Governance Policy

Section 1: Purpose and Applicability

This Governance Policy defines the organizational structure, leadership responsibilities, impartiality safeguards, and conflict of interest management principles adopted by LEI International Pvt. Ltd. (TNV-LEI) in its role as a Local Operating Unit (LOU) under the Global Legal Entity Identifier Foundation (GLEIF).

Applies to:

Board of Directors and Executive Leadership
Chief Compliance Officer, CTO, Validation/Verification Managers
All staff and outsourced teams
Impartiality Committee members and advisory panels

To be read with:

Impartiality and Conflict of Interest Provisions
Risk Management Framework
Procedural Governance Model

Section 2: Governance Structure and Leadership Roles

2.1 Legal Entity Status

TNV-LEI is a registered private limited company under the Companies Act, 2013 (India), operating as a LOU under GLEIF Accreditation ID: 9269.

2.2 Organizational Hierarchy

Board of Directors – Strategic direction, policy, fiduciary oversight
Managing Director / CEO – Implements policies, operations, GLEIF alignment
Chief Compliance Officer (CCO) – Legal and accreditation compliance
Chief Technology Officer (CTO) – Cybersecurity, ISO 27001, data privacy
Validation & Verification Leads – LE-RD validation, data quality control
Impartiality Committee – Independent oversight of risks and conflicts

2.3 Subsidiary and Outsourced Functions

All external agents operate under agreements aligned with TNV-LEI’s governance and impartiality principles.

Section 3: Impartiality Commitment and Risk Mitigation

3.1 Statement of Impartiality

TNV-LEI performs all services without bias or undue influence.

Section 1: Purpose and Applicability

Applies to:

Board of Directors and Executive Leadership
Chief Compliance Officer, CTO, Validation/Verification Managers
All staff and outsourced teams
Impartiality Committee members and advisory panels

To be read with:

Impartiality and Conflict of Interest Provisions
Risk Management Framework
Procedural Governance Model

Section 2: Governance Structure and Leadership Roles

2.1 Legal Entity Status

TNV-LEI is a registered private limited company under the Companies Act, 2013 (India), operating as a LOU under GLEIF Accreditation ID: 9269.

2.2 Organizational Hierarchy

Board of Directors – Strategic direction, policy, fiduciary oversight
Managing Director / CEO – Implements policies, operations, GLEIF alignment
Chief Compliance Officer (CCO) – Legal and accreditation compliance
Chief Technology Officer (CTO) – Cybersecurity, ISO 27001, data privacy
Validation & Verification Leads – LE-RD validation, data quality control
Impartiality Committee – Independent oversight of risks and conflicts

2.3 Subsidiary and Outsourced Functions

All external agents operate under agreements aligned with TNV-LEI’s governance and impartiality principles.

Section 3: Impartiality Commitment and Risk Mitigation

3.1 Statement of Impartiality

TNV-LEI performs all services without bias or undue influence.

Governance Function	Board of Directors	Chief Compliance Officer	Management Team
Strategic Direction	Approves policies	Reviews legal implications	Executes strategy
Impartiality Oversight	Reviews IC reports	Conducts risk assessments	Implements safeguards
Conflict of Interest Management	Approves declarations	Maintains logs	Declares proactively
GLEIF Compliance	Approves framework	Tracks accreditation	Implements technical controls
Policy Review	Final approval	Coordinates audits	Provides operational inputs
Complaint Escalation	Appellate function	Investigates	Assists inquiry process

Governance Policy

Section 1: Purpose and Applicability

Section 2: Governance Structure and Leadership Roles

2.1 Legal Entity Status

2.2 Organizational Hierarchy

2.3 Subsidiary and Outsourced Functions

Section 3: Impartiality Commitment and Risk Mitigation

3.1 Statement of Impartiality

Governance Policy

Section 1: Purpose and Applicability

Section 2: Governance Structure and Leadership Roles

2.1 Legal Entity Status

2.2 Organizational Hierarchy

2.3 Subsidiary and Outsourced Functions

Section 3: Impartiality Commitment and Risk Mitigation

3.1 Statement of Impartiality

3.2 Risk Identification

3.3 Mitigation Controls

3.4 Third Parties

3.5 Transparency

Section 4: Conflict of Interest Management

4.1 Declaration and Disclosure

4.2 Conflict Identification

4.3 Prevention

4.4 Escalation

4.5 Training

Section 5: Impartiality Committee (IC)

5.1 Mandate

5.2 Composition

5.3 Meeting Frequency

5.4 Documentation

5.5 Confidentiality

Section 6: Responsibility Matrix

Section 7: Oversight and Accountability Mechanisms

7.1 Internal Oversight

7.2 External Oversight

7.3 Record-Keeping

Section 8: Regulatory Alignment and GLEIF Requirements

8.1 GLEIF Compliance

8.2 National and Global Laws

8.3 Audit Readiness

8.4 Continuous Monitoring

Section 9: Policy Review and Update Cycle

9.1 Review Frequency

9.2 Review Responsibility

9.3 Final Approval and Publication

9.4 Version Control