Code of Conduct

Bank Danamon is a financial institution which the existancy and role are taken into account in the banking industry in particular and the national economy in general. With the large number of network across the provinces in Indonesia, as well as continue growth of the number of working units, the Bank is able to play its role in supporting economic growth and social sectors through venture fund raising, distribution of funds and other banking services as well as through employment opportunity in a significant amount. Commitment to continuously expand its business and the participation of more than three thousands employees has lead to numerous prestigious successes and honors. The achievement can be obtained due to the contribution of the power of integrity, moral ethics of the Parties which continuously improved and built. The success needs to be maintained, therefore, in line with the fast changing of business development, the Parties need to continue making necessary adjustments in business strategy and organization. With the increasing number of human resources, a guideline is required for The Parties which universally applied for act and behaviour in performing their tasks and responsibilities. These guidelines were derived from the Company Vision, Mission, Culture values, Banking Ethics, provisions, as well as the regulation incorporated in Code of Ethics. The Parties should know, understand, appreciate and agree to implement this Code of Ethics as the foundation of morals, attitudes and ethics in the act and behaviour. This Code of Ethics is made for the interest of the glory and betterment of Bank Danamon.


CHAPTER I

PRELIMINARY

A. Background 

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. PT Bank Danamon Indonesia Tbk’s Management and Employees are obliged to be aware of, to understand, and to implement the Code of Ethics as well as PT  Bank Danamon Indonesia Tbk's policies, Bank Indonesia Regulations, Financial Services Authority Regulations and other applicable laws and regulations. All Heads of Working Units are expected to be a role model in the application of the Code of Ethics within the Working Units 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 applicable procedures and regulations. Any  person who  identifies a violation of the Code of Ethics, but fails to report such breach, is considered to be in  violating the Code of Ethics.

B. Definition

The following words and terms, unless expressly determined otherwise, shall have meanings as stated below:

Assets are all facilities and infrastructure, tangible and intangible including but not restricted to software, hardware, intellectual property, data and information in either digital or non digital form provided by the Company, whether owned or leased, directly or indirectly by the company, to support the work of Management and Employees in the Company.

Covered Persons are all  Management and Employees, who by virtue of their position/employment,  may come across non-public information, or whose personal investment decisions may conflict with their professional roles.

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.

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 Units (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, including but not limited to the Company’s securities.

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 implementation.
    The Company's vision is to 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.
  1. Company Mission 
    The Company seeks to realize its vision through it’s mission statements as follow:
    1. The Company aims to be the "Leading Financial Institution" in Indonesia with a significant market presence;
    2. A customer centric organization, which covers all customer segments, each with a defined value proposition, based on sales and service excellence supported by world-class technology;
    3. To become the Employer of choice and to be respected by customers, Employees, shareholders, regulators and the communities, whereever the Company is located.
  1. Company Values
    Company’s values are the guidance for Management and Employees’ daily conduct in carrying out the duty and responsibility as to achieve goals stated in the Vision and Mission of the Company.

The values are:

  1. Caring
    We have a genuine concern for the well being and advancement of others. This brings out the best in us.
    • I respond to events that occur around us;
    • If I find a problem, I will escalate it to the appropriate stakeholders and will ensure that the problem is addressed in a timely and professional manner;
    • I listen sincerely to understand other people’s views;
    • I am sensitive to the needs of our stakeholders;
    • I anticipate possible problems and take steps to address them.

  2. Honesty
    We are true to ourselves and others without any hidden agenda.
    • I act with the highest standards of integrity;
    • I speak openly and candidly based on what I see as facts;
    • I courageously speak up when I know something is wrong;
    • I build trust by acting without any ulterior motive;
    • I admit my mistake when I am wrong.

  3. Passion to excel
    We dare to always come up with a better way of doing things whilst balancing the risk involved and never compromising the strength of our Company.
    • I never give up  finding a better solution;
    • I am focused in completing my work with excellence;
    • I will follow up issues until they are  resolved and if necessary I will refer  to a more competent party;
    • I explore ideas including unconventional they might be, always searching and investing to come up with an industry changing idea;
    • I am willing to take calculated risks and get buy in.

  4. Teamwork
    We achieve better result as a team, benefiting from the strength of our diversity.
    • The totality of Company is my ultimate concern;
    • I value differences as strengths;
    • I create synergies by seeking opinions of others to complete my thinking and get their help for execution;
    • I help others  whenever needed;
    • I will not let my colleagues fail;
    • I think and act win-win.

  5. Disciplined Professionalism
    We act with responsibility in order to uphold the standards and ethics of the profession, through disciplined people, disciplined thinking and disciplined actions.
    1. Disciplined People 
      • I lead by example;
      • I continue to update myself with the latest developments in my profession.
    2. Disciplined Thought
      • I admit if something is not working and courageously act to put it right;
      • I know my goals and focus on them.
    3. Disciplined Action 
      • I execute based on what is expected;
      • I take ownership for my area of responsibility and I am responsible for my actions.

 

CHAPTER II

CONFLICT OF INTEREST

The common principles that are the foundation of  the  Company’s policy with regard to conflict of interest are:

  1. Management and Employees must avoid a situation of conflict between their personal interest and the Company’s interest;
  2. Personal interests include Family Interests and the interests of others;
  3. In the event 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.
  4. Management and Employees are prohibited from misusing authority and taking advantage either directly or indirectly from the Company's business activities for personal interest.
  5. 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 Employees have an obligation to disclose any activities conducted outside the Company, either in the annual statement and/or through their Supervisor in accordance with applicable policies of 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:

  1. Their outside activities are performed during office hours; and/or
  2. Create any Conflict or Association with his/her occupation/ position in the Company; and/or
  3. Can be deemed to Impact their concentration on their work and/or fulfillment of their duties at the Company; and/or
  4. 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 Employees as individuals to associate and to assemble, including participation in association/clubs/parties/social, political and religious organizations with the following conditions:

  1. Association/clubs/parties/community organizations are not prohibited by the Government; and/or
  2. Association/clubs/parties/community organizations adhere to values which are not contradictory to the values applied by the Company and/or Company reputation; and/or
  3. Association/clubs/parties/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 Employees 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 their 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 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

  1. 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 any Company policy, insider trading regulations and other laws and regulations.
  2. Personal investment decisions should be geared towards long-term investments 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. 
  3. 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.

 

CHAPTER III

COMPANY INFORMATION MANAGEMENT

A. Information Security

All data and information owned by the Company is proprietary and cannot be used by Employees  without permission 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 in accordance with the 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

  1. All reports, data, and information owned, used, and managed by the Company shall be accurate and complete.
  2. The Management and Employees are responsible for the integrity of the reports, data, and information which fall under the control of respective Management and Employees.
  3. 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.
  4. All reports, data, and information shall be kept in accordance with the applicable laws and/or Company’s policies.
  5. 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.
  6. Submission of reports, data, and information to internal and external/public shall be in accordance with the applicable regulations.

C. Company Identity

  1. The Company Identity, including and not limited to the Company's name, logo, brand and other intellectual property rights, are wholly owned by the Company.
  2. Management and Employees may utilize the Company Identity solely for the purpose of Company’s business and misuse and personal use of the Company Identity is prohibited.
  3. Usage of the Company Identity should comply with applicable provisions concerning copyrights, trademarks, publicity rights and Company policy.

D. Social Media Usage

  1. Management and Employees 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.
  2. Management and Employees shall not use any Company logo, symbol or other company identity in a personal social media account.
  3. 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. 

E. Providing Information to Other Party

  1. Management and Employees are not allowed to provide any information to other parties, directly or indirectly, if that information has potential to: 
    1. cause harm to the Company or other concerned parties; and/or
    2. provide personal benefits either to any person, group, or other third parties; and/or
    3. violate the information security policies of the Company; and/or
    4. violate any regulation and/or law
  2. 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.
  3. 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 information before obtaining formal acknowledgement from both involved parties, or based on commitment with other parties or applicable laws and regulations.

 

CHAPTER IV

ANTI MONEY LAUNDERING AND PREVENTION OF TERRORISM FUNDING

  1. 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 thatfinancial 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 lines of businesses must develop and implement effective Anti Money Laundering programs to comply with applicable laws and to protect the 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.
  2. 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 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.
  3. 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 Employee principles in the screening process of new Employees and in monitoring Employee profiles which cover character, behaviour and lifestyle.
  4. 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. Failure to comply with these laws and regulations can have serious consequences, including legal liabilities and penalties..

 

CHAPTER V

BUSINESS ETHICS OF COMPANY

In carrying out its work, Management and Employees are required to apply business ethics which harmonise with the Company’s values and are in line with the vision and mission of the Company. 

A. Personal Ethics

  1. Appearance and attire of the Management and Employees shall reflect professional values and ethics.
  2. Management and Employees are prohibited from acting harshly or using harsh words, abusive or foul language, alluding to someone’s physical defects, ethnic group, race, religion, either in Bahasa Indonesia or any other language. In order to maintain a haramonious working environment it is important to always remain professional and unemotional. This includes communication through media such as email/ letter/memo/social media/printed media.
  3. 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 of the Company for such activities.
  4. Management and Employees are prohibited from being intoxicated or under the influence of any intoxication, including alcohol in the Company’s premises. Management and Employees are also prohibited from storing/ misusing/using and/or distributing narcotics, psychotropics, drugs and other additives/other stimulants in the Company’s premises.
  5. 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.

B. Ethics with Customers 

  1. Management and Employees should serve every customer professionally by being polite, friendly and unpretentiously.
  2. Management and Employees shall be responsive and try to understand the needs and to find alternative solutions for the customer problems, by always considering the Company’s interest and prevailing regulations.
  3. The precision and efficiency of services are factors that support service excellence.
  4. 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 capacity and/or providing financial advice unless authorized by the Company as part of their job responsibilities.

C. Ethics with Third Party

  1. In selecting suppliers/vendors/ outsourcing companies that function as partners, Management and Employees shall observe the principles of efficiency, effectiveness , competitiveness, transparency, fairness and accountability.
  2. Management and Employees shall ensure that suppliers/vendors/ outsourcing companies/outsourced employees understand and comply with the Code of Ethics and relevant Company policies.
  3. Management and Employees shall ensure that the cooperation undertaken by the supplier/vendor has a written agreement and the transaction is conducted on an arm’s-length basis.

D. Ethics with Regulator

  1. The Company is committed to comply with applicable laws and regulations. Therefore, Management and Employees are obliged to study, understand and comply with any applicable laws and regulations.
  2. Management and Employees are also required to maintain good relationship and communication with the Regulator. 

E. Ethics between Management and Employees

  1. Relations between Management and Employees are based on mutual reliance, mutual dignify and respect based on Company values.
  2. The Company is committed to provide equal opportunity in all aspects of employment.
  3. The Company will not tolerate any discrimination based on race, color, religion, gender, national origin, social status, physical disability, and marital status.
  4. The Company prohibits any form of sexual harassment and the act of slander, attacking, abusing, threatening any supervisor or fellow Employees / Management and/or their families. This includes all forms of harassment / slander whether done verbally and/or in writing via any form including but not limited to email, electronic media, social media, etc.
  5. Management and Employees have the responsibility to create a positive work environment and ensure that all individuals are treated with respect and dignity.
  6. Management and Employees shall decide matters relating to work professionally and responsibly keeping in mind the Values of the Company.
  7. Management and Employees shall carry out the work on the basis of their authority with full responsibility and prudence.
  8. 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.
  9. 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. Giving and Receiving Gifts and Entertainment

  1. Management and Employees are prohibited from giving or receiving any gifts and/or entertaiment to/from other parties as a form of remuneration and/or expression of interpersonal sympathy related to work and/or their position.
  2. In the event that Management and Employees receive gifts and/or entertaiment and for some reason it is difficult for the gift to be returned, Management and Employees must report the gift to the Company.
  3. Giving gifts and/or entertainment 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 not contrary to the Company's values.

G. Protection and Utilization of Facilities of Customer, Client and Vendors

  1. 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 or other favours from them for personal purposes.
  2. 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.

H. Bribery and Corruption

  1. The Company prohibits bribery and corruption in any form.
  2. 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.
  3. 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.

I. Ethics with Competitors

  1. 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:
    1. Implement prudent principles and good communication ethics;
    2. Not defame a competitor, other company, other organization or country.
    3. Ensure compliance with Information Security policy and guidelines.
    4. Ensure that any exchange of information does not result in collusion
  2. 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.

 

CHAPTER VI

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 Employees are required to submit annual declaration in relation to the implementation of the Code of Ethics, which includes among others:

  1. Relationship or interest which is indicated to cause conflict of interest with the Company;
  2. Family and/or marriage relationship;
  3. Activity outside the Company;
  4. Receiving gifts/entertainment; and/or
  5. 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, Employees, 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 Employees 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

  1. 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.
  2. 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 in accordance with the applicable policies of the Company.
  3. 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

  1. The Director in charge for Human Resources is responsible for the implementation and documentation of the Code of Ethics provisions.
  2. In the event there is inconsistency in the Code of Ethics, the Director in charge for Human Resources shall propose amendments to the Company.

 

CHAPTER VII

CLOSING PROVISION

  1. 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 .
  2. The Code of Ethics shall become effective on the date of its promulgation.