TCHIKAMALOR Global Nig. Ltd.
Governance, Risk & Responsibility

Responsible institutional controls for economic participation infrastructure

TCHIKAMALOR Global's governance and responsibility framework provides the standards and controls that guide how the institution, its Economic Participation Infrastructure System, operating platforms and relevant business relationships are governed and operated. The framework covers governance and ethics, sustainability and responsibility, operational quality, information security, data protection, responsible supply chains and the continuing development of enterprise risk and compliance capabilities.

Governance, Risk & ResponsibilityInstitutional control layer
Governance & Ethics
Sustainability
Security & Quality
Risk & Compliance
Purpose of this Framework

A Clear Governance, Risk & Responsibility Architecture

This page establishes the governance, risk and responsibility architecture supporting TCHIKAMALOR Global and its Economic Participation Infrastructure System (EPIS). It separates institutional governance from infrastructure functions, operating platforms, markets and partnerships so that each layer has a clear purpose and no unnecessary policy overlap.

Core architectural principle: EPIS defines what TCHIKAMALOR Global builds and connects. Governance, Risk & Responsibility defines how the institution and those infrastructure capabilities are governed, controlled and operated responsibly.

Institutional Architecture

TCHIKAMALOR Global Architectural Hierarchy

01

TCHIKAMALOR Global — Economic Participation Infrastructure Platform

02

Governance, Risk & Responsibility Framework — cross-cutting institutional control layer

03

Economic Participation Infrastructure System (EPIS) — six infrastructure functions

04

Operating Platforms — Kamsiparts, Kambi3PL, KambiHome, Lornzi and MazesAI

05

Markets & Participants — consumers, businesses, enterprises, suppliers, institutions and other economic participants

06

Partnership & Integration Architecture — technology, regulated, commercial, infrastructure, institutional and capital partners

Governance, Risk & Responsibility Architecture

Four Areas of Institutional Control

Governance & Ethics

  • Corporate Governance Policy
  • Code of Business Conduct & Ethics
  • Anti-Bribery & Anti-Corruption Policy
  • Whistleblowing & Speak-Up Policy

Sustainability & Responsibility

  • Sustainability & Environmental, Social and Governance (ESG) Policy
  • Corporate Environmental Policy
  • Health, Safety & Environment (HSE) Policy
  • Human Rights & Labour Policy
  • Diversity, Equity & Inclusion (DEI) Policy

Operational Quality, Security & Supply Chain

  • Quality Policy
  • Information Security & Data Protection Policy
  • Supplier Code of Conduct

Enterprise Risk & Compliance — Developing

  • Enterprise Risk Management Framework
  • Compliance Management Framework
  • Business Continuity & Resilience Framework
  • Internal Controls Framework
  • Third-Party Risk Management Framework
  • Incident Management Framework
  • Responsible AI & AI Governance Framework
Relationship to EPIS

How the Framework Applies Across the Institution

The framework applies across TCHIKAMALOR Global, EPIS, all operating platforms, employees and representatives, suppliers, technology providers, partners and other relevant institutional relationships.

LayerPrimary role
InstitutionPurpose, strategy, stewardship and institutional direction.
Governance, Risk & ResponsibilityRules, standards, controls, ethical conduct, risk, responsibility and accountability.
EPIS FunctionsInfrastructure capabilities supporting economic participation.
Operating PlatformsMarket-facing systems and businesses applying those capabilities.
Markets & ParticipantsEconomic activity and users of the infrastructure.
PartnersSpecialised, regulated, technological, commercial and institutional capabilities.
Governance & Ethics

Governance & Ethics Policies

Corporate governance, ethical conduct, business integrity and appropriate channels for raising concerns.

Policy

Corporate Governance Policy

Our Commitment

TCHIKAMALOR Global Nig. Ltd. is committed to strong corporate governance as the foundation for building and stewarding an Economic Participation Infrastructure System. Our governance framework supports responsible leadership, accountability, transparency, sound decision-making, risk oversight and long-term institutional sustainability across the Company and its operating platforms.

Governance Principles

  • Act with integrity, accountability and professionalism.
  • Comply with applicable laws, regulations and corporate obligations.
  • Maintain effective Board oversight and clear management accountability.
  • Align major decisions with the Company's purpose, strategy and long-term objectives.
  • Maintain appropriate risk management and internal control systems.
  • Protect the legitimate interests of shareholders and stakeholders.
  • Promote responsible stewardship of infrastructure, information, capital and relationships.
  • Review governance arrangements as the Company's scale, activities and institutional requirements evolve.

Board Responsibilities

The Board provides oversight of corporate strategy, governance, enterprise risk, financial integrity, major policies, institutional stewardship and the long-term development of TCHIKAMALOR Global and its Economic Participation Infrastructure System.

Management Responsibilities

Management implements Board-approved strategy and policies and is responsible for disciplined, ethical, compliant and effective operation of the Company and its activities.

Employee and Representative Responsibilities

Every employee, contractor and representative is responsible for acting in accordance with applicable law, Company policies, delegated authority and the standards of conduct expected by TCHIKAMALOR Global.

Approval note: The statement 'Approved by the Board of Directors' should appear only after formal Board approval.

Policy

Code of Business Conduct & Ethics

Our Commitment

TCHIKAMALOR Global is committed to conducting its activities with integrity, fairness, accountability and professionalism. This Code establishes the standards of conduct expected of directors, employees, contractors, consultants and representatives acting on behalf of the Company and, where applicable, its infrastructure and operating activities.

Ethical Conduct

Act honestly, ethically and in good faith; comply with applicable law and Company policies; protect the Company's reputation, assets and information; maintain accurate records; and avoid conduct that could compromise trust in the institution.

Conflicts of Interest

Actual, potential or perceived conflicts must be disclosed promptly and managed through appropriate Company procedures.

Respectful Workplace

The Company does not tolerate discrimination, harassment, intimidation or retaliation and expects professional, respectful conduct.

Business Integrity

Bribery, corruption, fraud, theft, falsification of records, misuse of confidential information and other dishonest conduct are prohibited.

Speaking Up

Concerns about misconduct or policy violations should be reported through approved channels. Good-faith reporting should be treated fairly and without retaliation.

Policy

Anti-Bribery & Anti-Corruption Policy

Our Commitment

TCHIKAMALOR Global maintains a zero-tolerance approach to bribery, corruption, facilitation payments and improper inducements. The Company will manage corruption risks across its operations, procurement, partnerships, third-party relationships and institutional engagements.

  • Business decisions must be based on legitimate commercial, institutional and operational considerations.
  • Gifts, hospitality and business courtesies must be lawful, reasonable, transparent and incapable of improperly influencing a decision.
  • Actual, potential or perceived conflicts of interest must be disclosed and appropriately managed.
  • Relevant third parties may be subject to integrity screening and contractual requirements.
  • Accurate records and appropriate financial and operational controls must be maintained.
  • Suspected bribery, corruption or related misconduct must be reported through approved channels.
Policy

Whistleblowing & Speak-Up Policy

Our Commitment

TCHIKAMALOR Global encourages employees, contractors, consultants, suppliers, partners and other relevant stakeholders to raise genuine concerns about misconduct, unethical behaviour, legal or regulatory violations and breaches of Company policy.

  • Provide accessible and appropriate reporting channels.
  • Protect good-faith reporters from retaliation.
  • Handle concerns confidentially to the extent reasonably practicable.
  • Assess and investigate concerns objectively and fairly.
  • Take appropriate corrective action where misconduct is established.
  • Maintain records and periodically review the effectiveness of reporting arrangements.
Sustainability & Responsibility

Sustainability & Responsibility Policies

Environmental, social, workplace and human-rights responsibilities across the institution and relevant business relationships.

Policy

Sustainability & ESG Policy

Our Commitment

TCHIKAMALOR Global integrates environmental, social and governance considerations into the development, operation and stewardship of its Economic Participation Infrastructure System. The Company seeks to create long-term value while managing relevant environmental, social, governance and stakeholder impacts.

Environmental

  • Comply with applicable environmental requirements.
  • Manage energy, water, materials and waste responsibly.
  • Consider climate-related risks and opportunities where relevant.
  • Promote responsible procurement and environmental stewardship.

Social

  • Respect human rights and fair labour practices.
  • Maintain safe and respectful working environments.
  • Promote equal opportunity and responsible stakeholder relationships.
  • Consider social impacts associated with infrastructure and operations.

Governance

This policy is the overarching sustainability policy. Detailed environmental, HSE, human rights and DEI requirements should sit in their respective policies.

  • Maintain ethical leadership, accountability and risk oversight.
  • Protect information and stakeholder trust.
  • Apply responsible procurement and partner governance.
  • Monitor and improve sustainability performance.
Policy

Corporate Environmental Policy

TCHIKAMALOR Global is committed to responsible environmental management across its offices, technology activities, logistics and mobility activities, procurement, infrastructure development and other applicable operations.

  • Comply with applicable environmental requirements.
  • Prevent pollution and minimise environmental impacts.
  • Use energy, water and other resources responsibly.
  • Reduce, reuse and recycle waste where practicable.
  • Consider environmental and climate-related risks in relevant planning.
  • Encourage responsible environmental practices among suppliers and partners.
  • Continually improve environmental performance.
Policy

Health, Safety & Environment (HSE) Policy

TCHIKAMALOR Global is committed to protecting the health and safety of employees, contractors, customers, partners and visitors and to managing environmental risks associated with its activities. HSE requirements shall be applied proportionately to the nature and risk profile of each operation, platform, project and worksite.

  • Identify hazards and assess operational HSE risks.
  • Implement appropriate controls and safe working procedures.
  • Provide relevant training, information and protective measures.
  • Report, investigate and learn from incidents.
  • Manage environmental impacts responsibly.
  • Comply with applicable HSE requirements and continuously improve performance.
Policy

Human Rights & Labour Policy

TCHIKAMALOR Global respects internationally recognised human rights and is committed to fair, safe and responsible labour practices across its operations and relevant business relationships.

  • Prohibit forced, bonded and child labour.
  • Promote fair recruitment, employment and remuneration practices.
  • Provide safe and healthy working conditions.
  • Prohibit discrimination, harassment and intimidation.
  • Respect lawful freedom of association and employee representation.
  • Encourage suppliers and partners to uphold comparable standards.
Policy

Diversity, Equity & Inclusion Policy

TCHIKAMALOR Global is committed to equal opportunity, respectful treatment and an inclusive working environment. Employment decisions shall be based on competence, performance, qualifications, legitimate business requirements and applicable law.

  • Promote equal employment opportunity.
  • Prohibit unlawful discrimination, harassment and victimisation.
  • Support fair recruitment, development and advancement practices.
  • Respect different backgrounds, experiences and perspectives.
  • Promote inclusive leadership and professional conduct.
Operational Responsibility

Operational Quality, Security & Supply Chain

Quality, information security, data protection and responsible supplier expectations supporting infrastructure and operations.

Policy

Quality Policy

TCHIKAMALOR Global is committed to quality across the development, operation and delivery of its infrastructure capabilities, products and services. Quality shall be managed through clear requirements, disciplined processes, performance monitoring, risk management, customer feedback and continuous improvement.

  • Understand and meet agreed customer, participant and partner requirements.
  • Maintain reliable, consistent and fit-for-purpose processes and services.
  • Comply with applicable legal, regulatory and contractual requirements.
  • Monitor performance and address quality issues through corrective action.
  • Use feedback and operational learning to improve infrastructure and services.
  • Apply recognised quality frameworks where appropriate as the organisation develops.
Policy

Information Security & Data Protection Policy

TCHIKAMALOR Global recognises information as a critical institutional and infrastructure asset. The Company is committed to protecting the confidentiality, integrity and availability of information and to processing personal and business information responsibly and lawfully.

  • Protect information against unauthorised access, disclosure, alteration, loss and misuse.
  • Apply appropriate administrative, technical and operational safeguards.
  • Collect and process personal information for legitimate purposes and in accordance with applicable requirements.
  • Control access according to legitimate business and operational needs.
  • Manage cybersecurity, privacy and information risks.
  • Maintain incident response and recovery arrangements appropriate to the Company's activities.
  • Require appropriate confidentiality and security standards from relevant third parties.

Where TGN or an operating platform processes regulated or sensitive information, additional platform-specific controls may apply.

Policy

Supplier Code of Conduct

TCHIKAMALOR Global expects suppliers, contractors, consultants and service providers supporting its infrastructure and operations to conduct business ethically, responsibly and in compliance with applicable law.

Integrity

  • Prohibit bribery, corruption and fraud.
  • Maintain accurate records and disclose relevant conflicts.

People

  • Respect human rights and labour standards.
  • Prohibit forced and child labour.
  • Provide safe working conditions.

Environment & HSE

  • Comply with applicable environmental and HSE requirements.
  • Manage operational impacts responsibly.

Information

  • Protect confidential information and personal data.
  • Maintain appropriate security controls.

Responsible Supply

  • Support responsible procurement and continuous improvement.
  • Cooperate with reasonable due diligence and corrective-action requirements.
Developing
Enterprise Risk & Compliance

Enterprise Risk & Compliance — Developing

The following frameworks are under development to support the governance, risk and responsibility architecture of TCHIKAMALOR Global and its Economic Participation Infrastructure System. They will be published as policies once they are finalised and approved.

Enterprise Risk Management Framework

Enterprise Risk Management Frameworkidentifies, assesses, treats, monitors and reports strategic, financial, operational, technology, regulatory, reputational and other material risks.

Compliance Management Framework

Compliance Management Frameworkestablishes responsibility for legal and regulatory obligations and evidence of compliance.

Business Continuity & Resilience Framework

Business Continuity & Resilience Frameworkprotects critical operations and infrastructure against disruption.

Internal Controls Framework

Internal Controls Frameworkestablishes control ownership, segregation of duties, approvals, monitoring and assurance.

Third-Party Risk Management Framework

Third-Party Risk Management Frameworkapplies proportionate due diligence and monitoring to suppliers, technology providers, partners and other third parties.

Incident Management Framework

Incident Management Frameworkestablishes reporting, escalation, response, investigation, corrective action and learning.

Responsible AI & AI Governance Framework

Responsible AI & AI Governance Frameworkgoverns AI development and use, including accountability, data, security, transparency, human oversight, risk management and responsible deployment.

Policy Governance Rules

How Policies Are Controlled and Maintained

01

Every policy should have an owner, approval authority, effective date, review date and version number.

02

Policies should establish principles and responsibilities; procedures and work instructions should contain detailed operational steps.

03

Policies should cross-reference other policies rather than duplicate their requirements.

04

Platform-specific requirements should be maintained as procedures, standards or platform policies where appropriate, rather than rewriting the Group policy.

05

Board approval should only be stated after formal approval has occurred.

06

The framework should be reviewed periodically and updated as TGN's activities, platforms, jurisdictions and risk profile evolve.

Institutional Governance Supports Responsible Infrastructure Development

For governance, institutional, enterprise or strategic enquiries, contact TCHIKAMALOR Global.