IMS Policy

1. Introduction

GlobalWire Ng Limited, a Central Bank of Nigeria (CBN)-licensed International Money Transfer Operator (IMTO), is committed to implementing and maintaining an Integrated Management System (IMS) that ensures compliance with regulatory requirements, promotes operational excellence, and upholds the highest standards of quality, information security, risk management, and business continuity.

2. Purpose

The purpose of this IMS policy is to establish a structured framework that integrates quality management, information security, anti-money laundering (AML) compliance, risk management, and business continuity into a unified system. This policy ensures that GlobalWire Ng Limited:

Complies with all applicable CBN regulations, international financial regulations, and industry best practices.
Protects customers, stakeholders, and assets from financial crimes and cyber threats.
Enhances operational efficiency, customer satisfaction, and continuous improvement.
Fosters a culture of compliance, security, and risk awareness.

3. Scope

This policy applies to all employees, partners, and stakeholders of GlobalWire Ng Limited. It covers:

Quality Management: Ensuring service excellence, customer satisfaction, and continuous improvement.
Information Security: Safeguarding sensitive customer and business information against unauthorized access, breaches, and fraud.
Risk Management: Identifying, assessing, and mitigating financial, operational, regulatory, and reputational risks.
AML/CFT Compliance: Adhering to CBN guidelines, Financial Action Task Force (FATF) recommendations, and global AML/CFT regulations.
Business Continuity: Ensuring resilience and continuity of critical services in the event of disruptions.

4. Policy Statements

4.1 Quality Management

Ensure compliance with ISO 9001:2015 standards for quality management.
Continuously improve service delivery through customer feedback and performance monitoring.
Train and empower employees to uphold high service standards.

4.2 Information Security

Comply with ISO 27001:2013 standards to protect customer and company data.
Implement access controls, encryption, and secure transaction processing.
Conduct regular security assessments, audits, and awareness training.

4.3 Risk Management

Identify, assess, and mitigate risks using a structured risk management framework.
Establish risk tolerance thresholds in alignment with industry best practices.
Report risks and mitigation measures to the Board and regulatory authorities as required.

4.4 AML/CFT Compliance

Conduct Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) per CBN regulations.
Implement robust transaction monitoring and reporting mechanisms.
Ensure compliance with international AML/CFT frameworks, including FATF recommendations.
Provide regular AML training for employees and stakeholders.

4.5 Business Continuity

Maintain a Business Continuity Plan (BCP) to ensure minimal service disruption.
Conduct periodic testing and drills to assess business resilience.
Establish clear roles and responsibilities for crisis management and recovery.

5. Implementation and Monitoring

The Compliance and Risk Management teams will oversee IMS implementation and adherence.
Regular audits, reviews, and internal assessments will be conducted to ensure policy effectiveness.
Performance metrics will be established to track compliance, risk, and quality objectives.
Employees will undergo continuous training to stay updated on regulatory and security developments.

6. Responsibilities

Board of Directors: Provide oversight and strategic direction for IMS implementation.
Senior Management: Ensure the integration of IMS components into daily operations.
Compliance and Risk Teams: Monitor adherence to regulatory and IMS requirements.
All Employees: Adhere to the policy and contribute to its successful implementation.

7. Continuous Improvement

Regularly review policies and procedures in line with evolving regulatory and business needs.
Implement technological advancements to enhance security and efficiency.
Encourage a culture of innovation, compliance, and proactive risk management.

8. Conclusion

This IMS policy reflects GlobalWire Ng Limited’s dedication to excellence, compliance, and security. All employees and stakeholders must comply with this policy to ensure the company’s success and integrity in the international remittance sector.

Approved by: Head, Compliance, GlobalWire Ng Limited

Date: 01/03/2025