GMR Airport Treasury Policy Overview
GMR Airport Treasury Policy Overview
AIRPORT LIMITED
TREASURY POLICY
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TABLE OF CONTENTS
Page
Descriptions
No
1. Preamble 02
2. Risk Philosophy 03
3. Policy Review 03
4. Procedure followed for investment/hedging 03
5. Role of Treasury Front, Mid and Back Office 03
6. Investment Policy 04
7. Investment Authorization Limits 06
8. Stop Loss Limits 06
9. Approvals/Ratification for MF/FD Investments 07
10. Equity Investment Policy 07
11. Forex Policy 07
12. Policy Review 07
13. Exposures 07
14. Risk Identification/Recognition 08
15. Netting of Exposures 08
16. Treatment to Natural Hedge 08
17. Risk Measurement 08
18. Risk Benchmark-Currency 09
19. Risk Mitigation-Currency 09
20. Risk Benchmark-Interest Rate 10
21. Risk Mitigation-Interest Rate 10
22. Risk Control 11
23. Risk Reporting 11
24. RASCI 12
25. Reporting to the Board or Committee 14
26. Audit 15
27. Accounting & Disclosures 15
28. Appendix 16
29. Annexure-I 17
30. Annexure-II 18
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TREASURY POLICY
PREAMBLE
As per the best practices of Global Treasuries and to align the same with market
developments, GMR Visakhapatnam International Airport Limited (GVIAL) has
formulated Treasury Policy which is broadly in sync with the Group Policy. Treasury
Policy encompasses deployment of surplus money in fixed income, money market
instruments, fixed deposits, commercial papers etc., foreign currency risk
management and interest rate risk management. The Policy sets out the basic
principles of a prudent system to control the risks in investment and forex transactions.
These include:
Appropriate oversight by the senior management and the Board of the Company;
Adequate risk management process that integrates prudent risk limits, sound
measurement procedures and information systems, continuous risk monitoring and
frequent management reporting;
It is essential, while dealing with potentially complex products, such as forex and
derivatives that the board and senior management should understand the nature of
the transaction, which the Company is undertaking. This includes an understanding of
the nature of the relationship between risk and reward, in particular an appreciation
that it is inherently implausible that an apparently low risk business can generate high
rewards. The board of directors and senior management demonstrates through this
policy that they have a strong commitment to an effective control environment
throughout the organization.
Investment and Forex Policy is based on the principle of safety, liquidity and returns.
The purpose of this Policy is:
To evaluate the risk of each instrument before investing and not to get lured by
the return alone;
The Company shall work in close coordination with Corporate Treasury to ensure that
the Investment and FX risks are properly evaluated from a risk framework and
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informed decisions are made to risk-off the balance sheet from such investments and
FX exposures.
RISK PHILOSOPHY
POLICY REVIEW
Such changes in the Investment and FX policy will have to be adopted by the company
Board.
The Company shall inform Treasury about surplus funds available for deployment;
Treasury Front Office identifies various Investment opportunities in the market and
advises the Company for investments;
As soon as the Company enters into Contractual Obligations other than INR same
will be informed to Treasury for recommendation of suitable instrument of
hedging., After approval from the Company, Treasury will execute the hedge
transactions;
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Front Office
Investment Management & position the portfolio to insulate from adverse market
movements;
Liquidity Management;
Strict adherence to stop loss limits and responsible for reporting limit breaches.
INVESTMENT POLICY
Amount Tenor
(Rs. In Cr) (Years)
50 Upto 3
100 >3
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Products Limits Remarks
Overnight Scheme Overnight Scheme and Liquid Scheme as per
and Liquid Mutual following slabs of AUM:
Funds
Investment Limit
AUM
per AMC
(In Rs. Crs)
(In Rs. Crs)
10,000-15,000 Rs. 100 Crs
15,000-45,000 Rs. 250 Crs
45,000-1,00,000 Rs. 500 Crs
Above 1,00,000 Rs. 1,000 Crs
• No Investment Horizon Period for
Overnight Fund / Liquid Fund Scheme,
Reason is Reinvestment will attract
Stamp Duty @ 0.005% p.a.
Refer Annexure-I.
Certificate of Deposits Bank Wise Exposure Limits as per Annexure
– II.
In case stop loss triggers, the positions would be unwound at the prevailing market
levels.
In case stop loss triggers and Treasury is unable to sell the securities due to
circumstances beyond its control, Treasury will immediately report the same to
CFO of the Company and place the same before CEO/CCM/BCM for ratification
Securities which have been sold and not sold which has breached stop loss limits will
be reported immediately to CFO of the Company and will be placed before the
CCM/BCM/CEO for ratification.
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APPROVALS/RATIFICATION FOR MF AND FD INVESTMENTS
Investment with Mutual Funds other than the approved list will be with the prior
approval of CEO/CCM/BCM.
CFO of the Company is authorized to approve investment in AMCs which are not in
the permitted list once the AUM reaches Rs.10,000 Crs level.
The Company can exceed Bank wise FD limits and can place Fixed Deposit with
Banks other than the approved Banks with the approval of CEO/CCM/BCM.
FOREX POLICY
Preamble
The Company’s FX and Interest Rate risk management policy will govern all the
domestic as well as overseas borrowings and it will provide guidance to hedge existing
and prospective currency and interest rate liabilities. The Company’s FX and Interest
policy is based on the principle of “De-Risking” the balance sheet as soon as the risk
is identified.
Risk Philosophy
Types of Exposures
There are three types of exposures that an entity can have. The Company shall identify
the exposures and make the Corporate Treasury aware of the exposures.
a) Translation Exposure
It arises from the need, for purposes of reporting and consolidation, to convert
the results of foreign operations from the local currency to the home currency.
e.g., an appreciation in the Rupee would lead to a fall in the value of investments
in the balance sheet of an Indian company, which has equity holdings in USA.
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b) Transaction Exposure
c) Economic Exposure
It is defined as the extent to which the value of the firm, as measured by the
present value of all expected future cash-flows will change when exchange rates
change. The currency movement of the competitor in another country impacts the
sales of our products.
Risk Identification/Recognition
A transaction exposure arises every time the Company enters into a contractual
obligation where the payment or receipt is denominated in a currency other than its
balance sheet currency or when it raises borrowing in a currency other than its balance
sheet currency.
Netting of Exposure
For the contracted exposures the Company shall adopt the concept of netting wherever
the currency of the exposure matches. Time gap between the payable and receivable
should not exceed 15 working days. If any natural hedge is identified, the Company
must get it validated by the Corporate treasury.
Transactions, payables as well as receivables, can be kept open until one of the
transaction is executed.
Once one of the transactions is executed, the second transaction for its respective
maturity date should be simultaneously hedged to avoid volatility in the spot
USD/INR.
Natural hedge transaction should be done with prior approval of the BCFO.
Net exposure, will be hedged as per the policy guidelines defined in this policy.
Risk Measurement
FX risk should be measured through sensitivity analysis of the net open positions.
Exposure Reviews
Event Risk
Corporate Treasury will inform and recommend a review call in cases of an event risk,
which can lead to significant market movement and impact on company FX or Interest
Rate Exposure.
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Periodic Review
CFO of the Company or person designated by him/her can request market review call
with Treasury after-market hours to discuss market sentiments and initiate any action
if deemed fit.
Corporate Treasury will circulate monthly market review to facilitate discussion and
decision making at the group level. CFO of the Company will attend the call to discuss
market sentiments and initiate any action if deemed fit. Stop Loss or Hedge target rate
will be discussed and decided on the call so that Corporate Treasury can act in the
market until next monthly review meeting. Such decisions, if they are in deviation
from the policy should be ratified by CCM/BCM/CEO or any such competent authority.
Corporate Treasury will consider day 1 full hedging cost as per the exact
schedule/model rate shared by the Company for any hedging or risk/impact/stress
analysis. Day 1 being the day when the confirmed exposure is recognized by the
Company in its balance sheet.
Model FX rate which the Company has taken into consideration for costing purposes
will be communicated by the Company to Corporate Treasury for any risk analysis.
The Company will also communicate the buffer, either in terms of number or
percentage, kept in the model for costing/budget purposes.
Any hedge cost breach, of the day 1 hedge cost/model rate, should be immediately
brought to the notice of CFO for appropriate discussion/action.
A more then 2% advantage, from the day 1 hedge cost/model rate, should be
immediately brought to the notice of the BCFO for appropriate discussion/action.
Hedge 100% net currency risk for the entire tenure of the exposure, once the net
exposure with specific hedging schedule has been recognized by the Company. This
can be done by the Corporate Treasury within 10 trading days of having received
such schedule from the Company. If exposure is required to be kept open for any
reason, approval of CEO shall be obtained.
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Deviation from the Risk Mitigation – Currency
Corporate Treasury should communicate the same to CFO of the Company and
shall seek an extension of time for the hedging from CFO of the Company.
If CFO of the Company feels that the currency should be kept unhedged for a
certain period to take advantage of the market movement, explicit written approval
must be obtained from CEO of the Company.
Currency risk can be kept unhedged if there are explicit written instructions from
CEO or any such competent authority, to do so.
These unhedged positions must be closely monitored and discussed with corporate
treasury.
The Company will consider foreign currency loans only if there is a cost advantage
on a fully-hedge basis for the entire tenure of the exposure vis-à-vis the most
comparable loan in the balance sheet currency.
Corporate Treasury will consider day 1 full hedging cost as per the exact schedule
shared by the Company, for any hedging or risk/impact/stress analysis. Day 1
being the day when the confirmed exposure is recognized by the Company in its
balance sheet.
Such model rate will be communicated by the individual entity/SPV to treasury for
any risk analysis.
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No speculative trades should be undertaken, unless explicitly permitted in writing
by the CCM/BCM/CEO.
Cost reduction products are permitted for managing interest rate risk.
Risk Control
Hedge permitted only against valid underlying. Cost reduction strategies are
permitted but contingent liability hedges can be undertaken with the due approval
from CEO.
MTM reports and stress impacts shall be shared by the Corporate Treasury with the
management once a month or as required.
Individual deal size limits have been laid down, while providing the authority for
undertaking derivative transactions.
Corporate Treasury front desk must ensure that deals are executed upon
confirmation of the underlying document.
Corporate Treasury front office must ensure that the hedges taken match the
currency and tenure of the underlying.
Post deal execution by Corporate Treasury, front office must inform accurate deal
details to the Company as well as to the back office for documentation.
Back office must match all deal details sent by the bank with the deal details sent
by the front office before executing deal contracts sent by the banks.
Back office will facilitate the Company in executing the deal contracts sent by
banks.
Risk Reporting
A report will be prepared by the Back Office which will include MTM of the Interest Rate
and currency transactions on a monthly basis or as required by the management.
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Deviation & Escalation
Early Termination
Early termination for any other reason must be with prior approval of CEO.
RASCI
Consult Inform
Activity Responsible Approve Support (prior to (after
approval) approval)
FX Policy CFO CEO Corporate GCFO, Sector CFO
Updation and Treasury Corporate (SCFO)
Review Chairman
(CCM) &
Head ERM
FX and IR Finance Team CFO - - Corporate
Exposure of the Treasury
(Updation/Ch Company
anges)
Seeking CFO SCFO Corporate Head ERM -
Approval for Treasury
Interest Rate
Hedging
Deal Personnel Corporate Corporate CFO
Execution for Authorized by Treasury- Treasury
Hedging the Board Front office
FX/IR Risk
Deviation CFO CEO Corporate Head ERM SCFO
Request Treasury
MIS/ Corporate Treasury Finance - CFO,SCFO,G
Reporting Treasury - Head Team of CFO, CCM,
Back office the Head ERM &
Company CEO
Corporate Treasury must seek approval from CFO of the Company before rolling-
over the hedge.
Treasury must ensure the availability of underlying for rolling over of hedge
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Responsibility of Corporate Treasury Front, Mid & Back Office
Front Office
Corporate Treasury’s role for any hedging related decision will only be
recommendatory in nature. The execution will be initiated only after obtaining
approval from CEO as per the RASCI metric.
Hedge 100% of net forex exposure and approved Interest Rate for the entire tenure
of the exposure based on the approval as per RASCI metric.
1. The time hedging limits are made available to the Corporate Treasury.
2. The exact hedging schedule is shared by the Company with Corporate Treasury.
Provide FX rates to be considered for AOP. Such rate should be in line with the
group policy.
Provide accurate deal details to back office and the Company post the deal
execution with the bank.
Mid Office
One point Contact for group entities for periodic/timely audit by internal/statutory
auditors.
Back Office
Verify all the deal contracts as per the details provided by front office post deal
execution with the banks
To obtain quarterly statement from banks of the hedges taken & cancelled during
a quarter and outstanding at the end of the quarter to be given to the Company
Co-ordinate with the Company to obtain valid underlying and send to banks.
Co-ordinate with the Company to obtain signatures on bank contracts and send to
banks.
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Corporate Treasury Views & Market Info
Corporate Treasury will do currency or interest rate hedging as per policy post
approvals.
The Company will report its Forex and Interest exposures to Corporate Treasury.
Corporate Treasury will initiate hedging only after the exact payment/receipt
schedule is made available.
To share exact exposure schedule with treasury for hedging and inform the changes
if any within 3 working days.
To provide the documentation support to the treasury back office. Valid underlying
duly signed and stamped has to be provided to treasury back office immediately
after the hedging has been undertaken.
It is the responsibility of the CFO to obtain approval from CEO for hedge.
ISDA documentation will be carried by the Company and related legal teams.
Corporate Treasury will provide inputs, if required.
CFO shall submit to the Board/Audit Committee, a summary report on quarterly basis
on all foreign currency and interest rate hedging arrangements. This report will
include:
A statement about the status of all open Forex hedges during the period of the
report, which shall include known foreign currency assets, known foreign currency
liabilities, existing Forex hedge positions, and the resulting net foreign currency
exposure.
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A statement by the CFO as to whether or not, in his or her opinion, all of the Forex
hedges entered during the period of the report are consistent with any regulatory
or statutory policies, if applicable; and
Such other information that the Board may require or that, in the opinion of the
CFO, should be included.
b. Currency Options – All Variants as permissible under RBI guidelines from time to
time.
c. Cost reduction structures
f. Caps/Floors/Collars
All cumulative currency and interest rate hedges cannot exceed at any point of time
actual contractual obligations (underlying exposure).
Audit
Audit will be conducted by MAG every month and the report will be submitted as per
group policy guidelines.
According to the extant regulations, the company would adopt prudent accounting
treatment and disclosure standards.
While dealing with the Contract, the company would specify the rationale for the
hedge, linking the hedge to the underlying exposure, classify the type of hedge,
valuation and periodically assess the effectiveness of the hedge. For all type of
hedges, accounting will be in line with Accounting Standards.
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APPENDIX
(Subject)
Particulars Review of
Previous New Target Rate Stop-Loss Rate
of the the Decision
Decision Decision for Hedging of Hedging
Transaction (If any)
Upsides: Upsides:
Downsides: Downsides:
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ANNEXURE-I
Source: [Link]
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ANNEXURE-II
Notes
(b) Investment with Mutual Funds other than the approved list will be with the prior
approval of CEO/CCM/BCM.
(c) CFO of the Company is authorized to approve investment in AMCs which are
not in the permitted list once the AUM reaches Rs.10,000 Crs level.
(d) The Company can exceed Bank wise FD limits and can place Fixed Deposit with
Banks other than the approved Banks with the approval of CEO/CCM/BCM.
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