The Code of Ethics PT. Bank Danamon Indonesia Tbk (hereinafter referred to as "Code of Ethics") represent ethical and corporate culture values upheld by PT. Bank Danamon Indonesia, Tbk as part of its vision and mission.
The Code of Ethics aims to be a behavioural guideline to all Management and Employees of PT. Bank Danamon Indonesia, Tbk in performing their day-to-day duties and in establishing business relationships with customers, partners and third parties.
The Code of Ethics is expected to support business continuity and to maintain the good reputation of PT. Bank Danamon Indonesia, Tbk.
The Code of Ethics is an integral part of all policies of PT. Bank Danamon Indonesia Tbk and Collective Labor Agreement.
Management and Employee are obliged to be aware of, to understand, and to implement the Code of Ethics as well as PT. Bank Danamon Indonesia, Tbk. policies, Bank Indonesia Regulations, Financial Services Authority Regulations and other applicable laws and regulations.
All Heads of Working Unit are required to be a role model in the application of the Code of Ethics within the Working Unit they lead
The Code of Ethics is binding and therefore any breach of the Code of Ethics may be subject to sanctions, whether administrative, civil or criminal in accordance with the applicable procedures and regulations.
Any person who identifies the violation of the Code of Ethics, but fails to report such breach, is considered violating the Code of Ethics.
The following words and terms, unless expressly determined otherwise, shall have meanings as stated below:
Assets are all facilities and infrastructure that is provided by the Company, whether owned or leased, to support the work of Management and Employee in the Company. Included as Assets are, but not limited to, software/hardware, intellectual property, data and information in either digital or non digital format, both tangible and intangible.
Covered Person are Management and Employee, who by virtue of their position/employment, may obtain material non-public information, or whose personal investment decisions may conflict with their professional roles, whether related to Bank Danamon's securities or other securities.
Fraud is the act or omission that comitted intentionally to defraud, deceive, and manipulate the Company, customers, or other parties, which happened in the Company and/or using the facilities of the Company that resulted in the losses for the Company, customers or other parties and/or the fraudster obtains financial benefits both directly or indirectly.
Family Interest is the interest of Management and Employees that relates to the interest of parties who have marital and/or family relationships including parents, siblings, spouses and children.
Management includes all Board of Directors, Board of Commissioners, Sharia Supervisory Board, include but not limited to any person from outside the Company who is a member of the Audit Committee/Risk Monitoring Committee.
Public Official means official, employee (regardless of rank or level), member and representative of any of the following:
- National, regional, local or municipal government bodies (e.g., executive, legislative, judicial), departements, agencies, or instrumentalities thereof (e.g., central banks, sovereign wealth funds, state utilities);
- State or regional- controlled companies. Generally, a company would be deemed state or regional-controlled if one or more government bodies, departments, or agencies have at least one of the following attributes:
- More than 50% ownership;
- Voting Control;
- Board Control; or
- Other Indicator of Control
- International organizations, development banks, and public health agencies (e.g., the United Nations, World Bank, or International Monetary Fund);
- Royal families;
- Political parties and the offices of candidates for any political office; and
- Any entity whose employess or representatives are deemed "public officials" by local law or regulation, including for Indonesia, individuals receiving salaries or wages from: a) a corporation which receives assistance from state or regional finance, or b) other corporations which use capital or facilities from the state or from the public.
Employee is a person who has a working relationship with the Company and has fulfilled the conditions stipulated in accordance with the provisions of manpower laws.
The Company is PT. Bank Danamon Indonesia, Tbk
Head of Working Unit (Supervisor) are the parties who lead working units in accordance with the applicable Company organization.
Securities shall mean all forms of stocks, notes, bonds, debentures, or other evidences of indebtedness, including senior debt, subordinated debt, commercial papers, investment contracts, commodity contracts, futures and all derivative instruments such as options, warrants and stock index futures, include but not limited to Company’s security.
C. VISION, MISSION AND COMPANY VALUES
1. Company Vision
Vision is the direction to be achieved by the Company in the long term. A clear vision is necessary to enable everyone in the organization to have the same frame of mind in creating business strategy, determining goals, and in the way of accomplishing the determined goals, as well as monitoring the implementation.
The Company's vision is care and help millions to prosper.
Such vision means that Management and Employees must have sincere and honest attention to all constituents including customers, employees, business partners, community and shareholders and help facilitate them, to grow and prosper.
2. Company Mission
The Company seeks to realize its vision through it's mission statements as follows:
- The Company aims to be the "Leading Financial Institution" in Indonesia with a significant market presence;
- A customer centric organization, which covers all customer segments, each with value proposition, based on sales and service excellence supported by world-class technology;
- To become the Employer of choice and to be respected by customers, Employees, shareholders, regulators and the communities, wherever the Company is located.
3. Corporate Values
Corporate Core Values are core values upheld by the Company in its journey to attain its vision and mission.
The Corporate Core Values consist of Berkolaborasi (Collaboration), Integritas (Integrity), Sigap Melayani (Customer Centric) and Adaptif (Adaptive) or abbreviated as “BISA”.
Leveraging diversity as strength to achieve common goals:
- Thinking and Working Together
Think and work together with my colleagues to achieve common goals.
- Display sense of ownership
I initiate, commit, and assume responsibility of the work process, contributing towards the achievement of the common goals.
- Give Mutual Respect
- I accept, understand and respect diversity as a source of strength.
- I contribute towards a positive and conducive work environment.
Prioritize professionalism, transparency, accountability and code of ethics as work guidance in a consistent manner.
- Take accountability
- I am committed and responsible over decisions and action taken.
- I immediately escalate any irregularity and recommend solutions.
- Be transparent
- I am honest and consistent in both my words and actions.
- I am open in giving and receiving opinions or ideas.
- Act Fairly
I give out appreciation and recognition based on performance objectively without hesitation.
- Customer Centric
Providing the best service excellence accurately and immediately.
- Listen and understand customer
- I will continuosly solicit customer feedback for improvement of the bank.
- I understand and fullfill customer's needs by leveraging the latest information and technology.
- Be responsive and reliable
- I respond to customer request and deliver my promise.
- I actively take part in improving the quality and financial knowledge of individuals, customers as well as community at large.
- Give added value
I always give added values in delivering services.
Always adapt and develop self potential to be the best.
- Be competitive
I have the courage and positive mindset to take on competition for the good of the organization.
- Be innovate
I will not hesitate to contribute to new ideas and improvement.
- Be agile
- I am nimble in anticipating, and responding positively to changes.
- I am not afraid to try something new and conduct positive changes.
ZERO TOLERANCE TO FRAUD
- The Company has zero tolerance to Fraud. Any Management and Employees found committing fraud will be prosecuted in accordance to the prevailing law.
- Responsibility to prevent Fraud from happening is relied on Management and Employees.
- Management and Employees obliged to conduct their jobs and responsibilities in accordance with prevailing laws and Company's regulation.
- In the event of a suspected Fraud, Management and Employee who become aware of the Fraud must immediately report as per Company’s policy and regulation.
- Once the Fraud is established, it is responsibility of process owner to review the existing work process and governance to prevent a repeat of the Fraud.
- Management and Employees are obliged to sign the Integrity Pact on the Implementation of Anti-Fraud Strategy
CONFLICT OF INTEREST
The common principles that are the foundation of the Company's policy with regard to conflict of interest are:
- Management and Employees must avoid a situation of conflict between their personal interest and the Company’s interest;
- Personal interests include Family Interests and the interests of others;
- In the event of a conflict of interest arises, Management and Employees with a personal interest are not allowed to engage in all stages of decision-making and shall disclose the conflict of interest in accordance with applicable policies in the Company.
- Management and Employees are prohibited from misusing authority and taking advantage either directly or indirectly from the Company's business activities for personal interest.
- If any conflict of interest arises amongst anyone from the Management or Employees it must be declared, so that the Company can take appropriate actions in accordance with applicable policies and procedures of the Company.
A. Activities Outside the Company
In order to avoid conflict of interest, Management and Employee have an obligation to disclose any activities conducted outside the Company, either in the annual statement and/or through the Supervisor in accordance with applicable policies in the Company.
Management and Employees shall not engage in activities outside the Company, including being bound by employment agreement with other parties and/or obtaining other income outside the Company that satisfies the following conditions:
- Their outside activities are performed during office hours; and/or
- Create any conflict or association with his/her occupation/position in the Company; and/or
- Can be deemed to impact their concentration on their work and/or fulfillment of their duties at the Company; and/or
- Impact their professionalism and/or integrity in any manner whatsoever.
In the event that such circumstances are unavoidable, Management and Employees are required to obtain written permission and/or assignment from the Company in accordance with applicable policies of the Company.
The Company upholds the freedom of Management and Employee as individuals to associate and to assemble, including participation in association/clubs/social, political and religious organizations with the following conditions:
- Association/clubs/community organizations are not prohibited by the Government; and/or
- Association/clubs/community organizations adhere to values which are not contradictory to the values applied by the Company and/or Company reputation; and/or
- Association/clubs/community organizations do not impact working hours, occupations/positions in the Company, concentration, professionalism and integrity of the Management and Employees.
In order to avoid conflict of interest, Management and Employees are not permitted to assume positions in any political parties and/or political-oriented public organizations.
Management and Employees are prohibited from misusing their positions or authorities to influence other employees to join or participate in any activities of the association/club/party/community/organization they attend.
B. Utilization of the Company's Assets
In order to create an adequate and appropriate working environment, the Company provides Assets to support the work of Management and Employees within the Company.
Management and Employees are responsible to utilize the Assets provided for the interest of the Company with due regard to the prevailing procedures.
Management and Employee should understand that they do not own these Assets provided by the Company during their work and these must be returned to the Company at the end of the assignment.
Management and Employees are prohibited from using Assets for personal purposes since that can harm the Company's interests.
Management and Employees are responsible to safeguard all Company's Assets entrusted to them.
Management and Employees shall only use the Company's assets in relation with their job and responsibilities.
The Company reserves the rights to monitor and enforce necessary measures on all assets used by Management and Employees to protect Company from the risk of misuse and loss including but not restricted for investigation purposes if there is any indication of violation.
C. Personal Investment
- Management and Employees may conduct Securities transactions, foreign exchange trading, precious metals, and other transactions for personal interest only if there is no conflict of interest, violation of Company policy, insider trading regulations and other laws and regulations.
- Personal investment decisions should be geared towards and based solely on publicly available information.
Management and Employees are required to obtain prior written approval from Supervisor and Compliance Unit for conducting personal investment related with Securities issued by the Company and/or its affiliated party.
In the event Management and Employees invest in the Securities of the Company and/or its affiliated party, they can trade again in the same Securities only after mandatory holding period of 30 calender days.
- A Covered Person should prevent any conflict of interest in making any personal investment over Securities (issued by the Company or its affiliated party) decisions. Company may cancel such planned personal investment decisions by a Covered Person in accordance with applicable policies in the Company.
COMPANY INFORMATION MANAGEMENT
A. Information Security
All data and information are Company's proprietary and cannot be used by Management and Employee, for any purpose, other than performing their responsibilities as specified in their job requirements.
Management and Employees are responsible for safeguarding and maintaining the confidentiality of all data and information (including customer and non customer data) in accordance with the agreed Company's Information Security Policies and shall adhere to the procedures established to prevent the spread and misuse of non public information via any kind of media, such as email, social media, and other communication tools.
The obligation to protect the confidentiality of all non-public information is applicable for Management and Employees even after resignation from the Company.
Management and Employees found to have violated the Company’s Information Security Policies and/or having used the Company's system for unauthorized activities will be subject to disciplinary action.
B. Accuracy of Company Reporting and Recording
- All reports, data, and information owned, used, and managed by the Company shall be accurate and complete.
- The Management and Employee are responsible for the integrity of the reports, data, and information, which fall under the control of respective Management and Employees.
- The preparation, recording, and/or reporting of information should consider the completeness, accuracy, and confidentiality aspects of the information, to avoid providing any misleading information to relevant users and to prevent causing errors in decision making.
- All reports, data, and information shall be kept in accordance with the applicable laws and/or Company’s policies.
- Making false or misleading statements to anyone, including but not limited to the external or internal auditors, consultants of the Company or Regulator, is a criminal offence which may result in severe penalties.
- Management and Employees must take all measure ensure the accuracy of reports, data, and other information provided to internal and external stakeholder.
- All information and reports submitted to regulators and public must be in accordance with the applicable regulations.
- Management and Employees must consider the agreed security measures to be taken when such data/information is transmitted, whether in digital or non-digital format.
C. Company Identity
- Company Identity, including and not limited to any other Company's name, logo, brand and other intellectual property rights, is wholly owned by the Company.
- Management and Employees may utilize Company Identity solely for the purpose of Company’s business and misuse and personal use of the Company Identity is prohibited.
- Usage of Corporate Identity should comply with applicable provisions concerning copyrights, trademarks, publicity rights and Company policy.
D. Social Media Usage
- Management and Employee shall not publish and or declare any material in social media on behalf of the Company and/or represent the Company, unless specifically authorized by the Company and /or based on Company directives.
- Management and Employees are prohibited to use Company’s logo, symbol or other Company’s identity on a personal social media account, unless specifically authorized by the Company and /or based on Company’s directives.
- Management and Employees's social media behaviour should comply with applicable rules and regulations, including but not limited to regulations concerning information and electronic transactions and related Company policies.
- At all times Management and Employees must ensure that the authorised use of Company’s logo, symbol or other Company’s identity on personal social media account should not in any way harm the Company’s reputation or be used in a manner that results in bringing disrepute to the Company.
E. Providing Information to Other Party
- Management and Employees are not allowed to provide any information to other parties, directly or indirectly, if that information has potential to:
- cause harm to the Company or other concerned parties; and/or
- provide personal benefits either to any person, group, or other third parties, and/or
- violate the information security policies of the Company; and/or violate any regulation and/or law.
- Providing information to third parties outside the Company (for publicity purposes) shall be made only by authorized personel with the prior written consent from the Company.
- In order to maintain good image of the Company, Management and Employees shall maintain confidentiality and protect all forms of information they know that belongs to other parties. Management and employees are not entitled to disseminate such informations before obtaining formal acknowledgement from both involved parties, or based on commitment with other parties or applicable laws and regulations.
ANTI MONEY LAUNDERING AND PREVENTION OF TERRORISM FUNDING
- Management and Employees must act diligently to prevent our products and services from being used to further money laundering and terrorist financing and to detect suspicious activity in accordance with relevant laws and regulations.
The Company adopts Anti Money Laundering industry principles that outline the role that financial institutions can and should play in preventing money laundering and the financing of terrorism.
The Company is committed to combating money laundering, terrorist financing and other crimes to the fullest extent permitted by law. In accordance with the Company Anti Money Laundering Policy, the Company's line of businesses must develop and implement effective Anti Money Laundering programs to comply with applicable laws and to protect Company from being used for money laundering or terrorist financing.
These programs emphasize the importance of knowing and understanding who Company is dealing with (“Know Your Customer”), identifying parties involved in transactions and monitoring certain activity and transactions to look for any unusual activity.
- Management and Employees should become familiar with and follow the requirements set forth in the Company Anti Money Laundering Policy and related policies and procedures, including those that govern specific business and legal entity. Management and Employees responsibilities include applying the appropriate level of due diligence when entering into client relationships and, where applicable, individual transactions. No client relationship is worth compromising our commitment to combating money laundering, terrorist financing and other crimes.
- In order to prevent the Company from being used as a media/destination of money laundering and/or terrorism financing, the Company has applied Know Your Employees principles in the screening process of new Employees and in monitoring Employee profiles which cover character, behaviour and lifestyle.
- Management and Employees are prohibited from providing banking products, services, and/or advice that helps any client in money laundering, tax evasion, and/or terrorism financing in accordance with relevant laws and regulations, including violations of Sanctions Policies. Failure to comply with these laws and regulations can have serious consequences, including legal liabilities and penalties.
- Management and Employees must not disclose the handling and reporting of Suspicious Financial Transactions. Notification to customers or other unauthorized parties is categorized as an act of data leakage (tipping off)
BUSINESS ETHICS OF COMPANY
In carrying out its work, Management and Employees are required to apply business ethics which harmonise with Company’s values and are in line with the vision and mission of the Company.
A. Personal Ethics
- Appearance and attire of the Management and Employees shall reflect professional values and ethics.
- Management and Employees are prohibited from acting/speaking alluding to someone's physical defects, ethnic group, race, religion, either in Bahasa Indonesia or any other languages. In order to maintain a harmonious working environment, it is important to always remain professional. This includes communication through media such as email/letter/memo/social media/printed media.
- Management and Employees are not permitted to enter into or participate in any form of gambling and lottery in the Company's premises. Management and Employees shall not use the systems and equipment in the Company for such activities.
- Management and Employees are prohibited from being intoxicated or consume intoxicating drinks in the Company’s premises.
Management and Employees are also prohibited from retaining/ misusing/using and/or distributing narcotics, psychotropics, drugs and other additives/other stimulants in the Company’s premises.
- Management and Employees are prohibited from storing/carrying guns or any dangerous weapons in the Company’s premises, except for Management and Employees designated for the purpose by the Company and carried out in accordance with applicable regulations.
- Management and Employees should protect the Company's reputation and avoid actions that could damage the Company's reputation.
- Management and Employees are prohibited from being involved/participating/assisting in criminal acts on any kind whatsoever.
- Management and Employees are responsible for escalating and disclosing if they become aware of potential risk issues that may cause financial, regulatory and/or reputational damage to the Company.
B. Ethics with Customers
- Management and Employee should serve every customer professionally by being polite, friendly and unpretentiously.
- Management and Employee shall be responsive and try to understand the needs and to find alternative solutions for the customer problems as much as possible by always considering the Company’s interest and prevailing regulations.
- The preciseness and efficiency of services are factors that support service excellence.
- In providing services to customers, the Management and Employees shall not provide services beyond the applicable procedures in the Company, which includes, but not restricted to providing or taking loans to or from customers in their personal activity and/or providing financial advice unless authorized by the Company as part of their job responsibilities.
- Management and Employees should be equipped with the knowledge and skills necessary to propose and provide services and products to the customers including regulatory certifications necessary for performing their duties.
- Management and Employees should provide clear and accurate information that allow customers to understand the nature and risks of the Company's products and services as well as to understand and accept the risks associated with them.
- Management and Employees should be fair-minded, courteous and sincere in serving and dealing with customers.
C. Ethics with Third Party
- In selecting a supplier/vendor/ outsourcing companies that function as partners, Management and Employee shall observe the principles of efficiency, effectiveness, competitiveness, transparency, fairness, and accountability.
- Management and Employees shall ensure that suppliers/vendors/ outsourcing companies/outsourced employees understand and comply with the Code of Ethics and relevant Company policies.
- Management and Employee shall ensure that the cooperation undertaken by the supplier/vendor has a written agreement and reasonable value of the transaction is conducted on arm's -length basis.
D. Ethics with Public Official
- The Company is committed to comply with applicable laws and regulations. Therefore, Management and Employee are obliged to study, understand and comply with any applicable laws and regulations.
- Management and Employees are also required to maintain good relationship and communication with the Public Official.
E. Ethics between Management and Employees
- Relations between Management and Employee based on mutual reliance, mutual dignify and respect based on Company values .
- The Company is committed to provide equal opportunity in all aspects of employment.
- The Company will not tolerate any discrimination based on race, color, religion, gender, national origin, social status, physical disability, and marital status.
- The Company prohibits any form of sexual harassment and the act of slander, attacking, abusing, threatening any Supervisor or fellow Employees and/or their families. This includes all forms of harrasment/slender whether done verbally and/or in writing via any form including but not limited to email electronic media, social media, etc.
- Management and Employees have the responsibility to create a positive work environment and ensure that all individuals are treated with respect and dignity.
- Management and Employees shall decide matters relating to work professionally and responsibly keeping in mind the Values of the Company.
- Management and Employees shall carry out the work on the basis of their authority with full responsibility and prudence.
- Management and Employees are not allowed to borrow and / or lend money and/or other favours to each other since that may affect professionalism in their performance.
- The Company has absolute authority to provide work, assignment, and/or job rotation/relocation with respect to all Management and Employees in accordance with applicable policies.
F. Protection and Utilization of Facilities of Customer, Client and Vendors
- Management and Employees are not allowed to use or receive facilities or favours from customers, clients, and or vendors and are not permitted to obtain or request loans from them for personal purposes.
- The purpose of this prohibition is to enable Management and Employees to take a firm position when making decisions under the prevailing rules/regulations based on their authority and responsibility, delegated to them.
G. Bribery and Corruption
- The Company prohibits bribery and corruption in any form, including but not limited to relationship involving Public Officials.
- Management and Employees must abide by all laws and regulations related to dealing with Public Officials.
- Bribery is an act committed by other parties toward Management and Employees and vice versa for the purpose of influencing decision-making and conducted merely for the interests/ benefit of both parties in conflict with applicable laws and regulations.
- Included therein, is the receipt or provision of a reward or promise to do so in the broadest sense or words, either in the form of money, goods, services, facilities or other convenience, with and/or without neglecting prevailing procedures and law when resolving an issue.
- Management and Employee are prohibited from offering, promising and/or giving anything of value, whether tangible or intangible, directly or indirectly to anyone either intended or appear as intended to obtain or retain an improper business benefit or advantage.
- In the event that it cannot be refused due to cultural sensitivities, then it must fulfill criteria determined by the Company and carry out pre-clearance refer to the prevailing Anti Bribery and Corruption Policy.
- Giving gifts and/or business hospitality may only be performed by Management and Employees appointed by the Company to maintain goodwill and this should be implemented in accordance with the prevailing provisions and must not contradictory to the Company's values.
H. Ethics with Competitors
- In conducting business and day-to-day operations, relationship with competitors becomes something that is difficult to be avoided both in business competition and in a cooperation or exchange of information. Therefore, it is necessary to notice below matters:
- Implement prudent principles and good communication ethics;
- Not defame a competitor, other company, other organization or country.
- Ensure compliance with Information Security policy and guidelines.
- Ensure that any exchange of information does not result in collusion.
- The Company respects and complies with the anti-monopoly law that supports fair and competitive business competition climate and always protects the interests of its customers from all unfair business practices.
I. Sustainable Growth (ESG)
- Company is committed to support the realization of sustainable development of the national economic system and help to prioritize the harmony between economic, social, and environmental aspects and address global environmental issues.
- Management and Employees are encouraged to always consider the consequences of their actions and identify solutions to help reduce negative environmental and social impacts that can arise from carrying out our business and operational activities.
- Management and Employees are committed to be actively working to find solutions to global environmental issues through its business activities.
- Management and Employees in performing their day to day operational activities are responsible for the environment through the use of resources (such as water, electricity, paper, plastics, etc).
- Management and Employees are participated actively in the implementation of corporate social responsibility activities.
CODE OF ETHICS ENFORCEMENT
A. Roles and Responsibility
Management and Employees shall study, understand, comply, and implement the Code of Ethics and report to the Company in the event of any breach of violation or any attempt to violate the Code of Ethics.
B. Annual Declaration
Management and Employee are required to submit annual declaration in relation to the implementation of the Code of Ethics, which includes among others:
- Relationship or interest which is indicated to cause conflict of interest with the Company;
- Family and/or marriage relationship;
- Activity outside the Company;
- Receiving and/or giving gifts/business hospitality;
- Information Security
C. Violation Reporting System (Whistle Blowing)
In recognition of the Company's commitment to continue implementing the principles of good corporate governance consistently and continuously, the Company implements a violation reporting system in order to provide opportunities for the Management, Employee, customer and third party to submit reports on alleged violations of good corporate governance principles and applicable ethical values, based on evidence and in good faith for the benefit of the Company.
Given this policy, none of Management and Employees may use their position to prevent a person from making a report.
If Management and/or Employess by virtue of their role in the Company become aware of the identity of the whistleblower, they must ensure that such identity does not become known to anyone who is not authorized to receive such information.
D. Breach of the Code of Ethics
- Non-compliance with this Code of Ethics is subject to disciplinary action in accordance to prevailing Company regulations and may be subject to sanctions based on civil or criminal law as in accordance with the applicable laws and regulations.
- In the event the Management and the Employees commit serious violation of the Code of Ethics, the Management and Employees will face sanctions including termination accordance with the applicable policies of the Company.
- Management and Employees, who identify the violation or attempted violation of the Code of Ethics but fail to report such breach, are considered to be violating the Code of Ethics.
E. Code of Ethics Implementation Guideline
- The Director in charge for Human Resources is responsible for the implementation and documentation of the Code of Ethics provisions.
- In the event there is inconsistency in the Code of Ethics, the Director in charge for Human Resources shall propose amendmens t to the Company.
- All matters that are yet to be provided or not adequately covered in the Code of Ethics shall be regulated further by a separate Company’s policy .
- The Code of Ethics shall become effective on the date of its promulgation.