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Page 1
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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                                                                                                                Employee Development
                                                                              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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                Community Development            Excellent Service for                Sustainability
                  and Empowerment               Customer Satisfaction              Governance Integrity




    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




                                                 Sustainability Report 2024 | PT Bank Tabungan Negara (Persero) Tbk                109
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                                                                                                                 Employee Development
                                                                              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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                 and Empowerment                 Customer Satisfaction          Governance Integrity




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




                                                  Sustainability Report 2024 | PT Bank Tabungan Negara (Persero) Tbk             111
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                                                                                                                                                      Employee Development
                                                                                                       Sustainable Environmental                       and Welfare Support
                             About The Report                      BTN Profile
                                                                                                             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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                      Community Development                            Excellent Service for                       Sustainability
                        and Empowerment                               Customer Satisfaction                     Governance Integrity




                                       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




                                                                        Sustainability Report 2024 | PT Bank Tabungan Negara (Persero) Tbk                                113
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                                                                                                                                 Employee Development
                                                                                          Sustainable Environmental               and Welfare Support
                           About The Report                    BTN Profile
                                                                                                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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            Community Development               Excellent Service for            Sustainability
              and Empowerment                  Customer Satisfaction          Governance Integrity




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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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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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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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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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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      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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                                             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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                                                                             Sustainable Environmental       and Welfare Support
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                                            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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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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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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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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                                                                         Sustainable Environmental            and Welfare Support
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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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                                                                              Sustainable Environmental         and Welfare Support
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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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                                                           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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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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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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Development and
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153   Corporate Social Responsibility (CSR)
160   Financial Inclusion and Literacy
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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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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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            About The Report               BTN Profile
                                                                        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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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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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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                                                                                 Management                   Welfare Support




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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                                                                                                 Management                      Welfare Support




      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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                                                                          Management                         Welfare Support




                                                            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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                                                                                Management                        Welfare Support




                                                                 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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            and Empowerment                                                           Governance Integrity




                                                                                           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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                                                                                  Management                 Welfare Support




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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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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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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                         Excellent Service for
Community Development   Customer Satisfaction             Sustainability
  and Empowerment                                      Governance Integrity




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Sustainability
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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                        About The Report               BTN Profile
                                                                                       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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                      About The Report               BTN Profile
                                                                                  Management              and Welfare Support




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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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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            Community Development           Excellent Service for        Governance Integrity
              and Empowerment              Customer Satisfaction




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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                                                                                                                   Management                     and Welfare Support




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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            Community Development           Excellent Service for           Governance Integrity
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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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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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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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                 and Empowerment                       Customer Satisfaction




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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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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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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                   and Empowerment                                      Customer Satisfaction




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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                         Community Development                               Excellent Service for                      Governance Integrity
                           and Empowerment                                  Customer Satisfaction




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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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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              Community Development             Excellent Service for        Governance Integrity
                and Empowerment                Customer Satisfaction




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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                                                                                     Management              and Welfare Support




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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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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                                                                                 Management               and Welfare Support




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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                          About The Report                       BTN Profile
                                                                                                 Management                          and Welfare Support




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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                                                                                                                                                                       Management                                       and Welfare Support




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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                                         Community Development                                         Excellent Service for                            Governance Integrity
                                           and Empowerment                                            Customer Satisfaction




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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                                                                                              Sustainability
                Community Development                     Excellent Service for            Governance Integrity
                  and Empowerment                        Customer Satisfaction




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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             About The Report             BTN Profile
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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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                                                                                    Omission
                                                                                                                  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




                                            Sustainability Report 2024 | PT Bank Tabungan Negara (Persero) Tbk         317
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                    About The Report               BTN Profile
                                                                                Management              and Welfare Support




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




318            PT Bank Tabungan Negara (Persero) Tbk | Sustainability Report 2024
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              and Empowerment              Customer Satisfaction           Governance Integrity




 SEOJK Reference                                        Disclosure                                                   Page

                    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




                                             Sustainability Report 2024 | PT Bank Tabungan Negara (Persero) Tbk                   319
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                      About The Report               BTN Profile
                                                                                   Management              and Welfare Support




          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




320              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




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




                                       Sustainability Report 2024 | PT Bank Tabungan Negara (Persero) Tbk                321
Page 219
                                                                          Sustainable Environmental         Employee Development
                      About The Report             BTN Profile
                                                                                Management                   and Welfare Support




 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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          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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328   PT Bank Tabungan Negara (Persero) Tbk | Sustainability Report 2024
Page 226

          
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

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Names mentioned 75 people and organisations named in the text · linked when the evidence is strong

linked org Bank Tabungan Negara (Persero) Tbk p.3 ×305
linked person Iqbal Latanro · Vice President p.5 ×3
linked person Andi Nirwoto · Director of p.6 ×3
linked person Eko Waluyo · Director of p.7 ×3
linked person Setiyo Wibowo · Director of Risk p.24
linked org Pantai Indah Kapuk p.55
possible — Chandra M. · President p.5 ×2
possible — Herry · Commissioner p.6 ×2
possible — Adi · Independent p.6 ×2
possible — Bambang · Independent p.6 ×2
possible — Jasmin · Director of p.6 ×2
possible person Muhammad · Director of SME p.7 ×2
possible — Morgan Stanley p.78
possible — Batavia Prosperindo p.86
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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