Customer Frontline Solutions

I. INTRODUCTION

This Policy defines the roles and responsibilities of Management, Internal Audit and the Audit Committee of Customer Frontline Solutions, Inc. (“CFS” or the “Company”) related to controls over organization’s processes. It also describes the responsibility for a system of checks and balances and emphasizes the importance of internal control processes. Internal control is an integral part of Company’s governance system and risk management.

II. STATEMENT OF POLICY

A.
Strictly comply with the Company’s disclosure controls and procedures and internal controls requirements and not knowingly misrepresent, or cause others to misrepresent facts or information about the Company to others, whether inside or outside the Company, including the Company’s independent auditors, government regulators and self-regulatory organizations.
B.
Ensure that the contents of, and the disclosures in, reports and documents that the Company files with, or submits to the Securities and Exchange Commission (the "SEC"), Bangko Sentral ng Pilipinas (“BSP”), other government agencies or regulators and all other Company’s public communications are complete, fair, accurate, timely and understandable in accordance with applicable disclosure statutes, listing rules, and standards of materiality.
C.
Establish open communication links and make the appropriate disclosures regarding our corporate goals, objectives, rules, financial positions, material transactions with related parties, and prospects to all our stakeholders.
D.
Actively encourage employees to actively participate in discussions and raise any legitimate work-related concern or issue.

III. INTERNAL CONTROL RESPONSIBILITIES OF THE COMPANY

A.
Controlling is a function of management and is an integral part of the overall process of managing operations. As such, it is the responsibility of managers at all levels of the organization to:
- 1.
  Identify and evaluate the exposure to loss which relate to their particular sphere of operations.
- 2.
  Specify and establish policies, plans and operating standards, procedures, systems, and other disciplines to be used to minimize, mitigate, and/or limit the risks associated with the exposures identified.
- 3.
  Establish practical controlling processes that require and encourage officers and employees to carry out their duties and responsibilities in a manner that achieves the five control objectives outlined in Section 1 of the preceding paragraph.
- 4.
  Maintain the effectiveness of the controlling processes that have been established and foster continuous improvement to these processes.
B.
The internal auditing function is charged with the responsibility for ascertaining that the ongoing processes for controlling operations throughout the organization are adequately designed and are functioning in an effective manner, Internal audit is also responsible for reporting to the Audit Committee of the Board and the President and CEO on the adequacy and effectiveness of the organization’s systems of internal control, together with the ideas, counsel and recommendations to improve the systems.
C.
The Audit Committee is responsible for monitoring, overseeing, and evaluating the duties and responsibilities of management the internal audit activity, and the external auditors as those duties and responsibilities relate to the organization’s processes for controlling its operations. The Audit Committee is also responsible for determining that all major issues reported by Internal Audit, the external auditor, and other outside advisors have been satisfactorily resolved.

This Policy was approved on February 19, 2021 by the Board of Directors.