1

TATA KELOLA PERUSAHAAN

YANG BAIK
Good Corporate Governance (CGG)

Daftar Isi
2

Latar Belakang GCG

Prinsip GCG
Pengertian, Definisi GCG
Tujuan, Purpose GCG
Model GCG
Komite Audit
Internal Audit
What to expect from Internal Audit Dept.
The Agency Concept of GCG

Latar Belakang GCG

Todays Top 10 Issues for Internal Auditing

1.
2.
3.
4.
5.
6.
7.
8.
9.
10.

Risk
Ethics
Governance
Fraud
Control Assessment
Quality
Management Discussion & Analysis
Reporting Relationships
Access to Information
Incentive Compensation

Mengapa GCG
5

Latar belakang kebutuhan atas good corporate governance

(GCG) dapat dilihat dari latar belakang praktis dan latar
belakang akademis.
Dari latar belakang praktis. GCG yang buruk disinyalir sebagai
salah satu sebab terjadinya krisis ekonomi politik Indonesia yang
dimulai tahun 1997 yang efeknya masih terasa hingga saat ini.
Krisis keuangan global juga ditengarai karena tidak
diterapkannya prinsip-prinsip GCG, beberapa kasus skandal
keuangan seperti Enron Corp., Worldcom, Xerox dan lainnya
melibatkan top eksekutif perusahaan tersebut menggambarkan
tidak diterapkannya pronsip-prinsip GCG.
Dari latar belakang akademis. kebutuhan GCG timbul berkaitan
dengan principal-agency theory, yaitu untuk menghindari konflik
antara principal dan agentnya. Konflik muncul karena perbedaan
kepentingan tersebut haruslah dikelola sehingga tidak
menimbulkan kerugian pada para pihak. Teori lain yang juga
kerap dikaitkan dengan GCG a.l. Stewardship Theory, dan
Management Theory

Mengapa GCG Dibutuhkan?

6

Korporasi yang dibentuk dan merupakan suatu

Entitas tersendiri yang terpisah merupakan Subyek
Hukum, sehingga keberadaan korporasi dan para
pihak yang berkepentingan (stakeholders) tersebut
haruslah dilindungi melalui penerapan GCG.

Concerns.
7

Everywhere shareholders are re-examining their

relationships with company bosses what is known
as their system of corporate governance. Every
country has its own, distinct brand of corporate
governance, reflecting its legal, regulatory and tax
regimes The problem of how to make bosses
accountable has been around ever since the public
limited company was invented in the 19th century,
for the first time separating the owners of firms
from the managers who run them. Corporate Governance:
Watching the Boss, THE ECONOMIST (Jan. 29, 1994).

The need for Corporate Governance

The degree to which corporations observe basic principles
of corporate governance is an increasingly important
factor for investment decisions
Integrity of accounting statements, and stress on ethical
behaviour are the key objectives of good Corporate
Governance from the investors viewpoint.
Insider trading, selective leak of price sensitive
information, & dubious accounting practices are the
biggest concerns from Corporate Governance perspective
Resultant critical issues are disproportionate returns to
insiders, extensive expansion into unrelated business, high
leverage & risky financial structure

The need for Corporate Governance Cont.

Hence the issue is the protection of minority
shareholders and other stakeholders from the
opportunism of the controlling shareholders
Investor opinion surveys indicate that Corporate
Governance remains a great concern for institutional
investors, with an overwhelming majority of them
willing to pay a premium for companies demonstrating
consistent adherence to high governance standards
Many investors believe that there is a linkage between
good Corporate Governance and good long-run
corporate performance

10

PRINSIP GCG

Prinsip GCG (TARIF)

11

1.

Transparansi (Transparency), yaitu keterbukaan dalam melaksanakan

proses pengambilan keputusan dan keterbukaan dalam mengungkapkan
informasi material dan relevan mengenai perusahaan;

2.

Akuntabilitas (Accountability), yaitu kejelasan fungsi, pelaksanaan dan

pertanggungjawaban Organ sehingga pengelolaan perusahaan
terlaksana secara efektif;

3.

Pertanggungjawaban (Responsibility), yaitu kesesuaian di dalam

pengelolaan perusahaan terhadap peraturan perundang-undangan dan
prinsip-prinsip korporasi yang sehat;

4.

Kemandirian (Independency), yaitu keadaan di mana perusahaan dikelola

secara profesional tanpa benturan kepentingan dan pengaruh/tekanan
dari pihak manapun yang tidak sesuai dengan peraturan perundangundangan dan prinsip-prinsip korporasi yang sehat;

5.

Kewajaran (Fairness), yaitu keadilan dan kesetaraan di dalam memenuhi

hak-hak Pemangku Kepentingan (stakeholders) yang timbul berdasarkan
perjanjian dan peraturan perundangundangan.

OECD Principles
12

The Principles are divided into five (5) themes:

1.
2.

3.

The corporate governance framework should protect

shareholders rights.
The corporate governance framework should ensure the
equitable treatment of all shareholders, including minority
and foreign shareholders. All shareholders should have the
opportunity to obtain effective redress for violation of
their rights.
The corporate governance framework should recognize
the rights of stakeholders as established by law and
encourage active co-operation between corporations and
stakeholders in creating wealth, jobs, and the
sustainability of financially sound enterprises. (The role of
stakeholders in corporate governance)

OECD Principles, Contd

13

4.

5.

The corporate governance framework should ensure

that timely and accurate disclosure is made on all
material matters regarding the corporation, including
the financial situation, performance, ownership, and
governance of the company (Disclosure and
Transparency)
The corporate governance framework should ensure
the strategic guidance of the company, the effective
monitoring of management by the board, and the
boards accountability to the company and the
shareholders (Responsibility of the Board)

14

PENGERTIAN & DEFINISI GCG

What is Organizational Governance?

15

Policies, processes, and structures used by an

organization to direct and control its activities, to
achieve its objectives, and to protect the interests of
its diverse stakeholder groups in a manner consistent
with appropriate ethical standards.
Governance is essentially a function of leadership
and direction within an organisation; appropriate
risk management and control over its activities; and
the manner in which meaningful disclosure relating
to its activities is made to shareholders and other
stakeholders.

Pengertian GCG
16

Hard Definition
GCG merupakan sistem pengendalian dan pengaturan
perusahaan yang dapat dilihat dari mekanisme
hubungan antara berbagai pihak yang mengurus
perusahaan

Soft Definition
"nilai-nilai" yang terkandung
pengelolaan (governance)

dari

mekanisme

Pengertian GCG
17

GCG adalah prinsip-prinsip yang mendasari suatu

proses dan mekanisme pengelolaan perusahaan
berlandaskan peraturan perundang-undangan dan
etika berusaha (Kepmen BUMN 01 /MBU/2011)
"KOMITMEN,
ATURAN
MAIN,
SERTA
PRAKTIK
PENYELENGGARAAN BISNIS SECARA SEHAT DAN
BERETIKA (BPKP)

Governance Defined
18

The whole set of legal, cultural, and institutional

arrangements that determine what organizations can
do, who controls them, how that control is exercised, and
how the risks and returns from the activities they
undertake are allocated. (Margaret Blair, 1995)
Governance involves a set of relationships between an
organisations management, its board, its stakeholders
and other stakeholders. Governance also provides the
structure through which the objectives of the company
are set, and the means of attaining those objectives
and monitoring performance are determined. (OECD)

Governance Defined
19

A set of processes, controls, and structures generally

performed within the organization by, or on behalf
of, stakeholders (including the board or other body
directly appointed by stakeholders for example,
a community oversight board) to ensure that that
their interest are protected and their goals are
achieved.
The objective of organizational
governance is to ensure that management is acting
appropriately and consistently within the interest of
stakeholders. (Norman Marks, IA Professional,
Author, Blogger)

Corporate Governance
20

Corporate governance is the system by which companies are

directed and controlled, in the interest of shareholders and other
stakeholders, to sustain and enhance value (OECD)
At CalPERS CG means relationship among various participants in
determining the direction & performance of corporations. Primary
participants are (1) shareowners, (2) management, & (3) the board
of directors.
Distribution of rights and responsibilities among different participants
in the organisation including other financial stakeholders, and the
rules and procedures laid down and followed for making decisions
on corporate affairs
CG has evolved based on dispersion of equity, the changes between
ownership &control of modern corporations, economic crisis and
corporate failures, pension reforms and growth of private savings, &
deregulation & integration of capital markets

21

TUJUAN GCG

OECDs Stands about GCG

22

Defining corporate governance:

Corporate governance relates to the internal means by which
corporations are operated (directed) and controlled - Sir Adrian
Cadbury
Objective standards:
The corporate governance principles promulgated by the
Organization for Economic Cooperation and Development
(OECD), available at the OECDs website (www.oecd.org) are
recognized as an influential, objective set of corporate
governance principles and represent the first initiative by an
inter-governmental organization to develop the core elements of
a good corporate governance regime.
The Principles can be used as a benchmark by governments as
they evaluate and improve their laws and regulations. They also
can be used by private sector parties that have a role in
developing corporate governance systems and best practices.

Tujuan GCG
23

1.

2.

3.

Mengoptimalkan nilai perusahaan agar memiliki daya

saing yang kuat, sehingga mampu mempertahankan
keberadaannya dan hidup berkelanjutan untuk mencapai
maksud dan tujuan;
Mendorong pengelolaan perusahaan secara profesional,
efisien, dan efektif, serta memberdayakan fungsi dan
meningkatkan kemandirian Organ Perusahaan.
Agar dalam membuat keputusan dan menjalankan
tindakan dilandasi nilai moral yang tinggi dan kepatuhan
terhadap
peraturan
perundangundangan,
serta
kesadaran akan adanya tanggung jawab sosial terhadap
Pemangku Kepentingan maupun kelestarian lingkungan di
sekitar perusahaan

Governance Ensures The Organization:

24

Complies with societys legal & regulatory rules

Satisfies the generally accepted business norms,
ethical precepts, and social expectations of society
Provides overall benefit to society and enhances
interests of stakeholders
Reports fully and truthfully to its owners, regulators,
other stakeholders, and general public to ensure
accountability for its decisions, actions, conduct , and
performance

Governance Purpose
25

The purpose of organizational governance is to

facilitate effective and prudent management that
can deliver long-term success to the organization.

26

MODEL GCG

The IIA Corporate Governance Model

27

Effective
Governance

Sound Governance Requires Synergy !!

Governance can be defined as the mixture of
processes, procedures and structures implemented by
management and the board to inform, direct, manage,
and monitor organizational activities

Corporate Governance
28

The Four Cornerstones

Audit Committee of the Board
Executive Management
Internal Auditors
External Auditors

Corporate Governance Framework

29

Other
30

Control Model GCG Untuk Bank

31

QUASI - SINGLE BOARD STRUCTURE

Common Governance Components

32

1.
2.
3.
4.
5.
6.
7.

Board of Directors and Committees

Laws and Regulations
Business Practices and Ethics
Disclosure & Transparency
Enterprise Risk Management
Monitoring
Communication

Board Responsibilities
33

Establishes the tone at the top

Focal point for all governance activities
Ultimate accountability
Oversees all organizational activities, but does not
directly manage any of them

Board Responsibilities
34

Establishes the tone at the top

Focal point for all governance activities
Ultimate accountability
Oversees all organizational activities, but does not
directly manage any of them
Dewan Komisaris/Dewan Pengawas bertanggung
jawab dan berwenang melakukan pengawasan atas
kebijakan pengurusan, jalannya pengurusan pada
umumnya, baik mengenai BUMN maupun usaha BUMN
dan memberikan nasihat kepada Direksi

Senior Management
35

Establishes strategic direction and an entitys value

system (with board oversight)
Provides assurance of risk management process,
operations monitoring, measurement of results, and
implementation of timely corrective actions
Direksi BUMN menyusun GCG manual yang
diantaranya memuat :
board manual, manajemen risiko manual, sistem
pengendalian intern, sistem pengawasan intern, mekanisme
pelaporan atas dugaan penyimpangan pada BUMN yang
bersangkutan, tata kelola teknologi informasi, dan
pedoman perilaku etika (code of conduct).

Operating Management
36

Deploys strategy, enforces internal control, and

provides direct supervision for areas under its
control
Accountable to executive management and
ultimately the board for implementing and
monitoring the risk management process and
establishing effective and appropriate internal
control systems

External Auditing
37

Provides independent assurance on the financial

statement preparation and reporting activities in
accordance with applicable regulations and
accounting principles

Internal Auditing
38

Performs assessments to provide assurance the

governance structures and processes are properly
designed and operating effectively
Provides advice on potential improvements to
governance structures and processes
What is Internal Auditings Role?
Assessor
Advisor
Advocate
Catalyst

Governance Challenges
39

Diversity of audience.
Remaining independent and objective, yet being part
of the organization.
Constant development of business knowledge, insight,
good judgment, and communications.
No one-size-fits-all method to improve organizational
governance
No governance system, no matter how well designed,
will fully prevent greedy, dishonest people from putting
their personal interest ahead of the interests ahead of
others or the interest of their organization.

Addressing Governance Challenges &

Navigating Politics
40

Ramp up communications.
Place renewed focus on risk management and governance process.
Strengthen the risk assesment process.
Operate with a more flexible and adaptable plan
Strengthen business knowledge.
Strengthen your relationshsips and communications
organizations other governance, risk, and control functions.
Enhance the efficiency of audit process
Be open and honest.

with

the

Dont discriminate when sharing information with the oversight body.

Be aware of political firestorms.
Pick you battles.
Walk the talk

41

The Audit Committee

Purpose, Process, Professionalism

A New World of Corporate Governance

42

Boards of directors and committees must be:

Proactive
Informed
Investigative
Accountable

The Bad News

43

Stakes are greater

No figure head board members allowed
Public trust has diminished
Greater challenges
More director liability

Fiduciary Duties
44

The duties of care and loyalty, and the expectation

that directors will act in good faith.
Board members who wish to become empowered
guardians and builders of corporate value must
Learn and follow best practices,
avoid conflicts of interest,
pay strict attention to board matters,
drawing on appropriate expertise, including their own.

What is the ACs Role in Governance?

45

Oversight of financial reporting

Risk management
Internal control
Compliance
Ethics
Management
Internal auditors
External auditors

Best Practices in Code-of-Conduct Oversight:

46

Ensure:
A code of conduct has been developed, reviewed and
updated as needed.
All employees receive the code of conduct, understand
it, and receive training.
Management exhibits ethical behavior and reported
violations receive action.

Best Practices in Compliance and Ethics

Oversight:
47

Ensure:
Compliance with laws and regulations
Financial reporting of significant issues
Management monitoring of program effectiveness
Staying informed and recognizing trends to ensure
appropriate action
Internal audit includes assessment of compliance and
ethics risks in their audit plan
AC meetings with program manager to discuss key risks,
status, issues, investigations, disciplinary action and
effectiveness.

Noses In. Fingers Out

48

The lines of authority for audit committees and

management should be clear and understood.
AC members must communicate openly with
management.
They
must
also
challenge
management as appropriate.

Communications Checklist
49

Management is easily accessible.

Management reaches out to the audit committee
regularly.
Management answers audit committee questions fully
and completely.
Management provides factual information to support
responses.
Management admits not knowing an answer.
Management supports the audit committee by contacting
additional resources and specialists
Management advises the audit committee of significant
issues in a timely manner.
Management seeks audit committee input in advance of
key decisions.

Key Issues of Concern

50

Financial Accuracy
Risk Management
Control Assessment
External Auditor Oversight
Effective Use of Internal Auditing

Clarifying the Value of Internal Auditing

51

Audit committees must understand internal auditings

role if they are to work effectively and share a
healthy interdependence.

Charting the Course

52

An audit committee charter is a blueprint for its

operation and should address
Processes
Procedures
Responsibilities

53

INTERNAL AUDIT

Understanding Internal Audit

54

Objectivity
Reporting structure
Risk management
Staffing
Prioritization
Adding Value

Understanding Internal Audit

55

Objectivity IA should have no personal or professional

involvement with or allegiance to the area being
audited; and should maintain an un-biased and
impartial mindset in regard to all engagements.
Reporting Structure IA should report to a level within
the organization that allows the internal audit activity to
fulfill its responsibilities and remain independent. This
often results in a dual reporting relationship between
executive management and the audit committee.
Whatever, the reporting relationship there must be
organizational independence.

Understanding Internal Audit

56

Risk Management Implemented by management, ERM

is evaluated by the internal auditors for effectiveness
and efficiency.
Staffing A broad range of skills and expertise, and
ongoing professional development are critical to the
formation and maintenance of an effective internal
audit activity.
Prioritization The CAE independence should provide
the necessary organizational knowledge for staying in
sync with risks and the organizations overall priorities
that allow for effective management of internal audit
resources

Understanding Internal Audit

57

Adding Value IA serves management and the

board, assesses the ethical climate and the
effectiveness and efficiency of operations, and
provides a safety net for organizational compliance
with rules, regulations, and overall business
practices.

Internal Auditing Best Practise

58

IA should assess and make recommendations for

improving the governance process
Promoting appropriate ethics & values
Ensuring effective performance management
Effective communication of risk & control information
Effective coordinating of activities & communication
between Board, External Auditors, Internal Auditors &
Management

Internal Auditing Governance Maturity Model

59

Allocation of Audit

Consideration of best practices and adaptation to the specific organization

focus on optimization of governance practices and structure

Perform audits of design and effectiveness of

specific governance related processes

Provide advice with focus on governance

structure to meet compliance requirements and
basic risks of organization

Less Structured

More Structured

Specific Internal Auditing Activities

60

Consider assessing the following

Board Structure, Objectives, and Dynamics
Board Committee Functions
The Board Policy Manual
Processes for Maintaining Awareness of Governance Requirements
Education of the Board
Proper Assignment of Accountabilities and Performance Management
Communication and Acceptance of Ethics Policies and Codes of Conduct
Ethics Investigations and Related Employee Discipline
Management Evaluation and Compensation
Recruitment Processes for Senior Management and Board Members
Employee Training
Governance Self-assessments
Comparison with Governance Codes or Best Practices
External Communications
Oversight of External Audit

What Are The Risks of Internal Auditor as

Consultant
61

Risk of Political Exposure

Project Failure
Management Expectations
Conflict of Interest
Maintaining Independence and Objectivity
Consulting Assignment

Consulting Skills for Auditors

62

Include consulting services in annual audit

plan/budget
Define and communicate scope early and often
Gain client buy-in
Dont be afraid to say no
Identify process improvement areas
RVA Real Value Added
BVA Business Value Added
NVA Non-Value Added

Tips for a Consultative Approach to Audit

63

Strive to understand the business on a deeper level

Align resources to critical areas of risk
Develop in-house expertise
Build trust through relationships
Offer something extra
Speak business, not audit

Other Considerations
64

Internal Audits role in governance may impair its independence

and should be evaluated and if necessary communicated to
management and the board.
If impaired internal audit should not perform audits or
assessments related to this role.
Organizational strategies usually not questioned by the internal
auditor may need to be if observed to be inadequate, conflicting
or negatively impacting the organization or its stakeholders.
Internal auditing must assess the big picture of governance.
Governance is changing rapidly and requires the internal auditor
to monitor these changes and evaluate how they impact the role
of internal auditing in the future.
Internal auditor skills and competencies should be evaluated
before undertaking audits in the governance area

65

What should you expect from your Internal

Audit Department?

VALUE PROPOSITION OF INTERNAL AUDITING FOR

KEY STAKEHOLDERS
Internal Auditing: Assurance Insight Objectivity
Governing bodies and senior management rely on Internal Auditing for objective
assurance and insight on the effectiveness and efficiency of governance, risk
management and internal control processes.

Internal Auditing Provides:

Assurance that the organization is operating as
management intends.
Insight for improving controls, processes,
procedures, performance, and risk management;
and for reducing expenses, enhancing revenues,
and improving profits.
Objective assessments of operations.

Internal Auditors:
Have variety of skills, educational backgrounds,
and expertise.
Use their broad knowledge of the business to help
management achieve its business objectives and
assist the governing body in fulfilling its oversight
responsibility.
Are catalysts, risk and control experts, efficiency
specialists, and problem-solvers.

VALUE PROPOSITION OF INTERNAL AUDITING FOR

KEY STAKEHOLDERS
What else should you expect from your IA Department?

Assurance: Governance, Risk, Control

Internal Auditing provides assurance on the
organizations governance, risk management
and control processes to help the organization
achieve its strategic, operational, financial,
and compliance objectives.

Governance, Risk, Control

Internal Auditing, as one of the four cornerstones of
corporate governance (along with the governing body,
executive management, and external auditing) helps
organization focus on strong controls, accurate reporting,
effective oversight, mitigation of risks, and protection of
investments.
Assists management and governing bodies in identifying
risks.
Provides insight on effectiveness of controls and
compliance with procedures and regulations, and
recommends improvements.

Insight : Catalyst, Analyses, Assessments

Internal Auditing is a catalyst for improving an
organizations effectiveness and efficiency by
providing insight and recommendations based
on analyses and assessments of data and
business processes.

Catalyst, Analyses, Assessments

As catalyst for improvement, evaluates processes,
reports findings and recommends appropriate
courses of action; and advises on key
projects/initiatives.
Through analyses of data and information, provides
insight into process improvements.
Through understanding of the business and its
objectives, assesses the efficiency and effectiveness
of operations and protection of assets.

Objectivity :
Integrity, Accountability, Independence
With commitment to integrity and accountability,
Internal Auditing provides value to governing
bodies and senior management as an
independent source of objective advice.

Integrity, Accountability, Independence

Grounded in professionalism and integrity

through professional Standards and Code of
Ethics.
Accountable in helping management and
governing bodies achieve their objectives.
To ensure independence, CAE should report to
independent governing body for functional
direction;
and
to
management
for
administrative oversight. Maintains objectivity
by
not
assuming
any
operational
responsibilities.

VALUE PROPOSITION OF INTERNAL AUDITING FOR KEY

STAKEHOLDERS

The Agency Concept

The Main Driver for Corporate Governance is Based on

the Agency Concept.

External audit fits into the corporate governance jigsaw by

providing a report on the final accounts prepared by the board.

Internal Audit vs External Audit

Audit Committee

Internal Audit

Linking Risk Management to internal control.

The fully built model of corporate governance

A Possible Framework for Banks

85

86

CONCLUSION

Back to Basics: Risk, Controls, Governance

Internal auditing is an
independent, objective
assurance and consulting
activity designed to add value
and improve an organization's
operations. It helps an
organization accomplish its
objectives by bringing a
systematic, disciplined
approach to evaluate and
improve the effectiveness of
risk management, control,
and governance processes.

Fostering Enterprise Risk

Management

Re-engaging Internal
Controls

Facilitating
more effective
corporate governance

Key To Effective Corporate Governance

An effective, independent board
A proactive audit committee
A compensation committee aligning executive compensation to
shareholder value
Nominating committee ensuring effective governance of board
A sound internal control framework
A relevant code of ethical behavior
Clear, enforced policies and procedures
Effective management of risk
An objective, well-resourced internal audit function
Independent, effective external audit
Transparent disclosure, effective communication, and systems that
ensure effective measurement and accountability

Ten Aspects to be Assured

Board Governance:
Roles & authorities of Boards and their members
Board nomination and appointments
Board Independence
Board-members expertise and experience
Board-members performance monitoring & evaluation

Business Governance
Business-strategy planning & implementation
Risk management
Information and reporting
Business & community consultations

Employee Governance
Employee guidelines and Code of Conduct

Board Governance
Board charters must be complete & updated:
Roles & responsibilities of each board-committee and
board-member must be clearly stated
Minutes of meetings should note dissenting opinions and how
they are resolved

Appointments & performance monitoring:

Clear processes and minutes of board nomination and
appointments
Board-members expertise and experience
Board-members performance monitoring & evaluation

Board independence should be maintained:

Undue influences and treatment of controlling shareholder
must be avoided

Business Governance
Business-strategy properly planned & implemented:
Planning process should take into account external conditions as
well as internal capabilities
Strategic objective must be to develop business

Management of business-risk:
Business is all about translating risk into profits.
Hence, risk-management is a core of governance

Information and reporting

Management needs sufficient information
Transparency has no meaning without proper info

Business & community consultations

Stakeholder communications must be sufficient
Corporate social responsibility

Employee Governance
Employees as key corporate asset:
Placement & promotion opportunities open to all employees
Fair goal setting and performance evaluation

Competence & performance-based HR management:

Clear description of jobs & required competencies
Employees allowed to advance themselves

Right to organize:
Unions common, but not the only form of employee
organization

Employee guidelines and Code of Conduct

Understood & implemented by everybody in the company

Final Conclusion
Improvement of corporate governance will be increasingly
important, both within a company, and on a macro level
affecting the companies market values
With an increasingly global economy, good governance will
help support a companys business role and importance
The main motivating factors behind good governance are
investors & creditors, society at large, government &
regulators and the company itself (including its stakeholders)
Companies should formalize its corporate governance
platform. This can be done by codifying a Corporate Policy
Manual, to serve as the main reference in the banks
structure, systems & procedures.

94

END OF PRESENTATION
Thank You