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A. Right of Shareholders

Part	Items	BMRI Practice Year 2020	Source Information
A.1 Basic Shareholder Rights
	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.	Interim Dividend: Bank Mandiri didn't distribute interim dividend Script Dividend: Bank Mandiri didn't distribute script dividend Final Dividend: Bank Mandiri paid for dividend for less than 30 calendar days. days from performance of the Annual General Meeting of Sharholders (AGMS), as follows: Date to AGMS: 15 Maret 2021 Payment Date : 12 April 2021 as mentioned under Bank Mandiri 2021 AGMS Result, 3rd column Annual Report FY 2020, page 402-403	Bank Mandiri 2021 AGMS Annual Report Bank Mandiri FY 2020
A.2 Right to Participate in decisions concerning fundamental corporate changes
A.2.1	Amendments to the company's constitution?	Shareholders have the right to participate in the amendments to the company's constitution through GMS as stated in : Articles of Association of Bank Mandiri FY 2021, Article 28, section 2 (page 107) Articles of Association of Bank Mandiri FY 2021, Article 25, section 5 (page 99)	Articles of Association of Bank Mandiri FY 2021, Article 28 Articles of Association of Bank Mandiri FY 2021, Article 25
A.2.2	The authorisation of additional shares?	Shareholders have the right to participate in the authorization of additional shares as stated in : Articles of Association of Bank Mandiri FY 2021, Article 4, section 5 (page 6)	Articles of Association of Bank Mandiri FY 2021, Article 4
A.2.3	The transfer of all or substantially all assets, which in effect results in the sale of the company?	Shareholders have the right to participate in the transfer of all or substantially assets, whic in effect results in the sale of company as stated in : Articles of Association of Bank Mandiri FY 2018, Article 12, section 10 (page 58)	Articles of Association of Bank Mandiri FY 2018, Article 12
A.3 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.3.1	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?	GMS determines remuneration and honorarium for fiscal year 2021 and performance tantieme (bonus) for Fiscal Year ended on December 31, 2020 for members of Board of Directors and Board of Commissioners of the Company, as mentioned under : Bank Mandiri 2021 AGMS Result, 3rd Agenda. Bank Mandiri 2021 AGMS Highlight, 3rd Agenda.	Bank Mandiri 2021 AGMS Result Bank Mandiri 2021 AGMS Highlight
A.3.2	Does the company provide non-controlling shareholders a right to nominate candidates for board of directors/commissioners?	Members of the Board of Directors and Commissioners shall be appointed by the GMS of the candidates nominated by the Shareholders of Series A Dwiwarna shares, of which such nomination shall bind the GMS. Procedure for election of members of Board of Directors/Board of Commissioners shall comply with Regulation of the Minister of State-Owned Enterprise No. No.PER-04/MBU/2009 dated November 16, 2009 regarding Requirements and Procedure For Appointment and Dismissal of Board of Directors of the State-Owned Enterprise the latest amendments which of those regulations are as follows : Regulation of the Minister of State-Owned Enterprise No. No.PER-03/MBU/02/2015 dated February 17, 2015 regarding Requirements and Procedure For Appointment and Dismissal of Board of Directors of the State-Owned Enterprise, Chapter III.C.15 - UKK. Regulation of the Minister of State-Owned Enterprise No. No.PER-02/MBU/02/2015 dated February 17, 2015 regarding Requirements and Procedure For Appointment and Dismissal of Board of Commissioners and Board of Supervision of the State-Owned Enterprise, Chapter III.C.11 - Evaluation. Articles of Association of Bank Mandiri FY 2021, Article 11, section 10 (page 25) Articles of Association of Bank Mandiri FY 2021, Article 14, section 12 (page 52)	- Excerpt of Regulation of the Minister of State-Owned Enterprise No. No.PER-03/MBU/2015, Chapter III.C.15 - Excerpt of Regulation of the Minister of State-Owned Enterprise No. No.PER-02/MBU/2015, Chapter III.C.11 - Regulation of the Minister of State-Owned Enterprise No. No.PER-03/MBU/02/2015 dated February 17, 2015 - Regulation of the Minister of State-Owned Enterprise No. PER-02/MBU/02/2015 dated February 17, 2015 Article of Association of Bank Mandiri FY 2021, Article 11 Article of Association of Bank Mandiri FY 2021, Article 14
A.3.3	Does the company allow shareholders to elect directors/commissioners individually?	Shareholders may elect individual Board of Directors / Board of Commissioners: Articles of Association of Bank Mandiri FY 2021, Article 11, section 10 (page 25) Articles of Association of Bank Mandiri FY 2021, Article 14, section 12 (page 52) Bank Mandiri 2021 AGMS Result, 9th Agenda Bank Mandiri 2021 AGMS Highlight, 9th Agenda	Articles of Association of Bank Mandiri FY 2021, Article 11 Articles of Association of Bank Mandiri FY 2021, Article 14 Bank Mandiri 2021 AGMS Result Bank Mandiri 2021 AGMS Highlight
A.3.4	Does the company disclose the voting procedures used before the start of meeting?	Bank Mandiri has described the voting procedures used before performance of GMS in : Bank Mandiri 2021 AGMS Code of Conduct, point 12 – Voting procedures	Bank Mandiri 2021 AGMS Code of Conduct
A.3.5	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?	In Bank Mandiri 2021 AGMS Minutes has provided information on answers to questions raised by Shareholders at the AGMS	Bank Mandiri 2021 AGMS Minutes
A.3.6	Does the company disclose the voting results including approving, dissenting, and abstaining votes for all resolutions/each agenda item for the most recent AGM?	Bank Mandiri has disclosed the results of the voting including consent, dissenting opinion, and abstention on each agenda, in: Bank Mandiri 2021 AGMS Result Bank Mandiri 2021 AGMS Highlight	Bank Mandiri 2021 AGMS Result Bank Mandiri 2021 AGMS Highlight
A.3.7	Does the company disclose the list of board members who attended the most recent AGM?	Bank Mandiri has disclosed the list of Board of Directors and Board of Commissioners presented at the GMS 2021, in: Bank Mandiri 2021 AGMS Result Bank Mandiri 2021 AGMS Highlight	Bank Mandiri 2021 AGMS Result Bank Mandiri 2021 AGMS Highlight
A.3.8	Does the company disclose that all board members and the CEO (if he is not a board member) attended the most recent AGM?	The Meeting was chaired by Mr Muhamad Chatib Basri as President Commissioner/Independent Commissioner based on resolution of the Meeting of the Board of Commissioners dated 4 March 2021 and attended by members of the Board of Directors and Board of Commissioners , as metioned under: Bank Mandiri 2021 AGMS Result, 1st column, paragraph 2. Bank Mandiri 2021 AGMS Highlight, page 1, paragraph 2	Bank Mandiri 2021 AGMS Result Bank Mandiri 2021 AGMS Highlight
A.3.9	Does the company allow for voting in absentia?	The shareholder either is personally or represented by virtue of a Letter of Proxy reserves the right to attend the GMS, under condition that during the voting, members of Board of Directors, members of Board of Commissioners and employees of the Company shall be prohibited to act as a proxy under GMS. Articles of Association of Bank Mandiri FY 2021, Article 25, section 12, page 102 Bank Mandiri 2021 AGMS Code of Conduct point 12a, page 6	Articles of Association of Bank Mandiri FY 2021 Article 25 Bank Mandiri 2021 AGMS Code of Conduct Bank Mandiri 2021 AGMS Invitation
A.3.10	Did the company vote by poll (as opposed to by show of hands) for all resolutions at the most recent AGM?	In the implementation of voting, each share provides the holder of it to cast 1 (one) vote, as mentioned under: Bank Mandiri 2021 AGMS Code of Conduct, point 11 – Meeting Resolutions Bank Mandiri 2021 AGMS Code of Conduct, point 12c, page 6 – Voting Procedures Articles of Association of Bank Mandiri FY 2021, article 25, section 10, page 102	Bank Mandiri 2021 AGMS Code of Conduct Articles of Association of Bank Mandiri FY 2021, Article 25
A.3.11	Does the company disclose that it has appointed an independent party (scrutineers/inspectors) to count and/or validate the votes at the AGM?	Bank Mandiri has disclosed the appointment of the independent party namely the Notary Utiek R. Abdurachman SH., MLI., MKN and PT Datindo Entrycom for the purpose of vote counting : Bank Mandiri 2021 AGMS Result, 1st column Bank Mandiri 2021 AGMS Highlight, page 3	Bank Mandiri 2021 AGMS Result Bank Mandiri 2021 AGMS Highlight
A.3.12	Does the company make publicly available by the next working day the result of the votes taken during the most recent AGM for all resolutions?	Bank Mandiri has published voting results under 2021 GMS within 1 (one) business day after Performance to AGMS on the date of 16 March 2021. (Bank Mandiri 2021 AGMS Highlight)	Bank Mandiri 2021 AGMS Highlight
A.3.13	Do companies provide at least 21 days notice for all AGMs and EGMs?	Announcement of 2021 AGMS: 4 February 2021 Summons for 2021 AGMS: 19 February 2021 Performance of 2021 AGMS: 15 March 2021 Based on the aforementioned information, Summons for AGMS made within 24 calendar days before performance of GMS (more than 21 calendar days.) Bank Mandiri 2021 AGMS Announcement Bank Mandiri 2021 AGMS Invitation	Bank Mandiri 2021 AGMS Announcement Bank Mandiri 2021 AGMS Invitation
A.3.14	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?	Bank Mandiri has prepared explanation to each agenda requiring Shareholders’ approval under: Bank Mandiri 2021 AGMS Invitation - Meeting Agenda Bank Mandiri 2021 AGMS List of Supporting Material for Agenda	Bank Mandiri 2021 AGMS Invitation Bank Mandiri 2021 AGMS List of Supporting Material for Agenda
A.3.15	Does the company give the opportunity for shareholder to place item/s on the agenda of AGM?	In the agenda of the Annual GMS, may be included a proposal proposed by the Board of Commissioners and/or a Shareholder or more representing at least 1/20 (one-twentieths) of the total shares issued by the Company with the valid voting rights, provided that the relevant proposal shall be received by the Board of Directors no later than 7 (seven) days prior to the notice of the Annual GMS. Articles of Association FY 2021, Article 23 Section 6 (page 80-81)	Articles of Association Bank Mandiri FY 2021, Article 23
A.4 Markets for corporate control should be allowed to function in an efficient and transparent manner
A.4.1	In cases of mergers, acquisitions and/or takeovers requiring shareholders approval, does the board of directors/commissioners of the offeree company appoint an independent party to evaluate the fairness of the transaction price?	Bank Mandiri has disclosed information related to Investment, Expansion, Divestment, Acquisition and/or Restructuring of Debt/Capital in the Annual Report of Bank Mandiri, stated that the engagement of third party’s services to asses fairness of Investment, Acquisition, Divestment and Restructuring transactions made subject to the capital market applicable provisions. (Annual Report Bank Mandiri FY 2020, page 398)	Annual Report Bank Mandiri FY 2020
A.5 The exercise of ownership rights by all shareholders, including institutional investors, should be facilitated.
A.5.1	Does the company disclose its practices to encourage shareholders to engage with the company beyond AGM?	In order to provide fast and accurate information and become a media link between companies and capital market players, the Company has formed a work unit called Investor Relations. With the provision of accurate and accurate data, it is expected to be able helping capital market players in the investment decisionmaking process in the Company including to instill perceptions and expectations in the eyes of investors and potential investors regarding the Company’s strategy, operational performance and financial performance. In 2020, Bank Mandiri held several event related to Relations Activity : Investor Confrence (3 times, Jakarta & Singapore) Virtual Investor Confrence (13 times, Jakarta) Non Deal Roadshow (1 times, UK/ Europe) Virtual Non Deal Roadshow (2 times, Jakarta) Adhoc Investor Meeting Teleconfrence (±100 times, Jakarta) Quarterly Earnings Call/ Analyst Meeting (4 times, Jakarta) Review Meeting with Credit Rating Agencies (2 times, Jakarta) The information is mentioned in: Activities in Investor Relations during 2020 (Annual Report Tahun 2020, page 802 - 803) Menu Investor Relations (Bank Mandiri Website – Menu Investor Relations)	Annual Report Bank Mandiri FY 2020 Bank Mandiri Website

B. Equitable Treatment of Shareholder

Part	Items	BMRI Practice Year 2020	Source Information
B.1 Shares and voting rights
B.1.1	Do the company's ordinary or common shares have one vote for one share?	In the implementation of voting, each share provides the holder to cast 1 (one) vote, as mentioned in: Bank Mandiri 2021 AGMS Code of Conduct Bank Mandiri 2021 AGMS Power of Attorney Articles of Association of Bank Mandiri FY 2021 Article 25, section 10 and 12 (page 102) Annual Report FY 2020, page 563	Bank Mandiri 2020 AGMS Code of Conduct Bank Mandiri 2020 AGMS Power of Attorney Articles of Association of Bank Mandiri FY 2021, Article 25 Annual Report Bank Mandiri FY 2020
B.1.2	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)?	Bank Mandiri’s shares are registered shares and are issued on behalf of the owner as registered in the Shareholders Register consisting of Series A Dwiwarna share that specifically can only be owned by the State of The Republic of Indonesia and Series B shares which may be owned by the public. The Company only acknowledges one person (individual person or legal entity) as the holder of 1 (one) share or more. The information is mentioned in: Articles of Association FY 2021, Article 5 Section 1 (page 9) Annual Report Bank Mandiri FY 2020 page 563	Articles of Association of Bank Mandiri FY 2021, Article 5 Annual Report Bank Mandiri FY 2020
B.2 Notice of AGM
B.2.1	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?	Each determination for agenda is not related to determination of other agendas. Bank Mandiri 2021 AGMS Result Bank Mandiri 2021 AGMS Highlight	Bank Mandiri 2021 AGMS Result Bank Mandiri 2021 AGMS Highlight
B.2.2	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?	Summons for 2021 AGMS is made in counterparts, in Indonesian and English languages, as well as published on the same date (19 February 2021) Bank Mandiri 2021 AGMS Agenda (Indonesia & English) Bank Mandiri 2021 AGMS Announcement (Indonesia & English)	Bank Mandiri 2020 AGMS Invitation (Indonesia) Bank Mandiri 2020 AGMS Invitation (English) Bank Mandiri 2020 AGMS Announcement (Indonesia) Bank Mandiri 2020 AGMS Announcement (English)
B.2.3	Are the profiles of directors/commissioners ( at least age, academic qualification, date of first appointment, experience, and directorships in other listed companies) in seeking election/re-election included?	Profile of prospective member of Board of Commissioners and Board of Directors shall be presented during performance to AGMS. Bank Mandiri 2021 AGMS List of Supporting Material for Agenda, 5th agenda Bank Mandiri 2021 AGMS Announcement	Bank Mandiri 2021 AGMS List of Supporting Material for Agenda Bank Mandiri 2021 AGMS Announcement
B.2.4	Are the auditors seeking appointment/re-appointment clearly identified?	Bank Mandiri appointed Public Accounting Firm Purwantono, Sungkoro & Surja to audit the Consolidated Financial Statements of the Company and Annual Partership and Community Development Program Report for the Financial Year ended on 31 Desember 2019, as mentioned in : Bank Mandiri 2020 Attachment to AGM Supporting Materials, Agenda 4 Bank Mandiri 2020 AGMS Invitation	Bank Mandiri 2020 List of Supporting Material for Agenda Bank Mandiri 2020 AGMS Invitation
B.2.5	Were the proxy documents made easily available?	Document of power of attorney from Shareholders may be downloaded in Bank Mandiri website and may be obtained at the Company’s share registrar office during office hours. Bank Mandiri 2021 Invitation of the AGMS Bank Mandiri 2021 Power of Attorney	Bank Mandiri 2021 Invitation of the AGMS Bank Mandiri 2021 Power of Attorney
B.3 Insider trading and abusive self-dealing should be prohibited
B.3.1	Does the company have policies and/or rules prohibiting directors/commissioners and employees to benefit from knowledge which is not generally available to the market?	Bank officials possessing the confidential information shall not misuse such information for their personal, their families or other third parties advantages. as mentioned in: Management of the BOC’s Conflict of Interest - Annual Report FY 2020, page 594 Management of the Board of Directors Conflict of Interest - Annual Report FY 2020, page 632 The Content of The Code of Conduct - Annual Report FY 2020, page 813-816 Prevention of Insider Trading - Annual Report FY 2020, page 834	Management of the BOC’s Conflict of Interest Management of the Board of Directors Conflict of Interest The Content of The Code of Conduct Prevention of Insider Trading
B.3.2	Are the directors / commissioners required to report their dealings in company shares within 3 business days?	With reference to Regulation of the Financial Service Authority (POJK) No. 60/POJK.04/2015 concerning Disclosure of Shareholder’s Information, where the Board of Directors or Board of Commissioners of Public Company will be under obligation to report to Financial Services Authority for ownership and any changes to ownership of Public Company's shares no later than 10 (ten) days after the transaction. During 2020, there had been 19 trading transactions of Bank Mandiri’s share conducted by Bank Mandiri’s members of Board of Directors and Board of Commissioner. Those transaction had been reported to OJK. (Annual Report FY 2019, page 156-157)	Annual Report Bank Mandiri FY 2020
B.4 Related party transactions by directors and key executives
B.4.1	Does the company have a policy requiring directors /commissioners to disclose their interest in transactions and any other conflicts of interest?	Bank Mandiri has policy stipulating the disclosure by Board of Directors and Board of Commissioners regarding conflict of interest stated in GCG Charter. GCG Charter, point. C - Conflict of Interest number 2 & 3, page 18. Annual Report of Bank Mandiri FY 2019, page 475 and 513	GCG Charter Management of the BOC’s Conflict of Interest Management of the Board of Directors Conflict of Interest
B.4.2	Does the company have a policy requiring a committee of independent directors/commissioners to review material/significant RPTs to determine whether they are in the best interests of the company and shareholders?	Transaction Policies with the Related Parties of Bank Mandiri are as follows: The restructured credits to the Related Parties must be be analyzed / reviewed by the certified and reputable an independent financial consultant. (Bank Mandiri Website - Menu GCG - Governance Document - Transaction Policy with Related Parties, page 4, points 5 and 6) Referring to Bank Mandiri’s internal policies regarding credit disbursement, the provision of funds to related parties (individuals or groups, including executive officers, Board of Directors and Commissioners of the Bank) has been fairly performend reasonably with the approval of the Board of Commissioners. (Annual Report FY 2020, page 415)	Transaction Policy with Related Parties Annual Report Bank Mandiri FY 2020
B.4.3	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?	Bank Mandiri determines policies specifying: Each member of the Board of Directors who is personally in any way whatsoever, either directly or indirectly, has interest in a transaction, contract or a proposed contract in which matter the Company is a party, must declared in the Board of Directors Meeting and accordingly has no right to cast a vote concerning the matters in relation to the such transaction or contract. Each member of the Board of Commissioners who is personally in any way whatsoever, either directly or indirectly, has interest in a transaction, contract or a proposed contract in which matter the Company is a party must be declared in the Board of Commissioners Meeting and accordingly has no right to cast a vote concerning matters in relation to such transaction or contract. as mentioned in: Articles of Association of Bank Mandiri FY 2021, Article 13, section 22 (page 49) Articles of Association of Bank Mandiri FY 2021, Article 16, section 21 (page 66) Charter of Board of Commissioners Article 5 section 3, and 11 section 9 Charter of Board of Directors, Article 6 and 11 section 3	Articles of Association of Bank Mandiri, Article 13 Articles of Association of Bank Mandiri, Article 16 Charter of Board of Commissioners Charter of Board of Directors
B.4.4	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?	Bank Mandiri determines policies specifying: Bank Mandiri has internal policies related to transactions containing conflict of interest and/or transactions with affiliates. The policy of providing funds to related parties shall not be contrary to the general procedure of granting the provision of funds in force and shall continue to provide a reasonable benefit to the company, the provision shall also be subject to the approval of the Board of Commissioners. Policy: Loan Policy of Board of Directors Loan Policy of Board of Commissioners Practice: Loan Policy for the Board of Commissioners and Directors - Annual Report of Bank Mandiri FY 2020 page 415	Loan Policy of Board of Commissioners Loan Policy of Board of Directors Loan Policy for the Board of Commissioners and Directors
B.5 Protecting minority shareholders from abusive actions
B.5.1	Does the company disclose that RPTs are conducted in such a way to ensure that they are fair and at arms' length?	Bank Mandiri and Subsidiaries have transactions with related parties as defined in SFAS 7, “Related Party Disclosures” and Regulation of the Financial Services Authority (formerly Bapepam-LK) or POJK No. KEP-347/BL/2012 dated June 25, 2012 on the “Presentation of Financial Statements of Public Company”. All transactions conducted in 2020 were performed fairly and were in accordance with normal commercial requirements. Fairness of transactions with related parties or containing conflicts of interest has been carried out fairly according to the laws and regulations. Transactions were conducted on the behalf of the Company’s needs and were free from conflicts of interest. During 2020 there were no related party transactions requiring GMS approval. (Annual Report of Bank Mandiri FY 2020, page 414)	Rights and Reasons
B.5.2	In case of related party transactions requiring shareholders approval, is the decision made by disinterested shareholders?	During 2020 there shall be no Related Party Transactions requiring approval from GMS. There were also no conflict of interest transactions as mentioned in BAPEPAM LK Regulation No. IX.E.1 on Conflict of Interest. Transaction Policy with the Related Parties - Bank Mandiri Website Annual Report of Bank Mandiri FY 2020, page 407-413, 415, 833-834	Transaction Policy with the Related Parties Transaction Containing Conflict of Interest

C. Role of Stakeholders

Part	Items	BMRI Practice Year 2020	Source Information
C.1 The rights of stakeholders that are established by law or through mutual agreements are to be respected. (Does the company disclose a policy AND PRACTICES that ADDRESS)
C.1.1	The existence and scope of the company's efforts to address customers' welfare?	Policy and Implementation: Corporate Social Responsibilities to Customers - Annual Report of Bank Mandiri FY 2020, page 894-899 Stakeholder Engagement - Sustainability Report of Bank Mandiri FY 2017, page 139-141 Company's Product: Bank Mandiri Website - Individual Menu Bank Mandiri Website - Business Menu Bank Mandiri Website - Priority Menu	Corporate Social Responsibilities to Customers Stakeholder Engagement Individual Menu Business Menu Priority Menu
C.1.2	Supplier/contractor selection procedures?	Procurement of Goods and Services According To Ethics and Basic Principles of Procurement of Goods and Services - Annual Report of Bank Mandiri FY 2020, page 875-879 Procurement Policy - Bank Mandiri Website	Corporate Social Responsibilities to Suppliers Procurement Policy
C.1.3	The company's efforts to ensure that its value chain is environmentally friendly or is consistent with promoting sustainable development?	Policy and Implementation: Corporate Social Responsibilities to he Environment (Annual Report of Bank Mandiri FY 2020 page 880-886)	Corporate Social Responsibilities Related to the Environment
C.1.4	The company's efforts to interact with the communities in which they operate?	Policy and Implementation : Corporate Social Responsibilities Related to Social and Community Development - Annual Report of Bank Mandiri FY 2019, page 900-905	Corporate Social Responsibilities Related to Social and Community Development
C.1.5	The company's anti-corruption programmes and procedures?	Implementation of Anti-Corruption Strategy: Anti Fraud Strategy Application - Annual Report of Bank Mandiri FY 2020, page 47 Anti Corruption Program - Annual Report of Bank Mandiri FY 2020, page 817 Gratifcation Reporting Mechanism - Annual Report of Bank Mandiri FY 2020, page 818	Anticorruption and antifraud policy (OJK Recommendation) Anti Corruption Program Gratification Reporting Mechanism
C.1.6	How creditors' rights are safeguarded?	Creditor's Rights Policy - Bank Mandiri Website Creditor’s Rights (OJK Recommendation) - Annual Report of Bank Mandiri FY 2020, page 843 Bond's holder rights	Creditor's Rights Policy (website) Creditor’s Rights (OJK Recommendation) Bondholder's Right
C.1.7	Does the company have a separate report/section that discusses its efforts on environment/economy and social issues?	Bank Mandiri has made a separated report discussing contribution of Bank Mandiri in environmental/economic and social management, comprising Sustainability Report that may be downloaded from Bank Mandiri Website. (Bank Mandiri Website)	Sustainability Report Bank Mandiri
C.2 Where stakeholder interests are protected by law, stakeholders should have the opportunity to obtain effective redress for violation of their rights.
C.2.1	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?	Bank Mandiri provides contact details through Bank Mandiri's website or Annual Report, where stakeholders may submit their criticisms and suggestions, as outlined in : Customers Complaint Activities (Annual Report of Bank Mandiri FY 2020, page 895) Contact Us (Bank Mandiri Website)	Customer Complaint Contact Us
C.3 Performance-enhancing mechanisms for employee participation should be permitted to develop.
C.3.1	Does the company explicitly disclose the policies and practices on health, safety and welfare for its employees?	Bank Mandiri has disclosed policies and implementation on employees health, safety and welfare as follows : Process and Policy Human Capital - Annual Report of Bank Mandiri FY 2020, page 526-527 Performance and Reward Management (Bank Mandiri Website - About Mandiri Menu - GCG - Governance Structure - Governance Document - Reward Management) Health Facility Providing Activities - Annual Report of Bank Mandiri FY 2020, page 891) Corporate Social Responsibilities related to Employment, Health and Safety - Annual Re[prt of Bank Mandiri FY 2020, page 887 - 888	Process and Policy Human Capital Performance and Reward Management Health Facility Providing Activities Corporate Social Responsibilities related to Employment, Health and Safety
C.3.2	Does the company explicitly disclose the policies and practices on training and development programmes for its employees?	Bank Mandiri has disclosed Policy and Implementation of employee training and development as follows : Performance and Reward Management (Bank Mandiri Website) Design For Training And Development of Human Capital - Annual Report of Bank Mandiri FY 2020, page 518-519 Profile of Employee Competencies and Development - Annual Report of Bank Mandiri FY 2020, page 144-153	Performance and Reward Management Design for Human Capital Training & Development Competence Development for Employee
C.3.3	Does the company have a reward/compensation policy that accounts for the performance of the company beyond short-term financial measures?	Bank Mandiri has policies regarding reward / compensation based on performance, as included in: Human Capital Management Strategy - Award - Annual Report of Bank Mandiri FY 2020, page 521 Performance and Reward Management - Bank Mandiri Website	Annual Report of Bank Mandiri FY 2020 Performance and Reward Management
C.4 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.
C.4.1	Does the company have a whistleblowing policy which include procedures for complaints by employees and other stakeholders concerning illegal and unethical behaviour and provide contact details via the company's website or annual report?	Bank Mandiri has owned and disclosed the policy regarding: Whistleblowing System (Bank Mandiri Website) Implementation of Whistleblowing System and Code of Conduct (Annual Report of Bank Mandiri FY 2020, page 874) Whistleblowing System (Annual Report of Bank Mandiri FY 2020, page 819-821) The Management of Gratification Control (Annual Report of Bank Mandiri FY 2020, page 817 - 818) Whistle blowing System Policy regulating: Management of Whistleblowing System Submission of Violation Reports and Handling of Complaints Protection for Whistleblower Types of Violation to be Reported LTC Mechanism	Whistleblowing System (web) Whistleblowing System (AR) Management of Gratification Control Implementation of Whistleblowing System and Code of Conduct
C.4.2	Does the company have a policy or procedures to protect an employee/person who reveals illegal/unethical behaviour from retaliation?	Bank Mandiri has established procedures for protection of employees reporting activities that violate code of ethics as included in : Whistle blowing System (Bank Mandiri Website) Protection for Whistleblower - Annual Report of Bank Mandiri FY 2020, page 820	Whistle blowing System Protection for Whistleblower

D. Disclosure and Transparency

Part	Items	BMRI Practice Year 2020	Source Information
D.1 Transparent Ownership Structure
D.1.1	Does the information on shareholdings reveal the identity of beneficial owners, holding 5% shareholding or more?	Information regarding identities the of the shareholders has been disclosed in the Annual Report of Bank Mandiri FY 2020 regarding Shareholder Composition (Annual Report of Bank Mandiri FY 2020 , pages 154-155)	Shareholders' Composition
D.1.2	Does the company disclose the direct and indirect (deemed) shareholdings of major and/or substantial shareholders?	Bank Mandiri has disclosed information regarding Shareholders as referred to in the Annual Report of Bank Mandiri FY 2020 regarding Shareholder Composition Shareholders’ Composition - Annual Report of Bank Mandiri FY 2020 , pages 154-155	Shareholders’ Composition
D.1.3	Does the company disclose the direct and indirect (deemed) shareholdings of directors (commissioners)?	Bank Mandiri has disclosed information regarding share ownership and options of Board of Directors / Board of Commissioners in the Annual Report of Bank Mandiri FY 2020. Board of Commissioners’ and Board of Directors’ Shareholding - Annual Report of Bank Mandiri FY 2020 , page 156 Stock Ownership of the Board of Commissioners - Annual Report of Bank Mandiri FY 2020 , page 595 Stock Ownership of the Board of Directors - Annual Report of Bank Mandiri FY 2020 , page 632- 633	Board of Commissioners’ and Board of Directors’ Shareholding Stock Ownership of the Board of Commissioners Stock Ownership of the Board of Directors
D.1.4	Does the company disclose the direct and indirect (deemed) shareholdings of senior management?	Bank Mandiri has disclosed information regarding share ownership and options of Board of Directors / Board of Commissioners in the Annual Report of Bank Mandiri FY 2020. Employee Stock Option Program (ESOP)/Management Stock Option Program (MSOP) - Annual Report of Bank Mandiri FY 2020 , page 403-404)	ESOP/MSOP
D.1.5	Does the company disclose details of the parent/holding company, subsidiaries, associates, joint ventures and special purpose enterprises/ vehicles (SPEs)/ (SPVs)?	Bank Mandiri has disclosed information regarding the structure of Bank Mandiri's group of companies in the Annual Report FY 2020, as mentioned under: Company Group Structure - Annual Report of Bank Mandiri FY 2020 , page 166 - 167 Names and Addresses of Subsidiaries, Associates, Overseas Branch Offices, and Regional Offices - Annual Report of Bank Mandiri FY 2020 , page 196 - 199	Company Group Structure Names and Addresses of Subsidiaries, Associates, Overseas Branch Offices, and Regional Offices
D.2 Quality of Annual Report Does the company's annual report disclose the following item :
D.2.1	Corporate objectives	Company Vision, Missions, and Culture - Annual Report of Bank Mandiri FY 2020, page 102-105 Company Strategy - Annual Report of Bank Mandiri FY 2020, pages 221-223	Vision, Mission and Corporate Culture Company Strategy
D.2.2	Financial performance indicators	Financial Highlights - Annual Report of Bank Mandiri FY 2020, pages 22-27 Market Share - Annual Report of Bank Mandiri FY 2020, pages 221-223 Financial Review - Annual Report of Bank Mandiri FY 2020, pages 288-321	Financial Highlights Market Share Financial Review
D.2.3	Non-financial performance indicators	Operational Highlights - Annual Report of Bank Mandiri FY 2020, pages 25 - 27 Corporate Governance Perception Index - Annual Report of Bank Mandiri FY 2020, page 848-850 ASEAN CG Scorecard Assessment - Annual Report of Bank Mandiri FY 2020, page 850-851 Customer Satisfaction Result - Annual Report of Bank Mandiri FY 2020, page 898 Market Share - Annual Report of Bank Mandiri FY 2020, page 221-223	Operational Highlight CGPI Assessment ASEAN CG Scorecard Assessment Customer Satisfaction and Experience Survey Result Market Share
D.2.4	Dividend policy	Dividend Policy - Annual Report of Bank Mandiri FY 2020, page 402-403) Dividend Policy (Bank Mandiri Website)	Annual Report Bank Mandiri FY 2020 Bank Mandiri Website
D.2.5	Biographical details (at least age, qualifications, date of first appointment, relevant experience, and any other directorships of listed companies) of directors/commissioners	Board of Commissioners' Profile - Annual Report of Bank Mandiri FY 2020, page 106-119 Board of Directors Profile - Annual Report of Bank Mandiri FY 2020, page 120-136 Diversity in Composition of the Board of Commissioner - Annual Report of Bank Mandiri FY 2020, page 821-822 Diversity of The Board of Directors - Annual Report of Bank Mandiri FY 2020, page 822-824	Board of Commissioners' Profile Board of Directors Profile Policies on Diversity of Board of Commissioners Director Diversity Policy
D.2.6	Attendance details of each director/commissioner in all directors/commissoners meetings held during the year	Board of Commissioners Meeting (website) Board of Directors Meeting (website)	Board of Commissioners Meeting Board of Directors Meeting
D.2.7	Total remuneration of each member of the board of directors/commissioners	Bank Mandiri has disclosed Total Remuneration for Board of Directors and Board of Commissioners as stated in the Annual Report of Bank Mandiri in Remuneration Policy for the Board of Commissioners and the Board of Directors - Annual Report of Bank Mandiri FY 2020, page 756-763	Annual Report of Bank Mandiri FY 2020
Corporate Governance Confirmation Statement
D.2.8	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?	Statements regarding implementation of Governance have been included in the Annual Report of Bank Mandiri FY 2020 as mentioned in: Statement of Good Corporate Governance Implementation - Annual Report of Bank Mandiri FY 2020, page 851 In addition, Bank Mandiri has included information by reference to FSA regulation regarding Aspect and Principle of Corporate Governance Implementation According to Financial Service Authority (comply or explain) as mentioned in: Aplication of Open Corporate Governance Guidelines - Annual Report of Bank Mandiri FY 2020 page 836-844	Statement of Good Corporate Governance Implementation Application of Public Listed Company Governance Guidelines
D.3 Disclosure of related party transactions (RPT )
D.3.1	Does the company disclose its policy covering the review and approval of material/significant RPTs?	Transaction Policies with the Related Parties of Bank Mandiri are as follows : Secretary of the Credit Committee submit and report on Gross Assets Value requiring for consultation or requesting for approval to Board of Commissioners. Restructured Credits to the Related Parties will be analyzed/reviewed by the certified and reputable financial consultant. (Transaction Policy with Related Parties - Bank Mandiri Website) Referring to Bank Mandiri's internal policy, it is stated that the policy of providing funds to related parties shall not be contrary to the general procedure of granting the provision of funds in force and shall continue to provide a reasonable benefit to the company, the provision shall also be subject to the approval of the Board of Commissioners. (Annual Report of Bank Mandiri FY 2020, page 415)	Transaction Policy with Related Parties Review Mechanism Policy for Transaction And Fulfillment of Related Terms and Conditions
D.3.2	Does the company disclose the name, relationship, nature and value for each significant/material RPTs?	Bank Mandiri has disclosed information about Related Parties Transaction as mentioned in Name and Nature Of Related Relations - Annual Report of Bank Mandiri FY 2020, page 407-413	Name and Nature Of Related Relations
D.4 Does the company disclose trading in the company's shares by insiders?
D.4.1	Does the company disclose trading in the company's shares by insiders ?	Bank Mandiri has disclosed information as referred to in the Annual Report of Bank Mandiri FY 2020, as mentioned in: Board of Directors and Board of Commisioner’s Share Trading (Annual Report of Bank Mandiri FY 2020, page 156 - 157)	Board of Commissioners and Directors’ Share Trading
D.5 External auditor and Auditor Report Where the same audit firm is engaged for both audit and non-audit services
D.5.1	Are the audit and non-audit fees disclosed ?	In 2020 KAP fees amounting to Rp28 billion with details of audit fees on the financial statements worth Rp 13 billion and Rp15 billion the rest for fees of other services provided by the Accountant. (Annual Report of Bank Mandiri FY 2020, page 764)	Audit Fee
D.5.2	Does the non-audit fee exceed the audit fees ?	Non-audit fee amounted to IDR 627 million does not exceed the audit fee that amounted to IDR 28 billion (Annual Report of Bank Mandiri FY 2020, page 764)	Non Audit Fee
D.6 Medium of communications
D.6.1	Quarterly reporting	Bank Mandiri uses Quarterly Financial Report as communication media with the shareholders and stakeholders. Such quarterly reports may be downloaded on Bank Mandiri Website, (Bank Mandiri Website)	Quarterly Financials
D.6.2	Company website	Bank Mandiri uses Company Website as communication medium, which may be accessed through : www.bankmandiri.co.id (Bank Mandiri's Website)	Bank Mandiri Website
D.6.3	Analyst's briefing	Bank Mandiri prepares Analyst's Meeting as a communication medium. Such information may be accessed through Bank Mandiri Website. (Bank Mandiri Website)	Corporate Presentation
D.6.4	Media briefings /press conferences	Bank Mandiri uses press release media as communication medium. The information may be accessed through : Press Release (Annual Report of Bank Mandiri FY 2020, page 808-811) News Release (Bank Mandiri Website)	Press Release News Release
D.7 Timely filing/release of annual/financial reports
D.7.1	Are the audited annual financial report / statement released within 120 days from the financial year end?	Bank Mandiri has published Financial Statement Year 2020 on January 29, 2021 (within 120 days) through : The Print Media Kontan	Kontan
D.7.2	Is the annual report released within 120 days from the financial year end?	Bank Mandiri has published Annual Report FY 2020 through Bank Mandiri Website and Indonesia Stock Exchange Website on 29 January 2021, and has officially determined the Annual Report in GMS on 15 March 2021, as mentioned on: Annual Report (Bank Mandiri Website) IDX Website Bank Mandiri's Letter to OJK Number HBK.CSC/CMA.177/2021 date 19 February 2021, concerning The Submission of Bank Mandiri's Annual Report FY 2020	Bank Mandiri Website IDX Website Bank Mandiri's Letter to OJK Number HBK.CSC/CMA.177/2021 date 19 February 2021
D.7.3	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?	Information as referred to under the Annual Report of Bank Mandiri FY 2020 in: Board of Director's Statement regarding The Responsibility For The Consolidated Financial Statements as at and for the year ended 31 December 2020 (Annual Report of Bank Mandiri FY 2020, page 920)	Board of Director's Statement
D.8 Company website (Does the company have a website disclosing up-to-date information on the following:) Does the company have a website disclosing up-to-date information on the following:
D.8.1	Financial statements/reports (latest quarterly)	Bank Mandiri has disclosed latest quarterly Financial Statements / Reports on Bank Mandiri Website.	Quarterly Financials
D.8.2	Materials provided in briefings to analysts and media	Bank Mandiri disclosed the Information which is provided in Analyst's Meeting available in Bank Mandiri Website.	Corporate Presentations
D.8.3	Downloadable annual report	Bank Mandiri has disclosed Annual Report downloadable in Bank Mandiri Website.	Annual Report
D.8.4	Notice of AGM and/or EGM	Bank Mandiri has disclosed Summons for the AGMS and the Extraordinary General Meeting of Shareholders (EGMS) in Bank Mandiri Website	AGMS EGMS
D.8.5	Minutes of AGM and/or EGM	Bank Mandiri has disclosed Minutes to AGMS and EGMS in Bank Mandiri Website	AGMS EGMS
D.8.6	Company's constitution (company's by-laws, memorandum and articles of association)	Bank Mandiri has disclosed Articles of Association of the Company in Bank Mandiri Website	Articles of Association
D.9 Investor relations
D.9.1	Does the company disclose the contact details (e.g. telephone, fax, and email) of the officer / office responsible for investor relations?	Bank Mandiri has disclosed detail of contact from Investor Relations Unit available at Bank Mandiri Website. Contact Us (Bank Mandiri Website) Company Information and Data Access - Annual Report of Bank Mandiri FY 2020, page 806 Customer Complaint Activities - Annual Report of Bank Mandiri FY 2020, page 895	Contact Us Company Information and Data Access Customer Complaint Activities

E. Responsibilities of the Board

Part	Items	BMRI Practice Year 2020	Source Information
E.1 Board Duties and Responsibilities Clearly defined board responsibilities and corporate governance policy
E.1.1	Does the company disclose its corporate governance policy / board charter?	Bank Mandiri has disclosed Corporate Governance Policy available at : GCG Charter (Bank Mandiri Website) Board Charter Guidelines and Rules For Work (Annual Report Bank Mandiri FY 2020, page 588) Board Charter of The Board of Directors (Annual Report Bank Mandiri FY 2020, pages 623)	GCG Charter Board Charter Guidelines and Rules For Work Board Charter of The Board of Directors
E.1.2	Are the types of decisions requiring board of directors/commissioners' approval disclosed?	Actions taken by Board of directors subject to written approval from Board of Commissioners as included in Articles of Association of Bank Mandiri FY 2021 (Articles of Association of Bank Mandiri FY 2021, Article 12, section 7, page 38-39) Decision that need to be approved by the Board of Commissioners of Bank Mandiri are stipulated in Annual Report Bank Mandiri FY 2020, page 587	Articles of Association, Article 12 Decision that Needs to Agree to the Board of Commissioners
E.1.3	Are the roles and responsibilities of the board of directors/commissioners clearly stated ?	Tasks and responsibilities of Board of Directors / Board of Commissioners are included in : Board Charter of Board of Directors (Annual Report of Bank Mandiri FY 2020, page 622) Charter of Board of Director (Bank Mandiri Website) Duties and responsibilities of Board of Commissioners (Annual Report of Bank Mandiri FY 2020, pages 586) Tasks and Responsibilities of Board of Commissioners, (Bank Mandiri Website)	Duties and Responsibilities of Board of Directors Duties and Responsibilities of Board of Directors (website) Duties and Responsibilities of Board of Commissioners Duties and Responsibilities of Board of Commissioners (website)
Corporate Vision/Mission
E.1.4	Does the company have an updated vision and mission statement?	Vision and Mission of Bank Mandiri are included in the Annual Report of Bank Mandiri FY 2017, page 102-105	Vission & Mission of Bank Mandiri
E.1.5	Does the board directors play a leading role in the process of developing and reviewing the company’s strategy at least annually?	Board of Directors has significant role in company strategic review process within at least annually. Review on Vision and Mission by The Board Commissioner and Director (Annual Report of Bank Mandiri FY 2020, page 104) Review of Company Annual Strategy (Annual Report of Bank Mandiri FY 2020, pages 659) Articles of Association, article 17, section 1 page 67	Review on Vision and Mission by The Board Commissioner and Director Review of Company Annual Strategy Articles of Association, Article 17
E.1.6	Does the board of directors have a process to review, monitor and oversee the implementation of the corporate strategy?	Board of Directors has significant role in company strategic review process within at least annually. Review on Vision and Mission by The Board Commissioner and Director (Annual Report of Bank Mandiri FY 2020, page 104) Review of Company Annual Strategy (Annual Report of Bank Mandiri FY 2020 page 659)	Review on Vision and Mission by The Board Commissioner and Director Review of Company Annual Strategy
E.2 Board Structure Code of Ethics or Conduct
E.2.1	Are the details of the code of ethics or conduct disclosed?	Details regarding Code of Conduct are disclosed in : Code of Conduct (Annual Report of Bank Mandiri FY 2020, pages 813-816) Code of Conduct (Bank Mandiri Website)	Code of Conduct (AR) Code of Conduct (website)
E.2.2	Are all the directors/commissioners, senior management and employees required to comply with the code/s?	All Board of Commissioners, Board of Directors and employees of Bank Mandiri must comply with the basic principles of personal and professional conduct. Annual Report of Bank Mandiri FY 2020, page 815	Compliance with Code of Conduct
E.2.3	Does the company have a process to implement and monitor compliance with the code/s of ethics or conduct?	Bank Mandiri has implementation and monitoring procedures for ethical code compliance to through Disclosure and socialization of ethical codes and Bank Compliance Statement to the Code of Ethics and corporate culture. Annual Report of Bank Mandiri FY 2020, pages 816	Effort in Implementation and Enforcement of The Code of Conduct
Board Structure & Composition
E.2.4	Do Independent directors/ commissioners make up at least 50% of the board of directors/commissioners?	Number and Composition of Board of Commissioners FY 2017 (after changes in composition of Board of Commissioners), indicates that composition of Independent Commissioners is 5 (five) out of 10 eight) or 50% of the members of Board of Commissioners are the Independent Commissioners. Bank Mandiri 2021 AGMS Result Bank Mandiri 2021 AGMS Highlight Annual Report of Bank Mandiri FY 2020, page 589-590	Bank Mandiri 2020 AGMS Result Bank Mandiri 2020 AGMS Highlight Composition and Basis for Board of Commissioners
E.2.5	Does the company have a term limit of nine years or less or 2 terms of five years¹ each for its independent directors/commissioners? ¹ The five years term must be required by legislation which pre-existed the introduction of the ASEAN Corporate Governance Scorecard in 2011	Board of Directors' Term of Office: Law No. 19 of 2003 Indonesia State-Owned Entities, Chapter 16, section 4, stated that The term of office of a member of the Board of Directors shall be 5 (five) years and may be re-appointed for 1 (one) term of office. Board of Commissioners' Term of Office: Law No. 19 of 2003 Indonesia State-Owned Entities, Chapter 28, section 3, stated that The term of office of a member of the Board of Commissioners shall be 5 (five) years and may be re-appointed for 1 (one) term of office. Tenure of Board of Commissioners (Annual Report Bank Mandiri FY 2020, page 587-588) Tenure of the Board of Directors-Annual Report Bank Mandiri FY 2020, page 622-623	Law No. 19 of 2003 Indonesia State-Owned Entities Excerpt of Law No. 19 of 2003 Indonesia State-Owned Entities, Chapter 16 Excerpt of Law No. 19 of 2003 Indonesia State-Owned Entities, Chapter 28 Tenure of Board of Commissioners Tenure of the Board of Directors
E.2.6	Has the company set a limit of five board seats that an individual independent/ non-executive director/commissioner may hold simultaneously	Information related to double positions of Board of Commissioners / Independent Commissioners presented under: Articles of Association of Bank Mandiri FY 2021, Article 14, section 26, page 56-57 Concurrent Position of The Board of Commissioners (Annual Report of Bank Mandiri FY 2020, pages 593-594) Policies on The Board of Directors Concurrent Positions (Annual Report of Bank Mandiri FY 2020, pages 630-631)	Articles of Association, Article 14 Concurrent Position of The Board of Commissioners Policies on The Board of Directors Concurrent Positions
E.2.7	Does the company have the executive directors who serve more than two boards of listed companies outside of the group?	Default by Regulation None of Board of Directors of Bank Mandiri having double positions at the other Public Companies. Article of Association of Bank Mandiri FY 2021, Article 11, section 24, page 29-30 Annual Report of Bank Mandiri FY 2020, pages 592-593 Annual Report of Bank Mandiri FY 2020, pages 629-630	Article of Association Bank Mandiri, Article 11 Affiliate Relationship of The Board of Commissioners Affiliations of Board of Directors
E.2.8	Does the company have a Nominating Committee (NC)?	Bank Mandiri establishes Nomination and Remuneration Committee Charter of Board of Commissioners, Chapter III, Article 7 Annual Report of Bank Mandiri FY 2020, pages 678-690	Charter of Board of Commissioners Remuneration and Nomination Committee
E.2.9	Is the Nominating Committee comprised of a majority of Independent directors/commissioners?	Composition of members of the Independent Commissioners under Remuneration and Nomination Committee is 3 (three) person from 5 (five) members of Remuneration and Nomination Committee, as well as according to POJK No. 55/POJK.06/2016 regarding Implementation of Good Corporate Governance for Commercial Banks. Board of Comissionaires Committee (website) Annual Report of Bank Mandiri FY 2020, page 678-690	The Table of the Structure, the Membership and Expertise of the Remuneration and Nomination Committee (website) Composition of Remuneration & Nominating Committee
E.2.10	Is the chairman of the Nominating Committee an independent director/commissioner ?	Chairman of Nomination and Remuneration Committee is a Commissioner namely Mr. Muhamad Chatib Basri. Board of Comissionaires Committee (website) Annual Report of Bank Mandiri FY 2020, page 678-690	The Table of the Structure, the Membership and Expertise of the Remuneration and Nomination Committee (website) Composition of Remuneration & Nominating Committee
E.2.11	Does the company disclose the terms of reference/governance structure/charter of the Nominating Committee?	Bank Mandiri has disclosed Nomination Committee Charter through : Bank Mandiri Website Annual Report of Bank Mandiri FY 2020, page 678	Remuneration & Nominating Committee Charter (website) Charter of Remuneration & Nominating Committee (AR)
E.2.12	Is in the meeting attendance of the Nominating Committee disclosed and if so, did the Nominating Committee meet at least twice during the year?	The attendance of members of Nomination Committee are disclosed in the Annual Report of Bank Mandiri. (Annual Report of Bank Mandiri FY 2020, page. 685-688) Nomination and Remuneration Committee Charter, point 2.3, page 8	Meeting of Remuneration and Nomination Committee Remuneration & Nomination Committee Charter
E.2.13	Does the company have a Remuneration Committee?	Bank Mandiri establishes Remuneration and Nomination Committee Remuneration & Nomination Committee Charter (website) Annual Report of Bank Mandiri FY 2020, pages 678-690	Remuneration & Nomination Committee Charter (website) Remuneration & Nomination Committee
E.2.14	Is the Remuneration Committee comprised of a majority of Independent Directors/ Commissioners?	Composition of members of the Independent Commissioners under Remuneration and Nomination Committee is 3 (three) person from 7 (seven) members of Remuneration and Nomination Committee, as well as according to POJK No. 55/POJK.06/2016 regarding Implementation of Good Corporate Governance for Commercial Banks. Board of Comissionaires Committee (website) Annual Report of Bank Mandiri FY 2020, page 679-680	The Table of the Structure, the Membership and Expertise of the Remuneration and Nomination Committee (website) Composition of Remuneration & Nominating Committee (AR)
E.2.15	Is the chairman of the Remuneration Committee an independent director/commissioner?	Chairman of Remuneration and Nomination Committee is Independent Commissioner namely Mr. Muhamad Chatib Basri. Board of Comissionaires Committee (website) Annual Report of Bank Mandiri FY 2020, page 676	The Table of the Structure, the Membership and Expertise of the Remuneration and Nomination Committee (website) Composition of Remuneration & Nominating Committee
E.2.16	Does the company disclose the terms of reference/governance structure/charter of the Remunerations Committee?	Bank Mandiri has disclosed Nomination Committee Charter through : Bank Mandiri Website Annual Report of Bank Mandiri FY 2020, page 678	Charter Remuneration & Nominating Committee Charter (website) Remuneration & Nominating Committee Charters (AR)
E.2.17	In the meeting attendance of the Remuneration Committee disclosed and if so, did the Remuneration Committee meet at least twice during the year?	The attendance of members of Nomination Committee are disclosed in the Annual Report of Bank Mandiri. (Annual Report of Bank Mandiri FY 2020, page. 681-683) Nomination and Remuneration Committee Charter, point 2.3, page 8	Meeting Agenda of Remuneration & Nomination Committee Remuneration & Nomination Committee Charter
Audit Committee
E.2.18	Does the company have an Audit Committee?	Bank Mandiri has Audit Committee Audit Committee Charter (website) Audit Committee - Annual Report of Bank Mandiri FY 2020, page 665-677	Audit Committee Charter (website) Audit Committee
E.2.19	Is the Audit Committee comprised entirely of non-executive directors/ commissioners with majority of independent directors/commissioners?	Composition of members of Audit Committee consists of 5 (five) Independent Commissioners, 2 (two) Independent Parties, and 1 Commissioners, Annual Report of Bank Mandiri FY 2020, page 668-671	Composition of Committee Audit
E.2.20	Is the chairman of the Audit Committee an Independent Director/ Commissioner?	Chairman of Audit Committee is an Independent Commissioner namely Mr. Boedi Armanto Audit Committee Charter, point 3.3 (page 3) Annual Report of Bank Mandiri FY 2020, page 668-671	Audit Committee Charter Composition of Audit Committee
E.2.21	Does the company disclose the terms of reference/ governance structure/charter of the Audit Committee?	Bank Mandiri has disclosed Charter Audit Committee through: Bank Mandiri Website Annual Report of Bank Mandiri FY 2020, pages 665-666	Audit Committee Charter (Website) Committee Audit Charter (AR)
E.2.22	Does at least one of the independent directors/ commissioners of the committee have accounting expertise (accounting qualification or experience)?	In the Audit Committee Charter, point 4.2, page 3, it is mentioned that the committee members have sufficient knowledge to read and understand the financial statements. Qualification of Audit Committee has disclosed through Annual Report of Bank Mandiri FY 2020, pages 668-669	Audit Committee Charter Qualification of Audit Committee
E.2.23	Is the meeting attendance of the Audit Committee disclosed and, if so, did the Audit Committee meet at least four during the year	Attendance of members of Audit Committee are disclosed in the Annual Report of Bank Mandiri. (Annual Report of Bank Mandiri FY 2020, page. 673-676 Performance of the Meeting of Audit Committee will be held according to the need and assignment from Board of Commissioners, at minimum 2 (twice) a year. (Audit Charter Committee, point 4.2, page 3)	Audit Committee Meeting Audit Committee Charter
E.2.24	Does the Audit Committee have primary responsibility for recommendation on the appointment, and removal of the external auditor?	Audit Committee provides recommendations on appointment of Public Accountant and Public Accountant Office to Board of Commissioners to be submitted to GMS. Audit Committee Charter, point 5.3.5 (page 12) Annual Report of Bank Mandiri FY 2020, pages 666-667	Audit Committee Charter Duties & Responsibilities of Audit Committee
E.3 Board Processes Board meetings and attendance
E.3.1	Are the board of directors meeting scheduled before the start of financial year?	Board of Directors has scheduled meeting for the following year before end of each fiscal year, as detailed in : Annual Report of Bank Mandiri FY 2020, page 598-599 Annual Report of Bank Mandiri FY 2020, page 633-634 Meeting Schedule uploaded in Bank Mandiri Website	Board of Commissioers Meeting Board of Directors Meeting BoC Meeting Schedule (website) BoD Meeting Schedule (website)
E.3.2	Does the board of directors/commissioners meet at least six times during the year?	Board of Directors arranged the Meeting of Board of Directors for 40 times, while Board of Commissioners arranged 36 BoC meetings. Annual Report of Bank Mandiri FY 2020, pages 599-611 Annual Report of Bank Mandiri FY 2020, pages 634-651	Board of Commissioers Meeting Board of Directors Meeting
E.3.3	Has each of the directors/commissioners attended at least 75% of all the board meetings held during the year?	The attendance of each Board of Directors and Board of Commissioners must at least 75% of the all performance of meeting of Board of Directors/ Board of Commissioners. Annual Report of Bank Mandiri FY 2020, pages 599-611 Annual Report of Bank Mandiri FY 2020, pages 634- 651	Board of Commissioers Meeting Board of Directors Meeting
E.3.4	Does the company require a minimum quorum of at least 2/3 for board decisions?	Meeting of Board of Commissioners will be valid and entitled to take binding resolutions when attended or represented by more than 2/3 (two thirds) of the members of Board of Commissioners Annual Report of Bank Mandiri FY 2020, page 598 Charter of Board of Commissioners, Article 7, Section 3 Meeting of Board of Directors is valid and entitled to adopt binding resolutions if more than 2/3 (two thirds) from the total members of Board of Directors attend or represented in the meeting, as mentioned in : Annual Report of Bank Mandiri FY 2020, page 633 Charter of Board of Directors, Article 10, section 1	Board of Commissioners Meeting Charter of Board of Commissioners Board of Directors Meeting Charter of Board of Directors
E.3.5	Did the non-executive directors/commissioners of the company meet separately at least once during the year without any Executives present?	Board of Commissioners has organized 36 times of Board of Commissioners’ internal meetings Annual Report of Bank Mandiri FY 2020 pages 599-611 Annual Report of Bank Mandiri FY 2020 pages 634-651	Meetings of Board of Commissioners Meeting of The Board of Directors
Access to information
E.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?	Material for the Board of Commissioners Meeting shall be distributed to all meeting participants at the latest of 5 (five) business days prior to the meeting, as mentioned in : Charter of Board of Commissioners , Chapter III, Article 10 Annual Report of Bank Mandiri FY 2020 page 598 Materials for the scheduled meetings as of referred to under Article 6 section 3 shall be submitted in written to members of the meeting within the latest of 5 (five) business days prior to convening the meeting to each member of Board of Directors, as mentioned in : Charter of Board of Directors, Chapter III, Article 12, point 1 Annual Report of Bank Mandiri FY 2020, page 633	Charter of Board of Commissioners Board of Commissioners Meeting Charter of Board of Directors Board of Directors Meeting
E.3.7	Does the company secretary play a significant role in supporting the board in discharging its responsibilities?	Corporate Secretary holds significant role to support the management in carrying out its responsibilities. Annual Report of Bank Mandiri FY 2020, pages 718-723	Corporate Secretary
E.3.8	Is the company secretary trained in legal, accountancy or company secretarial practices and has kept abreast on relevant developments?	FY 2020, Corporate Secretary has participated in various trainings. Annual Report of Bank Mandiri FY 2020, page 721-722	Competence Development for The Corporate Secretary
Board Appointments and Re-Election
E.3.9	Does the company disclose the criteria used in selecting new directors/commissioners?	Bank Mandiri has disclosed the criteria used in selection of Board of Directors / Board of Commissioners in the Annual Report and Website of Bank Mandiri, as mentioned under: Annual Report of Bank Mandiri FY 2020, pages 588 Annual Report of Bank Mandiri FY 2020, pages 623 Bank Mandiri Website	Criteria for Member of The Board of Commissioners Criteria of the Board of Directors Board of Commissioners Selection Criteria (website) Board of Directors Selection Criteria (website)
E.3.10	Did the company describe the process followed in appointing new directors/commissioners?	Bank Mandiri has disclosed process for appointment of Board of Directors and Board of Commissioners in the Annual Report and Bank Mandiri Website. Annual Report of Bank Mandiri FY 2020, pages 689-690 Annual Report of Bank Mandiri FY, page 2020 588	Nomination and Selection Process of Board of Commissioners Board of Directors Succession Policy
E.3.11	Are all the 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? ² The five years term must be required by legislation which pre-existed the introduction of the ASEAN Corporate Governance Scorecard in 2011	Term of office for members of Board of Commissioners and Board of Directors at maximum 5 years and may be reappointed for another 1 (one) term of office 2(two) times of term of office = maximum 10 years) Articles of Association of Bank Mandiri FY 2021, Article 11, point 12 (page 26) Articles of Association of Bank Mandiri FY 2021, Article 14, point 14 (page 56) Law No. 19 of 2003 Indonesia State-Owned Entities, Chapter 16, section 4, stated that The term of office of a member of the Board of Directors shall be 5 (five) years and may be re-appointed for 1 (one) term of office. Law No. 19 of 2003 Indonesia State-Owned Entities, Chapter 28, section 3, stated that The term of office of a member of the Board of Commissioners shall be 5 (five) years and may be re-appointed for 1 (one) term of office. Annual Report of Bank Mandiri FY 2020 page 622-623 Annual Report of Bank Mandiri FY 2020 page 587-588	Articles of Association of Bank Mandiri FY 2021, Article 11 Articles of Association of Bank Mandiri FY 2021, Article 14 Law No. 19 of 2003 Indonesia State-Owned Entities, Chapter 16, section 4, Law No. 19 of 2003 Indonesia State-Owned Entities, Chapter 28, section 3 Tenure of Board of Commissioners Tenure of The Board of Directors
Remuneration Matters
E.3.12	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 has disclosed Remuneration Policy for Board of Directors through : Annual Report of Bank Mandiri FY 2020, pages 403-404 Annual Report of Bank Mandiri FY 2020, pages 756-763	Employee Stock Option Program (ESOP)/Management Stock Option Program (MSOP) Remuneration of the Board of Commissioners and The Board of Directors
E.3.13	Is there disclosure of the fee structure for non- executive directors/commissioners?	Company has disclosed Remuneration Policy for Board of Commissioners and Board of Director through: Annual Report of Bank Mandiri FY 2020, page 759-763	Remuneration anf Facilities of the Board of Commissioners and The Board of Directors
E.3.14	Do the shareholders or the Board of Directors approve the remuneration of the executive directors and/or the senior executives?	Shareholders approved remuneration for Board of Directors and Board of Commissioners as included in: Bank Mandiri 2020 AGMS Result Bank Mandiri 2020 AGMS Highlight	Bank Mandiri 2021 AGMS Result Bank Mandiri 2021 AGMS Highlight
E.3.15	Does the company have measurable standards to align 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?	Company has size to adjust performance based remuneration Annual Report of Bank Mandiri FY 2020, pages 756-757 Annual Report of Bank Mandiri FY 2020, pages 762-763	Variable Remuneration Remuneration Policy for The Board of Commssioners and the Board of Directors
Internal Audit
E.3.16	Does the company have a separate internal audit function?	Bank Mandiri has separate internal audit function Annual Report of Bank Mandiri FY 2020, pages 746-752	Internal Audit
E.3.17	Is the head of internal audit identified or, if outsourced, is the name of the external firm disclosed?	Head of Internal Audit is Mrs. Mustaslimah Annual Report of Bank Mandiri FY 2020, page 747	Head of Internal Audit
E.3.18	Does the appointment and removal of the internal auditor require the approval of the Audit Committee?	Appointment and Termination of Chief Audit Executive (CEA) presented that Chief Audit Executive (CEA) is appointed and terminated as well as directly responsible to President Director on approval of Board of Commissioners or Audit Committee and furthermore reported to Bank Indonesia, Financial Service Authority (FSA). Annual Report of Bank Mandiri FY 2020, page 747	Appointing and Dismising Parties of The Head of Internal Audit
E.3.19	Does the company establish a sound internal control procedures/risk management framework and periodically review the effectiveness of that framework? (AS REPHRASED BY INDONESIA)	Mandiri has Risk Management Framework and Internal Control System periodically reviewed Annual Report of Bank Mandiri FY 2020, pages 765-786 Annual Report of Bank Mandiri FY 2019, pages 787-790	Risk Management Internal Control System
E.3.20	Does the Annual 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?	Mandiri has Risk Management Framework and Internal Control System periodically reviewed Annual Report of Bank Mandiri FY 2020, page 790 Annual Report of Bank Mandiri FY 2020, page 786 Annual Report of Bank Mandiri FY 2020, page 797	The Evaluation of Internal Monitoring System Implementation The Evaluation of Risk Management System Evaluation of Effectivenes of Compliance Function
E.3.21	Does the company disclose the key risks to which the company is materially exposed to (i.e. financial, operational including IT, environmental, social, economic)? (AS REPHRASED BY INDONESIA)	Bank Mandiri has disclosed Company's key risks in the Annual Report of Bank Mandiri FY 2020 pages 742-782	Management of Risk
E.3.22	Does the Annual 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 of Audit Committee on Effectiveness of Internal Control Systems and Risk Management : The internal control system performed by Bank Mandiri was considered effective and adequate, reflected in the effectiveness of the implementation of internal control functions, including internal audit function, risk management, compliance, financial and operational controls. (Annual Report of Bank Mandiri FY 2020, page 677)	Statement of Internal Control & Risk Management Adequation
E.4 People on the Board Board Chairman
E.4.1	Do different persons assume the roles of chairman and CEO?	Positions of President Director and President Commissioner of Bank Mandiri held by different parties. In this case position of President Director is held by Mr. Darmawan Junaidi and President Commissioner were held by Mr. Muhamad Chatib Basri. Annual Report of Bank Mandiri FY 2020, page 106-1119 Annual Report of Bank Mandiri FY 2020, page 120-136 Bank Mandiri 2021 AGMS Result	Board of Commissioners Profile Board of Directors Profile Bank Mandiri 2021 AGMS Result
E.4.2	Is the chairman an independent director/commissioner?	President Commissioner of Bank Mandiri is an Independent Commissioner. Annual Report of Bank Mandiri FY 2020, page 106-119 Bank Mandiri 2021 AGMS Result	Board of Commissioners Profile Bank Mandiri 2020 AGMS Result
E.4.3	Is any of the directors a former CEO of the company in the past 2 years?	In the Annual Report FY 2020, no Board of Directors previously positioned as President Director in the last 2 (two) years Annual Report of Bank Mandiri FY 2020, page 120-136	Board of Directors Profile
E.4.4	Are the role and responsibilities of the chairman disclosed?	Bank Mandiri has disclosed Duties and Responsibilities of President Commissioner Annual Report of Bank Mandiri FY 2020, page 582	Duties & Responsibilities of Chairman
Lead Independent Director
E.4.5	If the Chairman is not independent, has the Board appointed a Lead/Senior independent Director and has his/her role been defined?	President Commissioner of Bank Mandiri is an Independent Commissioner. Annual Report of Bank Mandiri FY 2020, page 106 Bank Mandiri 2021 EGMS Result	Bank Mandiri 2021 AGMS Result Annual Report of Bank Mandiri FY 2020
Skills and Competencies
E.4.6	Does at least one non-executive director/commissioner have prior working experience in the major sector that the company is operating in?	More than one members of Board of Directors and Board of Commissioners have working experiences in banking sector, as mentioned under: Annual Report of Bank Mandiri FY 2020, pages 106-119 Annual Report of Bank Mandiri FY 2020, pages 120-136 Annual report of Bank Mandiri FY 2020, pages 821-825	Board of Commissioners Profile Board of Directors Profile Diversity of Board of Commissioners and Directors
E.5 Board Performance Directors Development
E.5.1	Does the company have orientation programmes for new directors/commissioners?	Bank Mandiri has disclosed orientation program for the new Board of Directors and Board of Commissioners Annual Report of Bank Mandiri FY 2020, pages 590-591 Annual Report of Bank Mandiri FY 2020, pages 626-628	Orientation Program of New Commissioners Orientation Program of New Board of Directors
E.5.2	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 ?	Bank Mandiri has determined policies encouraging Management to join professional education programs. Annual Report of Bank Mandiri FY 2020, pages 201-205 Bank Mandiri Website	Competence Development of Board of Commissioners and Board of Directors Board of Commissioners Development Program Board of Directors' Development Program
CEO/Executive Management Appointments and Performance
E.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?	Perusahaan has disclosed planning process carried out by Board of Directors and Board of Commissioners related to succession of President Director and other members of Board of Directors. Annual Report of Bank Mandiri FY 2020, pages 689-690 Bank Mandiri Website	Board of Directors Succession Policy Board of Directors Succession Policy (website)
E.5.4	Does the board of directors/commissioners conduct an annual performance assessment of the CEO/Managing Director/President?	An evaluation of the Board of Directors’ performance is based on the achievement (KPI) previously agreed through the GMS mechanism by the Shareholders, the Board of Commissioners, and the Board of Directors. Annual Report of Bank Mandiri FY 2020, page 659-661	Performance Assessment of the Board of Directors
Board Appraisal
E.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? (ORIGINAL E.5.6 and E.5.7 MERGED INTO THIS QUESTION - THAILAND IN CHARGE OF MARKING GUIDELINES)	Bank Mandiri has disclosed the criteria used in performance assessment for Board of Directors and Board of Commissioners in the Annual Report of Bank Mandiri FY 2020. Annual Report of Bank Mandiri FY 2020, pages 617-619 Annual Report of Bank Mandiri FY 2020, pages 659-661	Criteria for Performance Evaluation of The Board of Commissioners Criteria of Performance Evaluation of The Board of Directors
Director Appraisal
E.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? (ORIGINAL E.5.8 and E.5.9 MERGED INTO THIS QUESTION - THAILAND IN CHARGE OF MARKING GUIDELINES)	Bank Mandiri has disclosed the criteria used in performance assessment for Board of Directors and Board of Commissioners in the Annual Report of Bank Mandiri FY 2020. Annual Report of Bank Mandiri FY 2020, pages 617-619 Annual Report of Bank Mandiri FY 2020, pages 659-661	Performance Assessment of The Board of Commissioners Performance Assessment of the Board of Directors
Committee Appraisal
E.5.7	Did the company conduct an annual performance assessment of the board committees and disclose the criteria and process followed for the assessment? (REPHRASED ORIGINAL E.5.10 - THAILAND IN CHARGE OF MARKING GUIDELINES)	Committee's performance assessment shall be prepared by Board of Commissioners in annual basis using method specified by Board of Commissioners Annual Report of Bank Mandiri FY 2020, pages 619-620 Annual Report of Bank Mandiri FY 2020, pages 661-662	The Evaluation of Commitees Under The Board of Commissioners Performance Assessment of Committees Under The Board of Directors

F. Bonus

Part	Items	BMRI Practice Year 2020	Source Information
(B)A. Right of Shareholder
(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?	Voting is performed by vote cards and electronic counting. (Bank Mandiri 2021 AGM Highlight, page 3 and Annual Report of Bank Mandiri FY 2020, page 565, 571-572, 574-575,579-580,582-583)	Bank Mandiri 2021 AGM Highlight Annual Report of Bank Mandiri FY 2020
(B)B. Equitable treatment of shareholders
(B)B.1 Notice of AGM
(B)B.1.1	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?	Date of the Annual GMS Performance: March 15, 2021 Summons Date: February 12, 2021 (Less than 28 days) (Bank Mandiri 2021 AGM Agenda and Annual Report of Bank Mandiri FY 2020, page 565, 571-572, 574-575,579-580,582-583)	Bank Mandiri 2021 AGMS Invitation Annual Report of Bank Mandiri FY 2020
(B)C. Roles of Stakeholders
(B)C.1.1	Does the company adopt an internationally recognized reporting framework for sustainability (i.e. GRI, Integrated Reporting, SASB)?	Bank Mandiri has disclosed that the company has adopted the Global Reporting Initiatives G4 (GRI-G4) and Indicators of the Financial Services Sector Supplement as mentioned in: POJK Reference and Standard GRI Content Index -Sustainability Report FY 2020, page 224-227	Sustainability Report of Bank Mandiri FY 2020
(B)D. Disclosure and transparency
(B)D.1.1	Are the audited annual financial report /statement released within 60 days from the financial year end?	Bank Mandiri has published Financial Statement Year 2020 through the Print Media Koran Kontan on January 29, 2020	Kontan
(B)D.1.2	Does the company disclose details of remuneration of the CEO?	Bank Mandiri has disclosed the Total Remuneration of the President Director as set out in the Annual Report of Bank Mandiri as mentioned in: Policy and Remuneration for the Board of Directors - Annual Report of Bank Mandiri FY 2020, page 756-763	Annual Report of Bank Mandiri FY 2020
(B)E. Responsibilities of the Board
(B)E.1 Board Competencies and Diversity
(B)E.1.1	Does the company have at least one female independent director/commissioner?	Bank Mandiri have 1 (one) female independent commissioner, namely Ibu Loeke Larasati Agoestina (Bank Mandiri Website, Annual Report of Bank Mandiri FY 2020 page 821-825)	Bank Mandiri Website Annual Report of Bank Mandiri FY 2020
(B)E.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?	Policy on the Diversity Composition of the Board of Commissioners and its Implementation - Annual Report of Bank Mandiri FY 2020, page 821-825 Diversity in Board of Directors Policies and Its Implementation - Annual Report of Bank Mandiri FY 2020, page 821-825 Bank Mandiri Diversity Policy refers to governance principles and recommendations as Circular Letter of OJK number. 32 / SEOJK.04 / 2015 concerning Corporate Governance of Public Company Guidelines. (Aspect and Principle of Corporate Governance Implementation According to Financial Service Authority, PART B.1.2 and C.1.2)	Annual Report of Bank Mandiri FY 2020
(B)E.2 Board Structure
(B)E.2.1	Does the Nominating Committee comprise entirely of independent directors/ commissioners?	The composition of members of the Independent Commissioners in the Nomination Committee were 3 (three) persons out of 7 (seven) members of the Nomination and Remuneration Committee, in line with OJK Regulation No. 55/POJK.06/2016 concerning Application of Governance for Commercial Banks. (Annual Report of Bank Mandiri Year 2020, page 679-680)	Board of Comissionaires Committee
(B)E.2.2	Does the Nominating Committee undertake the process of identifying the quality of directors aligned with the company's strategic directions?	Remuneration & Nomination Committee Charter, page 9-13. (Bank Mandiri Website) To identify candidate of the Board of Directors either from internal or external and candidate of the Board of Commissioners who has met the requirements to be proposed for the appointment as Director or the Board of Commissioners which is tailored to the Company strategy. (Annual Report of Bank Mandiri Year 2020, page 689-690)	Bank Mandiri Website Annual Report of Bank Mandiri FY 2020
(B)E.3 Board Appointments and Re-Election
(B)E.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?	Bank Mandiri hired Appraisal Service Companies for selecting Candidates for the Board of Commissioners and the Board of Directors. In 2020, Bank Mandiri is working with the Company Assessment Service of PT Daya Dimensi Indonesia to conduct assessment against candidates for the Board of ommissioners and Board of Directors. (Annual Report of Bank Mandiri Year 2020, page 690)	Annual Report of Bank Mandiri FY 2020
(B)E.4 Board Structure & Composition
(B)E.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?	In compliance with resolutions of the Annual General Meeting of Shareholders of Bank Mandiri on 15 March 2021, the composition of Independent Commissioner is 50% and the President Commissioner of Bank Mandiri is an Independent Commissioner. The composition of the Board of Commissioners of the Company as of December 31, 2020 totaled 10 (ten) members with 5 (five) of whom were Independent Commissioners, which meant 50% (fifty percent) of the total Commissioners. (Annual Report of Bank Mandiri FY 2020, page 595-598, 623,624,590)	Bank Mandiri 2021 AGM Result Annual Report of Bank Mandiri FY 2020
(B)E.5 Risk Oversight
(B)E.5.1	Does the board describe its governance process around IT issues including disruption, cyber security, disaster recovery, to ensure that all key risks are identified, managed and reported to the board?	IT-related governance process has been disclosed in Annual Report of Bank Mandiri Year 2020 as: IT Governance - Annual Report of Bank Mandiri FY 2020, page 551-553 Discussed in Board Agenda - Annual Report of Bank Mandiri FY 2020, page 634-649	IT Governance Discussed in Board Agend
(B)E.6 Board Performance
(B)E.6.1	Does the company have a separate board level Risk Committee?	Bank Mandiri has the Risk Monitoring Committee and Risk Management Committee separate from other committees as mentioned on Annual Report of Bank Mandiri Year 2020, page 690-703, 737-738, 741-744	Annual Report of Bank Mandiri FY 2020

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A. Right of Shareholders

Part

Items

BMRI Practice Year 2020

Source Information

A.1 Basic Shareholder Rights

Interim Dividend: Bank Mandiri didn't distribute interim dividend

Script Dividend: Bank Mandiri didn't distribute script dividend

Final Dividend: Bank Mandiri paid for dividend for less than 30 calendar days. days from performance of the Annual General Meeting of Sharholders (AGMS), as follows: Date to AGMS: 15 Maret 2021 Payment Date : 12 April 2021

as mentioned under

Bank Mandiri 2021 AGMS Result, 3rd column

Annual Report FY 2020, page 402-403

A.2 Right to Participate in decisions concerning fundamental corporate changes

A.2.1

Amendments to the company's constitution?

Shareholders have the right to participate in the amendments to the company's constitution through GMS as stated in :

Articles of Association of Bank Mandiri FY 2021, Article 28, section 2 (page 107)

Articles of Association of Bank Mandiri FY 2021, Article 25, section 5 (page 99)

A.2.2

The authorisation of additional shares?

Shareholders have the right to participate in the authorization of additional shares as stated in : Articles of Association of Bank Mandiri FY 2021, Article 4, section 5 (page 6)

A.2.3

The transfer of all or substantially all assets, which in effect results in the sale of the company?

Shareholders have the right to participate in the transfer of all or substantially assets, whic in effect results in the sale of company as stated in : Articles of Association of Bank Mandiri FY 2018, Article 12, section 10 (page 58)

A.3 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.3.1

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?

GMS determines remuneration and honorarium for fiscal year 2021 and performance tantieme (bonus) for Fiscal Year ended on December 31, 2020 for members of Board of Directors and Board of Commissioners of the Company, as mentioned under :

Bank Mandiri 2021 AGMS Result, 3rd Agenda.

Bank Mandiri 2021 AGMS Highlight, 3rd Agenda.

A.3.2

Does the company provide non-controlling shareholders a right to nominate candidates for board of directors/commissioners?

Interim Dividend:
Bank Mandiri didn't distribute interim dividend

Script Dividend:
Bank Mandiri didn't distribute script dividend

Final Dividend:
Bank Mandiri paid for dividend for less than 30 calendar days.
days from performance of the Annual General Meeting of Sharholders (AGMS), as follows:
Date to AGMS: 15 Maret 2021
Payment Date : 12 April 2021

Shareholders have the right to participate in the authorization of additional shares as stated in :
Articles of Association of Bank Mandiri FY 2021, Article 4, section 5 (page 6)

Shareholders have the right to participate in the transfer of all or substantially assets, whic in effect results in the sale of company as stated in :
Articles of Association of Bank Mandiri FY 2018, Article 12, section 10 (page 58)