Compliance Risk Compliance with Anti-Money Laundering and Terrorism Funding APU-PPT Legislation

Annual Report 2013 PT Bank Mandiri Persero Tbk.

3. Compliance Risk

As part of the efort to support the achievement of the Bank Mandir vision, the Compliance Function has prepared a Long-Term Compliance Plan focusing on the strengthening of the compliance function’s role as the 2nd line of defense. Eforts to strengthen the Compliance Function that were undertaken in 2013 include the following: a. Reining the Bank Mandiri Compliance Policy KKBM and Compliance Standard Guidelines SPKp. b. Preparing methodology for assessing the Compliance Function’s performance Compliance Quality Charter consisting of 3 dimensions, namely Speedy, Safe, and Steady. c. Standardizing staf competencies in the Compliance Function through a Compliance Oicer certiication program. d. Managing compliance risk in a more comprehensive and integrated manner through Enterprise Risk Management ERM.

4. Compliance with Anti-Money Laundering and Terrorism Funding APU-PPT Legislation

In compliance with the APU-PTT legislation, the Bank has taken the following measures: a. Further reining Bank Mandiri’s APU-PPT Policies and Standard Procedures in accordance with PBI No.1427PBI2012 dated 28 December 2012. b. Heightening awareness of APU-PPT bankwide through the provision of regular APU-PPT training. c. Enhancing AML Solution system to improve the monitoring of suspicious inancial transactions. d. Complying with requests for customer inancial transaction datadocuments, particularly in relation to alleged money laundering and terrorism, at the request of the regulators and law enforcement agencies BI, PPATK, KPK, Police, Attorney General’s Oice and BNN, with due observance to the SLA and the prevailing laws and regulations. e. Establishing and maintaining cooperation and coordination with the authorities, law enforcement Pursuant to Article 552 and Article 7 of Law No. 21 of 2011 on the Financial Services Authority OJK Law, as of 31 December 2013, regulatory and supervisory functions, duties, and powers over inancial services in the banking sector microprudential were transferred from Bank Indonesia to the Financial Services Authority OJK. The direct impact of this transition is that the Bank will be required to coordinate with 2 two regulators, namely BI and the OJK. Bank Mandiri is also required to continue complying with all regulations issued by BI to the extent that they are not amended, modiied or revoked, or declared void by the OJK or BI. These regulations include those on: 1. adjustment in shareholdings on the part of shareholders whose holdings exceed the maximum limit over 5 ive years counting from 1 January 2014. 2. adjustments to the commercial operations where such operations are not in accordance with BUKU. 3. the obligation of branch oices of banks that are domiciled overseas KCBA to place operational funds in inancial assets by fulilling certain requirement, where such placements shall amount to 8 of the relevant bank’s total liabilities every month, and at least Rp 1 trillion, up to December 2017. compliance human capital Annual Report 2013 PT Bank Mandiri Persero Tbk. Amendments to the laws and regulations during 2013 that had an impact on Bank Mandiri are as listed below:

1. Bank Indonesia Regulation Number 1517PBI2013 on Hedging Swap Transactions with Bank