Code of Conduct of PT Bank Mandiri (Persero) Chapter I Definition Article 1 In t

his decree: a. Bank is PT Bank Mandiri (Persero). b. Commissioner is member of t

he Board of Commissioners of the Bank as mentioned in its article of association
. c. Director is member of the Board of Directors of the Bank as mentioned in it
s article of association. d. Executive Management is Board of Directors as well
as Executive Vice President (EVP) and Senior Vice President (SVP) appointed by B
oard of Directors with specific duties, authorities and responsibilities as mand
ated by Board of Directors. e. Employee is employees of the Bank other than Exec
utive Management and Board of Commissioners, including permanent employees and e
mployees on contract basis. f. Members of the Bank are Board of Commissioners, E
xecutive Management and employee. g. Insiders are members and shareholders of th
e Bank. Insiders also include individuals / legal entities that are engaged by t
he Bank to provide products or services, such as legal consultant, public accoun
tant and others. h. Reward or compensation. Following are categorized as reward
or compensation: 1. Cash 2. Securities 3. Durable goods 4. Commissions 5. Specia
l price discounts 6. Price concessions 7. Special personal items 8. Special pers
onal services ( utilizing facilities owned by customers, business relatives or v
endors such as villas, vehicles and others) i. Gift is item for daily consumptio
n such as food / drink, flowers, cards and other that can express sympathy. j. P
romotional item is item used by the Bank or customers, business relatives or ven
dors for promotional purposes such as diaries, umbrellas, calendars, ballpoints
and others. k. Family relationship is a familial relationship with and between m
embers of Board of Commissioners, Executive Management and employees, as ruled i
n articles of association of the Bank and Letter of Decree of Director of Bank I
ndonesia no. 31/177/KEP/DIR dated 31 December 1998. This rule assumes following
as family relationship: 1. Parent (own/step/adopted)

2. Brother / sister (sibling / step / adopted) 3. Spouse 4. Child (own / step /

adopted) 5. child s in-law (own / step / adopted) 6. Grand parent (own / step / adop
ted) 7. Grand child (own / step / adopted) 8. Brother / sister in laws 9. Brothe
r / sister in laws (own / step / adopted) 10. Parent in laws Chapter II Objectiv
e and Target Article 2 Objective This Code of Conduct gives members of the Bank
proper and trustworthy direction in conducting businesses with customers, busine
ss partners and colleagues. Article 3 Target This Code of Conduct will enable me
mbers of the Bank to immediately detect any deviation in conducting businesses.
It will also prevent members of the Bank to have improper relationship with cust
omers, business partners and colleagues. However, it is not purposed to interven
e personal life of members of the Bank. Chapter III Conflict of Interests Articl
e 4 Explanation Conflict of interests is a condition where Members of the Bank i
n conducting his duties and responsibilities cannot make objective decisions as
authorized by the Bank. This condition is due to benefiting him- or her-self, hi
s or her families, or other outsiders other than the Bank itself. Article 5 Cove
rage a. Members of the Bank must act respectfully and responsibly and be free fr
om any influences that may jeopardize objectivity in conducting businesses or ca
use Bank to loose its businesses or reputation.

b. Members of the Bank must acknowledge, realize and avoid any activities that m
ay lead to conflict of interests. Member must report to his or her immediate sup
ervisor instantaneously when such activities are unavoidable. c. Members of the
Bank is not permitted to endorse or request approval for loan facilities and spe
cial interest rates as well as any exceptions for: 1. Him/her-self 2. His or her
families. 3. Business entities where he or she or his or her families has inter
ests. d. Members of the Bank must not have any relations with an organization or
individual that might lead to conflict of interests. e. Members of the Bank can
not concurrently assume responsibility as director, employee, consultant or comm
issioner of other financial institution, unless that institution is a subsidiary
or an affiliate of the Bank or as assigned by the Bank. f. Members of the Bank
cannot concurrently assume responsibility as director, consultant or commissione
r of any business entities unless Bank permits it in written. g. Members of the
Bank are forbid to directly or indirectly vend products or services to the Bank.
h. Members of the Bank may use and utilize all facilities and resources of the
Bank for business purposes only. i. Members of the Bank are forbid to seize prop
erties of the Bank purposely for any individual, family member or other outsider
. j. Members of the Bank might have transaction on securities, foreign exchanges
, metal, commodities and derivatives for his or her own interest providing that
there is no conflict of interests, violation of insider trading regulation of BA
PEPAM and other laws and regulations. Chapter IV Confidentiality Article 6 a. Me
mbers of the Bank must understand and acknowledge that all information related t
o Bank and its customers is confidential and must maintain its confidentiality.
b. Information received by members of the Bank is only for operational purposes
of the Bank, and cannot be used for benefits of receiver, receiver s families and ot
her third parties or activities other than of the Bank. Violation of which may b
reak article 47 (2) of Act no 7 year 1992 about Banking as amended into Act no.
10 year 1998 and / or rules on insider trading of BAPEPAM. c. Members of the Ban
k might not disseminate information on business activities of the Bank otherwise
authorized by and on behalf of the Bank and obliged by regulation. d. Members o
f the Bank must act according to policies and internal procedures of the Bank up
on receiving request for information on customers of the Bank.

Member must seek direction from his or her immediate supervisor before releasing
the information when in doubt. e. To prevent any misuse, information disseminat
ion to internal parties of the Bank must be made carefully and only to relevant
parties. f. Members of the Bank might not spread information to external parties
on following: 1. Businesses of the Bank with the Government of Republic Indones
ia 2. Internal policies and work procedures of the Bank 3. System management of
information, data and reporting 4. Data of employees, either active or inactive
5. Business activities with customers and business partners e. Former members of
the Bank are obligated to keep all of the confidentialities of the Bank, as reg
ulated by article 323 (1) of Criminal Act. Chapter V Abuse of Authority Article
7 b. Members of the Bank might no exploitation his or her authority and profit f
rom his or her knowledge of business activities of the Bank, directly or indirec
tly, for: 1. Personal benefit 2. Benefit of his or her families 3. Benefit of ot
her third parties a. Members of the Bank might not request or accept, allow or a
pprove to accept reward or compensation from third parties in order to get or in
attempt to get loan facilities from the Bank, either cash or non-cash loan, or
in arrangement to buy or discount bank drafts, promissory notes, checks and trad
e bills or other liabilities and facilities that related to operational activiti
es of the Bank. b. Members of the Bank might not request or accept, allow or app
rove to accept reward or compensation from third parties that get or seek to get
job orders for procuring activities of the Bank. c. When customers, business pa
rtners and other third parties of the Bank give gifts on certain occasion, such
holidays, celebration, disaster / tragedy and others and if: 1. the giving will
give negative influence and affect the decision making of the Bank, and 1. The v
alue is not proper, then member of the Bank that receives it must return it imme
diately and explain politely that members of the Bank cannot accept any gift. a.
When the gift abovementioned in point d cannot be returned for one reason or an
other, member of the Bank received it must report immediately to his or her imme
diate supervisor that will take necessary action as regulated. b. When customers
, business partners and other third parties of the Bank give promotional items t
o members of the Bank, and member may accept the giving

c.
d. e. f.
as long as he or she believes will not be affected in making the decision by the
giving. Members of the Bank must seek the best price with maximum discount in p
rocuring products and services for the Bank. Those discounts from such as office
furniture and fixtures / ticket / insurance premium and or money back from nota
ry, lawyer / legal consultant, appraiser, independent accountant and or other di
scount, must be recorded for the benefit of the Bank. Members of the Bank might
not use his or her function in the Bank to loan from customers of the Bank. Memb
ers of the Bank might not use facilities of the Bank for personal benefit other
than provided by the Bank. Immediate supervisor might consult with Human Resourc
es Division and Legal Division to review reward and compensation, gifts, promoti
onal items and price discounts that are not included in this section.
Chapter VI Insiders Article 8 a. Insiders with confidential information might no
t use the information to profit for him- or herself, his or her families or othe
r third parties, to: 1. influence individual or institutional customers of the B
ank in transacting with the Bank 2. disseminate that confidential information to
individual or institutional customers of the Bank. a. Members of the Bank might
not use internal information to buy or trade securities, unless that informatio
n is already available to the public. b. Insiders might not all the time misuse
their position and function and profit from it or influence decision making proc
ess. c. Decision to sell or buy assets or services of other banks must put inter
ests of the Bank at first without any influence from insiders, particularly when
reward, compensation, entertainment and others are exist. Chapter VII Integrity
and Accuracy of Data of the Bank Article 9 a. As banking is a highly regulated
industry, data accuracy presented by the Bank must be valid and accountable. b.
Members of the Bank, either on his or her initiative, as ordered by his or her s
upervisor or as requested by other third parties, might not book, edit, and or e
rase data improperly, mislead or intentionally obscure a transaction. c. Members
of the Bank must follow standard procedures of the Bank, that all data changes
and omission must be authorized by persons in charge.

d. Members of the Bank might not manipulate receipts, including medical receipts
for improper prices. Chapter VIII Integrity of Banking System Article 10 a. Mem
bers of the Bank, either individually or mass, might not involve in proceedings
that could weaken or diminish integrity of Indonesian banking system. b. Members
of the Bank must be firm to ensure that they are not manipulated to do criminal
or other illegal activities. c. Members of the Bank must aware of money launder
ing activities and prevent the Bank involvement in those activities. This will a
lso include restraining each individual members of the Bank from drugs and narco
tics use. d. Bank has effective know your customer policy and comprehensive procedure
without expensing customer s interests. This policy requires members of the Bank to
infer any irregular transaction and take necessary action to detect suspicious
accounts for money laundering, corruption and other criminal acts. Chapter IX Ad
ministration of Account of Employee Article 11 a. To ease salary payment for emp
loyee and other services, Bank requires members of the Bank to open an account w
ith the Bank. b. Bank must ensure that all employees
accounts opened in the branch
are adequately supervised and reviewed, hence meet all personnel division condition
as well as keep the confidentiality of those accounts. Chapter XI Annual Disclo
sure Article 12 a. Members of the Bank must sign annual disclosure as attached i
n this decree, in relation to code of conduct implementation particularly: 0. Fa
milial relationships or interests 0. Reward / present, gifts and promotional ite
ms 0. Compensation from third parties 0. Income other that salary, bonus and per
sonal savings 0. Insider trading b. Official receiving this disclosure must unde
rstand clearly that it is confidential must maintain its confidentiality.

Chapter XI Sanction for Violation / Disobedient Article 13 a. Members of the Ban

k who violate or disobey this policy might be sanctioned as degree of breach. Sa
nction made by the Bank subject to type of violation, degree of breach and compr
ehensive review upon the violator. b. All conflict of interests or violation mus
t be reported to handled by each members
immediate supervisor with following order:
1. Non officer Reports to and is evaluated by immediate supervisor. Copy of whi
ch is sent to Human Resource Division and Office of Compliance. 2. Officer Repor
ts to and is evaluated by EVP Human Resources/Training. Copy of which is sent to
Compliance Director. 3. Executive Management Reports to and is evaluated by pre
sident director. Copy of which is sent to Compensation Committee. 4. Director Re
ports to and is evaluated by Board of Commissioners or Bank s legal counsel. Copy of
which is sent to Compensation Committee. 5. Commissioner Reports to and is eval
uated by Shareholder s Meeting. Chapter XII Supervision and Update of Implementation
Article 14 a. Executive Management in charge of Human Resources is responsible
for implementation and documentation of this Code of Conduct. b. If due to some
internal or external reasons this Code of Conduct is irrelevant then Executive M
anagement in charge of Human Resources obligates to propose the amendment and up
date to Boards of Directors and Commissioners. Chapter XIII Closing Article 15 a
. Matters that have not been governed in this decree will be governed separately
. b. Considering that matters in Board of Directors Circular Letter no. DIR/001/199
9 dated December 20, 1999 regarding Receiving Reward/Compensation/Using

Facilities from Bank s affiliated parties had been included in this code, then that
Circular Letter is revoked. c. This decree is applicable since the date signed.
Determined in Jakarta on April 18, 2000 PT Bank Mandiri (Persero)
Binhadi President Commissioner
Robby Djohan__ President Director