ASEAN CG Scorecard

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A. Right of Shareholders

Part	Items	BMRI Practice Year 2021	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?	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 Dividend & Split (Bank Mandiri Website) Bank Mandiri 2022 AGMS Result, 2nd column Annual Report Bank Mandiri FY 2021 page 373-374	Dividend & Split Bank Mandiri 2022 AGMS Result Annual Report of Bank Mandiri FY 2021
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 2022 and performance tantieme (bonus) for Fiscal Year ended on December 31, 2021 for members of Board of Directors and Board of Commissioners of the Company, as mentioned under : Bank Mandiri 2022 AGMS Result, 3rd Agenda. Bank Mandiri 2022 AGMS Highlight, 3rd Agenda. Annual Report of Bank Mandiri FY 2021, page 509, 517-518	Bank Mandiri 2022 AGMS Result Bank Mandiri 2022 AGMS Highlight Annual Report of Bank Mandiri FY 2021 Page 509 Annual Report of Bank Mandiri FY 2021 Page 517-518
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) Annual Report of Bank Mandiri FY 2021 page 509, Rights of the Shareholders Annual Report of Bank Mandiri FY 2021 page 522-523, The Ninth Meeting Agenda, Change in composition of management of the company Annual Report of Bank Mandiri FY 2021 page 527-532, Fifth Meeting Agenda, Change in composition of management of the company	- 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 Rights of the Shareholders The Ninth Meeting Agenda, Change in composition of management of the company Fifth Meeting Agenda, Change in composition of management of the company
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, 8th Agenda Bank Mandiri 2021 AGMS Highlight, 8th Agenda Annual Report of Bank Mandiri FY 2021 page 509, Rights of the Shareholders Annual Report of Bank Mandiri FY 2021 page 522-523, The Ninth Meeting Agenda, Change in composition of management of the company Annual Report of Bank Mandiri FY 2021 page 527-532, Fifth Meeting Agenda, Change in composition of management of the company	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 Rights of the Shareholders The Ninth Meeting Agenda, Change in composition of management of the company Fifth Meeting Agenda, Change in composition of management of the company
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 2022 AGMS Code of Conduct, point 13 – Voting procedures Annual Report of Bank Mandiri FY 2021 page 512	Bank Mandiri 2022 AGMS Code of Conduct Annual Report of Bank Mandiri FY 2021
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. Annual Report of Bank Mandiri FY 2021 page 515-523, Decision of the 2021 Annual General Meeting of Shareholders Annual Report of Bank Mandiri FY 2021 page 524-529, Decision and Realization of the 2020 Annual General Meeting of Shareholders Annual Report of Bank Mandiri FY 2021 page 530-532, 2020 Extraordinary GMS Implementation and Realization	Decision of the 2021 Annual General Meeting of Shareholders Decision and Realization of the 2020 Annual General Meeting of Shareholders 2020 Extraordinary GMS Implementation and Realization
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 2022 AGMS Result - Mechanism for Resolution Making Bank Mandiri 2022 AGMS Highlight -Mechanism for Resolution Making, page 3 Annual Report of Bank Mandiri FY 2021 page 515-523, Decision of the 2021 Annual General Meeting of Shareholders Annual Report of Bank Mandiri FY 2021 page 524-529, Decision and Realization of the 2020 Annual General Meeting of Shareholders Annual Report of Bank Mandiri FY 2021 page 530-532, 2020 Extraordinary GMS Implementation and Realization	Bank Mandiri 2022 AGMS Result Bank Mandiri 2022 AGMS Highlight Decision of the 2021 Annual General Meeting of Shareholders Decision and Realization of the 2020 Annual General Meeting of Shareholders 2020 Extraordinary GMS Implementation and Realization
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 2022 AGMS Result, paragraph 2 Bank Mandiri 2022 AGMS Highlight, page 1-2 Annual Report of Bank Mandiri FY 2021 page 514-515	Bank Mandiri 2022 AGMS Result Bank Mandiri 2022 AGMS Highlight Annual Report of Bank Mandiri FY 2021
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 20 January 2022 and attended by members of the Board of Directors and Board of Commissioners , as metioned under: Bank Mandiri 2022 AGMS Result, 1st & 2nd column, paragraph 2. Bank Mandiri 2022 AGMS Highlight, page 1 & 2, paragraph 2 Annual Report of Bank Mandiri FY 2021 page 514-515	Bank Mandiri 2022 AGMS Result Bank Mandiri 2022 AGMS Highlight Annual Report of Bank Mandiri FY 2021
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 11, page 102 Bank Mandiri 2022 AGMS Code of Conduct point 13a, page 7 Bank Mandiri 2022 AGMS Agenda, Notes point 6.d Annual Report of Bank Mandiri FY 2021 page 512	Articles of Association of Bank Mandiri FY 2021 Article 25 Bank Mandiri 2022 AGMS Code of Conduct Bank Mandiri 2022 AGMS Agenda Annual Report of Bank Mandiri FY 2021
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 2022 AGMS Code of Conduct, point 12 – Meeting Resolutions Bank Mandiri 2022 AGMS Code of Conduct, point 13c, page 7 – Voting Procedures Articles of Association of Bank Mandiri FY 2021, article 25, section 10, page 102 Annual Report of Bank Mandiri FY 2021 page 512	Bank Mandiri 2022 AGMS Code of Conduct Articles of Association of Bank Mandiri FY 2021, Article 25 Annual Report of Bank Mandiri FY 2021
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 2022 AGMS Result, Independent Party for Vote Count Bank Mandiri 2022 AGMS Highlight, page 3 Annual Report of Bank Mandiri FY 2021 page 514	Bank Mandiri 2022 AGMS Result Bank Mandiri 2022 AGMS Highlight Annual Report of Bank Mandiri FY 2021
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 2022 GMS within 1 (one) business day after Performance to AGMS on the date of March 11, 2022. Bank Mandiri 2022 AGMS Highlight Annual Report of Bank Mandiri FY 2021 page 513-514	Bank Mandiri 2022 AGMS Highlight Annual Report of Bank Mandiri FY 2021
A.3.13	Do companies provide at least 21 days notice for all AGMs and EGMs?	Announcement of 2022 AGMS : 31 January 2022 Summons for 2022 AGMS : 16 February 2022 Performance of 2022 AGMS : 10 March 2022 Based on the aforementioned information, Summons for AGMS made within 21 calendar days before performance of GMS. Bank Mandiri 2022 AGMS Announcement Bank Mandiri 2022 AGMS Agenda Annual Report of Bank Mandiri FY 2021 page 513-514	Bank Mandiri 2022 AGMS Announcement Bank Mandiri 2022 AGMS Agenda Annual Report of Bank Mandiri FY 2021
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 2022 AGMS Invitation - Meeting Agenda Bank Mandiri 2022 AGMS List of Supporting Material for Agenda Annual Report of Bank Mandiri FY 2021 page 513-514	Bank Mandiri 2022 AGMS Invitation Bank Mandiri 2022 AGMS List of Supporting Material for Agenda Annual Report of Bank Mandiri FY 2021
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) Annual Report of Bank Mandiri FY 2021 page 509	Articles of Association Bank Mandiri FY 2021, Article 23 Annual Report of Bank Mandiri FY 2021
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 of Bank Mandiri Tahun 2021, hal 368)	Annual Report of Bank Mandiri FY 2021
A.5 The exercise of ownership rights by all shareholders, including institutional investors, should be facilitated.
A.5.1	Does the company publicly disclose policy/practice to encourage shareholders including institutional shareholders to attend the general meetings or engagement with the company ?	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. The information is mentioned in : Menu Investor Relations (Bank Mandiri Website – Menu Investor Relations) Rights of General Shareholders (Annual Report Bank Mandiri FY 2021 page 509-510) The Ninth Meeting Agenda, Change in composition of management of the company (Annual Report of Bank Mandiri FY 2021 page 522-523) Fifth Meeting Agenda, Change in composition of management of the company (Annual Report of Bank Mandiri FY 2021 page 527-528)	Bank Mandiri Website Rights of General Shareholders The Ninth Meeting Agenda Fifth Meeting Agenda

B. Equitable Treatment of Shareholder

Part	Items	BMRI Practice Year 2021	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 2022 AGMS Code of Conduct, point 13 – Voting Procedure Bank Mandiri 2022 AGMS Power of Attorney Articles of Association of Bank Mandiri FY 2021 Article 25, section 10 and 12 (page 102) Annual Report of Bank Mandiri FY 2021, page 509-510	Bank Mandiri 2022 AGMS Code of Conduct Bank Mandiri 2022 AGMS Power of Attorney Articles of Association of Bank Mandiri FY 2021, Article 25 Annual Report Bank Mandiri FY 2021
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 of Bank Mandiri FY 2021 page 509-510	Articles of Association of Bank Mandiri FY 2021, Article 5 Annual Report Bank Mandiri FY 2021
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 2022 AGMS Result Bank Mandiri 2022 AGMS Highlight Annual Report of Bank Mandiri FY 2021 page 524-532, 2020 AGMS Implementation and Realization Annual Report of Bank Mandiri FY 2021 page 513-514, 2021 Annual General Meeting of Shareholders Annual Report of Bank Mandiri FY 2021 page 515-523, Decision of the 2021 Annual General Meeting of Shareholders	Bank Mandiri 2022 AGMS Result Bank Mandiri 2022 AGMS Highlight 2020 AGMS Implementation and Realization 2021 Annual General Meeting of Shareholders Decision of the 2021 Annual General Meeting of Shareholders
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 (16 February 2022) Bank Mandiri 2022 AGMS Agenda (ndonesia & English) Bank Mandiri 2022 AGMS Announcement (Indonesia & English) Annual Report of Bank Mandiri FY 2021 page 513-514	Bank Mandiri 2022 AGMS Agenda (Indonesia) Bank Mandiri 2022 AGMS Agenda (English) Bank Mandiri 2022 AGMS Announcement (Indonesia) Bank Mandiri 2022 AGMS Announcement (English) Annual Report of Bank Mandiri
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 2022 AGMS Agenda, Notes Bank Mandiri 2022 AGMS Announcement Annual Report of Bank Mandiri FY 2021 page 522-523, The Minutes of Meeting stated that there was no question and/or response from shareholders and shareholder's power of attorney Annual Report of Bank Mandiri FY 2021 page 527-532, Changes in the Composition of the Management of the Company	Bank Mandiri 2022 AGMS Agenda Bank Mandiri 2022 AGMS Announcement Annual Report of Bank Mandiri FY 2021 page 522-523 Annual Report of Bank Mandiri FY 2021 page 527-532
B.2.4	Are the auditors seeking appointment/re-appointment clearly identified?	Bank Mandiri appointed Public Accounting Firm Tanudiredja, Wibisana, Rintis and Partner (PricewaterhouseCoopers International Limited) 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 2022, as mentioned in : Bank Mandiri 2022 Attachment to AGM Supporting Materials, Agenda 3, page 5 Annual Report of Bank Mandiri FY 2021 page 518-519, 526-527	Bank Mandiri 2022 List of Supporting Material for Agenda Bank Mandiri 2022 AGMS Invitation Annual Report of Bank Mandiri FY 2021 page 518-519 Annual Report of Bank Mandiri FY 2021 page 526-527
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 2022 Invitation of the AGMS Bank Mandiri 2022 Power of Attorney	Bank Mandiri 2022 Invitation of the AGMS Bank Mandiri 2022 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 2021, page 542 Management of the Board of Directors Conflict of Interest - Annual Report FY 2021, page 621 The Content of The Code of Conduct - Annual Report FY 2021, page 733-738 Prevention of Insider Trading - Annual Report FY 2021, page 744 Transaction With a Conflict of Interest - Annual Report FY 2021 page 380	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 Transaction With a Conflict of Interest
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 2021, there have been 22 trading transactions purchases of Bank's shares conducted by Board of Commisioners and Board of Directors. Those transaction had been reported to OJK more than 3 bussiness Days (Annual Report of Bank Mandiri FY 2021, page 153-155)	Annual Report Bank Mandiri FY 2021
B.4 Related party transactions by directors and key executives
B.4.1	Are directors and 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 - Conflict of Interest point 3.c2 & c3, page 8-9. Annual Report of Bank Mandiri FY 2021 page 621, Management of the Board of Directors Conflict of Interest Annual Report of Bank Mandiri FY 2021 page 542, Management of the Board of Commissioners’s Conflict of Interest	GCG Charter Management of the Board of Commissioners’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 2021, page 382) Transaction with Afiliated Parties - Annual Report Bank Mandiri FY 2021 page 376-377	Transaction Policy with Related Parties Transaction With Affiliated Entities
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 4 section 3, and 11 section 9 Charter of Board of Directors, Article 16 section 3 Annual Report of Bank Mandiri FY 2021 page 542, Management of the Board of Commissioners’s Conflict of Interest Annual Report of Bank Mandiri FY 2021 page 621, Management of the Board of Directors Conflict of Interest	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 Management of the Board of Directors Conflict of Interest Management of the Board of Commissioners’s Conflict of Interest
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. Annual Report of Bank Mandiri FY 2021 page 382 Annual Report of Bank Mandiri FY 2021 page 383 Annual report of Bank Mandiri FY 2021 page 542 Annual report of Bank Mandiri FY 2021 page 621	Review Mechanism Policies for Transaction and Compliance With Relevan Rules and Regulations Lending Policies fot The Board of Commissioners and Directors Management of the Board of Commissioner's Conflict of Interest Management of the Board of Directors Conflict of Interest
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 made in 2021 were conducted in an arm's length manner conforming with normal commercial terms. The arm's length nature of transactions with related parties or having conflicts of interest were conducted in an arm's length manner conforming with the laws and regulations. Transactions were made due to the needs of Bank Mandiri and were considered free from conflicts of interest. In 2021, there were no related party transactions requiring approval from the GMS. (Annual Report of Bank Mandiri FY 2021, page 382)	Arm's Length Nature and Reasons for The Transactions Transactions with Affiliated Parties
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 2021, page 381-382, 749	Transaction Policy with the Related Parties Name and Nature of Related Relations Review Mechanism Policies for Transactions and Compliance with Relevant Rules and Regulations Funding to Related Parties

C. Role of Stakeholders

Part	Items	BMRI Practice Year 2021	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 : Customer Service and Satisfaction - Sustainability Report FY 2021 page 109-113 Company's Product : Bank Mandiri Website - Individual Menu Bank Mandiri Website - Business Menu Bank Mandiri Website - Priority Menu	Customer Services and Satisfaction Individual Menu Business Menu Priority Menu
C.1.2	Supplier/contractor selection procedures?	The Public Company has policy on vendor or supplier selection and capability improvement - Annual Report of Bank Mandiri FY 2021, page 499 Procurement Policy - Bank Mandiri Website Sustainability Report of Bank Mandiri FY 2021, page 69-71	The Public Company has policy on vendor or supplier selection and capability improvement Procurement Policy Sustainability Report
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: Preserving The Environment - Sustainability Report Bank Mandiri FY 2021, page 138-148	Preserving the Environment
C.1.4	The company's efforts to interact with the communities in which they operate?	Policy and Implementation : Sustainability Report of Bank Mandiri 2021, page 150-163	Concern for Society
C.1.5	Describe the company's anti-corruption programmes and procedures?	Implementation of Anti-Corruption Strategy : Implementation of Anti-Fraud Strategy - Annual Report of Bank Mandiri FY 2021, page 47 Anti Corruption Program - Annual Report of Bank Mandiri FY 2021, page 740 Gratuity Reporting Mechanism - Annual Report of Bank Mandiri FY 2021, page 741-742	Implementation of Anti Fraud Strategy Anti Corruption Program Gratuity Reporting Mechanism
C.1.6	Describe how creditors' rights are safeguarded?	Creditor's Rights Policy - Bank Mandiri Website Creditor’s Rights (OJK Recommendation) - Annual Report of Bank Mandiri FY 2021, page 500 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 corporate responsibility (CR) report/section or sustainability report/section ?	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 : Reporting Media (Annual Report of Bank Mandiri FY 2021, page 747) Customer Complaint Handling (Sustainability Report FY 2021 page 111-112) Contact Us (Bank Mandiri Website)	Reporting Media Customer Complaint Handling 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 : Employee Engagement - Annual Report of Bank Mandiri FY 2021, page 451 Performance and Reward Management (Bank Mandiri Website - About Mandiri Menu - GCG - Governance Process - Governance Document - Performance & Reward Management) Improving The Quality of Personnel	Performance and Reward Management Employee Engagement Improving The Quality of Personnel
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 development as follows : Performance and Reward Management (Bank Mandiri Website) Employees Competence Development - Annual Report of Bank Mandiri FY 2021, page 147-148 Employee Development - Annual Report of Bank Mandiri FY 2021, page 437-438 Employee Competencies Development - Annual Report of Bank Mandiri FY 2021 page 439-440	Performance and Reward Management Employees Competence Development Employee Development Employee Competencies Development
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 : Employee Engagement - Award - Annual Report of Bank Mandiri FY 2021, page 451-452 Performance and Reward Management - Bank Mandiri Website	Employee Engagement - Award 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 whistle blowing policy which include procedures for complaints by employeesconcerning alleged illegal (inclucing corruption) 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) Whistleblowing System (Annual Report of Bank Mandiri FY 2021, page 746-748) Gratuity Reporting Mechanism (Annual Report of Bank Mandiri FY 2021 page 741-742) 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) Gratuity Reporting Mechanism
C.4.2	Does the company have a policy or procedures to protect an employee/person who reveals alleged 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 2021, page 747	Whistle blowing System Protection for Whistleblower

D. Disclosure and Transparency

Part	Items	BMRI Practice Year 2021	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 2021 regarding Shareholder Composition (Annual Report of Bank Mandiri FY 2021 , pages 150-151)	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 2021 regarding Shareholder Composition Shareholders’ Composition - Annual Report of Bank Mandiri FY 2021 , pages 150-151	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 2021. Board of Commissioners’ and Board of Directors’ Shareholding - Annual Report of Bank Mandiri FY 2021 , page 152 Stock Ownership of the Board of Commissioners - Annual Report of Bank Mandiri FY 2021 , page 542 Shareholding of the Board of Directors - Annual Report of Bank Mandiri FY 2021 , page 621-622	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 2021. Shares Ownership by Employees and/or Management (ESOP)/Management Stock Option Program (MSOP) - Annual Report of Bank Mandiri FY 2021, page 374-375)	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 2021, as mentioned under : Corporate Shareholding Structure - Annual Report of Bank Mandiri FY 2021 , page 156 - 157 Subsidiaries, Second-Tier Subsidiary Entities and/or Associates - Annual Report of Bank Mandiri FY 2021 , page 158-173	Corporate Shareholding Structure Subsidiaries, Second-Tier Subsidiary Entities and/or Associates
D.2 Quality of Annual Report Does the company's annual report disclose the following item :
D.2.1	Corporate objectives	Vision, Missions, and Corporate Culture - Annual Report of Bank Mandiri FY 2021, page 82-84 Marketing Strategies - Annual Report of Bank Mandiri FY 2021, pages 257 Business Review - Annual Report of Bank Mandiri FY 2021, page 262 Operational Review per Business Segment - Annual Report of Bank Mandiri FY 2021, page 274	Vision, Mission and Corporate Culture Marketing Strategies Business Review Operational Review per Business Segment
D.2.2	Financial performance indicators	Financial Highlights and Financial Ratios- Annual Report of Bank Mandiri FY 2021, pages 20-25 Analysis of The Company Performance - Annual Report of Bank Mandiri FY 2021, pages 59 Operational Review per Business Segment - Annual Report of Bank Mandiri FY 2021, pages 274-278 Financial Review - Annual Report of Bank Mandiri FY 2021, pages 328-361	Financial Highlights and Financial Ratios Analysis of The Company Performance Operational Review per Business Segment Financial Review
D.2.3	Non-financial performance indicators	Operational Highlights - Annual Report of Bank Mandiri FY 2021, pages 25 Operational Review Per Business Segment - Annual Report of Bank Mandiri FY 2021, pages 274-278 Corporate Governance Perception Index - Annual Report of Bank Mandiri FY 2021, page 482-485 ASEAN CG Scorecard Assessment - Annual Report of Bank Mandiri FY 2021, page 486 Customer Satisfaction Result - Sustainability Report of Bank Mandiri FY 2021, page 113	Operational Highlight CGPI Assessment ASEAN CG Scorecard Assessment Customer Satisfaction and Experience Survey Result Operational Review Per Business Segment
D.2.4	Dividend policy	Dividend Policy - Annual Report of Bank Mandiri FY 2021, page 373) Dividend Policy (Bank Mandiri Website)	Annual Report Bank Mandiri FY 2021 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 Directors & Commissioners' Profile - Annual Report of Bank Mandiri FY 2021, page 110-134 Diversity in Composition of the Board of Commissioner - Annual Report of Bank Mandiri FY 2021, page 669-670 Diversity of The Board of Directors - Annual Report of Bank Mandiri FY 2021, page 669-671	Board of Directors & Commissioners' Profile Diversity in Composition of the Board of Commissioner Diversity of The Board of Directors
D.2.6	Attendance details of each director/commissioner in all directors/commissoners meetings held during the year	Meeting Agenda and Attendance of The Board of Commissioners - Annual Report of Bank Mandiri FY 2021, page 547-548 Board Of Directors Meetings Agenda - Annual Report of Bank Mandiri FY 2021, page 624-629	Meeting Agenda and Attendance of The Board of Commissioners Board of Directors Meetings Agenda
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 2021, page 677-678)	Remuneration and Facilities of the Board of Commissioners and Directors
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 2021 as mentioned in : Statement of Good Corporate Governance Implementation - Annual Report of Bank Mandiri FY 2021, page 760 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 Corporate Governance Guidelines to Public Companies - Annual Report of Bank Mandiri FY 2021 page 487-502	Application of Corporate Governance Guideance to Public Companies Statement of Good Corporate Governance Implementation
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 2021, page 376-379, 380-382, 1001-1002, 1191-1213)	Transaction with Related Parties Related Parties Transaction Review Mechanism Policies for Transaction and Compliane Relevant Rules and Regulation Transaction with Related Parties & Related Party Transaction
D.3.2	Does the company disclose the name of the related party and relationship 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 2021, page 381-382, 1191-1213 (Related Party Transactions)	Name and Nature of Related Relations Related Party Transactions
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 2021, as mentioned in : Board of Directors and Board of Commisioner’s Share Trading (Annual Report of Bank Mandiri FY 2021, page 153 - 155)	Board of Directors and Board of Commisioner’s 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 2021 KAP fees amounting to Rp15 billion with details of audit fees on the financial statements worth Rp 14,7 billion and Rp450 million the rest for fees of other services provided by the Accountant. (Annual Report of Bank Mandiri FY 2021, page 699)	Fees for Audit Services and Other Services
D.5.2	Does the non-audit fee exceed the audit fees ?	Non-audit fee amounted to IDR 450 million does not exceed the audit fee that amounted to IDR 15 billion (Annual Report of Bank Mandiri FY 2021, page 699).	Fees for Audit Services and Other Services
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) Periodic Report - Annual Report of Bank Mandiri FY 2021 page 688	Quarterly Financials Periodic Report
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) Information on Bank Mandiri Website - Annual Report of Bank Mandiri FY 2021 page 199	Bank Mandiri Website Information on 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 2021, page683-687) 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 2021 on January 28, 2022 (within 120 days) through : The Print Media Kontan, Bisnis Indonesia and The Jakarta Post	Kontan, Bisnis Indonesia and The Jakarta Post
D.7.2	Is the annual report released within 120 days from the financial year end?	Bank Mandiri has published Annual Report FY 2021 through Bank Mandiri Website and Indonesia Stock Exchange Website on 28 January 2022, and has officially determined the Annual Report in GMS on 10 March 2022, as mentioned on : Annual Report (Bank Mandiri Website) IDX Website Bank Mandiri's Letter to OJK Number HBK.CSC/CMA.295/2022 date 16 February 2022, concerning The Submission of Bank Mandiri's Annual Report FY 2021 Financial Statement - Annual Report of Bank Mandiri FY 2021, page 927	Bank Mandiri Website IDX Website Bank Mandiri's Letter to OJK Number HBK.CSC/CMA.295/2022 Annual Report of Bank Mandiri FY 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 2021 in : Board of Director's Statement regarding The Responsibility For The Consolidated Financial Statements as at and for the year ended 31 December 2021 (Annual Report of Bank Mandiri FY 2021, page 916)	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) Investor Relations Group - Annual Report of Bank Mandiri FY 2021, page 689 Company Information and Data Access - Annual Report of Bank Mandiri FY 2021, page 732	Contact Us Investor Relations Group Company Information and Data Access

E. Responsibilities of the Board

Part	Items	BMRI Practice Year 2021	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) Annual Report of Bank Mandiri FY 2021, page 537 Annual Report of Bank Mandiri FY 2021, pages 617	GCG Charter Charter of Board of Commissiones Charter of 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 2021, page 535	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 ?	Duties and responsibilities of Board of Directors/Board of Commissioners are included in : Duties and responsibilities of Board of Directors (Annual Report of Bank Mandiri FY 2021, page 615) Duties and responsibilities of Board of Commissioners (Annual Report of Bank Mandiri FY 2021, pages 533) Duties and responsibilities of Board of Directors, (Bank Mandiri Website) Duties 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 2021, page 82-83	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. Annual Report of Bank Mandiri FY 2021, page 84 Annual Report of Bank Mandiri FY 2020, pages 634 Articles of Association, article 17, section 1 page 67	Review Vission & Mission by The Board Commissioners and Directors Evaluation of The Company's 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. Annual Report of Bank Mandiri FY 2021, page 251-261 Annual Report of Bank Mandiri FY 2021, page 634	Review Vission & Mission Evaluation of The Company's 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 2021, pages 733-738) 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 2021, page 737	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 2021, pages 737	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 2021 (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 2021, page 537-538 Annual Report of Bank Mandiri FY 2021, page 543-545 Annual Report of Bank Mandiri FY 2021, page 972	Bank Mandiri 2021 AGMS Result Bank Mandiri 2021 AGMS Highlight Changes of the Board of Commissioners Composition Independent Commissioner Structure and Management
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. The Tenure of the Board of Directors-Annual Report Bank Mandiri FY 2021, page 617 Tenure of Board of Commissioners - Annual Report Bank Mandiri FY 2021, page 535	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 Annual Report of Bank Mandiri FY 2021, pages 540-542 Annual Report of Bank Mandiri FY 2021, pages 620-621	Articles of Association, Article 14 Concurrent Position of The Board of Commissioners Board of Directors Concurrent Positions Policy
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 2021, pages 540 Annual Report of Bank Mandiri FY 2021, pages 619-620	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 2021, pages 558, 575-585	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 Nomination Committee is 3 (three) person from 6 (six) members of Nomination and Remuneration Committee, as well as according to POJK No.55/POJK.06/2016 regarding Implementation of Good Corporate Governance for Commercial Banks. Annual Report of Bank Mandiri FY 2021, page 577-578	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 2021, page 577-578	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 2021, page 575	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 2021, page. 580-582) Performance of the Meeting of Nomination Committee will be held according to the needs and assignment from Board of Commissioners, at minimum 2 (twice) in 1(one) year.	Meeting of Remuneration and Nomination Committee
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 2021, pages 558, 575-585	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 Nomination Committee is 3 (three) person from 6 (six) members of Nomination and Remuneration Committee, as well as according to POJK No.55/POJK.06/2016 regarding Implementation of Good Corporate Governance for Commercial Banks. Annual Report of Bank Mandiri FY 2021, page 577-578	Composition of Remuneration & Nominating Committee
E.2.15	Is the chairman of the Remuneration Committee an independent director/commissioner?	Chairman of Nomination and Remuneration Committee is Independent Commissioner namely Mr. Chatib Basri. Annual Report of Bank Mandiri FY 2021, page 577-578	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 2021, page 575	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 2021, page. 580-582) Performance of the Meeting of Nomination Committee will be held according to the needs and assignment from Board of Commissioners, at minimum 2 (twice) in 1(one) year.	Meeting of Remuneration and Nomination Committee
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 2021, page 562-574	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 2021, page 565-566	Structure, Membership and Expertise of the Audit Committee
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 Annual Report of Bank Mandiri FY 2021, page 565-566	Structure, Membership and Expertise of the 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 2021, pages 562	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 4.2.2, page 6, 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 2021, pages 565-566	Audit Committee Charter Structure, Membership and Expertise of the 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 2021, page. 569-572) 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 5.1, page 8)	Table of Audit Committee Meeting Agenda Committee Audit 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 3.1.1.2).c).i.(1) page 3 Annual Report of Bank Mandiri FY 2021, pages 563-564	Committee Audit 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: Charter of Board of Directors, Article 6, point 3 (page 4). Charter of Board of Commissioners, Article 7, section 5 (page 7). Meeting Schedule uploaded in Bank Mandiri Website Annual Report of Bank Mandiri FY 2021 page 546-547, 623-624	Charter of Board of Director Charter of Board of Commissioners Meeting of The Board of Commissioners (website) Meeting of The Board Directors (website) Meeting of The Board of Commissioners Meeting of The Board Directors
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 51 times, while Board of Commissioners arranged 26 BoC meetings. Annual Report of Bank Mandiri FY 2021, pages 547-548 Annual Report of Bank Mandiri FY 2021, pages 624-628	Meeting of The Board of Commissioners Meeting of the Board of Directors
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 2021, pages 549 Annual Report of Bank Mandiri FY 2021, pages 628-629	Board of Commissioners Meeting Attendance Board of Directors Meeting Attendance
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 2021, page 547-548 Charter of Board of Commissioners, Article 7, Section 2, page 7 Charter of Board of Directors, Article 10, Section 1, page 5 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 2021, page 624-628 Charter of Board of Directors, Article 10, section 1	Meeting of the Board of Commissioner Charter of Board of Commissioners The 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 26 times of Board of Commissioners’ internal meetings Annual Report of Bank Mandiri FY 2021 pages 547-548, 624-628	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 page 7 Annual Report of Bank Mandiri FY 2021 page 546 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) working days prior to convening the meeting to each member of Board of Directors, as mentioned in : Charter of Board of Directors, Chapter II, Article 12, point 1 page 6 Annual Report of Bank Mandiri FY 2021, page 623	Charter of Board of Commissioners Meeting of the Board of Commissioner 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 2021, pages 682-683	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 2021, Corporate Secretary has participated in various trainings. Education and/or Training of The Board of Commissioners, Directors, Committees, Corporate Secretary, Internal Audit Unit and Risk Management - Annual Report of Bank Mandiri FY 2021, page 215 Corporate Secretary Capacity Building Programs - Annual Report of Bank Mandiri FY 2021, page 682-683	Competence Development for The Corporate Secretary Corporate Secretary Capacity Building Programs
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 2021, pages 536 Annual Report of Bank Mandiri FY 2021, pages 617-618 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 2021, pages 536 Annual Report of Bank Mandiri FY 2021, pages 583-584 Annual Report of Bank Mandiri FY 2021, pages 617-618	Criteria for Members of the Board of Commissioners Requirements and Criteria Criteria of the Board of Directors
E.3.11	Are all the directors/commissioners subject to re-election at least once every 3 years; or 5 years for listed companies in countries whose legislation prescribes a term of 5 years² to 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 2021 page 536, 617	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 2021, pages 374-375 Annual Report of Bank Mandiri FY 2021, pages 672-673 Annual Report of Bank Mandiri FY 2021, pages 676-677	Employee Stock Option Program (ESOP)/Management Stock Option Program (MSOP) Remuneration Policy for the Board of Commissioners and The Board of Directors Remuneration and Facilities of the Board of Commissioners and 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 2021, page 676-677	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 2022 AGMS Result Bank Mandiri 2022 AGMS Highlight	Bank Mandiri 2022 AGMS Result Bank Mandiri 2022 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 2021, pages 672-673 Annual Report of Bank Mandiri FY 2021, pages 675-676 Annual Report of Bank Mandiri FY 2021, pages 678-679	Variable Remuneration Remuneration Policy for The Board of Commissioners and the Board of Directors Performance Measurement Related to Remuneration
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 2021, pages 691-698	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 Mr. Danis Subiyantoro Annual Report of Bank Mandiri FY 2021, page 690	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 2021, page 691	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 2021, pages 701-706 Annual Report of Bank Mandiri FY 2021, pages 761-801	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 2021, page 702-703 Annual Report of Bank Mandiri FY 2021, page 705-706 Annual Report of Bank Mandiri FY, page 716 Annual Report of Bank Mandiri FY, page 770-772 Annual Report of Bank Mandiri FY 2021, page 791	Risk Identification and Assessment Evaluation of Internal Control System Evaluation of Effectivenes of Compliance Function Active Supervision by The Board of Commissioners and Directors Review of Risk Management System Effectiveness
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 2021 pages 778-790	Key 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 conducted by Bank Mandiri is considered effective and proper, reflected in the implementation of internal control functions, i.e. internal audit, risk management, compliance, financial and operational control functions. (Annual Report of Bank Mandiri FY 2021, page 574) Statements From The Board of Directors and/or the Board of Commissioners or the Audit Committee on The Adequacy of Risk Management System - Annual Report of Bank Mandiri FY 2021 page 791	Statement of Internal Control & Risk Management Adequation Statements From The Board of Directors and/or the Board of Commissioners or the Audit Committee on The Adequacy of Risk Management System
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 2021, page 110-120 Annual Report of Bank Mandiri FY 2021, page 122-134	Board of Commissioners Profile Board of Directors Profile
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 2021, page 110 Bank Mandiri 2022 AGMS Result	Board of Commissioners Profile Bank Mandiri 2022 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 2021, page 122-134	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 2021, page 533-534	Role & 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 2021, page 110 Bank Mandiri 2021 EGMS Result	Bank Mandiri 2021 AGMS Result Annual Report of Bank Mandiri FY 2021
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 2021, pages 110-120 Annual Report of Bank Mandiri FY 2021, pages 122-134 Annual report of Bank Mandiri FY 2021, pages 668-671	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 2021, pages 538-539 Annual Report of Bank Mandiri FY 2021, pages 622-623	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 2021, pages 200-209 Bank Mandiri Website	Competence Development of Board of Commissioners and Board of Directors Board of Commissioners Development Program (website) Board of Directors' Development Program (website)
CEO/Executive Management Appointments and Performance
E.5.3	Does the company disclose how the board of directors/commissioners plans for the succession of the CEO/Managing Director/President and key management?	Bank Mandiri 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 2021, pages 583 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 2021, page 634-637	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 2021. Annual Report of Bank Mandiri FY 2021, pages 556-557 Annual Report of Bank Mandiri FY 2021, pages 634-637	Performance Assessment Criteria and Result of The Board of Commissioners Performance Asessmentof Individual 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 2021. Annual Report of Bank Mandiri FY 2021, pages 556-557 Annual Report of Bank Mandiri FY 2021, pages 634-637	Performance Assessment Criteria and Result of The Board of Commissioners Performance Asessmentof Individual 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 2021, pages 557-558 Annual Report of Bank Mandiri FY 2021, pages 639-640	Performance Assessment of the Committee Under the Board of Commissioners and the Basis of the Assessment Performance Assessment of the Committee Under the Board of Directors and the Basis of the Assessment

Level 2 - Bonus Items

Part	Items	BMRI Practice Year 2021	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 2022 AGMS Highlight, page 3 and Annual Report of Bank Mandiri FY 2021, page 512, 513-514, 524	Bank Mandiri 2022 AGM Highlight Annual Report of Bank Mandiri FY 2021
(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 10, 2022 Summons Date : February 16, 2022 (Less than 21 days) (Bank Mandiri 2021 AGM Invitation and Annual Report of Bank Mandiri FY 2021, page 512, 513-514, 524)	Bank Mandiri 2022 AGMS Invitation Annual Report of Bank Mandiri FY 2021
(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 2021, page 221-229	Sustainability Report of Bank Mandiri FY 2021
(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 2021 through the Print Media Koran Kontan, Bisnis Indonesia and The Jakarta Post on January 28, 2022	The Jakarta Post
(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 2021, page 672-673 Nominal Amount of Remuneration for The Board of Commissioners and Directors - Annual Report of Bank Mandiri FY 2021, page 677-678	Annual Report of Bank Mandiri FY 2021
(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 2021 page 114, 668)	Bank Mandiri Website Annual Report of Bank Mandiri FY 2021
(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 2021, page 668-669 Diversity in Board of Directors Policies and Its Implementation - Annual Report of Bank Mandiri FY 2021, page 669-671	Annual Report of Bank Mandiri FY 2021
(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 6 (sixn) 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 2021, page 577-578)	Annual Report of Bank Mandiri FY 2021
(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, poin 3.1.1.3) page 4 (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 2021, page 583-584)	Bank Mandiri Website Annual Report of Bank Mandiri FY 2021
(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 2021, 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 2021, page 584)	Annual Report of Bank Mandiri FY 2021
(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 10 March 2022, 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, 2021 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 2021, page 543-545)	Annual Report of Bank Mandiri FY 2021
(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 2021 as : IT Governance - Annual Report of Bank Mandiri FY 2021, page 461-462 Discussed in Board Agenda - Annual Report of Bank Mandiri FY 2021, page 624-628	Annual Report of Bank Mandiri FY 2021
(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 2021, page 586-598, 655-656, 661-665	Annual Report of Bank Mandiri FY 2021

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A. Right of Shareholders

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BMRI Practice Year 2021

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?

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

​​​​​​​Dividend & Split (Bank Mandiri Website)

Bank Mandiri 2022 AGMS Result, 2nd column

Annual Report Bank Mandiri FY 2021 page 373-374

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 2022 and performance tantieme (bonus) for Fiscal Year ended on December 31, 2021 for members of Board of Directors and Board of Commissioners of the Company, as mentioned under :

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

Dividend & Split (Bank Mandiri Website)

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)

Annual Report of Bank Mandiri FY 2021 page 509, Rights of the Shareholders

Bank Mandiri 2021 AGMS Result

Annual Report of Bank Mandiri FY 2021 page 515-523, Decision of the 2021 Annual General Meeting of Shareholders

Annual Report of Bank Mandiri FY 2021 page 524-529, Decision and Realization of the 2020 Annual General Meeting of Shareholders

Annual Report of Bank Mandiri FY 2021 page 530-532, 2020 Extraordinary GMS Implementation and Realization