Bayarcash

Enterprise Risk Management (ERM) Policy

Version 1.0
Effective Date [Insert Date]
Approved By Compliance & Risk Committee
Next Review Date [Insert Date]

1. Purpose

Bayarcash recognizes that risk management is essential to achieving its strategic objectives, protecting stakeholders, and sustaining long-term growth. This policy provides a structured framework for identifying, assessing, managing, monitoring, and reporting risks across the organization.

The objectives of this policy are to:

  • Establish a consistent and integrated approach to risk management across Bayarcash.
  • Ensure compliance with applicable laws, Bank Negara Malaysia (BNM) regulations, and industry standards.
  • Promote a risk-aware culture at all levels of the company.
  • Safeguard the interests of customers, employees, shareholders, regulators, and stakeholders.

2. Scope

This policy applies to:

  • All Bayarcash employees, managements, and directors.
  • Contractors, agents, service providers, and third parties acting on behalf of Bayarcash.
  • All business units, subsidiaries, and affiliates of Bayarcash.

3. Risk Management Principles

Bayarcash’s ERM approach is guided by the following principles:

ERM PrincipleDescription
Alignment with StrategyRisk management supports Bayarcash’s strategic and operational objectives.
Integrated ApproachRisks are managed across the enterprise, not in silos.
ProportionalityControls are proportionate to the nature, scale, and complexity of risks.
AccountabilityRisk management is a shared responsibility across all levels.
TransparencyRisks are identified, reported, and communicated openly to management and the Board.
Continuous ImprovementRisk practices are reviewed regularly and enhanced in line with evolving threats and regulatory changes.

4. Risk Appetite & Tolerance

  • The Board of Directors defines Bayarcash’s risk appetite - the amount and type of risk the company is willing to accept in pursuit of business objectives.
  • Risk tolerances are established to ensure that risks remain within acceptable levels.
  • All business decisions must be made within the approved risk appetite framework.

5. Risk Categories

Bayarcash manages the following key risk areas:

Risk AreaDescription
Strategic RiskRisks affecting business strategy and market positioning.
Operational RiskRisks arising from inadequate processes, systems, or human errors.
Technology & Cybersecurity RiskRisks of system failures, cyberattacks, and data breaches (aligned with BNM’s RMiT guidelines).
Compliance & Regulatory RiskRisks of non-compliance with laws and regulations (BNM, AMLA, PDPA, MACC Act).
Financial RiskCredit, liquidity, interest rate, and investment risks.
Reputation RiskRisks impacting customer trust, brand integrity, or public confidence.
Fraud & Misconduct RiskRisks arising from fraud, bribery, corruption, or unethical behavior.
Business Continuity RiskRisks from natural disasters, pandemics, or critical service disruptions.

6. ERM Governance Structure

Bayarcash’s Enterprise Risk Management (ERM) governance involves clearly defined roles and responsibilities across all levels of the organisation, ensuring effective oversight, execution, and risk-aware culture.

RoleResponsibility
Board of DirectorsProvides oversight, approves risk appetite, and ensures effective ERM governance.
Audit & Risk CommitteeMonitors risk management practices, reviews reports, and advises the Board.
Senior ManagementImplements risk management processes, ensures compliance, and promotes risk culture.
Risk Management & Compliance DepartmentDevelops policies, monitors risks, conducts assessments, and reports to management and the Board.
All EmployeesResponsible for identifying, reporting, and managing risks within their roles.

7. Risk Management Process

Bayarcash follows a structured risk management process:

Risk Management StageDescription
Risk IdentificationDetect risks from internal and external sources.
Risk AssessmentEvaluate likelihood, impact, and inherent/existing controls.
Risk ResponseDecide on mitigation strategies: Avoid, Reduce, Transfer, or Accept risk.
Risk MonitoringTrack key risk indicators (KRIs) and control effectiveness.
Risk ReportingProvide timely risk reports to management, Audit & Risk Committee, and Board.

8. Reporting & Escalation

  • Regular risk reports shall be submitted to senior management and the Board Audit & Risk Committee.
  • Significant or high-impact risks must be escalated immediately.
  • External reporting to regulators (e.g., BNM) will be conducted as required.

9. Business Continuity & Disaster Recovery

10. Training & Awareness

  • Employees shall receive periodic training on risk awareness, cybersecurity, compliance, and ethical conduct.
  • Management shall foster a proactive risk culture across the company.

11. Review & Continuous Improvement

This policy shall be reviewed at least annually, or earlier if required by regulatory or business changes. Independent audits and assessments may be conducted to ensure effectiveness.