BUSINESS GOVERNANCE & OPERATIONAL CONTROLS FRAMEWORK
Governance • Accountability • Operational Assurance
Version 1.0 | Effective 1 January 2026
Governance • Accountability • Operational Assurance
Version 1.0 | Effective 1 January 2026
Version 1.0 • Effective Date: 1 January 2026
Approval date: 24 December 2025
Document Owner: Management
Approver: Tapati Bhattacharya – Managing Director
Review: At least annually and when material changes occur
This Internal Control Framework describes the governance arrangements and practical controls Magma uses or is to implement to support reliable operations, protect company and client interests, maintain accurate records, and manage operational, financial, personnel, information-security and compliance risks. It is proportionate to the company’s size and IT outsourcing / consulting activities.
Material activities have an identified responsible role.
Transactions and commitments are approved by an authorized person.
Important information and transactions are checked before processing.
Where full separation is not possible, management review is used.
Approvals, reconciliations and material decisions are retained.
Access to company, client and personal information is limited.
| Control area | Responsible function | Review / oversight |
|---|---|---|
| Recruitment and candidate checks | Recruitment | HR / Management, as appropriate |
| Employment records and onboarding / offboarding | HR / Administration | Management |
| Consultant deployment and timesheets | Account Management / Operations | Management |
| Client contracts, work orders and PO tracking | Account Management / Operations | Management |
| Invoicing, expenses and payments | Finance / Accounts | Authorized Management reviewer |
| Payroll preparation and verification | Finance / Payroll | Authorized reviewer / Management |
| Work authorization tracking, if applicable | HR / Administration | Management |
| IT access and information security | Designated IT contact / system owner | Management |
| Privacy and data handling | Relevant process owner | Management |
| Risk register and corrective actions | Relevant risk owners | Management |
Recruitment activities must not involve forced labour, human trafficking, deceptive recruitment, unlawful worker-paid recruitment fees or coercive retention of identity documents. Recruitment partners should be informed of these expectations where relevant.
The incident coordinator or Management should assess the incident, take reasonable containment steps, preserve relevant evidence, record the known facts and actions taken, and determine whether client, affected-person or regulator notification is required by applicable law or contract.
AI and other digital tools may be used only for legitimate business purposes. Confidential client information, personal data, CVs, payroll information, credentials and restricted records must not be entered into public or unauthorized AI tools. AI-generated outputs must be checked by an appropriate person before use, including for accuracy, confidentiality, bias and intellectual-property concerns.
For material suppliers or subcontractors, proportionate due diligence should be performed before engagement and periodically where warranted. Checks may include business identity, service capability, conflicts of interest, confidentiality commitments, data-protection and security arrangements, and relevant legal or contractual compliance. The extent of screening should reflect the nature and risk of the services.
Assess likelihood, impact and risk score; assign owners and monitor mitigation actions.
Escalate, investigate, preserve evidence and maintain proportionate continuity plans.
Maintain secure evidence and review the Framework at least annually.
Business Governance & Operational Controls Framework • Version 1.0 • 10 pages
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