Corporate Treasury Policy Template

Treasury Policy: [Group name]

Board-approved treasury policy for a non-financial group: objectives, governance and delegated authorities, liquidity, funding, foreign exchange and interest rate risk (summary level), counterparty and bank relationship limits, investment of surplus cash, approved and prohibited instruments, payment and bank account controls, derivative regulatory obligations, reporting and breach handling. It follows common corporate treasury practice (board approval, annual review, segregation of duties) and refers by name and number to the instruments that shape it: IFRS 9 and IFRS 7 (hedge accounting and risk disclosures), EMIR (Regulation (EU) No 648/2012 as amended, including Regulation (EU) 2024/2987), the US non-financial end-user clearing exception (17 CFR 50.50) and the GAO Green Book (GAO-25-107721, 2025) as an open internal-control reference. Replace every [bracketed] value and every row marked Example. The worked example uses the fictional Corvid Commerce Group (parent Corvid Commerce Group plc, England and Wales, listed; EUR functional currency; calendar financial year; operating headquarters and group treasury in Germany; subsidiaries in the UK, the US and Vietnam). This is a document format, not financial, investment, tax, legal or accounting advice. Obtain the standard or law for the normative text.

Document control

Approvals

Revision history

Contents

• 1. Purpose, scope and approval
• 2. Governance, roles and delegated authorities
• 3. Liquidity and cash management
• 4. Funding and capital structure
• 5. Foreign exchange risk
• 6. Interest rate risk
• 7. Counterparty and bank relationship management
• 8. Investment of surplus cash
• 9. Approved instruments and prohibited activities
• 10. Payments, bank accounts and fraud prevention
• 11. Derivative regulatory obligations
• 12. Intercompany financing and tax
• 13. Reporting and key indicators
• 14. Breaches, exceptions and policy review
• 15. Glossary and references
• Appendix A. Entities, bank accounts and mandates
• Standard and licence note

1. Purpose, scope and approval

1.1 Purpose

This policy sets the objectives, authorities, limits and controls for the management of cash, liquidity, funding and financial market risk in [Group name]. Its purpose is to make sure the group can meet its obligations as they fall due, at an acceptable cost, while reducing the effect of exchange rate and interest rate movements on cash flow, earnings and covenant headroom to a level the board has accepted.

1.2 Treasury objectives

1.3 Risk philosophy

Treasury is a cost centre. It manages risks that arise from the business; it does not create risk to earn a return. Any transaction whose purpose is to profit from a view on market prices, rather than to reduce an identified exposure, is prohibited (section 9.3).

1.4 Scope

The policy applies to [Group name] and to every subsidiary it controls, listed in Appendix A. Joint ventures and associates are outside scope but treasury reports their bank debt and guarantees to the CFO. Local law or regulation that is stricter than this policy prevails for the entity concerned; the local finance lead notifies the group treasurer of the difference.

Example: Corvid Commerce Group plc (CC-HOLD, England and Wales, listed parent and borrower under the group facilities, EUR), Corvid Commerce GmbH (CC-DE, Germany, operating headquarters and group treasury centre, EUR), Corvid Commerce Ltd (CC-UK, GBP), Corvid Commerce Inc (CC-US, USD) and Corvid Commerce Vietnam LLC (CC-VN, VND). Group treasury sits in CC-DE and deals the group's FX hedges; the parent deals the interest rate hedges of its own facilities and the GBP hedge of its loan to CC-UK (section 11).

2. Governance, roles and delegated authorities

2.1 Governance structure

The board sets policy and limits; the CFO and the Treasury Committee supervise; the group treasurer executes; Group Finance confirms, settles and accounts independently of dealing; internal audit reviews the whole cycle.

2.2 Roles and responsibilities

2.3 Delegated authorities

Amounts are in EUR thousand per transaction (notional for derivatives) unless stated. Two authorised persons approve every transaction; at least one must hold the authority level shown. Limits are cumulative upwards: the CEO column covers amounts above the CFO limit up to the CEO limit. R means the role recommends and the next approving column decides; A means approves; I means informed.

This table is the treasury extract of the Delegation of Authority Matrix (finance/delegation-of-authority-matrix) sections 5.5 and 6. It must stay identical to that matrix, to section 10.1 of the FX and Interest Rate Hedging Policy and to the bank mandates; change all of them in the same board resolution. The back office checks the mandates and the treasury management system user limits against this table every [six] months.

Example: The EUR 21,000k pay-fixed swap on the term loan (section 6.3) needed CFO approval: the treasurer has no own authority for swaps, and 21,000 is within the CFO's 25,000. A EUR 30,000k FX hedge dealt as one trade would need the CEO. The same amount layered monthly in trades of EUR 5,000k or less stays within the treasurer's authority under the Treasury Committee's monthly hedge plan, which is the intended route.

3. Liquidity and cash management

3.1 Cash forecasting

Measure forecast accuracy each week for the first four weeks of the 13-week forecast and report the variance trend to the Treasury Committee. The 13-Week Cash Flow Forecast (finance/13-week-cash-flow-forecast) holds the format.

3.2 Cash concentration and pooling

1. Concentrate surplus cash daily into the group header account held by the treasury centre (Example: CC-DE) through [zero-balancing / notional pooling] where law allows.
2. Keep operating cash in subsidiaries at the level the local finance lead needs for [ten] business days of payments.
3. Where exchange controls or local rules prevent pooling (for example Vietnam, where foreign-currency transactions and offshore loans are regulated by the State Bank of Vietnam; check local law), forecast the trapped cash separately and exclude it from group headroom.
4. Document every cash pool in a written agreement that sets interest, guarantees and set-off rights, and price it at arm's length (section 12).

3.3 Liquidity headroom

Liquidity headroom is unrestricted cash (excluding trapped and restricted cash) plus undrawn committed facilities with more than [12] months to maturity. A facility stops counting on the day its remaining life falls to 12 months, even though it can still be drawn, so that the group never relies on money it must soon repay or refinance. The operating cash buffer is not deducted; it is one of the reasons the minimum is set where it is.

The stress floor sits above the contractual minimum liquidity covenant in the facility agreement (Example: EUR 15,000k in the Covenant Compliance Certificate, finance/covenant-compliance-certificate), so that a stress event is handled under this policy long before it becomes a default. Do not confuse the two: the policy minimum of EUR 35,000k is the board's own limit; the covenant floor is what the lenders can enforce.

Example: Corvid Commerce Group headroom at 2026-12-31.

Check: 28,000 - 1,000 + 20,000 = 47,000. Headroom is above the EUR 35,000k minimum and the EUR 45,000k early warning trigger, so the status is green. The forward view matters more than the spot figure. The EUR 30,000k term loan and the revolving facility both mature on 2028-06-30. From 2027-07-01 the revolving facility no longer counts, so on the FY2027 budget closing cash of EUR 26,400k the headroom at 2027-12-31 would be 26,400 - 1,000 + 0 = EUR 25,400k, below the minimum. The refinancing must therefore be signed by 2027-06-30. The Liquidity and Funding Plan (finance/liquidity-funding-plan) holds the refinancing mandate and the quarterly projection; where it shows headroom on the management basis (all cash counted), reconcile the difference to this definition in the treasury report.

3.4 Liquidity stress scenarios

If the stress case falls below the stress minimum, the group treasurer proposes actions (draw facilities, delay discretionary capex, arrange new funding) to the CFO within [five] business days.

4. Funding and capital structure

4.1 Funding principles

1. Fund long-term assets with long-term capital; do not fund acquisitions or capex with short-term or uncommitted lines.
2. Keep committed facilities from at least [three] relationship banks so that the loss of one lender does not breach the headroom minimum.
3. Start refinancing any facility at least [18] months before maturity and sign the replacement at least [12] months before maturity, so that headroom never depends on a facility in its final year; no more than [30%] of gross debt may mature in any 12-month period.
4. Keep leverage inside the target range set in the Capital Structure and Dividend Policy (finance/capital-structure-dividend-policy), which also holds the distribution rules; the limits in 4.2 repeat its figures and change only together with that policy.
5. Negotiate covenants, events of default and change of control clauses with the group treasurer and legal counsel; record each covenant in the covenant register and certify compliance with the Covenant Compliance Certificate (finance/covenant-compliance-certificate).

4.2 Funding limits

Leverage below the target range is not a breach: it means unused debt capacity, and the Capital Structure and Dividend Policy decides how to use it. Leverage above the ceiling, or interest cover below the floor, is a breach under section 14.

Example: Corvid Commerce Group has a EUR 30,000k bullet term loan and an undrawn EUR 20,000k revolving facility, both originated on 2025-06-30 with a three-year tenor and maturing on 2028-06-30.

Check: 30,000 + 8,000 - 27,000 = 11,000 and 11,000 / 17,800 = 0.62x; 30,000 - 26,400 = 3,600 and 3,600 / 21,600 = 0.17x; 30,000 + 6,400 - 25,400 = 11,000 and 11,000 / 21,600 = 0.51x. The management basis (Annual Budget, finance/annual-budget) excludes leases and nets all cash; the covenant basis follows the facility agreement and excludes the EUR 1,000k of restricted cash. Report both and label them, because the gap (0.17x against 0.51x for the same year) is large enough to confuse a board. Both are below the 1.0x floor of the target range and far inside the 3.00x covenant. FUND-LIM-04 is met at 2026-12-31, because nothing matures within 12 months, but it would be breached from 2027-07-01 without the refinancing in 3.3. That is why FUND-LIM-03 is the binding rule this year.

4.3 Credit rating

If the group holds or seeks a public credit rating, the CFO maintains the rating agency relationship, and the funding plan shows the effect of proposed transactions on the rating metrics. If the group has no rating, state that here and use the leverage and cover limits above as the internal substitute.

5. Foreign exchange risk

5.1 Exposure types and approach

5.2 Group position

Example: The group is net long USD. Corvid Commerce Inc (CC-US) sells subscriptions in USD (FY2027 budget USD 24,640k against USD costs of USD 4,107k, a net inflow of USD 20,533k, ASM-014 in the Annual Budget, finance/annual-budget). CC-US pays most of this surplus to Corvid Commerce GmbH (CC-DE) as a monthly USD platform fee (forecast USD 16,000k in FY2027), which is a transaction exposure for CC-DE; the USD 4,533k retained in CC-US is translation exposure. The parent lends GBP 10,000k to Corvid Commerce Ltd, and the group holds net investments in the UK (GBP 18,000k) and the US (USD 25,000k). Forecast USD platform-fee receipts are hedged in bands by selling USD forward, the GBP loan is hedged with rolling FX swaps, and both net investments are not hedged. A 10% weaker USD would cost about EUR 1,697k of EBITDA before hedging (SEN-003 in the Annual Budget).

The FX and Interest Rate Hedging Policy (finance/fx-interest-rate-hedging-policy) sets the bands, instruments, dealing controls and hedge accounting approach.

6. Interest rate risk

6.1 Approach

1. Measure the share of gross debt that pays a fixed rate, directly or through interest rate swaps, over the next [three] years.
2. Keep the fixed share within the band set in the hedging policy (for Example, 40% to 75% in years 1 to 2). Measure it on bank and capital market borrowings; lease liabilities are fixed by nature and are reported separately so that they do not mask the floating-rate exposure.
3. Do not let a hedge extend beyond the expected life of the borrowing it protects, and do not hedge debt that is not drawn or highly probable to be drawn. A swap that runs past the current facility's maturity is allowed only as a forward-starting hedge of a refinancing that is in the board-approved funding plan (hedging policy section 6.2).
4. Report the sensitivity of annual net interest cost to a parallel move of [100] basis points each month.

6.2 Benchmarks

Record each floating-rate benchmark used in facility agreements and derivatives, with its administrator and fallback provisions: for Example, EURIBOR and the euro short-term rate (euro debt), SOFR (US dollar debt), SONIA (sterling debt). Check that the fallback language in each loan and in each derivative confirmation (through the ISDA fallback protocol or bilateral terms) points to the same replacement rate, so that a benchmark cessation does not create a basis mismatch.

6.3 Position

Example: Corvid's EUR 30,000k term loan pays 3-month EURIBOR plus a margin, and the revolving facility is undrawn. A EUR 21,000k pay-fixed swap, traded by the parent on 2025-06-30 and maturing on 2028-06-30 with the facility, fixes 21,000 / 30,000 = 70% of gross bank debt, inside the 40% to 75% band. A 100 basis point rise would raise annual interest on the unhedged EUR 9,000k by 0.01 x 9,000 = EUR 90k, against the EUR 500k appetite in the hedging policy. Because the swap ends with the facility, the fixed share of the replacement debt from 2028-07-01 is nil until a forward-starting swap is traded; the hedging policy (Appendix A.3) shows the proposal, which may only be executed once the refinancing is in the board-approved funding plan.

7. Counterparty and bank relationship management

7.1 Minimum credit quality

A bank or fund may hold group cash or face the group in a derivative only if it meets one of the following, measured at the time of the transaction and monitored [weekly]:

• a long-term rating of at least [A- / A3] from at least two of [S&P Global, Moody's, Fitch], using the lower rating where they differ; or
• for a money market fund, the criteria in section 8; or
• explicit written CFO approval for a named local bank needed for operations in a country where no bank meets the rating (limit in 7.2).

7.2 Exposure limits

Counterparty exposure is the sum of deposits, money market fund holdings with funds managed by that bank's group, and the positive fair value of derivatives (net only where an enforceable netting agreement exists), plus an add-on of [5%] of derivative notional for potential future exposure.

If a downgrade puts a counterparty outside its limit, the group treasurer reduces the exposure within [ten] business days or asks the CFO for a time-bound exception (section 14).

7.3 Bank relationships

1. Keep a bank relationship register showing services, facilities, share of ancillary business and contacts for each bank.
2. Allocate ancillary business (cash management, FX, derivatives) in proportion to each bank's credit commitment; review annually.
3. Sign derivatives only under a master agreement (for example the ISDA 2002 Master Agreement with a schedule agreed by legal counsel); a credit support annex is optional and requires CFO approval because it creates margin calls on the group's liquidity.
4. Complete each bank's know-your-customer requests promptly and keep the authorised signatory list current.

8. Investment of surplus cash

8.1 Principles

Invest surplus cash to protect principal first, keep it available second and earn a return only third. Match investment tenor to the cash forecast; never invest cash that the 13-week forecast shows will be needed.

8.2 Approved investments

8.3 Excluded

Equities, corporate bonds, structured deposits, deposits with capital at risk, crypto-assets, and any fund with a notice period of more than one business day are not approved.

9. Approved instruments and prohibited activities

9.1 Approved instruments

9.2 New instruments

A new instrument requires a written proposal by the group treasurer covering purpose, risks, valuation, accounting (including whether hedge accounting can be applied), tax, systems and regulatory reporting, reviewed by the group financial controller and approved by the board.

9.3 Prohibited activities

• Transactions that are not linked to an identified underlying exposure, or that exceed it (speculation).
• Net written options, leveraged or path-dependent structures (for example knock-in or target redemption forwards).
• Changing a trade after execution other than by a documented close out and new trade.
• Dealing with an unapproved counterparty, on an unrecorded line, or through personal devices or messaging apps.
• Using the group's credit to support third parties without board approval.

10. Payments, bank accounts and fraud prevention

10.1 Controls

Map these controls into the Risk and Control Matrix (compliance/risk-control-matrix) and assess payment fraud in the Fraud Risk Assessment (compliance/fraud-risk-assessment). The GAO Green Book (2025) is a useful open reference for designing control activities and segregation of duties.

10.2 Sanctions and payments

Payments are screened against applicable sanctions lists before release, under the group sanctions procedure (Sanctions Compliance Procedure, compliance/sanctions-compliance-procedure). Treasury does not open accounts or deal with counterparties in sanctioned jurisdictions.

11. Derivative regulatory obligations

Regimes and dates as of 2026-10; check local law and the consolidated texts.

Keep a Legal Entity Identifier (LEI) current for every entity that trades derivatives, and renew it before it lapses.

12. Intercompany financing and tax

1. Document every intercompany loan, cash pool and guarantee in a signed agreement covering amount, currency, interest, repayment, subordination and governing law.
2. Price intercompany financing at arm's length using the method set by the head of tax, consistent with the Transfer Pricing Master File (finance/transfer-pricing-master-file) and Local File (finance/transfer-pricing-local-file). OECD Transfer Pricing Guidelines 2022 Chapter X addresses financial transactions.
3. Check thin capitalisation and interest limitation rules in each country before lending (for example the EU Anti-Tax Avoidance Directive interest limitation rule and US Internal Revenue Code section 163(j)), and withholding tax on interest payments.
4. Record each arrangement in the Related Party Register (finance/related-party-register) where it involves a related party outside the consolidated group.
5. The head of tax reviews treasury's annual funding plan for tax consequences before the board approves it.

13. Reporting and key indicators

13.1 Reports

13.2 Key indicators

14. Breaches, exceptions and policy review

14.1 Breaches

1. Anyone who identifies a breach of this policy informs the group treasurer and the CFO on the same business day.
2. The group treasurer records it in the breach log with cause, amount, duration and proposed remedy.
3. Active breaches (caused by an action) are reported to the Audit Committee at its next meeting; breaches above [EUR 5m] or involving a prohibited activity are reported to the Audit Committee chair within [two] business days.
4. Passive breaches (caused by market moves, downgrades or forecast changes) are remedied within the time stated in the relevant section or under an approved exception.

14.2 Exceptions

The CFO may approve a time-bound exception of up to [90] days; longer or repeated exceptions need board approval. Each exception names the limit, the reason, the end date and the compensating control.

14.3 Review

Review this policy at least annually and after any of: a major acquisition or disposal, a new financing, a change in risk appetite, a material control failure, or a change in law or accounting standards affecting treasury (for example the IASB Risk Mitigation Accounting exposure draft, if it becomes a standard).

15. Glossary and references

15.1 Glossary

15.2 References

• IFRS 9 Financial Instruments, Chapter 6 (hedge accounting) and IFRS 7 Financial Instruments: Disclosures (IFRS Foundation; cited by name only).
• Regulation (EU) No 648/2012 (EMIR), as amended by Regulation (EU) 2019/834 and Regulation (EU) 2024/2987, EUR-Lex.
• Regulation (EU) 2017/1131 on money market funds, EUR-Lex.
• 17 CFR 50.50, Non-financial end-user exception to the clearing requirement, eCFR.
• 17 CFR 270.2a-7, Money market funds, eCFR.
• GAO, Standards for Internal Control in the Federal Government (GAO-25-107721, May 2025, effective from fiscal year 2026).
• OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022, Chapter X.
• Association of Corporate Treasurers (ACT), guidance on treasury policy (name only).

Appendix A. Entities, bank accounts and mandates

Standard and licence note

Structure aligned with common corporate treasury practice and with the policy topics described by the Association of Corporate Treasurers (name only). Based on public law and public-domain texts where cited: Regulation (EU) No 648/2012 and its amendments, Regulation (EU) 2017/1131 (EUR-Lex, reuse with acknowledgement), 17 CFR 50.50 and 17 CFR 270.2a-7 (US federal works, public domain) and the GAO Green Book 2025 (public domain). IFRS 9 and IFRS 7 are cited by name only; no text from IFRS Foundation material is reproduced or paraphrased, and IFRS is a trade mark of the IFRS Foundation, which does not endorse this template. The OECD Transfer Pricing Guidelines are cited by chapter only. All text is original. Check the current official version of each law, regulation and standard, and the law of each country where the group operates, before use. Corvid Commerce Group and every figure are fictional. Template licence: MIT.