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Section 6: Roles and Responsibilities

Document: Simpaisa Group Operating Model
Version: 0.1 | April 2026
Owner: Chief Operating Officer


6.1 Executive Role Profiles

The following profiles cover all C-Suite and Country Head roles. Each profile follows a standardised structure: Purpose | Key Accountabilities | Key Performance Indicators | Decision Authority | Critical Interdependencies | Reporting Line.


6.1.1 Chief Executive Officer - Yassir Pasha

Purpose

The Chief Executive Officer is the ultimate accountable officer for the Simpaisa Group. The CEO sets the strategic direction of the organisation, represents the Group to investors, regulators, and external stakeholders, and ensures that the Group delivers on its mission to build the leading cross-border payments infrastructure for frontier and emerging markets. The CEO is the primary custodian of the Group's licence to operate and the principal architect of long-term value creation.

Key Accountabilities

  • Develop and communicate the Group's long-term vision, strategy, and commercial objectives to the Board, leadership team, investors, and regulators.
  • Own the overall Group P&L and hold all functional heads accountable for delivery against financial and operational targets.
  • Lead investor relations: manage existing investor relationships, lead fundraising processes, prepare investor communications, and drive future capital raise activity (building on five completed funding rounds totalling $90M).
  • Cultivate and maintain strategic regulatory relationships with central banks and payment system regulators across all jurisdictions - including the State Bank of Pakistan, Bangladesh Bank, Nepal Rastra Bank, Central Bank of Iraq, DFSA (UAE), MAS (Singapore), FINTRAC (Canada), SAMA (Saudi Arabia), and emerging markets in MENA and Central Asia.
  • Represent the Group at the highest level in strategic partnership negotiations, including banking correspondents, mobile money operators, and white-label wallet clients.
  • Chair the Executive Leadership Team (ELT) and drive cross-functional alignment on strategic priorities.
  • Lead the Group's geographic expansion agenda, including Saudi Arabia, MENA, and Central Asia, making market-entry decisions in consultation with the Board.
  • Ensure the Group maintains sound governance standards consistent with the expectations of the Board, investors, and multi-jurisdictional regulators.
  • Lead the Group's culture, setting the tone at the top for integrity, compliance, innovation, and customer focus.
  • Oversee CEO-sponsored initiatives including strategic partnerships, large-scale commercial agreements, and licence acquisitions.
  • Report to the Board of Directors on Group performance, strategy execution, material risks, and regulatory matters.

Key Performance Indicators

KPI Target / Threshold
Group revenue growth (year-on-year) As per Board-approved plan
Total Payment Volume (TPV) growth As per Board-approved plan
Fundraising - capital raised and timing Per funding round milestones
New market launches Saudi Arabia Q2 2026; Kazakhstan Q1 2026
Regulatory licence milestones achieved Per Licence Acquisition Roadmap
Investor satisfaction / NPS (where measured) Positive trajectory
Employee engagement (senior leadership) Measured annually
Board-approved strategy execution score Quarterly Board review

Decision Authority

  • Full authority over Group strategy and direction, subject to Board approval for material changes.
  • Sole authority to approve commitments to investors and Shareholder agreements.
  • Authority to approve Group-level regulatory positions and licence applications.
  • Authority to approve capital allocation decisions above the threshold defined in the Delegation of Authority (DoA) Matrix.
  • Authority to appoint and terminate C-Suite officers, subject to Board Remuneration and Nomination Committee approval.
  • Authority to approve all material commercial contracts above designated thresholds (per DoA).

Critical Interdependencies

  • Board of Directors: strategy approval, governance oversight, capital decisions.
  • Global CFO: financial performance, treasury, audit, and investor reporting.
  • Chief Strategy and Network Officer: strategy execution, operational performance management.
  • Chief Operating Officer: institutionalisation, governance, and regulatory compliance framework.
  • Global Head of Regulatory Affairs: licence strategy and central bank relationships.
  • CRO / Head of Business: commercial pipeline, revenue, and strategic partnerships.
  • All Country Heads: market performance, local regulatory relationships.

Reporting Line

Reports to the Board of Directors (Chairman: Nadeem Hussain).


6.1.2 Chief Strategy and Network Officer - Bachir Njeim

Purpose

The Chief Strategy and Network Officer (CSNO) is responsible for translating the Group's strategic intent into executable plans and ensuring that operational performance is continuously managed against those plans. Drawing on deep expertise in global payments network operations (20 years at Western Union including Head of Planning for Account Payout Network, Dubai), the CSNO owns the Strategic Planning Process (SPP), product performance management, and the cross-functional collaboration frameworks that enable the organisation to operate as one cohesive entity across multiple geographies and product lines.

Key Accountabilities

  • Own and drive the Group's annual and multi-year Strategic Planning Process (SPP), including strategic framework development, objective-setting, initiative prioritisation, and execution monitoring.
  • Translate Board-approved strategy into operational plans with clear owners, timelines, milestones, and KPIs for each function and geography.
  • Manage product performance against commercial targets - monitoring TPV, revenue, margins, and corridor-level performance for Pay-Ins, Pay-Outs, Remittances, Crypto Off-Ramping, and White-Label Wallets.
  • Chair the cross-functional operational review cadence (weekly/monthly/quarterly), driving accountability and resolving cross-departmental blockers.
  • Lead the planning and operationalisation of new corridor activations, product launches, and geographic expansion in close partnership with the CEO, COO, and Country Heads.
  • Own management reporting dashboards and executive-level performance packs presented to the CEO and Board.
  • Identify strategic risks and operational gaps; develop mitigation plans and escalate material issues.
  • Drive continuous improvement initiatives across the business, applying learnings from global payment network operations to enhance efficiency, partner management, and service quality.
  • Act as the CEO's operational counterpart: deputise for the CEO in internal operational forums as required.
  • Oversee the operationalisation of the Group's Payment Channel and Partner Network strategy, ensuring sufficient reach and redundancy across all active corridors.
  • Support fundraising and investor processes by providing operational performance data, narrative, and strategic projections.

Key Performance Indicators

KPI Target / Threshold
SPP cycle completion - on time and to quality Annual; Board approval by Q4 each year
OKR / strategic initiative completion rate ≥80% on-track per quarter
Product revenue vs. plan (by corridor and product) ≤5% negative variance
Management reporting pack delivery timeliness 100% on schedule
Cross-functional blocker resolution time ≤5 business days for escalated items
New corridor activation - time to operational Per corridor roadmap milestones

Decision Authority

  • Authority to approve operational process changes across functions (below capital expenditure thresholds).
  • Authority to reprioritise operational initiatives within approved strategic plans.
  • Authority to direct cross-functional working groups and impose resolution timelines.
  • Recommends to CEO all decisions relating to corridor strategy, product prioritisation, and partner network changes above operational thresholds.

Critical Interdependencies

  • CEO: strategic direction, mandate, and escalation.
  • COO: governance framework and institutionalisation workstreams.
  • CPO: product roadmap alignment with strategic priorities.
  • Global CFO: financial performance data and budget management.
  • CRO: revenue targets, commercial pipeline, and go-to-market execution.
  • Country Heads: operational performance reporting and market intelligence.
  • Payment Channel Partnerships: channel performance and corridor SLAs.

Reporting Line

Reports to the Chief Executive Officer.


6.1.3 Chief Operating Officer - Kamil Shaikh

Purpose

The Chief Operating Officer (COO) is responsible for building the institutional foundations of the Simpaisa Group - transforming a high-growth fintech into a regulated, governed, and operationally resilient multi-jurisdictional financial services organisation. Drawing on 17 years at Citi (London and Dubai) across Shariah-compliant custody, AML remediation programmes, and MiFID II implementation, the COO owns the Group's institutionalisation and regularisation agenda, geographic expansion operational framework, corporate governance, cost control, and legal entity structuring for new markets.

Key Accountabilities

  • Own the Group's institutionalisation programme: identify and close gaps in governance, policy, process, and control infrastructure required by regulators and institutional partners across all jurisdictions.
  • Develop and maintain the Group's overarching governance framework, including the Delegation of Authority Matrix, committee structures, entity governance documents, and the corporate governance calendar.
  • Lead the operational and corporate structuring for all new market entries - including entity formation, registered office establishment, local director appointments, and opening of banking relationships.
  • Manage operational efficiency and cost control across support functions (HR, Legal, Admin, Procurement, Finance); own the Group's cost-to-income trajectory.
  • Oversee the HR function: talent acquisition strategy, organisational design, compensation frameworks, performance management, and people development.
  • Oversee the Group Legal function: contract management, entity compliance, employment law, and legal risk management across all jurisdictions.
  • Own the Admin and Procurement function: vendor management, office operations, and procurement governance.
  • Drive the Growth and Governance function: regulatory readiness programmes, investor-grade operational documentation, and institutional investor due diligence preparedness.
  • Ensure the Group meets fit-and-proper requirements and governance standards required by DFSA (UAE), MAS (Singapore), SBP (Pakistan), Bangladesh Bank, and other relevant regulators for senior appointed roles.
  • Act as the internal audit sponsor; oversee the internal audit function and ensure timely remediation of audit findings.
  • Chair operational risk governance forums and own the operational risk register.
  • Build the marketing and brand function to support B2B commercial objectives, investor communications, and regulatory credibility.

Key Performance Indicators

KPI Target / Threshold
Governance framework completeness Policy gap closure per roadmap (Section 27.4)
New entity operational readiness (days to operable) Per market entry milestones
Cost-to-income ratio Improving trajectory year-on-year
Audit findings closed on time ≥90% within agreed remediation deadlines
HR - time to hire (senior roles) ≤60 days
Employee retention rate ≥85% annually
Vendor contract compliance 100% of material contracts reviewed annually
Internal SLA compliance (support functions) ≥95%

Decision Authority

  • Authority to approve operational policy changes across support functions.
  • Authority to approve vendor and supplier contracts up to thresholds defined in the DoA Matrix.
  • Authority to approve organisational structure changes below C-Suite level, subject to CFO budget sign-off.
  • Authority to initiate entity formation processes in new markets, subject to Board approval of market entry.
  • Joint authority with the CEO on senior appointments below C-Suite level.

Critical Interdependencies

  • CEO: strategic mandate, governance escalations, and Board reporting.
  • CSNO: operational alignment with strategic plan.
  • Global CFO: budget, cost control, and entity financial structuring.
  • Global Head of Regulatory Affairs: regulatory compliance framework and new market licensing.
  • Legal (Head of Legal): entity governance, contract management, and regulatory submissions.
  • HR (Head of HR): people strategy and organisational design execution.
  • Country Heads: country governance and operational standards compliance.

Reporting Line

Reports to the Chief Executive Officer.


6.1.4 Chief Product Officer - Rizwan Zafar

Purpose

The Chief Product Officer (CPO) is responsible for defining and delivering Simpaisa's product vision across its full portfolio - Pay-Ins, Pay-Outs, Remittances, Crypto Off-Ramping, and White-Label Wallets. The CPO owns the Group's product roadmap, drives Agile delivery practices across all development teams, and ensures that all product development meets PCI DSS and ISO 27001 standards. Leveraging experience at Daraz (Alibaba Group) and Tapmad, the CPO brings a data-driven, customer-centric, and commercially oriented approach to product development for frontier-market payment ecosystems.

Key Accountabilities

  • Define, own, and communicate the Group's product vision and multi-year product roadmap, aligned to the strategic plan and approved by the CEO and CSNO.
  • Oversee all product development: Portal, Pay-Ins (Collections), Pay-Outs (Disbursements), Remittances, Crypto Off-Ramp, and White-Label Wallet products.
  • Embed and champion Agile delivery practices across the technology organisation - Scrum, XP, sprint planning, backlog grooming, and retrospectives - in close partnership with the CTO.
  • Own merchant onboarding automation: design and continuously improve KYB (Know Your Business) workflows, automated due diligence integrations, and merchant portal self-service capabilities.
  • Ensure all product development adheres to PCI DSS and ISO 27001 requirements - working with the CISO to embed security and compliance requirements into product specifications from inception.
  • Own the product performance management framework: define product KPIs, track product health metrics, and drive continuous improvement based on data and customer feedback.
  • Lead the cross-border payment ecosystem strategy: identify integration opportunities, API partnerships, and product innovations that extend Simpaisa's network reach and competitive differentiation.
  • Manage the PMO function, ensuring programme governance, project delivery standards, and dependency management across all concurrent initiatives.
  • Own the Service Delivery function, including SLA management for merchant and partner-facing service commitments.
  • Drive integration management: oversee technical integration onboarding for new payment channels, partners, and white-label clients.
  • Collaborate with the CRO on go-to-market product strategy, pricing, and merchant-facing product collateral.
  • Represent the product organisation at the ELT and Board level; provide product update reporting on a regular cadence.

Key Performance Indicators

KPI Target / Threshold
Product roadmap milestone delivery (on time) ≥80% of quarterly roadmap items
Merchant onboarding automation rate (KYB) ≥70% automated (reducing manual touchpoints)
Sprint velocity and predictability Improving trend; <10% variance from committed
Payment success rate (by product / corridor) ≥98% (Pay-Ins); ≥97% (Pay-Outs)
Time to integrate new payment channel ≤30 working days (standard); ≤60 (complex)
PCI DSS annual certification Maintained without critical findings
ISO 27001 product-related controls compliance 100% at each annual audit
Merchant portal NPS / CSAT score Positive trajectory; target ≥40 NPS

Decision Authority

  • Authority to approve product specifications and roadmap prioritisation within approved budget.
  • Authority to approve integration designs and API specifications.
  • Authority to determine Agile team composition and sprint priorities in coordination with the CTO.
  • Authority to approve KYB workflow designs and merchant onboarding policies (in coordination with Compliance).
  • Recommends to the CEO any product pivots, major roadmap changes, or new product development requiring incremental investment.

Critical Interdependencies

  • CTO: engineering delivery, infrastructure, and technical architecture.
  • CISO: PCI DSS and ISO 27001 product-level compliance.
  • CSNO: product performance against commercial targets.
  • CRO: commercial product requirements, merchant feedback, and go-to-market.
  • Global Head of Regulatory Affairs: regulatory requirements embedded in product design.
  • Country Head Pakistan: operational requirements from payment channel operations.
  • Country Heads (Bangladesh and Nepal): local product requirements and channel-specific specifications.

Reporting Line

Reports to the Chief Executive Officer.


6.1.5 Global Chief Financial Officer - Mohammad Mustafa

Purpose

The Global Chief Financial Officer (Global CFO) is responsible for the financial integrity, sustainability, and strategic financial positioning of the Simpaisa Group. As an ACCA-qualified professional with 10+ years of experience including a Big Four background (PwC) and a track record of closing five funding rounds totalling $90M, the Global CFO manages all aspects of the Group's finance function across multiple entities and jurisdictions - including treasury, financial reporting, audit, taxation, cross-border transfer pricing, budgeting, and cost optimisation.

Key Accountabilities

  • Own and manage the Group's global finance function across all entities: Simpaisa Holdings (Singapore), PublishEx (Pakistan), Simpoysha BD / Soft Tech (Bangladesh), Simpaisa Technologies (UAE), Commerce Plex (UK), Simpaisa CA (Canada), and Pay Nest (Nepal).
  • Produce accurate, timely, and IFRS-compliant group and entity-level financial statements; manage statutory reporting obligations for each jurisdiction.
  • Lead the Group's external audit relationships (PwC Pakistan, PwC Singapore) and ensure unqualified audit opinions are achieved for all entities.
  • Own the Group treasury function: manage multi-currency cash positions, bank account structures, liquidity planning, and pre-funding requirements for payment operations.
  • Develop and maintain the Group's financial planning and budgeting process, including the annual budget, quarterly reforecasts, and multi-year financial model for investor use.
  • Manage cross-border transfer pricing and intercompany arrangements in compliance with applicable tax regulations across all jurisdictions.
  • Lead the Group's tax strategy and compliance across Singapore, Pakistan, Bangladesh, UAE, Canada, UK, and Nepal - managing local tax advisors where required.
  • Support and lead fundraising processes: prepare investor-grade financial models, due diligence data room materials, cap table management, and post-round reporting.
  • Drive cost optimisation initiatives across the Group in partnership with the COO.
  • Manage financial risk: FX risk management for frontier currency pairs (USD/PKR, USD/BDT, USD/NPR, USD/IQD), liquidity risk, counterparty credit risk, and settlement risk.
  • Ensure client funds safeguarding arrangements comply with Group Policy and applicable regulatory requirements.
  • Provide financial analysis and decision support to the CEO, Board, and ELT on material commercial and strategic decisions.
  • Oversee the internal audit function or support the appointment of an internal auditor.

Key Performance Indicators

KPI Target / Threshold
Statutory accounts filed on time (all entities) 100% on time per jurisdictional deadlines
Audit opinion - all entities Unqualified
Group management accounts delivery By 10th of following month
Cash and liquidity - minimum operating reserve As per Board-approved liquidity policy
FX exposure vs. hedging thresholds Within Board-approved risk appetite
Budget vs. actuals variance (OPEX) ≤5% negative variance quarterly
Fundraising milestone delivery Per agreed fundraising timeline
Transfer pricing documentation completeness 100% per annual review

Decision Authority

  • Authority to approve all Group financial commitments within thresholds defined in the DoA Matrix.
  • Authority to approve payment runs, treasury transactions, and bank account operations per authorised signatory mandates.
  • Authority to approve intercompany invoicing, transfer pricing positions, and tax filings.
  • Joint authority with CEO on investment decisions and capital allocation above defined thresholds.
  • Authority to appoint and manage external accountants, auditors, and tax advisors.

Critical Interdependencies

  • CEO: fundraising, investor reporting, capital allocation.
  • CSNO: management reporting and operational financial performance.
  • COO: cost control, budget management, and entity structuring.
  • Head of Treasury: day-to-day treasury operations, pre-funding, and cash management.
  • Country Head Pakistan: Pakistan settlement and reconciliation financial flows.
  • Country Head Bangladesh and Nepal: BD/NP entity financial management.
  • Global Head of Regulatory Affairs: regulatory capital requirements and licence fee planning.

Reporting Line

Reports to the Chief Executive Officer. Functional accountability to the Board Audit and Risk Committee.


6.1.6 Chief Information and Security Officer - Danish Hamid

Purpose

The Chief Information and Security Officer (CISO) is responsible for defining, implementing, and maintaining the Group's Information Security Management System (ISMS), cybersecurity programme, and technology governance framework. With 12+ years of cybersecurity experience including a background at Tapmad and deep expertise in PCI DSS and ISO 27001, the CISO ensures that Simpaisa's payment platform, customer data, and operational infrastructure are protected against cyber threats, and that the Group maintains its certifications and regulatory compliance in information security.

Key Accountabilities

  • Own and continuously improve the Group's ISMS in accordance with ISO 27001 - maintaining certification and managing annual surveillance and recertification audits.
  • Own the Group's PCI DSS compliance programme - managing scope definition, control implementation, Qualified Security Assessor (QSA) relationships, and annual Report on Compliance (RoC) or Self-Assessment Questionnaire (SAQ) processes.
  • Oversee the 24/7 Security Operations Centre (SOC) and Network Operations Centre (NOC): monitoring, alerting, incident detection, and response across all Group infrastructure and platforms.
  • Own cloud security architecture and operations on AWS: Security Hub, GuardDuty, Detective, WAF, Inspector, Network Firewall, and Microsoft Defender tooling.
  • Manage the DevSecOps programme in partnership with the CTO: embedding security controls into the CI/CD pipeline, code review, dependency scanning (Snyk), and automated security testing.
  • Own the Group's penetration testing programme: commission internal and external penetration tests, manage vulnerability disclosure, and track remediation.
  • Define and maintain the Group's information security policies, standards, and procedures - including Acceptable Use Policy, Identity and Access Management (IAM) standards, data classification, and encryption standards.
  • Manage the IT infrastructure function: servers, networking, end-user computing, and IT help desk operations.
  • Own the Group's incident response plan: lead cyber incident response for all material information security incidents; coordinate with regulators as required.
  • Manage data protection and privacy compliance by jurisdiction: Pakistan PECA, Bangladesh ICT Act, Nepal Privacy Act, PDPA Singapore, UAE data protection law, and UK GDPR (via Commerce Plex).
  • Conduct security awareness training and phishing simulation programmes for all employees.
  • Provide the CISO function to the Board Technology and Information Security Committee; report on the Group's security posture, incidents, and risk indicators.
  • Manage the CyGlass, Datadog, Amazon CloudWatch, AttackMetricx, and related security tooling platforms.

Key Performance Indicators

KPI Target / Threshold
ISO 27001 certification - maintained No lapse; recertification on schedule
PCI DSS compliance - maintained No lapse; RoC/SAQ completed annually
Mean Time to Detect (MTTD) - security incidents ≤4 hours for critical incidents
Mean Time to Respond (MTTR) - security incidents ≤24 hours for critical; ≤72 hours for major
Critical/high vulnerabilities remediated ≥90% within SLA
Penetration test - critical findings remediated 100% within 30 days of report
Security awareness training completion 100% of employees annually
NOC uptime monitoring coverage 100% of production systems

Decision Authority

  • Authority to impose security controls, access restrictions, and system changes in response to security threats, without prior approval when time-critical.
  • Authority to approve information security architecture decisions and tooling procurement.
  • Authority to invoke the incident response plan and direct incident response activities.
  • Authority to approve or reject changes to the production environment from a security-risk perspective.
  • Recommends to the CEO/Board any material security incidents requiring regulatory disclosure.

Critical Interdependencies

  • CTO: DevSecOps integration, infrastructure security, and change management.
  • CPO: PCI DSS and ISO 27001 requirements in product design.
  • COO: security policy integration with operational governance.
  • Global Head of Regulatory Affairs: data protection and security regulatory requirements by jurisdiction.
  • Global CFO: information security budget and investment decisions.
  • Lead NOC and System Administration: day-to-day operations of monitoring and infrastructure.
  • Information Security Manager: operational management of the security programme.

Reporting Line

Reports to the Chief Executive Officer. Functional accountability to the Board Technology and Information Security Committee.


6.1.7 Chief Technology Officer - Saqlain Raza

Purpose

The Chief Technology Officer (CTO) is responsible for the design, development, delivery, and operational stability of all Simpaisa technology platforms. With 17+ years of technology leadership at major financial institutions (UBL, HBL, K-Electric) and post-graduate qualifications in computer science (MCS and MSCS), the CTO leads the full engineering organisation - encompassing Portal development, Pay-Ins (Collections), Pay-Outs (Disbursements), DevOps, database management, software quality assurance, and system architecture - to deliver a scalable, resilient, API-first payment technology platform.

Key Accountabilities

  • Own all software development across the Group's platform: Merchant Portal, Pay-Ins (Collections) engine, Pay-Outs (Disbursements) engine, and supporting microservices.
  • Define and own the Group's technology architecture - in partnership with the Principal Architect and Application Architect - ensuring scalability, resilience, and maintainability.
  • Own the DevOps and CI/CD function: Jenkins, Terraform, Ansible, and AWS infrastructure automation; manage the DevOps and Infrastructure team.
  • Own the database architecture and engineering: MySQL, PostgreSQL, MongoDB, and Amazon DocumentDB - ensuring data integrity, availability, and performance.
  • Own the Software Quality Assurance (SQA) function: manage the SQA team across automation and manual testing; maintain quality gates using REST Assured, Gatling, JMeter, Playwright, and Appium.
  • Manage the engineering organisation across all development teams (Portal: 7; Disbursements: 7; Collections: 6; DevOps and DB: 9; SQA: 7; Architecture: 2) - totalling approximately 38 technology professionals.
  • Drive engineering excellence: code review standards, technical debt management, documentation, and engineering competency development.
  • Translate product roadmap requirements (from the CPO) into technical delivery plans; manage engineering capacity and prioritisation.
  • Own the Group's infrastructure on AWS: EC2, VPC, ALB/NLB, CloudFront, NAT Gateway, Parameter Store, Certificate Manager, Autoscaling, SNS, Kafka (messaging), and Redis (caching).
  • Own the technology roadmap (12–24 months); present to the CEO, ELT, and Board Technology Committee.
  • Partner with the CISO on DevSecOps, cloud security, and secure development lifecycle (SDLC) practices.
  • Manage vendor and technology partner relationships for engineering tooling, cloud services, and infrastructure.
  • Ensure system availability meets the Group's 99.9%+ uptime target across all production environments.

Key Performance Indicators

KPI Target / Threshold
Platform availability (production) ≥99.9% monthly uptime
Deployment frequency (releases per sprint) Per Agile sprint cadence; ≥2 releases/sprint
Change Failure Rate ≤5% of production deployments
Mean Time to Recovery (MTTR) - production incidents ≤2 hours (critical)
Technical debt ratio Reducing trajectory (tracked per sprint)
SQA - defect escape rate (post-release) ≤1% of tested features
Engineering team velocity (story points) Improving trend; <10% variance from committed
Infrastructure cost vs. budget ≤5% negative variance

Decision Authority

  • Authority to approve all technology architecture decisions.
  • Authority to approve engineering tooling, cloud infrastructure, and technology vendor procurement within DoA thresholds.
  • Authority to determine engineering team structures and sprint priorities.
  • Authority to approve production deployments and change requests.
  • Recommends to the CEO any technology investment decisions above DoA thresholds.

Critical Interdependencies

  • CPO: product roadmap to engineering delivery translation.
  • CISO: DevSecOps, cloud security, and ISO 27001/PCI DSS technical controls.
  • Principal Architect: technical architecture decisions and platform evolution.
  • Head of DevOps and Infrastructure: infrastructure operations and CI/CD management.
  • Head of SQA and SD: quality assurance governance and test coverage.
  • Country Head Pakistan: operational requirements for payment channel integrations.
  • Global CFO: technology budget and infrastructure cost management.

Reporting Line

Reports to the Chief Executive Officer.


6.1.8 Chief Revenue Officer / Head of Business - Shahroze Khan

Purpose

The Chief Revenue Officer (CRO) is responsible for driving the commercial performance of the Simpaisa Group - building the merchant and partner portfolio, developing strategic partnerships, and executing the go-to-market strategy across all products and geographies. With 10+ years of experience including UBL Innovation and Ricoh UK (IoT and Digital Transformation), the CRO leads business development, key account management, strategic alliances, and revenue growth, ensuring that Simpaisa achieves its commercial targets and builds a defensible, diversified revenue base.

Key Accountabilities

  • Own the Group's total revenue target and drive revenue growth across all product lines (Pay-Ins, Pay-Outs, Remittances, Crypto Off-Ramp, White-Label Wallets) and geographies.
  • Lead and manage the business development function: identify, pursue, and close new merchant, partner, and institutional client relationships across all active and expansion markets.
  • Own key account management: maintain and deepen relationships with Tier A merchants and partners, ensuring retention, volume growth, and expansion of product usage.
  • Develop and execute the Group's go-to-market strategy for each product and market, in coordination with the CPO, CSNO, and Country Heads.
  • Own strategic partnerships: identify and negotiate partnerships with banks, mobile money operators, MNCs, gig economy platforms, and B2B clients that create distribution, integration, or volume advantages.
  • Build and manage the Business Intelligence (BI) function: deliver commercial insights, competitor analysis, corridor performance data, and market sizing to support commercial and strategic decisions.
  • Own the Growth and Governance function within the CRO organisation - operationalising commercial governance, pipeline reporting, and revenue forecasting.
  • Ensure that commercial agreements (Merchant Payment Service Agreements, Service Addenda, country addenda, Remittance Agreements) are commercially sound, properly documented, and executed in coordination with Legal.
  • Collaborate with the CPO on product requirements emerging from market and client feedback.
  • Support the CSNO in operationalising the Group's corridor activation and market expansion strategy from a commercial perspective.
  • Represent Simpaisa at industry events, conferences, and regulatory/commercial forums to build market presence and brand authority.
  • Manage the sales pipeline, forecasting, and CRM discipline; report commercial performance to the CEO and Board.

Key Performance Indicators

KPI Target / Threshold
Total revenue vs. budget Per Board-approved plan
Total Payment Volume (TPV) by product and corridor Per Board-approved plan
New merchant/partner accounts signed (quarterly) Per commercial plan
Tier A merchant revenue retention ≥95% annually
Revenue per corridor (top 5 corridors) Improving trajectory
Pipeline conversion rate ≥25% (qualified pipeline to signed)
Time to first transaction (new merchant) ≤30 days from agreement signing
White-Label Wallet client pipeline Per roadmap targets

Decision Authority

  • Authority to approve commercial terms within delegated pricing parameters (per DoA).
  • Authority to approve standard Merchant Payment Service Agreements within defined limits.
  • Authority to approve CRM, sales tooling, and commercial team expenditure within budget.
  • Recommends to the CEO any strategic partnership agreements, non-standard commercial terms, or contracts above DoA thresholds.

Critical Interdependencies

  • CEO: strategic partnerships, large-scale commercial agreements, and market entry decisions.
  • CSNO: commercial performance management and corridor activation.
  • CPO: product features and merchant onboarding experience.
  • Country Head Pakistan: Pakistan commercial pipeline and operational support.
  • Country Head Bangladesh and Nepal: in-market commercial execution.
  • Payment Channel Partnerships: channel availability and SLA performance (directly impacts commercial delivery).
  • Head of Legal: contract review and execution.
  • Global CFO: revenue reporting, pricing models, and commercial financial analysis.

Reporting Line

Reports to the Chief Executive Officer.


6.1.9 Country Head Pakistan - Noor Ali

Purpose

The Country Head Pakistan is responsible for the day-to-day operational integrity of Simpaisa's payment operations, with direct accountability for Pakistan as the Group's most established and largest-volume market. Noor Ali ensures that all payment transactions are processed, settled, and reconciled accurately and on time; that payment channel relationships are maintained to agreed SLAs; and that merchant and partner support functions operate effectively.

Key Accountabilities

  • Own end-to-end payment operations for the Pakistan market, covering all active payment rails: Easypaisa, JazzCash, HBL Konnect, Alfa, Mobilink/Telenor/Ufone/Zong (Direct Carrier Billing), OTC (Over-the-Counter), IBFT (1LINK), and card processing.
  • Oversee the settlements function: manage daily settlement cycles, ensure accurate net/gross settlement execution, and resolve settlement exceptions in a timely manner.
  • Own three-way reconciliation processes: internal ledger versus partner/bank statements versus client records - ensuring break identification and resolution within SLAs.
  • Manage partner support: maintain operational relationships with all payment channel partners in Pakistan, manage escalations, and ensure SLAs are met.
  • Manage merchant support: handle operational queries, complaints, and escalations from merchants and clients in coordination with the Service Delivery function.
  • Provide operational oversight of payment channel performance: monitor uptime, success rates, error rates, and latency across all active Pakistan channels.
  • Coordinate with the Head of Settlements and the CSNO on float management, pre-funding requirements, and liquidity for Pakistan payment operations.
  • Ensure operational compliance with SBP regulations, the SBP Schedule H framework, Branchless Banking Agency guidelines, and applicable AML/CFT controls.
  • Contribute to new payment channel onboarding from an operational readiness perspective: participate in integration testing, UAT, and go-live sign-off.
  • Represent Pakistan operations at the ELT level; provide monthly country performance reports to the CSNO and CEO.
  • Manage the Pakistan operations team: Settlements, Reconciliation, Partner Support, and Merchant Support functions.

Key Performance Indicators

KPI Target / Threshold
Payment success rate - Pakistan (Pay-Ins) ≥98%
Payment success rate - Pakistan (Pay-Outs) ≥97%
Settlement cycle adherence (on-time) ≥99% of settlement cycles
Reconciliation break resolution time ≤24 hours (standard); ≤4 hours (critical)
Merchant support ticket resolution (SLA) ≥95% within agreed SLA
Partner SLA compliance (uptime / availability) Per channel-specific SLA thresholds
Operational incident escalation time ≤1 hour for critical; ≤4 hours for major

Decision Authority

  • Authority to approve operational decisions relating to Pakistan payment channel management.
  • Authority to approve settlement and reconciliation process decisions within operational parameters.
  • Authority to escalate and direct partner support activities and SLA remediation.
  • Recommends to the CSNO and CEO any operational changes requiring commercial or strategic decisions.

Critical Interdependencies

  • CSNO: operational performance reporting and strategic alignment.
  • CPO: payment operations requirements in product development.
  • Payment Channel Partnerships (Ahsan Hussain): channel onboarding, SLA management, and relationship escalations.
  • Head of Settlements: settlement operations and reconciliation management.
  • Global CFO / Head of Treasury: pre-funding, float management, and financial reconciliation.
  • Global Head of Regulatory Affairs: SBP regulatory compliance for Pakistan operations.
  • CISO: security requirements for payment operations.

Reporting Line

Reports to the Chief Executive Officer.


6.1.10 Country Head Bangladesh and Nepal - Sanjana Farid

Purpose

The Country Head Bangladesh and Nepal is responsible for the full operational, regulatory, commercial, and financial management of Simpaisa's Bangladesh and Nepal businesses. This role manages two distinct but operationally related markets, overseeing the Simpoysha BD / Soft Tech Innovation (aamarPay) entities in Bangladesh and the Pay Nest entity in Nepal, driving local growth, regulatory compliance, and operational excellence in close coordination with functional heads at Group level.

Key Accountabilities

  • Provide overall leadership and accountability for Simpaisa's business in Bangladesh and Nepal - covering commercial performance, operational delivery, regulatory compliance, and organisational management.
  • Manage the Bangladesh entity operations: Pay-Ins via aamarPay's PSO licence (bKash, Nagad, Rocket, Upay, Tap Pay, OK Wallet, cards, OTC), Pay-Outs (mobile wallets, NPSB/BEFTN bank transfers, EMI), and Remittances.
  • Manage the Nepal entity operations: PSP integrations via Pay Nest with Khalti, e-Sewa, IME Pay, and Paywell.
  • Oversee and develop the Deputy Country Managers for Bangladesh (Faruk Kaysar) and Nepal (Shailendra Joshi), providing direction, mentorship, and performance management.
  • Own treasury management for the Bangladesh entity: manage BDT liquidity, pre-funding positions, FX management, and bank account operations in coordination with the Group Head of Treasury.
  • Own reconciliation processes for both markets: ensure three-way reconciliation is accurate, timely, and that breaks are resolved within SLAs.
  • Manage local legal matters: oversee the country legal function (in coordination with the Head of Legal at Group level), local regulatory submissions, and contractual matters.
  • Maintain and develop relationships with local regulatory authorities: Bangladesh Bank, Bangladesh Financial Intelligence Unit (BFIU), and Nepal Rastra Bank (NRB).
  • Manage local banking and payment partner relationships across both markets.
  • Oversee the NPR 150M/250M capital requirement for Pay Nest (Nepal) and manage compliance with NRB's PSP framework requirements.
  • Identify and evaluate local M&A or investment opportunities (e.g., PSO licence acquisition in Nepal) in coordination with the CEO and COO.
  • Provide regular country performance reports to the CSNO and CEO; represent Bangladesh and Nepal at ELT forums.

Key Performance Indicators

KPI Target / Threshold
Payment success rate - Bangladesh (Pay-Ins) ≥98%
Payment success rate - Bangladesh (Pay-Outs) ≥97%
TPV growth - Bangladesh and Nepal (year-on-year) Per Board-approved plan
Settlement and reconciliation adherence ≥99% on-time settlement cycles
Regulatory reporting compliance (BD and NP) 100% of filings submitted on time
BDT treasury / pre-funding adequacy Zero settlement failures due to liquidity
Deputy CM performance vs. objectives Annual review

Decision Authority

  • Authority to approve operational decisions within Bangladesh and Nepal.
  • Authority to approve local vendor and partner contracts within DoA thresholds.
  • Authority to manage and direct the Deputy Country Managers and local operations teams.
  • Recommends to the CEO and CSNO any strategic decisions, licence applications, M&A activity, or commercial agreements above DoA thresholds.

Critical Interdependencies

  • CSNO: operational performance management and strategic alignment.
  • Global CFO / Head of Treasury: treasury, pre-funding, and financial reporting for BD/NP entities.
  • Global Head of Regulatory Affairs: regulatory strategy and central bank relationships.
  • CPO: product requirements and integration roadmap for BD/NP channels.
  • CRO: commercial pipeline and go-to-market for BD/NP.
  • Head of Legal: country legal and entity compliance.
  • Payment Channel Partnerships: channel onboarding and SLA management for BD/NP channels.

Reporting Line

Reports to the Chief Executive Officer. Functionally aligned with the CSNO for operational performance management.


6.1.11 Global Head of Regulatory Affairs - Shoukat Bizinjo

Purpose

The Global Head of Regulatory Affairs is the Group's most senior regulatory expert and is responsible for all aspects of the Group's regulatory strategy, licensing programme, compliance policy framework, and engagement with payment system regulators across all active and target jurisdictions. With 25+ years of experience at the State Bank of Pakistan - including as Director of Payment Systems and Digital Financial Services - the Global Head of Regulatory Affairs brings unparalleled understanding of regulatory environments in frontier payment markets and leads the Group's efforts to build and maintain a robust regulatory moat across its operating footprint.

Key Accountabilities

  • Own the Group's global licensing strategy and licence acquisition roadmap: EMI (Pakistan), PSO/PSP (Pakistan own licence), DFSA Category 3D (UAE/DIFC), PSO (Nepal), SAMA Major PI (Saudi Arabia), Payment Organisation (Kazakhstan), and all future licence applications.
  • Lead and manage all regulatory engagement across every jurisdiction in which the Group operates or plans to operate - including SBP, Bangladesh Bank, NRB, CBI, DFSA, MAS, FINTRAC, HMRC, SAMA, and Central Asian regulators.
  • Develop and maintain the Group's regulatory compliance framework: group-level regulatory policy architecture, jurisdiction-specific addenda, and annual compliance framework reviews.
  • Own the Group's sanctions compliance programme at a policy and framework level - ensuring alignment with OFAC, UN, EU, UK, and local sanctions regimes across all jurisdictions; working with the CISO and operations teams on the Eastnets screening platform.
  • Monitor regulatory developments globally - new payment regulations, AML/CFT updates, FATF recommendations, VASP licensing requirements, and central bank policy changes - and assess their impact on the Group's business model and operations.
  • Develop and manage the Group's market entry regulatory playbook: standardised process for regulatory assessment, pre-application engagement, licence application preparation, and post-licence operational compliance.
  • Advise the CEO, COO, and Board on regulatory risk, regulatory strategy, and the Group's licence-to-operate across all markets.
  • Lead preparation of all regulatory submissions, licence applications, renewal filings, and regulatory reporting across all entities and jurisdictions - in coordination with Country Heads and the Head of Legal.
  • Manage relationships with external regulatory counsel in key jurisdictions.
  • Represent the Group at regulatory consultations, industry associations, and policy forums - building Simpaisa's reputation as a credible, compliant, and constructive regulated entity.
  • Provide regulatory affairs updates to the Board Compliance and Regulatory Committee.
  • Ensure that fit-and-proper requirements for appointed regulatory roles (e.g., DFSA SEO, MLRO, Compliance Officer) are met and documented.

Key Performance Indicators

KPI Target / Threshold
Licence acquisition - milestones achieved on time Per Licence Acquisition Roadmap (Section 11.4)
Regulatory reporting - all jurisdictions 100% submitted on time and without material error
Licence renewal - zero lapses 100% (no licence lapses or suspensions)
Regulatory enquiries / examinations - resolved ≤30 days for standard; escalation within 48 hours
Sanctions policy - annual review completed 100% on schedule
New market regulatory assessment completed ≤45 days from market entry decision
Regulatory incident escalations to Board As required; zero unplanned regulatory surprises

Decision Authority

  • Authority to approve all regulatory submissions and licence applications (prior to CEO co-sign where required).
  • Authority to approve the Group's regulatory compliance framework and sanctions policy.
  • Authority to engage directly with regulators at all levels on behalf of the Group.
  • Authority to impose regulatory holds or operational restrictions where regulatory risk demands immediate action.
  • Recommends to the CEO and Board all material regulatory strategy decisions, licence investments, and regulatory risk positions.

Critical Interdependencies

  • CEO: regulatory strategy alignment and central bank relationship management.
  • COO: governance framework and entity structuring for new markets.
  • Country Heads: local regulatory relationships and country-level compliance.
  • Head of Legal: regulatory submissions, contractual regulatory requirements, and legal risk.
  • Global CFO: regulatory capital requirements and licence fee budgeting.
  • CISO: sanctions screening technology and data protection regulatory compliance.
  • CPO: regulatory requirements in product design (particularly for VASP / crypto, EMI, and cross-border remittance products).

Reporting Line

Reports to the Chief Executive Officer. Functional accountability to the Board Compliance and Regulatory Committee.


6.1.12 Payment Channel Partnerships - Ahsan Hussain

Purpose

The Head of Payment Channel Partnerships is responsible for building, managing, and optimising Simpaisa's network of payment channel partners - including banks, mobile money operators (MMOs), and Over-the-Counter (OTC) networks - across all active geographies. This role ensures that the Group's payment channels are commercially sound, technically integrated, operationally stable, and managed to agreed Service Level Agreements, providing the connectivity infrastructure upon which all Simpaisa products depend.

Key Accountabilities

  • Own and manage all bank partner relationships across Pakistan, Bangladesh, Nepal, Iraq, UAE, and expansion markets - including correspondent banks, local settlement banks, and acquiring banks.
  • Own and manage all mobile money operator (MMO) partnerships: Easypaisa, JazzCash, HBL Konnect, Alfa, bKash, Nagad, Rocket, Upay, Tap Pay, OK Wallet, Khalti, e-Sewa, IME Pay, Paywell, and any future MMO integrations.
  • Own and manage the OTC (Over-the-Counter) agent network across Pakistan, Bangladesh, and Nepal - including branchless banking agent relationships.
  • Own payment channel integration management: oversee the technical integration of new payment channels in coordination with the CTO and CPO; manage integration timelines, API documentation, and UAT sign-off.
  • Negotiate and manage commercial agreements with payment channel partners: pricing, revenue share, SLAs, exclusivity provisions, and renewal terms.
  • Own channel SLA management: monitor uptime, transaction success rates, error rates, and response times for all payment channels; manage escalations with partners when SLAs are breached.
  • Identify and develop new payment channel partnerships that expand the Group's reach, reduce concentration risk, or improve commercial terms.
  • Provide channel performance reporting to the CSNO, Country Head Pakistan, and Country Heads on a regular cadence.
  • Support the Country Head Pakistan with operational payment channel issues requiring partner engagement.
  • Manage the due diligence, onboarding, and third-party risk assessment of new payment channel partners in coordination with Compliance and Legal.

Key Performance Indicators

KPI Target / Threshold
Payment channel uptime (all active channels) ≥99.5% per channel per month
Channel success rate (transactions processed) Per corridor and channel targets
New channel integration - time to live ≤30 days (standard); ≤60 days (complex)
SLA breach resolution time ≤24 hours for critical; ≤72 hours for major
Contract renewal completion ≥90 days before expiry
Channel concentration risk (top 3 channels) No single channel >30% of total TPV
Partner onboarding due diligence completion 100% prior to go-live

Decision Authority

  • Authority to approve channel SLA escalations and partner remediation plans.
  • Authority to approve standard channel partnership agreements within DoA thresholds.
  • Authority to manage day-to-day commercial and operational channel relationships.
  • Recommends to the CEO and CSNO any new strategic channel partnerships, exclusivity arrangements, or contracts above DoA thresholds.

Critical Interdependencies

  • CSNO: channel network strategy and operational performance management.
  • Country Head Pakistan: Pakistan channel operations and escalations.
  • Country Head Bangladesh and Nepal: BD/NP channel operations and escalations.
  • CTO: technical integration of payment channels.
  • CPO: channel requirements for product roadmap.
  • Global CFO / Head of Treasury: pre-funding and float management tied to channel settlement.
  • Global Head of Regulatory Affairs: regulatory requirements for channel partnerships.
  • Head of Legal: channel agreement review and execution.

Reporting Line

Reports to the Chief Strategy and Network Officer.


6.2 Senior Management Role Profiles

Senior management roles are documented in a shorter format: Purpose | Key Accountabilities | Reports To.


6.2.1 Head of Treasury

Purpose Responsible for all day-to-day treasury operations across the Group, including multi-currency cash management, pre-funding of payment corridors, FX management, bank account operations, and client funds safeguarding compliance.

Key Accountabilities - Manage the Group's multi-entity, multi-currency bank account structure; execute daily funding and payment runs. - Own cash flow forecasting and liquidity management - ensuring sufficient pre-funded balances across all active payment corridors at all times. - Manage FX exposure for frontier currency pairs (USD/PKR, USD/BDT, USD/NPR, USD/IQD): execute FX transactions, monitor mark-to-market positions, and manage within Board-approved risk appetite. - Operate and maintain the client funds safeguarding arrangements per the Group Client Funds Safeguarding Policy and applicable regulatory requirements. - Support the Global CFO with month-end treasury reconciliations, intercompany settlements, and financial close processes. - Manage banking relationships at an operational level; coordinate with the Global CFO on strategic banking strategy. - Provide daily treasury position reports to the Global CFO and Country Heads as required. - Support the Global CFO in fundraising processes by providing treasury data room materials and cash position analyses.

Reports To: Global Chief Financial Officer.


Purpose Responsible for managing the Group's legal function, including contract management, entity corporate governance, employment law, intellectual property, and legal risk management across all jurisdictions, ensuring the Group's legal exposure is identified, managed, and mitigated.

Key Accountabilities - Draft, review, and negotiate all material Group contracts: Merchant Payment Service Agreements (MPSAs), Service Addenda, Country Addenda, Remittance Agreements, partnership agreements, and supplier contracts. - Manage entity-level corporate governance: maintain statutory records, manage filing obligations, and support the Corporate Secretary function across all Group entities. - Manage employment law matters across all jurisdictions: employment contracts, disciplinary processes, terminations, and local employment law compliance. - Manage intellectual property: trade marks, software ownership, and IP assignment agreements. - Provide legal advice to the CEO, COO, and ELT on material legal risks, contract disputes, and regulatory matters. - Manage relationships with external legal counsel across all jurisdictions (Pakistan, Bangladesh, Nepal, UAE, Singapore, Canada, UK). - Support the Global Head of Regulatory Affairs with regulatory submissions requiring legal review. - Manage the Group's data protection obligations from a legal perspective, in coordination with the CISO.

Reports To: Chief Operating Officer. Dotted line to Global Head of Regulatory Affairs for regulatory submissions.


6.2.3 Head of HR

Purpose Responsible for all human resources operations across the Group, including employee lifecycle management, compensation and benefits, performance management, learning and development, HR policy, and people analytics.

Key Accountabilities

# Accountability Area Key Responsibilities
1 Employee Lifecycle Manage the full employee lifecycle: onboarding, probation management, performance reviews, salary reviews, promotions, and offboarding
2 HR Policies and Compliance Maintain HR policies, employment contracts, and staff handbooks for each jurisdiction, ensuring local employment law compliance (Pakistan, Bangladesh, Nepal, UAE, Singapore, Canada, UK)
3 Compensation and Benefits Own the compensation and benefits framework: manage payroll processes (by entity), benefits administration, and leave management
4 Performance Management Manage the annual and mid-year performance management cycle, providing tools, training, and support to line managers
5 Learning and Development Develop and deliver learning and development programmes aligned with the Group's capability needs and individual development plans
6 Culture and Engagement Manage the Group's culture and engagement programmes: employee surveys, action planning, and DEI (Diversity, Equity, and Inclusion) initiatives
7 Organisational Design Partner with the COO and functional heads on organisational design, job evaluation, and workforce planning
8 Regulatory Compliance Ensure fit-and-proper assessment processes are maintained for regulated roles
9 People Analytics Manage HR information systems and provide people analytics reporting to the COO and CEO

Reports To: Chief Operating Officer.


6.2.4 Head of Global Recruitment

Purpose Responsible for delivering the Group's talent acquisition strategy across all geographies and functions, ensuring a consistent, efficient, and high-quality recruitment process that scales with the Group's growth ambitions.

Key Accountabilities - Own the end-to-end recruitment process for all permanent and contract hires across the Group, from vacancy approval through to offer acceptance. - Develop and maintain a talent pipeline for critical and hard-to-fill roles (senior technology, compliance, and regulatory skills). - Manage recruitment channels: direct sourcing, job boards, recruitment agencies, referrals, and university partnerships. - Build employer branding initiatives to position Simpaisa as an employer of choice in target talent markets (Pakistan, Bangladesh, UAE, and MENA). - Manage recruitment vendor relationships and agency PSL (Preferred Supplier List). - Deliver recruitment reporting and analytics to the COO: time to hire, cost per hire, pipeline conversion, diversity metrics. - Ensure all candidates undergo appropriate pre-employment screening (background checks, reference checks, and fit-and-proper verification for regulated roles). - Partner with the Head of HR on onboarding to ensure a seamless new-hire experience.

Reports To: Chief Operating Officer. Closely aligned with Head of HR.


6.2.5 Head of DevOps and Infrastructure

Purpose Responsible for the Group's DevOps practices, CI/CD pipeline, cloud infrastructure, and systems administration - ensuring reliable, automated, and scalable delivery of the Simpaisa platform on AWS.

Key Accountabilities - Own and manage the Group's AWS infrastructure: EC2, VPC, ALB/NLB, CloudFront, NAT Gateway, Parameter Store, Certificate Manager, Autoscaling, SNS, Kafka (messaging), and Redis (caching). - Manage the CI/CD pipeline: Jenkins, Terraform, Ansible - ensuring automated build, test, and deployment workflows are reliable, secure, and efficient. - Lead the DevOps team (approximately 9 engineers including Database Administrators): define team standards, tooling, and operational practices. - Manage infrastructure-as-code: maintain Terraform and Ansible codebases for all production and non-production environments. - Own infrastructure monitoring and alerting: Datadog, Amazon CloudWatch - in coordination with the Lead NOC and System Administration. - Manage database administration: MySQL, PostgreSQL, MongoDB, and Amazon DocumentDB - ensuring availability, performance, backup, and recovery procedures. - Drive infrastructure cost optimisation: right-sizing, reserved instances, and cloud cost management. - Partner with the CISO on cloud security controls and DevSecOps practices. - Manage disaster recovery (DR) infrastructure and participate in DR testing exercises.

Reports To: Chief Technology Officer.


6.2.6 Head of SQA and Software Delivery

Purpose Responsible for the Group's software quality assurance programme and software delivery processes, ensuring that all releases meet quality standards, are thoroughly tested, and are delivered through a well-governed release management process.

Key Accountabilities - Lead and manage the SQA team (approximately 7 engineers) across automation and manual testing disciplines. - Define and maintain the Group's test strategy, test standards, and quality gates for all software releases. - Own automated testing frameworks: REST Assured (API testing), Gatling and JMeter (performance and load testing), Playwright (UI automation), Appium (mobile testing). - Own manual testing practices for exploratory, regression, and UAT processes. - Manage the release management process: co-ordinate release readiness with development team leads, manage release calendars, and ensure sign-off gates are enforced. - Define and track quality metrics: defect density, defect escape rate, test coverage, and automation coverage. - Manage the defect management lifecycle: defect logging, triage, prioritisation, and resolution tracking. - Partner with the CPO and development leads on Agile ceremonies: sprint reviews, release planning, and retrospectives. - Ensure PCI DSS and ISO 27001 quality and security testing requirements are incorporated into the test programme.

Reports To: Chief Technology Officer.


6.2.7 Head of Development - Pay-Ins (Collections)

Purpose Responsible for leading the Collections (Pay-Ins) development team, delivering all software engineering work related to the pay-in payment flows - from API integration through to transaction processing, payment method support, and settlement interfaces.

Key Accountabilities - Lead, manage, and develop the Collections development team (approximately 6 developers). - Own the technical delivery of all Pay-Ins product features: payment method integrations (mobile wallets, DCB, IBFT, OTC, cards), payment gateway APIs, and transaction processing logic. - Translate product requirements (from CPO and Product Managers) into technical specifications, sprint backlogs, and engineering tasks. - Ensure code quality: conduct or oversee code reviews, enforce engineering standards, and manage technical debt within the Collections codebase. - Collaborate with the Principal Architect on architectural decisions affecting the Collections platform. - Work with the Integration Lead on new payment channel onboarding from a technical perspective. - Partner with the SQA team on test coverage and defect resolution for the Collections domain. - Participate in Agile ceremonies: sprint planning, daily stand-ups, sprint reviews, and retrospectives.

Reports To: Chief Technology Officer.


6.2.8 Development Manager - Pay-Outs (Disbursements)

Purpose Responsible for leading the Disbursements (Pay-Outs) development team, delivering all software engineering work related to pay-out payment flows - including mobile wallet disbursements, bank transfers, IBFT push, and OTC disbursement rails.

Key Accountabilities - Lead, manage, and develop the Disbursements development team (approximately 7 developers). - Own the technical delivery of all Pay-Outs product features: disbursement engine, mobile wallet integrations, NPSB/BEFTN (Bangladesh), IBFT push (Pakistan), PSP integrations (Nepal), and OTC network connectivity. - Translate product requirements into technical specifications and sprint backlogs. - Ensure code quality and engineering standards are maintained across the Disbursements codebase. - Collaborate with the Principal Architect on architectural decisions and with the Integration Lead on channel integrations. - Partner with the Head of SQA and SD on testing strategy and defect management for the Disbursements domain. - Support the Country Head Pakistan and operational teams in diagnosing and resolving production issues related to disbursements.

Reports To: Chief Technology Officer.


6.2.9 Development Manager - Portal

Purpose Responsible for leading the Portal development team, delivering and maintaining the Simpaisa Merchant Portal - the primary self-service interface for merchants, partners, and internal operations teams.

Key Accountabilities - Lead, manage, and develop the Portal development team (approximately 7 developers). - Own the technical delivery of all Portal features: merchant dashboard, transaction reporting, KYB/merchant onboarding workflows, account management, reconciliation views, and API key management. - Translate CPO and Product Manager requirements into engineering specifications and sprint deliverables. - Ensure the Portal meets UX quality standards, performance benchmarks, and PCI DSS / ISO 27001 security requirements. - Manage front-end and back-end Portal architecture in coordination with the Principal Architect. - Partner with the Head of SQA and SD on Portal-specific test plans and quality gates. - Work with the CPO on continuous improvement of the merchant onboarding automation (KYB) workflow within the Portal.

Reports To: Chief Technology Officer.


6.2.10 Information Security Manager

Purpose Responsible for the day-to-day operational management of the Group's information security programme, including ISMS operations, PCI DSS control management, vulnerability management, security incident management, and security policy administration - supporting the CISO in all aspects of the security function.

Key Accountabilities - Manage the operational elements of the Group's ISO 27001 ISMS: risk assessments, control monitoring, Statement of Applicability maintenance, and audit preparation. - Manage PCI DSS operational controls: cardholder data environment (CDE) scoping, control testing, evidence collection, and QSA liaison. - Operate the vulnerability management programme: asset scanning, vulnerability triage, remediation tracking (with SLA enforcement), and reporting to the CISO. - Manage information security policies and procedures: annual review cycles, exception management, and employee communications. - Coordinate security awareness and training programme delivery. - Manage identity and access management (IAM) governance: access reviews, privileged access management, and joiners/movers/leavers processes. - Support the CISO in managing the data protection programme by jurisdiction. - Assist in security incident management: triage, containment, investigation, and post-incident review documentation.

Reports To: Chief Information and Security Officer.


6.2.11 Principal Architect

Purpose Responsible for the overall technical architecture of the Simpaisa platform - defining architectural principles, standards, and patterns that guide all engineering teams; ensuring the platform is scalable, resilient, maintainable, and aligned with the Group's long-term technology strategy.

Key Accountabilities - Define and maintain the Group's technology architecture: platform design, microservices architecture, API design standards, data architecture, and integration architecture. - Review and approve all architectural decisions made by development team leads; maintain an Architecture Decision Record (ADR). - Lead the API management and integration architecture: defining standards for internal and external API design, versioning, documentation, and security. - Evaluate and recommend new technologies, frameworks, and architectural patterns for adoption. - Partner with the CISO on security-by-design architectural principles. - Provide architectural guidance and review for all major new features, product integrations, and platform changes. - Work with the Application Architect (Laique Ali) on domain-specific architecture for individual product components. - Contribute to the Group's technology roadmap from an architectural perspective. - Represent the architecture function in Agile ceremonies: sprint reviews and architecture governance reviews.

Reports To: Chief Technology Officer.


6.2.12 Lead NOC and System Administration

Purpose Responsible for managing the Group's Network Operations Centre (NOC) and system administration functions - ensuring 24/7 monitoring of all production systems, rapid incident detection and escalation, and reliable IT infrastructure operations.

Key Accountabilities - Manage the NOC team (NOC/SOC Associates, NOC Engineer, and IT Help Desk - approximately 7 staff). - Own 24/7 system monitoring using Datadog, Amazon CloudWatch, and CyGlass: configure alerting thresholds, escalation rules, and on-call rotas. - Manage system administration: server patching, configuration management, access provisioning, and infrastructure health checks. - Own the incident management process for infrastructure and system incidents: detection, triage, escalation to development/DevOps teams, and resolution tracking. - Manage IT Help Desk operations: end-user computing support, device management, software licensing, and VPN/access management. - Maintain system administration documentation: runbooks, SOPs, network diagrams, and asset registers. - Partner with the CISO and Information Security Manager on security event monitoring and SOC escalations. - Report infrastructure performance and incident metrics to the CTO and CISO.

Reports To: Chief Technology Officer. Functionally aligned with the CISO for SOC and security monitoring activities.


6.2.13 PMO Manager

Purpose Responsible for managing the Group's Project Management Office - establishing and maintaining project governance standards, portfolio visibility, and delivery assurance across all concurrent technology, product, and business change initiatives.

Key Accountabilities - Define and maintain the Group's project management framework: project initiation, planning, tracking, change control, risk management, and closure standards. - Maintain the Group's programme and project portfolio view: track all in-flight initiatives, highlight dependencies, identify risks, and report status to the CPO and CSNO. - Manage the PMO governance cadence: project review meetings, steering committee packs, and status reports. - Support Project Managers in adopting and applying the PMO framework consistently. - Own the programme-level risk and issues log; escalate material risks to the CPO and ELT. - Maintain a resource capacity view across all projects; raise capacity conflicts for resolution. - Drive continuous improvement in project delivery practices across the organisation. - Support the CPO in producing the product roadmap update for Board and investor audiences.

Reports To: Chief Product Officer.


6.2.14 Head of Settlements

Purpose Responsible for the Group's settlements operations - managing daily settlement cycles, reconciliation processes, break management, and settlement partner relationships - ensuring that all financial obligations to and from merchants, partners, and payment channels are discharged accurately and on time.

Key Accountabilities - Own all settlement operations across Pakistan, Bangladesh, and Nepal: manage daily net/gross settlement cycles for all active payment rails. - Manage three-way reconciliation: internal ledger versus partner/bank statements versus client records - across all active corridors and payment channels. - Own break management: identify, investigate, and resolve reconciliation breaks within SLAs; maintain an exceptions log with root-cause analysis. - Manage settlement partner relationships at an operational level - coordinate with payment channel partners and correspondent banks on settlement queries, discrepancies, and timing issues. - Produce daily settlement and reconciliation reports for the Country Head Pakistan and Global CFO. - Coordinate with the Head of Treasury on pre-funding requirements based on settlement cycle positions. - Maintain settlement SOPs for each active corridor and payment channel; update for any changes to settlement arrangements. - Support regulatory and audit requirements related to settlement and reconciliation - providing evidence, records, and explanations as required.

Reports To: Country Head Pakistan. Dotted line to Global Chief Financial Officer for financial reporting.


6.2.15 Head of Growth and Governance

Purpose Responsible for driving the Group's operational governance readiness and commercial growth enablement - building the institutional infrastructure, documentation, and frameworks that support institutional investor due diligence, regulatory governance requirements, and accelerated commercial growth.

Key Accountabilities - Develop and maintain Group-level governance documentation: operating model artefacts, policy registers, governance matrices, and board reporting templates. - Lead regulatory readiness projects: prepare the organisation for DFSA application, MAS requirements, SAMA onboarding, and institutional investor due diligence. - Own the Group's business development governance: pipeline reporting standards, CRM governance, and commercial KPI frameworks for the CRO organisation. - Support the CSNO with the Strategic Planning Process artefacts, OKR frameworks, and executive reporting packs. - Manage the Group's corporate calendar: board meeting schedules, AGM preparations, regulatory reporting calendars, and audit cycles. - Develop governance training and awareness programmes for senior managers. - Identify and close gaps in the Group's governance framework in advance of regulatory applications and investor processes. - Support the COO with operational governance projects and institutionalisation initiatives.

Reports To: Chief Operating Officer. Functionally aligned with CSNO on strategic planning deliverables.


6.2.16 Brand Manager / Head of Marketing

Purpose Responsible for building and managing Simpaisa's brand and marketing function - developing brand strategy, managing digital and physical brand assets, producing B2B marketing materials, and supporting commercial and regulatory credibility through consistent, professional external communications.

Key Accountabilities - Define and manage the Simpaisa Group brand identity: brand guidelines, visual identity, tone of voice, and brand architecture across all entities. - Develop and execute B2B marketing strategies to support the CRO's commercial pipeline: industry events, digital marketing, thought leadership, case studies, and partner marketing materials. - Manage the Group's digital presence: website, LinkedIn, and other relevant channels - ensuring content is current, accurate, and consistent with brand guidelines. - Produce marketing collateral for product launches, new market entries, and commercial development - including pitch decks, brochures, and white papers. - Support investor relations communications from a brand and presentation quality perspective. - Manage PR and media relations where appropriate; build Simpaisa's profile in the fintech and cross-border payments press. - Manage marketing budget and vendor relationships (design agencies, content producers, event organisers). - Align marketing activities with regulatory sensitivity in relevant markets (particularly Islamic-majority markets: Pakistan, Bangladesh, Iraq, Saudi Arabia).

Reports To: Chief Operating Officer. Closely aligned with CRO for commercial marketing activities.


6.3 Middle Management and Specialist Roles

The following table defines the role families for middle management and specialist individual contributors. These roles are typically positioned between senior management and individual contributor levels.


6.3.1 Role Family Table - Team Leads

Role Title Function Key Responsibilities Reports To
Portal Development Lead Technology - Portal Technical leadership of Portal team; code review; sprint delivery; mentoring junior developers; architectural alignment. Development Manager (Portal)
Pay-Ins (Collections) Lead Developer Technology - Collections Technical lead for Pay-Ins development stream; code review; integration design; delivery ownership for Collections features. Head of Development (Pay-Ins)
Pay-Outs (Disbursements) Lead Developer Technology - Disbursements Technical lead for Pay-Outs development stream; code review; integration design; delivery ownership for Disbursements features. Development Manager (Pay-Outs)
DevOps Lead Technology - DevOps Lead DevOps engineer; CI/CD pipeline management; infrastructure-as-code development; mentoring junior DevOps engineers. Head of DevOps and Infrastructure
SQA Lead Technology - SQA Lead quality assurance engineer; define and manage test plans; automation framework maintenance; defect triage. Head of SQA and Software Delivery
NOC Lead / System Administration Lead Technology - NOC Shift lead for NOC operations; monitoring alert management; incident escalation; system administration oversight. Lead NOC and System Administration

6.3.2 Role Family Table - Product Managers and Product Owners

Role Title Function Key Responsibilities Reports To
Product Manager - Pay-Ins Product Own Pay-Ins product backlog; write user stories; manage merchant requirements; track product KPIs; facilitate Agile ceremonies for Collections domain. Chief Product Officer
Product Manager - Pay-Outs Product Own Pay-Outs product backlog; write user stories; manage disbursement product requirements; track Pay-Outs KPIs. Chief Product Officer
Product Manager - Remittances Product Own Remittances product definition; corridor requirements; FX product features; regulatory product requirements for remittance corridors. Chief Product Officer
Product Manager - Wallet and Crypto Product Own White-Label Wallet and Crypto Off-Ramp product backlog; define feature specifications; manage VASP product requirements. Chief Product Officer
Product Owner - Portal Product Own Merchant Portal backlog; merchant experience requirements; KYB workflow features; internal ops portal features. Chief Product Officer / Development Manager (Portal)

6.3.3 Role Family Table - Project Managers

Role Title Function Key Responsibilities Reports To
Project Manager (Technology Delivery) Technology / PMO Manage technology delivery projects: scope, schedule, risk, dependencies, and stakeholder communications. Facilitate Agile ceremonies. PMO Manager
Project Manager (Business Change) PMO / Operations Manage business change projects: market entry, product launches, compliance programmes, and operational restructuring. PMO Manager
Project Manager (Integrations) Product / Technology Manage the end-to-end lifecycle of payment channel and merchant integration projects: timeline, technical co-ordination, UAT, go-live. PMO Manager / Integration Lead

6.3.4 Integration Lead

Role Title Function Key Responsibilities Reports To
Integration Lead Product / Technology Own the technical integration process for new payment channels, merchants, and white-label clients; define integration standards and API onboarding playbooks; manage integration project pipeline; co-ordinate between CPO, CTO, and commercial teams on integration delivery. Chief Product Officer

6.3.5 Role Family Table - Senior Developers

Role Title Function Key Responsibilities Reports To
Senior Full Stack Developer Technology (any team) Design and develop full-stack features; code review; performance optimisation; mentoring of junior developers; architectural input for domain components. Relevant Development Manager / Lead
Senior Java Developer Technology (any team) Java-based backend services development; microservices design and implementation; API development; performance tuning. Relevant Development Manager / Lead
Senior Frontend Developer Technology - Portal React/Angular frontend development; UI/UX implementation; front-end performance optimisation; accessibility standards. Portal Development Lead / Development Manager (Portal)

6.3.6 Role Family Table - Business Development Managers

Role Title Function Key Responsibilities Reports To
Business Development Manager (Pakistan) Revenue - BD Identify and acquire new merchant and partner accounts in Pakistan; manage pipeline; negotiate commercial terms; handover to KAM post-signing. CRO / Head of Business
Business Development Manager (Bangladesh) Revenue - BD Identify and acquire new clients in Bangladesh; manage local commercial pipeline; coordinate with Country Head BD and Nepal. CRO; dotted line to Country Head BD and Nepal
Business Development Manager (UAE / MENA) Revenue - BD Develop the UAE and MENA commercial pipeline; target white-label wallet clients, B2B partners, and corridor origination clients. CRO / Head of Business
Key Account Manager Revenue - KAM Manage relationships with signed Tier A merchants and partners; drive volume growth, product adoption, and retention; manage SLA escalations and commercial renewals. CRO / Head of Business

6.3.7 Role Family Table - Compliance Analysts and Regulatory Policy Analysts

Role Title Function Key Responsibilities Reports To
Compliance Analyst Regulatory Affairs / Compliance Day-to-day compliance operations: KYC/KYB review, AML transaction monitoring alerts, SAR/STR drafting, record-keeping, and compliance reporting. Global Head of Regulatory Affairs
Sanctions Analyst Regulatory Affairs / Compliance Operate the Eastnets sanctions screening platform; manage hit alerts; conduct hit disposition analysis; escalate confirmed matches; maintain sanctions screening records. Global Head of Regulatory Affairs
Regulatory Policy Analyst Regulatory Affairs Monitor regulatory developments across all active jurisdictions; draft regulatory impact assessments; support licence application preparation; maintain the Group's regulatory calendar. Global Head of Regulatory Affairs
AML/CFT Officer (Country) Country Operations Serve as the designated AML/CFT officer or deputy MLRO for a country entity; manage local AML reporting obligations; liaise with local financial intelligence units. Country Head (solid); Global Head of Regulatory Affairs (dotted)

6.4 Individual Contributor Role Profiles

The following table defines the individual contributor role families across the Group. These roles are the operational backbone of the organisation.


6.4.1 Role Family Table - Software Developers and Engineers

Role Title Band Core Responsibilities
Software Engineer (Junior) IC1 Develop features under supervision; write unit tests; participate in code reviews (as reviewee); fix bugs; attend Agile ceremonies.
Software Engineer IC2 Develop features independently; write unit and integration tests; participate in code reviews (as reviewer for junior peers); contribute to technical documentation.
Senior Software Engineer IC3 Design and develop complex features; lead code reviews; provide technical mentorship to IC1/IC2; contribute to architectural discussions; manage technical debt within assigned domain.

6.4.2 Role Family Table - SQA Engineers

Role Title Band Core Responsibilities
SQA Engineer (Junior) IC1 Execute manual test cases; log defects; perform regression testing; support UAT activities.
SQA Engineer IC2 Write and execute automated test scripts (REST Assured, Playwright, Appium, JMeter); manage test cases in test management tool; conduct API and UI testing.
Senior SQA Engineer IC3 Design automation frameworks; lead test planning for assigned domains; performance and load test execution; mentor junior SQA engineers; defect triage.

6.4.3 Role Family Table - DevOps Engineers

Role Title Band Core Responsibilities
DevOps Engineer IC2 Maintain CI/CD pipelines (Jenkins); write and maintain Terraform/Ansible infrastructure code; manage AWS infrastructure components; support deployments and release activities.
Senior DevOps Engineer IC3 Design and implement infrastructure-as-code; optimise CI/CD pipelines; cloud cost management; DR infrastructure management; mentor junior DevOps engineers.

6.4.4 Role Family Table - Database Administrators

Role Title Band Core Responsibilities
Database Administrator (DBA) IC2 Manage and maintain MySQL, PostgreSQL, MongoDB, and Amazon DocumentDB instances; database performance tuning; backup and recovery procedures; schema change management; query optimisation.
Senior DBA IC3 Database architecture input; capacity planning; high-availability and replication configuration; performance benchmarking; security hardening of database environments; mentoring.

6.4.5 Role Family Table - NOC / SOC Associates and Analysts

Role Title Band Core Responsibilities
IT Help Desk Associate IC1 Provide Tier 1 IT support to staff; manage hardware/software issues; user provisioning and deprovisioning; escalate to system administration for Tier 2 issues.
NOC Associate IC1–IC2 Monitor production systems using Datadog, CloudWatch, and CyGlass; acknowledge and triage alerts; escalate incidents per the escalation matrix; log incidents and maintain the incident register.
SOC Analyst IC2–IC3 Monitor security events and SIEM alerts; investigate anomalous activity; conduct initial threat analysis; escalate confirmed or suspected incidents to the Information Security Manager and CISO; document security events.
NOC Engineer IC2–IC3 Manage network and infrastructure monitoring configuration; lead complex NOC incident investigations; produce NOC performance and availability reports; support system administration activities.

6.4.6 Role Family Table - Finance and Treasury Analysts

Role Title Band Core Responsibilities
Finance Analyst IC2 Assist with monthly management accounts preparation; variance analysis; accounts payable/receivable processing; expense management; support statutory reporting.
Treasury Analyst IC2 Execute daily payment runs and funding transfers; maintain cash position schedules; support FX transaction processing; assist with bank reconciliations; maintain treasury records.
Senior Finance Analyst IC3 Lead management reporting for assigned entities; financial modelling; budget vs. actuals analysis; intercompany invoicing and transfer pricing support; support external audit.

6.4.7 Role Family Table - HR and Admin Associates

Role Title Band Core Responsibilities
HR Associate IC1–IC2 Support HR operations: onboarding administration, leave management, payroll data inputs, maintenance of employee records, and HR system updates.
Admin / Office Manager IC1–IC2 Manage office facilities, procurement of supplies, vendor liaison, travel bookings, and general administrative support to the leadership team.
Procurement Associate IC2 Support vendor onboarding, purchase order management, contract register maintenance, and procurement process compliance.

Role Title Band Core Responsibilities
Legal Counsel (Country) IC3–SM Provide legal advice on country-specific matters: local regulatory requirements, employment law, commercial contracts with local partners, and entity compliance obligations. Support the Head of Legal on cross-border matters. Liaise with the Global Head of Regulatory Affairs on regulatory submissions.

6.4.9 Role Family Table - Service Delivery Associates

Role Title Band Core Responsibilities
Service Delivery Associate IC1–IC2 Provide first-line operational support to merchants and partners: handle transaction queries, escalate processing issues, manage support tickets, provide status updates, and escalate to the Country Head Pakistan or Head of Settlements for operational issues.
Service Delivery Analyst IC2–IC3 Manage escalated merchant and partner queries; conduct root-cause analysis for operational incidents; liaise with technology, settlements, and payment channel teams to resolve issues; identify service improvement opportunities.

6.5 Country-Specific Roles and Dual-Reporting Structures

6.5.1 Overview of the Matrix Reporting Model

Simpaisa operates a functional-geographic matrix across its multi-country footprint. This model reflects a deliberate design choice: the Group requires both the depth of functional expertise (e.g., treasury, legal, compliance) that can only be built and maintained at Group level, and the proximity to local markets, regulators, banking partners, and cultural contexts that can only be provided by in-country leadership.

The result is a dual-reporting structure for all country-level functional roles:

  • Solid-line reporting to the relevant Country Head for day-to-day direction, local priorities, resource deployment within the country, and performance management of in-country activities.
  • Dotted-line reporting to the relevant Group Functional Head for functional standards, methodology, technical guidance, policy compliance, professional development, and functional KPIs.

This structure is deliberately not a pure global functional model (which would leave Country Heads without adequate authority over in-country resources) nor a pure geographic model (which would risk fragmentation of functional quality and policy compliance across jurisdictions).


6.5.2 Illustrative Examples

The following examples illustrate how dual-reporting applies in practice.

Example 1: Legal Counsel - Nepal

The Legal Counsel based in Nepal provides day-to-day legal support to the Pay Nest entity and the Country Head Bangladesh and Nepal. The reporting structure is:

  • Solid line → Country Head Bangladesh and Nepal (Sanjana Farid): daily direction, local regulatory submissions, NRB relationship support, employment matters, and local partner contract review.
  • Dotted line → Head of Legal (Group): legal standards, contract templates, Group policy compliance, professional development, and cross-jurisdictional legal matters.

Example 2: Treasury Manager - Bangladesh

The Treasury Manager in Bangladesh manages BDT liquidity, pre-funding, and bank account operations for the Simpoysha BD and Soft Tech entities. The reporting structure is:

  • Solid line → Country Head Bangladesh and Nepal (Sanjana Farid): daily treasury operations decisions, local bank relationship management, in-country pre-funding execution, and local performance management.
  • Dotted line → Head of Treasury (Group): treasury policy compliance, FX management standards, cash reporting formats, intercompany treasury transactions, and functional development.

Example 3: AML/CFT Officer - Pakistan (PublishEx)

The AML/CFT Officer for the Pakistan entity manages local AML obligations under the SBP framework and the Group's AML/CFT/PF policy (Pakistan addendum). The reporting structure is:

  • Solid line → Country Head Pakistan (Noor Ali): day-to-day AML operational activities, local SAR/STR submissions to the FMU, and in-country compliance management.
  • Dotted line → Global Head of Regulatory Affairs (Shoukat Bizinjo): AML/CFT policy standards, FATF compliance framework, Group sanctions policy, training and methodology, and professional development.

Example 4: Finance Analyst - UAE (Simpaisa Technologies)

The Finance Analyst in the UAE supports the preparation of statutory accounts and management reporting for Simpaisa Technologies LTD. The reporting structure is:

  • Solid line → Country/Entity lead (senior manager in UAE, reporting to COO): day-to-day financial tasks, local entity priorities, and local vendor payments.
  • Dotted line → Global Chief Financial Officer: IFRS accounting standards, intercompany reporting, Group chart of accounts compliance, audit support, and financial development.

6.5.3 Rules for Conflict Resolution in Dual-Reporting Arrangements

Where the Country Head and the Group Functional Head give conflicting direction to a country-level functional role, the following rules apply:

  1. Day-to-day operational priorities are determined by the Country Head (solid line). The Country Head has authority to direct the timing and sequencing of in-country work within the overall scope of the functional role.

  2. Functional standards, policies, and methodologies are non-negotiable and are set by the Group Functional Head (dotted line). A country-level employee is not permitted to deviate from Group-level policy at the direction of the Country Head. Examples include: AML/CFT policies, treasury risk management standards, legal contract templates, and information security controls.

  3. Resourcing conflicts (e.g., a Group functional initiative requires the country resource's time during a period of high in-country demand) are escalated jointly by the Country Head and the Group Functional Head to their shared line manager (typically the CEO or CSNO) for resolution. The default is that regulatory and compliance-driven Group functional priorities take precedence over commercial in-country activities.

  4. Performance management is conducted by the Country Head with input from the Group Functional Head on functional competency and standards compliance. Annual appraisals require sign-off from both the solid-line and dotted-line manager. Where there is a material disagreement between the two managers on performance, the matter is escalated to the COO and Head of HR for resolution.

  5. Hiring, salary changes, and role changes for country-level functional roles require approval from both the Country Head and the relevant Group Functional Head, plus the Head of HR and the COO (per the Delegation of Authority Matrix).

  6. Regulatory obligations: where a country-level functional role holder has a personal regulatory responsibility (e.g., a designated AML officer or MLRO under local law), that individual's obligations to the local regulator take precedence over all other internal reporting instructions. The individual must not be prevented from fulfilling their regulatory duties by any internal direction from either reporting line.


6.5.4 Country-Specific Functional Role Register

The following table summarises the country-level functional roles currently in existence or planned, their dual-reporting lines, and the relevant entity.

Role Country / Entity Solid Line Dotted Line
Deputy Country Manager - Bangladesh Bangladesh (Simpoysha BD / Soft Tech) Country Head BD and Nepal CSNO
Deputy Country Manager - Nepal Nepal (Pay Nest) Country Head BD and Nepal CSNO
Treasury Manager - Bangladesh Bangladesh Country Head BD and Nepal Head of Treasury
Legal Counsel - Bangladesh Bangladesh Country Head BD and Nepal Head of Legal
Legal Counsel - Nepal Nepal Country Head BD and Nepal Head of Legal
AML/CFT Officer - Bangladesh Bangladesh Country Head BD and Nepal Global Head of Regulatory Affairs
AML/CFT Officer - Nepal Nepal Country Head BD and Nepal Global Head of Regulatory Affairs
AML/CFT Officer - Pakistan Pakistan (PublishEx) Country Head Pakistan Global Head of Regulatory Affairs
Finance Analyst - Pakistan Pakistan Country Head Pakistan Global CFO
Finance Analyst - Bangladesh Bangladesh Country Head BD and Nepal Global CFO
Legal / Regulatory Support - Iraq Iraq (Branch Office) Designated in-country manager Head of Legal / Global Head of Regulatory Affairs
Compliance / Regulatory Officer - UAE UAE (Simpaisa Technologies) UAE entity senior manager Global Head of Regulatory Affairs
Country MLRO - Canada (Commerce Plex) Canada COO (Group) Global Head of Regulatory Affairs
Country MLRO - Canada (Simpaisa CA) Canada COO (Group) Global Head of Regulatory Affairs

End of Section 6 - Roles and Responsibilities


Document Control

Version Date Author Changes
0.1 April 2026 Operating Model Working Group Initial draft