Part C - Disclosure and Transparency | PT Bank Tabungan Negara (Persero) Tbk

C.1
C.1.1
Transparent ownership structure	Does the information on shareholdings reveal the identity of beneficial owners, holding 5% shareholding or more?
Company Practices 2023-2024	The company has disclosed the information on shareholdings reveal the identity of beneficial owners, holding 5% shareholding or more. The complete disclosure can be found in Table of Composition of Shareholders of 5% or More of Bank BTN as of December 31. The information is mentioned in: Bank Tabungan Negara Annual Report FY 2023, Shareholders Composition 5% or More, page 172.
Source	Annual Report FY 2023
C.1.2
Transparent ownership structure	Does the company disclose the direct and indirect (deemed) shareholdings of major and/or substantial shareholders?
Company Practices 2023-2024	The company has disclosed the direct and indirect shareholdings of major shareholders. The information is mentioned in: Bank Tabungan Negara Annual Report FY 2023, Information on The Top 20 Shareholders, Page 170-173.
Source	Annual Report FY 2023
C.1.3
Transparent ownership structure	Does the company disclose the direct and indirect (deemed) shareholdings of directors (commissioners)?
Company Practices 2023-2024	"The company has disclosed the direct and indirect shareholdings of directors (commissioners). As of December 2023, there is no indirect share ownership by the Board of Commissioners and Directors of Bank BTN. The information is mentioned in: Bank Tabungan Negara Annual Report FY 2023, Share Ownership by Management, Page 173-174.
Source	Annual Report FY 2023
C.1.4
Transparent ownership structure	Does the company disclose the direct and indirect (deemed) shareholdings of senior management?
Company Practices 2023-2024	"The company discloses the direct and indirect shareholdings of Directors on 1 January 2023 and 31 January 2023. As of December 2023, there is no indirect share ownership by the Board of Commissioners and Directors of Bank BTN. The information is mentioned in: Bank Tabungan Negara Annual Report FY 2023, Share Ownership by Management, Page 173-174.
Source	Annual Report FY 2023
C.1.5
Transparent ownership structure	Does the company disclose details of the parent/holding company, subsidiaries, associates, joint ventures and special purpose enterprises/ vehicles (SPEs)/ (SPVs)?
Company Practices 2023-2024	As of December 31, 2023 as well as the date this data/information was submitted, The Company does not have any Subsidiaries and/or Associated Entities. Thus, there is no information regarding the names of subsidiaries, associated companies, joint venture companies along with the percentage of share ownership, line of business, total assets, and operating status of subsidiaries, associated companies, joint venture companies. The information is mentioned in: Bank Tabungan Negara Annual Report FY 2023, List of Subsidiaries, Associates and Joint Venture Companies, Page 175.
Source	Annual Report FY 2023

C.2 Does the company's annual report disclose the following items:
C.2.1
Transparent ownership structure	Corporate objectives
Company Practices 2023-2024	"The company's annual report disclose Corporate objectives. The information is mentioned in: Bank Tabungan Negara Sustainability Report FY 2023, Short and Medium Term Strategy, Page 212. Bank Tabungan Negara Annual Report FY 2023, Long-Term Strategy, Page 218.
Source	BTN Annual Report FY 2023 BTN Sustainability Report FY 2023
C.2.2
Transparent ownership structure	Financial performance indicators
Company Practices 2023-2024	"The company has disclosed financial performance indicators in the Annual Report 2023. The information is mentioned in: Bank Tabungan Negara Annual Report FY 2023, Financial Ratio, Page 24.
Source	Annual Report FY 2023
C.2.3
Transparent ownership structure	Non-financial performance indicator
Company Practices 2023-2024	The company has disclosed the company non-financial performance indicators, such as Customer Satisfaction Index & Market Share, Environmental Performance, Social Performance, and Governance Performance. The information is mentioned in: Bank Tabungan Negara Sustainability Report FY 2023, Sustainability Performance Highlights, Page 6-7 Bank Tabungan Negara Annual Report FY 2023, Market Share, Page 231.
Source	BTN Annual Report FY 2023 BTN Sustainability Report FY 2023
C.2.4
Transparent ownership structure	Dividend policy
Company Practices 2023-2024	"The company's annual report discloses dividend policy. The policy basis for dividend distribution was based on the resolution of the ""Annual General Meeting of Shareholders (AGMS) or the Extraordinary General Meeting of Shareholders (EGMS) based on Law no. 40 of 2007 concerning Limited Liability Companies. The amount of Bank BTN dividends was determined at the General Meeting of Shareholders (GMS). Management plans to pay a minimum cash dividend of 20% of net profit each year. The information is mentioned in: Bank Tabungan Negara Annual Report FY 2023, Dividend Policy, Page 305
Source	Annual Report FY 2023
C.2.5
Transparent ownership structure	Biographical details (at least age, academic qualifications, date of first appointment, relevant experience, and any other directorships of listed companies) of all directors/commissioners
Company Practices 2023-2024	"The company has disclosed the Biographical details (at least age, academic qualifications, date of first appointment, relevant experience and any other directorships of listed companies) of all directors/commissioners. The information is mentioned in: Bank Tabungan Negara Annual Report FY 2023, Board of Directors Profile, Page 120-130. Bank Tabungan Negara Annual Report FY 2023, Board of Commissioners Profile, Page 134-142.
Source	Annual Report FY 2023 Annual Report FY 2023
Corporate Governance Confirmation Statement
C.2.6
Transparent ownership structure	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?
Company Practices 2023-2024	"The Annual Report contain a tabular form indicating each principle and guideline and commenting on if they have complied or not with an explanation. The Company always complies with applicable regulations in implementing GCG. It includes referring to the Public Company Governance Guidelines stipulated in OJK Regulation No. 21/POJK.04/2015 and OJK Circular Letter No. 32/SEOJK.04/2015 concerning Public Company Governance Guidelines. The information is mentioned in: Bank Tabungan Negara Annual Report FY 2023, Public Company Governance Implementation Guidelines, Page 684-692."
Source	Annual Report FY 2023

C.3
C.3.1
Remuneration of Members of the Board and Key Executives	Is there disclosure of the fee structure for non-executive directors/commissioners
Company Practices 2023-2024	"The company has dislosed the fee structure for non-executive directors/commissioners. The remuneration structure showing the types and/or short-term, long-term and/or post-employment benefits is as follows: Types of short-term remuneration consist of: Honorarium, Allowances (holidays, transportation), Facilities (health, legal aid) and Tantiem. Types of long-term and/or post-employment remuneration consist of Post-Employment Insurance and can also be given long-term incentives (LTI) as well as Tantiem/work incentives, on which bonuses can be given in addition to long-term rewards (long-term incentives/LTI). The information is mentioned in: Bank Tabungan Negara Annual Report FY 2023, Structure and Amount of Nominal/Remuneration for Each Director and Board of Commissioners, Page 499 - 500.
Source	Annual Report FY 2023
C.3.2
Remuneration of Members of the Board and Key Executives	Does the company publicly disclose [i.e. annual report or other publicly disclosed documents] details of remuneration of each non- executive director/commissioners?
Company Practices 2023-2024	The company has disclosed details of the remuneration of non-executive directors/commissioners. The details provided are Salary/Honorarium, Tantiem, Holiday Allowance, Pension Insurance & BPJS Insurance, Housing Allowance, Vehicle Facilities, Health Facilities, Legal Aid Facilities, and other Facilities. This information is mentioned in: Bank Tabungan Negara Annual Report FY 2023, The remuneration components of the Board of Commissioners and Directors, Page 499-501.
Source	Annual Report FY 2023
C.3.3
Remuneration of Members of the Board and Key Executives	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?
Company Practices 2023-2024	The company has disclosed remuneration policies/practices (fees, allowances, allowances and other rewards) (i.e. use of incentives and short-term and long-term performance measures) for executive directors and CEOs which refer to Directors Regulation No. 02/PD/HCD/2017 concerning Income of Directors and Board of Commissioners, Implementation of Governance In Providing Remuneration, the remuneration components of the Board of Commissioners and Directors of Bank BTN Apart from that, the scope of the Company's remuneration policy has been adjusted to OJK Regulation Number 5/POJK.03/2015 and OJK Circular Letter Number 40/SEOJK.03/2016 relating to the Implementation of Governance in Providing Remuneration for Commercial Banks, including The principle of prudence in remuneration is based on performance and risk. Remuneration structure indicating the types and/or rewards short term, long term and/or post can be seen in the BTN 2023 annual report page 499, including: Types of short-term remuneration consist of: Honorarium, Allowances (holidays, transportation), Facilities (health,legal aid) and Tantiem. Type of long-term and/or post-employment remunerationconsists of Retirement Insurance and can also be providedlong-term incentives (LTI) as wellTantiem/work incentives, which can be included in the bonusadditionally given in the form of long-term rewards (long term incentive/LTI). This information is mentioned in: Bank Tabungan Negara Annual Report FY 2023, Procedure for Determining The Remuneration for The Board of Directors and Board of Commissioners, Page 498-501. Bank Tabungan Negara Annual Report FY 2023, Structure and Amount of Nominal/Remuneration for Each Director and Board of Commissioner, Page 490-491.
Source	Annual Report FY 2023 Annual Report FY 2023
C.3.4
Remuneration of Members of the Board and Key Executives	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]?
Company Practices 2023-2024	The company has disclose the total remuneration for BoD and CEO. The total remuneration include salary, bonuses, holiday allowance, retirement insurance and other facilities) This information is mentioned in: Bank Tabungan Negara Annual Report FY 2023, Structure and Amount of Nominal/Remuneration for Each Director and Board of Commissioners, Page 499 - 500.
Source	Annual Report FY 2023

C.4
C.4.1
Disclosure of related party transactions (RPT)	Does the company disclose its policy covering the review and approval of material RPTs?
Company Practices 2023-2024	The company has disclose its policy covering the review and approval of material RPTs in Annual Report, Page 308 and page 315. The policy of providing funds to related parties that contained conflicts of interest was contained in a separate Directors Regulation which stipulated that Bank BTN was prohibited from providing funds to related parties without the approval of the Board of Commissioners. Also, in the Annual Report 2023, page 315 states that All transactions have gone through a review mechanism according to the type of transaction. The company has provisions related to RPT which include, among others: The Board of Commissioners has the authority to give approval for actions included in material transactions as determined by laws and regulations in the Capital Market sector with a certain amount determined by the Board of Commissioners unless the action is included in material transactions which are excluded by the applicable Laws and Regulations. in the field of Capital Markets. (Articles of Association article 12 paragraph 7 letter j and Board Manual article 6 paragraph 3 letter i) The review process for RPT transactions includes the provision of credit. This information is mentioned in: Bank Tabungan Negara Annual Report FY 2023, Information on Material Transactions Containing Conflicts of Interest and/or Transactions with Affiliates Parties, Page 308. Bank Tabungan Negara Annual Report FY 2023, Transaction Review Mechanism Policy, Page 315.
Source	Annual Report FY 2023 Annual Report FY 2023 Information on Material Transactions Transaction Review Mechanism Policy
C.4.2
Disclosure of related party transactions (RPT)	Does the company disclose the name, relationship, nature and value for each material RPTs?
Company Practices 2023-2024	The company has disclosed the name, relationship, nature for each material RPTs. As stated in Annual Report 2023 page 313-315 that Related party transactions occur due to the Company’s business needs. All transactions were carried out normally and fairly (arm’s length transactions) as transactions with other parties. The Company guarantees that all transactions are free from conflicts of interest and comply with applicable laws and regulations. Moreover, the details of the realization of related party transactions due to ownership relationships with the Government of the Republic of Indonesia and related party transactions with Key Management can be found in Annual Report page 309 This information is mentioned in: Bank Tabungan Negara Annual Report FY 2023, Realization of Related Party Transactions, Page 315.
Source	Annual Report FY 2023 Realization of Related Party Transactions Related Party Transactions Information on Material Transactions

C.5
C.5.1
Directors and commissioners dealings in shares of the company	Does the company disclose its policy covering the review and approval of material RPTs?
Company Practices 2023-2024	The company has disclose its policy covering the review and approval of material RPTs in Annual Report, Page 308 and page 315. The policy of providing funds to related parties that contained conflicts of interest was contained in a separate Directors Regulation which stipulated that Bank BTN was prohibited from providing funds to related parties without the approval of the Board of Commissioners. Also, in the Annual Report 2023, page 315 states that All transactions have gone through a review mechanism according to the type of transaction. The company has provisions related to RPT which include, among others: The Board of Commissioners has the authority to give approval for actions included in material transactions as determined by laws and regulations in the Capital Market sector with a certain amount determined by the Board of Commissioners unless the action is included in material transactions which are excluded by the applicable Laws and Regulations. in the field of Capital Markets. (Articles of Association article 12 paragraph 7 letter j and Board Manual article 6 paragraph 3 letter i) The review process for RPT transactions includes the provision of credit. This information is mentioned in: Bank Tabungan Negara Annual Report FY 2023, Information on Material Transactions Containing Conflicts of Interest and/or Transactions with Affiliates Parties, Page 308. Bank Tabungan Negara Annual Report FY 2023, Transaction Review Mechanism Policy, Page 315.
Source	Annual Report FY 2023 Annual Report FY 2023 Information on Material Transactions Transaction Review Mechanism Policy

C.6
C.6.1
External auditor and Auditor Report	Are the audit and non-audit fees disclosed?
Company Practices 2023-2024	The Company has disclosed the audit and non-audit fees. The total costs incurred for the implementation of audit services on Bank BTN by KAP Purwantono, Sungkoro & Surja with audit fee of Rp4.800.000.000,- Fees and Other Services Provided by Accountants During 2023, there is no other services provided by accountants. This information is mentioned in: Bank Tabungan Negara Annual Report FY 2023, Fees and Other Services Provided by Accountants, Page 605. Bank Tabungan Negara Annual Report FY 2023, Information on Material Transactions Containing Conflicts of Interest and/or Transactions with Affiliates Parties, Page 308. Bank Tabungan Negara Annual Report FY 2023, Transaction Review Mechanism Policy, Page 315.
Source	Annual Report FY 2023
C.6.2
External auditor and Auditor Report	Does the non-audit fee exceed the audit fees?
Company Practices 2023-2024	The non - audit fee does not exceed the audit fee because Accounting Firms do not provide other services besides the scope of audit services. Fees and Other Services Provided by Accountants. During 2023, there is no other services provided by accountants. This information is mentioned in: Bank Tabungan Negara Annual Report FY 2023, Fees and Other Services Provided by Accountants, Page 605.
Source	Annual Report FY 2023

C.7 Does the company use the following modes of communication?
C.7.1
Medium of communications	Quarterly reporting
Company Practices 2023-2024	"The Company published its Quarterly Report through Stock Exchange's website and Bank Tabungan Negara's Website in Quarterly Report . The information is mentioned in: This information is mentioned in: Bank Tabungan Negara Website, Menu Investor Relations - The Company Report - Quarterly Report"
Source	Quarterly Financial Report - Q1 Quarterly Financial Report - Q2 Quarterly Financial Report - Q3 Quarterly Financial Report - Q4 Audit Finance Report FY 2023
C.7.2
Medium of communications	Company website
Company Practices 2023-2024	"The company uses Company Website as medium of communication. The information is mentioned in: Bank Tabungan Negara Website, www.btn.co.id"
Source	Website BTN
C.7.3
Medium of communications	Analyst's briefing
Company Practices 2023-2024	"The company prepares Analyst's Meeting as a medium of communication. Such information may be accessed through Bank Tabungan Negara The information is mentioned in: This information is mentioned in: Bank Tabungan Negara Website, Menu Investor Relations - Company Presentations - Presentation"
Source	Analyst Meeting Q1 Analyst Meeting Q2 Analyst Meeting Q3 Analyst Meeting Q4
C.7.4
Medium of communications	Media briefings/press conferences
Company Practices 2023-2024	The company invites media/press to conduct media briefings/press conference during 2023. The evidence of media briefings and press conference can be found in our websites. Website Bank : https://www.btn.co.id/en/About/Gallery/News/Press-Conference This information is mentioned in: Bank Tabungan Negara Annual Report FY 2023, Access to Company Information and Data,Page 638-647
Source	Annual Report FY 2023 Press Conference 2023

C.8
C.8.1
Timely filing/release of annual/financial reports	Are the audited annual financial report / statement released within 120 days from the financial year end?
Company Practices 2023-2024	"The company's audited annual financial statements was issued and submitted to IDX (at 12 February 2024 -> 43 days from the financial year end). This information is mentioned in: Exchange website (News->Announcement -> Search BBTN->Financial Report->PDF Lampiran 5.)"
Source	Website IDX
C.8.2
Timely filing/release of annual/financial reports	Is the annual report released within 120 days from the financial year end?
Company Practices 2023-2024	"The Company has released its annual report within 120 days from the financial year end. It submitted to IDX at 13 February 2024 (44 days from the financial year end). The information is mentioned in: Exchange Website (News->Announcement -> Search BBTN->Annual Report -> PDF Lampiran 5."
Source	Website IDX
C.8.3
Timely filing/release of annual/financial reports	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?
Company Practices 2023-2024	The true and fairness/fair representation of the annual financial statement/reports is affirmed by the BOC's and BOD's. The information is mentioned in: Bank Tabungan Negara Annual Report FY 2023,Page 757
Source	Annual Report FY 2023

C.9 Does the company have a website disclosing up-to-date information on the following
C.9.1
Company website	Financial statements/reports (latest quarterly)
Company Practices 2023-2024	"The quarterly financial reports can be accessed through Bank Tabungan Negara's website. The information is mentioned in: This information is mentioned in: Bank Tabungan Negara Website, Menu Investor Relations - The Company Report - Quarterly Report"
Source	Quarterly Financial Report - Q1 Quarterly Financial Report - Q2 Quarterly Financial Report - Q3 Quarterly Financial Report - Q4 Audit Finance Report FY 2023
C.9.2
Company website	Materials provided in briefings to analysts and media
Company Practices 2023-2024	"The Company has disclosed the materials provided in briefings to analysts and media on its website. The information is mentioned in: Bank Tabungan Negara Website, Menu Investor Relations - Company Presentations - Presentation"
Source	Analyst Meeting Q1 Analyst Meeting Q2 Analyst Meeting Q3 Analyst Meeting Q4
C.9.3
Company website	Downloadable annual report
Company Practices 2023-2024	"The Annual Report of Bank Tabungan Negara can be accessed and downloaded through Bank Tabungan Negara's website. The information is mentioned in: Bank Tabungan Negara Website, Menu Investor Relations - The Company Report - Annual Report"
Source	The Company Report - Annual Report
C.9.4
Company website	Notice of AGM and/or EGM
Company Practices 2023-2024	"The Company has disclosed notice of AGM and EGM on its website which are available for download. The information is mentioned in: Bank Tabungan Negara Website - Menu Investor Relations - GMS - Announcement RUPST 2023"
Source	Announcement of 2023 AGMS
C.9.5
Company website	Minutes of AGM and/or EGM
Company Practices 2023-2024	"The Company has disclosed minutes of AGM and EGM on its website which are available for download. The information is mentioned in: https://www.btn.co.id/sitecore/content/BTN/en/tentang-btn/hubungan-investor/rups"
Source	Minutes of AGM and/or EGM 2023
C.9.6
Company website	Company's constitution (company's by-laws, memorandum and articles of association)
Company Practices 2023-2024	"The Company has disclosed Company's Constitution on its website which are available for download. The information is mentioned in: Bank Tabungan Negara Website,: /en/About/Governance/Company-Culture/Articles of Association"
Source	Articles of Association

C.10
C.10.1
Investor relations	Does the company disclose the contact details (e.g. telephone, fax, and email) of the officer / office responsible for investor relations?
Company Practices 2023-2024	The company has disclosed contact details of the officer/office responsible for investor relations on its website and annual report. Website www.btn.co.id contact Call Center 1500 286 Investor Relations on email: investor_relations@ btn.co.id or telephone to (62-21) 633 6789 ext: 2003. The company also continuously submits information disclosure reports and/ or material facts to the Financial Services Authority and the Indonesia Stock Exchange as well as through the electronic reporting systems: spe.ojk.go.id and idxnet.co.id and the website www.btn.co.id. The information is mentioned in: Bank Tabungan Negara Annual Report FY 2023, Access to Company Information and Data, Page 638.
Source	Annual Report FY 2023

C.1	Transparent ownership structure	Company Practices 2023-2024	Source
C.1.1	Does the information on shareholdings reveal the identity of beneficial owners, holding 5% shareholding or more?	The company has disclosed the information on shareholdings reveal the identity of beneficial owners, holding 5% shareholding or more. The complete disclosure can be found in Table of Composition of Shareholders of 5% or More of Bank BTN as of December 31. The information is mentioned in: Bank Tabungan Negara Annual Report FY 2023, Shareholders Composition 5% or More, page 172.	Annual Report FY 2023
C.1.2	Does the company disclose the direct and indirect (deemed) shareholdings of major and/or substantial shareholders?	The company has disclosed the direct and indirect shareholdings of major shareholders. The information is mentioned in: Bank Tabungan Negara Annual Report FY 2023, Information on The Top 20 Shareholders, Page 170-173.	Annual Report FY 2023
C.1.3	Does the company disclose the direct and indirect (deemed) shareholdings of directors (commissioners)?	"The company has disclosed the direct and indirect shareholdings of directors (commissioners). As of December 2023, there is no indirect share ownership by the Board of Commissioners and Directors of Bank BTN. The information is mentioned in: Bank Tabungan Negara Annual Report FY 2023, Share Ownership by Management, Page 173-174.	Annual Report FY 2023
C.1.4	Does the company disclose the direct and indirect (deemed) shareholdings of senior management?	"The company discloses the direct and indirect shareholdings of Directors on 1 January 2023 and 31 January 2023. As of December 2023, there is no indirect share ownership by the Board of Commissioners and Directors of Bank BTN. The information is mentioned in: Bank Tabungan Negara Annual Report FY 2023, Share Ownership by Management, Page 173-174.	Annual Report FY 2023
C.1.5	Does the company disclose details of the parent/holding company, subsidiaries, associates, joint ventures and special purpose enterprises/ vehicles (SPEs)/ (SPVs)?	As of December 31, 2023 as well as the date this data/information was submitted, The Company does not have any Subsidiaries and/or Associated Entities. Thus, there is no information regarding the names of subsidiaries, associated companies, joint venture companies along with the percentage of share ownership, line of business, total assets, and operating status of subsidiaries, associated companies, joint venture companies. The information is mentioned in: Bank Tabungan Negara Annual Report FY 2023, List of Subsidiaries, Associates and Joint Venture Companies, Page 175.	Annual Report FY 2023

C.2	Transparent ownership structure	Company Practices 2023-2024	Source
Does the company's annual report disclose the following items:
C.2.1	Corporate objectives	"The company's annual report disclose Corporate objectives. The information is mentioned in: Bank Tabungan Negara Sustainability Report FY 2023, Short and Medium Term Strategy, Page 212. Bank Tabungan Negara Annual Report FY 2023, Long-Term Strategy, Page 218.	Annual Report FY 2023 BTN Sustainability Report FY 2023
C.2.2	Financial performance indicators	"The company has disclosed financial performance indicators in the Annual Report 2023. The information is mentioned in: Bank Tabungan Negara Annual Report FY 2023, Financial Ratio, Page 24.	Annual Report FY 2023
C.2.3	Non-financial performance indicator	The company has disclosed the company non-financial performance indicators, such as Customer Satisfaction Index & Market Share, Environmental Performance, Social Performance, and Governance Performance. The information is mentioned in: Bank Tabungan Negara Sustainability Report FY 2023, Sustainability Performance Highlights, Page 6-7 Bank Tabungan Negara Annual Report FY 2023, Market Share, Page 231.	Annual Report FY 2023 BTN Sustainability Report FY 2023
C.2.4	Dividend policy	"The company's annual report discloses dividend policy. The policy basis for dividend distribution was based on the resolution of the ""Annual General Meeting of Shareholders (AGMS) or the Extraordinary General Meeting of Shareholders (EGMS) based on Law no. 40 of 2007 concerning Limited Liability Companies. The amount of Bank BTN dividends was determined at the General Meeting of Shareholders (GMS). Management plans to pay a minimum cash dividend of 20% of net profit each year. The information is mentioned in: Bank Tabungan Negara Annual Report FY 2023, Dividend Policy, Page 305	Annual Report FY 2023
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	"The company has disclosed the Biographical details (at least age, academic qualifications, date of first appointment, relevant experience and any other directorships of listed companies) of all directors/commissioners. The information is mentioned in: Bank Tabungan Negara Annual Report FY 2023, Board of Directors Profile, Page 120-130. Bank Tabungan Negara Annual Report FY 2023, Board of Commissioners Profile, Page 134-142.	Annual Report FY 2023
Corporate Governance Confirmation Statement
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?	"The Annual Report contain a tabular form indicating each principle and guideline and commenting on if they have complied or not with an explanation. The Company always complies with applicable regulations in implementing GCG. It includes referring to the Public Company Governance Guidelines stipulated in OJK Regulation No. 21/POJK.04/2015 and OJK Circular Letter No. 32/SEOJK.04/2015 concerning Public Company Governance Guidelines. The information is mentioned in: Bank Tabungan Negara Annual Report FY 2023, Public Company Governance Implementation Guidelines, Page 684-692."	Annual Report FY 2023

C.3	Remuneration of Members of the Board and Key Executives	Company Practices 2023-2024	Source
C.3.1	Is there disclosure of the fee structure for non-executive directors/commissioners	"The company has dislosed the fee structure for non-executive directors/commissioners. The remuneration structure showing the types and/or short-term, long-term and/or post-employment benefits is as follows: Types of short-term remuneration consist of: Honorarium, Allowances (holidays, transportation), Facilities (health, legal aid) and Tantiem. Types of long-term and/or post-employment remuneration consist of Post-Employment Insurance and can also be given long-term incentives (LTI) as well as Tantiem/work incentives, on which bonuses can be given in addition to long-term rewards (long-term incentives/LTI). The information is mentioned in: Bank Tabungan Negara Annual Report FY 2023, Structure and Amount of Nominal/Remuneration for Each Director and Board of Commissioners, Page 499 - 500.	Annual Report FY 2023
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/commissioners?	The company has disclosed details of the remuneration of non-executive directors/commissioners. The details provided are Salary/Honorarium, Tantiem, Holiday Allowance, Pension Insurance & BPJS Insurance, Housing Allowance, Vehicle Facilities, Health Facilities, Legal Aid Facilities, and other Facilities. This information is mentioned in: Bank Tabungan Negara Annual Report FY 2023, The remuneration components of the Board of Commissioners and Directors, Page 499-501.	Annual Report FY 2023
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?	The company has disclosed remuneration policies/practices (fees, allowances, allowances and other rewards) (i.e. use of incentives and short-term and long-term performance measures) for executive directors and CEOs which refer to Directors Regulation No. 02/PD/HCD/2017 concerning Income of Directors and Board of Commissioners, Implementation of Governance In Providing Remuneration, the remuneration components of the Board of Commissioners and Directors of Bank BTN Apart from that, the scope of the Company's remuneration policy has been adjusted to OJK Regulation Number 5/POJK.03/2015 and OJK Circular Letter Number 40/SEOJK.03/2016 relating to the Implementation of Governance in Providing Remuneration for Commercial Banks, including The principle of prudence in remuneration is based on performance and risk. Remuneration structure indicating the types and/or rewards short term, long term and/or post can be seen in the BTN 2023 annual report page 499, including: Types of short-term remuneration consist of: Honorarium, Allowances (holidays, transportation), Facilities (health,legal aid) and Tantiem. Type of long-term and/or post-employment remunerationconsists of Retirement Insurance and can also be providedlong-term incentives (LTI) as wellTantiem/work incentives, which can be included in the bonusadditionally given in the form of long-term rewards (long term incentive/LTI). This information is mentioned in: Bank Tabungan Negara Annual Report FY 2023, Procedure for Determining The Remuneration for The Board of Directors and Board of Commissioners, Page 498-501. Bank Tabungan Negara Annual Report FY 2023, Structure and Amount of Nominal/Remuneration for Each Director and Board of Commissioner, Page 490-491.	Annual Report FY 2023 Bank Tabungan Negara Annual Report FY 2023
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]?	The company has disclose the total remuneration for BoD and CEO. The total remuneration include salary, bonuses, holiday allowance, retirement insurance and other facilities) This information is mentioned in: Bank Tabungan Negara Annual Report FY 2023, Structure and Amount of Nominal/Remuneration for Each Director and Board of Commissioners, Page 499 - 500.	Annual Report FY 2023

C.4	Disclosure of related party transactions (RPT)	Company Practices 2023-2024	Source
C.4.1	Does the company disclose its policy covering the review and approval of material RPTs?	The company has disclose its policy covering the review and approval of material RPTs in Annual Report, Page 308 and page 315. The policy of providing funds to related parties that contained conflicts of interest was contained in a separate Directors Regulation which stipulated that Bank BTN was prohibited from providing funds to related parties without the approval of the Board of Commissioners. Also, in the Annual Report 2023, page 315 states that All transactions have gone through a review mechanism according to the type of transaction. The company has provisions related to RPT which include, among others: The Board of Commissioners has the authority to give approval for actions included in material transactions as determined by laws and regulations in the Capital Market sector with a certain amount determined by the Board of Commissioners unless the action is included in material transactions which are excluded by the applicable Laws and Regulations. in the field of Capital Markets. (Articles of Association article 12 paragraph 7 letter j and Board Manual article 6 paragraph 3 letter i) The review process for RPT transactions includes the provision of credit. This information is mentioned in: Bank Tabungan Negara Annual Report FY 2023, Information on Material Transactions Containing Conflicts of Interest and/or Transactions with Affiliates Parties, Page 308. Bank Tabungan Negara Annual Report FY 2023, Transaction Review Mechanism Policy, Page 315.	Annual Report FY 2023 Annual Report FY 2023 Information on Material Transactions Transaction Review Mechanism Policy
C.4.2	Does the company disclose the name, relationship, nature and value for each material RPTs?	The company has disclosed the name, relationship, nature for each material RPTs. As stated in Annual Report 2023 page 313-315 that Related party transactions occur due to the Company’s business needs. All transactions were carried out normally and fairly (arm’s length transactions) as transactions with other parties. The Company guarantees that all transactions are free from conflicts of interest and comply with applicable laws and regulations. Moreover, the details of the realization of related party transactions due to ownership relationships with the Government of the Republic of Indonesia and related party transactions with Key Management can be found in Annual Report page 309 This information is mentioned in: Bank Tabungan Negara Annual Report FY 2023, Realization of Related Party Transactions, Page 315.	Annual Report FY 2023 Realization of Related Party Transactions Related Party Transactions Information on Material Transactions

C.4

Disclosure of related party transactions (RPT)

Company Practices 2023-2024

Source

C.4.1

Does the company disclose its policy covering the review and approval of material RPTs?

The company has disclose its policy covering the review and approval of material RPTs in Annual Report, Page 308 and page 315.

The policy of providing funds to related parties that contained conflicts of interest was contained in a separate Directors Regulation which stipulated that Bank BTN was prohibited from providing funds to related parties without the approval of the Board of Commissioners. Also, in the Annual Report 2023, page 315 states that All transactions have gone through a review mechanism according to the type of transaction.

The company has provisions related to RPT which include, among others:

The Board of Commissioners has the authority to give approval for actions included in material transactions as determined by laws and regulations in the Capital Market sector with a certain amount determined by the Board of Commissioners unless the action is included in material transactions which are excluded by the applicable Laws and Regulations. in the field of Capital Markets. (Articles of Association article 12 paragraph 7 letter j and Board Manual article 6 paragraph 3 letter i)
The review process for RPT transactions includes the provision of credit.

This information is mentioned in:

Bank Tabungan Negara Annual Report FY 2023, Information on Material Transactions Containing Conflicts of Interest and/or Transactions with Affiliates Parties, Page 308.
Bank Tabungan Negara Annual Report FY 2023, Transaction Review Mechanism Policy, Page 315.

Annual Report FY 2023

Information on Material Transactions

Transaction Review Mechanism Policy

C.4.2

Does the company disclose the name, relationship, nature and value for each material RPTs?

The company has disclosed the name, relationship, nature for each material RPTs. As stated in Annual Report 2023 page 313-315 that Related party transactions occur due to the Company’s business needs. All transactions were carried out normally and fairly (arm’s length transactions) as transactions with other parties. The Company guarantees that all transactions are free from conflicts of interest and comply with applicable laws and regulations.

Moreover, the details of the realization of related party transactions due to ownership relationships with the Government of the Republic of Indonesia and related party transactions with Key Management can be found in Annual Report page 309

This information is mentioned in:
Bank Tabungan Negara Annual Report FY 2023, Realization of Related Party Transactions, Page 315.

Annual Report FY 2023

Realization of Related Party Transactions

Related Party Transactions

Information on Material Transactions

C.5	Directors and commissioners dealings in shares of the company	Company Practices 2023-2024	Source
C.5.1	Does the company disclose trading in the company's shares by insiders?	The company has disclosed trading in the company shares by insiders. As 2023, there are 9 members of BOD holding shares. The table of Share Ownership of the Board of Commissioners and Directors of Bank BTN as of January 01, 2023 and as of December 31, 2023. This information is mentioned in: Bank Tabungan Negara Annual Report FY 2023, Shareholding by The Directors and Commissioners, Page 173-174.	Annual Report FY 2023

C.6	External auditor and Auditor Report	Company Practices 2023-2024	Source
Where the same audit firm is engaged for both audit and non-audit services
C.6.1	Are the audit and non-audit fees disclosed?	The Company has disclosed the audit and non-audit fees. The total costs incurred for the implementation of audit services on Bank BTN by KAP Purwantono, Sungkoro & Surja with audit fee of Rp4.800.000.000,- Fees and Other Services Provided by Accountants During 2023, there is no other services provided by accountants. This information is mentioned in: Bank Tabungan Negara Annual Report FY 2023, Fees and Other Services Provided by Accountants, Page 605.	Annual Report FY 2023
C.6.2	Does the non-audit fee exceed the audit fees?	The non - audit fee does not exceed the audit fee because Accounting Firms do not provide other services besides the scope of audit services. Fees and Other Services Provided by Accountants. During 2023, there is no other services provided by accountants. This information is mentioned in: Bank Tabungan Negara Annual Report FY 2023, Fees and Other Services Provided by Accountants, Page 605.	Annual Report FY 2023

C.7	Medium of communications	Company Practices 2023-2024	Source
Does the company use the following modes of communication?
C.7.1	Quarterly reporting	"The Company published its Quarterly Report through Stock Exchange's website and Bank Tabungan Negara's Website in Quarterly Report . The information is mentioned in: This information is mentioned in: Bank Tabungan Negara Website, Menu Investor Relations - The Company Report - Quarterly Report"	Quarterly Financial Report - Q1 Quarterly Financial Report - Q2 Quarterly Financial Report - Q3 Quarterly Financial Report - Q4 Audit Finance Report FY 2023
C.7.2	Company website	"The company uses Company Website as medium of communication. The information is mentioned in: Bank Tabungan Negara Website, www.btn.co.id"	Website BTN
C.7.3	Analyst's briefing	"The company prepares Analyst's Meeting as a medium of communication. Such information may be accessed through Bank Tabungan Negara The information is mentioned in: This information is mentioned in: Bank Tabungan Negara Website, Menu Investor Relations - Company Presentations - Presentation"	Analyst Meeting Q1 Analyst Meeting Q2 Analyst Meeting Q3 Analyst Meeting Q4
C.7.4	Media briefings/press conferences	The company invites media/press to conduct media briefings/press conference during 2023. The evidence of media briefings and press conference can be found in our websites. Website Bank : https://www.btn.co.id/en/About/Gallery/News/Press-Conference This information is mentioned in: Bank Tabungan Negara Annual Report FY 2023, Access to Company Information and Data, Page 638-647	Annual Report FY 2023 Press Conference 2023

C.8	Timely filing/release of annual/financial reports	Company Practices 2023-2024	Source
C.8.1	Are the audited annual financial report / statement released within 120 days from the financial year end?	"The company's audited annual financial statements was issued and submitted to IDX (at 12 February 2024 -> 43 days from the financial year end). This information is mentioned in: Exchange website (News->Announcement -> Search BBTN->Financial Report->PDF Lampiran 5)."	Website IDX
C.8.2	Is the annual report released within 120 days from the financial year end?	"The Company has released its annual report within 120 days from the financial year end. It submitted to IDX at 13 February 2024 (44 days from the financial year end). The information is mentioned in: Exchange Website (News->Announcement -> Search BBTN->Annual Report -> PDF Lampiran 5)."	Website IDX
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?	The true and fairness/fair representation of the annual financial statement/reports is affirmed by the BOC's and BOD's. The information is mentioned in: Bank Tabungan Negara Annual Report FY 2023, Page 757	Annual Report FY 2023

C.9	Company website	Company Practices 2023-2024	Source
Does the company have a website disclosing up-to-date information on the following
C.9.1	Financial statements/reports (latest quarterly)	"The quarterly financial reports can be accessed through Bank Tabungan Negara's website. The information is mentioned in: This information is mentioned in: Bank Tabungan Negara Website, Menu Investor Relations - The Company Report - Quarterly Report"	Quarterly Financial Report - Q1 Quarterly Financial Report - Q2 Quarterly Financial Report - Q3 Quarterly Financial Report - Q4 Audit Finance Report FY 2023
C.9.2	Materials provided in briefings to analysts and media	"The Company has disclosed the materials provided in briefings to analysts and media on its website. The information is mentioned in: Bank Tabungan Negara Website, Menu Investor Relations - Company Presentations - Presentation"	Analyst Meeting Q1 Analyst Meeting Q2 Analyst Meeting Q3 Analyst Meeting Q4
C.9.3	Downloadable annual report	"The Annual Report of Bank Tabungan Negara can be accessed and downloaded through Bank Tabungan Negara's website. The information is mentioned in: Bank Tabungan Negara Website, Menu Investor Relations - The Company Report - Annual Report"	The Company Report - Annual Report
C.9.4	Notice of AGM and/or EGM	"The Company has disclosed notice of AGM and EGM on its website which are available for download. The information is mentioned in: Bank Tabungan Negara Website - Menu Investor Relations - GMS - Announcement RUPST 2023"	Announcement of 2023 AGMS
C.9.5	Minutes of AGM and/or EGM	"The Company has disclosed minutes of AGM and EGM on its website which are available for download. The information is mentioned in: https://www.btn.co.id/sitecore/content/BTN/en/tentang-btn/hubungan-investor/rups"	Minutes of AGM and/or EGM 2023
C.9.6	Company's constitution (company's by-laws, memorandum and articles of association)	"The Company has disclosed Company's Constitution on its website which are available for download. The information is mentioned in: Bank Tabungan Negara Website,: /en/About/Governance/Company-Culture/Articles of Association"	Articles of Association

C.10	Investor relations	Company Practices 2023-2024	Source
C.10.1	Does the company disclose the contact details (e.g. telephone, fax, and email) of the officer / office responsible for investor relations?	The company has disclosed contact details of the officer/office responsible for investor relations on its website and annual report. Website www.btn.co.id contact Call Center 1500 286 Investor Relations on email: investor_relations@ btn.co.id or telephone to (62-21) 633 6789 ext: 2003. The company also continuously submits information disclosure reports and/ or material facts to the Financial Services Authority and the Indonesia Stock Exchange as well as through the electronic reporting systems: spe.ojk.go.id and idxnet.co.id and the website www.btn.co.id. The information is mentioned in: Bank Tabungan Negara Annual Report FY 2023, Access to Company Information and Data, Page 638.	Annual Report FY 2023

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Part C - Disclosure and Transparency