Compliance

At Transaction Capital Recoveries, we deem the application of proper corporate governance principles as a key imperative in ensuring a sustainable and reputable business. We do so in line with strategic and governance objectives set by Transaction Capital Limited, and endeavour to apply the same level of standards as required by listed companies.

Corporate Governance within Transaction Capital Recoveries is underpinned by the following functions:

• Internal Audit, consolidated under Transaction Capital group Internal Audit Services;
• Enterprise-wide Risk Management, facilitated by Internal Audit;
• Compliance Officer;
• Legal and Company Secretariat;
• a governance section is included in each quarterly Board agenda; and
• the Transaction Capital Audit, Risk and Compliance Committee.

This control matrix is further supported by controls and processes in the finance department including as it pertains to the revenue cycle and how collections are received on behalf of clients, are paid over and the issuing of invoices for commission and fees.

Internal Audit

The Transaction Capital Risk Services internal audit team comprises two managers and three auditors reporting to the Internal Audit executive. The team is suitably qualified and experienced and comprises one CA(SA), three CIAs and five Honours degrees.

The internal audit plan covers the Transaction Capital Risk Services group, linked to our risk register and is accordingly prioritised. Internal Audit works closely with the Compliance Officer and Legal Officer and includes monitoring of compliance with relevant legislation and regulations in the annual plan. An additional 20% time allowance for ad hoc internal audit reviews is included in the plan for management requests or forensic work that may be required.

The Transaction Capital group has an anonymous reporting line with Whistle Blowers for reporting of all unethical or fraudulent behaviour. Reports from this line are reported to the Internal Audit Executive who directs the reports to the appropriate person in the Governance structure in the group. Reports on all unethical and fraudulent behaviour, as well as the outcomes of the investigations, are included in the documentation for the Transaction Capital Social and Ethics Committee which reports to the Transaction Capital Board.

The Transaction Capital Group Ethics Charter requires all divisions to conduct their business with honesty, integrity and in accordance with the highest legal and ethical standards. The Group Ethics Officer (a Certified Ethics Officer) has an approved mandate and monitors implementation of the awareness framework.
Download a copy of the Transaction Capital Ethics Charter here.

Management status reports are distributed for management updates to audit statuses, which are verified in follow-up audits and reported on. A tracking register of unresolved Internal Audit issues is maintained and reported on. A tracking register of unresolved Internal Audit issues is maintained and reported on to the Board and the Group Audit Committee as well as the Group Risk and Compliance Committee.

General controls in Transaction Capital Recoveries are grounded in structured delegations of authority, segregation of duties and documented policies and procedures. Internal Audit is held in high regard and reports and findings are discussed at monthly executive meetings and resolution of findings is monitored at this level.

Risk Management

Enterprise-wide risk management is performed in line with the group-wide framework approved by the Transaction Capital Audit, Risk and Compliance Committee. Quarterly assessment workshops are held and a risk register is populated with details of risks and potential impacts and rated on an agreed three-point scale.

Management action plans and deadlines are agreed and prioritisation is performed to ensure that risks are addressed in a disciplined, progressive manner. Recently, a risk acceptance register has been introduced for recording those risks that are accepted as business risks. The risk acceptance register is communicated to the Board and the group Audit, Risk and Compliance Committee to ensure appropriate awareness of risks that have been accepted by management as well as the potential impact that these may have on Transaction Capital Recoveries.

Compliance

The Compliance Officer assists and provides a facilitation function to Transaction Capital Recoveries ensuring that all requisite regulatory requirements are managed effectively. This role is key, to supporting the Board of Directors and the CEO in promoting a pervasive compliance culture throughout the group. The Compliance Officer undertakes the co-ordination of the overall compliance system and for setting the compliance standards for the group.

Our regulatory universe has been identified and prioritised. In accordance with this priority Compliance is reviewing adherence with regulations through:

• workshops with Exco to ensure there is understanding of legislation;
• review of controls and processes with regards to compliance with legislation; and
• with the assistance of Internal Audit testing the operation of such controls.

The Compliance Officer also reviews any complaints made against Transaction Capital Recoveries to regulatory bodies.

Legal

The Senior Group Legal Advisor is a qualified lawyer with significant experience in providing legal advice in the debt collection arena, specifically, in relation to litigation and contracts.

Areas of responsibility include:

• contracts management;
• litigation management;
• company secretarial services;
• company policy management;
• legal oversight of consumer complaints where necessary;
• input into company training material in the regulatory environment; and
• management of regulatory certificates.