Governance & Accountability¶
| Domain ID | D08 |
| Owner | Chair, Board / Chief Executive Officer |
| Jurisdiction | NZ + AU |
| Applicability | Platform — Platform delivers the technical governance infrastructure: agent action logger (MOD-047), system decision log (MOD-048), and role-scoped data access (MOD-052). Board governance, risk committees, fit and proper processes, and accountability frameworks are human and administrative processes external to any system — this applies in both tracks. |
Board and management accountability, three lines of defence, risk appetite, and internal audit frameworks.
FAR (Financial Accountability Regime) — AU¶
FAR applies to ADIs from 15 March 2024. All accountable persons must be registered with APRA/ASIC. Deferred remuneration applies. Breach of accountability obligations can result in individual civil penalties.
CoFI — NZ equivalent¶
The Conduct of Financial Institutions Act 2022 establishes comparable senior manager accountability obligations in NZ. FMA expects a documented fair conduct programme with Board oversight.
Policies¶
| Code | Policy name | Status |
|---|---|---|
| GOV-001 | Board Charter | Draft |
| GOV-002 | Risk Appetite Statement Policy | Draft |
| GOV-003 | Three Lines of Defence Policy | Draft |
| GOV-004 | Fit & Proper Policy | Draft |
| GOV-005 | Financial Accountability Regime (FAR) Policy | Draft |
| GOV-006 | Internal Audit Policy | Draft |
| GOV-007 | Conflicts of Interest Policy | Draft |
| GOV-008 | Whistleblower Protection Policy | Draft |
| GOV-009 | Related Party Transactions Policy | Draft |
Systems satisfying this domain¶
- MOD-044: JWT RBAC — AUTO (role separation / GOV-007)
- MOD-046: PAM — LOG (privileged access / GOV-006)
- MOD-047: Agent action logger — LOG (all agent actions / GOV-006)
- MOD-048: System decision log — LOG (automated decisions / GOV-006)
Policies in this domain¶
| Code | Title | Status | Owner |
|---|---|---|---|
| GOV-001 | Board Charter | Draft | Company Secretary |
| GOV-002 | Risk Appetite Statement Policy | Draft | Chief Risk Officer |
| GOV-003 | Three Lines of Defence Policy | Draft | Chief Risk Officer |
| GOV-004 | Fit & Proper Policy | Draft | Chief People Officer |
| GOV-005 | Financial Accountability Regime (FAR) Policy | Draft | Company Secretary |
| GOV-006 | Internal Audit Policy | Draft | Chief Internal Auditor |
| GOV-007 | Conflicts of Interest Policy | Draft | Company Secretary |
| GOV-008 | Whistleblower Protection Policy | Draft | General Counsel |
| GOV-009 | Related Party Transactions Policy | Draft | Company Secretary |
| GOV-010 | Restricted Activities Policy | Draft | Chief Compliance Officer |
Compiled 2026-05-22 from source/entities/risk-domains/D08.yaml