Version 1.0
Prepared by: @Lorraine Sebata
Approved by: @Feli Capron
Review date: 2025-07-24
Next review date: 2026-07-24
This policy applies to all employees, agents, contractors, and third parties acting on behalf of Easyterms who are involved in the receipt, disbursement, reconciliation, storage, and transportation of physical cash across all business lines and operational activities.
This Cash Management Policy outlines Easyterms's commitment to the secure, efficient, and effective management of all physical cash. Its purpose is to establish clear guidelines and controls to minimize risks associated with cash handling (e.g., theft, fraud, errors), ensure accurate accounting, maintain optimal liquidity, and comply with all relevant internal controls and regulatory requirements.
This policy applies to all employees, agents, contractors, and third parties acting on behalf of Easyterms who are involved in the receipt, disbursement, reconciliation, storage, and transportation of physical cash across all business lines and operational activities.
Easyterms is committed to full compliance with all applicable national and international laws, regulations, and guidelines pertaining to cash management, financial reporting, and anti-money laundering, including but not limited to [mention specific local laws, e.g., Banking Act, Financial Reporting Standards, relevant central bank guidelines].
The company shall adopt a risk-based approach to cash management, identifying, assessing, and mitigating risks related to cash handling, storage, and movement. Controls will be implemented commensurate with the identified risk levels.
Critical cash handling functions shall be segregated among different individuals to ensure proper internal controls and reduce the risk of fraud or error. This includes separating duties such as cash receipt, cash disbursement, cash reconciliation, and record-keeping.
Maximum cash holding limits shall be established for each branch, safe, and individual cashier. Any cash exceeding these limits must be promptly deposited into the company's designated bank accounts.
Physical cash, when not in active use, must be stored in secure, locked safes or vaults. Access to these storage facilities shall be strictly controlled and monitored. Cash transportation between branches, to/from banks, or other locations must follow secure protocols, which may include dual control, armored car services, or other risk-mitigating measures.
All cash transactions (receipts and disbursements) must be reconciled daily with physical cash counts and system records (e.g., Loan Management System, Cash Book). Any discrepancies must be investigated and reported immediately to the Branch Manager and Finance Department.
All cash transactions must be fully documented with pre-numbered receipts, disbursement vouchers, and proper authorization. Records must be clear, accurate, and retained for the period required by law and internal policy.
Employees involved in cash handling must be vigilant in identifying and reporting any unusual or suspicious cash transactions to the Money Laundering Reporting Officer (MLRO) in accordance with the AML Policy.
Effective internal controls shall be established and maintained over all cash management processes. The cash management program shall be subject to regular internal and external audits to assess its effectiveness and compliance.
All employees involved in cash handling shall receive regular and comprehensive training on this Cash Management Policy, related procedures, security protocols, fraud prevention, and their roles and responsibilities.
Board of Directors / Senior Management: Overall responsibility for approving and overseeing the Cash Management Policy and ensuring adequate resources for its implementation and adherence.
Finance Department: Responsible for developing, implementing, and maintaining cash management policies and procedures, setting cash limits, monitoring cash flows, and performing reconciliations and audits.
Opeartons Managers: Oversee daily cash operations within their team, ensure compliance with the policy, approve transactions within delegated limits, and conduct regular and surprise cash counts.
Cashiers/Tellers: Responsible for the accurate and secure receipt, disbursement, and daily reconciliation of cash, and for adhering to all established procedures.
Security Personnel: Provides physical security for cash handling areas and movements.
This policy will be reviewed at least annually, or more frequently if there are significant changes in laws, regulations, business operations, cash handling risks, or internal control requirements.