CIMB Niaga is committed to maintain the anti-fraud and anti- corruption principles in their business activities. This commitment is very important and in accordance with the Bank’s main activities that are closely related to financial transactions. Anti- fraud and anti-corruption have significant influence on the Bank’s sustainability.
In 2019, CIMB Niaga developed an Anti-Corruption Policy No.
M.11 of 2019 as the Bank’s commitment in supporting anti- corruption practice. This policy regulates the Bank’s principles in supporting anti-corruption practice; anti-corruption
The Bank has policies and strategies to achieve a zero fraud target. Anti-fraud and anti-corruption policies are integrated with other policies so they can become guidelines in mitigating and preventing fraud and corruption that are inherent in every activity.
Until the end of 2019, through corruption prevention efforts evaluated by the Anti-fraud Management Work Unit (AFM), there was no identified significant corruption risks. Hence, there was no significant losses in regards to fraud or corruption. [FN-CB-510a.1]
anti-Money Laundering & terrorism Financing Prevention Program (aPu
PT BANK CIMB Niaga TbkSustainability Report 2019
SuStainability Governance
APU and PPT program is undertaken by applying 3 (three) lines of defence, which are as follows:
1. First Line of Defence, followed by the Bank’s Business/
Control/Operations Units which conduct daily activities as the front line of the organization.
2. Second Line of Defense, a monitoring function to ensure the first line of defense has carried out a proper function.
3. Third Line of Defence, a monitoring function of the APU and PPT Programs carried out by the first and second lines of defence. This function is conducted by internal auditors, external auditors and the Board of Commissioners to ensure that the first-line and second-line defence functions were effective.
The implementation of APU and PPT activities is actively monitored by the Directors and Board of Commissioners.
Implementation activities include the implementation of APU and PPT policies and procedures, the formation of the Anti Money Laundering (AML) Group, APU and PPT training for employees, evaluation of effectiveness by internal parties, and reports to the Regulator. The Bank also applies Know Your Employee (KYE) as part of efforts to prevent APU, PPT and fraud.
anti-Fraud strategy
The anti-fraud strategy is CIMB Niaga’s commitment to a zero tolerance for all types of fraud and perpetrators. Through the principle of anti-fraud and compliance in the working environment, CIMB Niaga believes that anti-fraud activities will be able to grow an integrity value. Based on Bank Indonesia Circular Letter No.13/28/DPNP 2011, which has been updated with POJK No. 39/POJK.03/2019 concerning the Implementation of the Anti-Fraud Strategy for Commercial Banks, CIMB Niaga has formed a special Anti-Fraud Management (AFM) unit to carry out the anti fraud strategy implementation function.
CIMB Niaga applies anti-fraud to all parties, both employees and partners through anti-fraud and anti-corruption statements in the Cooperation Agreement (PKS), Work Order (SPK), whistleblowing site, electronic mail to all vendors, as well as banners and posters in the Bank work areas.
In order to support the developed anti-fraud value, CIMB Niaga conducts mandatory Anti Fraud Awareness training for all employees. The training aims to increase employee knowledge about fraud prevention and its consequences. In 2019, 22.87%
of CIMB Niaga’s employees participated in anti-fraud training.
Anti-fraud training was conducted not only through face-to-face but also through e-learning media and the Learning on the Go (LoG) application. These training and education activities have significant impact on reducing fraud cases. Many of the fraud cases handled in 2019 were also from the reports submitted through the whistleblowing service media.
In 2018 and 2019, there were no incidents of fraud involving the Board of Commissioners and Board of Directors, or the contract employees. Fraudulent parties included permanent employees who were followed up by legal actions.
Number of Fraud Cases*
Internal Fraud Cases
Perpetrator Board of
Commissioners
& Board of directors
Permanent employees
Non Permanent employees 2019 2018 2019 2018 2019 2018
Resolved - - 4 4 - -
In the Bank’s internal resolution
- - - - - -
Unresolved - - - - - -
Has been followed up in Legal Process
- - 1 2 - -
total Fraud - - 5 6 - -
*This data is cases with a nominal value exceeding Rp100 million.
Total Employees Joined Anti-Fraud Awareness Mandatory Training (Employees)
2018 2017
4,212
2,829
2019
3,335
wistleblowing system (wBs) [102-17, Fs9]
CIMB Niaga has a whistleblowing system (WBS) and has appointed independent and professional third parties to manage the complaints. The appointment of a third party aims to provide a comfortable and transparent process so that the reporter can submit violation or fraud indication report. The Bank has gradually improved this reporting system, both reporting mechanisms and reporting media socialization. The WBS policy refers to OJK Regulation No. 39/POJK.03/2019 concerning the Implementation of Anti-Fraud Strategies for Commercial Banks.
The Bank also has an internal policy related to the whistleblowing system as outlined in the Whistleblowing Policy.
Sustainability Report 2019
SuStainability Governance
Internal CIMB Niaga communication channels
Independent party communication channels (PT Deloitte Konsultan Indonesia)
https://ayolapor.tipoffs.info [email protected] 14031
+62 822 113563636 +62 21 2856 5231
Ayo Lapor PO BOX 3331 JKP 10033 0878 296 52767 (0878 AYO LAPOR) [email protected]
Violation reporting Mechanism
Internal and external parties can report any violations to CIMB Niaga through the following communication channels:
In optimizing the function of the whistleblowing system through PT. Deloitte Konsultan Indonesia, since 2018 all reports coming into internal media emails will be automatically forwarded to emails managed by PT. Deloitte Konsultan Indonesia.
Grievance Mechanism
The grievance mechanism is carried out through established procedures and regulations. During each reporting process, protection and confidentiality of the reporter is guaranteed.
Following up the received information, the whistleblowing officer will contact the reporter secretly to request additional information or will contact PT Deloitte Konsultan Indonesia, as an independent party to communicate with the reporter, if there is information that is not known by the Bank.
Whistleblowing officers are also required to report the results of violations complaints regularly to the Director in charge of the whistleblowing service, Director of Compliance, with a copy to the Director of Risk Management, Director of Human Resources, Chief Audit Executive and all Whistleblowing Committee members. Furthermore, in practicing supervisory function of the Board of Commissioners, whistleblowing reports will then be submitted in periodical (on a quarterly basis) manner to the Board of Commissioners’ committee, namely the Audit Committee.
The Compliance Director, as the Director in charge of the Bank’s whistleblowing service is responsible in the evaluation process of handling whistleblowing reports and ensuring all processes are conducted in accordance with procedures and regulations.
In 2019, the whistleblowing service received 131 complaint reports, this number decreases from 228 reports in 2018. In addition, during 2019, the Bank has investigated and completed 34% of the whistleblowing complaint reports received.
Number of Whistleblowing (WB) Reports and Settlements
2019 2018 2017
WB reports were not proceeded for investigation (pre-closed) 74 145 80
WB reports proceeded for investigation 55 83 18
• WB Reports proceeded for investigation and have been closed 45 62 10
• WB Reports proceeded for investigation and under investigation (open) 10 21 8
WB Reports that are still awaiting data completeness 2 - -
Number of reports received 131 228 98
WB Reports are proven based on the results of the investigation 21 32 2
WB Reports are proven based on the results of the fraud investigations 5 8 2
Percentage of WB report investigated from total reports received 34% 27% 10%
PT BANK CIMB Niaga TbkSustainability Report 2019