Governance and Internal Control Mechanism | Risk Management and Internal Controls | Compliance Policy and Procedures | Outsourced Functions and Internal Audit | | Authorised Payment Institution API | Electronic Money Institution E-money EMI | Small Payment Institution SPI

Risk Management

Hirett Ltd (Hirett) Board of Directors are aware that it is operating in a highly regulated environment. They are also aware that they have a duty of care to its e-wallet holders and other stakeholders. In response to these challenging realities, the company has developed robust risk assessment procedures and management systems classifying risks into categories.

Please refer to Hirett’s Risk Management Policy, which can be found under Appendix 8.1.2

1 Internal controls

2 Corporate and management structure

Hirett Ltd (“Hirett”) has put in place clear management structures and governance arrangements that incorporate reporting structures and roles and responsibilities. The organisational structure is supported by well-defined job specifications, which clearly outline the roles and responsibilities of the individuals and their reporting lines. Furthermore, Senior Management will continue to monitor the growth of the business to make sure that the staffing levels increase to reflect the growth in the number of transactions and the complexity of the business.

Please see below the management structure of Hirett.

Figure 1: Organisation Chart

Please also refer to Hirett’s Risk Management Policy, which can be found under Appendix 8.1.2, and Hirett’s AML Handbook, which can be found under Sections 14.2.

3 Compliance Policy and Procedures

Please refer to Hirett’s Anti-money laundering (AML) Handbook, which can be found under Section

14.2 of the application form.

Persons responsible for internal control functions and management body can be found under Section 5.1 of the application form. Please find enclosed EMD individual form(s) and up-to-date curriculum vitae (CV) for both: Shannan Adarna (CEO) and Nikki Castro (Compliance Manager).

4 Complaints Procedure

Hirett is developing a Complaints Manual (See Complaints Policy under Appendix 9.2) that outlines the complaints procedures for its e-wallet holders. The procedure includes service levels on response times and provides extensive details on the approach that needs to be taken in specific instances. There are detailed service levels on how a complaint will be addressed and the timelines that will be involved. There is an escalation procedure for any ultimately dissatisfied customer. The ultimate sanction, that we hope will not be required, is for the customer to take the matter to the Financial Ombudsman.

5 Outsourced functions

In the short-run a number of key responsibilities will be outsourced to Hirett OU, (See Sections 5.1 Appendix 5.2 for outsourcing agreement) and will utilise their well established structures, procedures, manuals and years of expertise.

All outsourced functions will be regularly monitored for efficacy and efficiency savings at the monthly meeting of senior management.

Initially Shannan Adarna, the Chief Executive Officer, will have complete control and oversight of all outsourced activities. However, as the business grows, oversight and management of the outsourced activities will either be brought in-house or will be made the responsibility of the relevant Managers that will report directly to the Chief Executive Officer, who in turn reports to the Board. For example, sales and marketing activities, initially outsourced, will be managed by the Sales and Marketing Manager. Similarly the initially outsourced accounting and auditing functions will be brought in-house and managed by the Financial Controller / Finance Director.

6 Internal Audit

Whilst Hirett Limited is still in its infancy, it will outsource the conducting of internal business auditing to Hirett OU (Estonia). It is to be emphasised that although the physical conducting of the audit will be undertaken by Hirett OU (Estonia) the responsibility for the control of the business will remain entirely with Hirett.

The business (external) auditors which are in the process of being appointed will carry out a systematic analysis and evaluation of the company’s accounting policies and procedures and make recommendations for which the Board assumes final responsibility.

The company will undertake formal and informal reviews of the performance and efficiency of its operations.

With regard to compliance with Anti-Money Laundering regulations, the external auditors will perform a thorough audit of the company at least once a year.

Hirett is committed to continuous risk based internal review of its business processes and procedures to achieve its security, financial and market goals.