly emissions regulations a Mitigation Action Plan
mature, enabling carbon become stricter, Document (DRAM). The draft
credit prices to be increasing demand from will then be registered and
more competitive and companies that must evaluated by the National
profitable for BTN. reduce their carbon Registration System (SRN)
footprint. and international verification
3. Carbon credit becomes institutions.
a more established 3. BTN already has around 1,300
financial instrument, low-emission houses as a
opening up opportunities pilot project. In the future, BTN
for integration in BTN's will build a total of 150,000
long-term strategy and low-emission houses by 2029.
strengthening its position
as an ESG Champion in
green banking.
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Description of Estimated Impact on Various
Risks and Opportunities
Material Topic Sustainability Risks/ Financial Aspects of the
Related to Sustainability
Opportunities Company
Use of Natural Resources & Opportunities from the OJK has published the 1. Increasing Green Financing:
Environmental Management implementation of the KKUB Indonesian Green Taxonomy Focus on KKUB and OJK's
and Green Taxonomy by OJK / Taxonomy for Indonesian Green Taxonomy.
as well as the government's Sustainable Finance as a 2. Access to Green Funding:
NZE targets guide for LJKs to map and Enables the issuance of
increase financing in the green bonds or sustainability
Green sector. Apart from bonds.
that, OJK also classifies the 3. Support NZE 2060: Green
Sustainable Business Activity Building Certification and
Category as a guideline for environmental initiatives
LJK to support financing in improve the bank's
the sustainable sector and reputation.
contribute to NZE 2060
Sustainable Products and Opportunities from Opportunities from 1. Increased Income - BTN can
Services government support and implementing Low Emission obtain additional income
NZE targets mean that banks Homes, financing and from fee based Bale by BTN
need to create sustainable funding instruments that and efficiency of digitalized
products support ESG aspects such as paper operational costs at
sustainability-linked loans Bale by BTN
and green bonds as well as 2. Strengthening ESG Ratings
launching the BALE by BTN and Competitiveness
super app 3. Access to Green Funding –
BTN can more easily access
funding from ESG investors,
the GCF, and international
financial institutions that
support low-carbon projects.
4. Diversification of Green
Financial Products and
Services – BTN can expand
its green financing portfolio
such as the OJK KKUB
sustainable sector
Information Security Opportunities for PDP Law no. 27/2022 applies With good PDP governance and
implementing Personal Data from 17 October 2024 to information security systems,
Protection protect personal data, banks will avoid financial
prevent misuse, and increase losses such as data leaks and
public trust. LJKs, including customer data demands.
banks, are obliged to comply.
Sustainable procurement Opportunities from the Sustainable procurement 1. With this application, the
Implementation of End-to- is an area with significant bank can achieve cost
End Sustainable Procurement potential for further efficiency in paper usage
development, one of which during the procurement
can be achieved through process.
digitalization. 2. The bank's reputation
improves as its procurement
system becomes more
integrated, transparent,
paperless, and its business
processes more efficient.
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Short Term Medium Term Long Term Mitigation Measures
1. Increasing Sustainable From lending activities to the By continuing to be 1. The Bank has distributed
Financing: Focusing on sustainable sector, banks will committed to sustainability, credit to sustainable sectors
KKUB and OJK's Green gain access to funding, such the bank will have a good (KKUB OJK) such as SPAM
Taxonomy improves bank as by issuing green bonds or reputation in the eyes of projects, renewable energy,
reputation and investor sustainability bonds investors and the ESG rating environmentally friendly
confidence. can increase, and the transportation, etc.
2. Green Building company's financial stability 2. The bank will plan to issue
Certification: Good can be better maintained. thematic green / social /
environmental and waste sustainability bonds
management supports 3. The Bank has supported
green certification and the various environmental
bank's reputation. conservation programs
and good building waste
management, including
obtaining Green Building
certification for tower 2 of BTN
Increased Income – BTN can The Bank will be known 1. With the number of low- The Bank has implemented
obtain additional income as a pioneer of green emission houses reaching Low Emission Homes, financing
from fee based Bale by BTN and sustainable banking 150,000 units, BTN can and funding instruments that
and the efficiency of paper products & services that significantly increase support ESG aspects such as
operational costs that have provide many options for income from carbon sustainability-linked loans and
been digitized at Bale by BTN customer satisfaction trading as a stable source green bonds as well as launching
of fee-based income. the BALE by BTN super app
2. Banks will obtain funding
through the issuance
of green/social/
sustainability bonds
3. ESG Rating will increase as
will reputation and trust in
banks
Managing customer personal Banks become compliant Banks become compliant The Bank has committed to
data is better and safer with the regulations of the with the regulations of the Personal Data Protection, one
PDP Law, the security of PDP Law, the security of of which is by strengthening
customers’ PDP information is customers’ PDP information is IT and establishing a special
maintained, reputation and maintained, reputation and PDP department under the
trust in the bank can increase trust in the bank can increase Compliance & Governance work
unit
With this application, The bank's reputation The bank's reputation The Bank has developed an End
banks can make paper will be better if the bank's will be better if the bank's to End Procurement application
costs efficient in the bank procurement system is more procurement system is more to support a sustainable and
procurement process integrated, transparent and integrated, transparent and paperless procurement process
paperless, and business paperless, and business
processes are more efficient processes are more efficient
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Climate Risk Stress Testing (CRST) climate change. BTN is committed to supporting the
As part of global objectives, since 2023, the Financial transition to a low-carbon economy by adopting a
Services Authority (OJK) has issued policies on Climate science-based approach to climate risk analysis.
Risk Stress Testing (CRST) for financial institutions. This Climate risk testing is conducted through scenario
policy aims to identify and manage risks related to modeling and sensitivity analysis to identify potential
climate change, including physical risks and transition impacts and mitigate possible risks.
risks towards a low-carbon economy. In response to
this policy, BTN has taken positive steps by integrating BTN employs climate scenarios designed by the NGFS
the 2023 OJK CRST Guidelines into its risk management (Network for Greening the Financial System) and adjusts
strategy. These guidelines serve as a reference for them to suit Indonesia’s conditions.
systematically assessing the potential impacts of
Climate Risk Stress Testing (CRST) Matrix
High
Disorderly Too little, too late
Delayed
2ºC
Transition risks
Net Zero
2050
(1,5ºC)
Current
Policies
Low
Orderly Hot house world
Low Physical risks High
The three main scenarios used include: Current Policies variables such as GDP, inflation, exchange rates, and
(CP), which reflect current policies without additional interest rates, which are used to evaluate the impact
changes; Delayed Transition (DT), which depicts a of transition and physical risks on the bank’s portfolio.
delayed transition with drastic actions taken in the future; The macroeconomic modeling phase utilizes variables
and Net Zero 2050 (NZ), which represents an ambitious such as inflation and exchange rates to calculate their
scenario to achieve net zero carbon emissions by 2050. impact on credit and securities risks.
These scenarios include projections of macroeconomic
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The following is an illustration of the CRST methodology, covering the process from information gathering to the
assessment of capital adequacy impact.
CRST Framework Overview
1. Pengumpulan
2. Climate Risk Transmission 3. Impact Assessment
Informasi
NGFS Transition Risk Assessment Risk Indicators Credit Risk
Transition: Expected Credit
Portfolio Level: Probability of
• Macro Loss (ECL)
Loan Default (PD)
• Micro
Quantitative
Stressed Test Impact
RWA Kredit
Physical
Capital
Non-Performing Pendapatan Adequacy Ratio
Loan Bunga (CAR)
IPCC Loss Given Market Risk
Changes in the PD Matrix Default (LGD)
Physical
Market RWA
Ekuitas (B/S)
Loan To Value
Ratio (LTV)
Securities Operational Risk
Internal Data:
• Debtors Operational RWA
• Bank Interest Rate Changes Mark-to-Market
(MtM)
Qualitative
Liquidity Risk
Repricing Gap
External Data: Physical Risk Assessment
High Quality Inflow
• Public
Loss Event Liquid Asset LCR
• Private Collateral: Guarantees
(HQLA) Outlaw
The scenario analysis process begins with data the scope of climate risk; electricity, gas, steam/hot
collection from internal sources such as debtor financial water supply; transportation and warehousing; mining
performance and credit portfolio, as well as external and quarrying; manufacturing industry; and agriculture,
data from NGFS and IPCC. This analysis aims to identify forestry, and fisheries. These sectors represent 89.6% of
priority sectors that are impacted. These sectors consist the total credit portfolio.
of mortgage loans (KPR); construction; sectors outside
Proportion of Risk Impact Across Each Sector
Agriculture, Forestry, and Fisheries
Manufacturing Industry
Mining and Quarrying
Transportation and Warehousing
Electricity, Gas, Steam/Hot Water Supply
Sectors Outside the Scope of Climate Risk*
Construction
Mortgage Loans (KPR)
0% 10% 20% 30% 40% 50% 60% 70% 80% 90%
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a. Transition Risk Scenario Analysis gas, oil), passenger numbers, and GDP growth.
In the transition risk scenario analysis, BTN This simulation evaluates the impact on credit risk
incorporates relevant macroeconomic variables indicators, including Probability of Default (PD), Loss
such as unemployment rates, energy prices (coal, Given Default (LGD), and Non-Performing Loan (NPL).
Macroeconomic Projection Chart
Coal Price Oil Price Gas Price Number of Passengers (billion plan/
year) vs Yearly Change
Graph Legend
KEY INDICATORS
Net Zero 2060
Delayed Transition (3%)
Current Policies
Benchmark Interest Population Size USD/IDR Exchange Rate Inflation Rate Unemployment Rate GDP growth rate
Rate
SUPPORTING INDICATORS
The sensitivity analysis results indicate that transition Areas for the Consumer Credit Property Ownership
risks lead to an increase in Probability of Default (PD) Sector (Conventional and Sharia).
and Non-Performing Loan (NPL) in priority sectors
such as energy and transportation, while Loss Given From a financial impact perspective, direct losses
Default (LGD) increases in the property sector due due to physical risks are projected to reach Rp76.02
to a decline in property values in high-risk areas. billion in 2024. Transition risks add implementation
However, the NZ 2050 scenario simulation shows costs for NZE policies, including CAPEX of Rp59.67
that BTN’s Capital Adequacy Ratio (CAR) remains billion and OPEX of Rp16.36 billion. Over the long term
above the minimum threshold (10.8% compared to until 2050, the energy and infrastructure sectors are
the minimum of 9.18%), indicating the Bank’s ability projected to experience significant impacts due to
to manage these risks. policy changes related to carbon pricing and fossil
fuel energy costs.
b. Physical Risk Scenario Analysis
Physical risks involve damage caused by natural The distribution of risk to the Bank’s operations
disasters, such as floods and fires, which impact indicates that physical risk significantly impacts
the collateral value of assets and increase LGD. areas such as Bekasi, Bogor, and Makassar,
The focus areas are regions such as Bekasi, Bogor, particularly in the property sector and mortgage
and Makassar, which exhibit higher vulnerability to loans (KPR). Alternatively, transition risk primarily
physical risks. Below are the Physical Risk Impacted affects the energy sector due to rising carbon prices,
with substantial impacts felt by debtors such as PLN.
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Areas Affected by Physical Risk – Regencies/Cities
25%
Medan
20% Makasar
15%
Bogor
10%
Tangerang Regency
5%
Bekasi
Karawang Regency
0%
0 20,000,000 40,000,000 60,000,000 80,000,000 100,000,000 120,000,000
c. Climate Change Mitigation Plan Overall, the Climate Risk Stress Test (CRST) results
To mitigate climate change, BTN has designed show that BTN maintains strong financial resilience
strategic measures covering GHG reduction, in facing physical and transition risks. The CAR
automation of climate risk measurement, and green remains stable despite pressure from these risks.
portfolio policies. In the short term, BTN focuses Additionally, the transition plan toward Net Zero
on aligning climate risk calculations with PSAK Emission offers opportunities to develop green
standards. The medium-term approach involves portfolios. However, challenges remain, such as
monitoring the implementation of decarbonization, improving debtor data quality, particularly for MSMEs,
while long-term efforts include integrating carbon and strengthening the Bank’s human resources and
risk into pricing strategies and underwriting. The technology capabilities. With the planned mitigation
total budget for mitigation programs is projected measures, BTN demonstrates a strong commitment
to reach Rp76.02 billion in 2024, focusing on service to managing climate risks to ensure operational
digitalization, energy efficiency, and corporate social sustainability.
responsibility.
Risk Measurement and Assessment [GRI 2-16]
BTN uses a risk measurement system to assess regularly evaluated and refined as needed to ensure
risk exposures inherent in business activities, which the accuracy of assumptions, fairness, data integrity,
are then compared to the Bank’s risk appetite. This and compliance with procedures.
enables BTN to take appropriate mitigation actions
and ensure sufficient capital to manage residual risk. Stress testing is conducted to complement the risk
Risk measurement is conducted periodically across measurement system, aiming to estimate potential
products, portfolios, and all business activities. losses under adverse market conditions. Through
specific scenarios, stress testing measures performance
The risk measurement methods employed include sensitivity to changes in risk factors and identifies
standards set by Bank Indonesia and OJK, as well as significant impacts on portfolios. The results of stress
internal methods developed by BTN. These methods testing are used to review existing policies and limits,
are tailored to the characteristics and complexities of enabling the Bank to take appropriate actions should
business activities. The risk measurement system is conditions exceed the risk tolerance level.
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To provide a comprehensive and continuous overview risk, and ESG risk. For the Syariah Business Unit, two
of Bank health, BTN regularly conducts self-assessments additional types of risks are assessed: investment
on the Bank Soundness Level (TKB) and prepares the return risk and investment risk. This evaluation involves
Risk Profile Report. Assessments of the TKB, which refer to assessing both inherent risks and the quality of risk
POJK No. 4/POJK.03/2016 and SE OJK No. 14/SEOJK.03/2017 management implementation in the Bank’s operational
on Bank Soundness Level Assessments, are conducted activities.
semiannually. Meanwhile, the Risk Profile Report is
prepared quarterly. The TKB assessment encompasses In general, based on the self-assessment of the Q4
several aspects, including the risk profile (consisting 2024 Risk Profile, BTN aims to achieve a Low to Moderate
of inherent risks and the quality of risk management level, indicating that the composite risk faced by the
implementation), profitability, governance, and capital. Bank is relatively low, with a satisfactory quality of risk
management implementation. Below are the details of
Risk profile assessments include various types of risks, the assessment results:
such as credit risk, market risk, liquidity risk, operational
risk, legal risk, strategic risk, compliance risk, reputation
2024 Self-Assessment of Risk Profile
Risk Management Quality
Type of Risk Inherent Risk Rating Risk Level Rating
(KPMR) Rating
Credit Risk Moderate Statisfactory Low to Moderate
Market Risk Moderate Statisfactory Low to Moderate
Liquidity Risk Low to Moderate Statisfactory Low to Moderate
Operational Risk Moderate Statisfactory Low to Moderate
Legal Risk Low to Moderate Statisfactory Low to Moderate
Strategic Risk Low to Moderate Statisfactory Low to Moderate
Compliance Risk Low to Moderate Statisfactory Low to Moderate
Reputational Risk Low to Moderate Statisfactory Low to Moderate
BTN also has an ESG Risk Appetite Statement (RAS), in risks, social impacts, and collective well-being, while
which the bank is committed to conducting sustainable supporting the transition to net-zero emissions.
business practices that manage climate change
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Risk Monitoring
BTN implements a system and procedures for To ensure the smooth operation of the monitoring
monitoring that include tracking risk exposure levels, risk process, the Bank prepares an effective backup system
tolerance, compliance with internal limits, stress testing to prevent disruptions in risk monitoring. Additionally,
results, and consistency in the implementation of regular reviews and reassessments are conducted
established policies and procedures. The results of risk on the backup system to ensure its sustainability and
monitoring are presented in periodic reports submitted the effectiveness of the implemented risk monitoring
to management. These reports are used as a basis for process.
risk mitigation and determining necessary actions.
Risk Management Information System
The risk management information system is managed 2. BTN Technology/Applications
collaboratively by multiple divisions within the Bank. At The Bank also assesses potential risks related
the initial stage, the primary focus is on collecting and to the use of technology, particularly in data
improving the quality of risk and data. This is expected privacy and cybersecurity. Given the importance
to be developed and gradually applied within the risk of protecting customer personal data and the
management information system. The goal is to ensure security of the Bank’s information systems, this
that risk measurement and monitoring processes are aspect becomes a primary focus to avoid data
conducted in an integrated, timely, and compliant breaches or cyberattacks that could harm the
manner in accordance with applicable regulations. Bank and its customers.
Impact and Risk Assessment 3. Responsible Investments
The assessment is also conducted to ensure that
Impact and risk assessment conducted by the Bank is a the Bank’s investments adhere to sustainability
thorough evaluation process to identify and analyze risks principles by considering the social and
as well as potential impacts arising from certain activities environmental impacts that may arise. This
or policies. The main objective of this assessment is ensures that the Bank’s investments are not only
to minimize potential risks while understanding how financially beneficial but also socially and ethically
decisions made by the Bank can influence operations responsible.
and long-term business sustainability. This process
includes several key elements, such as: 4. Human Resource Development Policies
1. New Product Development Evaluating human resource development policies
The Bank evaluates risk related to new products, is crucial to ensure that the Bank can manage
whether funding or credit products. This and develop its employees effectively without
assessment includes the impact on customers, adding operational risk. This includes appropriate
the Bank’s operations, and business aspects such training and development to enhance employee
as information technology, compliance, legal, and competencies and support the Bank’s strategic
financial factors to ensure that the products can objectives.
operate smoothly without causing harmful risks.
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Comprehensive Internal Control System
Risk Control System
To implement effective risk management, BTN equips tolerance. Risk control is conducted through various
itself with a comprehensive internal control system. mechanisms, such as hedging, issuing guarantees,
This system is designed to safeguard the Bank’s asset securitization, credit derivatives, and capital
assets, ensure the availability of reliable financial augmentation to absorb potential losses.
and managerial reports, enhance compliance with
regulations and legal requirements, and minimize risk of The implementation of a reliable and effective internal
loss, as well as deviations to and breaches of prudential control system is a shared responsibility among all
principles. operational work units, supporting units, and the Internal
Audit Division. The Company has conducted audits on
BTN’s risk control system adheres to established all Bank operations at least once every 3 (three) years.
policies and procedures. The risk control process is This control process is designed to be integrated and
tailored to the Bank’s risk exposure and the level of risk can be described through the following steps:
to be undertaken, based on the predetermined risk
Risk Control Framework
3 Lines of Defense BTN Lines of Defense
Concept of 3 Lines of Defense, Comprising:
BoC – Audit Committee
1st Line of Defense: Business, Operational, and Risk
Functions
BoD
• Conducting business activities in line with the
Bank’s strategic objectives.
• Executing business activities following applicable
policies.
• Taking responsibility for risks arising from
External Audit
1st Line of Defense 2nd Line of Defense 3rd Line of Defense
Regular Audit
business activities.
• Developing and • Implementing effective controls and procedures
monitoring the Bank’s based on policies and directives.
• Conducting reviews
risk.
and evaluations
• Fostering a conducive • Supervising business 2nd Line of Defense: Risk Monitoring, Compliance,
of the design and
control environment. functions to ensure the
implementation of and Policy Management
• Ensuring consistent execution of policies
comprehensive risk
implementation and compliance
management. • Units Responsible for Risk Compliance.
of policies and with management
• Ensuring the • Policy Management Units for Procedures and
procedures. standards and
alignment of the Policies.
• Effective internal procedures.
first and second
control. • Monitoring and • Bank Risk Management Units.
defense layers with
• Business Functions. reporting the Bank’s
expectations.
risks comprehensively.
• Internal Audit. 3rd Fungsi Audit Internal
• Risk Management and
Compliance.
Responsible for ensuring the following:
• The Compliance function of the 2nd Line of
Risk Management Defense operates effectively.
Business Function Internal Audit • The 1st Line of Defense as the owner of risks
and Compliance
manages all risks adequately.
Risk Profile Assessment [GRI 2-16]
To provide a comprehensive and sustainable overview semiannually. Meanwhile, the Risk Profile Report is
of risk, BTN regularly conducts self-assessments of the prepared quarterly. TKB assessments encompass
Bank Soundness Level (TKB) and prepares Risk Profile several aspects, including the risk profile (consisting
Reports. TKB assessments, which refer to POJK No. 4/ of inherent risks and the quality of risk management
POJK.03/2016 and SE OJK No. 14/SEOJK.03/2017 on implementation), profitability, governance, and capital.
Bank Soundness Level Assessments, are conducted
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Internal Control Over Financial Reporting (ICOFR)
As part of efforts to improve sustainable corporate Enterprises (KBUMN) based on KBUMN Letter No. S-4/
governance, BTN has completed a Diagnostic Review DKU.MBU/02/2024. As part of efforts to strengthen
of its Internal Control Over Financial Reporting (ICOFR). corporate governance, BTN’s ICOFR Diagnostic Review
This process represents a strategic initiative aligned project is implemented through a systematic approach
with the directives of the Ministry of State-Owned consisting of four main stages:
Stages of Diagnostic Review for ICOFR at BTN
1 2 3 4
Conducting diagnostic
Comprehensive
Mapping BTN’s procedures to evaluate
Identifying significant improvement
corporate structure the effectiveness of
accounts in BTN’s recommendations
and assessing risks of internal controls in
financial statements. are drafted. An
material misstatements various areas. This
Each account is implementation
due to structural process includes
analyzed to assess the roadmap is also
complexity. The results interviews with process
risks attached, ensuring designed as a strategic
serve as a basis for owners, document
all elements affecting guide for executing
understanding potential reviews of policies
internal controls are improvements
risks in financial and procedures, and
appropriately mapped. in a phased and
reporting. in-depth analysis of
measurable manner.
control implementation.
Throughout the process, the diagnostic procedures In conducting the Diagnostic Review of Internal Control
include in-depth interviews, regulatory documents and Over Financial Reporting (ICOFR), BTN identified 13
supporting materials reviews, and identifying areas key areas as primary focuses, covering Entity Level
of control that require improvement. This approach Control, IT General Control, and processes in financial,
ensures that each step contributes significantly credit, treasury, and HR functions. This process is
to strengthening BTN’s internal controls to support designed to provide a comprehensive assessment of
transparent and accountable corporate governance. the effectiveness of internal controls across various
operational lines of the Bank.
Diagnostic Review Procedure for ICOFR at BTN
Understanding
Identifying control
processes and controls Reviewing samples of
Controls identified are areas that require
through interviews with transaction documents
confirmed through improvement and
Process Owners and to assess the adequacy
supporting documents obtaining confirmation
reviews of policy and of controls within a
for implementation. from Process Owners for
procedure documents. transaction cycle.
approval.
Identification of Areas
Walkthrough Confirmation Document Review
for Improvement
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Based on the diagnostic results, BTN then prepares Additionally, through the implementation of the ICOFR
a roadmap to ensure the timely and efficient Diagnostic Review, BTN reaffirms its commitment to
implementation of recommendations. The roadmap the principles of Good Corporate Governance. This
preparation involves intensive discussions with BTN effort is designed to strengthen internal controls while
management to align all improvement steps with the enhancing transparency and accountability in financial
Company’s operational needs. The primary focuses of reporting. These steps not only support efficient
the roadmap include: operational management but also serve as an essential
1. Setting implementation priorities based on the risk foundation for ensuring BTN’s business sustainability in
level and urgency of each recommendation. facing future challenges in the banking industry.
2. Continuous monitoring and evaluation to ensure
the implementation proceeds as planned and has
a positive impact on internal control management.
Basel Implementation
Basel is an international regulatory framework designed This framework supports the sustainability of banking
to strengthen the stability of the banking system businesses by maintaining customer trust and the
by improving risk management. In the Indonesian stability of the financial sector. To implement risk
banking sector, Basel implementation is carried out in management, particularly the application of Basel II
accordance with OJK regulations to ensure adequate and Basel III, which applies to all commercial banks, BTN
capital, liquidity, and risk management operations. has fulfilled the following requirements:
Requirement Status
Implementation of Basel II Pillar 1
The Bank has implemented market risk measurements using the standardized model in accordance with
SE OJK No. 38/SEOJK.03/2016, dated September 15, 2016, concerning the Guidelines for Using the Standard
Method in Calculating Minimum Capital Requirements for Commercial Banks by Considering Market Risk. The
portfolio included in determining the KPMM market risk consists of interest rate trading book portfolios and
currency trading book and banking book portfolios for exchange rate risk. The Bank has prepared SEOJK No. 23/
SEOJK.03/2022, dated December 7, 2022, regarding the Calculation of Risk-Weighted Assets for Market Risk for
Commercial Banks, which has been applied as of January 1, 2024. The Bank has also conducted trial calculations
and reporting to OJK for market risk ATMR positions as of June 2023, September 2023, and December 2023.
Implementation of Basel II Pillar 2
The Bank submitted the results of the implementation report on Interest Rate Risk in the Banking Book (IRRBB)
and the IRRBB calculation report to regulators quarterly in accordance with SE OJK No. 12/SEOJK.03/2018, dated
August 21, 2018, concerning the Implementation of Risk Management and Measurement of Risk Using the
Standard Method for Interest Rate Risk in the Banking Book (IRRBB).
Implementation of Basel III
In accordance with the regulatory plan to implement Basel III as stipulated in OJK Regulation No. 11/POJK.03/2016,
the Bank specifically has maintained a Capital Adequacy Ratio (CAR) of 20.17%, exceeding the minimum
requirement of the Basel III framework, which is 10.5%.
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Code of Conduct and Business Ethics [GRI 2-23, 2-24]
The Code of Conduct reflects BTN’s commitment to The Code of Conduct aims to shape behavior that
implementing Good Corporate Governance (GCG) by aligns with the ideal standards and fosters a work
adhering to the highest standards based on proven best culture based on BTN’s core values. The Code of
practices in the banking industry that have established Conduct consists of four main chapters, which are
credibility and trustworthiness. In the context of ethics, briefly described as follows:
the credibility and trust held by the public, shareholders, 1. Introduction
and customers are considered significant factors The Code of Conduct is a codification or
in supporting the Bank’s growth and sustainability. compilation of policies, regulations, and
Therefore, every business activity carried out by BTN not agreements jointly made between the Bank
only complies with applicable laws and regulations but and its employees, designed to influence and
also reflects adherence to norms and ethics prevailing establish the expected behavior standards for all
in society and business environments. individuals in the organization, from management
to employees. The main objective is to ensure that
Awareness of the importance of good ethical practices all activities carried out within the Bank adhere
plays a key role in building BTN’s positive reputation, to high ethical standards. The application of the
ultimately strengthening its image as a socially Code of Conduct, in terms of both compliance
responsible entity that contributes positively to society. and breaches, becomes one of the indicators
To support this goal, BTN is committed to upholding in evaluating employee performance. In other
integrity in every action and decision taken. The Bank words, as long as employees adhere to the
does so by applying ethical guidelines and clear Code of Conduct, it will positively influence their
behavior standards as a foundation for all members performance evaluations. The Code of Conduct
of the organization in carrying out their responsibilities. not only serves as a reference for decision-
These guidelines ensure that every individual and team making and policy implementation but also
at BTN works professionally and in accordance with acts as a foundation for managing the Bank’s
high ethical standards, aligned with BTN’s principles, practices. Consistency in applying the Code of
vision, mission, and established values, while adhering Conduct demonstrates BTN’s commitment to
to applicable internal and external regulations. always conducting its business with high ethical
values and good principles. This, in turn, supports
To ensure that every activity reflects a commitment the establishment of Good Corporate Governance
to ethical principles, BTN has established standards (GCG).
of ethics and conduct aligned with its vision, mission,
and values. These standards are implemented through 2. Business Ethics Standards
Joint Decision Letter of the Board of Commissioners The business ethics standards function as a guide
No. 01/SKPB/KOM/BTN/2024 and Board of Directors No. that governs the behavior and interactions of
SKPB-01/DIR/BTN/2024 on BTN’s Code of Conduct and the Bank across various aspects of its activities.
Behavior (Code of Conduct). This Code provides clear These ethical guidelines include relationships
guidelines for all BTN employees to act in accordance between the Bank and related parties, such as
with the upheld values, maintaining integrity and employees, customers, suppliers of goods and
professionalism in all aspects of operations. Non- services, and competitors. In addition, these
compliance or deviations from the Code of Conduct can standards also encompass ethics in relations with
result in significant reputational damage, operational work partners, the government, society, the media,
risk, reduced business efficiency and effectiveness, or and professional organizations. All interactions
credit risk, impacting the Bank’s ability to manage and must be carried out with principles of honesty,
provide loans responsibly. Therefore, business ethics transparency, and mutual respect, to maintain the
play a critical role in maintaining BTN’s sustainability Bank’s reputation and integrity.
and stability.
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Management and Welfare Support
3. Policy on Employee Conduct Standards to the Board of Directors and/or Commissioners,
• Employees must avoid conditions, situations, depending on their responsibilities and authority.
or impressions of a conflict of interest or abuse Based on the assessment results, the Board of
of authority. Directors and Commissioners will decide the
• Members of the Board of Commissioners, necessary actions, such as coaching, disciplinary
Directors, and Bank employees are prohibited sanctions, or corrective actions. In addition, the
from giving or receiving anything of value, Bank continues to develop and establish preventive
whether directly or indirectly, from business procedures and policies that all supervisors must
partners that could influence decision-making. follow within the work environment to ensure that
• The Bank is committed to engaging in fair and similar breaches do not recur in the future. [GRI 2-16]
ethical business competition in accordance
with applicable laws and regulations. The The Business Ethics and Code of Conduct document is
Bank avoids monopolistic practices, provides accessible to all parties through BTN’s official website
equal opportunities to all business players, and to ensure transparency and accountability. This code
promotes sustainable business innovation not only outlines the expected standards of conduct
while complying with all prevailing laws and within a business context but also emphasizes respect
regulations. for human rights, in line with the UN Guiding Principles
• Bank organs and employees must adhere to on Business and Human Rights (UNGP BHR). It affirms
laws, regulations, and Bank policies. the Bank’s commitment to operating responsibly
and upholding the rights of individuals in all business
4. Implementation and Enforcement activities. Furthermore, all decisions and actions taken
All BTN employees are obligated to report any by the Bank adhere to the principles of prudence,
breaches or deviations from the Corporate Code meaning that every decision and activity is conducted
of Conduct to the Human Capital Management with careful consideration and accountability. BTN’s
& Culture Specialist Division. BTN guarantees that Code of Ethics also requires all parties involved to
the reporter’s identity will be protected with full perform due diligence, including customer verification,
confidentiality to avoid retaliation or negative business partner inspections, and assessments of
repercussions. Upon receiving the report, the other related parties, to ensure compliance with ethical
Human Capital Management Division conducts standards and laws established by BTN. [GRI 2-23]
a thorough analysis and submits its evaluation
Compliance with the Code of Conduct
The Code of Conduct applies to all members of the accountability. The successful implementation of the
highest governance bodies and employees in every Code of Conduct is the responsibility of the leaders in
business activity of the Bank, including interactions each work unit, who must ensure that all employees
with stakeholders. The implementation of this code is understand and properly adhere to the code within their
regulated under the Joint Decision Letter of the Board of work environment.
Commissioners No. 01/SKPB/KOM/BTN/2024 and Board
of Directors No. SKPB-01/DIR/BTN/2024 concerning BTN implements the Code of Conduct comprehensively,
the Code of Conduct of PT Bank Tabungan Negara covering education, campaigns, application, reporting,
(Persero) Tbk. The Bank requires every individual in and follow-up actions for Code of Conduct breaches.
the organization to sign an Integrity Pact, aimed at [GRI 2-23]
ensuring the Code of Conduct is executed with full
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Ethics Guidelines Internalization Process
Education Application Reporting and Follow-Up Actions
• The Code of Conduct is • Signing of the Integrity Pact by all • 37001:2016 as part of the
disseminated and accessible to employees, aligned with the values enforcement of business ethics and
all Bank personnel through the of the Code of Conduct. behavior outlined in the Code of
Digital Room for E-learning Modules Conduct.
(DREAM). Additionally, quizzes • Internalization of the Code of
regarding the Code of Conduct are Conduct, anti-gratuity controls, • Implementing the Whistleblowing
conducted to evaluate employees’ and the Anti-Bribery Management System (WBS) program.
understanding. System (ABMS) for all employees via
Digital Room for E-learning Modules • Imposing sanctions on employees
• Commitment to implementing the (DREAM). who violate the Code of Conduct.
Code of Conduct is stipulated in the
Integrity Pact, which must be signed • Collaborating with the Corruption
by all members of the Board of Eradication Commission (KPK)
Directors, Board of Commissioners, through the Professional Integrity
and Bank employees. The Code of (PROFIT) program, which includes
Conduct is also accessible to all competent Human Resources (HR)
stakeholders through the company’s support to enhance integrity in
website. overseeing corruption prevention
within the Bank, participation in
training programs as certification of
Integrity Builder Expert, certification of
Anti-Corruption Counselors (PAKSI),
and collaboration in KPK anti-
corruption campaigns via various
communication media.
• Implementing anti-gratuity
control programs as planned and
submitting periodic reports on its
implementation to the KPK each
semester.
• Managing reports of gratuity
acceptance from all work units
and reporting them to the KPK in
accordance with regulations.
Sanctions for Breaches of the Ethics Guidelines
Total Employees
Categories of Type of
No
Sanctions Sanction
2024 2023 2022 2021 2020 2019 2018
1 Light Sanctions Light A 4 11 9 14 27 23 22
Light B 15 15 5 28 19 15 31
Light C - 11 6 35 47 25 24
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Total Employees
Categories of Type of
No
Sanctions Sanction
2024 2023 2022 2021 2020 2019 2018
2 Moderate Moderate A 8 15 8 54 62 69 18
Sanctions
Moderate B 20 12 10 21 32 53 13
Moderate C - 10 9 16 31 45 9
3 Severe Severe A 3 1 3 5 10 5 2
Sanctions
Severe B 27 43 42 19 24 40 22
Severe C 4 1 3 3 6 0 0
Total 81 119 95 195 258 275 141
Oversight for Ethics Issues
In an effort to reinforce good governance and effectiveness of existing fraud prevention strategies, and
ensure compliance with ethical principles, BTN ensures that any risks remain within acceptable limits.
has implemented strict oversight of fraud-related The Anti-Fraud Subcommittee holds regular meetings
issues and ethical breaches through the Anti- at least once every three months or more frequently if
Fraud Subcommittee, which operates under the Risk necessary, with decisions made through deliberation
Management Committee. This subcommittee plays a or voting when consensus cannot be reached. All
strategic role in establishing policies, strategies, and a decisions are documented in meeting minutes, signed
fraud risk management framework aimed at preventing, by the chairperson and all committee members, as a
detecting, and addressing potential breaches. The Anti- measure of transparency and accountability.
Fraud Subcommittee comprises both permanent and
non-permanent members from various directorates, To ensure the effective implementation of anti-fraud
including Risk Management, Operations, Information policies, the Anti-Fraud Subcommittee is supported by a
Technology, and Legal, with the Head of the Operational Supporting Group, responsible for formulating strategic
and Digital Risk Management Unit serving as the recommendations, collecting data, and evaluating
secretary. policy implementation. Additionally, the Operational
and Digital Risk Management Unit plays a key role in
As part of its commitment to fraud risk management, monitoring and following up on decisions made during
the Anti-Fraud Subcommittee is responsible for committee meetings. Through this structured oversight
implementing necessary corrective measures and mechanism, BTN remains committed to fostering a
reporting significant decisions to the Board of Directors. high-integrity work environment, mitigating fraud risks,
In carrying out its duties, the committee develops and ensuring that good governance principles are
fraud risk policies and tolerance limits, evaluates the consistently applied across all operational areas
Employee Training on Ethical Standards
As part of its commitment to maintaining high ethical adhere to the ethical principles enforced by the Bank,
standards, the Bank organized a Code of Ethics training enabling them to apply these standards in their daily
program in 2024 for all employees, including permanent activities. Additionally, every new employee is required
and contract employees, as well as development to undergo business ethics training as part of their
partners. The purpose of this training has been to ensure orientation to ensure they understand and implement
that all involved parties understand, internalize, and the established ethical standards.
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This training plays a crucial role in strengthening environment that protects the Bank’s reputation and
BTN’s ethical culture and ensuring that all actions credibility. The training also aims to raise awareness
taken align with values of integrity, transparency, and about the importance of ethics in business interactions
accountability. By involving all employees and partners, and equips participants with skills to address potential
BTN is committed to creating an ethical working conflicts of interest.
Employee Training on Ethical Standards Implementation
Implementation Number of Total Training
Training Name
Date Employees Trained Hours
Business Ethics Standards Training for ODP Batch 62 January 98 2
Business Ethics Standards Training for GBS Batch 1 January 30 2
Business Ethics Standards Training for ODP Batch 63 February 42 2
Business Ethics Standards Training for GBS Batch 2 February 43 2
Business Ethics Standards Training for Customer Service B1 February 27 2
Business Ethics Standards Training for Teller Services B1 February 72 2
Business Ethics Standards Training for GBS Batch 3 March 168 2
Business Ethics Standards Training for GBS Batch 4 March 37 2
Business Ethics Standards Training for Customer Service B2 March 20 2
Business Ethics Standards Training for Secretary Batch 1 March 10 2
Business Ethics Standards Training for GBS Batch 5 April 33 2
Business Ethics Standards Training for Teller Services B2 April 30 2
Business Ethics Standards Training for Secretary Batch 2 April 3 2
Business Ethics Standards Training for ODP Batch 64 May 97 2
Business Ethics Standards Training for GBS Batch 6 May 189 2
Business Ethics Standards Training for GBS Batch 7 May 65 2
Business Ethics Standards Training for GBS Batch 8 June 56 2
Business Ethics Standards Training for Customer Service B3 June 103 2
Business Ethics Standards Training for Teller Services B3 June 63 2
Governance & Operational Risk Training July 199 2
Governance & Operational Risk Training September 91 2
Governance & Operational Risk Training October 873 2
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Anti-Fraud and Conflict of Interest [GRI 2-15]
BTN has implemented a formal and comprehensive With the establishment of this policy and guidelines, BTN
policy regarding fraud prevention and anti-corruption, ensures that all stakeholders, including employees and
as outlined in specific policies and technical partners, adhere to strict integrity and anti-corruption
regulations. These policies are designed to prevent standards. The policy encompasses guidelines,
fraudulent practices across all Bank operations. As part procedures, and clear internal controls aimed at
of this commitment, the President Director and Chief preventing bribery. BTN not only commits to meeting
Commissioner of BTN signed BTN’s Anti-Bribery Policy legal obligations but also fosters an organizational
in 2023, which is an integral part of the Anti-Bribery culture rooted in accountability and ethics. This Anti-
Management System (ABMS). The signing of this policy Bribery Policy supports BTN in maintaining its reputation
underscores BTN’s seriousness in upholding integrity and fostering a cleaner and more trustworthy business
and transparency in all operational aspects. environment.
Anti-Fraud
As a foundational element in fostering build sustainable actions taken, whether by employees or leadership,
relationships with stakeholders, BTN prioritizes public consistently reflect integrity and fairness. The ultimate
trust through its commitment to integrity. The Bank goal is to establish a strong foundation that not only
strives to conduct all business activities with honesty, supports business continuity but also builds long-term
fairness, and without tolerance for corruption or fraud. relationships with all stakeholders, including customers,
BTN believes that any action violating these core values business partners, and other related parties. [GRI 3-3]
will significantly impact its reputation and business
sustainability. Therefore, the Bank views it as essential BTN has implemented a Zero Tolerance to Fraud and
not only to consider the financial impact of its decisions Zero-Defect program, which is in line with the Financial
but also to weigh their broader implications on public Services Authority Regulation No. 39/POJK.03/2019
trust, which may not be directly measurable but is on the Implementation of Anti-Fraud Strategies for
invaluable for the Bank’s sustainability and growth. Commercial Banks. To support the implementation
of this policy, various strategic measures have been
BTN firmly emphasizes that any breaches of its anti- implemented to strengthen the prevention, detection,
corruption and anti-fraud policies are treated as serious investigation and monitoring of potential fraud in
matters requiring stringent actions in accordance with banking operations. BTN conducts socialization
prevailing regulations and policies. Policy Number 6, regarding the anti-fraud program to all (100%) of
governs aspects related to Legal, Compliance, AML, employees and communicating anti-corruption
PPT, PPPSPM, and Corporate Governance. This policy policies and procedures to all (100%) active vendors
is applied comprehensively, covering all employees, through the signing of the ABMS clause in contracts.
whether permanent or contractual, and includes top Additionally, BTN continuously enhances efforts through
management such as the Board of Commissioners anti-fraud training related to the following areas: [GRI 205-
and Directors acting on behalf of BTN. This approach 2]
demonstrates BTN’s commitment to ensuring that all
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Employee Training on Anti-Fraud Implementation
Training Title Number of Participants Training Date
Anti-Fraud Awareness for ODP Batch 63 42 March 21, 2024
Anti-Fraud Awareness for Customer Service Batch 1 27 February 23, 2024
Anti-Fraud Awareness for Teller Staff 77 February 23, 2024
Anti-Fraud Awareness for ODP Batch 64 110 June 28, 2024
Anti-Fraud Awareness for (Branch Manager, Deputy Branch 28 April 3, 2024
Manager, Consumer Lending Unit)
Anti-Fraud Awareness for Frontliner Employees Transitioning 229 June 7, 2024
Through High Performance Pathway 2024
Anti-Fraud Awareness for Teller Staff & Customer Service 2024 161 June 12, 13 & 14, 2024
Anti-Fraud Awareness for General Banking Staff Batch 4 2024 38 March 28, 2024
Anti-Fraud Awareness for General Banking Staff Batch 7 2024 70 June 4, 2024
Anti-Fraud Awareness for General Banking Staff Batch 5 2024 33 April 29, 2024
Anti-Fraud Awareness for Assistant Manager Development 6 August 24, 2024
Program 2024
Anti-Fraud Awareness for General Banking Staff Batch 6 2024 200 May 3 & 6, 2024
Anti-Fraud Awareness for General Banking Staff Batch 8 2024 63 July 17, 2024
Anti-Fraud Awareness for Superstaff Digital Branch 11 November 14, 2024
Anti-Fraud Awareness for Operation Unit 171 July 16 & 19, 2024
Anti-Fraud Awareness for Branch Manager 113 August 6 & 9, 2024
Anti-Fraud Awareness for Regional HC & Service Head and 90 July 13, 2024
Operational Unit Head
Anti-Fraud Awareness for Operations & Services Supervisor (OSS), 680 September 4 & 10, 2024
Transaction Processing Staff & IT Support Staff
Anti-Fraud Awareness for Deputy Regional Manager Service & 90 October 1, 2, 8, 9, 2024
Collection and Deputy Branch Manager Service & Collection
Anti-Fraud Awareness for RBC, BBC, RLPC BC, CBC BC 195 October 5, 2024
Fraud Risk Assessment
The Bank must remain vigilant to any exposure arising As part of its mitigation efforts, the Bank has
from its involvement in business or operations in regions implemented a Fraud Risk Assessment (FRA). FRA is a
with higher incidents of corruption. This risk includes method used by BTN to identify and analyze potential
the potential for involvement in controversies related fraud risks, whether originating internally within BTN
to corrupt practices, which can damage the Bank’s (internal risks) or externally (external risks). FRA covers
reputation, affect relationships with stakeholders, and various business activities or services carried out by
result in legal sanctions that harm BTN’s operational different work units, such as funding, lending, human
stability. capital, operations, IT, and other units. The main goal
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of conducting FRA is to ensure that risk management instability. BTN adheres to strong governance principles
operates effectively through proactive and structured and complies with applicable regulations to maintain
procedures. This process includes assessments of transparent and corruption-free operational practices.
employee awareness regarding potential fraud risks The FRA process is carried out in accordance with the
and ensuring strict supervision in every work unit to guidelines stipulated in Technical Guideline No. PT.8-
prevent potential irregularities. D.2.These serve to detect fraud risks, enabling the Bank
to take preventive measures before more significant
In this regard, BTN emphasizes that the Bank does losses occur. The results of the FRA implementation are
not have exposure to corruption scandals and is not used by BTN to evaluate the potential impacts identified
involved in situations related to political or social and formulate corrective actions as needed.
Conflict of Interest [GRI 2-15]
BTN acknowledges that interactions between individuals must avoid making decisions that could create conflicts
within the organization or with external parties have the of interest that might compromise the objectivity and
potential to create conflicts of interest that could disrupt integrity of those decisions. In situations where a conflict
decision-making processes and implementation. These of interest arises, individuals involved are required to
conflicts of interest undermine the objectivity and disclose the existence. BTN has established policies
integrity of decisions made, thereby potentially harming regarding transactions involving conflicts of interest,
the Bank and its stakeholders. For this reason, BTN is which are regulated explicitly in the Code of Conduct
committed to identifying, managing, and resolving and Rules of Procedure for Directors and the Board of
conflicts of interest in a firm and transparent manner. Commissioners. If conflicts of interest arise between
This is crucial to ensure effective business management the Bank and shareholders, members of the Board
and the achievement of objectives free from practices of Commissioners, Directors, executive officials, or
that may cause harm, such as corruption, collusion, other parties related to BTN, members of the Board of
and nepotism (KKN). Additionally, the Bank strives to Commissioners, Directors, and executive officials are
build and maintain harmonious relationships with prohibited from making decisions or actions that could
all stakeholders to foster a healthy and sustainable harm or reduce the Bank’s profits. Furthermore, it is
business environment. mandatory to transparently disclose these conflicts of
interest and ensure accountability in every decision-
Fundamentally, every individual involved in the Bank making process.
Conflict of Interest Prevention Policy
Special Policy KK.6-H on Conflict of Interest Management To ensure the effective implementation of this policy,
Procedures serves as an umbrella policy regulating BTN has established provisions that reinforce the
mechanisms for managing conflicts of interest within integrity and independence of the Board of Directors in
BTN, encompassing Directors, employees, and other carrying out their duties. Each member of the Board of
related parties. This policy specifically details conflict of Directors is strictly prohibited from seeking or accepting
interest management within three main areas, namely personal gains, whether directly or indirectly, beyond
human resources (HR), procurement processes, and the remuneration and lawful benefits determined by
credit. As part of its internal business processes, KK.6-H the General Meeting of Shareholders. They are also
provides the foundation to ensure that any potential forbidden from exploiting the Bank for personal, family,
conflicts of interest are handled through consistent or third-party interests that may harm or diminish
mechanisms aligned with Good Corporate Governance the Bank’s profitability. Additionally, directors are not
principles. allowed to give, offer, or accept anything of value from
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customers or government officials in an attempt to 2. Disclosing share ownership, either personal or
influence decisions or as compensation for certain by family members, if it reaches five percent or
actions, in accordance with applicable laws and more in the Bank or any other company, whether
regulations. domestically or internationally.
3. Disclosing family, financial, managerial, or
If a member of the Board of Directors has an interest ownership relationships with other members of
in a transaction or contract involving the Bank, they the Board of Commissioners, Board of Directors,
are required to disclose this interest during a Board controlling shareholders of the Bank, and/or other
of Directors meeting and are not permitted to vote in related parties in the Bank’s business activities.
the related decision-making process. If faced with a 4. Disclosing any concurrent positions held in other
potential conflict of interest, where the Bank’s economic entities.
interests do not align with personal economic interests, 5. Disclosing conflicts of interest when a decision
the member of the Board of Directors must: must still be made under such circumstances. The
1. Prioritize the Bank’s interests and ensure that concerned member of the Board of Commissioners
conflicts of interest do not compromise its must refrain from participating in any decision-
profitability. making process related to the matter.
2. Refrain from participating in decision-making 6. Refraining from requesting, accepting, authorizing,
processes when a conflict of interest exists. or approving any form of compensation,
3. Disclose the conflict of interest in cases where commission, additional payments, services,
a decision must still be made under such money, valuable goods, or any other items of
circumstances. economic value for personal, family, or third-party
4. In the case of credit issuance to a member of the benefit in relation to the Bank’s business activities.
Board of Directors, it must be granted on a fair and
reasonable basis in accordance with the Bank’s BTN meticulously documents all disclosures made
applicable regulations, without any preferential in accordance with applicable regulations to ensure
treatment compared to other customers, following transparency and compliance. Every disclosure
the arm’s length principle. related to a conflict of interest is recorded in meeting
5. Report any transactions involving the Bank’s minutes, which explicitly include key information,
shares within three (3) business days. such as the identity of the individuals involved, the
source of the conflict, the reasons for the conflict, and
To maintain independence and accountability in the considerations underlying decisions related to it.
management, the Board of Commissioners is not Essentially, all individuals in the Bank are encouraged
permitted to engage in decision-making related to the to avoid situations in which their decisions could be
Bank’s operational activities, except in cases involving influenced by conflicts of interest, ensuring that every
fund provisions for related parties or other matters action taken remains objective and focused on the best
as stipulated in the Bank’s Articles of Association and interests of the Bank. [GRI 2-15]
applicable regulations. The involvement or approval
of the Board of Commissioners in such cases does Breachesrelated to conflicts of interest can be reported
not eliminate the Board of Directors’ responsibility through the Bank’s Whistleblowing System (WBS), which
for managing the Bank. Additionally, the Board of allows individuals to report allegations of misconduct
Commissioners is prohibited from participating in either anonymously or openly. As part of its efforts
decisions that could create conflicts of interest or violate to reduce the potential for conflicts of interest, all BTN
applicable laws and ethical standards. Therefore, employees are required to sign an Integrity Pact,
members of the Board of Commissioners must always affirming their commitment to adhering to the values
avoid potential conflicts of interest by adhering to the outlined in the Bank’s Code of Conduct. Disclosures
following principles: related to conflicts of interest, including ownership
1. Prioritizing the Bank’s interests and ensuring that structures in various business entities, financial ties with
conflicts of interest do not reduce the Bank’s affiliated parties, and other affiliations, are disclosed in
profitability. detail in BTN’s Annual Report. [GRI 2-15]
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Additionally, the Bank adheres to the provisions outlined BTN can also provide project financing for several
in Special Policy Number KK.1-A on Commercial Loan categories of projects, including:
Procedures, which regulates credit disbursement free • Toll roads;
from conflicts of interest. Based on this policy, the Bank • Power plants;
is prohibited from granting loans, either in rupiah or • Airports;
foreign currencies, to the following: • Monorails; and
• Nightclubs; • Telecommunications.
• Horse racing;
• Casinos;
• Turkish baths;
• Massage rooms; and
• Other businesses prohibited by the government and
regulators.
Fair Treatment Policy for Shareholders
As part of managing potential conflicts of interest, 4. Individuals who, within the last six months, no
BTN has established a policy related to insider trading, longer fall under the categories mentioned in
which is regulated under Special Policy Number KK.9- points 1, 2, and 3 above.
EE on Investor Relations Activities as well as the Code
of Conduct for the Board of Directors and the Board of The prohibition on Bank Insiders from trading BTN
Commissioners. These regulations strictly prohibit Bank securities is based on the principle of transparency in the
Insiders from engaging in insider trading through the capital market, ensuring equal access to information for
purchase or sale of the Bank’s securities or those of investment decision-making. Bank Insiders are strictly
other companies transacting with BTN. The term Bank prohibited from trading BTN securities if they possess
Insider refers to the following individuals: material non-public information (inside information or
1. Commissioners, Directors, or employees of the material facts). Transactions may only be conducted
Bank. after such material facts have been officially disclosed
2. The Bank’s major shareholders. to the public
3. Individuals who, due to their position, profession, or
business relationship with the Bank, have access
to inside information.
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Implementation of the Prudence Principle [GRI 2-23]
Know Your Customer (KYC) and Know Your Employee (KYE)
To strengthen the implementation of prudence already registered customers, in accordance with the
principles in its operations, BTN has adopted two primary regulations set forth in POJK No. 23/POJK.01/2019, which
approaches, namely Know Your Customer (KYC) and amends POJK No. 12/POJK.01/2017, updates several
Know Your Employee (KYE), which focus on operational provisions related to the implementation of Anti-Money
risk management across various business activities Laundering (AML) and Countering the Financing of
of the Bank. KYC, which was previously used to verify Terrorism (CFT) programs in the financial services
customer identities, has now evolved into customer sector. To support the effective implementation of
due diligence (CDD), a more comprehensive process prudence principles, the Bank provides training for
involving identification, verification, and monitoring its employees, focusing on CDD-related material
activities for customers or prospective customers. containing case studies relevant to prudence principles.
This process aims to ensure that all transactions This initiative aims to enhance employee understanding
conducted align with the customer’s profile, whether and awareness of the importance of vigilance in every
they are new customers, walk-in customers (WIC), or transaction conducted.
Anti-Money Laundering (AML), Counter-Terrorism Financing
(CTF), and Prevention of Financing the Proliferation of Weapons of
Mass Destruction (PFWMD)
BTN implements the AML (Anti-Money Laundering), CTF these programs at the regional and branch office levels
(Counter-Terrorism Financing), and PFWMD (Prevention is the responsibility of each Regional Office Head and
of Financing the Proliferation of Weapons of Mass Branch Manager.
Destruction) programs in its customer onboarding
process in compliance with applicable laws and Apart from implementation at the Head Office, BTN also
regulations in the banking sector. As part of its efforts ensures that the AML, CTF, and PFWMD programs are
to enhance the effectiveness of these three programs effectively carried out at Regional Offices and Branch
and ensure compliance with regulatory requirements, Offices. With comprehensive implementation, the Bank
the Bank has established a Special Work Unit (SWU) strives to improve the effectiveness of these programs
focusing on AML, CTF, and PFWMD at the Head Office. so they can operate optimally while ensuring that all
This unit is responsible for supervising and ensuring business activities comply with regulatory requirements,
that these programs are properly implemented across thereby maintaining adherence to applicable laws.
all Business Units. Additionally, the implementation of
Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) Policy
BTN has comprehensive policies and strategies for from any association with money laundering, terrorism
implementing anti-money laundering (AML), counter- financing, or financing the proliferation of weapons of
terrorism financing (CTF), and the Prevention of Financing mass destruction. BTN is committed to maintaining
the Proliferation of Weapons of Mass Destruction clean, transparent, and accountable practices by
(PFWMD), which have been established by the Board involving all employees and business partners in
of Directors and adhere to national and international training programs to ensure effective understanding
standards. These policies are designed to ensure that and implementation of these policies, thereby creating
every transaction and activity carried out by BTN is free a safe financial system that prevents misuse.
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To support the implementation of this policy, the Bank e. Data Requests Fulfillment by the LPP and
submits reports and data to regulators and/or law Other APGAKUM Agencies, such as the Police,
enforcement agencies (LEAs) covering the following National Narcotics Agency, and Prosecutor’s
components: Office.
1. Submitting Financial Transaction Reports to the 3. Submitting Reports Related to the Implementation
Financial Transaction Reports and Analysis Center of General Elections and Regional Elections to
(PPATK), including: PPATK, including:
a. Cash Financial Transaction Reports (LTKT) a. Participating in the Collaborative Analysis
b. Suspicious Financial Transaction Reports Team (CAT), which is a collaborative exchange
(LTKM) of information between public sector entities
c. Cross-border Fund Transfer Reports (LTKL) such as PPATK, reporting parties, supervisory
through the Integrated Customer Service User and regulatory bodies (LPP), and law
Information System (SIPESAT) enforcement agencies.
2. Providing Data/Information to Law Enforcement b. Monitoring the accounts related to Special
Agencies (LEAs) and Regulators, including: Campaign Funds (RKDK).
a. Information System for AML/CTF (SIGAP) to the c. Screening against political party treasurers,
Financial Services Authority (OJK) central and regional campaign committees.
b. AML/CTF Reports via the OJK’s APOLO d. Screening against the Permanent Voter List
Application (DCT) of participants in the General and
c. Suspected Terrorism Financing Information Regional Elections, which is reported to PPATK.
System (SIPENDAR) to PPATK e. Submitting all reports and information requests
d. Electronic Data Exchange (PEDAL) to the related to the implementation of the 2024
Corruption Eradication Commission (KPK) General and Regional Elections.
Strategic Awareness Program Initiatives
1. Thematic Refreshment Training on AML, CTF, and (CDD) for prospective customers, existing
PFWMD for Employees through Internal Bank customers, and WICs who have a Beneficial
Media, Using Both Print and Digital Platforms. Owner (BO).
2. Internalization of AML, CTF, and PFWMD Awareness c. Training on Understanding and Implementing
in 2024. AML, CTF, and PFWMD for High-Risk Customers.
a. Training of Trainer. BTN organizes training sessions to equip
BTN conducts Training of Trainers (TOT) sessions employees with the necessary knowledge to
to enhance employees’ understanding of APU, conduct Customer Due Diligence (CDD) and
PPT, and PPPSPM implementation, particularly Enhanced Due Diligence (EDD) for high-risk
for those who interact with customers and Walk- customers. This initiative aims to enhance
In Customers (WIC), such as customer service vigilance and ensure compliance with AML,
representatives. The expected outcome of this CTF, and PFWMD regulations.
program is that participants will continuously
internalize and disseminate knowledge to 3. AMOLA Office Battle BTN 2024
other employees, ensuring a broad, consistent, The AMOLA Office Battle BTN 2024 is a knowledge
and interactive understanding of AML, CTF, and competition on AML, CTF, and PFWMD among
PFWMD. conventional and Sharia branch offices from each
b. Training on Beneficial Owners regional office. The competition consists of teams
BTN provides Beneficial Owner (BO) training of three members, with mandatory participation
to improve employees’ understanding of from Customer Service Supervisors and Customer
AML, CTF, and PFWMD, particularly in the Service Staff at each branch office. This event aims
implementation of Customer Due Diligence to enhance competency, strengthen knowledge,
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and promote self-awareness of compliance distribution, Beneficial Owner documentation,
culture in AML, CTF, and PFWMD implementation. incomplete CIF records, and high-risk customers,
as well as findings from the 2023 Thematic AML
4. Branch Visit dan Surprise Review and CFT Audit. Additionally, surprise reviews
Branch visits are conducted to increase are conducted periodically at branch offices to
awareness among branch offices by internalizing evaluate employee understanding and assess
AML, CTF, and PFWMD principles. These visits take the effectiveness of AML, CTF, and PFWMD
into account Financial Transaction Reports (LTKM) implementation
Enhanced Due Diligence and High Risk Jurisdiction
BTN implements the principle of Enhanced Due Diligence the AML,CTF, and PFWMD applications. This approach
(EDD) and countermeasures that are appropriate applies to prospective customers, customers, beneficial
and proportional to manage and reduce risks arising owners, conductors, and/or walk-in customers (WIC)
from business relationships, transactions, prospective originating from countries or jurisdictions categorized
customers, walk-in customers (WIC), and/or customers as High-Risk Jurisdictions subject to a Call for Action,
originating from countries classified as high-risk, as according to the risk level set by FATF. As such, all
identified and published by the Financial Action Task business relationships and transactions with these
Force (FATF). To monitor High-Risk Jurisdictions, the Bank parties undergo stricter scrutiny. Additionally, BTN
utilizes the AML,CTF, and PFWMD systems accessible to applies EDD to prospective customers, customers,
all staff involved in this oversight, including front-line beneficial owners, conductors, and/or WICs from
personnel such as customer service representatives. countries or jurisdictions identified as having significant
deficiencies in anti-money laundering and counter-
Based on the list of countries deemed high- terrorism financing systems, as determined by FATF. This
risk under FATF regulations, BTN is committed to reflects BTN’s proactive efforts to identify and mitigate
implementing appropriate preventive measures, such potential risks arising from relationships with these
as countermeasures and Enhanced Due Diligence parties, ensuring adherence to applicable regulations
(EDD), and reporting any suspicious activities through and high standards of prudence.
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Compliance in Environmental and
Social Management [GRI 2-25] [SASB FN-CB-410A.2]
The Bank holds direct and indirect responsibility for BTN has begun to apply credit risk assessments by
managing environmental and social impacts potentially considering AMDAL results before granting credit
caused by debtor activities. Any non-compliance in decisions for a project. This is due to AMDAL’s significance
managing environmental and social impacts may affect as a critical requirement for licensing needed during
the Bank’s credit risk and reputation. This responsibility the decision-making process for planned business
aligns with the Bank’s role as an intermediary institution. activities. The AMDAL document can also provide an
evaluation of potential impacts arising from business
In its funding and credit disbursement processes, activities on the surrounding environment. AMDAL
BTN consistently implements environmental preparation is carried out during the planning stage of
risk management. This approach supports the projects that are anticipated to impact the environment,
implementation of sustainable finance principles and such as abiotic, biotic, and cultural aspects. Legal
complies with the POJK Number 40/POJK.03/2019 on regulations for AMDAL in Indonesia are stipulated under
the Assessment of Asset Quality of Commercial Banks, Government Regulation No. 27 of 2012 on Environmental
issued by the Financial Services Authority (OJK) in Permits.
2019, which which states that assessments of business
prospects, as part of credit quality evaluation, should In addition to considering AMDAL documents, the
include considerations of the efforts made by debtors Bank also conducts on-site monitoring or verification.
to preserve the environment. [FS1] This ensures that prospective debtors comply with
all applicable environmental regulations, reflecting
The commercial credit portfolio has become a key prudential principles in credit risk management.
priority in promoting BTN’s growth. Therefore, the
Bank has developed specific policies and procedures BTN also embraces the initiative “one home, one tree”
for disbursing commercial credit while considering as part of its commitment to environmental and social
environmental and social dimensions. These measures sustainability. Through this initiative, every house built
aim to ensure that commercial credit disbursements is required to include a green area with tree planting.
remain aligned with prudent banking principles and Furthermore, every housing project is equipped with
good corporate governance. social and public facilities. [FS1, FS2, FS5]
In KU.1 - General Policy on Bank Lending or Financing, the To ensure the effectiveness of this initiative, the Bank
following are following are regulated as part of legality regularly conducts audits, including identifying follow-
proof for projects: [FS1, FS2] [SASB FN-CB-240a.3] up actions in the event of breaches. These audits are
1. Land allotment; carried out annually by the Internal Audit Unit. During
2. Site plan authorized by the relevant authority; the general audit of Branch Offices, auditors will use
3. Building Permit; sampling techniques to perform inspections and
4. Proof of ownership; evaluations of compliance with existing policies. If
5. Copy of SPPT; discrepancies are found, auditors will investigate their
6. Proof of road access ownership; causes and provide recommendations for corrective
7. Flood-free certification; actions. In addition, audited Branch Offices are also
8. Certification from the local water company required to commit to necessary improvements, which
(PDAM); and will subsequently be monitored regularly. [OJK F.10] [FS9]
9. Environmental Feasibility Certificate or
Environmental Management Efforts and/or
Environmental Impact Analysis (AMDAL).
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Internal Control
The implementation of an internal control system aims and efficiency, as well as compliance with applicable
to support the achievement of optimal performance regulations. This way, the Bank can minimize potential
for the Bank while also providing added value for risks arising during operational and financial processes.
stakeholders. The system functions to minimize risk
and ensure compliance with applicable regulations. BTN management has established an ongoing
In addition to being a critical component of the Bank’s monitoring mechanism. The goal of this monitoring is
oversight mechanism, the internal control system also to protect the Bank’s assets, ensure that the reports
acts as a guideline to ensure the Bank’s operations run produced are accurate and reliable, and enhance
smoothly, efficiently, and in a controlled manner. compliance with applicable regulations. Moreover,
this system aims to improve cost efficiency, reduce
In designing the internal control framework, BTN refers the impact of financial losses, and prevent fraud or
to the Committee of the Sponsoring Organizations of breaches of prudential principles in Bank management.
the Treadway Commission (COSO)-Internal Control By implementing a strong internal control system,
Integrated Framework. This approach aims to ensure BTN can ensure operations run better and safer, thus
adequate controls in various aspects, such as maintaining long-term business sustainability.
operations, financial reporting, operational effectiveness
Gratification Control
BTN recognizes that every employee, across various Throughout the reporting period, BTN received 96
divisions, may face potential risks related to gratification. reports related to gratification from the Head Office
Therefore, BTN encourages all employees to actively and Branch Offices. These reports encompass various
support the anti-gratification program by reporting forms of gratification, such as gifts, gratification related
regarding any case of gratification & Governance Work to official duties, the provision of food before religious
Unit. This is a concrete step to reinforce commitment holidays, and refusals of gratification. As part of its
to controlling gratification and maintaining the Bank’s commitment to preventing gratification and corruption,
integrity. Furthermore, to support the implementation of BTN continues to strengthen monitoring and risk
anti-fraud values, BTN has established a Whistleblowing management within its operations. To maintain its ISO
System (WBS), accompanied by various internalization 37001 - SMAP Certification, Surveillance Audit with a
activities. The system is implemented by third-party scope of 15 work units and Extend Scope in 1 work unit
independent entities to ensure its execution is objective selected based on core business considerations with
and transparent, creating a work environment free from high corruption risks. This initiative ensures that all
irregularities and fraud. bank operations remain aligned with the principles of
transparency, integrity, and compliance with applicable
regulations. [GRI 205-1]
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Number of Reports Received Related to Gratification
2024 2023 2022
96 78 83
Whistleblowing System
BTN’s commitment to fraud prevention is evident b. Detection
through the implementation of an anti-fraud strategy This has been designed to identify and uncover
that manages all potential fraud risk. The strategy potential fraud through various mechanisms that
encompasses the execution of four pillars: have been established, such as the Whistleblowing
a. Prevention System (WBS) policy, surprise audits, surveillance
This covers various tools designed to reduce systems, and direct supervision by the Operational
the likelihood of fraud, including efforts to raise Responsibility Officer. Based on the Bank’s WBS
awareness about the importance of anti- report data for 2024, a total of 3 complaints were
fraud measures, conducting vulnerability received, all of which were submitted via email or
identification to detect potential fraud triggers, the website. All complaints received have been
and implementing policies to better understand properly processed and resolved, with appropriate
employees. sanctions applied, including administrative
sanctions. This information is detailed in the table
below.
Number of Reports and Complaints by Submission Method
Submission Method
Year
Mail/PO Box SMS/Telephone/WA Email/Website
2024 0 0 3
2023 0 1 4
2022 0 1 1
c. Investigation, Reporting, and Sanctions evidence, managing reports, and recommending
This includes systems, mechanisms, and tools sanctions for identified fraud. Below is the summary
aimed at gathering information, collecting of complaints and their follow-up actions:
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Resolution of Reports and Complaints
Follow-up
Reports Still in Process Reports Processed
Reports Referred
Year (Audit Process/ and/or Sanctions
Reports Closed to Investigators
Reporting Process/ Applied (Including
(Unsubstantiated) (Related to General
Cross-Division Administrative
Crimes or Corruption)
Process) Sanctions)
2024 0 1 2 0
2023 0 0 5 0
2022 0 2 0 0
d. Monitoring, Evaluation, and Follow-Up potential violation seriously and take necessary
Thie final pillar includes various actions taken by steps to address the issues. Additionally, the 19
BTN to monitor and evaluate potential fraud cases identified cases have been followed up through
while ensuring proper follow-up mechanisms appropriate legal channels. This reflects BTN’s
are in place. In the reporting year, BTN recorded strong commitment to handling every violation
19 internal fraud cases, of which 7 cases were in compliance with applicable laws, ensuring
successfully resolved, while the remaining integrity and adherence in all Company activities.
cases are still under resolution. This process [SASB FN-CB-510a.1]
demonstrates BTN’s efforts to respond to every
Table of Internal Fraud Cases Throughout 2024 [GRI 205-3]
Number of Internal Fraud Cases
Board of Commissioners
Permanent Employee Non-Permanent Employee
Internal Fraud Cases and Board of Directors
Throughout 2024
Current Current Current
Prior Year Prior Year Prior Year
Year Year Year
(2023) (2023) (2023)
(2024) (2024) (2024)
Total Reports 0 0 19 23 1 1
Resolved 0 0 17 23 1 1
In Progress (Internal) 0 0 2 0 0 0
Not Yet Addressed 0 0 0 0 0 0
Escalated to Legal Process 0 0 2 0 0 0
Remarks::
1. The number of cases during the current year is based on the Special Audit Report and Preliminary Investigation Report for the period of January to
December 2024.
2. The number of cases categorized as “Resolved” refers to cases that have received sanctions decisions from the Board of Directors as of December 2024.
3. The number of cases categorized as “In the process of resolution within the Bank” refers to cases that have not yet received sanctions decisions from the
Board of Directors as of December 2024.
4. The number of cases categorized as “Legally pursued” refers to cases that have been “Resolved” and received criminal sanctions decisions. Legal
proceedings are followed up by LGD.
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The Bank actively conducts training programs to is the total number and percentage of employees who
internalize the BTN Whistleblowing System (WBS) among participated in the WBS BTN internalization training,
its employees. These training sessions aim to ensure including a breakdown of employees by Work Regions:
that every employee understands and can effectively [GRI 205-2]
implement the whistleblowing reporting system. Below
Employee Training on the Internalization of BTN’s Whistleblowing System (WBS)
Passed Failed Did Not Access
Number of
Regions
Participants Total Total Total
% % %
Employees Employees Employees
Head Office 3,647 3,309 90.73% 3 0.08% 335 9.19%
Regional Office
1,345 1,201 89.29% 5 0.37% 139 10.33%
Jakarta I
Regional Office
1,007 875 86.89% 3 0.30% 129 12.81%
Jakarta II
Regional Office
1,378 1,270 92.16% 2 0.15% 106 7.69%
West Java
Regional Office
Central Java & 973 934 95.99% - 0.00% 39 4.01%
Yogyakarta (DIY)
Regional Office
East Java, Bali & 1,556 1,464 94.09% 2 0.13% 90 5.78%
Nusa Tenggara
Regional Office
608 541 88.98% 1 0.16% 66 10.86%
Kalimantan
Regional Office
Sulawesi, Maluku & 805 739 91.80% 1 0.12% 65 8.07%
Papua
Regional Office
1,528 1,355 88.68% 3 0.20% 170 11.13%
Sumatera
Total 12,847 11,688 90.98% 20 0.16% 1.139 8.87%
Remarks::
a .Out of 12,847 employees (100.00%) who participated in the internalization program, 11,688 were declared to have passed, while 20 employees did not pass.
b. A total of 1,139 employees (8.87%) have not participated in the internalization program.
Reporting Breaches [GRI 2-26]
BTN implements a Violation Reporting System Policy or breaches in operational activities. Through the WBS,
or Whistleblowing System (WBS) based on the BTN strives to detect any irregularities or breaches that
Financial Services Authority Regulation (POJK) No. 39/ may harm the Bank, both from a reputational and legal
POJK.03/2019 issued on December 19, 2019, regarding the standpoint. Additionally, the policy aims to create an
Anti-Fraud Strategy Implementation for Commercial open and transparent work culture, where employees
Banks. The WBS system is an integral part of the Bank’s can report potential breaches without fear or concern.
internal control efforts, aimed at preventing irregularities Its long-term goal is to foster a working environment
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that is open, honest, and responsible, enabling all to strengthen internal control mechanisms to support
parties to perform their duties with the highest integrity. business growth through the following steps:
[SASB FN-CB-510a.2] 1. Conducting early detection and prevention of
irregularities and breaches; and
BTN implements WBS with the aim of ensuring that 2. Gradually creating a work climate that is open,
every report received from whistleblowers is handled honest, and responsible at BTN.
seriously, in accordance with established procedures.
This involves a process of verification and investigation The BTN WBS team responsible for managing WBS
to ensure the validity of the reports. Based on the reports reports consists of:
received, the Bank is responsible for formulating and 1. Head of the Internal Audit Division;
imposing appropriate sanctions against parties proven 2. Deputy Head of the Internal Audit Division; and
to have committed breaches. The purpose of imposing 3. The WBS unit under the Fraud Investigation &
sanctions is to create a deterrent effect, thereby Whistleblowing System Department within the
preventing others from committing similar actions that Internal Audit Division.
could harm the Bank. The WBS BTN policy is designed
Reporting Channels for Breaches
BTN has developed supporting facilities for the
implementation of its whistleblowing system (WBS).
Every complaint report can be submitted through the
following channels:
●Mail: : PO Box 2828 JKP 10028
Website : idn.deloitte-halo.com/btnsiips
Email : btnsiips@tipoffs.info
SMS :+62 813 8870 1117
WhatsApp : +62 813 8870 1117
Phone :+62 21-50928882 / +62 21-5092888
Whistleblowing Report Submission Mechanism [GRI 2-16]
BTN provides a dedicated Whistleblowing System (WBS) 3. If the reported party is a member of the BTN WBS
channel to facilitate stakeholders in reporting violations Team, the Independent WBS Manager will forward
within the Bank. This mechanism ensures that individuals the report to the President Director.
who have information about misconduct can submit 4. If the reported party is a member of the Board
their reports securely and confidentially. Reports can of Directors, the Independent WBS Manager will
be submitted based on the identified indications of forward the report to the Board of Commissioners
violations, as follows: and the WBS Manager at the Ministry of State-
1. If the reported party is a BTN employee up to two Owned Enterprises (BUMN).
levels below the Board of Directors and is not 5. If the reported party is a Commissioner and/or a
part of the BTN WBS Team, the Independent WBS Committee under the Board of Commissioners, the
Manager will forward the report to the BTN WBS Independent WBS Manager will forward the report
Team. to an unrelated Commissioner and Committee
2. If the reported party is a BTN employee one level Member under the Board of Commissioners,
below the Board of Directors and is not part of the as well as the WBS Manager at the Ministry of
WBS Team, the Independent WBS Manager will BUMN (specifically if the reported party is a
forward the report to the President Director. Commissioner).
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6. If the reported party consists of all members 7. If the reported party is a Director and/or
of the Board of Commissioners collectively, the Commissioner of a Subsidiary, the Independent
Independent WBS Manager will forward the report WBS Manager will forward the report to the
to the WBS Manager at the Ministry of BUMN. President Director of BTN.
Whistleblower Protection Guarantee
BTN is committed to ensuring protection for 3. Protection against retaliation by the reported
whistleblowers who report violations in good faith, party, which includes:
especially if the violation has the potential to harm a. Physical and psychological protection for the
the Bank. This protection is implemented through the whistleblower and their family.
following policies: b. Protection of personal and family assets from
1. Provision of a free and confidential WBS reporting threats or retaliatory actions.
platform. Whistleblowers will receive updates c. Administrative protection, including
on their report status from the Independent WBS safeguards against delayed promotions, unfair
Manager through designated communication dismissals, improper transfers, and job security
channels. threats.
2. Confidentiality of the whistleblower’s identity, d. Legal protection, where necessary, in litigation
except in cases where legal proceedings require proceedings in accordance with applicable
identity disclosure before a judge. regulations.
Complaint Handling System
BTN has established a strategic partnership with professional, transparent, and accountable approach.
the Corruption Eradication Commission (KPK) of the Every step taken within this collaborative framework
Republic of Indonesia to manage the Whistleblowing emphasizes confidentiality and ensures that reports
System (WBS) as part of a joint effort to combat received are handled securely without fear of retaliation.
corruption practices. This collaboration aims to Accordingly, BTN is committed to optimizing policies
enhance the effectiveness and efficiency of complaint and internal strategies to comprehensively prevent and
handling conducted both internally by employees and combat corruption offenses through a reliable system
externally by third parties, by adopting an integrated, that fosters a strong anti-corruption culture.
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The WBS team follows up on each report received using the following mechanisms:
Flowchart (1) If the Reported Party is a BTN Employee (Up to Two Levels Below the Board of
Directors and Not a WBS Team Member)
Whistleblower Independent WBS Team Special Audit Relevant Work
WBS Manager Team Unit
Start
7b
WBS Report
4 Out of Scope
1 2
Enter the WBS Analyze the No
WBS Report Report into the Report
System
WBS Report in 7a
scope / out of
WBS Report in
scope
3 Scope
Process Workflow
Classify the WBS
Report 5
Sufficient 8b
Yes
WBS Report in information Follow-up
12a scope / out of 6 8a Action
scope Eligible for
Provide Follow-up
Special Audit Action
Feedback
11
Request the
Whistleblower to No Yes
Provide Additional
Additional Information 9
Information Prepare a Memo or
Other Documents on
WBS Report Follow-up
Inform the Actions
Whistleblower if
13 No Feedback is 10
12b Given
Close the Report
Status
No Feedback
Provided
Finish
Flowchart (2) If the Reported Party is a BTN Employee (One Level Below the Board of
Directors and Not a WBS Team Member)
Whistleblower Independent President Director Special Audit Relevant Work
WBS Manager Team Unit
Start
7b
WBS Report
4 Out of Scope
1 2
Analyze the No
Enter the WBS Report
WBS Report Report into the
System
WBS Report in 7a
scope / out of
WBS Report in
Process Workflow
3 scope
Scope
Classify the WBS
Report 5
Sufficient 8b
Yes
WBS Report in information Follow-up
13a scope / out of 6 Action
8a
scope
Provide Eligible for Follow-up
Feedback Special Audit Action
12
Request the
Whistleblower to No Yes
Provide Additional
Information
Additional 9
Information 15 Prepare a Memo or
Inform the Receive Other Documents on
Whistleblower if No Information WBS Report Follow-up
Feedback is Given That No Actions
14 Feedback is
Provided
13b 11 10
Closing Report
Status Instructions to
No Feedback Proceed with
Provided Report Closure
Finish
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Flowchart (3) If the Reported Party is a WBS Team Member
Whistleblower Independent WBS Team External Relevant Work
WBS Manager Auditor Team Unit
Start
7b
4
WBS Report
1 2 Enter the WBS Out of Scope
Enter the WBS Report into the
No
Report into the System
WBS Report
System
7a
WBS Report in
Process Workflow
scope / out of scope WBS Report in
3 Scope
Classify the WBS
Report 5
Sufficient 8b
Yes
WBS Report in information Follow-up
13a scope / out of 6 8a Action
scope
Provide Eligible for Follow-up
Feedback Special Audit Action
12
Request the
Whistleblower to No Yes
Provide Additional
Additional Information 9
Information Prepare a Memo or
15
Other Documents on
Inform the Receive
WBS Report Follow-up
Whistleblower if No Information
Actions
Feedback is Given That No
14 Feedback is
Provided
13b 11 10
Closing Report
Status Instructions to
No Feedback
Proceed with
Provided
Finish Report Closure
Flowchart (4) If the Reported Party is a Board of Directors Member
WBS
Independent WBS Board of External Manager of President Relevant
Whistleblower
Manager Commissioners Audit Team the Ministry Director Work Unit
of SOEs
Start
15
No
2 5 WBS Report
1 Out of Scope
Enter the WBS Analyze the
WBS 13
Report into the Report 4
Report System WBS Report
WBS Report in 8 Out of Scope
WBS Report In
Process Workflow
scope / out of WBS Report Scope Related
scope in Scope to the Board of
3
Directors
Classify the WBS
6 14
Report
Instructions
Sufficient Yes for Follow-up
WBS Report in information Actions on WBS
19a scope / out of 7 Report
scope 16
9
Provide Eligible for Finish Follow-up
Special Audit Follow-up
Feedback Action
18 Action
Request the
Whistleblower to No Yes
Provide Additional
Additional Information 10 17
Information Prepare a Memo or Documents
21 Other Documents on
Inform the Receive for WBS
Whistleblower if WBS Report Follow- Report Follow-
Information
No Feedback is up Actions up
That No
20 Given Feedback is
Provided
11
19b 12
Closing Report Instructions to
No Feedback Status Proceed with
Provided Report Closure
Finish
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Flowchart (5) If the Reported Party is a Commissioner and/or a Committee Member under
the Board of Commissioners
Special
Commissioner Not Audit Team WBS
Independent WBS Involved in the Complaint (SKAI) / Manager of President Relevant
Whistleblower
Manager and Not a Member of the External the Ministry Director Work Unit
Related Committee Auditor of SOEs
Team
Start
15
No
2 5 WBS Report
1 Out of Scope
Enter the WBS Analyze the
13
Process Workflow
WBS Report Report into the Report 4
System WBS Report
WBS Report in 8 WBS Report In Out of Scope
scope / out of Laporan WBS Scope Related
scope in scope to the Board of
3
Directors
Classify the WBS 6
Report 14
Sufficient Yes Instructions
information for Follow-up
WBS Report in Actions on WBS
7
19a scope / out of Report
Eligible for 9 16
scope
Provide Special Audit Follow-up
Tindak lanjut Finish
Feedback Action
18
Request the Yes
Whistleblower to No
Provide Additional
10 17
Additional Information
Prepare a Memo or
Information 21
Other Documents Documents
Receive on WBS Report
Inform the for WBS Report
Information Follow-up Actions
Whistleblower if No Follow-up
That No
Feedback is Given Feedback is
20
Provided
11
19b 12
Closing Report Instructions to
No Feedback Status Proceed with
Provided Report Closure
Finish
Flowchart (6) If the Reported Party is the Commissioners Collectively
Independent WBS Ministry of State-
Whistleblower
Manager Owned Enterprises
Start 4
Receive WBS Report
Analysis Results
1 2
Submit WBS Report Enter WBS Report
Process Workflow
into the System
5
WBS Report In
Scope
3
Classify the WBS
Report
6
WBS Report In Scope /
Out of Scope Follow-up / Determine
Handling Steps Based on
Authority
8
Closing Report
Status
7
Finish Instructions for WBS
Report Closure
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Flowchart (7) If The Reported Party is a Director and/or Commissioner of a Subsidiary
Independent President Special President
Whistleblower Audit Team / Director of
WBS Manager Director
Subsidiary Audit Subsidiary
Team
Start
7b
WBS Report
4 Out of Scope
1 2
Analyze the No
Enter the WBS Report
WBS Report Report into the
System
WBS Report in 7a
Process Workflow
scope / out of
WBS Report in
3 scope
Scope
Classify the WBS
Report 5
Sufficient 8b
Yes
WBS Report in information Follow-up
13a scope / out of 6 Action
8a
scope
Provide Eligible for Follow-up
Feedback Special Audit Action
12
Request the
Whistleblower to No Yes
Provide Additional
Information
Additional 9
Information 15 Prepare a Memo or
Inform the Receive Other Documents on
Whistleblower if No Information WBS Report Follow-up
Feedback is Given That No Actions
14 Feedback is
Provided
13b 11 10
Closing Report
Status Instructions to
No Feedback Proceed with
Provided Report Closure
Finish
Disciplinary Process Flowchart – Legal Path
Anti-Fraud Committee Human Capital Legal Division
Management & Culture
Specialist Division
1b 1a
Receive a Copy of the Initiate Execution of
Sanctions Decision Sanctions through Legal
Path
2 3
Coordination with Legal Prepare Legal Team and
Division for Legal Process Steps and Oversee the
Preparation Legal Process
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Flowchart of the Disciplinary Process at BTN
Disciplinary Board of
Start IAD HCMD End
& Sanctions Directors
Committee
Branch Office Initial
Issues, Regional Finish
Review.
Offices, Divisions.
Breaches
Occured
No
Breaches
Identified Implementation
Discussion Decision of the
Level of Issues of Decisions.
of Issues Board
N
Breaches
Y Identified Exceeds
N Authority
Recommendation
Special Audit Decision
Y
Resolved as per
Authority.
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Independent Assurance Statement
INDEPENDENT ASSURANCE STATEMENT
PT. Bank Tabungan Negara Tbk.
Sustainability Report 2024
Statement No: 016/IAS/CBC/II/2025
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 2024 Sustainability Report (the “Report”) in relation with accordance to
GRI Sustainability Reporting Standards (GRI Universal Standards and GRI-G4 FS),
POJK No.51/POJK.03/2017, SEOJK No.16/SEOJK.04/2021, SASB, SUSBA, TCFD,
and the adherence to AA1000 Accountability Principles (2018) with assurance over
the Subject Matter presented in the Report, for the reporting year ended 31st
December 2024. 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
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 all four AA1000 AccountAbility Principles (2018): Inclusivity,
Materiality, Responsiveness and Impact, where sufficient evidence has been
obtained to support our statement such that the risk of our conclusion being in
error is reduced, but not reduced to very low, but not zero.
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We have not performed any work, and do not express any conclusions, on any
other information outside of the Subject Matter that may be published in the Report
or on bank BTN’s website for the current reporting period or for previous periods and
assumed that the financial data and figures provided by bank BTN has been audited
by independent parties therefore, presentation of financial data and figures in the
report NOT within the scope of assurance.
Responsibilities of the Management of bank BTN
The Management of bank BTN is responsible for the preparation of the Subject Matter
in accordance with the Reporting Criteria. The responsibility includes designing,
implementing and maintaining internal control relevant to the preparation of Subject
Matter information that is free from material misstatement, whether due to fraud or
error.
Responsibilities, Competencies and Independency of CBC Global Indonesia
Our responsibility is to plan and perform our work to obtain assurance over whether
the Subject Matter information has been prepared in accordance with the GRI
Universal Standard, GRI-G4 FS, POJK No.51/POJK.03/2017, SEOJK
No.16/SEOJK.04/2021, SASB, SUSBA, TCFD and to report to bank BTN in the form
of an independent assurance conclusion, based on the work performed and the review
progress. We must also express a conclusion over whether the Report adheres to the
AA1000 Principles (2018) and comment on the nature and extent of each Principle
individually. All this engagement was carried out by an independent team of
sustainability assurance professionals whose already obtained the Certified
Sustainability Report Assurer (CSRA) and any relevant certifications.
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.
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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 2024.
• Evaluate the adherence of report content, disclosure and presentation against
the criteria of standard, principles, and indicators using references from
AA1000AS v3, AA1000AP (2018) (AccountAbility Principles), GRI Universal
Standards and GRI G4 Financial Services Sector Disclosure (GRI-G4 FS),
POJK No.51/POJK.03/2017, SEOJK No.16/SEOJK.04/2021, SASB, and
TCFD. Adopt IPCC Guidelines for calculation methodology of energy used and
emission.
• Conduct in-depth interview on compliance, governance, risk management,
business continuity management topics with the representatives of the relevant
functions/divisions of the bank BTN concerning sustainability strategy and
policies for material issues and the implementation of these across the bank
BTN’s business.
• Obtain an understanding of internal control relevant to the engagement in order
to design procedures that are appropriate in the sustainability program and
strategy.
• Obtained an understanding of how the identified sustainability information is
gathered, collated and aggregated internally and enquiries of management of
bank BTN to gain an understanding of the processes for determining material
issues for key stakeholder groups, internally and externally.
• 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.
• Evaluate the subject matter presented in the report to determine whether they
are in line with our overall knowledge of, and experience with, the sustainability
performance of the group.
• Discuss and analysis data and reports with management of bank BTN and data
contributor to determine whether there are any material misstatement of fact or
material inconsistencies based on our understanding obtained as part of our
assurance engagement.
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Finding and Conclusions
From the assurance program and the evidence, we have obtained, a detailed review
against the AA1000 AccountAbility Principles of Inclusivity, Materiality,
Responsiveness and Impact, the GRI Universal Standards, GRI-G4 FS, POJK
No.51/POJK.03/2017, SEOJK No.16/SEOJK.04/2021, SASB, and TCFD is set out
below:
INCLUSIVITY
An assessment was made to investigate the engagement of all key stakeholders
within the bank BTN. The presentation of stakeholder’s inclusivity in the report is fairly
identified and covers all bank BTN’s inclusivity material issues. The stakeholder’s
engagement has been held through communication based on various methods and
approaches with the contributions of all key stakeholders includes their internal and
external stakeholders to develop an accountable and strategic sustainability topic.
MATERIALITY
An assessment was made to investigate the material information disclosed by the bank
BTN. The report fairly covers the bank BTN’s material issues by using materiality matrix
and boundary mapping through the stakeholder’s inclusivity process. The materiality
topics shows in the report provide a fair and sufficient information and aligned with risk
management within the company which enables its stakeholders to make a
professional judgment about bank BTN’s performance and management.
RESPONSIVENESS
An assessment was made to investigate the transparency act of the bank BTN on
material sustainability topics and their related impacts. The report covers bank BTN’s
responsiveness issues. All the information related to the responses from management
to its stakeholder’s inputs and complaints have been included in the report and any
others company’s mechanisms transparently and appropriateness the responses to a
strategic stakeholder engagement management. Besides, the engagement with the
Indonesia Sustainable Finance (IKBI) indicated the bank BTN’s commitment towards
sustainability issues.
IMPACT
The Report content discloses data and information indicating the impacts of the bank
BTN’s decisions, activities, and services on the economy, environment, and society.
An assessment was made to investigate the practice of the bank BTN to monitor,
measure and be accountable for how their actions affect their broader ecosystems. In
overall, disclosures of impacts in the Report content are rather balance and adequate
with both metric and qualitative information. However, the Company still needs to
integrate comprehensively the identified impacts into key management processes to
conduct an impact assessment on the other stakeholders, including its organizational
strategy, governance, goals, objectives, and operations.
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GRI STANDARDS PRINCIPLES
The Report has prepared in accordance with GRI Universal Standards and GRI-G4 FS,
where all disclosure of each material topic is presented in 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 program.
Adherence to POJK No.51/POJK.03/2017, SEOJK No.16/SEOJK.04/2021, SASB,
SUSBA and TCFD
The report has followed or complied to all POJK No.51/POJK.03/2017, SEOJK
No.16/SEOJK.04/2021, SASB, SUSBA, and TCFD reporting guidelines. In terms of the
adherence against the regulations, bank BTN has developed and simplified more
policies and initiatives on social and environment concerns. The bank BTN is advised
to improve their risk and impact analysis on sustainability and also improve the
assessment on high-risk lending sectors with negative impacts towards social and
environment issues. In addition, the bank BTN should also update its sustainability
reporting data collection system more comprehensively, integrated, and reliable.
Opinion Statement
Our professional and certified team of sustainability report assurer has assured this
report in accordance with the AA1000AP (2018), AA1000AS v3 and GRI Standards.
From the review progress, we conclude that the bank BTN’s Sustainability Report 2024
provides a fair view of the all the bank BTN’s programs and performances during 2024.
The extent to which the GRI Standards has been applied in the Report and conclude
this report has been prepared in accordance with GRI Universal Standards.
We believe that the evidence we have obtained is sufficient and appropriate to provide
a basis for our conclusion. We conclude that the data in 2024 for all material topics
performance indicators are fairly represented and there is nothing has come to our
attention that would lead us to believe that the subject matter in the Report for the year
ended 31 December 2024, in all material respects, is not prepared in accordance with
the applicable criteria.
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Conclusion & Recommendations
Bank BTN needs to evaluate and ensure that credit disbursements made through third
parties align with BTN's sustainability commitments and sustainable finance
regulations.
For and on behalf of:
Jakarta, February 20th, 2025
Dr. Ari Purwanti, Ak. CA. CSRA CPMA., CRMP., CERA., CIBA
Operational Manager
PT. CBC Global Indonesia
PT CBC Global Indonesia
The Icon Horizon Broadway Blok M.5 No.3 BSD City, Tangerang, Indonesia 15345
Tel: (62)(21) 87780058
Email: services@cbcglobalindonesia.com
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Report Standard Index
GRI Content Index
Statement of Use PT Bank Tabungan Negara (Persero) Tbk has reported in accordance
with the GRI Standards for the period 1 January until 31 December 2024.
GRI 1 Used GRI 1: Foundation 2021
Applicable GRI Sector Standard GRI G4 Financial Services
Omission
No. Ref.
GRI Standard Disclosure Page Standar
Requirement
Reason Explanation Sektor GR
Omitted
General disclosures
GRI 2: General 2-1 Organizational details 56, 68
disclosures 2021
2-2 Entities included in 48
the organization’s
sustainability reporting
2-3 Reporting period, 48, 327
frequency and contact
point
2-4 Restatement of 48
information
2-5 Assurance oleh pihak 51
eksternal
2-6 Activities, value chain, 56, 57, 66,
and other business 68, 70, 73
relationship
2-7 Employees 110-114
2-8 Workers who are not 110-114
employees
2-9 Governance structure 20, 108,
and composition 226, 231
2-10 Nomination and 226, 242
selection of the highest
governance body
2-11 Chair of the highest 226-227
governance body
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Omission
No. Ref.
GRI Standard Disclosure Page Standar
Requirement
Reason Explanation Sektor GR
Omitted
2-12 Role of the highest 17, 226, 231
governance body
in overseeing the
management of impacts
2-13 Delegation of 17, 226, 231
responsibility for
managing impacts
2-14 Role of the highest 14, 15, 51
governance body in
sustainability reporting
2-15 Conflict of interest 282, 284,
286
2-16 Communication of 271, 274,
critical concerns 278, 295
2-17 Collective knowledge of 125
the highest governance
body
2-18 Evaluation of the 226, 230,
performance of the 247
highest governance body
2-19 Remuneration policies 243, 244
2-20 Process to determine 243
remuneration
2-21 Annual total 245
compensation ratio
2-22 Statement on sustainable 11, 12
development strategy
2-23 Policy commitments 11, 12, 48,
58, 59, 108,
248, 277-
279, 287
2-24 Embedding policy 11, 12, 277
commitments
2-25 Processes to remediate 290
negative impacts
2-26 Mechanisms for seeking 294
advice and raising
concerns
2-27 Compliance with laws 102, 149
and regulations
2-28 Membership associations 73
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Omission
No. Ref.
GRI Standard Disclosure Page Standar
Requirement
Reason Explanation Sektor GR
Omitted
2-29 Approach to stakeholder 20
engagement
2-30 Collective bargaining 137
agreements
Material Topics
GRI 3: Material 3-1 Process to determine 22, 24
topics 2021 material topics
3-2 List of material topics 22, 24
Economic Performance
GRI 3: Material 3-3 Management of material 76
Topics 2021 topics
GRI 201: 201-1 Direct economic 76, 77
Economic value generated and
Performance distributed
2016
201-2 Financial implications 77, 261
and other risks and
opportunities due to
climate change
201-3 Defined benefit plan 144
obligations and other
retirement plans
201-4 Financial assistance 77
received from
government
Market Presence
GRI 3: Material 3-3 Management of material 117, 137
Topics 2021 topics
GRI 202: Market 202-1 Ratios of standard entry 138
Presence 2016 level wage by gender
compared to local
minimum wage
202-2 Proportion of senior 117
management hired from
the local community
Indirect Economic Impacts
GRI 3: Material 3-3 Management of material 153
Topics 2021 topics
GRI 203: Indirect 203-1 Infrastructure 153
Economic investments and services
Impacts 2016 supported
203-2 Significant indirect 153
economic impacts
Procurement Practices
GRI 3: Material 3-3 Management of material 70
Topics 2021 topics
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Omission
No. Ref.
GRI Standard Disclosure Page Standar
Requirement
Reason Explanation Sektor GR
Omitted
Gri 204: 204-1 Proportion of spending 70
Procurement on local suppliers
Practices 2016
Anti-corruption
GRI 3: Material 3-3 Management of material 282
Topics 2021 topics
GRI 205: Anti- 205-1 Operations assessed for 291
corruption 2016 risks related to corruption
205-2 Communication and 282, 294
training about anti-
corruption policies and
procedures
205-3 Confirmed incidents of 293
corruption and actions
taken
Materials
GRI 3: Material 3-3 Management of material 99
Topics 2021 topics
GRI 301: Materials 301-1 Materials used by weight 99
2016 or volume
301-2 Recycled input materials 99
used
301-3 Reclaimed products 99
and their packaging
materials
Energy
GRI 3: Material 3-3 Management of material 85, 86
Topics 2021 topics
GRI 302: Energy 302-1 Energy consumption 86
2016 within the organization
302-2 Energy consumption 86
outside of the
organization
302-3 Energy intensity 86
302-4 Reduction of energy 87
consumption
302-5 Reductions in energy 87
requirements of products
and services
Water and
Effluents
GRI 3: Material 3-3 Management of material 95
Topics 2021 topics
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Omission
No. Ref.
GRI Standard Disclosure Page Standar
Requirement
Reason Explanation Sektor GR
Omitted
GRI 303: Water 303-1 Interactions with water as 95
and Effluents a shared resource
2018
303-2 Management of water 99
discharge-related
impacts
303-3 Water withdrawal 95
303-4 Water discharge 99
303-5 Water consumption 95
Emissions
GRI 3: Material 3-3 Management of material 88, 89
Topics 2021 topics
GRI 305: 305-1 Direct (Scope 1) GHG 89, 94
Emissions 2016 emissions
305-2 Energy indirect (Scope 2) 89, 94
GHG emissions
305-3 Other indirect (Scope 3) 89, 90, 94
GHG emissions
305-4 GHG emissions intensity 90
305-5 Reduction of GHG 94
emissions
305-6 Emissions of ozone- 94
depleting substances
(ODS)
305-7 Nitrogen oxides (NOX), 94
sulfur oxides (SOX), and
other significant air
emissions
Waste
GRI 3: Material 3-3 Management of material 96, 98, 99
Topics 2021 topics
GRI 306: Limbah 306-1 Waste generation and 96, 98
2020 significant waste-related
impacts
306-2 Management of 96, 98, 99
significant waste-related
impacts
306-3 Waste generated 96
306-4 Waste diverted from 96
disposal
306-5 Waste directed to 96
disposal
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Omission
No. Ref.
GRI Standard Disclosure Page Standar
Requirement
Reason Explanation Sektor GR
Omitted
E nvironmental Compliance
GRI 3: Material 3-3 Management of material 102
Topics 2021 topics
Gri 307: 307-1 Non-compliance with 102
Environmental environmental laws and
Compliance 2016 regulations
Employment
GRI 3: Material 3-3 New employee hires and 117
Topics 2021 employee turnover
GRI 401: 401-1 Perekrutan karyawan 117-119
Employment baru dan pergantian
2016 karyawan
401-2 Benefits provided to full 139
time employees that
are not provided to
temporary or part time
employees
401-3 Parental leave 143
Occupational Health and Safety
GRI 3: Material 3-3 Management of material 146
Topics 2021 topics
GRI 403: 403-1 Occupational health and 146
Occupational safety management
Health and system
Safety 2018
403-2 Hazard identification, risk 147-148
assessment, and incident
investigation
403-3 Occupational health 146
services
403-4 Worker participation, 147
consultation, and
communication on
occupational health and
safety
403-5 Worker training on 146-147
occupational health and
safety
403-6 Promotion of worker 146
health
403-7 Prevention and mitigation 147
of occupational health
and safety impacts
directly linked by
business relationships
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Omission
No. Ref.
GRI Standard Disclosure Page Standar
Requirement
Reason Explanation Sektor GR
Omitted
403-8 Workers covered by an 147
occupational health and
safety management
system
403-9 Work-related injuries 148
403-10 Work-related ill health 148
Training and Education
GRI 3: Material 3-3 Management of material 122
Topics 2021 topics
GRI 404: Training 404-1 Average hours of training 131
and Education per year per employee
2016
404-2 Programs for upgrading 125, 132,
employee skills and 143
transition assistance
programs
404-3 Percentage of employees 136
receiving regular
performance and career
development reviews
Diversity and Equal Opportunity
GRI 3: Material 3-3 Management of material 108, 114, 116,
Topics 2021 topics 137
GRI 405: Diversity 405-1 Diversity of governance 108-110,
and Equal bodies and employees 114, 116
Opportunity 2016
405-2 Ratio of basic salary and 137
remuneration of women
to men
Non-Discrimination
GRI 3: Material 3-3 Management of material 114, 116
Topics 2021 topics
GRI 406: Non 406-1 Incidents of 114, 116
Discrimination discrimination and
2016 corrective actions taken
Freedom of Association and Collective Bargaining
GRI 3: Material 3-3 Management of material 148
Topics 2021 topics
Gri 407: Freedom 407-1 Operations and suppliers 148
of Association in which the right to
and Collective freedom of association
Bargaining 2016 and collective bargaining
may be at risk
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Omission
No. Ref.
GRI Standard Disclosure Page Standar
Requirement
Reason Explanation Sektor GR
Omitted
Child Labor
GRI 3: Material 3-3 Management of material 114, 116
Topics 2021 topics
GRI 408: Child 408-1 Operations and suppliers 114, 116
Labor 2016 at significant risk for
incidents of child labor
Forced or Compulsory Labor
GRI 3: Material 3-3 Management of material 114, 116
Topics 2021 topics
GRI 409: Forced 409-1 Operations and suppliers 114, 116, 137
or Compulsory at significant risk for
Labor incidents of forced or
compulsory labor
Local Community
GRI 3: Material 3-3 Management of material 153
Topics 2021 topics
GRI 413: Local 413-1 Operations with local 153, 159
Community community engagement,
impact assessments, and
development programs
413-2 Operations with 218
significant actual and
potential negative
impacts on local
communities
Marketing and Labeling
GRI 3: Material 3-3 Management of material 222
Topics 2021 topics
GRI 417: 417-1 Requirements for product 222
Marketing and and service information
Labeling and labeling
417-2 Incidents of non- 222
compliance concerning
product and service
information and labeling
417-3 Incidents of non- 222
compliance
concerning marketing
communications
Customer Privacy
GRI 3: Material 3-3 Management of material 205
Topics 2021 topics
GRI 418: 418-1 Substantiated 209-210,
Customer complaints concerning 216
Privacy 2016 breaches of customer
privacy and losses of
customer data
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Omission
No. Ref.
GRI Standard Disclosure Page Standar
Requirement
Reason Explanation Sektor GR
Omitted
Socioeconomic Compliance
GRI 3: Material 3-3 Management of material 149
Topics 2021 topics
GRI 419: 419-1 Non-compliance with 149
Socioeconomic laws and regulations in
Compliance 2016 the social and economic
area
Sector disclosure
GRI G4 Financial FS1 Policies with certain 290
Services environmental and social
components
FS2 Procedures for 230, 290
assessing and screening
environmental and social
risks in business lines
FS3 Processes for monitoring 290
client implementation
and compliance with
environmental and
social requirements
included in agreements
or transactions
FS4 Processes for improving 125, 202
staff competency
to implement
environmental and social
policies and procedures
as applied to lines of
business
FS5 Interactions with clients/ 71, 181, 290
investments/business
partners regarding
environmental and social
risks and opportunities
FS6 Portfolio percentage for 160, 163,
business lines by specific 165, 166
area size (eg micro/SME/
large) and by sector
FS7 The monetary value of 163, 165,
products and services 166
designed to provide
specific social benefits
for each line of business
broken down by purpose
or objective
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No. Ref.
GRI Standard Disclosure Page Standar
Requirement
Reason Explanation Sektor GR
Omitted
FS8 The monetary value of 165
products and services
designed to provide
specific environmental
benefits for each line of
business broken down by
purpose or objective
FS9 Scope and frequency 290
of audits to assess
implementation of
environmental and
social policies and risk
assessment procedures
FS10 Percentage and number 181, 261
of companies held in the
portfolio of institutions
with which the reporting
organization interacts on
environmental or social
issues
FS11 Percentage of assets 261
that are subject to
positive and negative
environmental social
issues
FS14 Percentage of assets 202
that are subject to
positive and negative
environmental social
issues
FS15 Policies for the fair design 222
and sale of financial
products and services
FS16 Initiatives to improve 168-173
financial literacy by type
or beneficiary
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Financial Service Authority (OJK) Reference [OJK G.4]
SEOJK Reference Disclosure Page
Circular no. 16/ A.1 Descriptions of Sustainability Strategy 16
SEOJK.04/2021
B.1 Economic Aspects 6, 7, 70, 76, 77,
99, 187
B.2 Environmental Aspects 7
B.3 Social Aspects 8, 17
C.1 Vision, Mission and Sustainability Values 58
C.2 Company's Address 56
C.3 Scale of Business 56, 57, 68, 108,
110-114
C.4 Products, Services and Business Activities Conducted 56, 66
C.5 Membership of Associations 73
C.6 Significant Changes in Organization 73
D.1 Explanations from the Board 31
E.1 Responsibility in the Implementation of Sustainable Finance 17, 31
E.2 Development of Finance-Related Competency 125
E.3 Risk Assessment on the Implementation of Sustainable Finance 248
E.4 Stakeholder Relations 20
E.5 Issues Surrounding the Implementation of Sustainable Finance 17
F.1 Activities in Building a Culture of Sustainability 16, 98, 100, 102
F.2 Comparison between Production Target and Performance, Portfolio, 75
Financing Target, or Investment, Income and Profit and Loss
F.3 Comparison between Portfolio Targets and Performance, Financing 153
Targets, or Investments in Financial Instruments or Projects Compatible
with Sustainable Finance
F.4 Environmental Cost 99
F.5 Use of Environmentally Friendly Materials 99
F.6 Amount and Intensity of Energy Used 86
F.7 Efforts and Fulfillment of Energy Efficiency and Use of Renewable Energy 85
F.8 Water Usage 95
F.9 Impacts from Operational Areas Near or Located 102
Conservation or Biodiversity Areas
F.10 Biodiversity Conservation Efforts 102, 290
F.11 Amount and Intensity of Emissions Generated by Type 89
F.12 Emission Reduction Efforts and Achievements Made 94
F.13 Amount of Waste and Effluent Generated by Type 96
F.14 Waste and Effluent Management Mechanism 96
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F.15 Spills that Occured 100
F.16 Number and Material of Environmental Complaints Received and 102
Resolved
F.17 Commitment to Provide Services for Products and / or Services that are 222
Equal to Consumers
F.18 Equal Employment Opportunity 108
F.19 Child Labor and Forced Labor 114, 116, 137
F.20 Regional Minimum Wage 138
F.21 Decent and Safe Working Environment 146
F.22 Employee Capability Training and Development 125
F.23 Impact of Operations on Surrounding Communities 153
F.24 Public Complaints 218
F.25 Environmental Social Responsibility Activities (TJSL) 153
F.26 Innovation and Development of Sustainable Financial Products/ 194
Services
F.27 Safety Evaluated Products/Services for Customers 209, 222
F.28 Impact of Product/Service 222
F.29 Number of Products Recalled 222
F.30 Customer Satisfaction Survey on Sustainable Financial Products and/ 222
or Services
G.1 Written Verification from Independent Party 51
G.2 Feedback Form 14, 15, 51, 52, 326
G.3 Response towards Feedback on Previous Year's Sustainability Report 51, 52
G.4 List of Disclosures According to Financial Services Authority Regulation 318
Number 51/POJK.03/2017
Sustainability Accounting Standard Board (SASB) Reference
Code Description Page
Data Security
FN-CB-230a.1 (1) Number of data breaches 210
(2) Percentage of personally identifiable information
(3) Number of accounts affected
FN-CB-230a.2 Approaches to dealing with data security risks 209, 210
Keuangan
FN-CB-240a.1 Loan amount that is eligible for small business and community development programs 161
FN-CB-240a.2 Amount of eligible and non-accrual loans to promote small business and community 160
development
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Code Description Page
FN-CB-240a.3 Number of accounts that previously did not have a bank account or faced limited 290
banking access
FN-CB-240a.4 Number of participants in financial literacy programs 169
Inkorporasi
FN-CB-410a.1 Commercial and credit opening by industry 160, 161, 163,
165
FN-CB-410a.2 Approaches to including environmental, social and governance (ESS) factors in credit 290
analysis
Business
FN-CB-510a.1 Total losses due to legal proceedings relating to fraud, insider trading, antitrust, anti 149, 293
competitive conduct, market manipulation, malpractice, or other related financial
industry violations
FN-CB-510a.2 Whistleblowing policies and procedures 295
Task Force On Climate-Related Financial Disclosures (TCFD)
Framework
Code Disclosure Page
Governance
a Describes board oversight of climate-related risks and opportunities 17
b Describe the role of management in assessing and managing climate-related risks and 261
opportunities
Strategy
a Explain the climate-related risks and opportunities the organization has identified in the shorter, 261
medium, and longer terms
b Explain the impact of climate-related risks and opportunities on an organization's business, 261
strategy and financial planning
Risk Management
a Describe the organization's processes for identifying and assessing climate-related risks 261
b Describe organizational processes for managing climate-related risks 73, 261
c Describe processes for identifying, assessing, and managing climate-related risks integrated 261
into the organization's overall risk management
Metrics and Targets
a Disclose metrics used by the organization to assess climate-related risks and opportunities in 90, 94
line with their strategy and risk management processes
b Disclose Scope 1, Scope 2, and, where appropriate, Scope 3 greenhouse gases (GHG) and 89
related risks
c Describe the targets used by the organization to manage climate-related risks and opportunities 94
and performance against targets
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MSCI Rating Index Table
No Pillar Indicator Sub Indicator Description Page
1 Environment Financing ESG Risk Scope of management system 180-181
Pillar Environmental Management to assess ESG risks in financing
Impact Policies activities
2 Environment Financing Environmental credit Credit policy related to agriculture 182
Pillar Environmental policy
Impact
3 Environment Financing Environmental credit Credit policy related to biodiversity 182, 186
Pillar Environmental policy
Impact
4 Environment Financing Environmental credit Credit policy related to power utilities 183
Pillar Environmental policy
Impact
5 Environment Financing Environmental credit Credit policy related to mining 183, 184
Pillar Environmental policy
Impact
6 Environment Financing Environmental credit Credit policy related to oil and gas 185
Pillar Environmental policy
Impact
7 Environment Financing ESG Risk Involvement of group credit risk in 180-186
Pillar Environmental Management (ESRM) ESG due diligence 251-252
Impact Integration
8 Environment Financing ESG Risk ESG due diligence triggers and risk 180-186
Pillar Environmental Management (ESRM) escalation process clearly defined 251-252
Impact Integration
9 Environment Financing ESG Risk Conducts climate-related risk 260-271
Pillar Environmental Management (ESRM) analysis
Impact Oversight
10 Environment Financing ESG Risk Oversight of ESG risk management in 249-250
Pillar Environmental Management (ESRM) financing activities
Impact Oversight
11 Environment Financing ESG Risk Evidence of board-level 88
Pillar Environmental Management (ESRM) engagement on climate-related
Impact Oversight risks
12 Environment Financing ESG Risk Formal management systems 180-186, 253-
Pillar Environmental Management (ESRM) to assess ESG risks in financing 255
Impact Systems activities
13 Environment Financing Environmental Sustainability-related financial 190
Pillar Environmental Finance product development
Impact Opportunities
14 Environment Financing Environmental Involvement in green financing and 188-190
Pillar Environmental Finance securities
Impact Opportunities
15 Social Pillar Consumer Practices Employee training on consumer 210-211
Financial financial protection
Protection
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No Pillar Indicator Sub Indicator Description Pages
16 Social Pillar Consumer Practices Debt collection policy 217
Financial
Protection
17 Social Pillar Consumer Practices Oversight of financial product or 204
Financial service reviews
Protection
18 Social Pillar Consumer Practices Fair advertising policy 203
Financial
Protection
19 Social Pillar Consumer Practices Financial product complaint 220-221
Financial handling process
Protection
20 Social Pillar Consumer Practices Company offers loan modification 217
Financial options
Protection
21 Social Pillar Consumer Practices Financial education initiatives and 168-173
Financial stakeholder outreach
Protection
22 Social Pillar Consumer Practices Oversight of complaint resolution 220
Financial process
Protection
23 Social Pillar Human Capital Practices Scope of support for degree 128-129
Development programs and certifications
24 Social Pillar Human Capital Strategy Extent of human resource-related 145
Development grievance reporting or escalation
procedures
25 Social Pillar Human Capital Strategy Employee satisfaction survey 145
Development frequency
26 Social Pillar Human Capital Talent pipeline Formal talent pipeline development 117-118, 122-
Development development strategy 124
strategy
27 Social Pillar Human Capital Talent pipeline Graduate traineeship/ 133-136
Development development apprenticeship
strategy program
28 Social Pillar Human Capital Talent pipeline Partners with educational institutions 122-124
Development development to develop or deliver joint training
strategy programs for staff
29 Social Pillar Human Capital Programs & Employee equity programs 139-140
Development Initiatives
30 Social Pillar Human Capital Programs & Workforce eligible for non-pay 137-139
Development Initiatives benefits
31 Social Pillar Human Capital Programs & Variable performance-based 139
Development Initiatives component to pay
32 Social Pillar Human Capital Programs & Regular performance appraisals and 136
Development Initiatives feedback processes
322 PT Bank Tabungan Negara (Persero) Tbk | Sustainability Report 2024
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Community Development Excellent Service for Sustainability
and Empowerment Customer Satisfaction Governance Integrity
No Pillar Indicator Sub Indicator Description Pages
33 Social Pillar Human Capital Programs & Job-specific development training 129-130
Development Initiatives programs
34 Social Pillar Human Capital Programs & Skills and knowledge development 133-136
Development Initiatives training
35 Social Pillar Access to Finance Products and Extent of involvement in 160-167
Strategy microfinance/ microinsurance
36 Social Pillar Access to Finance Distribution and Innovation in mobile/online 194-202
Outreach distribution channels for financial
services
37 Social Pillar Access to Finance Distribution and Points of reach of financial services 195-196
Outreach
38 Social Pillar Access to Finance Distribution and Innovation in other alternative 194
Outreach branchless distribution channels for
financial services
39 Social Pillar Privacy & Data Practices - Scope of data protection policy 205
Security Operations
40 Social Pillar Privacy & Data Practices - Rights provided to consumers 212-213, 215
Security Operations regarding the control of their data
41 Social Pillar Privacy & Data Practices - Measures to address data breaches 206-209
Security Operations
42 Social Pillar Privacy & Data Practices - Frequency of audits of information 207, 216
Security Operations security system
43 Social Pillar Privacy & Data Practices - Responsibility for privacy and data 210
Security Operations security
44 Social Pillar Privacy & Data Practices - Evidence of access control and 207-208
Security Operations protection of personal or sensitive
data
45 Social Pillar Privacy & Data Practices - Consent policy for use of consumer 221
Security Operations data for secondary purposes
46 Social Pillar Privacy & Data Practices - Collection, usage and retention of 216
Security Operations customer information
47 Social Pillar Privacy & Data Practices - Supply Data protection programs covering 213
Security Chain suppliers and business partners
48 Social Pillar Privacy & Data Practices - Scope of employee training on 206, 211
Security Employees privacy and data security
49 Social Pillar Privacy & Data Practices - Scope of information security 207
Security Certification management system certifications
50 Social Pillar Privacy & Data Practices - Type of information security 207, 215
Security Certification management system certification
51 Governance Corporate Board - Audit Audit Board/ Committee Disclosed in
Pillar Governance Oversight Independence the Annual
Report
Sustainability Report 2024 | PT Bank Tabungan Negara (Persero) Tbk 323
Page 221
Sustainable Environmental Employee Development
About The Report BTN Profile
Management and Welfare Support
No Pillar Indicator Sub Indicator Description Pages
52 Governance Corporate Board - Board Executives on Board Disclosed in
Pillar Governance Independence the Annual
Report
53 Governance Corporate Board - Board Related Party Transactions Disclosed in
Pillar Governance Independence the Annual
Report
54 Governance Corporate Board - Board Skills & Bank has 30% female directors 110
Pillar Governance Diversity
55 Governance Corporate Board Attendance Attendance at Board meetings 228, 230
Pillar Governance
56 Governance Corporate Board - Pay Pay Committee Independence Disclosed in
Pillar Governance Oversight the Annual
Report
57 Governance Corporate Pay -Non-executive Director Equity Policy 246
Pillar Governance Director Pay
58 Governance Corporate Pay - Pay Figures Executive Pay Disclosure 243-245
Pillar Governance
59 Governance Corporate Pay - Pay CEO Equity Policy 246
Pillar Governance Performance
Alignment
60 Governance Corporate Pay - Pay Pay Linked to Sustainability 244
Pillar Governance Performance
Alignment
61 Governance Corporate Ownership & Control Annual Director Elections 242-243
Pillar Governance -Director Elections
62 Governance Corporate Ownership & Control Proxy Access Disclosed in
Pillar Governance - Director Elections the Annual
Report
63 Governance Corporate Ownership & Control Government Intervention Concerns Disclosed in
Pillar Governance - One Share One the Annual
Vote Report
64 Governance Corporate Ownership & Controlling Shareholder Disclosed in
Pillar Governance Control - Ownership the Annual
Structure Report
65 Governance Corporate Ownership & Controlling Shareholder Concerns Disclosed in
Pillar Governance Control - Ownership the Annual
Structure Report
66 Governance Corporate Ownership & Control Fair Bid Treatment Provisions 72
Pillar Governance - Takeover Provisions
67 Governance Corporate Business Ethics Responsibility for ethics issues 278-279
Pillar Behavior Policies & Practices
68 Governance Corporate Business Ethics Bribery and Anti-corruption Policy 282
Pillar Behavior Policies & Practices
324 PT Bank Tabungan Negara (Persero) Tbk | Sustainability Report 2024
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Community Development Excellent Service for Sustainability
and Empowerment Customer Satisfaction Governance Integrity
No Pillar Indicator Sub Indicator Description Pages
69 Governance Corporate Business Ethics Regular Audits of Ethical Standards 278-279,
Pillar Behavior Policies & Practices 280-282
70 Governance Corporate Business Ethics Whistleblower Protection 296
Pillar Behavior Policies & Practices
71 Governance Corporate Business Ethics Employee training on ethical 280-281
Pillar Behavior Policies & Practices standards
72 Governance Corporate Business Ethics Anti-Corruption Policy for Suppliers 282
Pillar Behavior Policies & Practices
73 Governance Corporate Business Ethics Anti-money Laundering Policy 287-289
Pillar Behavior Policies & Practices
74 Governance Corporate Tax Transparency Tax Transparency 78
Pillar Behavior
75 Governance Corporate Business ethics Corruption Risk Exposure & Disclosed in
Pillar Behavior controversies Controversies the Annual
Report
76 Governance Corporate Accounting Auditor Tenure Disclosed in
Pillar Governance - Auditor the Annual
Independence Report
Sustainability Report 2024 | PT Bank Tabungan Negara (Persero) Tbk 325
Page 223
Sustainable Environmental Employee Development
About The Report BTN Profile
Management and Welfare Support
Feedback Sheet [OJK G.2]
Thank you for reading PT Bank Tabungan Negara (Persero) Tbk 2024 Sustainability Report. To realize better reporting
quality in the coming year, we expect suggestions, criticisms and suggestions from readers and users of this report.
The Company is committed to continuously improving sustainability performance and providing the best for
stakeholder.
Profile
Name :
Institution/Company :
Phone/Hp :
Stakeholder Category :
Customer Shareholder Goverment and policy makers
Employee Partners, suppliers Other, please specify
Mass media Society, local community
Please choose the appropriate answer by putting a √ in front of the available answers:
1. Does this report describe the Company’s
performance in contributing to sustainable Agree Disagree I don’t know
development?
2. Is this report useful for you? Agree Disagree I don’t know
3. Is this report easy to understand? Agree Disagree I don’t know
4. Is this report interesting? Agree Disagree I don’t know
326 PT Bank Tabungan Negara (Persero) Tbk | Sustainability Report 2024
Page 224
Community Development Excellent Service for Sustainability
and Empowerment Customer Satisfaction Governance Integrity
Please write the answers according to your opinion?
1. Which piece of information is the most useful and interesting?
2. Which part of the information is not useful so it needs to be improved?
3. Is the data presented transparent, reliable, and balanced?
4. Suggestion/comment for future improvement of the report
We really appreciate the feedback
PT Bank Tabungan Negara (Persero) Tbk [GRI 2-3]
you provide. For this, please send this
feedback sheet to:
Corporate Secretary Division
BTN Tower 2 21st Floor
Jl. H. R. Rasuna Said No.1,
South Jakarta 12980
Email : csd@btn.co.id
Sustainability Report 2024 | PT Bank Tabungan Negara (Persero) Tbk 327
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Sustainable Environmental Employee Development
About The Report BTN Profile
Management and Welfare Support
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328 PT Bank Tabungan Negara (Persero) Tbk | Sustainability Report 2024
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Page 227
PT Bank Tabungan Negara (Persero) Tbk Menara BTN Jl. Gajah Mada No. 1 Jakarta Pusat 10130 Phone : (+62) 6336789, 6332666 E-mail : csd@btn.co.id www.btn.co.id
Names mentioned 75 people and organisations named in the text · linked when the evidence is strong
unresolved
—
Armand B.
· Independent
p.5 ×2
unresolved
person
Business Administration
· Commissioner
p.5
unresolved
—
Sentot A.
· Independent
p.5 ×2
unresolved
person
Administration
· Commissioner
p.5
unresolved
—
Andin
· Commissioner
p.6 ×2
unresolved
—
Himawan
· Commissioner
p.6
unresolved
org
Nixon L.P.
· President
p.6 ×2
unresolved
—
Oni Febriarto
· Vice President
p.6 ×2
unresolved
—
Elisabeth
· Director
p.6 ×2
unresolved
—
Hirwandi
· Director of
p.6 ×2
unresolved
—
Setiyo
· Director of Risk
p.6
unresolved
—
Nofry Rony
· Director of
p.6 ×2
unresolved
—
Hakim
· Director of
p.7 ×2
unresolved
org
Ministry of State-Owned Bank BTN
p.7
unresolved
org
Bank BTN’s
p.7 ×2
unresolved
org
Minister of State-
p.7
unresolved
org
Ministry of State-Owned Enterprises
p.7
unresolved
org
Minister of State-Owned Enterprises Number PER-
p.7
unresolved
—
Male
· 6,576
p.7
unresolved
—
Female
· 6,288
p.7
unresolved
—
Subtotal
· 12,864
p.7
unresolved
org
Ministry of SOEs
p.15
unresolved
person
Training
· Commissioner
p.22 ×4
unresolved
org
Risk Management Certification
· Commissioner
p.23 ×5
unresolved
—
Himawan Arief
· Commissioner
p.23
unresolved
org
PT Garda Multi Talenta Sulistyowati
p.23
unresolved
org
PT Garda Multi Rahardjo
p.24
unresolved
person
Refreshment
· Director
p.24
unresolved
org
PT Garda Multi Information
p.24
unresolved
org
PT Garda Multi Novie Riswanti
p.24
unresolved
org
PT Garda Multi Distribution
p.24
unresolved
org
PT Garda Multi Gafar
p.24
unresolved
org
PT Garda Multi Management
p.24
unresolved
org
PT Garda Multi Poetra
p.24
unresolved
org
PT Garda Multi Putratama
p.25
unresolved
org
Ministry of Manpower and Transmigration
p.34
unresolved
org
Minister of Manpower Regulation
p.34
unresolved
org
PT Bank Tabungan
p.41
unresolved
org
Negara (Persero) Tbk
p.41
unresolved
org
Ministry of Health Regulation
p.43 ×2
unresolved
org
Ministry of Comprehensively
p.44
unresolved
org
Ministry of Manpower Regulation
p.45
unresolved
org
Minister of State-Owned Enterprises
p.49
unresolved
org
Bank CSR
p.54
unresolved
org
Financial Services Authority
p.65 ×3
unresolved
org
Ministry of Housing and Settlement
p.68
unresolved
org
Ministry of Agrarian Affairs
p.68
unresolved
org
Bank Indonesia
p.69
unresolved
org
Ministry of Environment Labor Policies
p.79
unresolved
org
Ministry of Energy and Monitoring Effort
p.81
unresolved
org
Ministry of Environment and Forestry. A. Hold Environmental Management System
p.83
unresolved
org
Ministry of Housing
p.89
unresolved
org
Bank Regulation
p.89
unresolved
—
providing liquidity
p.89
unresolved
—
landed houses or
p.89 ×2
unresolved
—
apartment units
p.89 ×2
unresolved
—
specifically designed for Civil Servants (ASN)
p.89
unresolved
—
households (MBR)
p.89
unresolved
—
in Tapera, for
p.89
unresolved
—
purchasing
p.89
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