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Simpaisa Group Operating Model

Appendix D: Group Entity Register | Appendix G: KPI Dictionary

Version 0.1 | April 2026 | Document Owner: Chief Digital Officer

Classification: Confidential - Board and Executive Distribution Only


Drafting Note. Fields marked [TBC] require confirmation from Group Legal, the Company Secretary function, or the relevant in-country legal counsel before this appendix can be designated Version 1.0. Registration numbers, registered addresses, incorporation dates, and subsidiary directorship details are to be populated by Group Legal no later than 30 June 2026. This appendix is subject to the same quarterly review cadence as the main operating model.


Appendix D: Group Entity Register


D.1 Purpose and Scope

This register provides a consolidated reference for all legal entities within the Simpaisa Group as at April 2026. It covers:

  • The Singapore HoldCo and all nine operating subsidiaries and branch offices under Group ownership or effective operational control.
  • Equity investments in which the Group holds a minority or majority-acquiring stake.

The register is the authoritative source for entity-level corporate details, regulatory licences, and functional mandates. It is maintained by Group Legal, with updates approved by the Company Secretary and reviewed by the Chief Digital Officer on a quarterly basis and upon any trigger event (new entity, change of directors, acquisition or disposal of a licence, or regulatory status change).

The register should be read in conjunction with: - Section 3 (Corporate Structure and Ownership) of the main operating model. - Section 11 (Licensing and Regulatory Map) for the full multi-jurisdictional licence status. - Section 4 (Board and Executive Governance) for director-level governance obligations.


D.2 Entity Profiles


Entity 1: Simpaisa Holdings PTE. Limited

Field Detail
Registered Name Simpaisa Holdings PTE. Limited
Jurisdiction Republic of Singapore
Entity Type Private Limited Company
Group Role Ultimate Holding Company (HoldCo)
Registration Number [TBC - ACRA Registration Number]
Registered Address [TBC - Singapore registered office address]
Date of Incorporation [TBC]
Directors Nadeem Hussain (Non-Executive Chairman); Yassir Pasha (CEO / Executive Director); Blake Tan (Non-Executive Director); Bernhard Klemen (Non-Executive Director); Sebastian Reis (Non-Executive Director)
Company Secretary [TBC]
Primary Regulatory Authority Monetary Authority of Singapore (MAS)
Licence(s) Held [TBC - MAS licensing status; note: Singapore HoldCo may hold a Major Payment Institution (MPI) licence or operate under exemption; to be confirmed by Group Legal]
Licence Status [TBC]
Entity Purpose Ultimate holding company for all Group subsidiaries, equity investments, and branch offices. Issues equity to Group shareholders (Planet N Group, Sarmayacar VC, and other investors). Holds intercompany loans and provides Group-level treasury, governance, and strategic oversight.
Functional Mandate Board governance and oversight across all nine entities. Group-level capital allocation, treasury management, and intercompany financing. Strategic planning and M&A. Group regulatory posture and investor relations. Holder of Group-level intellectual property and brand rights.

Entity 2: PublishEx Solutions PVT Limited

Field Detail
Registered Name PublishEx Solutions PVT Limited
Jurisdiction Islamic Republic of Pakistan
Entity Type Private Limited Company
Group Role Principal Operating Subsidiary - Pakistan (trading as Simpaisa)
Registration Number [TBC - SECP Registration Number]
Registered Address [TBC - Pakistan registered office address]
Date of Incorporation [TBC]
Directors [TBC - Pakistan subsidiary directors]
Company Secretary [TBC]
Primary Regulatory Authority State Bank of Pakistan (SBP)
Secondary Regulatory Authorities Financial Monitoring Unit (FMU); Securities and Exchange Commission of Pakistan (SECP)
Licence(s) Held SBP Schedule H Payment Aggregation (via UBL sponsor arrangement); 1LINK Integration Agreement; Branchless Banking Agency Agreement; PSO/PSP Own-Licence Application (under review)
Licence Status Schedule H - Active; PSO/PSP Own-Licence - Application submitted, under SBP review
Entity Purpose The Group's primary revenue-generating entity and the home of the Group's engineering organisation. Operates Simpaisa's Pay-Ins, Pay-Outs, crypto off-ramping (USDT→PKR), white-label wallets, mobile top-ups, subscription billing, OTC cash collection, and domestic and international card processing in Pakistan.
Functional Mandate Payment aggregation and processing for Pakistan market. Host entity for all Group technology sub-teams (Pay-Ins engineering, Pay-Outs engineering, Portal, DevOps, SQA, Architecture). AML/CFT reporting to FMU. Merchant acquisition and management for Pakistan. Commercial and settlement operations for all Pakistan corridors.

Entity 3: Simpoysha BD Limited

Field Detail
Registered Name Simpoysha BD Limited
Jurisdiction People's Republic of Bangladesh
Entity Type Private Limited Company
Group Role Operating Subsidiary - Bangladesh (Holding / Management Entity)
Registration Number [TBC - RJSC Registration Number]
Registered Address [TBC - Bangladesh registered office address]
Date of Incorporation [TBC]
Directors [TBC - Bangladesh subsidiary directors]
Company Secretary [TBC]
Primary Regulatory Authority Bangladesh Bank
Secondary Regulatory Authorities Bangladesh Financial Intelligence Unit (BFIU); Registrar of Joint Stock Companies and Firms (RJSC)
Licence(s) Held [TBC - to be confirmed by Group Legal; note: active payment operations in Bangladesh are currently conducted through Soft Tech Innovation / aamarPay under that entity's PSO licence; Simpoysha BD Limited's own licensing status to be confirmed]
Licence Status [TBC]
Entity Purpose Group holding and management entity for Bangladesh operations. Oversees the Group's strategic relationship with Soft Tech Innovation PVT LTD (aamarPay) and manages Simpaisa-branded commercial and operational activities in Bangladesh pending consolidation of the aamarPay acquisition.
Functional Mandate Group representation in Bangladesh. Oversight of commercial and operational activities conducted through aamarPay. Regulatory liaison with Bangladesh Bank. AML/CFT compliance for Simpaisa Group activities in Bangladesh. Coordination of inbound remittance product in Bangladesh.

Entity 4: Soft Tech Innovation PVT LTD (trading as aamarPay)

Field Detail
Registered Name Soft Tech Innovation PVT LTD
Trading Name aamarPay
Jurisdiction People's Republic of Bangladesh
Entity Type Private Limited Company
Group Role Majority-Acquiring Equity Investment - Bangladesh Payment Operator
Registration Number [TBC - RJSC Registration Number]
Registered Address [TBC - Bangladesh registered office address]
Date of Incorporation [TBC]
Directors [TBC - existing aamarPay directors; to be updated post-acquisition completion]
Company Secretary [TBC]
Primary Regulatory Authority Bangladesh Bank
Secondary Regulatory Authorities BFIU; RJSC
Licence(s) Held Bangladesh Bank Payment Service Operator (PSO) Licence
Licence Status Active
Equity Position Simpaisa Group is acquiring a 75% controlling stake. Acquisition in progress as at April 2026. [TBC - completion date and final equity structure]
Entity Purpose Licensed payment system operator in Bangladesh. Operates aamarPay-branded payment gateway, mobile wallet integrations, and payment processing infrastructure. Provides the regulatory and operational foundation for Simpaisa's Bangladesh Pay-Ins and Pay-Outs products across bKash, Nagad, Rocket, Upay, and other local operators.
Functional Mandate Payment processing and settlement for Bangladesh market under Bangladesh Bank PSO licence. Integration hub for all Bangladesh mobile wallet operators and banking rails. Regulatory compliance and reporting to Bangladesh Bank and BFIU. Commercial merchant relationships in Bangladesh.

Entity 5: Simpaisa Technologies LTD

Field Detail
Registered Name Simpaisa Technologies LTD
Jurisdiction Dubai International Financial Centre (DIFC), United Arab Emirates
Entity Type Private Company Limited by Shares (DIFC entity)
Group Role Operating Subsidiary - UAE / MENA Hub
Registration Number [TBC - DIFC Registrar of Companies registration number]
Registered Address [TBC - DIFC registered address]
Date of Incorporation [TBC]
Directors [TBC - UAE/DIFC entity directors]
Company Secretary [TBC]
Primary Regulatory Authority Dubai Financial Services Authority (DFSA)
Secondary Regulatory Authorities Central Bank of the UAE (CBUAE) (as applicable to non-DIFC activities); UAE Financial Intelligence Unit (AMLSCU)
Licence(s) Held DFSA Category 3D Authorised Firm Licence - Application in progress; Operating under appropriate exemptions or limited activity pending licence grant [TBC - confirm with DFSA counsel]
Licence Status DFSA Cat 3D - Application under review as at April 2026
Entity Purpose The Group's MENA hub and primary regulated entity for UAE and MENA market operations. Upon receipt of the DFSA Category 3D licence, will operate as a licensed Providing Money Services firm, enabling Simpaisa to offer payment services and remittances to and from MENA markets with full regulatory authorisation.
Functional Mandate MENA commercial operations and merchant acquisition. Regulatory affairs and DFSA engagement. Treasury and FX operations for MENA corridors. SAMA licensing roadmap execution for Saudi Arabia. UAE-based senior leadership and executive function. Group-level compliance and legal hub for MENA and DIFC-regulated activities.

Entity 6: Commerce Plex Limited

Field Detail
Registered Name Commerce Plex Limited
Jurisdiction United Kingdom of Great Britain and Northern Ireland
Entity Type Private Limited Company
Group Role Operating Subsidiary - United Kingdom
Registration Number [TBC - Companies House Registration Number]
Registered Address [TBC - UK registered office address]
Date of Incorporation [TBC]
Directors [TBC - UK entity directors]
Company Secretary [TBC]
Primary Regulatory Authority Financial Conduct Authority (FCA)
Secondary Regulatory Authorities His Majesty's Revenue and Customs (HMRC) - for Money Service Business registration
Licence(s) Held [TBC - FCA authorisation or registration status; EMI registration, PI authorisation, or HMRC MSB registration, as applicable]
Licence Status [TBC]
Entity Purpose UK-registered entity supporting the Group's commercial and regulatory presence in the United Kingdom. Provides a regulated base for remittance origination from the UK diaspora market (Pakistani, Bangladeshi, and Nepali communities) and for engagement with UK-regulated merchants and partners.
Functional Mandate UK diaspora remittance operations. Commercial partnerships with UK-based digital merchants. FCA and HMRC regulatory compliance. UK-based business development and partnership management. Group point of contact for UK regulatory and legal matters.

Entity 7: Simpaisa CA LTD

Field Detail
Registered Name Simpaisa CA LTD
Jurisdiction Canada (Province of Ontario)
Entity Type Corporation (Ontario Business Corporations Act or Canada Business Corporations Act - [TBC])
Group Role Operating Subsidiary - Canada
Registration Number [TBC - Ontario / CBCA corporate registration number]
Registered Address [TBC - Ontario registered office address]
Date of Incorporation [TBC]
Directors [TBC - Canadian entity directors]
Company Secretary [TBC]
Primary Regulatory Authority Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
Secondary Regulatory Authorities Ontario Ministry of Finance (for money services business provincial registration, where applicable); Canada Revenue Agency (CRA)
Licence(s) Held FINTRAC Money Services Business (MSB) Registration; Foreign Money Services Business (FMSB) Registration (as applicable)
Licence Status [TBC - confirm active MSB/FMSB registration status with FINTRAC]
Entity Purpose Licensed money services business providing outbound remittance origination services from the Canadian diaspora market - primarily Pakistani, Bangladeshi, and Nepali communities in Ontario and broader Canada - to Simpaisa's South Asian operating corridors.
Functional Mandate Inbound remittance origination from Canada. FINTRAC compliance including suspicious transaction reporting, large cash transaction reporting, and LVTS reporting as applicable. Know Your Customer (KYC) and identity verification for Canadian-resident remittance senders. Partnership management with Canadian distribution channels and diaspora community organisations.

Entity 8: Simpaisa Holdings PTE. LTD - Iraq Branch Office

Field Detail
Registered Name Simpaisa Holdings PTE. LTD (Iraq Branch)
Jurisdiction Republic of Iraq
Entity Type Branch Office of the Singapore HoldCo
Group Role Branch - Iraq Market Presence
Registration Number [TBC - Iraqi Companies Registrar branch registration number]
Registered Address [TBC - Iraq branch registered address]
Date of Incorporation / Registration [TBC]
Branch Manager / Authorised Representative [TBC]
Directors As per Singapore HoldCo (Nadeem Hussain, Yassir Pasha, Blake Tan, Bernhard Klemen, Sebastian Reis); branch manager locally [TBC]
Company Secretary [TBC - Group Company Secretary; local notarised representative as required by Iraqi law]
Primary Regulatory Authority Central Bank of Iraq (CBI)
Secondary Regulatory Authorities Iraqi Companies Registrar (Ministry of Trade); Anti-Money Laundering and Countering the Financing of Terrorism Commission (AMLCFTC) of Iraq
Licence(s) Held [TBC - CBI payment institution or remittance operator licence; confirm with Iraqi legal counsel]
Licence Status In Development - active commercial discussions and regulatory engagement underway as at April 2026
Entity Purpose Represents the Simpaisa Group in Iraq. Supports the development of Pay-In and Pay-Out products for the Iraqi market, including integration with local banks, mobile wallet operators, and the Iraqi payment system infrastructure.
Functional Mandate Iraq market development and regulatory engagement. Local commercial partnerships and merchant development. CBI compliance and reporting. In-country operational coordination for Iraq products (Pay-Ins, Pay-Outs, Mobile Top-Ups) as they progress from In Development to Active status.

Entity 9: Pay Nest PVT LTD

Field Detail
Registered Name Pay Nest PVT LTD
Jurisdiction Federal Democratic Republic of Nepal
Entity Type Private Limited Company
Group Role Operating Subsidiary - Nepal
Registration Number [TBC - Office of the Company Registrar (OCR) registration number]
Registered Address [TBC - Nepal registered office address]
Date of Incorporation [TBC]
Directors [TBC - Nepal entity directors]
Company Secretary [TBC]
Primary Regulatory Authority Nepal Rastra Bank (NRB)
Secondary Regulatory Authorities Office of the Company Registrar (OCR); Department of Money Laundering Investigation (DMLI)
Licence(s) Held [TBC - NRB Payment Service Operator or Payment Service Provider licence; own-licence application in progress]
Licence Status [TBC - currently operating through PSP partnerships (Khalti, e-Sewa, IME Pay, Paywell) pending direct NRB licence]
Entity Purpose The Group's licensed vehicle for Nepal payment operations. Provides the regulatory foundation for Simpaisa's inbound remittance, Pay-In, and Pay-Out products in Nepal, initially through licensed PSP partnerships and progressively transitioning to directly licensed operations upon NRB licence grant.
Functional Mandate Nepal payment operations and PSP partnership management. Inbound remittance receiving in Nepal. NRB regulatory engagement and licence application. AML/CFT compliance and DMLI reporting. Commercial and settlement operations for Nepal corridors.

D.3 Equity Investments Register

The following entities are not wholly owned subsidiaries of the Group but represent material equity interests or strategic acquisitions in progress.


Investment 1: YAP Pakistan PVT LTD

Field Detail
Registered Name YAP Pakistan PVT LTD
Jurisdiction Islamic Republic of Pakistan
Entity Type Private Limited Company
Investment Nature Minority equity stake
Simpaisa Equity Interest [TBC - confirm % stake with Group Legal and Finance]
Primary Regulatory Authority State Bank of Pakistan (SBP)
Licence(s) Held [TBC - SBP EMI Licence or applicable licence held by YAP Pakistan]
Licence Status [TBC]
Strategic Rationale Provides the Group with access to an SBP-licensed electronic money institution framework in Pakistan, enabling the white-label wallet and stored-value product proposition. Aligns with Simpaisa's strategy to offer merchant partners a fully integrated wallet-plus-payments solution under a licensed infrastructure.
Governance Rights [TBC - board representation, information rights, consent rights per SHA]

Investment 2: Soft Tech Innovation PVT LTD (aamarPay)

Field Detail
Registered Name Soft Tech Innovation PVT LTD
Trading Name aamarPay
Jurisdiction People's Republic of Bangladesh
Investment Nature Majority acquisition in progress
Simpaisa Target Equity Interest 75%
Acquisition Status In progress as at April 2026 - [TBC - completion date, conditions precedent, and final equity structure with Group Legal and M&A counsel]
Primary Regulatory Authority Bangladesh Bank
Licence(s) Held Bangladesh Bank Payment Service Operator (PSO) Licence
Licence Status Active
Strategic Rationale Acquiring a controlling stake in aamarPay gives the Group a directly licensed payment system operator in Bangladesh, eliminating reliance on third-party operator arrangements and unlocking the full Pay-Ins, Pay-Outs, and settlement stack under Simpaisa's direct operational and regulatory control.
Governance Rights [TBC - upon completion; majority shareholder board control with minority protections as per SHA]

D.4 Group Entity Summary Table

The table below provides a consolidated one-line summary for navigation purposes.

# Entity Name Jurisdiction Type Group Role Primary Regulator Status
1 Simpaisa Holdings PTE. Limited Singapore HoldCo Ultimate Holding Company MAS Active
2 PublishEx Solutions PVT Limited Pakistan Subsidiary Principal Operating Entity (Pakistan) SBP Active
3 Simpoysha BD Limited Bangladesh Subsidiary Management Entity (Bangladesh) Bangladesh Bank Active
4 Soft Tech Innovation PVT LTD (aamarPay) Bangladesh Equity Investment (75% acquiring) Licensed Payment Operator (Bangladesh) Bangladesh Bank Active (acquisition in progress)
5 Simpaisa Technologies LTD UAE / DIFC Subsidiary MENA Hub DFSA DFSA licence application in progress
6 Commerce Plex Limited UK Subsidiary UK Operations FCA [TBC - licence status]
7 Simpaisa CA LTD Canada (Ontario) Subsidiary Canada / Diaspora Remittance FINTRAC Active (MSB/FMSB registered)
8 Simpaisa Holdings PTE. LTD (Iraq Branch) Iraq Branch Office Iraq Market Development Central Bank of Iraq In Development
9 Pay Nest PVT LTD Nepal Subsidiary Nepal Operations Nepal Rastra Bank In Development (licence application in progress)
INV-1 YAP Pakistan PVT LTD Pakistan Equity Investment EMI Licence Access (Pakistan) SBP [TBC - stake %]
INV-2 Soft Tech Innovation / aamarPay Bangladesh Equity Investment Licensed PSO (Bangladesh) Bangladesh Bank Acquisition in progress


Appendix G: KPI Dictionary


G.1 Purpose and Governance

This KPI Dictionary defines all Key Performance Indicators referenced across the Simpaisa Group Operating Model. It is the authoritative reference for how each KPI is named, defined, measured, and owned. The dictionary serves three purposes.

Measurement consistency. KPI definitions are specified precisely so that the same metric is calculated identically across Group, country, and entity-level reporting. Ambiguity in KPI definition is a frequent source of management reporting error; this dictionary eliminates it.

Ownership and accountability. Each KPI has a named functional owner who is accountable for the accuracy of the underlying data, the timeliness of reporting, and the escalation of performance concerns when a KPI moves outside tolerance. The owner is not necessarily the person responsible for achieving the target - they are the person responsible for ensuring the metric is measured and reported correctly.

Target-setting baseline. Targets marked [TBC] are to be set through the Group's annual planning process and validated against market benchmarks. Where a target is already established by regulatory requirement or contract, this is indicated. All targets are subject to quarterly review by the relevant functional head.

Review cadence. This dictionary is reviewed quarterly alongside the operating model. The Data team (reporting to the CDO) is responsible for maintaining the data lineage, source system mapping, and calculation logic underlying each KPI.


G.2 Category 1: Payment Operations KPIs

# KPI Name Definition Formula Data Source Target Reporting Frequency Owner
PO-01 API Uptime The percentage of time the Simpaisa Payment API (gateway entry point) is available and responding within the defined latency threshold (p99 ≤ 500ms), measured on a rolling 30-day basis. Excludes pre-announced maintenance windows of ≤ 4 hours per month. (Total minutes in period − Minutes of unplanned unavailability) ÷ Total minutes in period × 100 AWS CloudWatch; Cloudflare Health Checks; PagerDuty incident log ≥ 99.9% Daily (dashboard); Monthly (report) CTO
PO-02 Overall Payment Success Rate The percentage of all initiated payment transactions that reach a COMPLETED status, across all channels and all markets, within the same calendar day as initiation. Excludes transactions abandoned by the consumer prior to payment method selection. Completed transactions ÷ Initiated transactions (excluding consumer-abandoned) × 100 Transaction ledger (MySQL) ≥ 85% Daily (dashboard); Weekly (report) CTO / CPO
PO-03 Mobile Wallet Success Rate Payment success rate for mobile wallet transactions specifically (eWallet channel), segmented by country and by operator. Separate reporting lines for each major operator (Easypaisa, JazzCash, bKash, Nagad, Khalti, etc.). Completed wallet transactions ÷ Initiated wallet transactions × 100 Transaction ledger - channel-filtered ≥ 90% per operator Daily CTO
PO-04 Direct Carrier Billing (DCB) Success Rate Payment success rate for DCB / direct operator billing transactions, segmented by MNO (Mobilink, Telenor, Ufone, Zong). Completed DCB transactions ÷ Initiated DCB transactions × 100 Transaction ledger - channel-filtered ≥ 80% Daily CTO
PO-05 IBFT / Bank Transfer Success Rate Payment success rate for internet banking fund transfer (IBFT) and 1Bill/1LINK transactions. Completed IBFT transactions ÷ Initiated IBFT transactions × 100 Transaction ledger - channel-filtered ≥ 90% Daily CTO
PO-06 OTC Cash Collection Success Rate Percentage of OTC vouchers generated that result in a confirmed cash collection by an agent within the voucher validity window (typically 24–72 hours). Confirmed OTC collections ÷ OTC vouchers generated × 100 Transaction ledger - OTC channel ≥ 75% Daily CPO / CTO
PO-07 Settlement Timeliness The percentage of scheduled merchant settlement runs that are executed and confirmed within the contractually agreed settlement cycle (T+1 or T+2 as per individual merchant MPSA terms). Settlement runs executed on time ÷ Total scheduled settlement runs × 100 Settlement engine log; Finance GL 100% Daily (run-level); Weekly (report) CFO / CTO
PO-08 Reconciliation Break Rate The rate of reconciliation breaks (unmatched items between Simpaisa's internal ledger and operator/bank statement records) as a proportion of total transactions in each settlement period. Unmatched items in reconciliation ÷ Total transactions in period × 100 Finance reconciliation system; Settlement engine < 0.1% Daily CFO
PO-09 Webhook Delivery Success Rate The percentage of merchant-configured webhook notifications (transaction status updates) that are delivered to the merchant's registered endpoint and acknowledged with an HTTP 2xx response within 30 seconds of the triggering transaction event. Webhooks acknowledged (2xx) within 30 seconds ÷ Total webhooks dispatched × 100 Webhook dispatcher log (application log / Kafka consumer metrics) ≥ 99.5% Daily CTO
PO-10 Fallback Activation Rate The percentage of failed primary-channel transactions for which the fallback routing logic successfully re-routed the transaction to a secondary channel and achieved completion. Measures the effectiveness of Simpaisa's resilience-routing configuration. Transactions completed via fallback ÷ Transactions that triggered fallback logic × 100 Transaction ledger - fallback flag ≥ 60% Weekly CTO / CPO
PO-11 Transaction Processing Latency (p95) The 95th percentile end-to-end processing time from API receipt of a payment request to return of the first authorisation response (COMPLETED or FAILED status) to the merchant, measured in milliseconds. Excludes consumer dwell time on the hosted payment page. p95 of (authorisation response timestamp − API receipt timestamp) API gateway metrics (CloudWatch / Cloudflare) ≤ 3,000ms (p95) Hourly (dashboard); Daily (report) CTO
PO-12 Chargeback Rate (Card) The number of chargebacks received from card acquirers as a percentage of total card transactions processed in the same period. Monitored against Visa/Mastercard thresholds. Chargebacks received ÷ Total card transactions × 100 Card acquirer dispute file; Transaction ledger < 0.5% (Visa/MC threshold: 1%) Monthly CPO / CFO

G.3 Category 2: Commercial KPIs

# KPI Name Definition Formula Data Source Target Reporting Frequency Owner
CO-01 Gross Transaction Value (GTV) - Group Total value of all payment transactions successfully processed by the Simpaisa platform across all markets, channels, and corridors in a given period, denominated in USD. Includes Pay-Ins, Pay-Outs, and remittances. Excludes failed and reversed transactions. Sum of (completed transaction amount × applicable FX rate to USD) Transaction ledger; Finance FX rate table [TBC - monthly GTV target per annual plan] Daily (dashboard); Monthly (board report) CFO / CPO
CO-02 GTV by Country GTV segmented by operating country (Pakistan, Bangladesh, Nepal, UAE, Iraq, Canada). Enables country-level performance tracking and identification of market-specific trends. Sum of completed transaction amounts per country × FX to USD Transaction ledger - country dimension [TBC - per country per annual plan] Daily (dashboard); Monthly (report) CPO / Country Heads
CO-03 GTV by Payment Method GTV segmented by payment channel (mobile wallet, DCB, IBFT, OTC, card - domestic and international, crypto). Informs routing strategy, channel economics, and product investment decisions. Sum of completed transaction amounts per channel × FX to USD Transaction ledger - channel dimension [TBC] Weekly CPO / CTO
CO-04 MDR Yield The effective merchant discount rate yield achieved across the portfolio, calculated as total MDR revenue as a percentage of total GTV. Tracks whether the commercial pricing strategy is delivering the intended revenue per dollar of volume. Total MDR revenue ÷ Total GTV × 100 Finance GL - MDR revenue lines; Settlement engine [TBC - target blended MDR yield per pricing model] Monthly CFO / CPO
CO-05 Merchant Onboarding Time (Median) The median calendar days from a merchant's submission of a complete KYB application package to their first live transaction being processed. Measures the efficiency of the commercial and compliance onboarding process. Median of (first live transaction date − KYB application submission date) for all merchants onboarded in the period CRM / KYB workflow system ≤ 14 calendar days Monthly CPO / Global Head of Compliance
CO-06 Sales Pipeline Conversion Rate The percentage of qualified sales pipeline opportunities (prospects that have passed initial qualification and received a commercial proposal) that convert to signed and activated merchants within a 90-day window. Activated merchants in period ÷ Qualified opportunities entered pipeline 90 days prior × 100 CRM (pipeline stage tracking) ≥ 25% Monthly CPO / Commercial Lead
CO-07 Active Merchant Count The number of merchants that have processed at least one successful transaction in the trailing 30-day period. Distinguishes from total contracted merchants to identify dormant accounts requiring commercial intervention. Count of merchant IDs with ≥ 1 completed transaction in trailing 30 days Transaction ledger - merchant dimension [TBC - per annual plan] Monthly CPO
CO-08 Merchant Health Score A composite score (0–100) for each merchant account, calculated from: GTV trend (MoM), payment success rate, dispute/chargeback rate, support ticket volume, and days since last transaction. Identifies at-risk accounts before they churn. Weighted composite of: GTV trend (30%), success rate (25%), dispute rate (20%), support volume (15%), recency (10%) Transaction ledger; Support system; CRM Score ≥ 70 for ≥ 80% of active merchants Monthly CPO
CO-09 Merchant Churn Rate The percentage of merchants who were active (processed ≥ 1 transaction) in the prior 30-day period but were inactive (0 transactions) in the current 30-day period. Rolling 30-day calculation. Merchants active in prior period but inactive in current period ÷ Merchants active in prior period × 100 Transaction ledger - merchant dimension < 5% monthly Monthly CPO
CO-10 Revenue by Product Line Total net revenue (MDR + fees) segmented by product line (Pay-Ins, Pay-Outs, Remittance, Crypto, White-Label). Enables product-level P&L tracking and prioritisation. Sum of net revenue per product line per Finance GL Finance GL - product dimension [TBC - per product P&L in annual plan] Monthly CFO / CPO
CO-11 Cost per Acquisition (Merchant) Total commercial and compliance onboarding cost (sales team cost + KYB/KYC processing cost + technical integration support cost) divided by the number of merchants activated in the period. Total onboarding cost in period ÷ Merchants activated in period Finance GL (cost centre allocation); HR system [TBC] Monthly CFO / CPO

G.4 Category 3: Remittance KPIs

# KPI Name Definition Formula Data Source Target Reporting Frequency Owner
RM-01 Remittance Corridor Volume Total value of remittance transactions processed per active corridor (e.g., Canada→Pakistan, UK→Bangladesh, UAE→Nepal) in the period, in USD. Sum of completed remittance amounts per corridor × FX to USD Transaction ledger - remittance product, corridor dimension [TBC - per corridor per annual plan] Monthly CPO / Country Heads
RM-02 FX Spread Revenue Total revenue earned from FX conversion on remittance transactions, calculated as the difference between the interbank rate applied and the rate offered to the sender, multiplied by total remittance volume converted. (Simpaisa offered rate − Interbank rate) × FX volume converted Treasury FX blotter; Finance GL [TBC - target spread per corridor] Monthly CFO / Treasury
RM-03 Send-to-Receive Time (Median) The median elapsed time from the moment a remittance instruction is confirmed and funded by the sender to the moment the recipient account (wallet or bank account) is credited. Measured in minutes for instant rails and hours for T+1 rails. Median of (recipient credit timestamp − sender confirmation timestamp) per corridor Transaction ledger - remittance product ≤ 60 minutes (instant corridors); ≤ T+1 business day (bank corridors) Monthly CTO / CPO
RM-04 Compliance Screening Pass Rate The percentage of remittance transactions that clear sanctions screening, PEP screening, and transaction monitoring rules on the first pass without requiring manual intervention or suspension. Transactions auto-cleared ÷ Total remittance transactions screened × 100 Compliance screening system log [TBC - target based on false positive tuning; typically ≥ 95%] Monthly Global Head of Compliance
RM-05 Remittance Delivery Failure Rate The percentage of remittance transactions that fail to credit the intended recipient after the sender's funds have been confirmed, requiring manual intervention, reversal, or customer support resolution. Remittance delivery failures ÷ Total funded remittance instructions × 100 Transaction ledger; Customer support system < 1% Monthly CTO / CPO
RM-06 Active Remittance Senders (Monthly) The count of unique sender identities (KYC-verified) that initiated at least one remittance transaction in the calendar month. Tracks diaspora customer base growth. Count of distinct verified sender IDs with ≥ 1 completed remittance in the month Transaction ledger - remittance product [TBC - per corridor per annual plan] Monthly CPO
RM-07 Average Transaction Value - Remittance The mean USD-equivalent value of remittance transactions processed in the period. Informs pricing strategy and customer segmentation. Total remittance GTV ÷ Total remittance transaction count Transaction ledger - remittance product [TBC] Monthly CFO / CPO

G.5 Category 4: Technology KPIs

# KPI Name Definition Formula Data Source Target Reporting Frequency Owner
TE-01 Deployment Frequency The number of successful deployments to production across all services in the period. A deployment is counted once the build is confirmed healthy in production by automated health checks. Count of successful production deployments in period Jenkins deployment log; PagerDuty Daily deploys for all services (target state); current baseline: multiple deploys per week for Pay-Ins and Portal Weekly CTO
TE-02 Change Failure Rate The percentage of deployments to production that result in a degraded service condition (error rate spike, latency regression, or user-impacting incident) within 60 minutes of deployment, requiring a rollback or hotfix. Deployments causing degradation ÷ Total deployments × 100 Jenkins deployment log; PagerDuty incident log < 5% Weekly CTO
TE-03 Mean Time to Recovery (MTTR) The average elapsed time from the moment a production incident is detected (PagerDuty alert triggered or NOC/SOC detection) to the moment the service is restored to normal operating parameters. Measured in minutes. Mean of (service restored timestamp − incident detected timestamp) per incident PagerDuty incident log ≤ 30 minutes (P1); ≤ 2 hours (P2) Monthly CTO
TE-04 SLO Adherence Rate The percentage of defined Service Level Objectives (SLOs) - covering API uptime, latency, and success rate thresholds for each production service - that were met in the period. A separate SLO dashboard is maintained per service. SLOs met ÷ Total SLOs defined × 100 SRE SLO dashboard (CloudWatch / Grafana) ≥ 95% of SLOs met across all services Monthly CTO
TE-05 Error Budget Consumption The proportion of the monthly error budget consumed for each critical service. Error budgets are calculated from SLO targets (e.g., 99.9% uptime = 43.8 minutes monthly error budget). When a service has consumed > 80% of its budget, new feature deployments are paused in favour of reliability work. (Actual downtime / error events) ÷ Error budget for period × 100 SRE SLO dashboard < 80% of budget consumed per service per month Monthly CTO
TE-06 Infrastructure Cost per Transaction Total monthly cloud infrastructure spend (AWS + Cloudflare) divided by total successful transactions processed in the same month. Denominated in USD cents. Tracks the unit economics of the technology platform. Total cloud infrastructure cost (USD) ÷ Total successful transactions AWS Cost Explorer; Cloudflare billing; Transaction ledger [TBC - establish baseline; target reduction of 15% YoY] Monthly CTO / CFO
TE-07 Automated Test Coverage The percentage of production application code covered by automated unit and integration tests, as reported by the CI/CD pipeline on each build. Tracked per service and as a Group-level average. Lines covered by automated tests ÷ Total application code lines × 100 (per SonarQube / test runner report) SonarQube; Jenkins CI pipeline ≥ 80% per service Monthly CTO / SQA Head
TE-08 Mean Time to Detect (MTTD) - Incidents The average elapsed time between the onset of a production anomaly (as determined retrospectively from logs) and the triggering of an automated alert in PagerDuty. Lower MTTD indicates more effective observability tooling. Mean of (alert trigger timestamp − anomaly onset timestamp) per incident PagerDuty; CloudWatch logs; Grafana ≤ 5 minutes (for P1/P2 anomalies) Monthly CTO / CISO

G.6 Category 5: Security KPIs

# KPI Name Definition Formula Data Source Target Reporting Frequency Owner
SE-01 Security Incident Response Time - Critical (P1) Elapsed time from confirmed detection of a Critical (P1) security incident (e.g., active breach, ransomware, credential compromise) to initiation of the formal incident response procedure and notification of the CISO. Time from P1 incident confirmation to CISO notification and IR team activation (minutes) SIEM incident log; SOC ticket system ≤ 15 minutes Per incident; Monthly summary CISO
SE-02 Security Incident Response Time - High (P2) Elapsed time from confirmed detection of a High (P2) security incident to initiation of formal response. Time from P2 incident confirmation to IR team engagement (minutes) SIEM incident log ≤ 60 minutes Per incident; Monthly summary CISO
SE-03 Critical Vulnerability Remediation SLA Adherence The percentage of Critical (CVSS ≥ 9.0) vulnerabilities identified through Snyk, penetration testing, or threat intelligence that are remediated (patched, mitigated, or formally risk-accepted with CISO sign-off) within the defined SLA of 7 calendar days. Critical vulns remediated within 7 days ÷ Total critical vulns identified × 100 Snyk; Penetration test tracker; Vulnerability management register ≥ 95% Monthly CISO
SE-04 High Vulnerability Remediation SLA Adherence The percentage of High (CVSS 7.0–8.9) vulnerabilities remediated within 30 calendar days. High vulns remediated within 30 days ÷ Total high vulns identified × 100 Snyk; Vulnerability management register ≥ 90% Monthly CISO
SE-05 Phishing Simulation Click Rate The percentage of Group employees who click a link in a simulated phishing e-mail during scheduled phishing simulation exercises conducted by the Security team. Measures security awareness programme effectiveness. Employees who clicked ÷ Employees targeted in simulation × 100 Phishing simulation platform (e.g., KnowBe4 or equivalent) < 10% click rate; < 5% credential submission rate Quarterly (per simulation) CISO
SE-06 PCI DSS Compliance Status Binary and detailed indicator of the Group's compliance with PCI DSS requirements as assessed by the Qualified Security Assessor (QSA) or through self-assessment, segmented by cardholder data environment (CDE) in each country. Pass / Fail per control domain; percentage of controls fully compliant QSA report; SAQ (as applicable); Internal control testing log 100% of applicable controls compliant at all times Quarterly (internal); Annually (QSA assessment) CISO / CFO
SE-07 Penetration Test Critical / High Finding Closure Rate The percentage of Critical and High findings from the most recent penetration test that have been remediated and verified closed within 90 days of the test report being issued. Critical and High findings closed within 90 days ÷ Total Critical and High findings in test report × 100 Penetration test tracker ≥ 90% within 90 days Per test cycle (minimum annual) CISO
SE-08 Privileged Access Review Completion Rate The percentage of privileged access reviews (for production systems, cloud IAM roles, and database administrative accounts) completed on schedule each quarter, as required by the Group's Access Control Policy. Access reviews completed on schedule ÷ Access reviews due × 100 IAM review log; ITSM system 100% Quarterly CISO
SE-09 Security Awareness Training Completion Rate The percentage of all Group employees who have completed the mandatory annual security awareness training programme within the required completion window. Employees who completed mandatory training ÷ Total employees in scope × 100 LMS / training platform ≥ 95% within 30 days of assignment Annually; tracked monthly during window CISO / HR

G.7 Category 6: Compliance KPIs

# KPI Name Definition Formula Data Source Target Reporting Frequency Owner
CL-01 Suspicious Transaction Report (STR) Filing Timeliness The percentage of STRs filed with the relevant Financial Intelligence Unit (FMU, BFIU, FINTRAC, etc.) within the regulatory deadline from the date of suspicion being documented and approved for submission. Deadline varies by jurisdiction (24 hours in Pakistan; 3 days in Bangladesh; 30 days in Canada). STRs filed within regulatory deadline ÷ Total STRs filed × 100 Case management system; Compliance workflow log 100% Monthly Global Head of Compliance / Country Compliance Officers
CL-02 Sanctions Screening False Positive Rate The percentage of sanctions screening alerts that, upon manual review, are confirmed as false positives (i.e., legitimate transactions incorrectly flagged). High false positive rates indicate screening configuration requiring tuning; low rates may indicate under-screening. False positive alerts ÷ Total sanctions screening alerts × 100 Sanctions screening system (Dow Jones / Refinitiv / equivalent) < 90% false positive rate (i.e., ≥ 10% true positive rate within alerts); absolute rate to be benchmarked Monthly Global Head of Compliance
CL-03 KYB Completion Time (Merchant) The median calendar days from submission of a complete KYB documentation package by a prospective merchant to a final Approved, Declined, or Enhanced Due Diligence (EDD) referral decision by the compliance team. Median of (KYB decision date − complete documentation receipt date) for all KYB cases closed in the period KYB workflow system / CRM ≤ 5 business days (standard); ≤ 15 business days (EDD) Monthly Global Head of Compliance / CPO
CL-04 KYC Completion Time (Remittance Sender) The median elapsed time (in minutes for digital-first onboarding, or hours for manual review) from submission of KYC information by a new remittance sender to a final Verified or Rejected status. Median of (KYC decision timestamp − application submission timestamp) KYC platform (identity verification provider log) ≤ 5 minutes (automated); ≤ 24 hours (manual review) Monthly Global Head of Compliance / CPO
CL-05 Policy Review Adherence The percentage of Group policies due for periodic review (as scheduled in the Policy Register, Section 27) that have been reviewed, approved, and updated (or confirmed unchanged) within the scheduled review window. Policies reviewed on schedule ÷ Policies due for review in period × 100 Policy Register 100% Quarterly Global Head of Compliance / CDO
CL-06 Compliance Training Completion Rate The percentage of Group employees in roles with designated compliance training requirements (AML/CFT, sanctions, data protection, conduct) who have completed all assigned modules within the required completion window. Employees with all assigned compliance modules completed ÷ Employees with assigned compliance modules × 100 LMS / training platform ≥ 95% within required window Quarterly Global Head of Compliance / HR
CL-07 Regulatory Filing Timeliness The percentage of mandatory regulatory filings (FMU reports, Bangladesh Bank returns, FINTRAC reports, SBP returns, DFSA reports, etc.) submitted by the relevant entity within the regulatory deadline. Filings submitted on time ÷ Total mandatory filings due × 100 Regulatory calendar / compliance tracker 100% Monthly Global Head of Compliance / Country Compliance Officers
CL-08 Transaction Monitoring Alert Closure Time The median elapsed time (in business days) from an automated transaction monitoring alert being generated to a documented disposition decision (escalated to STR, closed as false positive, or placed on watchlist). Median of (alert disposition date − alert generation date) for all alerts closed in the period Transaction monitoring system; Case management system ≤ 5 business days Monthly Global Head of Compliance
CL-09 EDD Review Currency The percentage of merchants and partners classified as High Risk that have a current Enhanced Due Diligence review on file (completed within the last 12 months). High-risk entities with EDD completed within 12 months ÷ Total high-risk entities × 100 KYB system; Compliance case management 100% Quarterly Global Head of Compliance

G.8 Category 7: Financial KPIs

# KPI Name Definition Formula Data Source Target Reporting Frequency Owner
FI-01 Revenue Growth Rate Period-on-period growth in total net revenue (MDR + fees + FX spread) across the Group, expressed as a percentage. Reported MoM, QoQ, and YoY. (Current period revenue − Prior period revenue) ÷ Prior period revenue × 100 Finance GL - consolidated P&L [TBC - per annual plan] Monthly (MoM); Quarterly (QoQ); Annually (YoY) CFO
FI-02 Gross Margin Total net revenue less direct cost of revenue (operator interchange, payment network fees, gateway infrastructure costs, and settlement bank charges), expressed as a percentage of net revenue. (Net revenue − Direct cost of revenue) ÷ Net revenue × 100 Finance GL - P&L [TBC - target gross margin per annual plan] Monthly CFO
FI-03 EBITDA Earnings before interest, tax, depreciation, and amortisation. The primary measure of operating profitability for the Group, excluding the effects of capital structure, taxation, and non-cash charges. Net revenue − Operating expenses (excluding interest, tax, D&A) Finance GL - consolidated P&L [TBC - per annual plan; target timeline to EBITDA breakeven] Monthly CFO
FI-04 Cash Runway The number of months of operating expenses the Group can fund from its current cash and liquid asset position, assuming no new revenue inflows. Calculated at Group consolidated level and for each entity separately where the entity holds material cash balances. Cash and liquid assets ÷ Average monthly operating cash burn Bank statements; Finance GL - cash flow statement ≥ 12 months at Group consolidated level at all times Monthly CFO / Group Treasurer
FI-05 FX Exposure The net open foreign currency position of the Group across all currencies (PKR, BDT, NPR, AED, IQD, CAD, GBP), expressed in USD equivalent. Represents the financial risk from currency movements on unhedged positions. Sum of (net long or short position per currency × spot rate to USD) Treasury blotter; Finance GL - FX position report Within Board-approved FX risk appetite limits per currency [TBC - limits to be set by Board on CFO recommendation] Weekly CFO / Group Treasurer
FI-06 Settlement Float The total value of merchant funds received by Simpaisa but not yet disbursed to merchants (i.e., funds in transit between collection and settlement). Monitored for both liquidity management and client funds segregation compliance purposes. Sum of merchant account balances pending settlement across all markets (USD equivalent) Settlement engine; Finance GL - client money account Maintained within liquidity plan; fully segregated from operational funds Daily CFO / Group Treasurer
FI-07 Client Funds Segregation Accuracy The accuracy of client funds segregation - the degree to which all merchant and consumer funds held by the Group are held in designated, ring-fenced client money accounts, separate from the Group's own operational funds. Expressed as a percentage of client funds correctly segregated. Client funds correctly held in segregated accounts ÷ Total client funds held × 100 Bank account reconciliation; Finance GL 100% at all times Daily CFO / Global Head of Compliance
FI-08 Operator Counterparty Credit Exposure The aggregate exposure to each payment operator and banking partner arising from collected funds not yet settled to Simpaisa. Tracks concentration risk in the settlement cycle. Sum of outstanding settlement amounts receivable from each counterparty (USD equivalent) Settlement engine - counterparty ageing report Within Board-approved counterparty exposure limits [TBC] Weekly CFO / Group Treasurer
FI-09 Cost-to-Income Ratio Total operating expenses as a proportion of total net revenue. Measures operational efficiency at the Group level. Total operating expenses ÷ Total net revenue × 100 Finance GL - consolidated P&L [TBC - target per annual plan; directional target: declining over time as revenue scales faster than cost base] Monthly CFO

G.9 Category 8: Human Resources KPIs

# KPI Name Definition Formula Data Source Target Reporting Frequency Owner
HR-01 Headcount vs Plan Actual headcount (permanent and long-term contract employees, by entity and function) compared to the approved headcount plan for the period. Variance tracked in absolute number and as a percentage. (Actual headcount − Planned headcount) and (Actual headcount ÷ Planned headcount × 100) HRIS; Approved headcount plan Within ±5% of plan at Group level; individual entity variances escalated if > 10% Monthly CHRO / CFO
HR-02 Time to Hire The median elapsed calendar days from the date a hiring requisition is formally opened to the date a new hire accepts an offer. Measured separately for technical roles (engineering, data, security) and non-technical roles. Median of (offer acceptance date − requisition open date) for all hires in period ATS (Applicant Tracking System) ≤ 30 days (technical roles); ≤ 21 days (non-technical roles) Monthly CHRO
HR-03 Voluntary Attrition Rate The percentage of permanent employees who voluntarily resigned in the trailing 12-month period, annualised. Monitored at Group level and by function. Voluntary resignations in trailing 12 months ÷ Average headcount over trailing 12 months × 100 HRIS - exit records < 15% annualised at Group level; < 20% for engineering Monthly (rolling 12-month) CHRO
HR-04 Involuntary Attrition Rate The percentage of permanent employees whose employment was terminated by the company (performance, redundancy, or misconduct) in the trailing 12-month period, annualised. Involuntary terminations in trailing 12 months ÷ Average headcount over trailing 12 months × 100 HRIS - termination records [TBC - monitor for trend; no absolute target, but significant spikes trigger root cause review] Monthly (rolling 12-month) CHRO
HR-05 Training Completion Rate - All Mandatory Training The percentage of employees who have completed all mandatory training modules assigned to their role (compliance, security awareness, conduct, and any role-specific technical certifications required by regulation) within the prescribed completion window. Employees with all mandatory modules completed ÷ Total employees with assigned mandatory modules × 100 LMS ≥ 95% Quarterly CHRO / Global Head of Compliance / CISO
HR-06 Employee Engagement Score The Group-level composite engagement score derived from the annual employee engagement survey, measured on a 0–100 scale. Tracks employee sentiment, motivation, and intent to stay. Composite score from engagement survey instrument (standardised methodology to be applied consistently year-on-year) Employee engagement survey platform ≥ 65 (target initial baseline); ≥ 70 by Year 2 Annually (survey); quarterly pulse (where conducted) CHRO
HR-07 Fit-and-Proper Certification Currency The percentage of individuals in Controlled Functions (CFs) and Approved Persons (as defined by applicable regulations across DFSA, FCA, SBP, Bangladesh Bank, and FINTRAC) whose fit-and-proper assessments are current (completed within the required renewal window and any material change notifications filed as required). CF/AP roles with current fit-and-proper assessment ÷ Total CF/AP roles × 100 HR compliance register; Regulatory submissions log 100% at all times Monthly CHRO / Global Head of Compliance
HR-08 Internal Promotion Rate The percentage of open vacancies filled by internal candidates (promotion or lateral move) as a proportion of all vacancies filled in the period. Measures the effectiveness of talent development and succession planning. Internal hires ÷ Total hires in period × 100 HRIS; ATS ≥ 20% Annually CHRO
HR-09 Offer Acceptance Rate The percentage of formal employment offers made to candidates that are accepted. A declining rate indicates competitiveness issues with compensation, role design, or employer brand. Offers accepted ÷ Offers made × 100 ATS ≥ 80% Monthly CHRO

G.10 Category 9: Country-Level KPIs

Country KPIs are reported for each active operating market. The table below defines the standard KPI set applied to every country. Country Heads are responsible for ensuring data is available and accurate for their market. Country-specific addenda to this dictionary will be maintained where a market requires KPIs beyond the standard set (e.g., crypto off-ramp metrics for Pakistan; aamarPay-specific operator SLA metrics for Bangladesh).

# KPI Name Definition Formula Data Source Target Reporting Frequency Owner
CY-01 Country GTV Total GTV for the country in the period (USD equivalent). Primary measure of market scale and growth trajectory. Sum of completed transaction amounts for country × FX to USD Transaction ledger - country dimension [TBC - per country per annual plan] Monthly Country Head / CPO
CY-02 Country Payment Success Rate Overall payment success rate across all channels for the country. Enables country-level benchmarking and identification of systemic market issues. Completed transactions (country) ÷ Initiated transactions (country, excluding consumer-abandoned) × 100 Transaction ledger - country dimension ≥ 85% (all markets); market-specific stretch targets [TBC] Daily Country Head / CTO
CY-03 Regulatory Filing Compliance - Country The percentage of country-specific mandatory regulatory filings (central bank returns, FIU reports, tax filings, corporate secretarial filings) submitted on time by the local entity. Filings submitted on time ÷ Total filings due × 100 Country compliance calendar 100% Monthly Country Head / Country Compliance Officer
CY-04 Local Partner SLA Adherence The percentage of SLA commitments (availability, settlement timing, API response time) met by key local payment operator partners (e.g., Easypaisa, JazzCash, bKash, Nagad, 1LINK, local banks) against the agreed SLA in the relevant operator agreement. Partner SLA commitments met ÷ Total SLA commitments measurable in period × 100 Operator API monitoring logs; Settlement records; Partner relationship tracker ≥ 90% per partner; partners below threshold subject to formal remediation engagement Monthly CTO / Country Head
CY-05 Country Net Revenue Net revenue (MDR + fees) generated in the country in the period, in USD. Enables country-level P&L reporting and contribution margin analysis. Sum of net revenue attributed to country transactions per Finance GL Finance GL - country dimension [TBC - per country per annual plan] Monthly CFO / Country Head
CY-06 Country Merchant Count (Active) Number of merchants active (≥ 1 completed transaction in trailing 30 days) in the country. Count of merchant IDs with ≥ 1 completed transaction in trailing 30 days, filtered by country Transaction ledger - merchant × country dimension [TBC - per country per annual plan] Monthly Country Head / CPO
CY-07 Country Inbound Remittance Volume Total volume (USD equivalent) of inbound remittances credited to recipients in the country in the period. Relevant for Pakistan, Bangladesh, and Nepal as primary receive markets. Sum of completed inbound remittance credits for country × FX to USD Transaction ledger - remittance product, receive-country dimension [TBC] Monthly Country Head / CPO
CY-08 Country Compliance Incident Rate The number of compliance incidents (regulatory breaches, STR filing delays, sanctions hits, AML/CFT policy violations, or regulatory enforcement actions) attributable to the country entity in the period. Count of compliance incidents documented in the compliance incident register attributable to the country Compliance incident register Zero regulatory breaches or enforcement actions; STR delay incidents: 0 Monthly Country Head / Global Head of Compliance

G.11 KPI Ownership and Reporting Accountability Summary

Functional Area Primary KPI Owner Reporting Frequency Board Visibility
Payment Operations CTO Daily (dashboard); Monthly (report) Quarterly Board Report
Commercial CPO Daily (dashboard); Monthly (report) Quarterly Board Report
Remittance CPO / CFO Monthly Quarterly Board Report
Technology CTO Weekly (ops); Monthly (report) Quarterly Board Report
Security CISO Monthly Quarterly Board Report; CISO incident brief as required
Compliance Global Head of Compliance Monthly Quarterly Board Report; Compliance and Regulatory Committee
Financial CFO Monthly Quarterly Board Report; Audit and Risk Committee
Human Resources CHRO Monthly Quarterly Board Report
Country Operations Country Heads Monthly Quarterly Board Report - Country Scorecards

G.12 KPI Index - Numerical Reference

KPI ID KPI Name Category
PO-01 API Uptime Payment Operations
PO-02 Overall Payment Success Rate Payment Operations
PO-03 Mobile Wallet Success Rate Payment Operations
PO-04 Direct Carrier Billing (DCB) Success Rate Payment Operations
PO-05 IBFT / Bank Transfer Success Rate Payment Operations
PO-06 OTC Cash Collection Success Rate Payment Operations
PO-07 Settlement Timeliness Payment Operations
PO-08 Reconciliation Break Rate Payment Operations
PO-09 Webhook Delivery Success Rate Payment Operations
PO-10 Fallback Activation Rate Payment Operations
PO-11 Transaction Processing Latency (p95) Payment Operations
PO-12 Chargeback Rate (Card) Payment Operations
CO-01 Gross Transaction Value (GTV) - Group Commercial
CO-02 GTV by Country Commercial
CO-03 GTV by Payment Method Commercial
CO-04 MDR Yield Commercial
CO-05 Merchant Onboarding Time (Median) Commercial
CO-06 Sales Pipeline Conversion Rate Commercial
CO-07 Active Merchant Count Commercial
CO-08 Merchant Health Score Commercial
CO-09 Merchant Churn Rate Commercial
CO-10 Revenue by Product Line Commercial
CO-11 Cost per Acquisition (Merchant) Commercial
RM-01 Remittance Corridor Volume Remittance
RM-02 FX Spread Revenue Remittance
RM-03 Send-to-Receive Time (Median) Remittance
RM-04 Compliance Screening Pass Rate Remittance
RM-05 Remittance Delivery Failure Rate Remittance
RM-06 Active Remittance Senders (Monthly) Remittance
RM-07 Average Transaction Value - Remittance Remittance
TE-01 Deployment Frequency Technology
TE-02 Change Failure Rate Technology
TE-03 Mean Time to Recovery (MTTR) Technology
TE-04 SLO Adherence Rate Technology
TE-05 Error Budget Consumption Technology
TE-06 Infrastructure Cost per Transaction Technology
TE-07 Automated Test Coverage Technology
TE-08 Mean Time to Detect (MTTD) Technology
SE-01 Security Incident Response Time - Critical (P1) Security
SE-02 Security Incident Response Time - High (P2) Security
SE-03 Critical Vulnerability Remediation SLA Adherence Security
SE-04 High Vulnerability Remediation SLA Adherence Security
SE-05 Phishing Simulation Click Rate Security
SE-06 PCI DSS Compliance Status Security
SE-07 Pen Test Critical/High Finding Closure Rate Security
SE-08 Privileged Access Review Completion Rate Security
SE-09 Security Awareness Training Completion Rate Security
CL-01 STR Filing Timeliness Compliance
CL-02 Sanctions Screening False Positive Rate Compliance
CL-03 KYB Completion Time (Merchant) Compliance
CL-04 KYC Completion Time (Remittance Sender) Compliance
CL-05 Policy Review Adherence Compliance
CL-06 Compliance Training Completion Rate Compliance
CL-07 Regulatory Filing Timeliness Compliance
CL-08 Transaction Monitoring Alert Closure Time Compliance
CL-09 EDD Review Currency Compliance
FI-01 Revenue Growth Rate Financial
FI-02 Gross Margin Financial
FI-03 EBITDA Financial
FI-04 Cash Runway Financial
FI-05 FX Exposure Financial
FI-06 Settlement Float Financial
FI-07 Client Funds Segregation Accuracy Financial
FI-08 Operator Counterparty Credit Exposure Financial
FI-09 Cost-to-Income Ratio Financial
HR-01 Headcount vs Plan Human Resources
HR-02 Time to Hire Human Resources
HR-03 Voluntary Attrition Rate Human Resources
HR-04 Involuntary Attrition Rate Human Resources
HR-05 Training Completion Rate - All Mandatory Training Human Resources
HR-06 Employee Engagement Score Human Resources
HR-07 Fit-and-Proper Certification Currency Human Resources
HR-08 Internal Promotion Rate Human Resources
HR-09 Offer Acceptance Rate Human Resources
CY-01 Country GTV Country
CY-02 Country Payment Success Rate Country
CY-03 Regulatory Filing Compliance - Country Country
CY-04 Local Partner SLA Adherence Country
CY-05 Country Net Revenue Country
CY-06 Country Merchant Count (Active) Country
CY-07 Country Inbound Remittance Volume Country
CY-08 Country Compliance Incident Rate Country

Total KPIs defined: 83


End of Appendix D and Appendix G


Document Control

Field Detail
Document Title Simpaisa Group Operating Model - Appendix D: Group Entity Register; Appendix G: KPI Dictionary
Version 0.1
Status Draft
Date April 2026
Author Chief Digital Officer
Next Review 30 June 2026
Classification Confidential - Board and Executive Distribution Only