Number : 005/000-174/III/2021/SR-Asia/Indonesia Type/Level : 1 and 2/Moderate
Dear stakeholders,
PT Bank CIMB Niaga Tbk (“the Bank” or the “Reporting Organization”) has engaged Social Responsibility Asia (“SR Asia”) to assess its 2020 Sustainability Report (“the Report”) for the reporting period of January 1 to December 31, 2020. The Reporting Organization is a commercial bank listed on the Indonesia Stock Exchange and a subsidiary of CIMB Malaysia. This is the Independent Assurance Statement (“the Statement”) that presents SR Asia’s conclusions and recommendations resulted from the assessment.
Intended User and Purpose
The Statement is intended to communicate the results of the assessment including our opinion, findings, and recommendations on the Report content to the stakeholders of the Bank. The assessment or assurance work was conducted following particular mechanisms, procedures, and scope of work. Due to some limitations, the Statement shall NOT be used as the basis for interpreting the Bank’s overall performance or sustainability, except for the areas covered in the scope of assurance work.
Responsibilities
Responsibilities of both SR Asia and the Bank are defined in the Non-Disclosure Agreement and the Engagement Agreement documents. The Bank is exclusively responsible for the presentation of data, figures, and information in the Report content. SR Asia as agreed by the Management1 did NOT carry out an auditing job, but performed an assessment on the Report content and come up with conclusions and recommendations as well as the Statement.
The results of assurance would be disclosed to the Management only. SR Asia does NOT accept or assume to undertake any responsibility for any other purpose or to any other person or organization. Any dependence that a third party has placed on the Statement or the Report is entirely at its own risk.
Independence, Impartiality, and Competency
SR Asia implements the assurance protocol following a professional code of conduct to ensure objectivity and fairness in generating conclusions, recommendations, and the Statement. SR Asia ensures that NO members of the Assurance Team have any relationships with the Reporting Organization that can influence their ability to provide an independent and impartial statement. SR Asia has assigned an Assurance Team, whose members were experts in the ISO 26000, the principles and standards of AA1000 AccountAbility, the GRI Sustainability Reporting Guidelines, and the country reporting regulation. The experts also have experience in writing and reviewing sustainability reports and integrated reports of organizations from different industry sectors.
1Management of the Bank
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Description and Source of Disclosures
The Assurance Team carried out a preliminary assessment on the disclosures of data and information in the Report content. Based on that, SR Asia discussed with the Management to clarify the findings and traced back data to the evidence documents provided by the Bank. When applicable, the Assurance Team reviewed data and information online that was significantly related to the topics in the Report content. During the assurance work, SR Asia applied the methodology and approach of the analysis referring to the AA1000 Assurance Standard v3 and the SR Asia Protocol on Assurance Analysis, and also using the SR Asia Great Assurance Tool digital platform.
Type and Level of Assurance Service
1. Type 1 assurance on the Report content and specifically Type 2 assurance was applied on the governance topic with respect to the AA1000 Assurance Standard v3 and AA1000APS (2018) AccountAbility Principles.
2. A moderate level of assurance procedure on the Report content and evidence, where the risks of information and conclusions of the Report being error is reduced, but not reduced to very low, but not zero.
Scope and Limitation of Assurance Service
1. SR Asia EXCLUDES financial data, information, and figures in the Report content in the scope of assurance work. It is assumed that the Bank, or independent parties, or other parties associated with the Bank, have verified and/or audited any data and information related to financial statements.
2. Data and information for the reporting period of January 1 to December 31, 2020, as presented in the Report, especially related to the topics that have been identified as “material” by the Bank: technology; welfare, health, and safety; sustainable finance; customer experience; governance; financial inclusion and literacy, and empowerment.
3. Under Type 2 assurance mechanism and procedures, assessment of data and information including the mechanisms, processes, and control system was conducted on the corporate governance topic as disclosed in the Report content.
4. Analysis of publicly disclosed information, system, and process of the Bank has in place to ensure adherence to the principles.
5. Adherence to the following reporting principles, guidelines, and standards;
a) Consolidated set of GRI Sustainability Reporting Standards 2020 (“GRI Standard”) and GRI G4 Financial Services Sector Disclosure (“GRI-G4 FS”) issued by the Global Reporting Initiative;
b) Sustainability Accounting Standard for Commercial Bank (FN-CB) issued by the Sustainability Accounting Standard Board (SASB);
c) Sustainable Banking Assessment (SUSBA) issued by World Wildlife Funds (WWF);
d) Regulation of Indonesia Financial Service Authority No.51/POJK.03/2017 regarding the Implementation of Sustainable Finance for Financial Service Institution, Listed, and Public Company (“POJK 51”).
Exclusion
1. Engagement activities with stakeholders that were performed during the Report content development.
2. Data and information outside the reporting period, or in the public domain not covered in the reporting period.
3. Aspects of the Report other than those mentioned under the defining materiality section and discussion on defining Report content.
4. Statements and claims indicating the opinion, belief, expectation, advertisement, and future planning or strategy of the Bank.
5. Financial statements or financial data, information, and figures other than those presented in the Report content.
SR Asia Independent Assurance Statement, version 2021, page 3 of 4 000-174
Methodology
1. SR Asia appointed a number of experts in sustainability report development and assurance to form an Assurance Team, followed by the pre-engagement phase to ensure the independence and impartiality of the team.
2. Kick-off meeting and initial analysis on the Report draft.
3. Evaluate data and information against the standards, principles, and indicators of AA1000AS v3, AA1000APS (2018), GRI Standard, GRI-G4 FS, SUSBA, SASB, and POJK 51.
4. Assess indicators data, traceback data to the sources, and discuss online the results of the analysis with the Management.
5. Under Type 2 assurance, conduct in-depth analysis on the overall mechanism, procedures, and system control related to the corporate governance practices of the Company; and also review the results of the assessment conducted by an independent party on the corporate governance of the Reporting Organization.
6. Apply the SR Asia Protocol on Assurance Analysis and use SR Asia Great Assurance Tool digital platform to evaluate the Report content.
Adherence to AA1000AP (2018) and GRI Standards
Inclusivity – The Report content indicates an inclusive presentation on the key stakeholders and the stakeholder engagement practices. Different units or functions of the Bank have performed various stakeholder engagement approaches and communication. In the future, the Bank is recommended to conduct more strategic and integrated practices of stakeholder engagement, including the inclusion of engagement results in risk management and the measurement of engagement effectiveness, outcomes, and impacts.
Materiality – In general, the Bank has described adequately material topics related to its sustainability context as a commercial bank. The Bank has conducted an FGD and a survey covering both internal and stakeholders to identify material topics. Occupational health and safety is considered highly material due to pandemic COVID-19 that occurred during the reporting period. Nevertheless, the Bank is expected to apply certain criteria and thresholds that are clear, credible, understandable, and defensible against the external assessment.
Responsiveness – In the Report, the Bank has demonstrated its responsiveness to the impacts of its business activities and stakeholders’ concerns including climate change. The Bank has also indicated the integration of its responses in relevant organization processes, such as employee engagement, customer experience, and community empowerment. However, the Bank needs to consider the relationship between the maturity, impact, and prioritization of a topic and the appropriateness of the responses through strategic stakeholder engagement management.
Impact – In overall, especially regarding material topics, the Bank has recognized, managed, measured, and evaluated both actual and potential impacts of business activities and decisions on the stakeholders. In the Report content, both quantitative data and qualitative information are presented in the Report content. In the next reporting period, the Bank is advised to strengthen its measurement and evaluation by conducting an impact assessment on social aspects, i.e. human rights.
In “Accordance” with Comprehensive Option – the Report content indicates its adherence to the comprehensive option of GRI Standards. Material topics are sufficiently presented and discussed in the Report content and the disclosure of management approach (DMA) is disclosed adequately. When applicable, specific GRI indicators of the financial sector are disclosed in the Report content.
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GRI Standards Principles – As per our assurance work is taken, the Principles for Defining Report Content (stakeholder inclusiveness, sustainability context, materiality, and completeness) and the Principles for Defining Report Quality (balance, comparability, accuracy, timeliness, clarity, and reliability) are to some extent applied in the Report content. During the assurance process, the Management has submitted evidence documents in a softcopy format to the Assurance Team.
Type 2 Assurance – The results of Type 2 assurance indicate that the Bank has implemented an adequate mechanism, process, and control system related to its corporate governance practices. The Bank also has sufficient policies, procedures, resources, as well as monitoring and evaluation mechanisms to ensure its good corporate governance (GCG) principles are well in place. Moreover, an external validation by an independent party on the Bank’s corporate governance performance has been conducted referring to the internationally recognized standard, namely the ASEAN CG Scorecard 2020.
Recommendations
1. Stakeholder engagement management practices should be more strategic and well documented as well integrated with risk management, and equipped with materiality testing with specific criteria and thresholds as specified by the AA1000 Stakeholder Engagement Standard (AA1000SES 2015).
2. Alignment with the indicators of Sustainable Development Goals (SDGs), when applicable, should be made specifically with targets and metrics.
3. Impact assessment on the stakeholders should be conducted properly following globally recognized approaches and methodologies.
The assurance provider, Jakarta, 6th of March 2021
Birendra Raturi International Director Social Responsibility Asia
Dr.Semerdanta Pusaka Country Director for Indonesia
Social Responsibility Asia
Social Responsibility Asia (SR Asia) International
4F-CS-25, Ansal Plaza, Vaishali, Ghaziabad (NCR Region Delhi), Uttar Pradesh 201010, INDIA Landline / Mobile: +91-120-4103023; +91-120-6452020 / +91-9810059109
E-mail: [email protected], Website: www.sr-asia.org Indonesia
PT Sejahtera Rambah Asia, #1607 Splendor Tower, Soho Pancoran, Jl. MT Haryono Kav.2-3, Jakarta 12810, INDONESIA Landline: +62-21-5010 1504, E-mail: [email protected], Website: www.srasia-indo.com
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