Bank BRI’s governance soft structure includes:

1. Articles of Association contained in Deed No. 3 dated March 9, 2021 as last amended by Deed No. No. 4th of October 6, 2021.
2. Joint Decree of the Board of Commissioners and Directors No. 06-KOM/BRI/12/2013 and Nokep: S.65-DIR/DKP/12/2013 dated December 16, 2013 concerning the BRI Code of Ethics.
3. Joint Decree of the Board of Commissioners and Directors No. 02-KOM/02/2020 and No. 01-DIR/KPT/02/2020 dated February 17, 2020 concerning the Good Corporate Governance Policy of PT Bank Rakyat Indonesia (Persero) Tbk.
4. Joint Decree of the Board of Commissioners and Directors No. 06-KOM/BRI/07/2015 and No. S.339-DIR/DKP/07/2015 dated July 28, 2015 concerning Guidelines for Integrated Governance of the Financial Conglomerate of PT Bank Rakyat Indonesia (Persero) Tbk.
5. Joint Decree of the Board of Commissioners and Directors No. 09-KOM/BRI/11/2017 and No. S.1023-DIR/KPS/11/2017 dated November 30, 2017 concerning the Remuneration Governance Policy of PT Bank Rakyat Indonesia (Persero) Tbk.
6. Decree of the Board of Commissioners No. 09-KOM/11/2018 dated November 1, 2018 concerning the Board of Commissioners Rules of Conduct.
7. Decree of the Board of Commissioners No. 11-KOM/11/2018 dated November 1, 2018 concerning Guidelines for Audit Committee Rules.
8. Decree of the Board of Commissioners No. 12-KOM/11/2018 dated November 1, 2018 concerning the Rules of Procedure of the Risk Management Monitoring Committee.
9. Decree of the Board of Commissioners No. 13-KOM/11/2018 dated November 1, 2018 concerning the Rules of Procedure for the Nomination and Remuneration Committee.
10. Decree of the Board of Commissioners No. 14-KOM/11/2018 dated November 1, 2018 concerning the Guidelines for the Integrated Governance Committee.
11. Board of Directors Decree Number KB.01-DIR/MAT/03/2020 dated March 31, 2020 concerning Policies for Fixed Assets and Logistics Management of PT Bank Rakyat Indonesia (Persero) Tbk.
12. Board of Directors Decree No. B.299-DIR/SKP/04/2020 dated April 24, 2020 concerning Stipulation of Guidelines and Work Procedures for Directors of PT Bank Rakyat Indonesia (Persero) Tbk.
13. Board of Directors Decree No. B.242-DIR/SKP/03/2020 dated March 30, 2020 regarding the Stipulation of Guidelines and Rules of Procedure for the Board of Directors Meeting of PT Bank Rakyat Indonesia (Persero) Tbk.
14. Board of Directors Decree Number 166-DIR/KPD/04/2022 dated April 19, 2021 concerning Corporate Governance Guidelines.
15. Board of Directors Decree No. B.1784-DIR/CSC/CSM/10/2022 dated October 31, 2022 regarding the Stipulation of Guidelines and Rules of Procedure for the Board of Directors Meeting of PT Bank Rakyat Indonesia (Persero) Tbk.
16. Board of Directors Circular No. SE.63-DIR/KEP/12/2020 dated December 8, 2020 concerning Provisions on Anti-Bribery and Gratification Control of PT Bank Rakyat Indonesia (Persero) Tbk.
17. Board of Directors Circular No. SE.65-DIR/KEP/10/2021 dated October 28, 2021 concerning the Whistleblowing System.
18. Board of Directors Circular No. SE.08.DIR/KEP/02/2022 dated February 17, 2022 concerning Implementation of the AntiMoney Laundering (APU) & Prevention of Terrorism Financing (PPT) Program.
19. Board of Directors Circular No. SE.11-DIR/KEP/03/2022 dated March 4, 2022 concerning Assessment of the Risk Level of Money Laundering and/or Terrorism Financing Crimes (TPPU and/or TPPT) Based on a Risk Based Approach.
20. Board of Directors Circular No. SE.27-DIR/KEP/04/2022 dated April 18, 2022 concerning Handling of Conflicts of Interest of PT Bank Rakyat Indonesia (Persero) Tbk.
21. Board of Directors Circular No. SE.28-DIR/KPD/05/2022 dated May 13, 2022 concerning Management of Policies and Procedures.
22. Board of Directors Circular No. SE. 38-DIR/PPM/06/2022 dated June 23, 2022 concerning Corporate Strategy (Book 2 RBB).
23. Board of Directors Circular No. SE.58-DIR/ORD/11/2022 datedNovember 22, 2022 concerning Guidelines for Implementing Operational Risk Management (Book 5 AntiFraud Strategy).
24. Standard Operating Procedure No. SO.79-KEP/12/2021 dated February 28, 2021 concerning Application of Anti-Money Laundering and Counter of Terrorism Financing (AML & CFT) in Operational Work Units.

Introduction

PT Bank Rakyat Indonesia (Persero) Tbk (BRI) is firmly committed to upholding integrity, transparency, and accountability in all aspects of its operations. This commitment is demonstrated under Circular Letter No. NOSE.09-DIR/KEP/03/2023 dated 31 December 2024 concerning Corporate Governance along with its amendment endorsed by Directors. The Circular letter reinforces the Bank’s zero-tolerance policy toward bribery and its dedication to ethical business conduct also implements good corporate governance through all BRI’s activities and set the policy toward Conflict of interest, whistleblowing system, Asset Declaration Report for State Officials, Anti-bribery and anti-corruption, Anti-Bribery Management System ISO 37001:2016, code of conducts, as well as good corporate governance.

BRI has taken necessary actions to prevent conflicts of interest by implementing clear policies and procedures that regulate employee conduct and decision-making. These measures are designed to ensure that all business activities are carried out objectively and free from personal interests that may influence professional judgment. Through periodical awareness programs, internal controls, disclosure mechanisms, and individual commitment BRI reinforces a culture of integrity and accountability across all levels of the organization.

Definition

Bribery is the act of offering, promising, giving, receiving, or soliciting any undue advantage of any value (whether financial or non-financial), either directly or indirectly, regardless of location, which constitutes a violation of laws and regulations, as an inducement or reward for a person to perform or refrain from performing an act in relation to the performance of their duties.

Conflict of Interest refers to a situation where there is a divergence between the economic interests of the company and the personal economic interests of members of the Board of Directors, members of the Board of Commissioners, major shareholders, or controlling parties — including, but not limited to, any employee — that may potentially harm the company

Corruption is defined as any unlawful act committed by a person to enrich themselves, another individual, or a corporation, which may cause losses to the state’s finances or economy. This definition is in accordance with Law No. 31 of 1999 concerning the Eradication of Corruption Crimes.

Gratification refers to any form of gift or benefit in a broad sense, including the provision of money, goods, discounts, commissions, interest-free loans, travel tickets, accommodation facilities, leisure trips, free medical treatment, and other facilities—whether received domestically or abroad, and whether conducted through electronic means or otherwise. Any form of gratification shall be considered a bribe if it is related to the recipient’s official duties and is contrary to their obligations or responsibilities.

Leadership and Commitment

BRI affirms its unwavering commitment to uphold standards of integrity, ethics, and good governance across all levels of the organization. The Board of Commissioners, Board of Directors, SEVP, and all employees consistently commit to:

1. Reject, prevent, and avoid any actions that violate or contradict their duties and authority under the Company’s Articles of Association or applicable laws and regulations that may harm the Company.
2. Adhere to the highest standards of ethical and moral conduct by demonstrating fairness, transparency, consistency, honesty, and integrity in all actions and decisions.
3. Enforce a zero-tolerance policy toward all forms of fraud—both internal and external — including bribery and gratification. Any individual found to have engaged in fraudulent activities shall be held fully accountable and subject to disciplinary action and legal sanctions in accordance with applicable laws and regulations.
4. Foster a work environment free from Corruption, Collusion, and Nepotism in any form, by any individual, company, or institution related to the execution of their duties.
5. Instruct all BRILiaN personnel to consistently apply the Code of Conduct, principles of Good Corporate Governance (GCG), risk awareness, compliance culture, anti-bribery management, and internal controls in all aspects of their work.

This commitment is formalized through an Integrity Pact signed annually by the Board of Commissioners and Board of Directors, as well as by all business unit leaders and employees.

Risk Management

BRI identifies and assesses risks and opportunities related to the implementation of the AntiBribery Management System as part of its commitment to continuously improving business processes. This process is documented through the Bribery Risk Assessment Form, which outlines how risks are controlled to minimize their likelihood and potential impact, while ensuring that opportunities are managed to maximize positive outcomes. The identification of risks and opportunities aims to ensure the effectiveness of the Anti-Bribery Management System, increase the likelihood of achieving desired outcomes, reduce potential adverse impacts, and support ongoing improvement.

Each business unit, as the designated risk owner, is responsible for identifying bribery-related risks and opportunities and for planning appropriate controls. The results of these controls are then submitted to the Anti-Bribery Compliance Function, which verifies the timeliness and effectiveness of their implementation in accordance with the applicable scope and internal guidelines.

Anti-Bribery Policy

BRI has established, maintained, and continuously reviewed its Anti-Bribery Policy under the supervision of the Board of Commissioners and the Board of Directors. The policy reflects the Company’s adherence to the Anti-Bribery Management System and promotes awareness among employees to report any violations in good faith or based on reasonable belief, without fear of retaliation. It also emphasizes continuous improvement and outlines the authority and independence of the Anti-Bribery Compliance Function, including consequences for noncompliance.

Anti-Corruption Policy

Aligned with the Company’s core value of Amanah, which emphasizes integrity, honesty, sincerity, and regulatory compliance, BRI’s Anti-corruption policy ensures our stance of anti-corruption, collusion, and nepotism. It prohibits the solicitation, acceptance, or offering of unauthorized gratification, mandates avoidance of conflicts of interest, and requires all violations to be reported through established company mechanisms.

Charitable contributions, gifts, hospitality and Comparable Advantages Guideline

BRI is firmly committed to maintaining the highest standards of integrity and transparency by prohibiting the giving or receiving of charitable contributions (donations), gifts, hospitality and Comparable Advantages Guideline intended to influence decisions or provide unfair advantage. This principle is embedded in the company’s Code of Conducts, Anti-Bribery and Gratification Control Policy, and further supported by regulations governing the Environmental Development Program and Sponsorship Funding. These frameworks align with Indonesia’s Corruption Eradication Commission (KPK) Circular No. 19 of 2021 on Gratification Control in the Financial Services Industry and clearly define acceptable practices, including the reporting and handling of excluded gratifications.

Prohibition of Involvement in Political Activities

BRI personnel are required to refrain from using their time, funds, or personal resources to support or participate in any form of political activity, in accordance with applicable corporate policies and regulations. This includes participating in the election of legislative or executive candidates, becoming members of political parties, or engaging with organizations or individuals that aim to support political parties or candidates. Additionally, they are prohibited from taking part in political campaigns, fundraising efforts for political causes, or any activities intended to support political participation. Engagement in political party activities or other similar endeavors is strictly prohibited to maintain the integrity and neutrality of the institution.

Support

BRI provides the necessary resources to implement, maintain, and improve the Anti-Bribery Management System. These resources include people, infrastructure, work environment, and knowledge—sourced internally or externally as needed. It also ensures that the Anti-Bribery Compliance Function has the required support, including budget, infrastructure, and qualified staff, to carry out its duties effectively.

Communication and Training

To enhance awareness of Anti-Bribery and Anti-Corruption within the company, these principles are incorporated into the Company’s Code of Conducts and the BRILiaN Employee Code of Conduct. To support ongoing understanding, BRI conducts periodical education and awareness programs each year through both in-person sessions and/or e-learning. These efforts help ensure that all employees review and sign the annual Anti-Bribery and Anti-Corruption commitment. Furthermore, to enhance transparency, all employees are required to sign the Code of Conduct and declare any potential conflicts of interest through the completion of an annual conflict of interest disclosure.

Performance Evaluation

As part of the performance evalation of good corporate governance, BRI has set an internal and/or external control for the policy. This includes the identification and assessment of significant risks, the enforcement of effective control mechanisms, the application of appropriate segregation of duties across the organization and all aspects of Anti-bribery Management system.

As part of the Company’s commitment to strengthening corporate governance, regular reviews of the Anti-Bribery Management System implementation are conducted by Senior Management, the Steering Committee, and the Anti-Bribery Compliance Function. These reviews aim to ensure the effectiveness of the system, alignment with established policies and objectives, adequacy of resources, and proper handling of potential violations. All evaluation processes are duly documented as a reflection of the Company’s commitment to integrity and compliance.

Investigation and Handling Guidelines

BRI promotes anti-bribery awareness by encouraging employees to report any suspected or actual bribery in good faith through the Whistleblowing System (WBS), which ensures confidentiality and protection for whistleblowers. All reports, whether involving internal or external parties, are handled according to established procedures. Investigations are conducted by the Investigation Unit in line with the Anti-Fraud Strategy and WBS policies. Proven cases of bribery result in appropriate sanctions, and outcomes are reported to the Anti-Bribery Compliance Function and escalated to Senior Management and the Steering Committee.

To demonstrate its commitment to complaint handling, the management of the Whistleblowing System (WBS) is carried out by an independent party. The Policy is communicated across the organization and relevant stakeholders. This effort aims to uphold a clean and corruption-free corporate environment and is subject to ongoing review to ensure alignment with BRI’s ethical commitments.

Punishment

Any violation of this commitment shall be subject to sanctions in accordance with prevailing laws and regulations.

Continual Improvement

Corrective actions are carried out to eliminate the causes of nonconformities and to prevent their recurrence. This includes taking necessary control and remedial measures, as well as addressing any consequences resulting from the nonconformity. The process involves evaluating actions needed to eliminate the root causes by reviewing and analyzing the nonconformity and assessing the likelihood of recurrence. All documented evidence related to corrective actions must be properly maintained.

BRI identifies and pursues opportunities for improvement that include strengthening the control measures within its Anti-Bribery Management System in line with applicable regulations, mitigating or preventing potential adverse impacts, and enhancing the overall performance and effectiveness of the system across the organization.

The procurement of good and services carried out by BRI aims to support bank operations and business performance in general. In an effort to provide the best service and heed the principles of Good Corporate Governance, BRI is determined to create a process of procurement of goods and services that is safe, effective and efficient.

The General Policy of Fixed Asset and Logistic Management (KEMAL) is a guideline in carrying out the process of Procurement of goods and services to support the Bank’s operational activities in accordance with the quality, quantity and time set at the best price while still observing Good Corporate Governance principles.

The objectives of the compilation of KEMAL BRI are:

1. As a guideline in managing fixed assets and quality logistics services for all BRI work units.
2. As a guideline in the process of procurement of goods and services at BRI so that the procurement process at BRI.

Principle of Good and Services Procurement

1. Efficient
   Procurement of goods and / or services must be endeavored to obtain optimal and best results in a short time by using the funds and the minimum capacity to be reasonable and not only based on the lowest price.
2. Effective
   Procurement of goods and / or services must be in accordance with predetermined needs and provide maximum benefits according to the targets set.
3. Competitive
   Procurement of goods and / or services must be open to providers of goods and / or services that meet the requirements and carried out through fair competition among providers of goods and / or services that areequal and meet certain requirements / criteria based on clear and transparent provisions and procedures.
4. Transparent
   All provision and information regarding the procurement of goods and / or services, including technical requirements for procurement administration, evaluation procedures, evaluation results, determination of prospective providers of goods and / or services, are open to participants who are interested in providing goods and / or services.
5. Fair and equal
   Provide equal treatment for all prospective suppliers of goods and services that meet the requirements.
6. Accountable
   Must achieve goals and be accountable so as to keep away from potential abuse and irregularities.

Good and Service Procurement Procedure

The stages of implementing the procurement of goods and services at BRI are carried out as follows:

1. In order to support operational activities, BRI requires adequate facilities and infrastructure to achieve the Company’s objectives. A procurement process is required to fulfill facilities, infrastructure and infrastructure.
2. In each implementation of the procurement process, it is necessary to determine the Self Estimated Price as one of the bases in determining the method of procurement. In 2017 an Estimation Group was formed, namely an independent work unit that has the duties and responsibilities in preparing and stipulating the HPS for the procurement of goods and / or services at BRI.
3. The procurement process can be carried out with several methods, including Swakelola, direct purchase, direct appointment, direct election and open auction.
4. In the procurement process an evaluation of the offer submitted by the prospective Provider of Goods / Services will be carried out to obtain the best quality and price.
5. In order to obtain conformity between the needs of BRI and the bids submitted by prospective suppliers of goods / services, Clarification and Negotiation will be carried out in the procurement process until the winner of the goods / service provider is determined.
6. If a winner has been determined, BRI provides a refutation time if there are parties who object to the procurement process that has been carried out or to the winner’s determination. This is done by BRI in order to realize the process of procurement of goods and services that meet the rules of Good Corporate Governance.

Partner Management

The stages of implementing the procurement of goods and services at BRI are carried out as follows:

1. Providers of good and/or services which will participate in the procurement of good and / or services in BRI need to have a BRI Registration Certificate (TDR). TDR (Partner Register) is a statement in the format of a certificate or letter explaining that the provider of good / services is listed therein has been registered as a BRI Partner, as a condition for participating in the procurement of good / services at BRI.
2. BRI has a list of suppliers of good/ services that can be used in the process of procuring goods/services at BRI. The list of partners is obtained from the selection of qualifications and requirements determined by BRI. Supplier selection process to consider the legality of the company (not limited to Hinderordonnantie (HO), Environmental impact assessment /AMDAL), the financial aspects, (the company's financial statements) and non-financial, among others related to labor and human factors. The partner selection process is carried out transparently and applies the GCG principles.
3. The requirements set for the partners of BRI has been done in accordance pinsip procurement such as:
   1. Have a valid business legality
   2. Financial performance report partner in both categories
   3. Having the experience of the field work to be done.
4. Partner Management Application. BRI has developed application management TDR (Associate Registration) that is integrated with BRISMILE starting from partner registration conducted independently by vendors (via BRI intranet), legality and vendor business evaluation process to issuance of BRI Partner Signs (BRI TDR) by BRI.

As a public company with more than 40% public ownership of its shares, PT Bank Rakyat Indonesia (Persero) Tbk is committed to carrying out its tax obligations following applicable regulations.

Key Tax Principle

In accordance with the provisions of the applicable tax laws, BRI consistently applies tax principles to its tax management implementation.

1) Compliance with tax laws and regulations in different jurisdictions

In their operational activities, BRI and its overseas branch offices have implemented good corporate governance that is carried out transparently and accountably, especially in managing their tax rights and obligations following the provisions of the applicable tax laws in each country.

On May 18, 2020, the Government issued Law Number 2 of 2020 concerning Enactment of Government Regulation in Lieu of Law Number 1 of 2020 concerning State Financial Policy and Financial System Stability For The Handling Of COVID-19 Pandemic and/or in the Framework of Dealing with Threats Endangering the National Economy and/or Financial System Stability Becomes Law, and enact Government Regulation No. 30 of 2020 concerning Reduction of Income Tax Rates for Domestic Entity Taxpayers in the Form of a Public Company and effective from the date of promulgation, namely on June 19, 2020. Furthermore, on October 29, 2021, the Government issued Law of the Republic of Indonesia Number 7 of 2021 concerning Harmonization of Tax Regulations.

The regulation has stipulated, among other things, a reduction in the income tax rate for domestic corporate taxpayers and permanent establishments from previously 25% to 22% for the fiscal years 2020, 2021, and 2022 onwards, as well as a further reduction in the tax rate of 3%, for domestic taxpayers who meet specific requirements such as a publicly listed company that satisfy a minimum listing requirement of 40% and certain other conditions.

Bank BRI has met the requirements to get an incentive to reduce the tax rate by 3% based on the provisions of Article 5 paragraph (2) of Law No. 2 of 2020 so that for 2021 Bank BRI will use a tax rate of 19% in the calculation of Corporate Income Tax.

2) Tax Risk Management and Information Disclosure

Tax-related policies and their implementation are approved and reviewed by the Director of Finance in reporting the Annual Corporate Income Tax Return. The Director of Finance reviews the strategy and performance of this tax obligation annually. Bank BRI always strives to comply with applicable tax regulations.