PT. Bank Rakyat Indonesia (Persero) Tbk. - Investor Relations: ASEAN Corporate Governance Scorecard

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Part A - Rights and Equitable Treatment of Shareholders

Part	Item	Practice	Source of Information
A.1	Basic Shareholder Rights
A.1.1	Does the company pay (interim and final/annual) dividends in an equitable and timely manner; that is, all shareholders are treated equally and paid within 30 days after being (i) declared for interim dividends and (ii) approved by shareholders at general meetings for final dividends? In case the company has offered Scrip dividend, did the company paid the dividend within 60 days.	Website https://www.ir-bri.com/dividend.html IR News https://www.ir-bri.com/news.html/id/2471594	Interim Dividends: In 2024, BBRI declared and paid an interim dividend, which was disclosed on December 16, 2024, and completed payment on January 15, 2025. Within thirty days of receiving the dividend payment, BBRI has satisfied the ACGS Criteria. Final Dividend Following BRI's Annual General Meeting Shareholders result, which was held on March 24, 2025, BBRI announced would distribute a final dividend. The final dividend had been transfered to shareholders on April 23, 2025. Based on that announcement, Final dividend payment has fulfilled ACGS Criteria within 30 Days. Script dividend: Bank BRI didn’t distribute script dividend.
A.2	Right to participate effectively in and vote in general shareholder meetings and should be informed of the rules, including voting procedures, that govern general shareholder meetings.
A.2.1	Do shareholders have the opportunity, evidenced by an agenda item, to approve remuneration (fees, allowances, benefit-in-kind and other emoluments) or any increases in remuneration for the non-executive directors/commissioners?	Article of Association Article 5 https://www.ir-bri.com/misc/Articles_of_Association.pdf#page=34 Summary of Minutes AGMS https://www.ir-bri.com/misc/NL/2025/MoM-AGMS-2025-EN.pdf	Shareholders have the right to effectively participate in AGMs as outlined in the company's articles of association. This includes the approval of agendas requiring their consent. In AGMS 2025, chairperson of AGMS has gave the opportunity for shareholders to approve each agenda including Determination of remuneration of member of the Board of Director and honorarium of member of the Board of Commissioners for the financial year of 2024.
A.2.2	Does the company provide non-controlling shareholders a right to nominate candidates for board of directors/commissioners?	Article of Association Article 5 https://www.ir-bri.com/misc/Articles_of_Association.pdf#page=34 Article of Association Article 23,section 6 https://www.ir-bri.com/misc/Articles_of_Association.pdf#page=126 Article of Association Article 25 https://www.ir-bri.com/misc/Articles_of_Association.pdf#page=138	BRI, as a state-owned enterprise (SOE) by the Republic of Indonesia, issued two types of shares: Series A Dwiwarna shares and Series B Shares. Series A Dwiwarna shares are issued and owned by the Government of the Republic of Indonesia and can not be transferred to any parties; on the other hand, Series B Shares are issued and owned by the Public. Based on Articles of Association Article 25.4 if GMS willingly to make the changes for BOC or BOD, then GMS shall be attended by Series A Dwiwarna shareholders and other shareholders who represent more than ½ (a half) from total shares with valid voting rights and the resolution is aproved by the shareholders of series A Dwiwarna and other shareholders who together represent more than ½ (a half) from total shares by voting present at GMS It is identified in Article of Association art 22.6.b and Announcement of GMS published in Bank’s Website: 1 (one) or more representing 1/20 (one twentieth) or more of the total shares that have been issued by the Company with valid voting rights have the rights to propose agenda for the meeting.
A.2.3	Does the company allow shareholders to elect directors/commissioners individually?	Summary Minutes of Meeting https://www.ir-bri.com/misc/NL/2025/MoM-AGMS-2025-EN.pdf	Shareholders Series A and B have the opportunity to elect candidates’ members of BOD and/or BOC at GMS. The rule was published 28 February 2025 through Bank’s website. Election of BOD/BOC candicate is included in 10th agenda that voted by shareholders. The announcement of the resolutions of 2025 AMS was published on 25 March 2025 through Bank’s website.
A.2.4	Does the company disclose the voting procedures used before the start of meeting?	GMS Voting Mechanisms https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=483 AGMS Meeting Materials https://www.ir-bri.com/misc/NL/2025/Meeting-Materials-AGMS.pdf	The voting procedures were disclosed in Invitation and code of conduct AGMS 2025. Furthermore, before the start of the AGMS, the rule was distributed to the Shareholders and The AGMS Chairman was red the rule of GMS.
A.2.5	Do the minutes of the most recent AGM record that the shareholders were given the opportunity to ask questions and the questions raised by shareholders and answers given recorded?	Summary Minutes of Meeting https://www.ir-bri.com/misc/NL/2025/MoM-AGMS-2025-EN.pdf#page=15	The question raised by shareholders and answer given was recorded in summary minutes of 2025 AGMS.
A.2.6	Does the company disclose the voting results including approving, dissenting, and abstaining votes for all resolutions/each agenda item for the most recent AGM?	Summary Minutes of Meeting https://www.ir-bri.com/misc/NL/2025/MoM-AGMS-2025-EN.pdf#page=3	BRI disclose the voting results including approving, dissenting, and abstain for all resolutions (each agenda item) for 2025 AGMS
A.2.7	Does the company disclose the list of board members who attended the most recent AGM?	Summary Minutes of Meeting https://www.ir-bri.com/misc/NL/2025/MoM-AGMS-2025-EN.pdf#page=2	Summary Minutes of 2025 AGMS recorded and disclosed list of attendance of BOD,BOC and Audit Committee.
A.2.8	Does the company disclose that all board members and the CEO (if he is not a board member) attended the most recent AGM?	Summary Minutes of Meeting https://www.ir-bri.com/misc/NL/2025/MoM-AGMS-2025-EN.pdf#page=2	All members of BOD, BOC and Audit Committee attended the 2025 AGMS.
A.2.9	Does the company allow voting in absentia?	Attendance of Shareholders and Other Parties at the GMS https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=483 Available Proxy document in corporate website https://www.ir-bri.com/misc/NL/2025/Surat-Kuasa-POA.pdf	Company has voting procedure which allow the shareholders to conduct voting in absentia by providing the proxy via eASY KSEI. The procedure also disclosed in the Notice and Code of Conduct 2025 AGMS.
A.2.10	Did the company vote by poll (as opposed to by show of hands) for all resolutions at the most recent AGM?	Summary Minutes of Meeting https://www.ir-bri.com/misc/NL/2025/MoM-AGMS-2025-EN.pdf#page=3	BRI used vote by poll for all resolutions at the 2025 AGMS.
A.2.11	Does the company disclose that it has appointed an independent party (scrutineers/inspectors) to count and/or validate the votes at the AGM?	Summary Minutes of Meeting https://www.ir-bri.com/misc/NL/2025/MoM-AGMS-2025-EN.pdf	Based on Summary minutes of 2025 AGMS BRI disclosed the appoinment of an independent party to count and/or validate the votes at the AGMS. The counting of votes as the basis of Meeting resolution is conducted by PT Datindo Entrycom as the Share Registrar and the validation is executed by Fathiah Helmi, S.H., Notary in Jakarta.
A.2.12	Does the company make publicly available by the next working day the result of the votes taken during the most recent AGM/EGM for all resolutions?	Summary Minutes of Meeting https://www.ir-bri.com/misc/NL/2025/MoM-AGMS-2025-EN.pdf	BRI makes publicly available the result of the AGMS by next working day through the company’s website. AGMS held on Monday, March 24th, 2025, and Summary Minutes of AGMS available on Tuesday, March 25th 2025.
A.2.13	Does the company provide at least 21 days notice for all AGMs and EGMs?	Invitation of AGMS https://www.ir-bri.com/misc/NL/2025/Pemanggilan-RUPS-EN.pdf	BRI provided 23 days notice for 2025 AGM. Notice was published on February 28th, 2025, and AGM held on March 25th 2025.
A.2.14	Does the company provide the rationale and explanation for each agenda item which require shareholders' approval in the notice of AGM/circulars and/or the accompanying statement?	Invitation of AGMS https://www.ir-bri.com/misc/NL/2025/Pemanggilan-RUPS-EN.pdf	BRI provided the rationale and explanation for each agenda item which require shareholders' approval in the notice of AGM / circulars and accompanying statement.
A.2.15	Does the company give the opportunity for shareholders to place item/s on the agenda of general meetings and/or to request for general meetings subject to a certain percentage?	Article of Association, Article 22 section 6b https://www.ir-bri.com/misc/Articles_of_Association.pdf#page=126	It is identified in Article of Association art 22.6.b and Announcement of GMS published in Bank’s Website: 1 (one) or more representing 1/20 (one twentieth) or more of the total shares that have been issued by the Company with valid voting rights have rights to propose the agenda for the meeting.
A.3	Markets for corporate control should be allowed to function in an efficient and transparent manner.
A.3.1	In cases of mergers, acquisitions and/or takeovers requiring shareholders' approval, does the board of directors/commissioners of the company appoint an independent party to evaluate the fairness of the transaction price?	-	There is no transaction such as merger, acquisition and takeover requiring shareholders' approval.
A.4	The exercise of ownership rights by all shareholders, including institutional investors, should be facilitated.
A.4.1	Does the company disclose its practices to encourage shareholders to engage with the company beyond General Meeting?	IR Website https://www.ir-bri.com/ Annual Report 2024 page 771 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=773	In addition to the GMS, Investor Relations also communicates the bank’s activities to stakeholders, particularly existing investors and capital market participants (regulators, investors, debenture holders, analysts, and rating agencies). Relevant information is shared with an emphasis on transparency to support investors in making effective decisions and aligning their perceptions and expectations regarding the bank’s strategy, performance, and financial condition
A.5	Shares and voting rights
A.5.1	Where the company has more than one class of shares, does the company publicise the voting rights attached to each class of shares (e.g. through the company website / reports/ the stock exchange/ the regulator's website)?	Article of Association Article 5 https://www.ir-bri.com/misc/Articles_of_Association.pdf#page=34	BRI has more than one class of shares with explanation of each characteristic and right. Shares of the Company are shares on behalf of and issued to the owner registered in the Register of Shareholders consisting of: Series A Dwiwarna shares which only can be owned by the State of the Republic of Indonesia and Series B shares that can be owned by Public. In terms of voting, Series A Dwiwarna shareholders and Series B shareholders have the same rights, and every 1 (one) share gives 1 (one) voting rights.
A.6	Notice of AGM should contain following details
A.6.1	Does each resolution in the most recent AGM deal with only one item, i.e., there is no bundling of several items into the same resolution?	Invitation of AGMS https://www.ir-bri.com/misc/NL/2025/Pemanggilan-RUPS-EN.pdf Summary Minutes of Meeting https://www.ir-bri.com/misc/NL/2025/MoM-AGMS-2025-EN.pdf	Each resolution in 2025 AGMS only deals with only one item and there is no bundling of several items into the same resolution.
A.6.2	Are the company's notice of the most recent AGM/circulars fully translated into English and published on the same date as the local-language version?	Invitation of AGMS https://www.ir-bri.com/misc/NL/2025/Pemanggilan-RUPS-EN.pdf	Notice of 2025 AGMS is fully translated into English and published on the same date as the local language version. Both were published on February 28th 2025
A.6.3	Are the profiles of directors/commissioners (at least age, academic qualification, date of appointment, experience, and directorships in other listed companies) in seeking election/re-election included?	Invitation of AGMS https://www.ir-bri.com/misc/NL/2025/Pemanggilan-RUPS-EN.pdf Summary Minutes of Meeting https://www.ir-bri.com/misc/NL/2025/MoM-AGMS-2025-EN.pdf	Profile of prospective member of Board of Commissioners and Board of Directors shall be presented during performance to AGMS
A.6.4	Are the auditors seeking appointment/re-appointment clearly identified?	AGMS Meeting Materials https://www.ir-bri.com/misc/NL/2025/Meeting-Materials-AGMS.pdf Accounting Firm profile https://www.ir-bri.com/misc/NL/2025/Profil-KAP-RUPST-2025.pdf	The auditor seeking appointment / re-appointment is clearly identified in the 2025 AGMS Meeting Material (published on the same date as notice of AGMS). As mentioned on 2025 AGMS Meeting Material about agenda 4th (appointment of Public Accountant and/or Public Accountant Firm to perform audit), GMS appointed Purwantono, Sungkoro & Surja (a member Firm of Ernst and Young Global Limited) as KAP which shall audit Company’s Consolidated Financial Statements and Financial Report of Partnership Program and Community Development Program for Financial Year of 2025.
A.6.5	Were the proxy documents made easily available?	Available Proxy document in corporate website https://www.ir-bri.com/misc/NL/2025/Surat-Kuasa-POA.pdf	Proxy documents/Power of Attorney Form (Both Indonesia & English versions) were available at the Share Administration Berau or download it from Company’s website.
A.7	Insider trading and abusive self-dealing should be prohibited.
A.7.1	Are the directors / commissioners required to report their dealings in company shares within 3 business days?	Annual Report 2024 page 571 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=573	There is disclosure of policy regarding the requirement for directors / commissioners to report their dealings in company shares within 3 business days. Share transactions carried out by BRI Board of Directors and Commissioners throughout 2024 has been reported to the Company within 3 (three) working days after the completion of transaction and further reported to the Financial Services Authority.
A.8	Related party transactions by directors and key executives.
A.8.1	Does the company have a policy requiring a committee of independent directors/commissioners to review material RPTs to determine whether they are in the best interests of the company and shareholders?	Duties and Responsibilities of Risk Management Monitoring Committee https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=618	BRI has a policy requiring a committee of independent directors/commissioners to review material RPTs. Risk Management Monitoring Committee has the duty and responsibility to evaluate and analyse the package proposals of the Board of Directors for funding to related parties that must be approved by the Board of Commissioners. Funding Mechanisms to Related parties are as follow: Funding to Related Parties are submitted independently or collectively through the Credit Operations Division (OPK) and must obtain the approval of the Board of Commissioners. Funding to Related Parties must be reviewed in advance by BRI Independent Committee prior to requesting approval from the Board of Commissioners. Funding (specifically for credit) to the Board of Directors and Board of Commissioners must be carried out fairly and with equal treatment
A.8.2	Does the company have a policy requiring board members (directors/commissioners) to abstain from participating in the board discussion on a particular agenda when they are conflicted?	Articles of Association, Article 13 Section 21 & 22 https://www.ir-bri.com/misc/Articles_of_Association.pdf#page=34 Board of Directors Conflict of Interest Management https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=502 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=525	Any member of the Board of Directors who personally, in any way, directly or indirectly, has an interest in a proposed transaction, contract or contract in which the company becomes one of his parties shall be declared the nature of interest in Board of Directors Meeting and therefore not has the right to participate in voting on matters relating to the transaction or contract. Each member of the Board of Commissioners who personally in any way, directly or indirectly, has an interest in a proposed transaction, contract or contract in which the Company is one of its parties, shall be declared the nature of interest in a Board of Commissioners Meeting and is not entitled to participate in voting on matters relating to the transaction or contract.
A.8.3	Does the company have policies on loans to directors and commissioners either forbidding this practice or ensuring that they are being conducted at arm's length basis and at market rates?	Policy of Giving Loan to the Board of Directors and Board of Commissioners https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=422	BRI has policies on loans to directors and commissioners to ensure that they are being conducted at market rates. Credit Policy to the Board of Directors and Board of Commissioners: Lending to the Board of Directors and Commissioners is included in the provision to Related Parties, and this must be approved by the Board of Commissioners. Funding to Related Parties has been regulated by the Financial Services Authority and the Company’s rules, which is BRI Legal Lending Limit.
A.9	Protecting minority shareholders from abusive actions
A.9.1	Does the company disclose that RPTs are conducted in such a way to ensure that they are fair and at arms' length?	Provision of Funds to Related Parties and Large Amount of Funds Mechanism for Provision of Funds to Related Parties Provision of Funds To Related Parties https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=422	BRI has a policy requiring a committee of independent directors/commissioners to review material RPTs. Risk Management Monitoring Committee has the duty and responsibility to evaluate and analyse the package proposals of the Board of Directors for funding to related parties that must be approved by the Board of Commissioners. Funding Mechanisms to Related parties are as follow: Funding to Related Parties are submitted independently or collectively through the Credit Operations Division (OPK) and must obtain the approval of the Board of Commissioners. Funding to Related Parties must be reviewed in advance by BRI Independent Committee prior to requesting approval from the Board of Commissioners. Funding (specifically for credit) to the Board of Directors and Board of Commissioners must be carried out fairly and with equal treatment
A.9.2	In case of related party transactions requiring shareholders' approval, is the decision made by disinterested shareholders?	RPT Mechanism & Evaluation - AR 2024 page 788 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=790	There is no RPTs requiring shareholders' approval in 2024 BRI disclose that all funding to related parties has been evaluated according to rules. During 2024, Risk Management Monitoring Committee reviewed 2 funding approval to related parties. The output can be found on Risk Management Monitoring Committee Work Plan & Budget 2024 realization.

Part B - Sustainability and Resilience

Part	Item	Practice	Source of Information
B.1	Sustainability-related disclosure should be consistent, comparable and reliable, and include retrospective and forward-looking material information that a reasonable investor would consider important in making an investment or voting decision
	Material Sustainability-related information should be specified
B.1.1	Does the company identify/report ESG topics that are material to the organization’s strategy?	Materiality Assessment https://www.ir-bri.com/misc/SR/SR-2024-EN.pdf#page=22	BRI identified & disclosed ESG topics that are material to the organisation strategy into several topics including climate change, communities interaction and corporate governance.
B.1.2	Does the company identify climate change as an issue?	Climate Change Poses Risk But Also Creates Opportunity https://www.ir-bri.com/misc/SR/SR-2024-EN.pdf#page=31	BRI disclose Climate Change Governance, implement the strategy and how to manage with risk management.
B.1.3	Does the company adopt an internationally recognized reporting framework or standard for sustainability (i.e. GRI, Integrated Reporting, SASB, IFRS Sustainability Disclosure Standards)?	Reporting Standards Index ( GRI Standard Index) SR 2024 page 230-236 https://www.ir-bri.com/misc/SR/SR-2024-EN.pdf#page=230-236 Indonesia Financial Services Authority (OJK) Reference SR Page 237-240 https://www.ir-bri.com/misc/SR/SR-2024-EN.pdf#page=237-240 Reporting Standards Index (SASB) SR 2024 Page 240-241 https://www.ir-bri.com/misc/SR/SR-2024-EN.pdf#page=240-241 Reporting Banking Assessment (SUSBA) SR 2024 Page 241 https://www.ir-bri.com/misc/SR/SR-2024-EN.pdf#page=241	BRI’s Sustainability Report comply with Indonesia Financial Services Authority Regulation (OJK) refer to POJK No. 51/POJK.03/2017 regarding the Implementation of Sustainable Finance and the Preparation of Sustainability Reports. Furthermore, BRI’s Sustainability Report also prepared in reference to several frameworks and standards such as Global Reporting Initiative (GRI), SASB, SUSBA,
	If a company publicly sets a sustainability-related goal or target, the disclosure framework should provide that reliable metrics are regularly disclosed in an easily accessible form
B.1.4	Does the company disclose quantitative sustainability target?	Scope 1 & 2 (Operational Emissions) SR 2024 Page 51 https://www.ir-bri.com/misc/SR/SR-2024-EN.pdf#page=51 Scope 3 (Financed Emissions) SR 2024 Page 51 https://www.ir-bri.com/misc/SR/SR-2024-EN.pdf#page=51	BRI disclose short term target in 2030 that scope 1 & 2 emissions decrease 42% from base year (2022)
B.1.5	Does the company disclose sustainability-related performance progress in relation to its previously set targets?	Scope 1 & 2 (Operational Emissions) SR 2024 Page 51 https://www.ir-bri.com/misc/SR/SR-2024-EN.pdf#page=51 Scope 3 (Financed Emissions) SR 2024 Page 51 https://www.ir-bri.com/misc/SR/SR-2024-EN.pdf#page=51	BRI discloseshort term target in 2030 that scope 1 & 2 emissions decrease 42% from base year (2022)
B.1.6	Does the company confirm that its Sustainability Report / Reporting is reviewed and /or approved by the Board or Board Committee?	President Commissioner Statement in SR 2024-page 5-7 https://www.ir-bri.com/misc/SR/SR-2024-EN.pdf#page=5-6 President Director in SR 2024-page7-8 https://www.ir-bri.com/misc/SR/SR-2024-EN.pdf#page=7-8 Reporting Mechanism and Assurance https://www.ir-bri.com/misc/SR/SR-2024-EN.pdf#page=4	BRI sustainability report is reviewed and approved by the BOD and BOC. The Bank's Board of Directors receives a periodic presentation of its sustainability performance report from the ESG Committee. In addition, 2024 Sustainability Report contains statement signed by President Director and President Commissioner
B.2	Corporate governance frameworks should allow for dialogue between a company, its shareholders and stakeholders to exchange views on sustainability matters
B.2.1	Does the company engage internal stakeholders to exchange views and gather feedback on sustainability matters that are material to the business of the company?	Materiality & Stakeholder Engagement https://www.ir-bri.com/misc/SR/SR-2024-EN.pdf#page=20	BRI recognizes that sustainability-related opportunities and risks are inherently linked to its business operations with direct and indirect stakeholders across the supply chain, value chain, and broader environmental landscape. These dynamics present a complex array of interconnected risks and opportunities. To effectively navigate these challenges, BRI implements a robust and integrated risk management framework. A comprehensive discussion on this approach is available in the Risk Management section of this report
B.2.2	Does the company engage external stakeholders to exchange views and gather feedback on sustainability matters that are material to the business of the company?	Materiality & Stakeholder Engagement https://www.ir-bri.com/misc/SR/SR-2024-EN.pdf#page=21	As a financial institution, BRI recognizes its broad impact on various aspects of life and a wide range of stakeholders, However, BRI categorizes stakeholders into 2 parts, Internal Stakeholders (Employees) and External Stakeholders (Customers, Investors, Regulators and Suppliers) as the main stakeholders based on their business relevance, commitment to diversity, willingness to participate, and reciprocal impact on BRI. By prioritizing these key stakeholders, BRI fosters collaboration and support, ensuring their engagement is integrated into its overall ESG management activities, including the materiality determination process.
B.3	The corporate governance framework should ensure that boards adequately consider material sustainability risks and opportunities when fulfilling their key functions in reviewing, monitoring and guiding governance practices, disclosure, strategy, risk management and internal control systems, including with respect to climate-related physical and transition risks
B.3.1	Does the company disclose that the board reviews on an annual basis that the company's capital and debt structure is compatible with its strategic goals and its associated risk appetite?	Capital Structure AR 2024-page 310 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=312	The management of capital structure aims to ensure that BRI consistently maintains adequate capital to cover inherent risks in managing its business while optimizing value for shareholders. BRI has established the ALCO Committee as a supporting body for the Board of Directors to periodically review BRI’s capital structure. The ALCO Committee is also responsible for determining strategies and policies for managing BRI’s assets and liabilities to achieve optimal results while considering potential risks, optimum yield generation, and cost efficiency. Additionally, BRI has the KCI Committee as a supporting body to review corporate actions and activities related to the management of subsidiaries, ensuring optimal capital management for BRI.
B.4	The corporate governance framework should recognise the rights of stakeholders established by law or through mutual agreements and encourage active co-operation between corporations and stakeholders in creating wealth, jobs, and the sustainability of financially sound enterprises.
B.4.1	The existence and scope of the company's efforts to address customers' welfare?	Protection of Customer Rights and Provision of Inclusive and Equal Services https://www.ir-bri.com/misc/SR/SR-2024-EN.pdf#page=63	BRI is committed to ensuring equal access for all customers while safeguarding consumer rights through inclusive services, transparent information, and data protection measures. Special services are provided for individuals with disabilities and the elderly, so they can make informed decisions regarding BRI’s products and services
B.4.2	Supplier/contractor selection procedures?	Vendor Management https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=792	"According to the General Policy of Fixed Assets Management & Procurement at BRI, vendors participating in the procurement process at BRI must have a Vendor Registration Certificate (SKT). To obtain SKT, vendors need to be managed professionally, considering feasibility and risks, to ensure that BRI has access to vendors who can deliver the required quality and availability effectively and efficiently."
B.4.3	The company's efforts to ensure that its value chain is environmentally friendly or is consistent with promoting sustainable development?	People And Communities Around BRI https://www.ir-bri.com/misc/SR/SR-2024-EN.pdf#page=135-140	BRI's Social and Environmental Responsibility (TJSL) initiatives are an integral part of the company’s strategic operations. Beyond supporting vulnerable groups, these programs play a crucial role in strengthening financial and economic resilience within communities, contributing to long-term business sustainability and enhancing stability in the financial industry. Additionally, BRI’s TJSL initiatives foster stakeholder engagement, raise public awareness and expand access to banking services. These efforts not only drive positive social impact but also reinforce BRI’s position as a trusted financial partner, aligning with the company’s business objectives
B.4.4	The company's efforts to interact with the communities in which they operate?	People And Communities Around BRI https://www.ir-bri.com/misc/SR/SR-2024-EN.pdf#page=135-140	BRI's Social and Environmental Responsibility (TJSL) initiatives are an integral part of the company’s strategic operations. Beyond supporting vulnerable groups, these programs play a crucial role in strengthening financial and economic resilience within communities, contributing to long-term business sustainability and enhancing stability in the financial industry. Additionally, BRI’s TJSL initiatives foster stakeholder engagement, raise public awareness and expand access to banking services. These efforts not only drive positive social impact but also reinforce BRI’s position as a trusted financial partner, aligning with the company’s business objectives
B.4.5	The company's anti-corruption programmes and procedures?	Anti Corruption Program AR 2024 page 784 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=784	BRI has anti-corruption programes that includes: Policy and IT System for Anti Bribery Management Continuous education to every employee through digital and face to face discussion Adoption of ISO 37001:2016 for procurement and Human Capital Recruitment Massive campaign to internal and external stakeholder
B.4.6	How creditors' rights are safeguarded?	Credit Protection Policy https://www.ir-bri.com/misc/OR/Credit-Protection-Policy.pdf https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=301	BRI has established policies and procedures to guarantee the protection of creditors' rights. Broadly speaking, the fulfillment of creditors' rights includes the following: assurance that interest and principal payments are rendered punctually; accessibility of financial report information for creditors; and compliance with all requirements outlined in the loan agreement.
B.4.7	Does the company have a separate report/section that discusses its efforts on environment/economy and social issues?	Sustainability Report 2024 https://www.ir-bri.com/misc/SR/SR-2024-EN.pdf TCFD Report 2024 https://www.ir-bri.com/esg/tcfd.html	In terms of initiatives addressing the environment, economy, and society, BRI published separate report (Sustainability Report & TCFD Report)
B.5	Where stakeholder interests are protected by law, stakeholders should have the opportunity to obtain effective redress for violation of their rights.
B.5.1	Does the company provide contact details via the company's website or Annual Report which stakeholders (e.g. customers, suppliers, general public etc.) can use to voice their concerns and/or complaints for possible violation of their rights?	Corporate Communication Channel https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=76 Whistleblowing System Channel https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=780	Any client complaint is regarded as to be valuable input for BRI to the enhancement of service and product quality. By adopting an integrated complaint handling system, BRI enables customers to voice their concerns and receive suggestions for future improvement. Therefore, in order to promptly identify and comprehend each customer complaint, BRI presently employs omni-channel media, which consists of facilities and access through which BRI customers can obtain comprehensive information about its products and services and lodge complaints via the channels that are currently accessible.
B.6	Mechanisms for employee participation should be permitted to develop.
B.6.1	Does the company explicitly disclose the policies and practices on health, safety and welfare for its employees?	Sustainability Report 2024 page 128 https://www.ir-bri.com/misc/SR/SR-2024-EN.pdf#page=128	BRI is committed to employee health and safety through its Occupational Health and Safety Management System (OHSMS) in all work units. The Operational Risk Division (ORD) under the Risk Management Directorate, which is part of the BCM Department, is responsible for all aspects of OHSMS, including the preparation, refinement, and implementation of OHS. BRI has Hazard Identification, Risk Assessment, and Determining Control (HIRADC) for the policies and practies on health, safety, and welfare for its employees. HIRADC is carried out periodically and includes work areas, descriptions of processes/goals/activities, nature of processes/goals/activities, external and internal legal aspects, OHS hazards, risk impacts, inherent risks before control efforts (inherent risks), types of controls, and remaining associated risks.
B.6.2	Does the company explicitly disclose the policies and practices on training and development programmes for its employees?	Annual Report 2024 page 429 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=431 BRI Talent Management System AR page 434-435 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=436-437	Developing employee competency becomes a top priority for the Company. Competency development is carried out through various programs, including education, training and certification which can be done offline or online through the digital learning platform (BRISMART). In order to developing employees’ careers, BRI implemented an integrated talent management system consisting of the stages of attraction, identification, selection, development and succession.
B.6.3	Does the company have a reward/compensation policy that accounts for the performance of the company beyond short-term financial measures?	Remuneration System and Long Term Compensation AR 2024 page 438 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=440	Company has a reward/compensation policy, to improve employee engagement and sense of belonging to the Company, and to motivate/provide longterm incentives for the employees to achieve the Company’s performance targets.
B.7	Stakeholders including individual employee and their representative bodies, should be able to freely communicate their concerns about illegal or unethical practices to the board and their rights should not be compromised for doing this.
B.7.1	Does the company have a whistleblowing policy which includes procedures for complaints by employees and other stakeholders concerning alleged illegal and unethical behavior and provide contact details via the company's website or annual report	AR 2024 page 778 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=780 Whistleblowing system channel (website) https://whistleblowing-system.bri.co.id/	BRI has a whistleblowing policy and system that allow stakeholders and the public to complain if any of BRI’s employee acts violate the code of conduct, GCG principles, internal policies, and external policies. Any indication of violation can be filed as a report through the following: SMS: 0812-8200-600 Written Letter: PO BOX 1895 JKP 10900 Webmail: whistleblower@corp.bri.co.id Website www.bri.co.id/whistleblowing-system
B.7.2	Does the company have a policy or procedures to protect an employee/person who reveals alleged illegal/unethical behavior from retaliation?	Whistleblower Protection AR Page 779 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=781	The company also provides protection to whistleblowers who are employees, shielding them from threats of retaliation such as pressure from superiors, delays in promotion, discrimination, dismissal, and unilateral transfers. Additionally, BRI offers legal assistance to reporters as required by the relevant regulations.

Part C - Disclosure and Transparency

Part	Item	Practice	Source of Information
C.1	Transparent ownership structure
C.1.1	Does the information on shareholdings reveal the identity of beneficial owners, holding 5% shareholding or more?	Shareholder Composition AR 2024 Page 142 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=144	Regarding ownership, Bank BRI disclosed the following: 20 biggest shareholders. all beneficial owners who held issued shares in equal to 5% or more. ownership by Board and senior management Shareholder composition
C.1.2	Does the company disclose the direct and indirect (deemed) shareholdings of major and/or substantial shareholders?	Shareholder Composition AR 2024 Page 142 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=144	Regarding ownership, Bank BRI disclosed the following: 20 biggest shareholders. all beneficial owners who held issued shares in equal to 5% or more. ownership by Board and senior management Shareholder composition
C.1.3	Does the company disclose the direct and indirect (deemed) shareholdings of directors (commissioners)?	Shareholder Composition AR 2024 Page 146 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=148	Regarding ownership, Bank BRI disclosed the following: 20 biggest shareholders. all beneficial owners who held issued shares in equal to 5% or more. ownership by Board and senior management Shareholder composition
C.1.4	Does the company disclose the direct and indirect (deemed) shareholdings of senior management?	Shareholder Composition AR 2024 Page 148 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=150	Regarding ownership, Bank BRI disclosed the following: 20 biggest shareholders. all beneficial owners who held issued shares in equal to 5% or more. ownership by Board and senior management Shareholder composition
C.1.5	Does the company disclose details of the parent/holding company, subsidiaries, associates, joint ventures and special purpose enterprises/ vehicles (SPEs)/ (SPVs)?	Subsidiaries - AR 2024 Page 149 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=151	The company discloses its subsidiaries and/or associates along with the ownership percentage.
C.2	Quality of Annual Report
C.2.1	Corporate objectives	Corporate Objectives - AR 2024 Page 82 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=84	A strategic plan, long-term plan, medium-term plan, and short-term plan have all been disclosed by Bank BRI.
C.2.2	Financial performance indicators	Financial Report Publication in Website https://www.ir-bri.com/financials.html Material Discussion for Analyst Meeting https://www.ir-bri.com/slides.html/year/2024 Corporate Financial Performance - AR 2024 Page 20 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=22	BRI has disclosed financial performance indicators quarterly through analyst meetings and a quarterly report. BRI publishes financial reports on a semi-annual basis and an annual report.
C.2.3	Non-financial performance indicators	Operational Overview AR 2024 page 27 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=29	BRI sustainability performance delivered in Sustainability Report 2024.
C.2.4	Dividend policy	Dividend Policy - AR 2024 Page 377 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=399	The dividend distribution policy has been regulated internally in SE.70.a–DIR/CMG/12/2022 Book 6 concerning Dividend Management. The policy regulates several principles related to dividends, including dividend management which aims to optimize capital and increase shareholder value, dividend distribution which takes into account the Company’s historical performance as well as future business and economic potential, the amount of the dividend ratio which is determined based on the reasonableness of the profitability performance of business activities and contributions to shareholders, the mechanism for approving dividend distribution through the GMS and fulfilling regulatory requirements, as well as technical provisions related to dividend distribution in more detail.
C.2.5	Biographical details (at least age, academic qualifications, date of first appointment, relevant experience, and any other directorships of listed companies) of all directors/commissioners	BOD Profile - AR 2024 page 106 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=108 BOC Profile - AR 2024 page 121 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=123	Bank BRI made available the biographies of all of its commissioners and directors in Annual Report 2024 and through the website including the current membership status, first appoinment and experience of each individual on the Board of Directors and Board of Commissioners.
C.2.6	Does the Annual Report contain a statement confirming the company's full compliance with the code of corporate governance and where there is non-compliance, identify and explain reasons for each such issue?	Compliance Assessment Based on Regulation https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=472	BRI has disclosed a statement confirming the company’s compliance with the code of corporate governance that is assessed by third parties and self-assessment. Bank BRI provided: Governance Regulation Assessment Asean Corporate Governance Scorecard Corporate Governance Perception Index S & P rating Self-assessment GCG GCG Maturity Index
C.3	Remuneration of Members of the Board and Key Executives
C.3.1	Is there disclosure of the fee structure for non-executive directors/commissioners?	Remuneration Structure - AR 2024 page 567 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=569	BRI has disclosed the remuneration policy for members of Board of Commisioner and Board of Director, including the procedure, indicator and structure of remuneration as regulated in Bank’s Risk Based Remuneration Policy. Additionally, BRI has disclosed Bank’s policy on Management Employee Stock Ownership Program. The method of determining the structure, policy, and value of compensation for each member of the Board of Directors (BOD) and Board of Commisioners (BOC) based on the capabilities of the Bank, the and board activities (the duties, authorities, performance, and responsibilities of the BOD and BOC). Authorization of the compensation of BOC and BOD members is legitimated by shareholders through voting in AGMS.
C.3.2	Does the company publicly disclose [i.e. annual report or other publicly disclosed documents] details of remuneration of each non-executive director/commissioner?	Amount of Remuneration for BOD & BOC - AR 2024 page 568 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=570	BRI disclosed the remuneration of the Board of Director & Board of Commissioner.
C.3.3	Does the company disclose its remuneration (fees, allowances, benefit-in-kind and other emoluments) policy/practices (i.e. the use of short term and long term incentives and performance measures) for its executive directors and CEO?	Amount of Remuneration for BOD & BOC - AR 2024 page 568 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=570	BRI disclosed the remuneration of the Board of Director & Board of Commissioner.
C.3.4	Does the company publicly disclose [i.e. annual report or other publicly disclosed documents] the details of remuneration of each of the executive directors and CEO [if he/she is not a member of the Board]?	Amount of Remuneration for BOD & BOC - AR 2024 page 568 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=570	BRI disclosed the remuneration of the Board of Director & Board of Commissioner.
C.4	Disclosure of related party transactions (RPT)
C.4.1	Does the company disclose its policy covering the review and approval of material RPTs?	RPT Mechanism & Evaluation- AR 2024 page 788 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=790 Policy of Giving Loan to the Board of Directors and Board of Commissioners https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=422	Bank BRI has disclosed a policy covering the review and approval of material RPTs. The Risk and Oversight Committee has the duty and responsibility to evaluate and analyze the Board of Directors' proposals for funding to related parties approved by the Board of Commissioners. Funding (specifically for credit) to the Board of Directors and Board of Commissioners must be carried out fairly and with equal treatment
C.4.2	Does the company disclose the name, relationship, nature and value for each material RPTs?	RPT Details - AR 2024 page 405 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=407	Bank BRI has disclosed the name, relationship, nature, and value for Related Party Transactions.
C.5	Directors and commissioners dealings in shares of the company
C.5.1	Does the company disclose trading in the company's shares by insiders?	Purchase/Sell of Shares of the Board of Commissioners and Directors - AR 2024 page 571=572 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=573-574 Conflict Of Interest Disclosure - AR 2024 page 788 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=790	In 2024, BRI disclosed the trading in BRI stock carried out by members of BOC and BOD during the year. BRI also has a Conflict of Interest Policy that regulates the prevention of insider transactions.
C.6	External auditor and Auditor Report
C.6.1	Are the audit and non-audit fees disclosed?	Public Accountant - AR 2024 page 728 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=730	The amount of Audit fee and non-audit fee are disclosed. In details, non-audit fee is not exceed the audit fees, where non-audit fee was amount to IDR 1.025.000.000 and audit fee was amount to IDR 16.625.000.000
C.6.2	Does the non-audit fee exceed the audit fees?	Public Accountant - AR 2024 page 728 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=730	The amount of Audit fee and non-audit fee are disclosed. In details, non-audit fee is not exceed the audit fees, where non-audit fee was amount to IDR 1.025.000.000 and audit fee was amount to IDR 16.625.000.000
C.7	Medium of communications
C.7.1	Quarterly reporting	Company Website - Quarter Report https://www.ir-bri.com/financials.html/year/2024	Bank BRI published quarterly report which can be downloaded from the company's website.
C.7.2	Company website	Company Website https://bri.co.id/	Bank BRI provide a Website as channel of communication with all of the stakeholders. This website consist not only profile of the company, but also materials issue with the company such as performance as gathering with shareholders.
C.7.3	Analyst's briefing	Company Website - IR Event & Calendars https://www.ir-bri.com/financial_calendar.html	Analyst Meeting is conducted quarterly by Bank BRI to expose the performance of BRI to the analyst / securities company so that they can present an updated report with the latest data to investors.
C.7.4	Media briefings /press conferences	Investor Relation Management - AR 2024 page 769-771 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=771-773	Investor Relation Division has conducted communication activities with the investors by utilizing virtual technology in various activities such as Analyst Meetings, Virtual Field Visits, Webinars, and Virtual Public Expose.
C.8	Timely filing / release of annual / financial reports
C.8.1	Are the audited annual financial report / statement released within 120 days from the financial year end?	Financial Report https://www.ir-bri.com/financials.html/year/2024 Annual Report https://www.ir-bri.com/ar.html	BRI Full Year Financial Statement 2024 released on 12 February 2025 (43 days after financial year end) Annual Report 2024 has released on 28 February 2025 (59 days after financial year end)
C.8.2	Is the annual report released within 120 days from the financial year end?	Annual Report https://www.ir-bri.com/ar.html	Annual Report 2024 has released on 28 February 2025 (59 days after financial year end)
C.8.3	Is the true and fairness/fair representation of the annual financial statement/reports affirmed by the board of directors/commissioners and/or the relevant officers of the company?	CEO & CFO Statement - AR 2025 Page 833 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=836	The true and fainess representation of the annual financial statement is affirmed by Mr. Sunarso as President Director and Mrs. Viviana Dyah Ayu R.K (Finance Director). It is stated that all information in the consolidated financial statements of PT Bank Rakyat Indonesia (Persero) Tbk and Subsidiaries has been disclosed in a complete and truthful manner; and PT Bank Rakyat Indonesia (Persero) Tbk and Subsidiaries consolidated financial statements do not contain any incorrect material information or facts, nor do they omit material information or facts.
C.9	Company website
C.9.1	Financial statements/reports (latest quarterly)	Company Website - Quarter Report https://www.ir-bri.com/financials.html	Company website provides up to date financial statements
C.9.2	Materials provided in briefings to analysts and media	Company Website - IR Event & Calendars https://www.ir-bri.com/financial_calendar.html	Company website provides up to date analyst and media briefings materials. The presentation for analys meeting can be downloaded from company’s website.
C.9.3	Downloadable annual report	Company Website - Annual Report https://www.ir-bri.com/ar.html	Annual report can be downloaded thorugh the company website.
C.9.4	Notice of AGM and/or EGM	Invitation of AGMS https://www.ir-bri.com/misc/NL/2025/Pemanggilan-RUPS-EN.pdf	Company website provides up-to-date notice of AGM and/or EGM.
C.9.5	Minutes of AGM and/or EGM	Summary of Minutes AGMS https://www.ir-bri.com/misc/NL/2025/MoM-AGMS-2025-EN.pdf	Company website provides up-to-date minutes of AGM and/or EGM.
C.9.6	Company's constitution (company's by-laws, memorandum and articles of association)	Article Of Association in Company Website https://www.ir-bri.com/misc/Articles_of_Association.pdf	Article of Association can be downloaded through company website.
C.10	Investor relations
C.10.1	Does the company disclose the contact details (e.g. telephone, fax, and email) of the officer / office responsible for investor relations?	Company Contact Information - AR 2023 page 748-750 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=771-772	Bank BRI disclosed contact details on its company website and annual report.

Part D - Responsibilities of the Board

Part	Item	Practice	Source of Information
D.1	Board Duties and Responsibilities
D.1.1	Does the company disclose its corporate governance policy / board charter?	BOD Charter - AR 2024 page 496 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=498 BOC Charter - AR 2024 page 521 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=523 Governance Policy - AR 2024 page 457-477 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=459-479	BRI discloses its summary of Board of Commissioners, Board of Directors Charter, and Corporate Governance Policy in the Annual Report.
D.1.2	Are the types of decisions requiring board of directors/commissioners' approval disclosed?	BOC Authority - AR 2024 page 518, Article of Association, article 15 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=520 https://www.ir-bri.com/misc/Articles_of_Association.pdf#page=97 BOD Decision Required Approval - AR 2024 page 518 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=520-521	BRI has disclosed the types of decisions requiring board of directors/commissioners' approval disclosed in Articles of Association & Annual Report 2024.
D.1.3	Are the roles and responsibilities of the board of directors/commissioners clearly stated?	BOD Authority - AR 2024 page 495, Article of Association, article 12 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=497 https://www.ir-bri.com/misc/Articles_of_Association.pdf#page=64 BOC Authority - AR 2024 page 518, Article of Association, article 15 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=520 https://www.ir-bri.com/misc/Articles_of_Association.pdf#page=97 BOD Decision Required Approval - AR 2024 page 518 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=520-521	Duties, Authorities and Obligations of the Board of Directors and Board of Commisioners are clearly stated in Articles of Association and Annual Report 2024
D.1.4	Does the company have an updated vision and mission statement?	BRI Vision & Mission - AR 2024 page 82 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=84-85	BRI has disclosed its updated vision and mission in the annual report. Based on Annual Report 2024, BRI vision is becoming The Most Valuable Banking Group in Southeast Asia & Champion of Financial Inclusion
D.1.5	Does the board of directors play a leading role in the process of developing and reviewing the company's strategy at least annually?	BOD & BOC Meeting - AR 2024 page 512 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=514 BOD Meeting - AR 2024 page 502-511 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=505-513 BOC & BOD Responsibilities - Article of Association Article 12 section 2 https://www.ir-bri.com/misc/Articles_of_Association.pdf#page=68 Article 17 section 1 https://www.ir-bri.com/misc/Articles_of_Association.pdf#page=110 Article 19 section 1 & 2 https://www.ir-bri.com/misc/Articles_of_Association.pdf#page=115	Based on Articles of Association, the Board of Directors shall prepare in time the Company's long-term plan, work plan and annual budget of the company and other work plans and changes to be submitted to the board of commissioners and approved by the board of commissioners. The Board of Directors shall draw up the Company's Annual Work Plan and Budget for each fiscal year, which at least contains. mission, business target, business strategy, company policy, and work program/activity; provincial budget for each work program/activity budget; financial projections of the company and its subsidiaries; and another thing that requires the decision of the Board of Commissioners The Board of Directors shall prepare a periodical report containing the implementation of the Corporate Plan and Budget. The periodical report includes quarterly reports and annual reports.
D.1.6	Does the board of directors have a process to review, monitor and oversee the implementation of the corporate strategy?	BOD & BOC Meeting - AR 2024 page 83 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=85	The Board of Directors and the Board of Commissioners jointly carry out monitoring and evaluation of the 2024 strategy contained in the Bank’s Business Plan, the Company’s Work Plan and Budget.
D.2	Board structure
D.2.1	Are the details of the code of ethics or conduct disclosed?	Code Of Conduct Policy - AR 2024 page 774-777 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=776-779 Company Website https://www.ir-bri.com/coc.html	BRI discloses summary of the code of conduct in Annual Report and company website. 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.
D.2.2	Are all directors/commissioners, senior management and employees required to comply with the code/s?	Code Of Conduct Policy - AR 2024 page 774-777 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=777	Statement that the Code of Conduct applies to all organizational levels Board of Directors, Board of Commissioners and all BRI Personnel are required to know,understand, and implement the BRI’s Code of Conduct 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
D.2.3	Does the company have a process to implement and monitor compliance with the code/s of ethics or conduct?	Code Of Conduct Policy - AR 2024 page 774-777 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=777	BRI encourage code of conduct through: Commitment from Top Management and employee Transparency in policy Enforcement & punishment Utilizing Whistleblowing System
D.2.4	Do independent directors/commissioners make up at least 50% of the board of directors/commissioners?	BOC Composition - AR 2024 page 523 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=525	During 2024, The Board of Commissioners has fulfilled the requirements of OJK Regulation no. 17 of 2023, which was issued on September 14, 2023, and pertains to the Governance Implementation for Commercial Banks. The regulation states that the number of Independent Commissioners should be at least 50% (fifty per cent) of the total number of members of the Board of Commissioners. As of December 31, 2024, there were 10 (ten) members in the Board, out of which 7 (seven) were Independent Commissioners, making up 70% of the Board of Commissioners’ composition.
D.2.5	Does the company have a term limit of nine years or less or 2 terms of five years each for its independent directors/ commissioners?	Board Tenure - AR 2024 page 519 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=525 Board Tenure - Article 14 section 14 https://www.ir-bri.com/misc/Articles_of_Association.pdf#page=87	Each member of the Board of Commissioners is appointed from the time it is determined in the GMS and ends at the closing of the 5th AGM with a period not exceeding 5 years.
D.2.6	Has the company set a limit of five board seats that an individual independent/non-executive director/commissioner may hold simultaneously?	BOC Composition - AR 2024 page 523 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=525 Concurrent Policies - Article of Association Article 11 section 2 8https://www.ir-bri.com/misc/Articles_of_Association.pdf#page=64 Article 14 section 29 https://www.ir-bri.com/misc/Articles_of_Association.pdf#page=97	According to BRI Articles of Association, a member of the Board of Commissioners is prohibited from holding multiple positions as: Members of the Board of Directors of state-owned enterprises, regional businessentities, private owned enterprises; The management of a political party and/or a candidate/member of DPR, DPD, DPRDlevel I, and Level II Regional Legislative Assembly and/or regional head candidate; Other positions in accordance with the provisions of the laws and regulations; and/or. Other positions that may create a conflict of interest.
D.2.7	Does the company have any executive directors who serve on more than two boards of listed companies outside of the group?	Policy Of BOD'Concurrent Position - AR 2024 page 500 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=502 BOC Composition - AR 2024 page 523 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=525 Concurrent Policies - Article of Association Article 11 section 2 https://www.ir-bri.com/misc/Articles_of_Association.pdf#page=64 Article 14 section 29 https://www.ir-bri.com/misc/Articles_of_Association.pdf#page=97	All of directors do not have any concurrent position in other companies. BRI Board of Directors has fulfilled the stipulation of concurrent position as regulated by Bank Indonesia. The Board of Directors members are prohibited from holding concurrent positions as members of the Board of Commissioners, Directors or Executive Officers of banks, companies and/or other institutions
D.2.8	Does the company have a Nominating Committee?	Nomination & Remuneration Committee - AR 2024 page 600 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=602	Bank BRI has a Nomination & Remuneration Committee
D.2.9	Is the Nominating Committee comprised of a majority of independent directors/commissioners?	Nomination & Remuneration Committee Composition - AR 2024 page 602-603 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=604-605	As of December 31, 2024 the Nominating Committee is comprised of a majority of independent commissioners. The Bank BRI Nomination Committee has 10 members, of whom 7 are independent commissioners.
D.2.10	Is the chairman of the Nominating Committee an independent director/commissioner?	Nomination & Remuneration Committee Composition - AR 2024 page 602-603 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=604-605	Yes, the chairman of the nominationg committee an independent commissioner, Mr Heri Sunaryadi.
D.2.11	Does the company disclose the terms of reference/ governance structure/charter of the Nominating Committee?	Nomination & Remuneration Committee Charter - AR 2024 page 600 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=602	The company disclosed the duties and responsibilities of the Nominating Committee in its Annual Report and company website.
D.2.12	Is the meeting attendance of the Nominating Committee disclosed and if so, did the Nominating Committee meet at least twice during the year?	Nomination & Remuneration Committee Activities - AR 2024 page 612 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=614	BRI disclosed the meeting attendance of its nominating committee, there were 25 meetings held by the committee in 2024. From the meeting agenda, the issue of nomination has been discussed 20 times during 2024
D.2.13	Does the company have a Remuneration Committee?	Nomination & Remuneration Committee - AR 2024 page 600 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=602	Bank BRI has a Nomination & Remuneration Committee
D.2.14	Is the Remuneration Committee comprised entirely of non-executive directors/commissioners with a majority of independent directors/commissioners ?	Nomination & Remuneration Committee Composition - AR 2024 page 602-603 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=604-605	As of December 31, 2024 the Nominating Committee is comprised of a majority of independent commissioners. The Bank BRI Nomination Committee has 10 members, of whom 7 are independent commissioners.
D.2.15	Is the chairman of the Remuneration Committee an independent director/commissioner?	Nomination & Remuneration Committee Composition - AR 2024 page 602-603 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=604-605	Yes, the chairman of the nominationg committee an independent commissioner, Mr Heri Sunaryadi.
D.2.16	Does the company disclose the terms of reference/ governance structure/ charter of the Remuneration Committee?	Nomination & Remuneration Committee Charter - AR 2024 page 600 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=602	The company disclosed the duties and responsibilities of the Nominating Committee in its Annual Report and company website.
D.2.17	Is the meeting attendance of the Remuneration Committee disclosed and, if so, did the Remuneration Committee meet at least twice during the year?	Nomination & Remuneration Committee Activities - AR 2024 page 612 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=614	BRI disclosed the meeting attendance of its nominating committee, there were 25 meetings held by the committee in 2024. From the meeting agenda, the issue of remuneration has been discussed 5 times during 2024
D.2.18	Does the company have an Audit Committee?	Audit Committee - AR 2024 page 578 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=580	BRI has an Audit Committee.
D.2.19	Is the Audit Committee comprised entirely of non-executive directors/commissioners with a majority of independent directors/commissioners?	Audit Committee Composition - AR 2024 page 582-583 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=580-581	As of December 31, 2024 The Audit Committee comprised entirely of Independent Commissioners with a majority of independent commissioners. The audit committee composition As of December 31, 2024comprised of 4 independent commissioners, and 5 independent parties.
D.2.20	Is the chairman of the Audit Committee an independent director/commissioner?	Audit Committee Composition - AR 2024 page 582-583 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=584	The chairman of the Audit Committee is an independent commissioner and as of 31 Des 24, The chairman of the Audit Committee is Rofikoh Rokhim
D.2.21	Does the company disclose the terms of reference/governance structure/charter of the Audit Committee?	Audit Committee Charter - AR 2024 page 578 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=580 Company Website https://www.ir-bri.com/audit_committee.html	BRI Audit Committee has Audit Committee Charter that disclose in Annual Report 2024 and Company website
D.2.22	Does at least one of the independent directors/commissioners of the committee have accounting expertise (accounting qualification or experience)?	Audit Committee Composition - AR 2024 page 582-583 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=584	The Audit Committee comprised entirely of Independent Commissioners with a majority of independent commissioners. The audit committee composition as of 31 December 2024 comprised of 4 independent commissioners, and 5 independent parties. In 2024, there are several members that has an audit education thorugh training & events.
D.2.23	Is the meeting attendance of the Audit Committee disclosed and, if so, did the Audit Committee meet at least four times during the year?	Audit Committee Activities - AR 2024 page 596 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=598	There is a detailed list of attendance of audit committee. Audit committee held 21 meetings during 2024.
D.2.24	Does the Audit Committee have primary responsibility for recommendation on the appointment, and removal of the external auditor?	Audit Committee Responsibilities - AR 2024 page 580 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=582	BRI have governed the Audit Committee's responsibilitity to provide recommendation on appointment and removal of the external auditor. Providing recommendation on the appointment of a Public Accountant and/or Firm that will provide audit services to the annual financial information, to the Board of Commissioners to be submitted to the GMS, taking into account the independence, scope of the assignment, and services fee. Providing recommendation to the Board of Commissioners, to be proposed to the GMS, in the case of the Public Accountant and/or Public Accountant Firm decided by the GMS as referred to in point 1) cannot meet the audit services on annual financial information during the Professional Assignment Period, the appointment of a replacement of Public Accountant and/or Public Accountant Firm may be conducted by the Board of Commissioners with due regard to the Audit Committee’s recommendation
D.3	Board Processes
D.3.1	Are the board of directors meeting scheduled before the start of financial year?	BOD Meeting Plan - AR 2024 page 501 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=503 BOC Meeting Plan - AR 2024 page 529 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=531	Board of Directors and Board of Commissioners meeting are scheduled before the start of financial year. Meetings of the Board of Commissioners shall be held periodically at least once a month. The joint meeting with Directors shall be held periodically at least once in four months; the meetings may be held at any time at the request of one or more Commissioners or at the request of the Directors, stating the matters to be discussed. Board of Directors shall hold regular Board of Directors’ Meeting at least once a month. Bank BRI also disclosed detailed Board of Commissioners and Board of Directors meeting plan for financial year 2025.
D.3.2	Does the board of directors/commissioners meet at least six times during the year?	BOD & BOC Meeting - AR 2024 page 536 - 537 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=538-539	As of 31 December 2024, Board Of Directors has 52 meeting Board Of Commissioner has at least 6 meeting BOD and BOC has 22 joint meeting
D.3.3	Has each of the directors/commissioners attended at least 75% of all the board meetings held during the year?	BOD Meeting Frequency & Attendance- AR 2024 page 512 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=514 BOC Meeting Frequency & Attendance- AR 2024 page 536-537 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=538-539	In BoC meetings during 2024, there are no members of BoC whose meeting attendance is less than 75%. In joint BoC and BoD meetings during 2024, there are no members of BoC and BoD whose meeting attendance is less than 75%. In BoD meetings during 2024, there are no members of BoD whose meeting attendance is less than 75%.
D.3.4	Does the company require a minimum quorum of at least 2/3 for board decisions?	BOD Meeting Policy- AR 2024 page 501 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=503 BOC Meeting Policy AR 2024 page 527 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=529	The meeting is legal and has the right to make binding decisions if it is attended and/or represented by more than 2/3 (two-thirds) of the total members of the Company’s Board of Directors. As a realization, every meeting that BoC and/or BOD attended, 75% more members attended the meeting.
D.3.5	Did the non-executive directors/commissioners of the company meet separately at least once during the year without any executives present?	BOC Meeting - AR 2024 page 530-531 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=532-533	Board of Commissioners meetings were held 6 times during 2024.
D.3.6	Are board papers for board of directors/commissioners meetings provided to the board at least five business days in advance of the board meeting?	BOD Meeting Policy- AR 2024 page 501 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=503 BOC Meeting Policy AR 2024 page 527 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=529	For both BOD or BOC meetings, for planned meetings, materials must be provided 5 working days before the meeting.
D.3.7	Does the company secretary play a significant role in supporting the board in discharging its responsibilities?	Corporate Secretary Activities- AR 2024 page 663 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=665	The company secretary plays a significant role in supporting the board in discharging its responsibilities.
D.3.8	Is the company secretary trained in legal, accountancy or company secretarial practices and has kept abreast on relevant developments?	Corporate Secretary Activities- AR 2024 page 666 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=668	The Corporate Secretary is held by Mr. Agustya Hendy Bernadi and has received specific education related to accounting and law in general.
D.3.9	Does the company disclose the criteria used in selecting new directors/commissioners?	Nomination Procedures of The Board of Commissioners and Directors https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=563	BRI has disclose the criteria used in selection new directors/commissioners in Annual Report 2024 based on regulation and best practice.
D.3.10	Did the company describe the process followed in appointing new directors/commissioners?	Nomination Procedures of The Board of Commissioners and Directors https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=563	The nomination procedures for Directors and Board of Commissioners have been disclosed from the talent pool stage to appointment.
D.3.11	Are all directors/commissioners subject to re-election every 3 years; or 5 years for listed companies in countries whose legislation prescribes a term of 5 years2 each?	Board Re-election Policy - Article of Association Article 11 section 12 https://www.ir-bri.com/misc/Articles_of_Association.pdf#page=91 Article 14 section 14 https://www.ir-bri.com/misc/Articles_of_Association.pdf#page=55	Board of Commisisoners and Board of Directors are subject to re-election in every 5 years.
D.3.12	Do the shareholders or the Board of Directors approve the remuneration of the executive directors and/or the senior executives?	Remuneration Determination Procedure- AR 2024 page 566 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=568	The GMS approve the remuneration of the board of directors. The remuneration of members of the Board of Commissioners and members of the Board of Directors is determined by the General Meeting of Shareholders.
D.3.13	Does the company have measurable standards to align the performance-based remuneration of the executive directors and senior executived with long-term interests of the company, such as claw back provision and deferred bonuses?	Remuneration Adjustment with Performance & Risk- AR 2024 page 564 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=566	BRI has disclose remuneration policy that include measurable standards to align the performance-based, clawback, malus and deferred bonus.
D.3.14	Does the company have a separate internal audit function?	Internal Audit Function- AR 2024 page 670 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=672	The company has a separate internal audit function and it is called Internal Audit Unit (IAU).
D.3.15	Is the head of internal audit identified or, if outsourced, is the name of the external firm disclosed?	Internal Audit Function- AR 2024 page 671 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=673	The head of internal audit is identified (Yulianto Setiawan)
D.3.16	Does the appointment and removal of the internal auditor require the approval of the Audit Committee?	Internal Audit Function- AR 2024 page 671 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=673	The SEVP Internal Audit Unit is appointed and terminated by the President Director following the approval of the Board of Commissioners by taking into account the recommendations of the Audit Committee. The appointment of SEVP IAU has been reported to the Financial Services Authority.
D.3.17	Does the company establish a sound internal control procedures/risk management framework and periodically review the effectiveness of that framework?	Internal Control Implementation- AR 2024 page 731 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=731 Compliance With COSO- AR 2024 page 731 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=731	The company has an internal control system that is evaluated periodically.
D.3.18	Does the Annual Report/Annual CG Report disclose that the board of directors/commissioners has conducted a review of the company's material controls (including operational, financial and compliance controls) and risk management systems?	Company Material Risk- AR 2024 page 734 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=736	The company explains material aspects of risk management in its annual report, which includes at least eight types of risk.
D.3.19	Does the company disclose the key risks to which the company is materially exposed to (i.e. financial, operational including IT, environmental, social, economic)?	Company Material Risk- AR 2024 page 749 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=751 Materiality Risk related with sustainability- SR 2024 page 22 https://www.ir-bri.com/misc/SR/SR-2024-EN.pdf#page=22	The company explains material aspects of risk management in its annual report, which includes at least eight types of risk. Material Risk for sustainability is disclosed in Sustainability Report which include environment, social and also governance.
D.3.20	Does the Annual Report/Annual CG Report contain a statement from the board of directors/commissioners or Audit Committee commenting on the adequacy of the company's internal controls/risk management systems?	Statement By The Board regarding adequacy of Internal Control- AR 2024 page 752 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=754	Based on Annual Report 2024, there is a statement by the Board of Commissioners and Board of Directors regarding the adequacy of BRI Internal Control.
D.4	People on the Board
D.4.1	Do different persons assume the roles of chairman and CEO?	Board Profile- AR 2024 page 106 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=108	As of 31 December 2024 Different persons assume the roles of chairman and CEO. The Chairman position is held by Mr. Kartika wirjoatmodjo, while the CEO position is held by Mr. Sunarso.
D.4.2	Is the chairman an independent director/commissioner?	Board Profile- AR 2024 page 121 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=123	As of 31 December 2024 The Chairman Commissioner held by Mr Kartika Wirjoatmodjo
D.4.3	Is any of the directors a former CEO of the company in the past 2 years?	Board Profile- AR 2024 page 106 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=108	There is no Directors as a former CEO of the Company in the past 2 years
D.4.4	Are the roles and responsibilities of the chairman disclosed?	Chairman Responsibilities- AR 2024 page 518 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=520	BRI has disclose roles and responsibilities of the chairman.
D.4.5	If the Chairman is not independent, has the Board appointed a Lead/Senior Independent Director and has his/her role been defined?	Board Profile- AR 2024 page 121 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=123	As of 31 December 2024 BRI has disclose that as vice chariman commissioner held by Rofkoh Rohim Independent Commissioner
D.4.6	Does at least one non-executive director/commissioner have prior working experience in the major sector that the company is operating in?	Board Profile- AR 2024 page 121 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=123	As of 31 December 2024 There are several commissioners who previously work in financial industries, among others are Mr. Kartika wirjoatmodjo and Mr. Rabin Indrajad Hattari,
D.5	Board Performance
D.5.1	Does the company have orientation programmes for new directors/commissioners?	BOD Education Programmes- AR 2024 page 514 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=516 BOC Education Programmes- AR 2024 page 540 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=542	BRI have orientation programmes for new directors/commissioners (Mr. Haryo Baskoro Wicaksono)
D.5.2	Does the company have a policy that encourages directors/commissioners to attend on-going or continuous professional education programmes?	BOD Education Programmes- AR 2024 page 513 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=515 BOC Education Programmes- AR 2024 page 538 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=540	BRI has the policy regarding competency development of the Board of Director and Board of Commissioners members with the objective to increase the competency as well as skill of each member in performing duties.
D.5.3	Does the company disclose the process on how the board of directors/commissioners plans for the succession of the CEO/Managing Director/President and key management?	Succession Policy- AR 2024 page 614 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=616	BRI has disclosed Succession Policy that adopted from regulation such as SoE Regulation & Banking Regulation.
D.5.4	Does the board of directors/commissioners conduct an annual performance assessment of the CEO/Managing Director/President?	Criteria & Performance Assessment for The CEO- AR 2024 page 544 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=546	BRI has conducted an annual performance assessment of the CEO in Annual Report.
D.5.5	Did the company conduct an annual performance assessment of the board of directors/commissioners and disclose the criteria and process followed for the assessment?	Collective Performance Assessment for The Board- AR 2024 page 544 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=546	BRI has conducted an annual performance assessment of the Collective Board Director & Board of Commissioner in Annual Report.
D.5.6	Did the company conduct an annual performance assessment of the individual directors/commissioners and disclose the criteria and process followed for the assessment?	Performance Assessment for The Board- AR 2024 page 544 https://www.ir-bri.com/misc/AR/AR2024-ID.pdf#page=546	BRI has conducted an annual performance assessment of the Board Director & Board of Commissioner as individually in Annual Report. BRI has conducted annual performance assessment for Board of Commissioner individually with criteria as follows in Annual Report.
D.5.7	Did the company conduct an annual performance assessment of the board committees and disclose the criteria and process followed for the assessment?	Performance Assessment for Committee Under BOC- AR 2024 page 554 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=556	BRI has conducted an annual performance assessment of the Board of Commissioner Committee in Annual Report. BRI has conducted Criteria of annual performance assessment for Board of Commissioner Committee in Annual Report.

Part Bonus

Part	Item	Practice	Source of Information
(B)A.	Right & Equitable treatment of shareholders
(B)A.1	Right to participate effectively in and vote in general shareholders meeting and should be informed of the rules, including voting procedures, that govern general shareholders meeting.
(B)A.1.1	Does the company practice secure electronic voting in absentia at the general meetings of shareholders?	Attendance of Shareholders and Other Parties at the GMS https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=483	Company has voting procedure which allow the shareholders to conduct voting in absentia by providing the proxy via eASY KSEI. The procedure also disclosed in the Notice and Code of Conduct 2025 AGMS.
(B)A.2	Right & Equitable treatment of shareholders
(B)A.2	Notice of AGM
(B)A.2.1	Does the company release its notice of AGM (with detailed agendas and explanatory circulars), as announced to the Exchange, at least 28 days before the date of the meeting?	Announcement of 2025 AGMS https://www.ir-bri.com/misc/NL/2025/Pengumuman-RUPST-2025-EN.pdf Invitation of 2025 AGMS https://www.ir-bri.com/misc/NL/2025/Pemanggilan-RUPS-EN.pdf Summary Minutes of Meeting & Resolution AGMS 2025 https://www.ir-bri.com/misc/NL/2025/MoM-AGMS-2025-EN.pdf	Announcement of 2024 AGMS = 31 January 2025 Invitation/Notice of AGMS 2024 = 28 February 2025 AGMS 2025 = 25 March 2025
(B)B.	Sustainability and Resilience
(B)B.1.1	Does the company disclose how it manages climate-related risks and opportunities?	Sustainability Report 2024 https://www.ir-bri.com/misc/SR/SR-2024-EN.pdf TCFD Report 2024 https://www.ir-bri.com/esg/tcfd.html	As of 2024, BRI has published Sustainability Report and TCFD Report as evidence of concern regarding ESG Impact & implementation.
(B)B.1.2	Does the company disclose that its Sustainability Report / Sustainability Reporting is externally assured?	SR 2024 Assurance- SR 2024 page 245 https://www.ir-bri.com/misc/SR/SR-2024-EN.pdf#page=245	BRI Sustainability Report 2024 has been assured by PT. CBC Global Indonesia
(B)B.1.3	Does the company disclose the engagement channel with stakeholder groups and how the company responds to stakeholders’ ESG concerns?	Materiality & Stakeholder Engagement https://www.ir-bri.com/misc/SR/SR-2024-EN.pdf#page=20	As a financial institution, BRI recognizes its broad impact on various aspects of life and a wide range of stakeholders, However, BRI categorizes stakeholders into 2 parts, Internal Stakeholders (Employees) and External Stakeholders (Customers, Investors, Regulators and Suppliers) as the main stakeholders based on their business relevance, commitment to diversity, willingness to participate, and reciprocal impact on BRI. By prioritizing these key stakeholders, BRI fosters collaboration and support, ensuring their engagement is integrated into its overall ESG management activities, including the materiality determination process.
(B)B.1.4	Does the company have a unit / division / committee who is specifically responsible to manage the sustainability matters?	ESG Structure - SR 2024 page 29 https://www.ir-bri.com/misc/SR/SR-2024-EN.pdf#page=29	BRI has an ESG Division that is specifically responsible for managing sustainability matters, and it also has a Risk Management and ESG Committee to plan and ensure the implementation of ESG in BRI.
(B)B.1.5	Does the company disclose board of directors/commissioners' oversight of sustainability-related risks and opportunities?	Materiality & Stakeholder Engagement https://www.ir-bri.com/misc/SR/SR-2024-EN.pdf#page=20	"As a financial institution, BRI recognizes its broad impact on various aspects of life and a wide range of stakeholders, However, BRI categorizes stakeholders into 2 parts, Internal Stakeholders (Employees) and External Stakeholders (Customers, Investors, Regulators and Suppliers) as the main stakeholders based on their business relevance, commitment to diversity, willingness to participate, and reciprocal impact on BRI. By prioritizing these key stakeholders, BRI fosters collaboration and support, ensuring their engagement is integrated into its overall ESG management activities, including the materiality determination process."
(B)B.1.6	Does the company disclose the linkage between executive directors and senior management remuneration and sustainability performance for the previous year?	Performance Assessment for The Board- AR 2024 page 544 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=546	BRI has disclose the linkage between BoD Perfomance Assessment with Sustainabiliy Performance. Each of KPI paramters there is a part of Environment (E); Social (S); Governance (G).
(B)B.1.7	Is the company’s Whistle Blowing System managed by independent parties / institutions?	AR 2024 page 778 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=780	BRI’s Whistle Blowing System managed by Independent Task Force
(B)C.	Disclosure & Transparency
(B)C.1	Quality of Annual Report
(B)C.1.1	Are the audited annual financial report /statement released within 60 days from the financial year end?	Full Year Financial statement 2024 https://www.ir-bri.com/misc/QR/2024/FY-2024.pdf	BRI Full Year Financial Statement 2024 released on 2 February 2025 (33 days after financial year end)
(B)D.	Responsibilities of the Board
(B)D.1	Board Competencies and Diversity
(B)D.1.1	Does the company have at least one female independent director/commissioner?	BOC and BOD Diversity Table - AR 2024 page 573 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=575	BRI has 3 female independent commissioners, Ms. Rofikoh Rokhim, Mrs Dwi Ria Latifa, and Mrs. Nurmaria Sarosa
(B)D.1.2	Does the company have a policy and disclose measurable objectives for implementing its board diversity and report on progress in achieving its objectives?	BOC and BOD Diversity Table - AR 2024 page 573 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=575	BRI has policy for implementing its board of commissioners and board of directors diversity. As of 2024, BRI has a diversity composition of board target include gender, experience and age.
(B)D.2	Board Structure
(B)D.2.1	Is the Nominating Committee comprise entirely of independent directors/commissioners?	Nomination & Remuneration Committee Composition - AR 2024 page 602-603 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=604-605	Yes, the Nominating Committee is comprised of a majority of independent commissioners. The Bank BRI Nomination Committee has 10 members, of whom 7 are independent commissioners.
(B)D.2.2	Does the Nominating Committee undertake the process of identifying the quality of directors aligned with the company's strategic directions?	Nomination Process - AR 2024 page 561 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=563	The management nomination procedure has been disclosed from the talent pool stage to appointment.
(B)D.3	Board Appointments and Re-Election
(B)D.3.1	Does the company use professional search firms or other external sources of candidates (such as director databases set up by director or shareholder bodies) when searching for candidates to the board of directors/commissioners?	Nomination Process - AR 2024 page 561 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=563	The Nomination and Remuneration Committee selects prospective members of the Board of Directors who meet the specified qualifications. The Nomination and Remuneration Committee allow to use third independent parties that handle professional assessment to identify potential candidates to meet desired profiles
(B)D.4	Board Structure & Composition
(B)D.4.1	Do independent non-executive directors/commissioners make up more than 50% of the board of directors/commissioners for a company with independent chairman?	Board Profile- AR 2024 page 106 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=108	BRI Board of Commissioners consist of 7 Independent Commissioners and 3 Non Independent
(B)D.5	Risk Oversight
(B)D.5.1	Does the company disclose that its Board identified key risk in relation to information technology including disruption, cyber security, and disaster recovery, to ensure that such risks are managed and integrated into the overall risk management framework?	Cyber Security and Disruption- AR 2024 page 448 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=450	To deal with the development of digitalization and the increasing threat of cyber attacks, since 2018, BRI has established a special business unit under the Digital & IT Directorate to handle information security. This unit is led by an experienced Chief Information Security Officer (CISO) with certifications such as Certified Information System Auditor (CISA) and Certified Information Systems Security Professional (CISSP). BRI also adopts the NIST Cyber Security Framework-based Enterprise Security Architecture as the main guideline in cybersecurity development.
(B)D.6	Board Performance
(B)D.6.1	Does the company have a separate board level Risk Committee?	Risk Management Oversight Committee- AR 2024 page 614 https://www.ir-bri.com/misc/AR/AR2024-EN.pdf#page=616	The Risk Management Monitoring Committee (RMOC) is one of the Committees under the Board of Commissioners whose duties and responsibilities are to assist the Board of Commissioners in carrying out evaluations and ensuring the implementation of risk management in the Company.

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