The case for CSR/ Sustainability Reporting Done Responsibly


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Home / case studies / Case study: How CIMB Niaga combats corruption

Case study: How CIMB Niaga combats corruption

CIMB Niaga is one of the largest financial institutions in Indonesia, with 451 branch offices consisting of conventional, sharia, and mobile cash and services covering consumer banking, micro, small and medium business (MSME), commercial banking, and corporate banking. CIMB Niaga is firmly committed to maintaining anti-fraud and anti-corruption principles in all its business activities.  Tweet This!

This case study is based on the 2019 Sustainability Report by CIMB Niaga published on the Global Reporting Initiative Sustainability Disclosure Database that can be found at this link. Through all case studies we aim to demonstrate what CSR/ ESG/ sustainability reporting done responsibly means. Essentially, it means: a) identifying a company’s most important impacts on the environment, economy and society, and b) measuring, managing and changing.

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In 2019, CIMB Niaga developed an Anti-Corruption Policy as the bank’s commitment in supporting anticorruption practice. This policy regulates CIMB Niaga’s principles in supporting anti-corruption practice, anti-corruption commitment, responsible parties, a corruption practice prevention programme, prohibition of gratification and political contributions, provision of sanctions for violations, and documentation and reporting. In order to combat corruption CIMB Niaga took action to:

  • implement an Anti-Money Laundering & Terrorism Financing Prevention Programme (APU and PPT)
  • apply an anti-fraud strategy
  • implement a whistleblowing system

What are the material issues the company has identified?

In its 2019 Sustainability Report CIMB Niaga identified a range of material issues, such as economic performance, product portfolio and loan quality, customer information protection, emissions, job diversity and opportunities. Among these, combating corruption stands out as a key material issue for CIMB Niaga.

Stakeholder engagement in accordance with the GRI Standards              

The Global Reporting Initiative (GRI) defines the Principle of Stakeholder Inclusiveness when identifying material issues (or a company’s most important impacts) as follows:

“The reporting organization shall identify its stakeholders, and explain how it has responded to their reasonable expectations and interests.”

Stakeholders must be consulted in the process of identifying a company’s most important impacts and their reasonable expectations and interests must be taken into account. This is an important cornerstone for CSR / sustainability reporting done responsibly.

Key stakeholder groups CIMB Niaga engages with:

To identify and prioritise material topics CIMB Niaga engaged with its stakeholders through the following channels:

Stakeholder Group                Method of engagement
Customers ·      Call Centre

·      Branch offices

·      Phone banking

·      Websites

·      Social media (Facebook, Instagram and Twitter)

·      Customer and internal satisfaction surveys

·      External assessments on customer satisfaction

·      Frontliner information



·      Performance reporting

·      Analyst Meetings

·      Public Expose

·      Reporting to the Indonesia Stock Exchange (IDX)

·      General Meeting of Shareholders



·      Submission of the Bank Business Plan (RBB) and RBB Realisation Report to Bank Indonesia and OJK

·      Submission of RAKB to OJK

·      Sharia compliance report to the National Sharia Board

·      Other reports in accordance with applicable regulations to the regulators

Suppliers ·      Policy socialisation (gatherings)


·      Public
Non-Governmental Groups ·      RSPO process meetings

·      Other NGO meetings e.g. IDH

·      Local multi-stakeholders initiatives

Employees ·      Internal Media (HR Info, Digital Magazine E-Potrait, E-Manual)

·      Town Hall

·      Employee Engagement Survey (EES)

·      Internal Customer Satisfaction (ICS)

Local Communities


·      Discussions with beneficiaries

·      Meetings and discussions with Foundations or Consultants acting as community development partners

Labour Union ·      Meetings and discussions

What actions were taken by CIMB Niaga to combat corruption?

In its 2019 Sustainability Report CIMB Niaga reports that it took the following actions for combating corruption:

  • Implementing an Anti-Money Laundering & Terrorism Financing Prevention Programme (APU and PPT)
  • CIMB Niaga implements an APU and PPT programme aimed to build an adequate risk culture at all organisational levels. The APU and PPT programme is undertaken by applying three lines of defence, as follows:
    • First Line of Defence, followed by the bank’s Business/ Control/Operations Units which conduct daily activities as the front line of the organisation.
    • Second Line of Defence, a monitoring function to ensure the first line of defence has carried out a proper function.
    • Third Line of Defence, a monitoring function of the APU and PPT Programmes 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 make sure 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 application 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. CIMB Niaga also applies Know Your Employee (KYE) as part of efforts to prevent APU, PPT and fraud.
  • Applying an anti-fraud strategy
  • Its anti-fraud strategy is CIMB Niaga’s commitment to 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. CIMB Niaga has also 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), a whistleblowing site, electronic mail to all vendors, as well as banners and posters in work areas. In order to support the developed anti-fraud value, CIMB Niaga carries out 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 carried out not only face-to-face but also through e-learning media and the Learning on the Go (LoG) application.
  • Implementing a whistleblowing system
  • CIMB Niaga has a whistleblowing system (WBS) and has appointed independent and professional third parties to manage complaints regarding fraud. The appointment of a third party aims to provide a comfortable and transparent process so that the reporter can submit a violation or fraud indication report. CIMB Niaga has gradually improved this reporting system, both the reporting mechanisms and the reporting media socialisation and also has an internal policy related to the whistleblowing system as outlined in the Whistleblowing Policy. In 2019, the whistleblowing service received 131 complaint reports and CIMB Niaga investigated and completed 34% of these.

Which GRI Standards and corresponding Sustainable Development Goals (SDGs) have been addressed?

The GRI Standard addressed in this case is: Disclosure 205-1 Operations assessed for risks related to corruption

Disclosure 205-1 Operations assessed for risks related to corruption corresponds to:


80% of the world’s 250 largest companies report in accordance with the GRI Standards

SustainCase was primarily created to demonstrate, through case studies, the importance of dealing with a company’s most important impacts in a structured way, with use of the GRI Standards. To show how today’s best-run companies are achieving economic, social and environmental success – and how you can too.

Research by well-recognised institutions is clearly proving that responsible companies can look to the future with optimism.

FBRH GRI Standards Certified, IEMA & CIM recognised Sustainability Course | Venue: London LSE

By registering for the next 2-day FBRH GRI Standards Certified, IEMA & CIM recognised course you will be taking the first step in gaining the many benefits of sustainability reporting.

Most importantly, you will gain the knowledge to use the GRI Standards, project manage your own first-class sustainability report and:

  • Identify your most important impacts on the Environment, Economy and Society
  • Begin taking solid, focused, all-round sustainability action ASAP



1) This case study is based on published information by CIMB Niaga, located at the link below. For the sake of readability, we did not use brackets or ellipses. However, we made sure that the extra or missing words did not change the report’s meaning. If you would like to quote these written sources from the original, please revert to the original on the Global Reporting Initiative’s Sustainability Disclosure Database at the link:


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