LEGAL REFERENCES
BRI’s code of conduct is an important part of BRI’s GCG framework and provides ethical guidelines for BRI people in carrying out their duties, authorities, obligations and responsibilities. The policies governing the elements of BRI’s code of ethics and their implementation are stated in the Joint Decree of the BRI Board of Commissioners and Directors Number: 06-KOM/ BRI/12/2013 and Nokep: S.65-DIR/DKP/12/2013 concerning the BRI Code of Conduct

CODE OF CONDUCT COMMITMENT
The Code of Conduct applies to all employees in all organization levels. The continuous application of code of conduct is carried out through attitudes, actions, commitments and provisions that foster the creation of a corporate culture.

COMPLIANCE WITH THE CODE OF CONDUCT
BRI has a code of conduct which is the basic value for all employees in carrying out their work professionally. All BRI employees sign a statement of compliance with the code of conduct every year as a form of commitment in compliance with the company’s code of conduct.

CODE OF CONDUCT KEY POINTS
BRI’s code of conduct has 9 (nine) elements, which are:

  1. Compliance with Law and Bank Policies
    The Bank’s commitment to comply with applicable laws and regulations to strengthen the Bank’s compliance culture.
  2. Relationships with Stakeholders
    1. Ethics to Customers
      The Bank’s commitment to providing excellent service to customers by prioritizing the principle of prudence.
    2. Ethics to Working Partners
      The Bank Commitment’s with Business Partners is based on legitimate and fair business practice and uphold professionalism by always prioritizing the interests of the company.
    3. Ethics to Competitor
      The Bank’s commitment to promote healthy competition in carrying out its business, by increasing competitor banks as a driver of increased performance.
    4. Ethics for Regulator
      The Bank’s commitment to fulfill the obligations and conditions set by the banking regulator and other authorized authorities.
    5. Ethics to Shareholders
      The Bank’s commitment in an effort to provide positive and optimal contributions to shareholders.
  3. Relation with Community and the Environment
    The Bank’s commitment to uphold the values of the local wisdom and providing benefits and supporting environmental preservation where the Bank performs its operations.
  4. Company Relations with Bank Employees
    1. The Bank’s commitment in providing equal opportunities to all employees to participate in achieving the Bank’s vision and mission.
    2. The Bank’s commitment in creating a favorable work environment to increase the productivity and ethics of fellow employees.
  5. Bank Information Confidentiality
    The Bank’s commitment to protect all customer and internal Bank information from outside/unauthorized parties.
  6. Bank Report Integrity and Accuracy
    The commitment of employee to submit the Bank reports promptly, accurately and accountable to the management, shareholders and other interested parties.
  7. Conflict of Interest
    The commitment of employee to implement a policy of conflicts of interest handling and does not place in conditions/situations where conflicts of interest arise between themselves and the Bank, Customers, and Third Parties which can be detrimental to the company.
  8. Political Contributions and Activities
    The commitment of employee to not contribute to political activities or other similar businesses.
  9. Prohibition of Receiving Gifts
    Employees are not permitted to ask for and receive any gifts or rewards that are not in accordance with the applicable laws and regulations.

STATEMENT THAT THE CODE OF CONDUCT APPLIES TO ALL ORGANIZATIONAL LEVELS

  1. Board of Directors, Board of Commissioners and all BRI Personnel are required to know, understand, and implement the BRI’s Code of Conduct.
  2. All Bank’s personnel must submit in writing the Statement of Compliance with BRI’s Code of Conduct. The signed BRI’s Statement of Compliance with Code of Conduct is a condition in continuing the working relationship with the Bank.

CODE OF CONDUCT DISSEMINATION
The company has communicated the code of conduct policy to all BRI personnel (Directors, Board of Commissioners and BRI employees) in 2020, including through:

  1. Company website.
  2. Landing Page on the BRISTARS application.
  3. Collective Labor Agreement between the Company’s Workers Union and the Company’s Management.
  4. Implementation of the Performance Improvement Forum.
  5. Posters, videos and other advertising media at the Company’s offices.

ENFORCEMENT OF CORPORATE CODE OF CONDUCT
In the effort to enforce the code of conduct in the company, the Board of Commissioners, Directors and All BRI Employees are committed to running the Bank’s business by implementing ethics in the banking system. This commitment is manifested in:

  1. Statement of Compliance with BRI’s Code of Conduct
    All BRI personnel are required to know and understand well and state a “Statement of Compliance with the Code of Ethics” every year.
  2. Commitment of Management and All BRI Employees
    The commitment of the management and all employees not to receive and give gratuities in the form of money and/or goods related to their obligations or responsibilities which are published in the mass media and the Company’s website.
  3. Annual Disclosure Conflicts of Interest
    All BRI personnel are required to make an annual disclosure that does not have a conflict of interest every year, and all work units are required to submit transaction reports/decisions that contain conflict of interest every month.
  4. Integrity Pact
    The signing of the integrity pact is carried out by the procurement committee, user work unit, vendor or partnerin the entire procurement process for goods and services at BRI. In addition, every year the Board of Directors and the Board of Commissioners sign the GCG Statement as a form of commitment to carry out the principles of Good Corporate Governance, while all employees sign a commitment to anti-fraud and gratuity control at the Performance Improvement Forum which is held annually.
  5. Awareness Program
    One form of implementing a code of ethics to become a culture at BRI is by strengthening the corporate culture through 5 corporate culture values, 10 corporate culture behaviors and 20 actions that reflect corporate culture behavior. In addition, to ensure & oversee the implementation of a code of ethics and corporate culture for every employee, BRI forms Culture Heroes (Work Unit Heads) and Culture Agents in each BRI work unit.
  6. Whistleblowing System
    All violations of BRI’s code of ethics are reported through the Whistleblowing System (WBS) mechanism. If based on the results of the investigation the violation of the code of ethics is proven, it will be subject to sanctions in accordance with BRI’s disciplinary violations.

CODE OF CONDUCT VIOLATIONS
During 2020 there were violations of the Code of Conduct committed by 51 BRI organic employees with the following details:

Sanction Category Total
Written Warning Letters 4
Written Reprimand 2
Demotion 1 6
Demotion 2 3
Work Termination 36
Total 51

The number of code of conduct violations based on settlement status is as follows:

Internal Violations Total Violations
BOC BOD Permanent Employee Contract Employee
2019 2020 2019 2020 2019 2020 2019 2020
Total - - - - 283 148 239 48
has been resolved - - - - 253 51 239 35
In an ongoing process - - - - 30 97 0 13