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INSIDE THIS REPORT
WE ARE CTOS DIGITAL ACCELERATING

Corporate Information
Corporate Overview
1
2
DIGITAL GROWTH
Corporate Structure 3
Financial Highlights 4 With more than 30 years of track
record within the industry, CTOS
Digital Berhad (“CTOS Digital” or
STRATEGIC LEADERSHIP AND GOVERNANCE “the Company”) and its subsidiaries
(“CTOS” or “the Group”) remain
Chairman’s Message 6
committed in growing the Group’s
Management Discussion & Analysis 10
data analytics, software, and
Board of Directors 20 solutions platforms capabilities via
Key Senior Management 28 organic expansions, and through
Sustainability Statement 31 strategic acquisitions of synergistic
Corporate Governance Overview Statement 62 companies in Malaysia and ASEAN.
Audit & Risk Committee Report 82
All in all, CTOS aims to provide
Statement on Risk Management & Internal Control 87
world class end-to-end digital/
credit management solutions to
OUR FINANCIALS its customer base, and ultimately
strengthen its entrenched position
Financial Reports 94
in the increasingly digital economy
within ASEAN.
OTHER INFORMATION
Analysis of Shareholdings 192

Notice of Annual General Meeting 195
Statement Accompanying Notice of
Annual General Meeting 200
Administrative Notes 201
Proxy Form 207
NAVIGATION ICONS
THE 2023 Icon can be found in this

annual report:
ANNUAL GENERAL MEETING
Web Refer
To find more information
Scan the QR code online via
attached to join the 2023 www.ctosdigital.com
DATE & TIME
Annual General Meeting
26 May 2023 (Friday) 9.30 a.m.
Page Refer
To find more related
ONLINE MEETING PLATFORM
information inside this
TIIH Online websites at https://tiih.online or https://tiih.com.my
report
CTOS Digital Berhad Annual Repor t 2022
CORPORATE INFORMATION
BOARD OF DIRECTORS AUDIT & RISK COMMITTEE
Tan Sri Izzuddin Bin Dali Nirmala A/P Doraisamy

Independent Non-Executive Chairman Chairman
Dato’ Noorazman Bin Abd Aziz
Dato’ Noorazman Bin Abd Aziz Member
Independent Non-Executive Director Su Puay Leng
Member
Loh Kok Leong
Non-Independent Non-Executive Director NOMINATION &
REMUNERATION COMMITTEE
Erick Hamburger Barraza
Executive Director and Lynette Yeow Su-Yin
Group Chief Executive Officer Chairman
Su Puay Leng Member
Independent Non-Executive Director Loh Kok Leong
Member
Lynette Yeow Su-Yin
Independent Non-Executive Director
BOARD INVESTMENT COMMITTEE
Nirmala A/P Doraisamy Dato’ Noorazman Bin Abd Aziz
Independent Non-Executive Director
Chairman
Su Puay Leng
Wong Pau Min
Member
Alternate Director to Loh Kok Leong
Loh Kok Leong
Member
COMPANY SECRETARIES REGISTERED OFFICE SHARE REGISTRAR

Joanne Toh Joo Ann Unit 30-01, Level 30, Tower A, Tricor Investor & Issuing House
[SSM PC No. 202008001119] Vertical Business Suite, Avenue 3, Services Sdn Bhd
(LS 0008574) Bangsar South, No. 8, Jalan Kerinchi, Unit 32-01, Level 32, Tower A,
59200 Kuala Lumpur Vertical Business Suite, Avenue 3,
Saw Hui Ying Tel. No.: +603 2783 9191 Bangsar South, No. 8, Jalan Kerinchi,
[SSM PC No. 202108000465] 59200 Kuala Lumpur
(MAICSA 7065214) CORPORATE OFFICE Tel. No.: +603 2783 9299
Unit 01-12, Level 8, Tower A,
AUDITORS Vertical Business Suite, Avenue 3, STOCK EXCHANGE LISTING
PricewaterhouseCoopers PLT Bangsar South, No. 8, Jalan Kerinchi, Main Market of Bursa Malaysia
Level 10, 1 Sentral, 59200 Kuala Lumpur Securities Berhad (5301)
Jalan Rakyat, Kuala Lumpur Sentral, Tel. No.: +603 2722 8888
50470 Kuala Lumpur Website: www.ctosdigital.com
Tel. No.: +603 2173 1188 E-mail: [email protected]
Partner-in-charge: Pauline Ho
Professional qualification:
Member of MIA
(MIA membership No.: CA11007)
1
WE ARE CTOS DIGITAL
CORPORATE OVERVIEW
About CTOS Digital Berhad Our solutions and services are widely used by the
country's banking and financial institutions, insurance and
telecommunication companies, large corporations, small
CTOS Digital Berhad is the holding medium enterprises as well as consumers for self-check.
company of CTOS Data Systems We provide solutions across three core customer segments:
Sdn Bhd, the leading Credit
Reporting Agency in Malaysia.
Founded in 1990, we offer a broad Key Account segment, which includes a significant
number of leading financial institutions and
suite of innovative digital products corporates;
and credit risk management
solutions and services giving us a
solid platform to thrive not just in Commercial segment, which includes a growing
credit reporting, but also in digital number of small-and-medium-sized businesses
locally and international customers located across
credit decisioning across Southeast Asia Pacific and Europe; and
Asia. Aside from having a presence
in Malaysia, CTOS Digital holds
24.83% stake in Business Online
Direct-to-Consumer (D2C) segment which are
Public Company Limited (BOL), the individual customers registered with CTOS ID.
leading credit information and risk
management provider in Thailand.
MISSION AND VISION
Our mission is to empower individuals and

businesses with the confidence to make
sound credit decisions through access to
data and insights at greater ease and speed,
leading the community to better financial health. Our
vision is to make Malaysia a centre of excellence for
credit reporting in ASEAN.
ACCELERATING DIGITAL GROWTH
CTOS has recorded solid growth in revenue and profit over the years, and we will
continue to drive growth trajectory through our innovative product and services,
harnessing acquisition synergies, expanding into new verticals and deepening the
market penetration of our digital solutions.
Technology, data, intelligent analytics and innovation will drive the future of the digital
economy and we are well-positioned to take advantage of the many opportunities that
lie ahead.
Please visit our website www.ctosdigital.com
2
CORPORATE STRUCTURE
CTOS DATA SYSTEMS

100% SDN BHD
199201016147 (247651-H)
CTOS DIGITAL
IS THE HOLDING
CTOS BUSINESS
100% SYSTEMS SDN BHD COMPANY OF AND
200401011532 (650035-U)
HOLDS INTERESTS
CTOS IDS
100%
SDN BHD
200701013358 (771363-P)
IN SOME OF
ASEAN’S LEADING
100%
AUTOMATED MAIL
RESPONDER SDN BHD
CREDIT REPORTING
AGENCIES
200101017695 (553452-V)
CTOS BASIS
100% SDN BHD
199401030027 (315708-X)
JURIS TECHNOLOGIES
49% SDN BHD
200301016066 (618486-X)
ENFO
SDN BHD
100% 10%
200801032960 EXPERIAN INFORMATION
(834297-P) SERVICES (MALAYSIA)
26%
CTOS INSIGHTS SDN BHD
SDN BHD 200001029664 (532271-T)
100% 16%
197301001965
(15478-D)
RAM HOLDINGS
57.675% BERHAD
199001016426 (208095-U)
BUSINESS ONLINE
PUBLIC COMPANY
24.825%
LIMITED
0107546000407
3
WE ARE CTOS DIGITAL
FINANCIAL HIGHLIGHTS
5 YEARS FINANCIAL HIGHLIGHTS
FINANCIAL SUMMARY (RM'000) 2018 2019 2020 2021 2022
Revenue 110,465 129,141 133,225 153,166 194,781

Gross Profit 92,939 107,542 115,716 133,976 164,627
EBITDA 35,081 48,537 53,652 66,434 97,997
Share of Profits of Associates - 761 1,785 7,217 23,274
NOTES
* Includes discontinued operations

** Normalised PATAMI is calculated as profit for the financial year attributable to Shareholders plus/less, where applicable
(i) losses from CIBI Philippines, Inc (“CIBI”) and CIBI Holdings Pte Ltd;
(ii) costs related to our acquisitions of Experian Information Services (Malaysia) Sdn Bhd, CIBI, CTOS Basis, Business Online Public Company
Limited, RAM Holdings Berhad and Juris Technologies Sdn Bhd;
REVENUE Key Accounts Commercial - Malaysia
YoY growth Commercial banks and leading Small-medium enterprises

large corporation within in Malaysia
financial institutions, insurance,
+27% e-commerce and others
RM194.8
million
PROFIT BEFORE TAX

38%
YoY growth
Revenue
Segmentation 47%
+62%
FY2022
RM85.7
million
8%
DIVIDEND PER SHARE 7%
Direct-to-Consumer Commercial - International
1.875
Individual customers International customers via
CTOS Basis Sdn Bhd
sen (“CTOS Basis”)
Based on dividend per share declared in respect

of FY2022.
4
FINANCIAL HIGHLIGHTS
FINANCIAL SUMMARY (RM'000) 2018 2019 2020 2021 2022
PBT 31,791 41,246 42,796 53,043 85,681

PATAMI* 29,656 39,009 39,187 43,122 71,718
Normalised PATAMI** 30,376 41,120 41,464 54,602 85,360
Basic Earnings per Share (sen) 1.5 2.0 2.0 2.1 3.1
(iii) share-based payment expense;

(iv) realised and unrealised foreign exchange losses/(gains) on USD borrowings; and
(v) incremental income tax expense of CTOS Data Systems Sdn Bhd (“CDS”) recognised based on the statutory tax rate of 24% for the period from
1 July 2021 to 31 December 2021 as compared to the tax payable by CDS in accordance with the tax exemption granted for the tax relief
period under the Pioneer Status incentives
Revenue EBITDA
(RM’000)
YoY growth
18’ 110,465
129,141
19’
+48%
20’ 133,225
21’
22’
153,166
194,781
RM98.0
million
Profit Before Tax
(“PBT”) (RM’000) NORMALISED PATAMI
YoY growth
18’ 31,791
19’ 41,246
+56%
20’ 42,796
RM85.4
21’ 53,043
22’ 85,681
million
Normalised Net Profit Attributable to Shareholders
(“Normalised PATAMI”) (RM’000) DIVIDEND PAYOUT
18’ 30,376
19’ 41,120
20’ 41,464
21’
22’
54,602
85,360
60.4% of PATAMI
RM43.3 million
Based on dividend declared in respect of FY2022.
5
STRATEGIC LEADERSHIP AND GOVERNANCE
CHAIRMAN’S MESSAGE
"CTOS Digital’s business is

underscored by the mission of
empowering individuals and
organisations with the confidence
to make sound credit decisions.
We continued to relentlessly focus
on innovation and technology in
2022 to harness the power of data,
successfully closing the year with
a new record performance while
increasing our market share."
HIGHLIGHTS OF FY 2022
All key business units

registered strong
double-digit revenue growth.
We wrapped the year with an
impressive
66%
year-on-year jump in net profit
to RM71.7 million.
Profit After Tax and Minority

Interests (PATAMI)
71.72 mil
Dear Shareholders,
Our business has demonstrated its relevance and resilience in the face of external
43.12 mil
volatilities. The adoption of credit risk management and innovative digital solutions is
39.18 mil
39.00 mil
more crucial than ever before as everyone seeks to make more informed decisions
29.65 mil
during challenging circumstances and automate their processes to drive business

growth. Transparent credit information is a prerequisite for sound risk management
and financial stability.
We had a productive year in 2022, concluding several acquisitions which will open
new opportunities for the future, while driving impressive organic growth. Our team
worked diligently to deliver another outstanding year for CTOS Digital, and I am proud
of their accomplishments. It is my great privilege to present to you the Annual Report
and Financial Statements for the financial year ended 31 December 2022. 22’ 21’ 20’ 19’ 18’
6
OVERVIEW PERFORMANCE REVIEW AND DIVIDENDS
In 2022, we faced yet another unconventional period, We achieved stellar growth in FY2022 and performed
marked by an exceptionally turbulent external well despite challenging external headwinds. Significant
environment. Despite the challenges, our unwavering progress was made in executing our strategy and this
focus remained on creating a positive impact for our resulted in another record performance. Revenue rose by
clients, consumers, and society by transforming data 27% to RM194.8 million versus RM153.2 million a year ago,
into analytical tools and reports that enable informed underpinned by solid organic and inorganic growth. All key
decision-making. business units (Key Accounts, Commercial, and Direct-to-
Consumer) registered strong double-digit revenue growth.
Throughout the year, we witnessed an accelerating We wrapped the year with an impressive 66% year-on-year
shift towards digital adoption, which bodes well for jump in net profit to RM71.7 million.
our business. As the economy digitalises, data assets,
analytics, and technology have become increasingly It is also worth noting that CTOS ended the year with a
vital, making our products and services even more strong balance sheet and a comfortable net gearing
relevant. The emergence of digital banking, buy-now- ratio of 0.26 times. We made efficient use of the cash we
pay-later (“BNPL”) services, and other Fintech activities generated, balancing the need for organic investment in
have paved the way for opportunities, both now and in human resources and innovation, inorganic expansion via
the future. Our efforts were channelled into helping our acquisitions and returns to shareholders through dividends.
clients drive their digital transformation.We also continued In line with our improved performance, the total dividend
to invest in our people and built capacities across declared in FY2022 was RM43.3 million compared to RM26.0
our business, including our technology, sophisticated in FY2021, representing a dividend payout ratio of 60%.
analytics, and data security. Our track record is evidence
that we are on the right track, and our business model
remains robust in both good and challenging times. With In line with our improved performance,
our superior data assets and analytic capabilities, we are the total dividend declared in FY2022 was
poised to capture a wide array of opportunities ahead.
RM43.3 million compared to RM26.0 in FY2021,
For more information, please refer our Management
Discussion & Analysis on page 10.
representing a dividend payout ratio of 60%.
7
SUSTAINABILITY IN CTOS DIGITAL
CTOS Digital’s commitment towards sustainability is intertwined with

our mission of empowering both individuals and businesses with the
confidence to make sound credit decisions through access to data and
insights, leading the community to better financial health.
Since our listing in 2021, we continued making steady headway and have
recently disclosed our sustainability blueprint, roadmap and set various
targets to steer our ESG advancement which includes working towards the
direction of achieving Net Zero by 2050. We are proud to be Malaysia’s first
credit reporting agency to receive an ESG rating from FTSE. The admission
into the FTSE4GOOD Bursa Malaysia ("FTSE4GOOD") and FTSE4GOOD
Bursa Malaysia Syariah ("F4GBMS") Indexes reinforces that we are on the
right track. We secured a 4-star ESG rating, placing us among the Top 25%
of public listed companies in the FTSE Bursa Malaysia EMAS Index.
We’re passionate about sharing our ESG story, and we’re on a journey to
UPHOLDING GOVERNANCE AND
improve our ESG disclosure.
INTEGRITY
The Sustainability Report set out from pages 31 to 61 comprehensively details our
sustainability performance, key highlights and achievements for the year under review. CTOS Digital continues to be a strong
advocate of good corporate governance
practices by constantly incorporating
improvements and benchmarking
We secured a 4-star ESG rating, placing us among the ourselves against international best
Top 25% of public listed companies in the FTSE Bursa practices. Your board recognises the
utmost significance of corporate
Malaysia EMAS Index
governance and internal control. We are
vigilant in broadening and enhancing the
governance framework to facilitate long-
term growth for an agile and responsible
business. In our path to sustainable
growth and value creation, we are
committed to transparency, pro-active
stewardship practices and continuous
open engagement with all stakeholder
groups.
Data privacy and security are becoming

increasingly prevalent topics with the
growth of the digital economy and online
transactions over the last few years. Given
the nature of our business, we need to
effectively govern our data management
capabilities to prevent any potential
leakages. The continued investments
in our Risk Management in Technology
(RMiT) and cybersecurity capabilities
enable us to stay ahead by building
up intelligent and reliable data security
systems to prevent the increasingly
sophisticated cyberattacks. Keeping
our sensitive customer data safe is the
cornerstone of a sustainable business.
8
LOOKING AHEAD NEW LEADERSHIP & ACKNOWLEDGEMENTS
Erick Hamburger’s appointment as Group Chief Executive Officer commenced

on 1 May 2022, alongside the retirement of Dennis Martin. The Board wants to
We are starting 2023 from
take this opportunity to thank Dennis for his service and wish him well in his
a position of strength and future endeavours. Erick brings over 28 years of corporate strategy expertise
have a clear strategy that and international digital solutions experience. His leadership roles in credit
bureaus across several emerging economies will undoubtedly benefit CTOS
will allow us to capture
Digital. Erick was also appointed to the board as an Executive Director on
the potential of new 30 September 2022.
verticals and exciting
I also wish to acknowledge Garris Chen Thai Foong, who retired from her
addressable markets. position as Group Chief Financial Officer, and welcome Chiam Hsing Chee,
who stepped into this role in January 2023.
In addition, our team endeavours
to increase our wallet share via My sincere gratitude to our shareholders, customers and business partners for
upselling and cross-selling opportunities their valuable trust and support, and my heartfelt thanks to my fellow board
within business units and across members for their contributions. To our employees - your talent, commitment
related companies, including extracting and enthusiasm drive our success and on behalf of the Board, I thank you
synergies from our highly sincerely for all your efforts in delivering our achievements. Last but not least,
complementary acquisitions. We expect I would like to express my gratitude to regulatory authorities and government
heightened service penetration and agencies for their assistance.
customer base expansion, driven by
analytics insights and digital solutions.
As we move to 2023, we shall begin with renewed
We are also mindful of external determination and commitment to achieve our goals and
headwinds which will come our
targets. With the growing importance of data and analytics,
way. In the year ahead, inflation and
higher interest rates are expected to acceleration of the digital economy and increasing financial
dominate the global and domestic literacy, we are optimistic about our future prospects.
landscapes. While we are monitoring
macroeconomic trends, we believe
our strong track record, superior data,
and technology assets will enable
us to continue delivering value for all
our stakeholders throughout every
economic cycle. After not just surviving
but thriving in a year of unprecedented Tan Sri Izzuddin Bin Dali
disruption, I have great confidence in Independent Non-Executive Chairman
our team and the future of our business. CTOS Digital Berhad
9
MANAGEMENT DISCUSSION
& ANALYSIS
FOREWORD BY OUR GROUP CEO
"I am truly delighted to introduce

CTOS Digital’s 2022 Annual Report,
my first as the Group CEO. Since
assuming this role a year ago in May
2022, it has become increasingly
clear to me that we are just at the
cusp of growth, looking at exciting
opportunities as the leading credit
reporting agency in ASEAN, where
the landscape is undergoing massive
shifts towards digital economy."
2022 was a transformative year for consumers FY2022 KEY HIGHLIGHTS

and businesses. The irrevocable path towards
digitalisation is becoming increasingly evident, 1
Customer Acquisition
and along with it comes the need for better Solid growth across all customer segments
financial literacy and credit decisioning.
Our mission is to empower individuals and 2
Growth in Data Analytics & Digital Solutions
businesses with access to crucial data and Strong double digit revenue uplift
insights to make sound credit decisions
3
Synergistic Acquisitions
confidently, at greater ease and speed. This
Concluded acquisitions & increased stake in several
purpose is now more relevant than ever, as we
associate companies to pursue tactical growth and broaden
help our clients and subscribers prepare for the
product offering
digital future which is coming to us at full speed.
4
Tax Incentive
Helping people and organisations thrive in the
Received approval-in-principle for extension of Pioneer Status
digital economy will underpin our growth in
for 5 years until November 2026
the coming years. Data assets, analytics, and
technology have become vital as the economy New Skilled Hires
5
digitalises, making our products and services Strengthened the team especially in the areas of data
increasingly critical. The opportunities for credit, analytics, cybersecurity and IT transformation
driven by the rise of the digital economy, are
not only for fintech players but also for the Partnership & New Products
6
growth of incumbent credit providers that are Broadened our partnership ecosystem & launched new
likewise in the process of enhancing their digital products to increase visibility and penetrate new verticals
capabilities. Our addressable markets are
large and expanding, and we are well-placed
7
Sustainability
to take advantage of new and compelling Included as a FTSE4GOOD constituent in Dec 2022 with a
opportunities. 4-star ESG rating
10
& ANALYSIS
BUSINESS OVERVIEW
CTOS Digital is the holding company of and holds interests in some of ASEAN’s leading credit reporting agencies, with a
presence in Malaysia and Thailand. The Company’s wholly-owned subsidiary CTOS Data Systems Sdn Bhd (“CTOS Data
Systems” or “CDS”) is the leading Credit Reporting Agency (“CRA”) in Malaysia, with an estimated total market share by
revenue increasing from 71.2% in 2020 to 72.7% in 2021. Founded in 1990, the group offers a broad suite of innovative digital
products and credit management solutions and services across every stage of the customer credit lifecycle.
CUSTOMER DESCRIPTION DIGITAL SOLUTIONS OFFERED

LIFECYCLE STAGE
Identification When a customer identifies a • CTOS CreditFinder

prospective business or consumer • CTOS Tenant Screening Report
for a new business relationship or • Company Search
transaction. • Business Listings
• Customised Bulk Data Sales
Customer/ The initial step of determining whether • CTOS IDGuard

vendor onboarding a prospective customer or vendor • CTOS electronic Know-Your-Customer
is suitable for a new transaction or (“eKYC”)
business relationship based on their • CTOS Application & Decisioning (“CAD”)
past business and financial dealings. • CTOS Credit Manager
• CTOS Tenant Screening Report
Application After a prospective customer is • CAD

and decisioning onboarded, the point in time when a • CTOS Scores
business decides whether to extend • CTOS Credit Manager
credit to the prospective customer. • CTOS Data Systems Reports, CTOS Basis
Reports and External Reports
• CTOS Basis
• CTOS e-Trade Reference (“eTR”)
• eTR Plus
Management Within a business’ portfolio of existing • CTOS Credit Manager

and monitoring customers, there are opportunities • Comprehensive Portfolio Review
to generate new and additional • CTOS Scores
sources of revenue as well as potential • CTOS Portfolio Analytics and Insights
areas of credit risk. Effective portfolio • CTOS IDGuard
management, analysis and monitoring • CTOS SecureID
can better identify these opportunities
and risks.
Recovery The stage in the customer lifecycle • CTOS Credit Manager

when a business must manage its • eTR
relationship with a customer that can • eTR Plus
no longer meet its credit obligations.
Through our reports, products and solutions, we help consumers to better understand their credit position, gain access
to financial services and protect themselves against fraud and identity theft. We also help businesses understand their
customers better and improve onboarding experience while minimising credit and fraud risk.
11
& ANALYSIS
We mainly serve customers across three key segments:
KEY ACCOUNTS
Accounting for 38% of FY2022 revenue, this segment consists of commercial banks and other leading large
corporations within the financial institutions, telecommunications, insurance, e-commerce, and other relevant industries.
The Group serves approximately 470 Key Accounts customers.
COMMERCIAL
Contributing 54% of CTOS Digital’s FY2022 topline, this segment comprises two further categories:
• Commercial-Malaysia refers to Small and Medium Enterprises (“SMEs”) customers.
• Commercial-International includes international customers located across Asia Pacific and Europe, contributed by
CTOS Basis which the Group acquired in 2021.
In total, the Group has approximately 20,000 commercial customers using its solutions and services.
DIRECT-TO-CONSUMER (“D2C”)
The Group’s fastest-growing segment which brought 8% to FY2022 revenue, this segment comprises individual customers
who proactively seek access to their credit information in order to more effectively manage their credit health and
financial well-being.
The Group has approximately 2.5 million users registered for a self-check account.
ASSOCIATE COMPANIES
The Group also holds stakes in several associate companies which positions us favourably in capturing the tremendous
opportunities in the new digital economy.
24.825% in its Thailand-based associate, Business Online PCL (“BOL”), the leader in
business decision-making solutions in Thailand. BOL is listed on the Stock Exchange of Thailand
and offers a comprehensive online business information platform and various customer
lifecycle, risk management, business intelligence, and data management solutions;
49% in Juris Technologies Sdn Bhd, a leading Malaysian-based fintech company that
specialises in enterprise-class software solutions covering end-to-end credit lifecycle
management; and
57.675% in RAM Holdings Berhad, a leading provider of independent credit ratings,

research, training, risk analysis, ESG analytics, and bond pricing.
12
& ANALYSIS
REVIEW OF FINANCIAL PERFORMANCE
Statement of Comprehensive Income
We reported another year of exceptional performance in the financial year ended 31 December 2022 (“FY2022”), registering
strong momentum across both top and bottom lines fuelled by organic and inorganic growth. We are executing well against
our long-term plans to meet and deliver value to our shareholders.
While FY2022 carried various uncertainties from geopolitical tensions to inflationary

pressures, we navigated it with exceptional success and momentum, delivering a
record-breaking performance owing to solid execution. 27%
YoY Revenue Growth
FY2022 FY2021 YoY Change Demonstrating weatherproof
Revenue Segmentation (RM ‘000) (RM ‘000) (%) business against a challenging
economic backdrop
- Key Accounts 74,767 53,589 +39.5
-
-
Commercial: Malaysia
Commercial: International
91,415
13,320
83,205
7,260
+9.9
+83.5
66%
YoY jump in PATAMI
- Direct-to-consumer 15,279 9,112 +67.7 Powered by BAU performance
Total Revenue 194,781 153,166 +27.2 and associate contributions
We achieved consolidated revenue of RM194.8 million, which translated to a growth Rewarding Shareholders
of 27.2% as compared to RM153.2 million in the previous financial year ended
31 December 2021 (“FY2021”). This was driven by broad-based strength across all We are grateful for the support of our
core business segments: Key Accounts, Commercial and Direct-to-Consumer, which valued shareholders and are committed
recorded double-digit growth in FY2022. to rewarding your loyalty through
dividends. We are proud to state CTOS
We registered a gross profit of RM164.6 million, an increase of 22.9% from the previous Digital declared total dividends of 1.875
year. Gross profit margin for the year was 84.5%. The growth in profit before tax (“PBT”) sen per share in respect of FY2022, in the
outstripped revenue, increasing by 61.5% to RM85.7 million. Effective tax rate for the form of four interim dividends:
year was 16.3% and we wrapped FY2022 with a record profit after tax and minority
interest (“PATAMI”) of RM71.7 million, an increase of 66.3% measured against FY2021. • first interim dividend of 0.325 sen per
Share of profits from associates amounted to RM23.3 million as compared to RM7.2 share paid on 10 June 2022;
million in the preceding year. Our normalised1 PATAMI of RM85.4 million exceeded the • second interim dividend of 0.59 sen
management’s target of RM75-80m for FY2022. CTOS Digital’s business has proven to per share paid on 13 September
be relevant and resilient in the face of external volatilities – the importance of data is 2022;
more evident than ever as everyone seeks to make more informed decisions during • third interim dividend of 0.60 sen per
challenging circumstances. share paid on 14 December 2022;
and
Statement of Financial Position • fourth interim dividend of 0.36 sen per
share paid on 15 March 2023.
CTOS Digital’s total assets stood at RM735.2 million as of 31 December 2022, an
increase from RM360.6 million at the end of the previous year. We completed a This translates to a total dividend payout
private placement of 110 million new shares in March 2022 which raised RM173.8 of RM43.3 million, representing a payout
million, used to partially fund the acquisition of 49% interest in JurisTech and an ratio of 60.4%, in line with our targeted
additional stake in BOL. The increase in our total assets was mainly contributed by payout ratio of at least 60% of our
our investments in associates this year. PATAMI attributable to the owners of our
Company.
We also raised borrowings to partially fund the acquisition of JurisTech and RAM. As of
31 December 2022, our total borrowings (excluding lease liabilities) were RM149.5 million
and our net gearing ratio at the end of the year stood at a comfortable 0.26 times.
1
Normalized PATAMI added back components including costs related to acquisitions, incremental income tax expense based on the statutory tax
rate of 24% prior to renewal of pioneer status incentives and write back of prior year tax on approval of transition to the MSC Malaysia Status Services
Incentive for the period from 1/7/2021 to 8/11/2021
13
& ANALYSIS
OPERATIONAL REVIEW
Updates on Business Segments
Key Accounts Commercial
Our clients in this segment consist of The bulk of our customers in the commercial segment are local SMEs
commercial banks and other leading which typically require face-to-face interaction during the onboarding
large corporations within the financial process. During the Movement Control Order in 2021, the operations of our
institutions, telecommunications, insurance, Commercial customers were momentarily impacted and this progressively
e-commerce, and other relevant industries. turned around in FY2022 when the economy re-opened. With this, our
The number of key account customers activation rate in FY2022 improved by 28% as compared to last year.
grew to 470 as of 31 December 2022, from
circa 430 in the preceding year. We have The revenue contribution of the commercial segment increased by 15.8%
a 100% client retention track record for this in FY2022 and our churn rate continued to improve from an already low
segment. single-digit percentage. There was also improvement in average ARPU
through a selective 6% price adjustment during the second quarter of the
Revenue from Key Accounts grew by an year, coupled with cross-selling/upselling initiatives.
impressive 39.5% in FY2022, driven by
increased adoption of our digital solutions
such as eKYC, CAD, and IDGuard. During Our activation rate in FY2022 improved by 28% as
the year, we launched end-to-end Digital compared to last year.
Money Lending solutions powered by
CTOS & JurisTech and onboarded 3 digital
money lenders. D2C
The emergence of digital banking, buy- CTOS Digital’s total D2C customer base grew by 47% to 2.5 million registered
now-pay-later services, and other fintech members from 1.7 million in the previous year. This is the fastest-growing
activities will provide growth and business segment with a revenue jump of 67.7% YoY. The increase was driven by
opportunities for our Group. We are making improved awareness via digital channels and various marketing activities
good progress in our discussions with the during the year. We also broadened our partnership ecosystem to
successful digital bank licensees and increase visibility and penetrate new verticals. Some partnership programs
in the fourth quarter of FY2022, we were launched in FY2022 included iBilik, PolicyStreet, and Property Guru.
officially appointed by a digital bank
licensee to implement an e-onboarding
system. We expect to see greater headway CTOS Digital’s total D2C customer base grew by 47% to
in the coming months, leading to positive 2.5 million registered members from 1.7 million previously.
contributions from digital banks in the
coming financial year.
The emergence of digital

banking, buy-now-pay-later
services, and other fintech
activities will provide growth
and business opportunities for
our Group.
14
& ANALYSIS
STRATEGIC ACQUISITIONS RENEWAL OF PIONEER STATUS
CTOS Data Systems (“CDS”), the main

operating subsidiary of CTOS Digital, was
2022 was a busy year at CTOS Digital, marked by several awarded in 2016 the ten-year pioneer status
strategic corporate activities aimed at future-proofing incentive by the Malaysia Digital Economy
Corporation (“MDEC”) under PIA 1986
our business. Financially, we are well positioned with a
for MSC Malaysia Qualifying Activities, at
strong balance sheet which allows us to conclude several which tax exemptions are granted on the
acquisitions, with an aim of balancing shareholder company’s statutory income. The tax relief
period was awarded between the period of
returns while pursuing tactical growth.
November 2016 to November 2021, being the
first five years of the ten-year tenure. Pursuant
to the Grandfathering and Transitional
In March 2022, we completed the acquisition of 49% equity interest in Juris
Guidelines which became effective on
Technologies Sdn Bhd (“JurisTech”). With JurisTech now part of our Group,
1 January 2019, the tax relief period for the
we can offer the best-in-class credit data, software solutions, and analytics
first five years lasted until 30 June 2021, after
services to bring to the market a stronger end-to-end digital lending
which CDS requires approval from MDEC
solution proposition, establishing ourselves as a one-stop solution for
to enjoy the tax incentives throughout the
financial institutions. We are starting to reap the synergies of this acquisition
transitional period.
and have made successful inroads into the digital moneylending space
by launching a CAD for moneylenders in collaboration with JurisTech.
On 26 May 2022, CDS received the approval
letter from the Malaysian Investment
To boost our regional presence, CTOS Digital increased its shareholdings
Development Authority (“MIDA”) via MDEC
by 2.175% in BOL Online PLC (“BOL”) during the year, and we now hold
on the Transition to the MSC Malaysia
24.825% of BOL which is listed on the Stock Exchange of Thailand. With
Status Services Incentive under Income
BOL’s strong market share and presence among large corporations in
Tax (Exemption) (No.10) Order 2018 [P.U.
Thailand, we hope to leverage greater cross-selling and sharing of best
(A) 389/2018], Income Tax Act 1967. The
practices between both companies.
Transition tax exemption period was from
1 July 2021 to 8 November 2021. With this
At the start of the year, we held an 8.1% stake in RAM Holdings Berhad
approval, there was an immediate reversal
("RAM") and progressively raised it to 57.675%. This was funded through
of approximately RM5.1mil in tax provisions.
a combination of internally generated funds and borrowings. Despite
our majority equity ownership in RAM, it will continue to be an associate
On 28 July 2022, CDS further received an
company of CTOS Digital. As a credit rating agency, RAM's management
approval in principle from the Ministry of
and operations will remain independent without influence from its
Finance (“MOF”) via MDEC on the extension
shareholders. We would like to state unequivocally that CTOS Digital will
of income tax exemption under Section
respect RAM's independence and integrity in all matters.
127(3)(b) of the Income Tax Act 1967. The
approval in principle is applicable until the
Our focus will be to work closely with RAM to strengthen its capacity to
amendment of provisions for the extension
develop innovative products and solutions designed particularly for SMEs.
of the second five-year period under P.U. (A)
This will provide more impetus for the growth of SMEs and support their
389/2018 is approved and gazetted. With
efforts to access growth capital. It is our intention to help grow the SME
this approval, CDS will enjoy tax exemption
industry in Malaysia, which forms the backbone of our economy.
for further 5 years, effective from 9 November
2021 until 8 November 2026. The additional
We have now put in motion plans to realise the growth potential from these
tax provided for the period 9 November
acquisitions to maximise synergies within the Group, while broadening
2021 to 31 December 2022 is RM14.6 million.
and strengthening CTOS Digital for the future.
This will be written back upon gazettement
of Income Tax Exemption Order.
15
& ANALYSIS
RISK FACTORS
1 Cybersecurity risks 5 Regulatory Risks
As the Company operates in an environment surrounding Our business and the business of our associates are subject to
the sensitive nature of information, we may be subject to various governmental regulations, laws, and orders, including
efforts by unauthorised persons and/or entities who may the CRA Act in Malaysia. These laws and regulations are
attempt to obtain access to our system and data, or inhibit complex and may change from time to time, and a failure
our ability to deliver solutions to our customers. A breach to comply with them could subject us and our associates
of our computer systems, software, networks, or other to civil or criminal penalties or other liabilities. Changes in
technology assets may result in a material loss of business applicable legislation or regulations that restrict or dictate
and/or significant harm to reputation, as well as have an how we or our associates collect, maintain, combine, and
adverse effect on our financials and operations. disseminate information, or that require us or our associates
to provide services to consumers or a segment of consumers
2 Geographical, Social, Economic, and Political risks without charge, could adversely affect our or our associates’
businesses, financial condition or results of operations.
With business activities and investments in Malaysia and
Thailand, CTOS Digital is subject to vagaries in the socio-
political environments in the respective geographical
markets, including changes in political leadership, risks of
war, civil unrest and terrorism, risk of natural disasters, power
shutdown or shortages, as well as potential restrictions on
repatriation of dividends or profits.
3 Foreign Currency Exchange Rate risks
The Company’s share of profit or loss from BOL is denominated

in THB while CTOS Basis’ revenue is mainly denominated in
USD, Euro and Singapore Dollars (SGD). CTOS Data Systems
also pays certain expenses in USD. Hence, our profit margins
may be affected by the exchange rate fluctuations of
these currencies against RM. Our financial statements and
reporting currency are denominated in RM. Consequently,
exchange rate losses resulting from the depreciation of THB,
USD, Euro and SGD against RM will have an adverse effect on
CTOS Digital’s financial results.
Loss of CTOS Data Systems’ Pioneer Status and/or

4
MSC Malaysia status
If the Pioneer Status of CTOS Data Systems is revoked or

not renewed, CTOS Data Systems’ statutory income will
be subjected to the prevailing statutory tax rate of 24.0%
instead of the lower effective tax rate (5.3% for the financial
year ended 31 December 2020). The Pioneer Status is also
conditional upon CTOS Data Systems’ MSC Malaysia Status
remaining valid. Hence, if CTOS Data Systems’ is unable to
continue to comply with the requirements prescribed by
MDEC, CTOS Data Systems may lose its MSC Malaysia Status,
and ultimately its pioneer status.
16
& ANALYSIS
STRATEGIC FOCUS AREAS
We have established growth strategies and focus areas in our quest to deliver sustainable profit growth. We are starting
2023 from a position of strength with well-defined strategies which will allow us to capture the potential of new verticals and
addressable markets, especially with the rise of the digital economy. With this, the management is targeting another strong
year in 2023 with normalised PATAMI between RM100-105 million. The outline of our focus areas is set out below:
BAU DIGITAL PROPRIETARY NEW HARNESSING

GROWTH ECOSYSTEM DATABASES VERTICALS SYNERGIES
Large Deep insights Enhance Expanding To integrate our

addressable and automation coverage of into new acquisitions to
market in our through fortifying alternative industries such realise each
key business data analytics, proprietary as Automotive, company’s
segments with fraud & ID databases Fintech, growth potential
upselling and and platform to offer more Insurance, Real and maximize
cross selling capabilities comprehensive Estate with refined synergies
opportunities resources with products and
improved quality services
of reports
BAU Growth Digital Ecosystem
We are a one-stop, fully integrated credit management The behaviour of consumers across the world is changing,
and digital solutions service provider offering end-to-end and the shifts to online spending and other services have
credit management and lending solutions. This is a key only been accelerated by the COVID-19 pandemic. New
competitive advantage for us and we intend to continue technologies will play a huge role in driving credit reporting
developing and extending our ecosystem to cement our growth. This shift will increase the need for real-time credit
market share leadership in Malaysia. We work closely with decisioning in digital ecosystems, creating significant
our customers to facilitate the digital transformation of their opportunities for us. Currently, our suite of credit management
credit management processes, by developing new value- solutions is already serving many of the P2P lenders in
added digital solutions which are customised to customers’ Malaysia, key BNPL players, and a number of local e-wallet
needs. This further differentiates us from most of our local companies. With the increased trend towards digital banking
and regional peers. Over the past three years, we have led by banks and fintech companies such as payment
launched CTOS eKYC, CTOS SME Score, CTOS IDGuard, CAD, companies and P2P lenders, our digital solutions including
CTOS Tenant Screening Report and CAD for moneylenders. but not limited to, CTOS eKYC, CAD, CTOS Portfolio Analytics
These new launches span across three customer lifecycle and Insights, will be well placed to cater to the digitalisation
stages and we expect them to further increase revenue of the banking economy. We are making good progress in
contributions from our Key Accounts and Commercial our discussions with the successful digital bank licensees
customers. We will continue to deepen wallet share via and in the fourth quarter of FY2022, a digital bank licensee
upselling and cross-selling opportunities within business officially appointed us to implement an e-onboarding
units and across related companies, including extracting system. We expect to see more significant headway in the
synergies from our highly complementary acquisitions. We coming months, leading to positive contributions from digital
expect heightened service penetration and customer base banks in the next financial year.
expansion, driven by analytics insights and digital solutions.
17
& ANALYSIS
STRATEGIC FOCUS AREAS (CONTINUED)
Proprietary Databases Harnessing Synergies
CRAs in Malaysia compete on the extent of their databases We are financially well positioned, with a strong balance
and range of value-added services. Over the last 30 years, sheet and funding liquidity, along with a proven record of
we have accumulated an extensive credit database of converting operating profit to cash. This allows us to focus
individuals and businesses in Malaysia. Despite our access on key investment areas, balancing shareholder returns
to a wide variety of databases from various public and with the need for constant innovation, as well as investing
proprietary sources in Malaysia and internationally, we in organic business growth while also pursuing strategic
continue to deepen and broaden our data sources to acquisition opportunities. Reinvesting our strong cash
provide unique insights to our customers. We have one of flow in accretive and strategic acquisitions was a central
the largest electronic trade reference database in Malaysia. part of our growth strategy. Our M&A priorities are clear
We are also expanding the information we collect to include and focused on expanding and strengthening our core
alternative data sources such as eTR Plus. Additionally, business. We typically seek acquisitions of digital solutions
our CTOS Enhanced Database ("CED") contains litigation that complement ours and have direct cost and capability
and bankruptcy proceeding information shared by our synergies with our digital solutions as well as businesses
subscribers such as banks, non-bank financial institutions, with significant growth potential, enabling us to expand our
telecommunication companies, and law firms. digital solutions offering, achieve value chain integration for
our existing segments and customers, and facilitate entry
Our proactive sourcing of new databases further enhances into new verticals mentioned above.
our proprietary database, forming the groundwork necessary
to provide our full suite of digital solutions. By consistently 2022 was a busy year where we acquired 49% of JurisTech
focusing on the depth and quality of information provision, and raised our stakes in BOL and RAM. We are focusing on
we believe we can establish an even higher barrier to entry, integrating these acquisitions and executing our synergy and
allowing us access to high-quality information and enabling growth plans to leverage our data, products, and capabilities.
us to deliver greater value to customers. Our continued We have made clear progress with JurisTech, embarking on
investments in data and analytics have also allowed us to joint account planning and carved successful inroads into
better provide customer-driven digital solutions and increase the digital moneylending space by onboarding new clients.
our engagement with any customer across our suite of We plan to use the next 1-2 years to realise each company’s
digital solutions. It has also enabled us to be quicker, more growth potential and maximise synergies. We are excited as
efficient, and more cost-effective across the process chain, we will be reaping the fruits of our acquisition imminently.
further positioning ourselves at the forefront of the industry.
New Verticals
We will continue expanding into new sectors with strong

growth potential. These sectors are typically present in
global credit bureaux, but relatively nascent and unique
to the Malaysian credit reporting industry. These sectors
include automotive, real estate, and insurance. Collectively,
the total addressable market of the automotive, real estate,
and insurance sectors is forecast to grow from RM25.1
million in 2021 to RM128.9 million by 2025, implying a 50.6%
CAGR during this period, according to IDC Market Research
(Malaysia) Sdn Bhd, the independent market researcher.
As the market leader in Malaysia, we are well-positioned to
capitalise on the growth of the automotive, real estate, and
insurance sectors, as well as expand our presence in digital
solutions to increase our revenue base.
18
& ANALYSIS
ACKNOWLEDGEMENTS
ESG PRIORITIES
Summing it up, 2022 was another
Our achievements are premised upon delivering sustainable and value-
remarkable year for CTOS Digital as we
driven solutions to our customers and the communities and environment
continue to invest for the future while
where we operate. In FY2022, we have intensified our ESG efforts and made
delivering record financial results. We
commitments to take action against climate change by setting targets for
moved into 2023 with our eyes firmly on our
emission reduction towards the target of achieving Net Zero by 2050.
vision of delivering growth by deepening
our market share while capturing new
CTOS Digital also unequivocally supports the fundamental rights of people,
and burgeoning markets. Data, intelligent
from addressing inequality to protecting human rights. It is clear that access
analytics, and technology will drive the
to data and technology is essential to building a more equitable future and
future of the digital economy and we are
this belief underscores our business of turning data into information, and
well-positioned to take advantage of the
deploying advanced technologies and analytics.
many opportunities which lie ahead. I
feel energised about the future, given the
Our efforts were recognised with the inclusion into the FTSE4GOOD Index
momentum we are witnessing and the
last December. CTOS Digital secured a 4-star ESG rating, placing us among
innovations which we are driving.
the top 25% of publicly listed companies in the FTSE Bursa Malaysia EMAS
Index. This recognition will further drive us to strive for greater positive
I want to thank the Board of Directors
impacts and long-term sustainability, making the shareholder value more
for their steadfast guidance, trust, and
sustainable and holistic.
support in achieving and even exceeding
The details of our ESG journey, progress, and targets are comprehensively set out in our goals in 2022. In closing, I would like
our Sustainability Report from pages 31 to 61. to convey my heartfelt appreciation and
gratitude to each and every member of
the CTOS Digital team for their unwavering
dedication, hard work, and perseverance.
To all stakeholders, I would like to thank you
for your trust and continuous support.
In FY2022, we have intensified our ESG efforts and made
commitments to take action against climate change by
setting targets for emission reduction towards the target of
Erick Hamburger
achieving Net Zero by 2050. Group Chief Executive Officer
CTOS Digital Berhad
19
BOARD OF DIRECTORS
AS AT APRIL 2023
TAN SRI IZZUDDIN

BIN DALI
Independent
Non-Executive Chairman
74 M
Board Meeting Attendance:

9/13
Date of Appointment
15 August 2014
Academic/Qualifications/Membership(s)
• Bachelor of Economics (Hons) in Public Administration (Malaya University, Malaysia)
• Master of Arts in Economics (Western Michigan University, USA)
Relevant Working Experience

Over 36 years in various departments in various ministries and sat on the boards of a number of government-linked companies,
public and private companies.
• Various senior positions in Ministry of Finance (MoF) including Secretary General, Director of Budget Division and General Manager
of KLIA Berhad (seconded by the MoF) and Principal Assistant Secretary at Economics and International Division
• Secretary General of Ministry of Works
• Chairman of Lembaga Hasil Dalam Negeri
• Director of UDA Holdings Berhad
• Board Member of Bank Negara Malaysia
• Non-Independent Non-Executive Director of Malaysian Airline System Berhad
Present Directorship(s) in other Public or Listed Companies

• Independent Non-Executive Chairman of TCS Group Holdings Berhad
BOARD COMMITTEES MEMBERSHIP
ARC Audit & Risk Committee NRC Nomination & Remuneration Committee BIC Board Investment Committee Chairman
20
BOARD OF DIRECTORS
AS AT APRIL 2023
DATO’ NOORAZMAN
BIN ABD AZIZ
Independent
Non-Executive Director
67 M

13/13
ARC NRC BIC

8/8 3/3 4/4
Date of Appointment Present Directorship(s) in other Public or Listed Companies

24 February 2020 • Non-Independent Non-Executive Chairman of UEM Sunrise
Berhad
Academic/Qualifications/Membership(s) • Non-Independent Non-Executive Director of UEM Edgenta
• Bachelor of Science in Finance (Louisiana State University, Berhad
USA) • Independent Non-Executive Director of Kumpulan Perangsang
• Citicorp Associate Programme Training Institute, New York, USA Selangor Berhad
• Member of the Chartered Institute of Islamic Finance • Non-Independent Non-Executive Director of PLUS Malaysia
Professionals (CIIF) Berhad
• Member of the Australian Institute of Company Directors • Independent Non-Executive Director of Sun Life Malaysia
• Member of the Institute of Corporate Directors Malaysia Assurance Berhad
• Independent Non-Executive Director of Sun Life Malaysia
Relevant Working Experience Takaful Berhad
Over 38 years of experience in banking and finance, investments, • Chairman of the Board of Trustees of Yayasan UEM and
and capital markets. International Centre for Education in Islamic Finance (INCEIF)
• Executive Director, Investments at Khazanah Nasional Berhad
• Co-founder and Managing Director, Fajr Capital Ltd Advisory
• Managing Director and Chief Executive Officer, BIMB Holdings • Member of the Investment Panel of Kumpulan Wang
Berhad Persaraan (KWAP)
• Managing Director and Chief Executive Officer, Bank Islam • Global Advisory Board of Creador Sdn Bhd
Malaysia Berhad • Limited Partner Advisory Committee of Ancora Fund
• Managing Director and Head of Corporate and Investment Management Co. in Indonesia
Banking, Citibank Berhad • Advisor, Vynn Capital Sdn Bhd
• Chief Operating Officer, Bursa Securities (Kuala Lumpur Stock
Exchange Berhad)
• Director General, Labuan Financial Services Authority
• Senior Vice President (Corporate Banking and Treasury),
Citibank Berhad
• Investment Analyst, Perbadanan Nasional Berhad (PERNAS)
21
BOARD OF DIRECTORS
AS AT APRIL 2023
LOH KOK LEONG
Non-Independent
51 M

9/13
NRC BIC
3/3 3/4
Date of Appointment
15 August 2014
• Bachelor of Science in Business Administration (Hawaii Pacific University, USA)
• MBA (Hawaii Pacific University, USA)

Over 27 years of experience in consulting, specializing in strategy development and execution and private equity.
• Senior Managing Director of Creador Sdn Bhd
• Founder of Aigeus Capital Sdn Bhd
• Partner and Managing Director of Boston Consulting Group Sdn Bhd

Nil
22
BOARD OF DIRECTORS
AS AT APRIL 2023
LYNETTE YEOW SU-YIN
Independent
53 F

11/13
NRC
3/3
Date of Appointment
1 October 2020
• Bachelor of Arts in Law (University of Cambridge, United Kingdom)
• Master of Arts in Law (University of Cambridge, United Kingdom)
• Advocate and Solicitor of the High Court of Malaya
• Member of the Malaysian Bar

A lawyer by profession, over 28 years of experience specialising in corporate and securities laws, mergers and acquisitions and
capital markets.
• Consultant, Messrs Sanjay Mohan
• Consultant, Messrs Chua Associates
• Partner, Messrs Chua Associates
• Partner, Kadir Andri & Partner
• Partner, Messrs Zaid Ibrahim & Co
• Partner, Messrs Raslan Loong

• Independent Non-Executive Director of Malaysia Building Society Berhad
• Board Member of the Securities Commission Malaysia
• Trustee of The Datai Pledge
23
BOARD OF DIRECTORS
AS AT APRIL 2023
NIRMALA A/P
DORAISAMY
Independent
56 F

13/13
ARC
8/8
Date of Appointment
1 April 2021
• Bachelor of Economics (Hons) (University Malaya, Malaysia)
• MBA (International Islamic University Malaysia, Malaysia)
• Member of Malaysian Institute of Accountants (MIA)
• Chartered Global Management Accountant, UK
• Fellow of Chartered Institute of Management Accountants, UK

Over 33 years of experience specialising in banking and finance, risk management and advisory work.
• Director of Ecobuilt Holdings Bhd (Ecobuilt), Chairman of Nomination Committee and Member of Audit Committee, Ecobuilt
• Director of Credience Malaysia Sdn Bhd
• Head of Risk Management, Credit Guarantee Corporation Malaysia Berhad
• Various positions in Affin Bank Bhd, Alliance Bank, Malaysia Bhd and MBF Finance Bhd

• Independent Non-Executive Director of Petronas Dagangan Berhad
• Independent Non-Executive Director of Evergreen Fibreboard Berhad
Other Appointments
• Member of Auditing and Assurance Standards Board, Malaysia Institute of Accountants
24
BOARD OF DIRECTORS
AS AT APRIL 2023
SU PUAY LENG
Independent
53 F

12/13
ARC BIC
8/8 4/4
Date of Appointment
27 May 2021
• First class honours in Bachelor of Laws (International Islamic University Malaysia)
• MBA from Judge Business School (University of Cambridge, United Kingdom)
• Advocate and Solicitor of the High Court of Malaya

Close to 30 years of experience within a law firm and corporate legal department.
• Head of Legal of Maxis Berhad and its subsidiaries
• In-house counsel with the Maxis group
• Legal Assistant at Messrs Skrine

Nil
25
BOARD OF DIRECTORS
AS AT APRIL 2023
ERICK HAMBURGER
Executive Director and

Group Chief Executive Officer
54 M

3/3
Date of Appointment
30 September 2022
• General Management Program (Harvard Business School)
• MBA (MIT Sloan School of Management)
• Bachelor of Science, Pontificia (Universidad Javeriana, Colombia)

Over 29 years of vast experience in corporate strategy and international credit reporting sector.
• President of Experian Colombia and Mexico
• CEO of Publicar S.A. (Colombia)
• President of Brightpoint Inc. (Miami)
• Director of Strategy & Business Development at Motorola Inc. (Miami)
• Engagement Manager at Mckinsey & Co (Miami)
• Director of Prepaid Products at Bell Canada (Colombia)
• Manager of Convenience Channel at British American Tobacco (Colombia)
• Assistant Brand Manager at Protect & Gamble (Colombia)

• Non-Independent Non-Executive Director of BOL (listed on the Stock Exchange of Thailand)
26
BOARD OF DIRECTORS
AS AT APRIL 2023
WONG PAU MIN
Alternate Director to
Loh Kok Leong
41 M

4
Date of Appointment
15 February 2021
• First class honours in Master of Engineering - Electrical & Information Sciences (University of Cambridge, United Kingdom)
• MBA from Haas School of Business (University of California Berkeley, USA)

Over 19 years of experience in strategic and operational expertise across Southeast Asia primarily in industrial goods, financial
services and the public sector.
• Executive Director of Creador Sdn Bhd
• Principal at Boston Consulting Group
• Associate at Boston Consulting Group

Nil
27
KEY SENIOR MANAGEMENT

AS AT APRIL 2023
ERICK HAMBURGER BARRAZA

Executive Director (30 September 2022)
and Group Chief Executive Officer (1 May 2022)
For details on Erick’s profile, refer to Directors’ profiles in Page 26 of CTOS 2022 Annual
Report
Date of Appointment of Current Position

18 November 2014
Academic/Qualification(s)
• Bachelor of Economics majoring in Industrial Economics (Universiti Kebangsaan
Malaysia)

Eric has over 25 years of experience in helming senior leadership roles in business,
sales and operational functions for multinationals and local corporates. He joined
CTOS in 2014 as the Chief Executive Officer and he first focused on strengthening
the core operations and services of the business. He has been involved in the
management of Key Accounts customers, oversees Legal Department and acting
as the key liaison with the regulators.
CHIN KUAN WENG, ERIC Prior to CTOS, he was Chief Operating Officer of Credit Bureau Malaysia (“CBM”).
Chief Executive Officer of Before CBM he was the Head of Professional and Technical Division in Kelly Services
(M) Sdn Bhd. And from 1998 to 2008, he worked at Siemens Malaysia Sdn Bhd under
CTOS Data Systems Sdn Bhd
the Siemens Business Services division, and Siemens Nixdorf Information Systems
(M) Sdn Bhd, where he rose through the ranks to become the Vice President of IT
52 M
and business advisory in charge of management of the business performance of
solutions and consulting services practice and establishing new solutions.
Join Date: 18 November 2014

16 January 2023
• Bachelor of Accounting & Financial Management (Hons), University of Essex (UK)
• Diploma in Business Studies, North Manchester College (UK)

Chiam joined CTOS in 2023 as the Chief Financial Officer, responsible of all finance
matters, provide leadership and function as a key advisor to the business.
Prior to joining CTOS, he was with WorleyParsons Limited (WOR), a ASX-listed company
based in Australia. He held various positions of increasing responsibility with the
WorleyParsons group - Group Executive Group Director (Operational Finance), Head
of Shared Services, Regional Group Finance Director (Asia, Middle East, North Africa &
CHIAM HSING CHEE Europe) and Finance Controller.
Group Chief Financial Officer
Chiam is a global senior leader with extensive international business experience
52 M within the energy and resources industry. He has transitioned operational finance
from a business-led to a functional-led model, revitalized the shared services unit to
Join Date: 16 January 2023 a standalone business and transformed the highly-fragmented emerging markets
(which consisted of numerous joint-venture businesses) into IPO-ready structures – a
vital factor to the public-listing of WorleyParsons on the ASX in 2002. At WorleyParsons, he
also had cultivated a culture of technology as an enabler to achieve next-level value-
adding services by embracing analytics, system enhancements and automation.
28

AS AT APRIL 2023

1 January 2019
• Bachelor of Business Administration (Hons) (University of Northumbria, United
Kingdom)
• MBA (Nottingham Trent University, Malaysia)

Tracy joined CTOS in May 2017 as the General Manager in Customer Experience
before being promoted to the Chief Operating Officer in January 2019. She has
been overseeing the strategic operations management and customer experience,
customer relations as well as the Commercial business segment.
TRACY GAN JO LIN She has over 23 years of experience in operations and prior to joining CTOS, she
held various senior positions in Maxis Berhad as Head of Distributor and Modern
Chief Operating Officer of
Trade Management and Head of Order Management and Fulfilment. At Maxis, she
CTOS Data Systems Sdn Bhd
was responsible to drive sales growth and reach of distributors, provide operational
support, cost optimisation with regards to distributorship and to monitor and analyse
46 F distributors’ performances. Before that, she was the Head of Customer Operations
in TIME dotCom Berhad and General Manager for Customer Service and Human
Join Date: 2 May 2017
Resources at e-pay (M) Sdn Bhd.
Date of Appointment of Current Position:

17 May 2022
• Bachelor of Information Technology (Hons) (The University of Queensland,
Australia)
• Bachelor of Informatics (Griffith University, Australia)

James has over 30 years of experience in IT - a transformational and strategic leader
with extensive knowledge of private banking, retail banking and central banking,
developing and implementing systems in core banking, trading, risk, compliance,
regulatory reporting, payments, document management and enterprise data
management platforms. He has vast experience in operating diverse, multi-cultural
JAMES FANCOURT MITCHELL environments and leading global and regional financial institutions spanning Asia,
the Middle East and Europe.
Group Chief Technology Officer
Before joining CTOS, he was the Deputy Director (Head of IT Transformation) at Bank
53 M
Negara Malaysia (BNM) and then went to Tata Consulting Services (TATA) as the
Head of Banking & Financial Services. At BNM he was responsible for the IT
Join Date: 17 May 2022
Transformation Programme and has transitioned into the target organization
structure and introduced new capabilities in the areas of Solution Delivery
& Deployment, Cyber Security, Infrastructure, Big Data & Analytics, Vendor
Management & Procurement, Testing, Enterprise Architecture and Human
Resource Management.
Prior to that, he was the Associate Partner at IBM Global Business Services (Malaysia),
Delivery Head Information Management & Integration at Standard Chartered Bank
(Malaysia), Head of IT Shared Services at Ambank (Malaysia), Chief Information
Officer at Hong Leong Bank (Malaysia), Head Change the Bank IT and Executive
Director at Bank Julius Bar (Singapore) and Vice President/ Program Manager
Strategic Projects at Credit Suisse (Switzerland & Singapore).
29

AS AT APRIL 2023
Date of Appointment of Current Position:

8 March 2023
• Bachelor of Computer Systems and Technologies (New Bulgarian University,
Bulgaria)

Ivo joined CTOS in March 2023 as Group Chief Data and Product Officer. He is
responsible for overseeing the Data, Analytics, Product and Presales teams across
all business units of the Group. His remit is to expand CTOS data assets, lead
analytics capabilities and set the strategic direction for the business’s overall product
development.
IVAYLO VENKOV KOLEV, IVO He brings close to 20 years of multinational experience in data businesses and proven
track-record in leading and building high-performance teams. He previously served
Group Chief Data and Product Officer
as the Executive Director of Creador Malaysia. Before that, he held several positions
at Experian Singapore, most recently as the General Manager for APAC, where he
41 M
oversaw Operations and was responsible for strategy, delivery, product development,
data sourcing, and distribution. Past roles include Head of Sales & Presales for ASEAN,
Join Date: 8 March 2023
Senior Consultant and Data Scientist at Experian Singapore, Bulgaria and Austria.

1 May 2021
• Diploma in Information Technology (Informatics College, Malaysia)

Sue Ling joined CTOS since 2006 and has acquired over 16 years of experience in
regulatory compliance and risk management of the credit bureau business and
currently, oversees all compliance related matters of our Group.
Before she was redesignated as Group Senior Head of Risk and Business Compliance
in May 2021, she held Senior Head of Risk and Business Compliance position, where
she is responsible for developing and overseeing Group’s enterprise risk governance
LIM SUE LING framework. Her primary responsibilities include developing annual regulatory and
compliance work plan and overseeing consumer redress mechanism. She has rose
Group Senior Head of Risk and
through the ranks from Customer Service Officer to the current position as Group Senior
Business Compliance
Head of Risk and Business Compliance. She held several roles including Special Project
Officer, Assistant Manager of the Settlement and Record Update, Manager of Business
39 F Compliance and Head of Business Compliance.
Join Date: 6 March 2006
30
SUSTAINABILITY
STATEMENT
31
SUSTAINABILITY STATEMENT
SUSTAINABILITY DISCLOSURES
At CTOS, we take
our commitment to
sustainability seriously.
We continuously strive
to improve the quality
of our sustainability
disclosure year after
year. Transparency is
key, and we aim to
share relevant data
on our progress as
well as the challenges
we face in managing
sustainability risks.
Reporting Period & Boundary
Our Sustainability Statement covers the period from 1st January 2022 to 31st December 2022 and includes all of CTOS' activities
and initiatives across our operations. We have also addressed our top material topics that influence stakeholder decisions
and directly or indirectly impact our business.
Reporting Standards
We have adhered to the following local and international standards and guidelines:
• Bursa Malaysia’s Main Market Listing Requirements on Sustainability Reporting
• Global Reporting Initiative (GRI) Standards (Reference)
• The ACCA Malaysia Sustainability Reporting Guidelines for Malaysian Companies
• ISO 26000:2010 Guidance on Social Responsibility
• The United Nations Sustainable Development Goals (UN SDGs)
Assurance
In the spirit of promoting accuracy and credibility, the internal auditor has undergone an internal review of this Statement,
which is consistent with Paragraph 6.2(e) of Practice Note 9, Main Market Listing Requirements (MMLR).
Point of Contact
We welcome all feedback and comments on ways we can improve the quality of our sustainability statement. Please contact
us at: 03-2722 8888.
32
SUSTAINABILITY KEY HIGHLIGHTS
Our purpose is to empower consumers and businesses to make sound

credit decisions confidently, leading to better financial health. By helping our
customers make informed and sustainable credit decisions, we can achieve
excellence in credit reporting while contributing to socio-economic progress.
In 2022, we have made significant progress towards our sustainability purpose within our four Sustainability Themes:
2.47mil >450
Individuals registered for Financial education roadshows and
CTOS self-check webinars conducted nationwide
16.6mil Diversity, Equity & Inclusion
EMPOWERING Free CTOS Reports provided to

OUR PEOPLE Individual and SMEs
Total Board Diversity,
AND SMEs 339,
Employees Female Directors
59%
+15 points
238,
Improvement in average credit score of

41%
43%
Male Female
Malaysians (From 663 in 2020 to 678 in 2022)
Start Scope 1 & 2 Scope 2 2022 tCO2 emission

tracking & monitoring
is 407.57, 2%
PROTECTING OUR
ENVIRONMENT
from 2022 below from 2019 Pre MCO level
EFFECTIVELY ZERO
MANAGING non-compliances
COMPLIANCE
AND RISKS
Devised a Three-Year Cyber
ZERO
Security Strategy to become an
ISO 27001-certified organisation by
ESTABLISHING breaches
TRUST IN DATA 2025
33
AWARDS
World Digital Asia Corporate

Technology Excellence &
Corporate Sustainability
Excellence Awards 2022
Award 2022 (ACES)
LEADERSHIP COMMITMENT
Dear Shareholders,
As a newly listed company, we are still in the early stages of entire company quarterly. The Audit and Risk Committee has
our sustainability integration. We understand that we have delegated authority to implement sustainable practices
a long road ahead, but we also know that sustainability is based on guidance from the Board. Our management team
a journey, not a destination. Therefore, we will continue to discusses and approves all key sustainability matters, and
improve our sustainability efforts each year to emerge as a each department head is responsible for operationalizing
sustainability leader in credit reporting. these initiatives. Our Group Head of Corporate Strategy &
Planning serves as our ESG champion, accountable for the
In 2022, we have made significant progress in our sustainability overall sustainability culture at CTOS.
journey. We have established a Sustainability Blueprint for
CTOS, which is built on our purpose of empowering consumers In the year ahead, we will accelerate our sustainability efforts
and businesses to make sound credit decisions confidently, by conducting an in-depth materiality assessment with our
leading to better financial health. By helping our customers external stakeholders. We are committed to using these
make informed and sustainable credit decisions, we can insights to shape our strategies, policies, and programs and
achieve excellence in credit reporting while contributing to strengthen our integration of sustainability.
socio-economic progress.
As a testament to our steady progress in sustainability, I
To further our sustainability mission, we are committed to am pleased to report that CTOS has been listed included
financially educating local communities and enabling them as a constituent of both the FTSE4Good Bursa Malaysia
to take control of their own credit health through our CTOS (FTSE4Good) Index and FTSE4Good Bursa Malaysia Shariah
Care programme on financial inclusion, which has already (F4GBMS) Index. This is an encouraging development, and
delivered results. In addition, we are actively working to assess has reinforced our team’s drive in sustainability.
and reduce our greenhouse gas (GHG) emissions in order
to protect the environment. We have set an ambitious target With that, I thank you for your support as we work towards
to reduce our emissions by 15% and are fully committed to building a more sustainable future for CTOS and our
achieving this goal. stakeholders.
As a firm believer of sustainability being a business imperative,

we are currently integrating sustainability into our strategy and
decision-making processes. The Board of Directors oversees Erick Hamburger
all sustainability-related matters, ensuring consistency with Group Chief Executive Officer
our overall business strategy, which is communicated to the CTOS Digital Berhad
34
Sustainability Blueprint for CTOS Digital
To help empower consumers and businesses to make sound credit

Purpose
decisions confidently, leading to better financial health
Vision To make Malaysia a centre of excellence for credit reporting in ASEAN
CTOS Protecting Our Empowering Our Effectively Managing Establishing Trust

ESG Theme Environment People and SMEs Compliance and Risks in Data
• Energy Management • Financial Literacy • Compliance to Evolving • Data Privacy &

• GHG Emissions • Customer Welfare & Regulations & Standards Cybersecurity
CTOS Responsibility • Business Ethics • Transparency & Trust
Sub-Theme
• Employee Engagement • Fraud Risks
• Diversity & Inclusion
FTSE4G
Environment Social Governance Governance & Social
ESG Pillar
FTSE4G Human Rights & Community Anti-Corruption Risk Management
Climate Change
ESG Theme Labour Standards Corporate Governance Customer Responsibility
WHAT SUSTAINABILITY MEANS TO US
STAKEHOLDER ENGAGEMENT
By engaging with stakeholders, we can better understand their expectations and needs, and integrate their feedback and
suggestions into its sustainability initiatives. This collaborative approach also helps to build trust and strengthen relationships
with stakeholders, which is essential for the long-term success of our company. Ultimately, by engaging with its stakeholders,
we improve the effectiveness and relevance of our sustainability programmes, and drive positive social, environmental, and
economic impact.
FREQUENCY OF ENGAGEMENT
O Ongoing D Daily M Monthly Q Quarterly A Annually T Twice a year
Stakeholders Key Concerns Our Objective Engagement Platform
Shareholders • Business sustainability • To secure financial capital A Annual General Meetings (AGMs)
& Investors • Shareholder and investor required for operational
relations commencement, business A Conference and meetings
• Shareholder returns continuity and growth
D Website
• Corporate Governance sustainability
• Strategic Growth Plans
A Investors and analyst briefings,
roadshows and forums
35
Stakeholders Key Concerns Our Objective Engagement Platform
Government • Regulatory Compliance • To safeguard various O Continuous active engagement

Bodies and • Ethical Business Practices licenses and permits to and consultations
Regulators • Health and Safety Practices simply exist, operate and Independent Engagement Survey
A
• Environmental thrive
management and
compliance • To avert violations or
• Cybersecurity breaches of relevant laws
and standards that could
result in fines, penalties,
forfeitures or sanctions
Customers • Customer Engagement • To acquire new and/or D Checkpoint call /
• Customer Accessibility retain existing customers face-to-face appointment
• Customer Satisfaction Multi-channel touchpoints
D
• Service Assurance • To convert customers into
• Customer Training repeat and long-standing D Customer Onboarding
customers by meeting
customer requirements D Regular meetings and day-to-day
and expectations interactions
A NPS Survey
• To capitalise on valuable
customer feedback O Response to customers from SLA
in achieving strategic, Management
financial operational M Credit Manager Training
excellence
Suppliers • Ethical Business Practices • To ensure delivery of A Audit
and Partners • Sustainability in supply products and services of
chain the best value
• Company performance O Regular meetings and
• Continuous Value Creation • To contribute to the daily interactions
development of capacities
A Strategic dialogues
and capabilities of our
business partners
Q Conferences and forums

• To support various national
agendas
Employees • Employee engagement • To build an innovative, T Employee Engagement Survey
and work-life balance creative, productive, diverse
• People learning and and inclusive workforce
development
• Diversity and equality • To attract, develop and
retain the best talents “WE CARE” activities
O
particularly among
Malaysian citizens for our
company’s survival and
sustainability
Local • Accessibility for SMEs • To build diverse, inclusive, A Independent stakeholder
Communities Financial literacy and balanced, resilient and engagement survey
inclusion sustainable societies and
• Ethical Business practices economies that thrive
• Good governance and reflects on our social
citizenship
36
MATERIAL MATTERS
We recognise the importance of identifying and addressing ESG issues that are most relevant to our business and industry.
Through the application of materiality, we incorporate stakeholder feedback and expectations into our sustainability strategy.
By prioritising the most material ESG issues, we can effectively allocate resources and focus our efforts where we will have the
greatest impact.
Our current material matters are based on an assessment done in 2021. Given that this was our first materiality exercise,
we limited our engagement solely with internal stakeholders. Future stakeholder engagement sessions in relation to the
materiality assessment exercises will involve our external stakeholders for a more extensive, diverse and inclusive horizon.
MATERIALITY METHODOLOGY
STEP STEP STEP STEP

1 2 3 4
STANDARDS STAKEHOLDER MATERIALITY

PEER
& ENGAGEMENT ASSESSMENT
ANALYSIS
FRAMEWORKS SESSIONS PRIORITISATION
Global peers and local Relevant material issues The insights from our In the Materiality
institutions consolidate are identified using external stakeholders Validation Workshop
all the issues. In order to Industry standards will be included with the our management
provide a local context, from global frameworks enhancement of the group prioritises the ESG
we chose global peers (SASB Materiality Map, process of stakeholder material issues by:
who had the similar FTSE4Good, UNGC, engagement. 1. Importance of
operations and local GRI) and all of Bursa material issues
financial institutions. Malaysia’s reporting 2. Prioritisation of
framework. stakeholders
3. Importance of
material issues
to stakeholder
assessments and
decisions
With Steps 1 and 2, a long list of potential material During Step 3, these In Step 4, the shortlist is
sustainability matters applicable and relevant are formed. preliminary sustainability verified and validated
matters are shortlisted to prioritised material
through various ESG matters through a
stakeholder engagement Materiality Validation
sessions and a list is Workshop.
formed with the most
relevant matters.
37
Following our materiality assessment, we have identified the 10 material matters, as shown in the matrix below:
Materiality Matrix
High
3 4 5
stakeholder assessments and decisons
3
Influence of material issue on
1 2
1 2
Low High
Significance of economics, environmental
and social impacts to the business
ENVIRONMENT SOCIAL GOVERNANCE
1 GHG Emission 1 Diversity & Inclusion 1 Fraud Risk
2 Energy Management 2 Employee Engagement 2 Transparency & Trust
3 Financial Literacy & Inclusion 3 Business Ethics
Customer Welfare & Compliance to Evolving

4 4
Responsibility Regulations & Standards
5 Data Privacy & Cybersecurity
In 2022, we streamlined our material matters for clarity purposes. Since there was a strong relationship between and small
overlap in content, we have merged two material matters: GHG emission & Energy Management. The new material matter
is named Climate Action, in line with the Sustainable Development Goals of the United Nations, under which we will report
about all our emissions as well as our energy management.
38
CONTRIBUTING TO THE SUSTAINABLE DEVELOPMENT GOALS
The Sustainable Development Goals (SDGs) are a call for action to promote prosperity while protecting the planet.
As CTOS, we are committed to contribute to the SDGs and have collectively selected the top SDGs priorities. Our key
SDGs are listed below.
CTOS Key SDGs
CTOS contributing to
the UN Sustainable
Development Goals
These seven SDGs were selected as our top priority based on SDG 4 Quality Education which contributes to a wealthier
the impact we make as a company towards our sustainability society and therefore additionally makes impact on SDG
themes and material matters. Our sustainability theme 8 Decent Work and Economic Growth. By offering these
‘Empowering our People and SMEs’ creates impact on SDG services for free or at an affordable price for underbanked or
4 Quality Education, SDG 8 Decent Work and Economic unbanked communities, we contribute to SDG 10 Reduced
Growth, SDG 10 Reduced Inequalities, SDG 16 Peace Justice Inequalities. Furthermore, an impact is also made on SDG 17
and Strong Institutions, and SDG 17 Partnerships For The Partnerships for the Goals by us working alongside non-profit
Goals. Particularly in our material matter ‘Financial Literacy’ organisations.
which brings the biggest impact on all these SDGs. We
contribute to society by using our core business strength. Within our sustainability theme ‘Protecting our Environment’
We are dedicated to educating consumers and businesses we focus specifically on SDG 13 Climate Action, while
regarding their financial health and credit risks, as well contributing to SDG12. Our commitment is to reduce the
as facilitating access to financial products and services, direct and indirect GHG emissions that are linked to our
particularly for underbanked or unbanked communities. operations covering Scope 1, 2 and 3 emissions.
By offering high quality education for all, we contribute to
39
MANAGEMENT APPROACH TO SUSTAINABILITY

The following table defines the qualified Sustainability Themes and Material Sustanability Matters in more detail. Furthermore
it shows which SDGs are impacted by each Material Matter.
Refer to
Sustainability Material ESG respective page
Themes Description Matters Definition for each theme SDGs
Environment
Continued Climate Environmental impacts associated with energy Pg 44
monitoring Action consumption. It addresses the management of
of CTOS’ energy efficiency, intensity, and energy mix, from
Protecting environmental sources such as data centres and offices
our footprint and
Environment impact to The release of direct and indirect greenhouse
reduce GHG gases that are linked to the company’s
emissions, operations, covering Scope 1, 2 and 3 emissions.
whilst also
enhancing Scope 1 includes direct Greenhouse Gas (GHG)
energy emissions from sources that are owned or
efficiency controlled by the company (e.g., combustion in
entity- owned vehicles).
Scope 2 are indirect GHG emissions from
the generation of purchased energy (e.g.,
purchased electricity in offices).
Scope 3 emissions are all other indirect GHG
emissions from the company’s value chain
Social
CTOS continues Financial Educating consumers and businesses (including Pg 47
to build an Literacy & SMEs) regarding their financial health and credit
engaged Inclusion risks, as well as facilitating access to affordable
Empowering and diverse financial products and services, particularly for
our People workforce, underbanked or unbanked communities
and SMEs whilst
Customer Providing services to customers that are aligned Pg 49
simultaneously
Welfare & with societal expectations, ensuring a smooth
considering
Responsibility customer experience, and listening and
customer
responding to customer feedback. This also
welfare and the
includes treating customers fairly in the conduct
development
of our business, as well as providing them with
of local SMEs
accurate, adequate and easily understood
information on the services they receive
Employee The cultivation of stronger connections with Pg 50
Engagement employees (commonly measured by the level
of employee satisfaction and commitment to
the company) through team bonding activities,
employee gatherings, and the investment in
and development of a talent pool of employees
and leadership
Diversity & Diversity refers to a mixed and balanced Pg 52
Inclusion representation of workers in the organisation,
in regard to race, gender, ethnicity, religion
and other group identities; Inclusion refers to a
workplace where there are equal opportunities
for contribution and influence
40
Refer to
Sustainability Material ESG respective page
Themes Description Matters Definition for each theme SDGs
Governance
Building a Compliance Constant review and maintenance of Pg 54
culture that to Evolving compliance with fast-changing acts,
emphasises Regulations & enactments, rules, regulations, bylaws, standards
Effectively proper business Standards and best practices in any jurisdiction that are
Managing conduct, relevant and applicable to the company
Compliance in line with Business The ethical conduct of business which Pg 56
and Risks comprehensive Ethics includes the management of risk associated
compliance with corruption, fraud, bias, misrepresentation,
to the relevant conflicts of interest, negligence and other factors
regulations with an ethical component. It also extends to
and standards, ensuring the organisation’s values, principles,
as part of the standards and norms of behaviour (e.g., code
enterprise’s risk of conduct and code of ethics) are developed
management and implemented
framework
Fraud Risks The management of risks arising from fraudulent Pg 57
activities arising at each stage of the customer
lifecycle, such as identity theft in the loan
origination or credit application process
Governing data Data The provision of complete and accurate Pg 59
management Privacy & disclosure of business activities, data handling,
capabilities Cybersecurity data use and other material matters in order
Establishing and continuing to maintain trust and facilitate productive
Trust in Data to comply discussions between the company and its
with relevant stakeholders
standards for Transparency The management of customer data Pg 61
information & Trust confidentiality, mitigation of data breach risks,
security protection of personal data from unauthorised
access or attacks that are aimed for exploitation
of the information. This includes a company’s
approach to collecting data, obtaining consent,
and managing user expectations regarding
how their data is used
41
GOVERNANCE STRUCTURE
SUSTAINABILITY GOVERNANCE STRUCTURE

Sustainability plays an important role throughout our governance systems and processes. Our Board takes overall
accountability for the management of all risks and opportunities, including all ESG related risks such as climate change.
Therefore, ESG-based KPIs are assigned to the leadership team by our CEO and our Head of Corporate Strategy & Planning.
All departments’ heads are assigned to specific sustainability responsibilities to drive ESG implementation across all levels.
FREQUENCY B Bi-weekly M Monthly Q Quarterly
LEAD RESPONSIBILITY FREQUENCY
Group Head of Corp Strategy Update on the progress & highlights on

B
& Planning key concerns
Group CEO Align Key Metrics M
Risk Management Committee (RMC) Review Key Sustainability Matters Progress Q
Audit and Risk Committee (ARC) Review Key Sustainability Matters Progress Q
Board of Directors Review Key Sustainability Matters Progress Q
Other C-level & Head of Departments Develop a list of sustainability responsibilities as additional tasks for each
committee, department, and other business division leaders to drive ESG
implementation company-wide across all levels
SUSTAINABILITY RISK MANAGEMENT

Sustainability is a key component to
effective risk management that allows
BOARD OF DIRECTORS
us to proactively deal with emerging
sustainability risk. In the long run, we
can better protect our stakeholder
AUDIT AND RISK COMMITTEE (ARC)
value and business performance.
ESG matters are integrated in our
existing risk management system,
RISK MANAGEMENT COMMITTEE (RMC)
thus enabling us to future-proof our
business. Additionally, quarterly risk
management reporting is carried out
GROUP CEO
on a regular basis with our Audit Risk
Committee (ARC). Both the ARC as well
as the Risk Management Committee
GROUP CORP HEAD OF STRATEGY & PLANNING
(RMC) review the progress on our key
sustainability matters each quarter.
42
DRIVING IMPACT IN THE INDUSTRY

We are passionate about establishing ourselves as an
industry Thought Leader. Part of this commitment includes
contributing to the Association of Credit Reporting Agencies
(ACRA), which represents the Malaysian credit reporting
industry and fosters engagement and cooperation among
key stakeholders to develop a professional, competitive,
and dynamic industry in Malaysia. We do not just sit on the
sidelines either. We are actively involved in discussions on key
regulatory changes, industry best practices, technological
advancements, and cyber risks that affect the credit
reporting industry in Malaysia.
We also take the lead in high-impact initiatives, such as

promoting financial literacy and improving access to
financing. Our collaborations with various stakeholders,
including government agencies, non-governmental
organizations, banks and financial institutions, and industry
associations, allow us to drive positive change and make a
meaningful impact in our industry.
CREATING VALUES
At the core of our business lies a commitment to sustainability. Our objective is to create value by optimising our impact on
the environment and stakeholders, while ensuring good governance across all our operations. We pursue strategies that
address our material topics and measure their impact, so that we can constantly improve our performance.
In the pages ahead, we dive deeper into our sustainability performance across four key themes and their associated material
matters.
PROTECTING OUR ENVIRONMENT EFFECTIVELY MANAGING COMPLIANCE

AND RISKS
M1 Climate Action 44
Compliance to Evolving
M6
Regulations & Standards 54
M7 Business Ethics 56
EMPOWERING OUR PEOPLE AND SMEs
M8 Fraud Risks 57
M2 Financial Literacy 47
M3 Customer Welfare & Responsibility 49 ESTABLISHING TRUST IN DATA
M4 Employee Engagement 50 M9 Data Privacy & Cybersecurity 58
M5 Diversity & Inclusion 52 M10 Transparency & Trust 60
43
PROTECTING OUR ENVIRONMENT
M1 Climate Action
Why Is It Important
Climate change poses one of the greatest threats to humanity, and

reducing greenhouse gas (GHG) emissions and limiting global
temperature rise are essential to mitigating the risk of climate disasters
that threaten social well-being and economic development. Our business
is exposed to two types of climate risks:
Physical Transitional
Major disruption and Reputational, compliance or

losses due to the physical market challenges stemming
damages incurred by from the global transitions
extreme weather events. towards a low-carbon economy.
Reducing GHG emissions is key to mitigating both types of risks. In

addition to reducing risk, it also improves efficiency, cost-effectiveness and
competitiveness. It is imperative that the whole world drastically reduces
carbon emissions to avoid the devastating effects of climate change. As
a company, we have a responsibility to lead by example and align with
the global climate agenda to protect our stakeholders and ensure the
long-term sustainability of our business.
What is Our Approach

SCOPE 1
At CTOS, we are committed to reducing our environmental impact Includes direct GHG emissions from
while actively seeking ways to create positive change. We understand sources owned or controlled by the
the importance of being accountable for our greenhouse gas (GHG)
company, such as combustion in
emissions and have taken a comprehensive approach to monitor and
entity-owned vehicles.
report them, including the voluntary scope 3 alongside mandatory
scope 1 and 2. This demonstrates our strong dedication to GHG
SCOPE 2
management and sustainability practices.
Includes indirect GHG emissions
To kickstart our journey, we have implemented a "Going Green" initiative
from the generation of purchased
to address our carbon footprint. Our ultimate goal is to be an organization
energy, such as purchased
that contributes to the United Nations' Sustainable Development Agenda.
electricity used in offices.
Although we are still in the early stages of our sustainability journey,
we remain dedicated to achieving this goal. To guide our efforts, we
have developed a sustainability blueprint for 2022-2025 that integrates SCOPE 3
sustainability practices into our operations.
Includes all other indirect GHG
emissions from the company’s
As part of our climate action efforts, we are focused on reducing our
value chain. While we have not yet
emissions according to the following three scopes:
begun measuring this scope in
2022, we are planning to start these
measurements in 2023.
44
To progressively reduce our emissions, we have established 2. GHG Emission

short to medium-term carbon reduction targets to support
the transition towards a low carbon economy: Through our efforts in 2022, we have achieved a reduction
of 3% in overall Scope 1 and Scope 2 carbon emissions
• Reducing Scope 2 emissions by 15% by 2025, from 2022 compared to our 2019 baseline:
levels
• Having carbon offset for Scope 1 and 2 emissions
gradually over the 5 years in operations only Scope 2 Emissions (tCO2)
• Reducing Scope 3 emissions by 15%, by 2030
As we progress on our sustainability journey, we will introduce

long-term carbon reduction targets, with the ambition of 416.35 407.57
396.37
achieving Net Zero by 2050.
0.911
Value Creation in 2022 323.61 0.781

0.806
1. Reduce electricity 0.691
Since 2019, we have been monitoring our Scope 2

emissions, beginning with our energy consumption. We
have been tracking all energy used by our facilities on a
monthly basis.
Our data shows that our energy usage has increased

slightly in 2022 compared to 2021, as we have transitioned
from working from home to the office. However, we are
committed to reducing our overall energy consumption 19’ 20’ 21’ 22’
to achieve our carbon targets.
Total Scope 2 Emissions (tCO2)
Emissions Intensity (Total emissions/FTE)

Energy consumption (MWh) &
Energy intensity (MWh/employee)
Additionally, our carbon emissions per employee were
lower compared to our 2019 baseline, despite the lifting of
711.70 movement restrictions. This has strengthened our
677.55 696.70
determination to achieve the lowest possible emissions per
553.18
employee at CTOS.
1.56
1.33
1.38 Total Emissions
1.18 (tCO2e) 2019 2020 2021 2022
Scope 1 3.36 1.30 0.50 0.82

Scope 2 416.35 396.37 323.61 407.57
19’ 20’ 21’ 22’
Total MWh
Emissions Intensity (MWh/FTE)
45
3. Waste Management
What We Did Results/Achievements
Recycling • “Paper Day Campaign” was promoted across CTOS Offices nationwide to instil the importance
of recycling.
• All paper required will be shredded and extended to vendors for recycling on a monthly basis
where vendors will collect from our office for recycling of papers.
• All the used printer cartridges are returned back to the vendor to ensure that these items do
not end up in landfills.
• Instalment of waste disposal bins to manage the waste efficiently and incorporate training
programmes to educate staff on how to reduce the volume of waste.
Reduce paper • Mandatory printing procedure whereby printing is only allowed when necessary and
approved via e–signature.
• Default printer setting where we have adopted printing on both sides to reduce carbon
footprint.
• Use papers Certified with the Programme for the Endorsement of Forest Certification (PEFC) to
promote sustainable forest management.
• Install hand dryers for employees to reduce the usage of hand paper towels in the office.
4. Green Culture
Plants are placed throughout our office to promote a “green culture”. This aims to raise green awareness for employees
while also creating a more natural and warm work environment.
5. Moving Forward
In 2023, we will take significant steps to achieve our goals. We will develop a comprehensive GHG inventory for Scope 1
and Scope 2 emissions, implement a strategy and action plan based on our Group-wide ESG metrics, and prioritize
environmental management. Our focus will be on developing a Roadmap towards achieving Net Zero impact, reporting
our progress to the Carbon Disclosure Project, and supporting the transition to a low-carbon economy. Additionally, we are
considering introducing TCFD disclosures, metrics and targets, and SBTi commitments.
46
EMPOWERING OUR PEOPLE AND SMES
M2 FINANCIAL LITERACY
Why Is It Important with the local community and indigenous people in the areas
where we operate.
It has always been our vision to make Malaysia a
centre of excellence for credit reporting in ASEAN, We understand the importance of educating consumers and small
and we aim to empower more Malaysians to to medium-sized enterprises (SMEs) about their financial health and
achieve sustainable credit wellbeing through credit risks. We provide access to affordable financial products and
increased financial literacy levels. A robust services, with a particular emphasis on underbanked and unbanked
financial literacy rate in Malaysia will lead to communities.
better financial inclusion, which results in the
wellbeing of its citizens and in turn, will help To achieve our goal of enhancing financial literacy, we have several
the nation achieve economic growth and ongoing initiatives in place under the CTOS Cares umbrella. They are
sustainable development. designed in alignment with the United Nations' Sustainable Development
Goals i.e., Reduced Inequalities, Quality Education and Decent Work
Our goal is to empower individuals and businesses and Economic Growth.
in Malaysia to take charge of their credit health
while improving their financial literacy through The programme has a two-fold approach:
educational programmes. We are committed 1. Providing local communities with necessary tools and knowledge
to ensuring that Malaysians, regardless of their as part of the core of the business
background or financial standing, have the 2. Improving their financial awareness through educational programs.
tools and knowledge to make informed financial
decisions, leading to greater financial inclusion Our primary focus is to provide self-check convenience to our customers
and stability in Malaysia. while offering a range of tools such as credit scoring, advisory services,
guidance, and know-how. This includes educating our customers on
What is Our Approach what affects their credit score and providing them with the necessary
information and resources to improve it.
We are dedicated to promoting financial
literacy and empowering individuals and Our commitment to promoting financial literacy reflects our dedication
businesses with the knowledge and skills they to being socially responsible and having a positive impact on society.
need to make informed financial decisions. We believe that by educating individuals and businesses about financial
Our programs are specifically designed literacy, we can create a more financially savvy and secure community.
to positively impact and strengthen links
Our primacy focus is to provide self-check convenience and increase credit

health awareness.
47
Value Creation in 2022
Focus Areas What We Do
Provide FREE & paid Reports We have provided more than 15.24 million free MyCTOS Basic Reports and over 1.42
million free MyCTOS Score and MyCTOS with CCRIS reports to consumers and businesses
alike, to encourage them to take charge of their credit health.
Financial Education Programs We offer integrated financial education programs, online and offline, year-round, to
through Media promote financial education and inclusion. Our content is available through newspapers,
magazines, e-news, e-magazine platforms, TV, radio, YouTube, and all our social media
channels.
Educational Content for Our website's Knowledge Base contains a vast array of educational content related
readerships to credit health, scoring, finances, budgeting, and more. Over 600,000 monthly visitors
benefit from the resources, and we expect the number to grow as more consumers
access credit health and financial education.
Roadshows and Webinars We've conducted 400+ financial education roadshows and webinars nationwide, in
partnership with Bank Negara Malaysia, the Ministry of Finance, the Employee Provident
Fund, the Credit Counselling and Debt Management Agency, the Ministry of Housing
and Local Government, the Private Pension Administrator Malaysia, the Social Security
Organization, Bursa Malaysia, various government agencies, banks, and property
developers. These initiatives aim to empower consumers to enhance their financial
management skills and improve their credit health and personal finances. We also
hosted 24 webinars that cater to SMEs.
Partnerships We partner with the Creador Foundation via its non-profit financial literacy platform
Multiply to provide regular financial education content across our social media channels.
This partnership gives consumers access to a broad range of tips and tools to manage
their personal finances.
Through these initiatives, we provide consumers with the opportunity to learn, engage, and strengthen their financial
management skills, empowering them to improve their credit health and personal finances.
OVERALL IMPACT
Increased number of Improvement Increased number of average

individuals registering for in average monthly visitors to Knowledge
CTOS self-check program CTOS Score Base hosted on CTOS website
15.24 million
2.47 mil
1.65 mil
Free MyCTOS Basic Reports

provided since 2016
678
675
1.37 mil
663
1.72 mil
1.02 mil
1.27 mil
1.42 million
MyCTOS Score and
MyCTOS with CCRIS Reports
provided since 2016
20’ 21’ 22’ 20’ 21’ 22’ 20’ 21’ 22’
48
M3 CUSTOMER WELFARE AND RESPONSIBILITY
Why Is It Important
Social responsibility drives us to discover and satisfy the

needs of our customers in ways that also provide for society's
well-being. As an agent of change in the community, we
have a role in ensuring the continuous development of
our local Small to Medium-Sized Enterprises (SMEs). We
must foster a responsive customer culture that emphasises
our responsibilities towards the customer’s welfare, as we
establish an emotional connection between our users and
our brand.
Acting in the best interests of our customers ensures we

consistently meet their needs, building our reputation as a
trusted and responsible organisation. This means protecting
our customers’ rights and delivering solutions that improve
their lives. Failure to meet these high standards could result
in damage to CTOS’s corporate reputation and business
performance. However, when done correctly, it can assist us
in attracting and retaining a strong customer base, thereby
contributing to our long-term growth and success.
We value our customers and strive to provide them with the best possible service. We begin by actively listening to their needs
and expectations to ensure that our services align with their requirements. Our goal is to create a seamless and satisfactory
experience for every customer, and we take their feedback seriously. We are committed to treating our customers fairly in all
aspects of our business and providing them with regular updates and information. To monitor our performance, we conduct
an annual Net Promoter Score (NPS) survey, which allows us to gather valuable feedback that we channel to our product
team to continuously improve our offerings.
Throughout the year, we continued to empower our customers through regular engagements as well as integrate digital
solutions into our customer journey. To support this, we employed different methods of customer engagement techniques to
ensure we can truly support our customers with the products and services they need to excel in their business.
What We Did How It Creates Value
Conducted checkpoint calls and offered face-to-face It allows us to form closer and more personal bonds with our
customer support across the six regions in which we customers, and build genuine relationships with them.
operate.
Actively conducted both online and face-to-face credit Due to the breadth of the end-to-end services, our employees
manager training for all of our support staff for our Software needed to be exposed to as many variables and situations
as a Service (SaaS) online credit management platform to be able to provide the most professional, all-rounded
that we offer to our SME customers. service to our customers.
Continue multiskilling our agents to optimise cost and Ensure customer enquiries through multi channels attended
increase productivity. on timely manner.
Increased our efforts to enforce quality monitoring These assessments ensure the accuracy and consistency
assessments for our customers. delivered to customers.
49
As part of our continuous improvement process, we benchmark the quality of our customer service against industry best
practices, in which we have significantly exceeded in 2022.
QUALITY SCORE*
Net Promoter
+12.83 +6.83 +4.8
Score (NPS)**
96.92% 93.06% 93.77%

(benchmark 85%) (benchmark 85%) (benchmark 85%)
20’ 21’ 22’
* Covering quality in both critical (compliance) and non-critical (soft skills in customer management) areas of the customer experience
** NPS – measures customers’ loyalty to the company
M4 EMPLOYEE ENGAGEMENT
Why Is It Important
In the pursuit of achieving sustainability, we believe that

having an engaged workforce is vital for continuous growth
and success towards our stakeholders and business.
Thus, fostering holistic engagements with our employees
help to promote positive working relationships across all
departments. In return, it improves our overall productivity
and enable employers to focus on higher-value activities
and business development. When employees are highly
invested in their job, they work harder because they like what
they do and believe in their value to the company.
Employees are truly the most trusted voice of our company.

High employee engagements have evidently made our
employees feel satisfied with their impact in CTOS. By
focusing on our employee’s wellbeing, we can create
higher employee performance and satisfaction that directly
increases long-term employee retention. Overall, employee
engagement is one of the core business objectives which
maintains our company’s morale towards stakeholders.
At CTOS, we understand that empowering our employees is instrumental to serving our clients and local communities better.
By investing in its employees' knowledge and skills, CTOS is not only improving its service delivery but also contributing to the
overall financial literacy of local communities.
50
It is important for us to build an engaged workforce and employee capabilities through a conducive and facilitative working
environment. We focus on a sustainable yet optimal commitment of our employees to invest in an environment in which
employees continuously develop their talents and use them in the most optimal manner. We position our people at the heart
of our company while empowering and inspiring them to constantly hone their talents and broaden their knowledge and
competencies.
A culture of continuous learning also promotes high employee engagement. That is why at CTOS, we have a comprehensive
learning & development framework to ensure that all employees receive continuous, regular, and adequate training. Some
examples of our learning and development work include refresher and onboarding training on company-wide policies,
training in the areas of risk and technology development in order to build cybersecurity awareness, and also on-the-job
competency training to cater to our employees’ further development.
Additionally, we comply with relevant labour laws on working hours / overtime and ensure fair labour standards within the
Group, and we strictly adhere to paying employees above national minimum wage. This is supported by an overtime policy
that applies to all employees beyond standard hours (as defined in the Employment Act 1955). CTOS further promotes work-
life balance by implementing work automation, process improvement and resource planning to reduce excessive working
hours. We also respect the rights for non-executives, trade workers and/or general employees to participate or form trade
unions provided for under the National Union of Commercial Workers (NUCW).
1. Employee Well-Being
We invested in both approached by implementing various initiatives to elevate our employee culture and developing the
knowledge and skills of our employees:
Focus Area What We Did
Collaboration • Established teambuilding activities and taskforces, including seasonal festive

celebrations and staff engagement activities throughout the year through our “WE
CARE” activities and our biannual dinners held once in two years.
Development • Created professional development programmes including trainings for our
employees.
• Provided product training for all new employees, where they are taught about
CTOS' suite of products and services. This training enables them to provide valuable
insights to clients who may be unfamiliar with credit reporting and scoring services.
• Upskilled our employees through a compulsory training on how to read a credit
report and sign up for CTOS self-check service. This self-check enables employees
to experience first-hand what it is like to pull their own credit report, understand their
own credit health status and help others too.
Health • Organised monthly engagement, medical screening and health activities.
Recognition of • Recognised high performance of our employees.
High Performance
Management KPI • Set employee engagement as a KPI for management performance to ensure
employees needs are integrated into decision-making.
51
2. Providing Fulfilment at Work
CTOS provides flexible working arrangements and are supportive of our employees engaging with and/or volunteering in
charitable organisations. We provide leave for charitable commitments on a case-by-case basis. At a company-level, we
are cognizant of the need to engage with charitable partners and as part of our 3-year roadmap, we target to design and
implement our own bespoke Employee Volunteerism CSR Program in 2023. We will also establish targets to monitor and
measure our progress in engaging our employees in charitable activities.
2021 2022
No. of non-compliances to labour standards 0 0

Employee attrition rate 3.3% 3.2%
Percentage of permanent employees 97.6% 88%*
Total training hours for employees 4,594 16,733
Average training hours per employee 9 29
* Lower % of permanent employees due to more interns
M5 DIVERSITY AND INCLUSION (D&I)
Why Is It Important
At CTOS, we believe in creating a working

environment free of discrimination,
harassment, victimisation. This means
every individual must be treated
equally and with respect, irrespective of
their age, gender, religion, backgrounds
and cultural values. An inclusive culture
embraces differences and enhances
the connection between our employees.
Diversity within our company creates
an environment in which people can
develop themselves which contributes
to the quality of our services. What is Our Approach
Providing a workplace that prioritises We are an equal opportunity employer, with a strict policy against any forms
diversity and inclusion will enable us of discrimination based on race, ethnicity, religion, nationality, gender or
to continue to build an environment disability. We do not discriminate when it comes to employment or pay. We
without any barriers to entry and career believe we can encourage our employees to thrive and gain access towards
advancement, an environment that unlocking and developing their full potential, by providing our employees
is purely based on equal opportunity with a fair and inclusive working environment. We take workplace bullying
and merit. While we need to provide a very seriously. Our employees also have access to a confidential reporting
conducive working environment that channel and a whistleblowing point of contact for harassment and hostility
practices equality and fosters an all- at the workplace. This is communicated and made readily available on our
inclusive spirit among our employees, it website for the accessibility of employees and other relevant stakeholders.
is equally imperative for us to cultivate
an inclusive and diverse talent pool that
forms the foundation of any successful Policies & Guidelines
business. Therefore, with a diversified
and inclusive workforce, we are able to Fit and Code of Business Whistleblowing
create a more innovative, resilient and Proper Policy Conduct and Ethics Policy
sustainable organisation.
52
Throughout the year, we implemented various programmes and initiatives designed to empower our employees, as well as
create a nurturing and inclusive work environment.
a. Designed flexible working b. Encouraged participation of c. Increased equal career

arrangement: all workers in company-wide progression opportunity for
activities: everyone:
We understand that our employees We value the participation of all We believe in providing equal
have diverse personal and our employees in company-wide opportunities for career advancement
professional responsibilities, and activities and events. We encourage to all our employees. We have
we strive to provide a flexible work everyone to share their ideas, established a merit-based system
environment that accommodates opinions, and perspectives, and that rewards performance, skills,
their needs. We offer various flexible we ensure that all voices are heard and experience, rather than gender,
working arrangements, such as and considered. We believe that ethnicity, or any other factors. We
telecommuting, flexible hours, and diversity and inclusivity are essential provide training and mentoring
job sharing, to ensure that our to fostering innovation and creativity, programs to help our employees
employees can achieve work-life and we celebrate our differences as develop the skills and competencies
balance while delivering quality work. a strength. needed for their desired career paths.
d. Offered equal training and development for e. Established a “We Care” (Engagement and Health
everyone: programme) for everyone:
We understand that our employees have diverse personal We value the participation of all our employees in
and professional responsibilities, and we strive to provide company-wide activities and events. We encourage
a flexible work environment that accommodates their everyone to share their ideas, opinions, and perspectives,
needs. We offer various flexible working arrangements, and we ensure that all voices are heard and considered.
such as telecommuting, flexible hours, and job sharing, to We believe that diversity and inclusivity are essential to
ensure that our employees can achieve work-life balance fostering innovation and creativity, and we celebrate our
while delivering quality work. differences as a strength.
Diversity & Inclusion Data
Throughout the year, we implemented various programmes and initiatives designed to empower our employees, as well as
create a nurturing and inclusive work environment.
3%
57% 43% 41% 59% 97%
Category of
Board Diversity Total Employees
Employees
Male Female Malaysian Non-Malaysian
53
EFFECTIVELY MANAGING COMPLIANCE AND RISKS
M6 COMPLIANCE TO EVOLVING REGULATIONS AND STANDARDS
We foster a culture that values

compliance with laws and
regulations. We regularly review
our processes against changes
in law and regulations to ensure
compliance.
The Compliance Strategy within

the Group is developed based on
the Board setting the tone from
the top of zero tolerance towards
any business non-compliance
with regulatory and statutory
requirements. The Compliance
Strategy focused on the following
key areas:
- Systematic review of monitoring

and evaluation of regulatory
requirements.
Why Is It Important - Adoption of a “Preventive rather
than reactive” approach.
At CTOS, compliance with laws, regulations, and industry standards is of utmost - Raising awareness though
importance. As a company, we are subject to a wide range of regulations in education and engagement.
areas such as data privacy, corporate governance, employment, and taxes.
Failure to comply with these regulations could result in legal and reputational By adhering to this approach, we
consequences, leading to damage and fines. Furthermore, regulatory changes ensure that we remain compliant
may lead to additional costs and a potential loss of expertise. Ensuring compliance and protect our customers,
is essential to protect our customers' data and our business in the long run. employees, and business.
54
In building a strong compliance culture within CTOS, we continued to implement various initiatives and programmes
throughout the year:
Focus Areas What We Did
Education, engagement and • Educated and raised awareness among a total of 577 employees through various
awareness-raising initiatives initiatives.
• Conducted mandatory employee training on the Credit Reporting Agencies Act,
PDPA, ABAC, and cybersecurity, followed by an exam to ensure comprehension.
• Distribute quarterly Regulatory newsletters to external parties, including CTOS
subscribers.
• Delivered a half-yearly risk assessment awareness newsletter to the Board of Directors,
Senior Management, and employees.
• Provided periodic reminders during town hall meetings by the Group Chief Executive
Officer on the company's zero tolerance towards ABAC, setting the tone from the top.
• Send periodic cybersecurity newsletters to promote cyber resilience and provide
updates on new or amended regulations.
Review and update on new • Conducted a gap and impact analysis on regulation changes, presenting the findings
regulations and amendments to the Board of Directors and Senior Management.
to existing regulations • Established a task force and committee to implement changes related to regulation
amendments.
• Validated and tested internal processes and applications, tightened business
processes to mitigate compliance risks.
Tighten business processes to • Enhanced the necessary requirements regarding submission of documentation for
mitigate compliance risk credit check review.
• Implemented a risk-based approach to customer segmentation and raised awareness
on security standards.
Raise information security • Commenced the ISO27001 implementation to establish robust information security
standards management.
• Introduced new SOP to perform sophisticated security assessment such as compromise
assessment, red teaming or breach and attack simulations on regular basis.
Regular engagement with • Clarify and align new digital processes during meetings to ensure continued
Regulators compliance.
• Implemented initiatives to improve financial literacy for Malaysians.
• Implemented initiatives to grow the credit reporting industry in Malaysia.
Through our strong compliance and regulatory culture, we have consistently reported zero non-compliances for the past
three years, as well as passed our annual audits by the Ministry of Finance (MOF) and Bank Negara Malaysia.
Annual audit by the

Annual audit by an
Registrar Office of Penalty, private or
independent auditor for Regulatory
the Credit Reporting public reprimand by
continuous access non-compliances
Agencies for CRA Regulators
to BNM
license renewal
Pass Satisfactory 0 0
All the data is the same from the year 2020 to 2022
55
M7 BUSINESS ETHICS
Human Rights into our business

operations. As practice, human
rights policy training is covered
under Code of Conduct during
onboarding training, which is
applicable to all staff.
In the future, we will explore aligning

our human rights commitments to
include reference to international
human rights instruments,
including those contained within
the International Bill of Human
Rights, such as but not limited to
Convention on the Elimination of
All Forms of Discrimination against
Women, Convention on the Rights
Why Is It Important of the Child, Convention on the
Rights of Persons with Disabilities
Ethics and integrity are fundamental to any business. Without a strong set of ethics, etc.
a business can run afoul of relevant laws and regulations, encounter financial
pitfalls and moral dilemmas. Companies that practice questionable ethics may We are in the midst of establishing
also experience a decrease in stock price and severed business partnerships, oversight responsibility and
which can affect profitability. In addition, business ethics contribute to improved resources to ensure respect for
customer and stakeholder loyalty. It cultivates trust and builds our reputation as a human rights. The Audit Risk
responsible organisation, which strengthens branding and revenue and therefore Committee and Risk Management
improves overall improve profitability. Committee currently have oversight
responsibility of human rights
What is Our Approach issues. Day-to-day responsibilities
lie with our Human Resources and
Integrity is essential and one of the core values of CTOS. We encourage our respective Heads of Departments
employees to carry out their daily responsibilities above and beyond compliance who oversee compliance with our
with laws and regulations. Ethical behaviour will increase employee performance, Code of Business Conduct and
job satisfaction, organisational commitment and trust from key stakeholders. We Ethics.
take our social responsibility as an employer and make sure all our employees
work in a healthy and safe environment. Working ethically and ensuring high Additionally, CTOS is strictly against
standards of integrity are key to business sustainability and resiliency. and opposed to child labour. We
ensure strict compliance within our
We have currently established mechanisms such as CTOS’ Whistleblowing Policy, operations with Children’s Rights as
Anti-Bribery and Corruption Policy, Code of Conduct and Human Resources’ Open per the Child Act and the Children
Door Policy, which are available to both internal and external stakeholders. These and Young Persons (Employment)
policies provide a formal mechanism for any grievances to be raised, including Act. As we aim to apply principles of
human rights, while guaranteeing confidentiality/anonymity. At onboarding the Global Reporting Initiative (GRI),
training, all employees are required to study and acknowledge these policies, thus United Nations Global Compact
fostering a strong culture of integrity and ethics. (UNGC) and the United Nations
Guiding Principles on Business
We are committed to work with affected parties when/where human rights have and Human Rights in the future,
been impacted to remedy the impacts caused or contributed. Additionally, we we will also explore opportunities
apply principles of the Global Reporting Initiative (GRI), United Nations Global to support children’s rights in our
Compact (UNGC) and the United Nations Guiding Principles on Business and operations or programmes.
56
Throughout the year, we continued to integrate good ethics into our business through by focusing on the key areas:
Focus Areas Our Approach
Anti-Corruption Practices Tightening ABC (Anti-Bribery and Corruption) P&P and framework and review of DOA.
Whistleblowing Monitored misconduct via a whistleblowing channel (internal and external), with
employees encouraged to report bribery and corruption concerns promptly.
Awareness Implemented Anti-Corruption and Bribery awareness programmes and communications
to employees and other stakeholders, which are performed on an annual basis. By doing
so, we create more awareness on the reporting of bribery and corruption concerns.
Risk monitoring Monitored corruption and bribery risks and reported it via ARC on a quarterly basis.
Performance Management Reinforced behaviour expectations by setting clear links of integrity to their performance
management.
Due diligence of third parties Conducted due diligence on all third parties linked to our business operations and
activities.
In the past three years, we consistently recorded zero cases of human rights breaches, bribery, corruption or unethical issues,
with zero related fines and penalties. This reflects our team’s commitment to upholding the highest standards of ethics and
integrity.
Human Other
Rights Bribery Corruption unethical
Breaches issues
0 0
0 0
All the data is the same from the year 2020 to 2022
M8 FRAUD RISKS
Why Is It Important
We are dedicated to establishing an ethical business culture that emphasises

proper conduct and management of potential risks to our business. Our
top priority is combatting fraud risks to safeguard our stakeholders. Effective
fraud prevention not only reduces financial losses but also aligns with our
company's values. By valuing fraud prevention highly, our stakeholders,
including employees, are encouraged to embrace the same values.
We adhere to comprehensive regulations and standards and prioritise

implementing an enterprise risk management framework to address
potential risks. Any fraudulent activities, such as identity theft in the loan
origination or credit application process, are strategically investigated at
CTOS. Our risk management practices ensure that materiality issues related
to compliance and risk management are well-reported and deliberated in
our annual Audit & Risk Committee ("ARC") meetings. This reinforces our
commitment to maintaining a culture of integrity and transparency at CTOS.
57
Additionally, we comply with the Federal Constitution and other relevant labour laws with regards to freedom of association.
Although we do not restrict the right to freedom of association for its employees, employees shall not hold any position in a
political party, in line with CTOS’ Code of Business Conduct and Ethics and Whistleblowing Policy.
To build an effective anti-fraud strategy, we carry out several measures to promote fraud risks prevention, detection and
investigation.
Prevention Detection Investigation

• Perform strict SOP customer • Review customer sign-ups • Perform routine audit checks
sign-ups regularly • Report potential fraud risks to
• Set Anti-Bribery & Corruption • Perform B2B assessment the Board
policies
As of 2022, our approach has been effective in detecting potential anomalous or fraudulent activities in our business.
ESTABLISHING TRUST IN DATA
M9 DATA PRIVACY & SECURITY
Why Is It Important
Given the nature of our business, any attack on our system can
result in severe consequences. We possess critical information within
our system that, if breached, may negatively impact our customers.
This includes potential financial losses, identity thefts or leaking of
sensitive information. Therefore, it is our corporate responsibility to
safeguard the data entrusted to us by our customers and other
stakeholders. Additionally, attacks on our systems may also disrupt
our business. Because we operate in a digital environment, potential
cyber security issues may halt our operations and activities until
the problem is resolved. This can have a significant impact on our
financial performance, as well as our ability to serve customers.
Therefore, as Malaysia’s leading credit reporting agency and a
provider of data and digital services, safeguarding our customers
data and privacy is fundamental to the sustainability of our business.
At CTOS, we define privacy and security as the provision of complete and accurate disclosure of business activities, data
handling, data use and other material matters to maintain trust and facilitate productive discussions between us and our
stakeholders. Our cyber security posture, which is underpinned by people, processes, and technology, is aligned with industry
best practises and regulatory requirements, and is designed to withstand cyber-attacks and enhance cyber resilience.
Our management team has devised a Three-Year Cyber Security Strategy that was rolled out in January 2023 that serves as
a guiding principle to achieve the end-state. One of the key objectives under the Strategy is to become a ISO 27001 certified
organisation by 2025. The strategy is governed by a variety of policies and frameworks, both internal and external to the
organisation, such as:
58
CTOS’ Risk Management Policy

1
Aligns with ISO 27001 and covers key components to managing cyber
security risks, including:
- Cyber-Resilience Framework (“CRF”) that protects our customer’s data
- Technology Risk Management Framework (“TRMF”)
Bank Negara Malaysia (BNM) Risk Management in Technology (RMiT)

POLICIES & Sets out the central bank’s requirements with regard to financial institutions'
2
FRAMEWORKS management of technology risk and given that we largely serve the
financial sector, we actively align our security practices with RMiT.
National Institute of Standards and Technology (NIST)

Cyber security Framework
Guides businesses of all sizes to better understand, manage, and reduce
their cyber security risk and protect their networks and data. This framework
3 guides all of CTOS' efforts to enhance cyber resilience, which comprises
the five essential components of cyber security: identification, protection,
detection, response, and recovery.
In addition to the adoption of frameworks above, we have implemented sophisticated mitigation mechanisms, such as continuous
vulnerability management, managed detection and response for endpoints, security operations centre, multi-factor authentication,
data loss prevention and micro-segmentation of network. We have also implemented a comprehensive cyber security awareness
programme that includes regular phishing simulations throughout the year for all employees. A robust governance process is also in
place to help us identify risks in technology operations and project management, ensuring regular reviews by the Board of Directors
and Senior Management.
In 2022, our company put in place a number of sophisticated countermeasures to improve our cyber security. These included
continuous vulnerability management, managed detection and response (MDR) for endpoints, a security operations centre (SOC),
data loss prevention (DLP), and micro-segmentation of the network. Together, these measures made us much more resistant to cyber-
attacks and better prepared to respond to them.
Implementation of Risk Mitigation

countermeasure
Continuous Continuous vulnerability management let us keep an eye on our systems and applications and find
vulnerability any possible flaws.This let us quickly patch and fix any problems before attackers could take advantage
management of them. This proactive approach helped to monitor and manage the overall attack surface of our
systems, making it harder for threat actors to get in.
Managed detection MDR for endpoints helped make sure that any attempts to break into our systems were quickly found
and response (MDR) and dealt with. By keeping an eye on endpoint activity in real time, we were able to spot and stop any
for endpoints suspicious activity, making it less likely that a breach would be successful.
Security operations The SOC gave us a central place to watch for and respond to cyber events and potential incidents.
centre (SOC) This made it possible for us to handle any network alerts quickly and effectively.
Data loss prevention DLP helped us intercept and stop the unauthorised transfer of sensitive data from inside the company
(DLP) to outside world. This decreased the chance of data leakages and made sure that our customers'
data was safe.
Micro-segmentation Lastly, micro-segmenting the network helped improve our security by breaking it up into smaller, more
of the network secure pieces. This made it harder for attackers to move laterally and helped us contain any possible
security breaches to a smaller and limited radius.
59
Overall, these measures have made us much more resistant

to cyber-attacks and better prepared to deal with them. Maintained ZERO validated
By being proactive about cyber security, we have greatly security breaches record
reduced the chance that an attack will be successful
and made sure that our systems, data, and customers will
2022 2021 2020
continue to be safe.
As a testament to our robust and resilient cyber security

0 0 0
system, we continue to maintain a record of zero validated
security breaches.
M10 TRANSPARENCY AND TRUST
To ensure that we maintain

the trust of our stakeholders,
we have implemented a
number of measures to
promote transparency and
protect our customers' data.
First and foremost, we handle
all customer data with
the utmost confidentiality.
We understand that our
customers trust us to
protect their personal
information, and we take
that responsibility very
seriously. To mitigate the
risks of data breaches, we
Why Is It Important protect personal data from
unauthorised access and
As Malaysia's leading credit reporting agency, our customer's trust is significantly defend against attacks
important for us to manage their data effectively. It is our duty to provide credible data that aim to exploit our
for our customers that will assist them to make better informed decisions. We recognise information.
that our stakeholders need accurate information to make informed decisions about
our strategies, outcomes, and effectiveness. This is why transparency is critical for our We also provide sufficient
company. We are committed to being entirely transparent to all parties, as we understand and effective external
that transparency helps build trust in our business operations. Our customers trust us to communication through
manage their data effectively, and we are committed to maintaining that trust. our official website, service
offerings, and vendor
We firmly believe that transparency and trust play a vital role in ensuring the sustainability agreements. By doing so, we
of our business growth. By being transparent and demonstrating our integrity, we are able can ensure that there is no
to foster long-term relationships with our stakeholders, which is essential for the continued room for miscommunication
success of our business. Therefore, we will continue prioritising transparency and honesty and that all parties share
in all our operations to ensure we remain a trusted partner to all our stakeholders. the same expectations.
60
KEY APPROACH IMPACT
Implement monitor trackers Ensure the completeness of our data
Undertake Investor Relations activities domestically Assist investors to make a fair valuation and assessment
and overseas of the company's prospects
Perform periodic audit by specialised third party Ensures business specific compliances such as financial
consultants and professionals and accounting, anti-bribery and anti-corruption
Perform consistent reviews by internal and external Ensure adequate risk management of internal controls
auditors activities
At CTOS, we take the security of our data and compliance with regulations seriously. With this in mind, we have implemented
a number of key initiatives to ensure that we maintain the highest levels of security and compliance in all our operations. One
of our top priorities has been enhancing the security of our data and protecting it against unauthorised access. To achieve
this, we've implemented multifactor security measures to safeguard against any potential threats and protect the transfer of
data to our subscribers.
We have also taken major steps to strengthen our existing policies for third party management. This includes reassessing our
process for conducting risk-based assessments on all third-party organizations, with a keen eye for potential red flags such
as past integrity issues, pre-existing or potential business relationships with CTOS, or affiliations with public officials. We also
enhanced checks on the third-party organization's anti-bribery programme for higher risk transactions.
In addition, we implemented quarterly updates to our Audit and Risk Committee (ARC). These periodic updates provide
our Board with a comprehensive overview of our compliance and risk management matters on a regular basis. We've also
included sustainability matters as part of the quarterly update to the ARC to provide the Board greater oversight of our long-
term sustainability initiatives and commitments.
As we move forward, we will continue to prioritize the security of our data and compliance with industry best practices to
maintain our position as a trusted partner to our customers and stakeholders. At CTOS, we remain committed to maintaining
the highest levels of compliance and risk management standards across all our operations.
61
CORPORATE GOVERNANCE
OVERVIEW STATEMENT
Corporate Governance Overview Statement 63
Audit & Risk Committee Report 82
Statement on Risk Management & Internal Control 87
62
OVERVIEW STATEMENT
FOR THE FINANCIAL YEAR ENDED 31 DECEMBER 2022
CTOS Digital Berhad (“CTOS Digital” or the “Company”) and its subsidiaries
(the ”Group” or “CTOS”) are committed to high standards of corporate
governance (“CG”) and believe good governance ethics are critical to
enhance shareholders’ value, business integrity and performance, and set as the
fundamental to achieve the Group’s mission, vision and corporate objectives.
The Board of Directors (“Board”), Management, and employees are constantly working to improve the Group’s CG practices
and processes and strive to uphold the CG principles.
The Board is pleased to present this CG Overview Statement for the financial year ended 31 December 2022 (“FYE 2022”)
in line with the Malaysian Code on Corporate Governance 2021 (“MCCG 2021”) and Main Market Listing Requirements
(“MMLR”) of Bursa Malaysia Securities Berhad (“Bursa Securities”) based on the following MCCG 2021 principles:-
PRINCIPLE A PRINCIPLE B PRINCIPLE C
Board Leadership Effective Audit & Integrity in Corporate

and Effectiveness Risk Management Reporting & Meaningful
Relationship with Stakeholders
The CG Overview Statement shall be read together with the CG Report 2022 (“CG Report”), available on the Company’s
website at www.ctosdigital.com. The comprehensive details of the Company’s overall approach and specific practices
pertaining to CG are disclosed in the CG Report detailing how the Company has applied each of the practices set out in
the MCCG 2021.
PRINCIPLE A – BOARD LEADERSHIP AND EFFECTIVENESS
I BOARD RESPONSIBILITIES
(A) Board of Directors
The Board is primarily responsible for the effective governance and management of the Group and also serves as
fiduciary responsibility for the Group’s financial and organisational health. Ultimately, the Board is collectively responsible
to ensure that sustainable value is delivered to its stakeholders. Each Director has a legal duty to act in the best interest
of the Group and the Directors collectively and individually are aware of their responsibilities to the stakeholders for the
manner in which the affairs of the Group are managed.
Details of which are set out in the Board Charter which is published on the Company’s website at
www.ctosdigital.com/corporate-governance
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OVERVIEW STATEMENT
In order to discharge of its stewardship role effectively, the Board has delegated its authority and specific duties and
responsibilities to the following Board Committees to carry out the Board’s oversight functions, each of which is explained
further in details under item E, Board Committees of this CG Overview Statement.
Please refer item E, Board Committees on page 67.
BOARD OF DIRECTORS
AUDIT AND NOMINATION AND BOARD INVESTMENT

RISK COMMITTEE REMUNERATION COMMITTEE COMMITTEE
All the Board Committees are actively engaged and act as oversight committees. They contemplate and recommend
matters under their purview for the Board to consider, approve and make the final decision. The Board also receives
updates from the respective Chairman of the Board Committees on matters that have been discussed and deliberated
at the respective meetings.
Essentially, the Board communicates its directions to Management through the Group Chief Executive Officer (“GCEO”),
who oversees their implementation. Management is responsible for the day-to-day management of the Group pursuant
to the powers delegated by the Board, subject to compliance with the applicable laws and regulations.
(B) Chairman and the GCEO
In maintaining effective supervision and accountability of the Board and the management, the position of Chairman
and Group Managing Director/Chief Executive Officer are held by different individuals, thereby ensuring balance of
power and authority. The segregation of roles also facilitates a healthy open, exchange of views between the Board and
Management in their deliberation of the business, strategic aims and key activities of the Company.
The Chairman of the Company is Tan Sri Izzuddin Bin Dali, an Independent Non-Executive Chairman who is primarily
responsible for the stewardship and smooth functioning of the Board especially taking a leading role in establishing
effective CG system and practices. The Chairman also leads the Board meetings by encouraging active participation
and allowing dissenting views to be expressed freely to ensure that discussions and contributions from all Directors are
forthcoming on matters being deliberated and that no Board member dominates the discussion.
The GCEO of the Company, Erick Hamburger Barraza is primarily responsible for the execution of business plans in line
with the Board’s direction and drives the business and performance towards achieving the Group’s vision and goals as
well as the day-to-day management of the Group, within the authorities as delegated by the Board.
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OVERVIEW STATEMENT
(C) Board Meeting and Access to Information and Advice
The Board is required to meet quarterly with additional meetings being convened as and when necessary to consider
urgent proposals or matters that require that Board’s consideration. To facilitate the Directors’ time planning, an annual
meeting calendar will be prepared and circulated before the beginning of each year.
The Board held thirteen (13) Board Meetings during the FYE 2022 and the attendance record is as follows:
Total Number of Board Meetings

Directors / Designation Attended during FYE 2022
Tan Sri Izzuddin Bin Dali

9/13
(Independent Non-Executive Chairman)
13/13
(Independent Non-Executive Director)
Loh Kok Leong
(Non-Independent Non-Executive Director) 9/13
(Alternate Director: Wong Pau Min)
Erick Hamburger Barraza1
3/3
(Executive Director/ GCEO)
Lynette Yeow Su-Yin
11/13
Nirmala A/P Doraisamy
13/13
Su Puay Leng
12/13
Datuk Azizan Bin Haji Abd Rahman2
1/3
Dennis Colin Martin3
6/10
(Non-Independent Non-Executive Vice Chairman/GCEO)
1
appointed as GCEO on 1 May 2022 and subsequently appointed as Director on 30 September 2022
2
resigned with effect from 7 March 2022
3
retired as GCEO on 30 April 2022, redesignated to Non-Independent Non-Executive Vice Chairman on 1 May 2023 and subsequently resigned
as Director with effect from 30 September 2022
The Board recognises the importance of timely dissemination of Board and Board Committee papers as well as minutes
of meetings to all Directors within a reasonable period prior to the Board and Board Committee meetings to enable
them to receive the information in a timely manner and facilitate decision making by the Board and to deal with
matters arising from such meetings. In ensuring the effective functioning of the Board, all Directors have individual and
unrestricted access to the advice and support services of the Company Secretaries, Internal Auditors, External Auditors
and Independent Advisers, if deemed necessary and may seek advice from the management on issues under their
respective purview.
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OVERVIEW STATEMENT
(D) Board Charter, Codes and Policies Anti-Bribery and Corruption Policy
The Board has the following in place:- CTOS has an established Anti-Bribery and Corruption
(“ABC”) Policy which sets forth the Group’s overall
Board Charter position against bribery and corruption in all its forms and
the Group’s objective in ensuring full compliance with
The Board Charter clearly set out the key values, all applicable anti-corruption regulatory requirements
principles and ethos of the Company, as policy when conducting its business and operation. The ABC
delineates the roles of the Board (including matters Policy further seeks to ensure that the Group adheres to
reserved for the Board), the Chairman, the GCEO, the the principles of good CG and emphasises on operating
Independent Director, the Board Committees and its business with transparency.
individual Directors. It provides structure guidance
and ethical standards for Directors and Management The Group has adopted a zero-tolerance approach
in discharging their duties towards the Company as against all forms of bribery and corruption. Employees
well as the Board’s operating practices. The Board who refuse to pay bribes or participate in acts of
will review the Board Charter annually and make any corruption will not be penalised even if such refusal may
necessary amendments to ensure that they remain result in losing business.
consistent and relevant with the Board’s objectives,
operating environment, current law and practices. This policy is applicable to the Group, business
associates, resellers, agents and distributors acting on
Code of Business Conduct and Ethics (“Code”) the Group’s behalf, the Board of Directors and all the
Group’s personnel.
The Code sets out the minimum standards which
require all employees to comply with areas and Directors’ Remuneration Policy
situations where public trust and confidence might
be compromised, or a law might be violated. The This Policy serves as a guidance to set an appropriate
Code serves as a guide for proper standards of level of remuneration that allows the Company to attract
business ethics and conduct for the Group and and retain talented and well-qualified Directors for the
the same shall not derogate, replace, or restrict the long-term business strategies of the Group.
matured judgement of the employees in conducting
their daily activities.
Directors’ Qualification, Fit and Proper Policy
Whistleblowing Policy
During the FYE 2022, CTOS had adopted a Directors’
CTOS has established a Whistleblowing Policy and Qualification, Fit and Proper Policy. It sets out the
it embodies the Group’s commitment to promote standards and the expectations on the suitability of both
and maintain high standards of transparency, the candidate and the current Directors of CTOS. The
accountability, ethics and integrity at the workplace. Policy shall provide transparency on the selection for the
This policy provides an avenue for employees and Board composition in order to ensure that the Directors
third parties (includes external agencies and any of CTOS have the character, integrity and competence
parties with a business relationship with the Group) required to perform the roles and responsibilities of a
to disclose cases of improper conduct which include Director of a public listed company.
criminal offences, fraud, corruption, non-compliance
to laws and regulations, breach of Group’s policies The Board believes that these documents define the
and the Code or other malpractices without the fear Group’s commitments towards issues relevant to good
of reprisal. corporate governance and are periodically reviewed to
ensure relevance and applicability.
They are all accessible on the Group’s website at

www.ctosdigital.com/corporate-governance
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OVERVIEW STATEMENT
(E) Board Committees
The Board Committees are to examine specific issues within their respective approved terms of reference (“TOR”) and
report to the Board with their recommendations. However, the ultimate responsibility for decision making remains with
the Board.
The TOR of the Board Committees are available for reference on the Group’s website at www.ctosdigital.com/corporate-governance
The Audit & Risk Committee
The Audit & Risk Committee (“ARC”) assists the Board in carrying out its statutory and fiduciary responsibilities related
to the monitoring and management of financial risk processes, as well as its accounting practices, system of internal
controls, and the Group’s management and financial reporting practices. To accomplish this, the ARC oversees the
reports of external and internal auditors, uphold the integrity of financial reporting, and ensures a sound system of risk
management and internal controls to protect and enhance the Company’s value.
A full ARC report is set out on pages 82 to 86 of this Annual Report.
The Nomination & Remuneration Committee
The Nomination & Remuneration Committee (“NRC”) is responsible for overseeing the nomination and selection of
Board members and GCEO, assessment framework for Senior Management, assessing and monitoring the Board’s
composition and effectiveness, undertaking development needs and succession planning initiatives, recommending
and reviewing policies and the remuneration structure/ framework for the Board and the Senior Management.
The NRC comprises entirely Non-Executive Directors, majority of whom are independent. During FYE 2022, there were
three (3) meetings held. The details of members of the NRC and the attendance record of meetings are as follows:
Total Number of NRC Meetings

NRC Members Designation Attended/Held
Lynette Yeow Su-Yin

Chairman 3/3
Member 3/3
Loh Kok Leong
Member 3/3
(Non-Independent Non-Executive Director)
The NRC is responsible in assisting the Board to ensure composition of the Board is refreshed periodically. Nomination
to the Board takes into consideration that the Board has appropriate size and a balanced composition with a diverse
mix of skills, knowledge, qualifications, experience, age, cultural background, and gender diversity in order to ensure its
effectiveness in discharging its duties. The tenure of each director is reviewed by the NRC and annual re-election of a
director is contingent upon satisfactory evaluation of the director’s performance and contribution to the Board as well
as the result of Fit and Proper Criteria Assessment.
The NRC had carried out the following activities in discharging its duties for FYE2022, inter alia:-
1. Reviewed the Board Composition of the Company.

2. Reviewed the Directors’ Qualification, Fit and Proper Policy.
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OVERVIEW STATEMENT
3. Reviewed the Director’s Service Contract for the Executive Director and Non-Independent Non-Executive Director
and the Addendum to the Letter of Appointment for the Independent Non-Executive Directors.
4. Reviewed the 2022 Key Performance Indicators (“KPIs”) for the C-Level executives.
5. Reviewed the trainings undertaken and the trainings recommended for Directors to attend.
6. Reviewed and recommended to the Board, the re-election and retirement by rotation of Directors at the 2022
Annual General Meeting (“AGM”).
7. Conducted the annual assessment of the Board, the Board Committees and the individual Directors.
8. Reviewed terms of office of ARC and each ARC member.
9. Reviewed the independence of Independent Directors.
10. Reviewed the remuneration packages of the Executive Director, Non-Executive Directors and Senior Management
of the Company.
11. Reviewed the nomination of Erick Hamburger Barraza as GCEO of the Company following the retirement of Dennis
Colin Martin as GCEO for recommendation to the Board.
12. Reviewed the appointment of Dennis Colin Martin as Vice Chairman to the Board.
13. Reviewed the appointment of Erick Hamburger Barraza as Executive Director including the assessment under the
Directors’ Qualification, Fit and Proper Policy.
14. Reviewed the FYE 2022 performance bonus and 2023 salary increase for GCEO, C-Level executives and overall
FYE2022 bonus pay-outs.
15. Reviewed the appointment of additional company secretary.
In addition to the nomination matters, the NRC is also responsible for providing oversight on the remuneration matters
of the Company. A more detailed description on the remuneration matters is provided in the Remuneration Section of
this CG Overview Statement.
The Board Investment Committee
The Board Investment Committee (“BIC”) is responsible to review and make recommendations on all matters in respect
of acquisitions and divestments of any business/investment including short term investments, within Malaysia or
overseas, subject to the relevant threshold as required under the MMLR of Bursa Securities.
The BIC comprises entirely of Non-Executive Directors who are majority independent. During the year under review, there
were four (4) meetings held. The details of each BIC’s members and their respective attendance record of meetings are
as follows:
Total Number of BIC Meetings

BIC Members Designation Attended/Held

Chairman 4/4
Su Puay Leng
Member 4/4
Loh Kok Leong
Member 3/4
(Non-Independent Non-Executive Director)
During FYE 2022, the BIC had undertaken the following activities in discharging its duties:-
1. Reviewed few acquisitions of stakes in RAM Holdings Berhad (“RAM”) from various shareholders of RAM; and
2. Reviewed the opportunity to acquire origination & decisioning portfolio of contracts in Malaysia.
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OVERVIEW STATEMENT
Company Secretaries Sustainability
The Board is supported by competent and qualified Company Secretaries who The Board together with
play a vital role in advising the Board in relation to the Company’s Constitution, Management are responsible
the Board policies and procedures and the applicable laws and regulations are for the governance of
complied with. The Company Secretary also assists the Board of Directors in its sustainability in the Group
leadership role, fiduciary duties, and governance stewardship. All Directors have including setting the Group’s
unrestricted access to the advice and services of the Company Secretary for the sustainability strategies,
purpose of the conduct of the Board’s affairs and the business. priorities and targets. The Board
provides guidance and has an
During the FYE 2022, Ms Sia Ee Chin resigned as Company Secretary and Ms Saw oversight role for the Group’s
Hui Ying has been appointed in place thereof. Ms. Joanne Toh Joo Ann and Ms. sustainability matters including
Saw Hui Ying are Company Secretaries of CTOS Digital. They further serve as the among others the development
Company Secretary of CTOS Digitals’ subsidiaries. and implementation of the
sustainability strategies,
The Company Secretaries ensures that the discussions and deliberations at Board business plans, major plans of
and Board sub-committee meetings are well documented, and subsequently action and risk management.
communicated to the Management for appropriate actions, as well as updating
the Board on the follow-up of its decisions and recommendations. The Company’s efforts in this
regard have been set out in
the Sustainability Statement on
During FYE 2022, the Company Secretaries had undertaken various activities in pages 31 to 61 of this Annual
discharging their duties, details of which are outlined in the CG Report. Report.
II BOARD COMPOSITION
(A) Board Composition and Boardroom Diversity
The Board recognises that a truly diverse and inclusive Board will leverage the differences of its members, to achieve
effective stewardship and in turn, retains its competitive advantage. In this respect, the Board through its NRC conducts
an annual review of its size and composition, to determine if the Board has the right size and sufficient diversity with
independence elements that fit the Company’s objectives and strategic goals.
As at 31 December 2022, the Board consists of eight (8) members, comprising of five (5) Independent Non-Executive
Directors (including one (1) Independent Non-Executive Chairman), one (1) Executive Director, one (1) Non-Independent
Non-Executive Director and one (1) Alternate Director (to Non-Independent Non-Executive Director).
A brief profile of each Director is presented in pages 20 to 27 of this Annual Report.
CTOS Digital believes that having a diverse Board provides a compelling competitive advantage. The Directors
collectively bring with them diverse knowledge, skill, extensive experience and expertise in areas such as corporate
strategy, economics, banking & finance, investments, risk management, corporate legal, mergers and acquisitions and
securities regulations. These enable them to discharge their duties and responsibilities effectively and objectively on
the Company’s strategies, compliance and business operations. By combining contributions of a group of people with
different skills, backgrounds, and experiences they are able to approach problems from a greater range of perspectives,
to raise challenging questions and to debate more vigorously. Multiple-perspective analysis of problems can change the
boardroom dynamics and is more likely to be of higher quality than decisions made under a 'groupthink' environment.
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OVERVIEW STATEMENT
CTOS Digital also respect the cultural diversity in the as members of the Board, representing 42.9% of female
Company in terms of ethnicity, race, religion and beliefs. representation on the Board.
Multiculturalism provides a variety of viewpoints along with
wide-ranging personal and professional experience which In addition, diversity at Senior Management will provide
offer new perspectives for looking at a business issue. It constructive debates, which lead to better decisions and
gives rise to out-of-the-box thinking for solving problems enabling discussion in an ever-changing environment.
and making sound business decisions. The Company The Board also values the diversity of perspectives and
embraces the differences and appreciates an individual’s experience at Senior Management level for better decision
contribution from different backgrounds for creating an making and competitive advantage. As at 31 December
inclusive environment where everyone feels valued and 2022, 50% of the Senior Management positions of the
respected. These divergences bring unique perspectives Company are held by women.
and insights for better risk management and allow for
difference in opinion and perspectives and all thoughts The criteria, processes, and requirements in terms of
to be deliberated to enable the Board for making an nomination, assessment, and re-election of Board
informed decisions which enhance shareholders’ value members are outlined in the Company’s NRC’s TOR and
and build stronger stakeholder engagement. Directors’ Selection Policy. In addition, the Board Charter
of the Company outlines the approach to diversity for the
The Board also acknowledges the need to promote Board, including gender, age, and ethnic diversity.
gender diversity within its composition and endeavour
to increase female participation in the Board and Senior Read about our diversity policy for board members in our Board
Management. Currently, there are three (3) women serving Charter at www.ctosdigital.com/corporate-governance
(B) Board Independence
Under CTOS Digital’s current Board composition, there are 7 Directors (excludes alternate director), out of which 5 Directors
are Independent Non-Executive Director, including the Chairman of the Company. The present Board composition complies
with Paragraph 15.02 of the MMLR which requires at least two (2) or one-third (1/3) of the Board of the Company, whichever is
higher, are Independent Directors.
The Board recognises the importance of significant representation by Directors who are capable and willing to make decisions
in the best interest of shareholders, free from any conflict of interest, and are also independent of Management. The Board is
satisfied that the current number of Independent Non-Executive Directors provides a fair check and balance in terms of bringing
independence of judgement and ensuring the Board’s decisions are made objectively in the best interest of the Company.
In line with the MCCG 2021 and the Board Charter, the tenure of an Independent Non-Executive Director should not exceed
a cumulative term of nine (9) years. Upon completion of nine (9) years, an Independent Director may continue to serve on
the Board subject to the Director’s re-designation as Non-Independent Director. If the Board intends to retain an Independent
Non-Executive Director who has served a cumulative term of nine (9) years in the Company, the Board must provide a strong
justification and obtain the approval of the shareholders. As at the date of this CG Overview Statement, none of the Independent
Non-Executive Director has reached nine (9) years of service since their appointment. The tenure of the respective Independent
Non-Executive Director as at 31 December 2022 are as follows:
Name of Directors Tenure
Tan Sri Izzuddin Bin Dali 8 years, 4 months

Dato’ Noorazman Bin Abd Aziz 2 years, 10 months
Lynette Yeow Su-Yin 2 years, 3 months
Nirmala A/P Doraisamy 1 year, 9 months
Su Puay Leng 1 year, 7 months
Datuk Azizan bin Haji Abdul Rahman Resigned with effect from 7 March 2022
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OVERVIEW STATEMENT
(C) Appointment and Re-appointment of Directors
Appointment of Board and Senior Management are based on objective criteria, merit and with due regard for diversity in skills,
experience, age, cultural background and gender. Directors appointed should be able to devote sufficient time to serve the
Board effectively. The Board should consider the existing Board positions held by a director, including on Boards of non-listed
companies. Any appointment that may cast doubt on the integrity and governance of the Company should be avoided.
In identifying candidates for appointment of directors, the Board does not solely rely on recommendations from existing
directors, management or major shareholders. The Board utilises independent sources to identify suitably qualified candidates.
If the selection of candidates was based on recommendations made by existing directors, management or major shareholders,
the NRC will explain why these source(s) suffice and other sources were not used.
Under the NRC’s TOR, the NRC may utilise independent sources and a variety of approaches to identify suitably qualified
candidates. The NRC would disclose the source, including whether such candidates were recommended by the existing
Directors, Members of Senior Management or major shareholders.
In addition, the Board had established Directors’ Selection Policy to capture the selection process for the appointment of
Directors. Under the Policy, the NRC shall proactively exchange views with Board Members to study and identify the needs of
the Company for new Directors and would request nominations from the Board, as well as actively seek suggestions for possible
nominees from other sources. The NRC may consider using executive search firms to assist with finding candidates with the
required skills and background.
Under the Constitution of the Company, a one-third (1/3) of the Directors for the time being, or, if their number is not three (3) or
a multiple of three, then the number nearest to one-third (1/3), shall retire from office at the conclusion of the AGM in every year
provided always that all Directors shall retire from office once at least in each three (3) years, but shall be eligible for re-election.
The Directors to retire in every year shall be the Directors who have been longest in office since the Directors’ last election, but
as between persons who became Directors on the same day, the Directors to retire shall be determined by lot, unless they
otherwise agreed among themselves.
Upon the recommendation of the NRC based on the satisfactory assessment result on the qualification, fitness and propriety
of Directors, the Board has confirmed that the following Directors who are retiring and standing for re-election at the 2023
AGM are able to continue to perform effectively and demonstrate commitment:-
Name of Directors Designation
Lynette Yeow Su-Yin - Clause 76(3) of the Constitution of the Company Independent Non-Executive Director
Erick Hamburger Barraza – Clause 78 of the Constitution of the Company Executive Director / GCEO
Profiles of the Directors standing for re-election are set out in Pages 20 to 27 of this Annual Report.
Tan Sri Izzuddin Bin Dali who retires by rotation pursuant to Clause 76(3) of the Constitution of the Company, has expressed his
intention not to seek for re-election and hence, he will retain his office until the conclusion of the 2023 AGM.
The Board ensures shareholders have the information they require to make an informed decision on the appointment and
re-election of a director. This includes details of any interest, position or relationship that might influence, or reasonably be
perceived to influence, in a material respect their capacity to bring an independent judgement to bear on issues before the
Board and to act in the best interests of the listed company as a whole.
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OVERVIEW STATEMENT
(D) Annual Evaluation
The Board has adopted a formal and objective annual evaluation of the Board, Board Committees and Directors’
performance as established under the Directors’ Performance Assessment Framework. The Directors’ Performance
Assessment Framework developed with the assistance of the NRC, serves as a guidance, inter alia on the following:-
1. The assessment on the Board’s leadership and effectiveness;
2. The annual assessment of Directors performance in discharging their responsibilities for the governance of
Company’s sustainability including setting the Company’s sustainability strategies, priorities and targets; and
3. The assessment on the necessary quality, integrity, credibility, and competencies of the Directors that contribute to
the development and growth of the Company.
The evaluation process was based on self/peer assessments whereby the Directors assessed themselves and also the
Board as a whole as well as the performance of each Board Committees. The criteria and outcome of the assessment
were properly documented. The evaluation process is led by the Chairman of the NRC, assisted by the Company
Secretary. Each Director conducts the evaluation based on an online questionnaire in a confidential manner.
Based on the recent assessment, the NRC was satisfied that the Board size and its composition are optimum as the
Board comprises individuals with the requisite skills, knowledge, experience, characteristics and competencies to
effectively discharge their roles. The Directors, the Board and the Board Committees had discharged their responsibilities
in a commendable manner and contributed to the overall effectiveness of the Board and the Company. The Directors
had committed the time necessary to responsibly fulfil their commitment to the Company during the year. In addition,
all the Directors had completed the Director's Qualification Declaration as well as the Director Fit and Proper Criteria
Declaration in accordance with the Directors' Qualification, Fit and Proper Policy. According to the declarations received,
all the Directors met the fit and proper criteria.
The NRC and the Board had also undertaken an annual assessment on the independence of Independent Directors
based on the criteria set out in the MMLR of Bursa Securities. The Board is satisfied with the independence assessment
as the current Independent Directors of the Company have fulfilled the criteria for “independence” as prescribed under
the MMLR of Bursa Securities.
(E) Directors’ Training
The Board recognises the importance of continuous training for Directors and encourages all Directors to attend
workshops, programmes, courses and seminars to stay abreast on relevant business development and industry outlook
as well as changes to statutory requirements and regulatory guidelines.
The Directors are required to evaluate their own training needs on a continuous basis with the overriding objective
of staying abreast of regulatory requirements and ongoing business developments. The Board is committed to stay
abreast of training programmes and workshops conducted by Bursa Securities and other training providers, while
receiving updates of new statutory and regulatory requirements from time to time.
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OVERVIEW STATEMENT
The training programmes and seminars attended by the Directors during the FYE 2022 are as follows:-
1. Dato’ Noorazman Bin Abd Aziz
No Course Title
1. Positioning Corporate Malaysia for a Sustainable Future - PricewaterhouseCoopers (PwC Malaysia)

2. An Invitation to a Talk by Rajeev Peshawaria on Steward Leadership for Sustainability - Asia School of
Business (ASB)
3. Briefing for UEM Sunrise’s Board, Top Management & Nominee Directors on the Latest Developments of
Section 17A of the MACC Act 2009 - UEM Sunrise Berhad
4. Overseeing the economic, environmental, social and governance perspectives of a listed issuer’s business
- Kumpulan Perangsang Selangor Berhad (KPS)
5. Legal Talk on Fiduciary Duties of Board and Investment Panel - Kumpulan Wang Persaraan (KWAP)
6. FIDE Forum Leadership Perspectives for Effectiveness in conjunction with BEE Launch - ASB
7. Invest Shariah Conference 2022 - Transforming Malaysia’s economy and society through Islamic Finance
- Bursa Malaysia
8. [Thought hUb] Merdeka Edition - Unlocking the Potential of History and Cultural Heritage in the Revitalisation
of Neighbourhoods - UEM Sunrise Berhad
9. Board Sustainability Awareness Session - UEM Edgenta Berhad
10. International Directors Summit 2022 - Institute of Corporate Directors Malaysia (ICDM)
11. Khazanah Megatrends Forum 2022 - Khazanah Nasional Berhad
12. Pre-Board Convergence 2022: Commitment with Purpose: Strengthening Resilience with Technology and
Sustainability - UEM Edgenta Berhad
13. Invitation to Private Equity Forum – Navigating Venture Capital and Technology Investments in Malaysia -
KWAP
14. KPMG Board Leadership Center Exclusive: Understanding the requirements in Bursa Malaysia’s enhanced
sustainability reporting framework - KPMG
15. Evening Talk on “Inflation, Looming Recession & Climate Change: A Tricky Balancing Act?” - ASB
16. Training on MFRS 17 Insurance Contracts: Understanding its impact & complications - Sun Life Malaysia
Assurance Berhad
17. Environmental Social Governance (ESG) Disclosures: Improving the Quality of ESG Data and its impact -
KWAP
18. Sustainability Training - UEM Sunrise Berhad
19. Board Leadership and Effectiveness and Enhanced Sustainability Reporting Framework - KPS
20. 2022 UEM Sunrise Integrity Day - UEM Sunrise Berhad
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OVERVIEW STATEMENT
2. Lynette Yeow Su-Yin
No Course Title
1. Empowering and Rewarding the Boardroom Brigade - A Board Remuneration Masterclass - KPMG
2. Anti-Corruption, AMLACFT and Corporate Governance Training - Malaysia Building Society Berhad (MBSB)
3. Training on Information & Cybersecurity and Branding & Communication - MBSB
4. MBSB Shariah Advisory Council Training - MBSB
5. “Conversations on Climate Governance” and “Climate Change and the Banking Sector - How will it affect
my company?” - ASEAN Climate Governance Network
6. CTOS ESG 101 Training - PwC Malaysia
7. CTOS Corporate Liability: Anti-Bribery & Corruption - Tricor Hive Sdn Bhd
8. Directors’ Duties and Climate Change - The Malaysian Bar and Climate Governance Malaysia
9. Conversations with Chairmen: A standing item in board agendas - FIDE Forum, Climate Governance
Malaysia
10. Board Effectiveness Evaluation - FIDE Forum
3. Nirmala A/P Doraisamy
No Course Title
1. Ethics, Integrity & Trust Conference - Malaysian Institute of Accountants (MIA)

2. ESG Oversight for Boards - MIA
3. FCD Series Module E: Digital Awareness and Upskilling for Board - Institute Of Corporate Directors Malaysia
(ICDM)
4. Petronas Board Conversation Series: A Session With Peter Bakker, Chief Executive Officer (CEO) Of World
Business Council For Sustainable Development (WBCSD) - Petronas
5. Sustainability And Its Impact on Organisations: What Directors Need To Know - Asia School Of Business (ASB)
6. Petronas Board Conversation Series 02/22: A Session with The United Nations Environment Programme
World Conservation Monitoring Centre (UNEP - WCMC) Experts - Petronas
7. Embracing A Cashless Transformation - WIFE & WBN
8. Ethical Finance Asean 2022 - GEFI
9. The Audit Committee: Unpacking The Roles Of The Committee & Honing Its Effectiveness Discharging Its
Responsibilities Holistically - Malaysian Institute Of Corporate Governance
10. RMIT - Sharing of Insights & Discussion on The Strategic Aspects of it Risk - ASB
11. Building A Formidable Tax Governance Framework - ICDM
74
OVERVIEW STATEMENT
No Course Title

14. Petronas Board Conversation Series: A Session with Dr. Fiona Wild, Vice President, Sustainability and Climate
Change at BHP - Petronas
15. MIA Conference - MIA
16. Advocacy Session for Directors & Senior Management of Main Market Listed Issuers - Bursa Malaysia Bhd
17. International Directors Summit - ICDM
18. Audit Oversight Board Conversation with Audit Committees – Securities Commission Malaysia (SC) Audit
Oversight Board (AOB)
19. Sustainability Training:
1) Development & Imperatives In ESG And Climate For PDB
2) Reinforcing The Case For Sustainability - PDB
4. Su Puay Leng
No Course Title
1. Audit Oversight Board Conversation with Audit Committees – Securities Commission Malaysia (SC) Audit
Oversight Board (AOB)
5. Loh Kok Leong
No Course Title
1. CTOS Corporate Liability : Anti-Bribery & Corruption - Tricor Hive Sdn Bhd
6. Erick Hamburger Barraza
No Course Title
3. Mandatory Accreditation Programme – Institute of Corporate Directors Malaysia
7. Wong Pau Min (Alternate to Loh Kok Leong)
No Course Title
75
OVERVIEW STATEMENT
III REMUNERATION
(A) Remuneration Policies and Procedures The Board has remuneration policies and procedures
to determine the remuneration of Directors, and Senior
As the Company prospers, the Board believes in an Management, taking into account the skills and
appropriate level of remuneration by aligning remuneration experience required as well as the demands, complexities
and performance with the key strategic drivers of long-term and performance of the Group. The Group has established
growth. The remuneration has been designed to align with the following policies:
industry practices, taking into account the appropriate
calibre of each Director whilst upholding of shareholders’ 1. Directors’ Remuneration Policy; and
interests and also aim to attract, retain, and motivate 2. Senior Management Remuneration and Assessment
capable directors to successfully manage the Group. Framework.
The NRC is responsible for reviewing and recommending These policies and practices are periodically reviewed by
the remuneration package for the Executive Directors, the NRC and its continued relevance periodically including
GCEO and Senior Management to the Board; whilst salaries, benefits-in-kind, other emoluments and annual
the Board has overall responsibility to determine the performance bonus in detail, ensuring the remuneration
remuneration of respective Directors with the approval is attractive to motivate and retain them in the Group. Any
from shareholders at the AGM. For Non-Executive Directors, revisions to the framework as recommended by the NRC
the level of remuneration reflects the experience and level will be tabled to the Board for consideration and approval.
of responsibilities undertaken. Each Non-Executive Director
The Directors’ Remuneration Policy is available on the CTOS Digital’s
receives a base fixed fee.
website.
(B) Remuneration of Directors
The remuneration package for Non-Executive Director reflects the individual’s merits, valuable contribution, and level of
responsibilities. The fees payable to Non-Executive Directors are set by the Board, with individual Director(s) abstaining from
discussion of their own remuneration package. The details of the aggregate remuneration of Directors on the named basis for
the FYE 2022 (Company and Group basis) are disclosed as below:
The Company
Other Total
Name Fees Allowance Salaries Bonus emoluments (RM)
Tan Sri Izzuddin Bin Dali 103,129 0 0 0 0 103,129

Dato' Noorazman Bin Abd Aziz 79,129 6,000 0 0 0 85,129
Lynette Yeow Su-Yin 85,129 0 0 0 0 85,129
Nirmala A/P Doraisamy 88,935 0 0 0 0 88,935
Su Puay Leng 79,329 4,800 0 0 0 84,129
Loh Kok Leong 0 0 0 0 0 0
Erick Hamburger Barraza (appointed w.e.f.
30 September 2022) 0 0 0 0 0 0
Wong Pau Min 0 0 0 0 0 0
Datuk Azizan Haji Abd Rahman (resigned
w.e.f. 7 March 2022) 15,581 0 0 0 0 15,581
Dennis Colin Martin
(resigned w.e.f. 30 September 2022) 0 0 0 196,700 0 196,700
76
OVERVIEW STATEMENT
The Group
Other Total
Name Fees Allowance Salaries Bonus emoluments (RM)
Tan Sri Izzuddin Bin Dali 103,129 0 0 0 0 103,129

Dato' Noorazman Bin Abd Aziz 79,129 6,000 0 0 0 85,129
Lynette Yeow Su-Yin 85,129 0 0 0 0 85,129
Nirmala A/P Doraisamy 88,935 0 0 0 0 88,935
Su Puay Leng 79,329 4,800 0 0 0 84,129
Loh Kok Leong 0 0 0 0 0 0
(appointed w.e.f. 30 September
2022) 0 7,500 450,000 0 0 457,500
Wong Pau Min
(alternate Director to Loh Kok
Leong) 0 0 0 0 0 0
Datuk Azizan Haji Abd Rahman
(resigned w.e.f. 7 March 2022) 15,581 0 0 0 0 15,581
Dennis Colin Martin
(resigned w.e.f. 30 September
2022) 0 0 0 196,700 0 196,700
(C) Remuneration of Group’s Senior Management
The Group’s remuneration policy takes into account the various levels of Senior Management based on job grade
structure, roles and responsibilities and levels of accountability. This ensure that remuneration packages are fair. For
Senior Management of the Company, all bonuses are determined by the Board on the recommendation of the NRC
after reviewing the individual performance appraisals and achievements. The details of the total remuneration of top
five Senior Management of the Company for the FYE 2022 (in the bands of RM50,000) are disclosed as below:
Other Total
Name / Position Salaries Allowance Bonus Benefits emoluments (RM)

(GCEO - appointed w.e.f. 1,900,000 - 0- 1,900,000 -
1 May 2022) 1,950,000 50,000 0 0 0 2,000,000
Chen Thai Foong
(Group Chief Financial Officer) 600,001 - 0- 100,001 - 700,001 -
(retired w.e.f 16 January 2023) 650,000 50,000 150,000 0 0 750,000
James Fancourt Mitchell 450,001 - 0- 450,001 -
(Group Chief Technology Officer) 500,000 50,000 0 0 0 500,000
Chin Kuan Weng
(CEO of CTOS Data Systems 550,001 - 0- 50,001 - 650,001 -
Sdn Bhd) 600,000 50,000 100,000 0 0 700,000
Tracy Gan Jo Lin
(Chief Operating Officer of CTOS 600,001 - 0- 50,001 - 700,001 -
Data Systems Sdn Bhd) 650,000 50,000 100,000 0 0 750,000
77
OVERVIEW STATEMENT
PRINCIPLE B – EFFECTIVE AUDIT & RISK MANAGEMENT
I AUDIT AND RISK COMMITTEE
(A) ARC’s Composition
The Board has delegated its authority to the ARC to carry out the Board’s oversight functions on audit, risk and compliance matters
as outlined under its TOR. The ARC assists the Board in carrying out its oversight responsibilities by reviewing financial information, risk
management, control systems and matters that may significantly impact the financial condition or affairs of the business and providing
an unbiased review of the effectiveness and efficiency of the Group’s internal controls.
The Chairman of ARC is not the Chairman of the Board ensuring that the impartiality and objectivity of the Board’s review on the ARC’s
findings and recommendations remain intact. The ARC consists of three (3) members, all of which are Independent Directors with
extensive experience in finance, legal, banking and consulting industry contributing to business strategy and CG.
The composition of the ARC, including its number of meetings and attendance of ARC, summary of ARC activities and Internal Auditors’
function during the financial year under review are set out on pages 82 to 86 under ARC Report of this Annual Report.
The composition of the ARC
Name of Directors Designation
Nirmala A/P Doraisamy1 Chairman, Independent Non-Executive Director

Dato’ Noorazman Bin Abd Aziz Member, Independent Non-Executive Director
Su Puay Leng 2
Member, Independent Non-Executive Director
Datuk Azizan Bin Haji Abd Rahman 3
Chairman, Independent Non-Executive Director
1 Redesignated as the Committee Chairman with effect from 7 March 2022

2 Appointed as the Committee Member with effect from 7 March 2022
3
Resigned as the Committee Chairman with effect from 7 March 2022
All ARC members are financially literate and have sufficient understanding of the Group’s business. This enables them to continuously
apply a critical and probing view on the Group’s financial reporting process, transactions and other financial information, and effectively
challenge management’s assertions on the Company’s financials.
The ARC also recognises the importance of upholding independence of its external auditors and that no possible conflict of interest
whatsoever should arise. The TOR of the ARC stated that no former key audit partner shall be appointed as a member of the ARC before
observing a cooling-off period of at least three (3) years in line with the practice of 9.2 of MCCG 2021. Presently, none of the ARC
members is a former key audit partner involved in auditing the Group.
(B) External Auditors
The Board maintains a good professional relationship with the external auditors through the ARC in discussing their audit plans, audit
findings and financial statements with them. The external auditors also have direct access to the ARC to highlight any issues of concern
at any point in time. Pursuant to the ARC’s TOR, private sessions between ARC and the external auditors will be held at least twice a year
without the presence of the Executive Director and Key Senior Management to discuss audit findings and any other observations they
might have during the audit process.
The ARC is responsible for the recommendation on the appointment and re-appointment of the Company’s external auditors and the
audit fees. The ARC carried out an assessment of the performance, independence and suitability of the external auditors based on the
following factors:
1. the competency, audit quality, experience and resource capacity of the external auditors in relation to the audit;
2. the persons assigned to the audit;
78
OVERVIEW STATEMENT
3. other audit engagements of the audit firm; Group in accordance with the Companies Act 2016 and applicable
4. the external auditors’ ability to meet deadlines approved financial reporting standards in Malaysia.
in providing services and responding to issues
timely as outlined in the external audit plan; The ARC assists the Board in discharging its fiduciary duties by
5. the nature and extent of the non-audit ensuring that the audited financial statements and quarterly financial
services rendered and the appropriateness reports are prepared in accordance with the Malaysian Financial
of the level of fees; and Reporting Standards and MMLR of Bursa Securities. In presenting the
6. obtaining written assurance from the external annual audited financial statements and quarterly announcements
auditors confirming that they are, and have of results to shareholders, the Board aims to present a balance and
been, independent throughout the conduct fair assessment of the Company’s financial position and prospects.
of the audit engagement in accordance The ARC reviews the Company’s quarterly financial results and
with the terms of all relevant professional and annual audited financial statements to ensure accuracy, adequacy
regulatory requirements. and completeness prior to presentation to the Board for its approval.
The assessment also considers the information The Statement of Directors’ Responsibility in respect of the preparation
presented in the Annual Transparency Report of the annual audited financial statements is set out in page 96 of
this Annual Report.
(“ATR”). The audit firm, PricewaterhouseCoopers
PLT issued its ATR in 2022 on matters typically
covered in the ATR including the firm’s governance II RISK MANAGEMENT AND INTERNAL CONTROL FRAMEWORK
and leadership structure as well as measures
undertaken by the firm to uphold audit quality and
manage risks. The Board acknowledges the significance of a sound system of risk
management and internal control to manage the overall risk exposure
PricewaterhouseCoopers PLT, the external auditors of the Group which provides reasonable assurance in ensuring the
of the Company have confirmed to the ARC that effectiveness and efficiency of the Group’s operations that is not
they are, and have been, independent throughout limited to financial aspects of the business but also operational and
the conduct of the audit engagement in regulatory compliance. In order to achieve the ultimate objectives
accordance with the terms of relevant professional whereby to protect the Group’s assets and safeguard shareholders’
and regulatory requirements. investments, the ARC has been entrusted by the Board in managing
the risks and establishment of the internal control system and
Being satisfied with the external auditors’ processes of the Group.
performance, technical competence and

independence, the ARC recommended the re- The Company recognises that an internal audit function is essential
appointment of PricewaterhouseCoopers PLT as to ensure the effectiveness of the Group’s system of internal control
external auditors for the financial year ending 31 and is an integral part of the risk management process. To achieve
December 2023. In view thereof, the Board has the purpose, the Group has established an in-house Group Internal
recommended the re-appointment of the external Audit ("GIA”) which reports directly to the ARC. The GIA carries out
auditors for the approval of shareholders at the its function in accordance with the approved Internal Audit Charter.
forthcoming 2023 AGM. The findings of the audits and the recommendations for improvement
or actions to be taken by the management to rectify the issue will
(C) Financial Reporting be presented in ARC Meeting. The further details of Internal Audit
Function are set out in the ARC Report of this Annual Report.
The Board aims to present a clear, balanced and

comprehensive assessment of the Group’s financial Any significant issue affecting the existing risks or emerging risks as
position and future prospects that extends to well as the changes to the action plans to address the risks identified,
the annual and quarterly financial statements. will be discussed during the ARC meetings, and brought to the
The Board is also responsible for keeping proper attention of the Board by the Chairman of ARC.
accounting records, which disclose with reasonable

accuracy at any time the financial position of the The Statement on Risk Management and Internal Control as set out
Group and ensuring that the financial statements in this Annual Reports provides an overview of the state of the Group’s
of the Group are prepared so as to give a true risk management and internal controls framework within the Group.
and fair view of the current financial status of the
79
OVERVIEW STATEMENT
PRINCIPLE C – INTEGRITY IN CORPORATE REPORTING & MEANINGFUL RELATIONSHIP WITH STAKEHOLDERS
• One-on-One and Group Meetings/Investor Conferences/

I ENGAGEMENT WITH STAKEHOLDERS
Roadshows - throughout the period, we held meetings
with major institutional investors, individual shareholder
The Company has a dedicated investor relations function groups and financial analysts to share and discuss the
led by the General Manager of Marketing, Public Relations, Group’s business performance and its strategic plan;
Corporate Communication and Investor Relations and and
the GCEO is an authorised spokesperson in relation to • Annual Reports - our Annual Report provides a
the disclosure of material information to shareholders and comprehensive report on the Group’s financial results,
stakeholders. business operations and strategic direction.
The Group communicates with its stakeholders through The information published in the Investors Relations section
various channels and media. A constructive and effective can be found at www.ctosdigital.com/investor-relations.
investor relationship is important to enhance shareholders’
value and to keep shareholders and various stakeholders During the period under review, we increased our engagements
informed of the Group’s performance, businesses, corporate with the investment community and conducted more than 61
affairs and establish a transparent, regular and effective two- one-to-one and group meetings. During these engagements,
ways communication. the Group would address their concerns, where possible, to
deliver sustainable value to its shareholders. In 2022, there were
Announcements, news, promotions and all relevant updates increased engagements with the Environmental, Social and
are posted on the Group’s website regularly. The shareholders Governance investors due to the higher focus on sustainability
and other stakeholders can subscribe to the Group’s matters. Additionally, we are actively engaged with other
Investor Relations News Alerts via its website on the latest IR stakeholders such as Bursa Securities, Malaysia Investor
announcements posted to its website. Shareholders may also Relations Association, and other IR service providers to ensure
communicate with the Group on investor relation matters via the Group practices the highest standards of transparency
email or phone call. The contact details are available here and disclosure.
www.ctosdigital.com/investor-relations/overview.
II CONDUCT OF GENERAL MEETINGS

The Group objective is to build long-term relationships with
shareholders and potential investors through appropriate
channels for the management and disclosure of information. The Board regards general meeting as the principal forum
The Group strives to disclose all price sensitive information for dialogue and interaction with shareholders for an
to the public as soon as practicable and in terms of degree effective two-way communication between the shareholders
of the disclosures, the Group is guided by Bursa Securities’ and Management. The shareholders are encouraged to
Corporate Disclosure Guide. participate in the general meetings and they are given
opportunity to enquire and comment on the Group’s
All public announcements are electronically published performance and operations and the Board may clarify issues
and can be accessed at Bursa Securities’ website at www. pertaining to the Group’s business activities, performance
bursamalaysia.com or the Group’s website at www.ctosdigital. and other related matters. All Directors (save for Mr Loh Kok
com. The Group’s website includes dedicated sections which Leong) together with the Senior Management team and the
provide all relevant information on the Group, including external auditors attended the 2022 AGM held on 27 May
announcements to Bursa Securities, share price information as 2022 to provide meaningful responses to the questions raised
well as the corporate and governance structure of the Group. by shareholders.
The Group communicates with its stakeholders through various The notice convening the 2022 AGM held on 27 May 2022
means including: was circulated to the shareholders on 29 April 2022, i.e.
twenty-eight (28) days before AGM, which gives shareholders
• Corporate Website - provides an essential platform for sufficient time to prepare themselves to attend the AGM or to
investors and other stakeholders to access information appoint proxy to attend and vote on their behalf. The notice
periodically through the Investor Relations section at included details of the resolutions to be tabled and detailed
www.ctosdigital.com; explanations on the resolutions. Details of the resolutions
• Annual/Extraordinary General Meetings - offers an proposed along with background information and reports or
opportunity to our shareholders to raise their questions recommendations that are relevant were also provided in the
and concerns on the Group’s performance directly to notice of AGM.
our Board and Management;
80
OVERVIEW STATEMENT
In view of the prevailing COVID-19 pandemic and as part of DIRECTORS’ RESPONSIBILITY STATEMENT
the Group’s precautionary measures, the AGM was held in
a fully virtual meeting through live streaming, using Remote Pursuant to the Companies Act 2016 (“the Act”) and Paragraph
Participation & Voting (“RPV”) facilities to enhance the 15.26(a) of the MMLR of Bursa Securities, the Directors are
participation of shareholders. During the fully virtual AGM, required to prepare the financial statements for each financial
shareholders were given opportunity to raise questions, year in accordance with the Malaysian Financial Reporting
suggestions, or comments before and throughout the AGM Standards (”MFRS”), International Financial Reporting Standards
and all the questions raised by the shareholders were duly (“IFRS”) and the requirements of the Act in Malaysia.
responded.
The Directors are responsible to ensure that the financial
Shareholders who are unable to attend the AGM are statements give a true and fair view of the financial position of
encouraged to vote on the proposed motions by appointing the Group and of the Company at the end of the financial year,
a proxy. At the 2022 AGM, submission of e-Proxy Form is and of the financial performance and cash flows of the Group
available on the RPV facilities for shareholders who were and of the Company for the financial year.
unable to attend to the AGM to appoint a proxy.
In preparing the financial statements, the Directors have:
In compliance with the MMLR, the Company has • Adopted appropriate accounting policies in accordance
implemented poll voting for all resolutions set out in the with applicable approved accounting standards and
Notice of AGM to be voted via electronic means using RPV applied them consistently;
facilities as well as to expedite verification and counting of • Made judgements and estimates that are reasonable
votes. The Company has also appointed an independent and prudent; and
scrutineer to validate the votes cast at the AGM. All • Prepared the financial statements on a going concern
resolutions tabled during 2022 AGM were duly passed. basis.
Thereafter, the outcome of the meeting together with poll
results were announced to Bursa Securities on the same day The Act further requires the Directors to ensure that the Group
for the information of shareholders. and the Company keep such accounting and other records of
the Group and of the Company with reasonable accuracy to
The Minutes of the 2022 AGM (including all the questions ensure that the financial statements comply with the provisions
raised during the meeting) was published on the Company’s of the Act.
corporate website no later than 30 business days after the
AGM held on 27 May 2022. The Directors are also responsible for taking such steps that are
reasonably available to them to safeguard the assets of the
COMPLIANCE STATEMENT BY THE BOARD ON Group and of the Company and to prevent and detect fraud
THE CORPORATE GOVERNANCE OVERVIEW and other irregularities.
STATEMENT
ADDITIONAL COMPLIANCE
This statement on the Company’s corporate governance
practices is made in compliance with paragraphs 15.25 and Material Contracts
15.08A of the MMLR of Bursa Securities. There were no material contracts entered into by the Group
involving the interests of the Director, Chief Executive Officer
Having reviewed and deliberated this statement, the Board and/or major shareholders during the FY2022 or still subsisting
is satisfied that to the best of its knowledge, the Company is at the end of the FY2022.
substantially in compliance with the principles and practices
set out in the MCCG 2021 as well as the relevant paragraphs Recurrent Related Party Transactions
under the MMLR of Bursa Securities for the financial period The Company did not seek any shareholders mandate in respect
under review. Any practices in the MCCG 2021 which have of Recurrent Related Party Transactions (“RRPTs”) of a revenue
not been implemented during the financial period would be or trading nature , and will not be seeking any shareholders’
reviewed by the Board and be implemented where practical mandate for the RRPTs at the forthcoming 2nd Annual General
and relevant to the Group’s business. Meeting to be held on 26 May 2023.
This statement has been presented and approved by the List of Properties
Board at its meeting held on 17 April 2023. The Group does not have any properties as at the end of the
financial year.
81
AUDIT AND RISK

COMMITTEE REPORT
The Board presents the Audit and Risk Committee (“ARC”) Report, which provides insights into the manner in which the ARC
discharged its functions for the Company in 2022.
Composition and meeting attendance
The ARC comprises three (3) members who are all Independent Non-Executive Directors (“INEDs”). These INEDs satisfy the
test of independence under the Main Market Listing Requirements (“MMLR”). The ARC meets the requirements of paragraph
15.09(1)(a) and (b) of the MMLR and Practice 9.4 under Principle B of the Malaysian Code on Corporate Governance
(“MCCG”). There were eight (8) ARC meetings held during the financial year ended 31 December 2022. The Committee
members’ attendance details are as follows:
Nirmala Doraisamy Dato’ Noorazman Abd Aziz Su Puay Leng

(Chairperson)
8 of 8 8 of 8 8 of 8
The ARC Chairperson, Nirmala Doraisamy, is a member of the Malaysian Institute of Accountants (“MIA”) and is a Fellow of
Chartered Institute of Management Accountants in the United Kingdom. Accordingly, the Company complies with paragraph
15.09(1)(c)(i) of MMLR.
The Board is satisfied that the ARC and its members discharged their functions, duties and responsibilities in accordance with
the ARC’s Terms of Reference (“TOR”) which is available on the Company’s website at www.ctosdigital.com.
Summary of work
The ARC’s work during 2022 comprised the following:
1. Financial performance reporting
a. Reviewed the annual audited financial statements of the Group, and thereafter, recommended the same to the
Board for adoption. In reviewing the annual audited financial statements, ARC discussed with the Management
and the external auditors on the accounting principles and standards that were applied and key assumptions
used by the Management and their opinion on the items that may affect the financial statements.
b. In the presence of the Group Chief Executive Officer (“GCEO”), reviewed the quarterly financial results of the
Group and subsequently recommended the same to the Board for approval to be released to Bursa Securities.
During these meetings, the Group Chief Financial Officer presented the quarterly financial reports and highlighted
the material variances or movements for the relevant reporting quarters.
c. Reviewed the documents for solvency test on the declarations and payments of dividends, as required by Section
132 of the Companies Act 2016, and thereafter, recommended the same to the Board for approval.
d. Reviewed the Budget for the financial year ending 31 December 2023 and deliberated on the key assumptions
used by Management in the preparation of the Budget, and thereafter, recommended the same to the Board for
approval.
82
AUDIT AND RISK

COMMITTEE REPORT
2. External audit
a. Reviewed the results of the annual audit and deliberated on the audit findings and internal control recommendations,
including Management’s response to the audit findings.
b. Reviewed the independence and effectiveness of the external auditors and recommended to the Board to propose
to shareholders the re-appointment of the external auditors at the Annual General Meeting of the Company. In
relation to independence of the external auditors, the ARC received formal written statement from the external
auditors, re-affirming the following:
- they have maintained their independence in accordance with the firm’s requirements, with the provisions
of the By-Laws on Professional Independence of the MIA and with the International Ethics Standards
Board for Accountants’ International Code of Ethics for Professional Accountants (including International
Independence Standards).
- the non-audit services provided to the Group during the financial year were in accordance with the
independence requirements and that there are no services provided that have compromised their
independence as external auditors of the Group.
c. Reviewed the external auditors’ audit plan for the financial year ended 31 December 2022, which outlined the
audit scope, key areas of audit emphasis and the audit approach.
d. Considered in consultation with the management the proposed audit fees of the external auditors for financial
year ended 31 December 2022 for recommendation to the Board for approval. The breakdown of fees for the
services provided by the external auditors are as follows:
Description Fee (RM) Fee percentage
Statutory audit 426,700 70%

Audit related services (agreed-upon procedures and purchase price 106,000 17%
allocation review)
Non-audit related services (tax compliance and advisory) 76,300 13%
Total 609,000 100%
In addition, the ARC had also carried out an assessment of their performance for the period under review, in
accordance with the Company’s Performance Evaluation Framework for External Audit and Internal Audit Function.
e. Held two private sessions with the external auditors without management’s presence during the financial year.
f. Reviewed the Statement on Risk Management and Internal Control (“SORMIC”), and recommended the same for
Board approval, prior to its publication in the 2022 Annual Report.
83
AUDIT AND RISK

COMMITTEE REPORT
3. Internal audit (“IA”) e. On quarterly basis, the ARC received update on

risk management activities held within the Group
a. Reviewed the IA reports presented by the Group and this including but not limited the following: -
Head of IA and assessed the IA observations, i. Report of risk activities adherence with the
recommendations and the Management’s Risk Appetite Statement (i.e, monitoring of
corrective actions to address internal audit breaches).
recommendations. ii. Status of Business Continuity Plan
b. Reviewed the adequacy and performance of formalisation within the Group.
IA function and its comprehensiveness of the iii. Trainings and awareness sessions
coverage of activities within the Group, including conducted to increase the knowledge of
adequacy of resources for the IA function. risk management.
c. Carried out an assessment of the performance of f. Received update on the development status of
the Group Head of IA for the period under review, the Key Risk Indicators for the Group.
in accordance with the Company’s Performance g. Discussed and received updates on the
Evaluation Framework for External Audit and adequacy of resources for risk management
Internal Audit Function. function.
d. Held two (2) private meetings with the Group Head
of IA without the presence of the Management. 5. Compliance
e. Approved the IA Plan for the year 2023.
Received updates from Group Senior Head of RBC on
4. Risk management the compliance status of the Group, which include the
following:
The ARC assisted the Board in its duty to review, monitor, - Reviewed the audit results carried out by the
on an ongoing basis, the effectiveness of the Group’s Registrar Office of Credit Reporting Agencies
risk management framework which include the (“the Registrar Office”) to assess the compliance
following: status of both CTOS Data Systems Sdn Bhd (a
a. Reviewed the key risks as reported by Group Credit Reporting Agency and the Company’s
Senior Head of Risk and Business Compliance main subsidiary) and CTOS Basis Sdn Bhd (a
(“RBC”) across the wide spectrum of risks facing Credit Reporting Agency and the Company’s
the businesses and operations, which included other subsidiary) with the Credit Reporting
strategic risk, business risk, financial risk and Agencies Act (“CRA Act”) 2010.
operational risk. The ARC has also assessed the - Discussed and approved the scope of work
adequacy and effectiveness of controls and/or to be carried out by the independent external
mitigation actions identified and/or implemented party, Crowe Governance Sdn Bhd, prior to
by the respective business units in addressing the commencement of audit work; this was to assess
identified risks. the adequacy of internal controls of CTOS Data
b. Received update on half-yearly enterprise- System Sdn Bhd to ensure it complies with BNM
wide and emerging risk assessments to ensure requirement. Subsequently, ARC reviewed the
additional mitigations to strengthen the audit results of the internal controls assessment.
management of existing and emerging risks were - New requirements under the CRA Act 2010 for
undertaken. both subsidiaries, CTOS Data Systems Sdn Bhd
c. Reviewed the Risk Appetite Statement that outlines and CTOS Basis Sdn Bhd.
the amount and type of risks that the Group is - ISO 27001 (the international standard
exposed to and is willing to take, in order to meet on information security management)
its strategic objectives for Board approval. implementation on quarterly basis; this is to ensure
d. Reviewed the Enterprise-wide Risk Management both subsidiaries, CTOS Data Systems Sdn Bhd
("ERM") Policy and Framework to incorporate and CTOS Basis Sdn Bhd are able to fulfil the new
updates such as Risk Appetite Statement, regulatory requirement to be ISO 27001-certified
alignment of roles and responsibilities of the by 2024.
ARC to be consistent with the approved TOR
and description of likelihood parameter and risk
matrix.
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AUDIT AND RISK

COMMITTEE REPORT
6. Environmental, Social and Governance (“ESG”) c. Reviewed the announcement to Bursa Securities
to comply with the Listing Requirements and
a. Reviewed the Company’s first Sustainability other relevant rules and regulations, and
Statement and recommended to same for Board considered procuring of shareholders’ mandate
approval, prior to its publication in the 2021 if the aggregate value of the recurrent and
Annual Report. related party transactions is expected to exceed
b. Received quarterly updates on ESG initiatives. the percentage ratio of 5% within a period of 12
c. Received ESG training as part of the Company’s months.
commitment to raise ESG awareness for both d. Deliberated on the related party transaction in
Board members and the Company’s employees. relation to the acquisition of a related party’s
d. Reviewed Sustainability Statement Addendum stake in RAM Holdings Berhad (“RAM”), including
and recommended the same for Board approval, the basis and justification for the purchase
prior to its publication on the Company’s consideration, rationale and benefits, prospects of
corporate website. The revision contributed to RAM as well as the evaluation of the independent
the Company’s inclusion in FTSE4Good Bursa advisor.
Malaysia Index and FTSE4Good Bursa Malaysia
Syariah Index in December 2022. 9. Other matters
7. Cybersecurity a. Reviewed and endorsed the ARC Report and

SORMIC, for Board approval, for the inclusion of
a. Reviewed the efficacy and the state of the current these documents in the 2022 Annual Report.
cyber security posture, including efforts to remedy b. Reviewed the adequacy of internal controls
existing vulnerabilities and to minimise future relating to anti-bribery and anti-corruption
potential vulnerabilities. (“ABAC”) and advised the management on
b. Reviewed and deliberated the adequacy of appropriate action plans based on good
existing resources to support the efforts to enhance practices in other public listed companies in
cyber resilience in line with the management’s Malaysia.
plans. c. Received quarterly updates of the management
c. Discussed ongoing projects to strengthen CTOS’ of litigation cases from Corporate Legal Affairs.
cyber security posture to ensure the project risks d. Received updates on the status of accounting
are effectively managed. and reporting system improvement initiative for
better management of accounting records, as
8. Related party transactions recommended by the external auditors. These
include vendor appointment status, estimated
a. Reviewed, on a quarterly basis, if any, all recurrent timeline to complete this initiative and progress
related party transactions within the Group to updates.
ensure these transactions were at arm’s length e. Reviewed the Independent Advice Letter issued
basis and were in the ordinary course of business; by the independent advisor in relation to the
on terms not more favourable than those acquisition of additional interest in RAM.
generally available to the public.
b. Reviewed the procedures for recurrent related
party transactions to ensure that the process and
controls were in place to monitor the transactions.
85
AUDIT AND RISK

COMMITTEE REPORT
Internal Audit (“IA”) Function
IA’s mission is to enhance and protect the organisational value of the Group by providing risk-based and objective assurance,
advice and insight. IA helps the Company to accomplish its objectives by bringing a systematic and disciplined approach to
evaluate and improve the effectiveness of risk management, internal controls, and governance processes.
IA reports functionally to the ARC and administratively to the GCEO. To ensure that the responsibilities of IA are fully
discharged in accordance with the International Standards for the Professional Practice of Internal Auditing, the ARC
reviews the adequacy of the scope and resources of the IA function as well as the competency and experience of the
Internal Auditors.
Further information on the resources, objectivity and independence of the Group Head of IA and internal auditors are
provided in the Corporate Governance Report in accordance with Practice 11.2 of the MCCG.
The following IA engagements were carried out during 2022:

1. Review of fee waiver activities in relation to CCRIS report extractions, to ensure that cost savings were fully passed on to
CTOS Data Systems Sdn Bhd’s customers.
2. Review to assess the compliance of both CTOS Data Systems Sdn Bhd and CTOS Basis Sdn Bhd with Sections 22 to 27
and Sections 29 to 31 of the CRA Act 2010.
3. Review of the Group's procurement activities, to assess the effectiveness of long-term supplier relationship management,
procurement efficiency and general ABAC controls.
4. Review of the Group's product development activities, to determine the adequacy and effectiveness of governance
surrounding product planning, product development and deployment, as well as third-party management.
5. Review of the Group's cybersecurity management, based on ISO 27001:2013 requirements.
6. Review to assess CTOS Data Systems Sdn Bhd’s compliance with Section 47(2) of the Central Bank of Malaysia Act 2009.
7. Review of the management of the Group's assets and software; it focused on the adequacy and effectiveness of internal
controls surrounding acquisitions, recordkeeping, maintenance activities and safeguarding of assets and software.
8. Review of the Group's budget management.
9. Validation of the Group's Sustainability Statement disclosures for FTSE4Good Bursa Malaysia Index inclusion.
These IA engagements were carried out based on the annual audit plan approved by the ARC. The results of the audits in the
IA reports were reviewed by the ARC. The relevant Management members were made responsible for ensuring that corrective
actions on reported IA observations were taken within the required timeframes. On a quarterly basis, IA tracked and reported
the implementation of such corrective action plans to ensure that these were implemented appropriately.
As part of its control assessment activities, IA also leverages on the following, and communicates and engages with these
independent parties for further information if necessary:
a. Report received annually from Crowe Governance Sdn Bhd on its assessment of the compliance of CTOS Data Systems
Sdn Bhd with BNM’s requirement to enable it to access to CCRIS.
b. Report received annually from the Registrar Office on its assessment of the compliance of CTOS Data Systems Sdn Bhd
and CTOS Basis Sdn Bhd with CRA Act 2010 and relevant guidelines issued by the Registrar Office.
The total costs incurred by IA in discharging its functions and responsibilities in 2022 amounted to RM269,452, as compared
to RM100,000 in 2021.
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STATEMENT ON RISK MANAGEMENT

AND INTERNAL CONTROL
The Board is committed to maintaining a strong internal In 2022, the adequacy and effectiveness of internal controls
control and risk management system. Under the leadership were reviewed by the ARC in relation to the audits conducted
of the GCEO, who is responsible for good business and by Internal Audit (IA) during the year. Audit issues and actions
regulatory governance, each business / functional unit taken by Management to address the issues tabled by IA
has implemented its own control processes. The following were deliberated on during the ARC meetings. Minutes of
statement describes the nature and scope of internal control the ARC meetings which recorded these deliberations were
and risk management at the Company and its subsidiaries presented to the Board.
("CTOS" or "the Group") in 2022.
The Board has received assurances from the GCEO and
BOARD RESPONSIBILITY Head of Financial Planning and Analysis that the Group’s risk
management and internal control systems are operating
The Board affirms its overall responsibility for the Company adequately and effectively, in all material aspects, based
and its subsidiary companies in establishing a sound on the risk management and internal control system of the
system of risk management and internal control. The Board Group.
reviews the effectiveness, adequacy and integrity of the risk
management framework and internal control system via KEY INTERNAL CONTROL PROCESSES
the Audit and Risk Committee (“ARC”). This is to ensure that
significant risks faced by the Group are being managed
appropriately in proportionate to their level of significance, A Authority and responsibility
to allow the Group in responding timely and appropriately to
The following are in place:
changes in business and operating environment.
• Selected Board responsibilities are delegated
to the ARC, the Nomination and Remuneration
The Board has established a strong risk management and
Committee, and the Board Investment Committee
internal control governance structure that is crucial in setting
via clearly defined Terms of Reference (“TOR”)
the tone and culture towards effective risk management
that are reviewed periodically.
and internal control. To discharge its oversight roles and
• The Delegation of Authority is in place to manage
responsibilities more effectively, the Board has delegated the
the Board Committees’ and Management’s
independent oversight over, inter alia, internal and external
authority and authorisation limits in all aspects
audit functions and internal controls and risk management
of the Group's major business operations and
to the ARC. The Board receives reports periodically from the
regulatory functions. This includes guidance
ARC to keep the Board informed of its work, key deliberations
for entering into contracts, commitments and
and decisions on delegated matters.
appropriating assets in the course of conducting
the Group's business.
The Board continually articulates, implements and reviews
• Senior Management is accountable for the
the adequacy and effectiveness of the Group’s enterprise-
comprehensiveness of the risk identified, their
wide risk management and internal control system which
assessment and their bottom-up reporting as
has been embedded in all aspects of the Group’s activities.
well as ensuring appropriate risk management
The Board, via the ARC reviews the processes, responsibilities
is being demonstrated. Their principal roles and
and assesses for reasonable assurance that risks have been
responsibilities are as follows:
mitigated by formalising relevant controls and processes
- Provide executive leadership in the
and to ensure that the system is viable and robust.
management of risk within their work
responsibilities.
The Board confirms that there is continuous effort to enhance
- Review, update and approve their respective
the overall risk management and internal control processes
divisional risk profile as registered by each
by pursuing various initiatives that involve the Group. This
business unit.
is in accordance with the guidance as contained in the
- Report risk exposures and status of action
“Statement on Risk Management and Internal Control –
plans to the Risk Management Committee
Guidelines for Directors of Listed Issuers”.
(“RMC”).
- Ensuring significant risks are considered and
assessed during business planning.
- Ensuring significant risks are mitigated by
appropriate mitigation actions.
87

• As of 31 December 2022, the Group has two The principles of our ERM Framework are
committees, namely the RMC and ISO27001 described in table below:
Committee, which have clearly defined TOR
to enable good business and regulatory No. Principles Description
governance.
1 Culture of risk Risk management is
B Planning, monitoring and reporting ownership part of the day-to-day
job of all employees,
The following are in place: driven through
• Strategic planning activities to set out the Group’s daily application of
direction on an annual basis. management and
• Budgetary planning that is carried out on operational decisions
an annual basis, and budgetary control and 2 Defined risk Clear articulation of the
monitoring that are reported on a quarterly basis. appetite and Board’s risk appetite in
• Periodic management review meeting, at both strategy pursuit of its business
Group level (between Group Senior Management objectives
and subsidiary) and at subsidiary level. 3 Ensure proper A clear, effective and
governance robust risk governance
C Policies and procedures and oversight structure with clearly
function defined lines of
To promote better compliance with internal controls
accountabilities has
and relevant laws and regulations, the Group has
been established within
developed clear, formalised, and documented internal
the Group
policies and procedures for key activities. These control
documents are reviewed on a regular basis to ensure 4 Implement Implementation
sound risk of integrated risk
that they remain current and relevant. Employees can
framework, framework, policies and
easily access common Group policies through the
policies and procedures to ensure
Company’s intranet.
process that risk management
practices and processes
D Risk management
are effective at all levels
The following are in place: 5 Execute risk Strong risk management
i. Risk management framework management processes are in place
practices and to actively identify,
The Enterprise Risk Management Policy and processes measure, control,
Procedure (“Framework”) is aligned to ISO monitor and report
31000:2018 “Risk Management - Principles and risks inherent in all
Guidelines”. The Framework provides a structured products and activities
and consistent approach to risk management undertaken by the
implementation across the Group for informed Group
decision-making. 6 Functional The right talent pool and
capabilities infrastructure are key to
With our Framework, we identify, analyse, and capacity effectively carry out risk
evaluate and mitigate the risks to protect the management activities
Group from negative financial and non-financial
consequences that exceed the risk appetite at
operational function, business unit, divisional and
group levels. All risks relevant to the achievement
of business objectives are evaluated and
monitored. The relevant controls, action plans and
Risk Owners are also identified. Each risk is rated
according to its severity level depending on its
likelihood and impact.
88

ii. Risk appetite
The Group's risk appetite is an integral component of the Group's robust Enterprise Risk Management Framework
and is driven by both top-down Board leadership and bottom-up involvement of Senior Management at all levels.
The detailed risk appetite statement and risk indicators will be developed in FY2022. These will enable the Board
and Senior Management to communicate, understand and assess the types and levels of risks that the Group is
willing to accept in pursuit of its business and strategic goals. It will also reflect the level of risk tolerance and limits
to govern, manage and control the Group’s risk-taking activities.
The risk appetite will be integrated into the strategic planning process, and will remain dynamic and responsive
to the changing internal and external drivers such as market conditions, stakeholders’ expectations and internal
capabilities. Our risk appetite, once refined, will further provide a consistent structure in understanding risk and will
be embedded in the day-to-day business activities and decisions throughout the Group.
iii. Risk governance and oversight
The risk governance model of the Group is supported by a formal organisational structure with clear lines of
authority and responsibility. It provides a formalised, transparent and effective governance structure that promotes
active involvement from the Board and Senior Management in the risk management process to ensure a unified
view of risk.
The risk management framework is effected through an organisational construct and escalation structure as
depicted below:
Board
The Board is responsible to ensure effective stewardship over the risk-control management mechanism,
including approval of the appropriate risk governance structure and risk appetite
Board Committee – The ARC
Board level oversight on risk exposure as well as the adequacy of risk management framework (and its
components), and effective implementation of risk management strategies and practices in line with the
tolerance and risk appetite limits as approved by the Board
Management level – The RMC
The RMC is established to assist the ARC to oversee the effective implementation and maintenance of CTOS’
risk management framework and programmes for the business units
Lines of defense
First line Second line Third line

• The first line of defense is • The second line of defense • The third line of defense is
undertaken by Risk Owners. is carried out by Risk and Group Internal Audit (“GIA”)
• To identify risks that are Business Compliance (“RBC”). which provides independent
associated with their daily • Establish frameworks, policies assurance on the adequacy
business activities, analyse, and procedures. and effectiveness of the risk
assess and prioritise the risk, • Provide overall risk management framework and
implement control measures governance and oversight its corresponding internal
and monitor the progress of and challenge the first line. controls.
the mitigating action plans. • Monitor level of compliance • The GIA reports independently
to the applicable laws, to the ARC and subsequently
regulations, established to the Board.
policies and procedures.
89

iv. Risk and compliance culture
The risk and compliance culture of the Group is driven by a strong tone from the top by the Board and Senior
Management and at the same time also inculcate an enterprise-wide awareness of risks at all level of the Group.
As part of the risk and compliance culture, the Group has instilled a culture where the Board, Senior Management
and employees are committed to adhere to the requirements of relevant laws, rules, and regulations. This is
reiterated in the recently formalised Risk Appetite Statement. This commitment is further demonstrated through
the establishment and enhancement of policies, processes and controls in managing and preventing non-
compliances.
Programmes related to risk and compliance including induction programme, e-Learnings and memorandums
are established and driven by the Board and Senior Management as part of the journey toward effective risk
management within the Group.
v. Risk management processes
The Group’s risk management process is guided by ISO31000:2018 Risk Management Guidelines as illustrated
below. It comprises of the following elements:
Identification Measurement
• Risk identification involves identifying and • Develop both quantitative and qualitative
documenting risk across all areas of the measurement to determine the severity of risk
business. depending on circumstances, information
• Ensure early detection of risk and sound risk available and perception from all business
management policies and procedures are in units.
place to manage and mitigate risk.
Monitoring and Reporting Controls

• Monitor forward looking key risk indicators to • Develop the necessary action plans and
ensure potential risk is reported and mitigation ensure its effectiveness to mitigate significant
actions are taken on a timely manner. risks. This is guided by established risk
• Periodic update to Management level and treatments, for example, risk avoidance, risk
Board level risk committees as well as to the acceptance, risk, reduction and risk sharing/
Board. transfer.
vi. Risk assessment
During the financial year ended 31 December 2022, the Group conducted their risk management and internal
control system reviews which were assessed by the RMC and reported to the ARC on a quarterly basis.
The Group identified major risk areas of concern and mitigating actions were undertaken within appropriate
timeframes. The management of the Group’s significant risks identified for the financial year 2022 is outlined below:
No. Risk name Risk description Mitigation action strategies / takeaways
1 Cyber threats As the technology landscape changes, The Group remains cautious and vigilant
and data increased adoption of digitalisation and on potential cyber threats and has been
security risk service delivery via cyberspace, the Group continuously upgrading and enhancing
could be more susceptible to external the cybersecurity strategy to improve
security attack, insider threats or network and upgrade processes, technology, and
vulnerability. people in managing cyber risks.
90

1 Cyber threats Additionally, the Group’s nature of business To further mitigate the risk, an insurance
and data in dealing with vast amount of data programme to safeguard major assets
security risk further elevates the above risks. These against financial loss is renewed annually.
(continued) may include data compromise resulting
in financial loss, reputational damage,
breach of regulatory requirements and/or
legal claims.
2 Legal, The Group’s main operating subsidiary The Group undertakes robust monitoring of
regulatory and is operating in a complex regulatory developments in laws and regulations and
compliance landscape and many of the business assesses its impact to its processes, where
risk activities and services are subject to legal applicable.
and regulatory influence.
We continuously strengthen our policies,
Changing regulations, compliance processes and controls in anticipation of
requirements and industry policies and in response to new regulations, and
could adversely impact the Group’s key regulatory requirements.
competitiveness and ability to conduct
business efficiently. Furthermore, the Group also maintains
regular engagement with the regulators,
Any incidence of non-compliance and authorities, and legal experts to seek
breach of regulations may result in guidance and ensure compliance at all
material litigation and regulatory actions times.
that will adversely impact the Group
resulting in financial loss and reputational
damage.
3 Financial risk The demand for the Group’s products The Group has a comprehensive suite of
and services depends on the transaction offerings encompassing end-to-end credit
volumes of its customers which, in turn, are management suite that enables the Group
sensitive to changes in general economic to be more competitive. It further invests
conditions. in upgrading its suites of products on a
continual basis to address changing and
Furthermore, as competition intensifies growing technological needs of the market.
amongst competitors, digital service
providers and the rapid growth of the The Group will continue to look into
fintech industry in Malaysia, price and implementing necessary strategies to
market erosion may impact both revenue further gain market share and maintain
and margin. leadership position.
4 Human The Group's success depends on the The Group has put in place
capital risk ability to attract, develop, motivate and comprehensive guidelines on the
retain key talent. Succession planning, employment, performance appraisal
especially on experienced senior and training program for the retention of
personnel is crucial to maintain the employees.
Group’s competitiveness in the market.
In addition, the Group also proactively
The need to maintain talented and reviews the remuneration benefits of
skilled personnel can positively impact employees from time to time to stay
the Group’s ability to execute business competitive.
strategies and deliver superior services to
our customers.
91

5 Business With the advent of cyber threats, computer The Group has put in place the necessary
continuity network and system failure and other disaster recovery plan for its critical
and crisis potential hazards such as pandemic business system to minimise any service
management outbreak, fires, floods, and major interruptions.
risk equipment failures, amongst others, the
continuity of business operations is of a During the financial year, the Group
major concern to the Group. did not encounter any major business
interruption or crises.
6 Operational The Group’s business relies on data The Group is constantly focusing
risk from external data providers including on enriching its data sources and
government agencies and other public developing alternative solutions to reduce
sources. Inability to continuously access dependency on external data sources
these data sources or experiencing any and service providers.
service performance issue could impact
the Group’s ability in services delivery
and harm its competitive position in the
industry.
7 Strategic risk The Company is a constituent of the The Company has established an ESG
FTSE4Good Bursa Malaysia Index roadmap. This will be further elaborated in
and the FTSE4Good Bursa Malaysia the Sustainability Statement.
Shariah Index. Inability to adhere to the
FTSE4Good requirements will result in the Continuous effort in complying with
Company’s removal from these indices, the requirements is vital to ensure the
and subsequently will impact the Group’s Company remains in the FTSE4Good
reputation and relationship with our indices in order to build a stronger
stakeholders. corporate brand and promote sustainable
long-term growth.
E Compliance management
The roles and responsibilities of Compliance are primarily guided by but not limited to the rules and regulations issued
by the relevant regulators including Registrar of Credit Reporting Agency under Ministry of Finance, Bank Negara
Malaysia, Department of Personal Data Protection, Securities Commission and Bursa Malaysia. Compliance provides
guidance and solutions to business whilst ensuring business objectives and regulatory obligations are met.
F Employee conduct
The following are in place:

• A Code of Business Conduct and Ethics establishes the Group's policy on business conduct and the standards of
behaviour / ethical conduct expected of its employees. It outlines the minimum requirements for all employees to
follow in areas and situations where public trust and confidence may be jeopardised or a law may be broken.
• The Group has a Whistleblowing Policy (“WP”) and Whistleblowing Investigation Procedures (“WIP”) that allow
any person, including employees, directors, and external parties, to report any improper conduct as defined in
the WP against any employee or director in a safe and confidential manner. An employee who reports improper
behaviour in good faith shall not face retaliation, termination or suspension of service, disciplinary action, transfer,
demotion, or any other use of authority to obstruct the whistleblower’s right to continue performing their duties. The
ARC is in charge of overseeing the implementation of WP and WIP, as well as ensuring effective administration by
Human Resources and GIA.
• The Group has also hired an external counsel to conduct a gap analysis on its anti-bribery and anti-corruption
(“ABAC”) practises; the results of this exercise include the development of new procedures (as well as revisions
to existing ones) that are expected to promote the highest levels of integrity and ethics amongst the Group's
employees.
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G Insurance REVIEW BY EXTERNAL AUDITORS
Insurance coverage and physical safeguards on major This Statement on Risk Management and Internal Control
assets are in place to protect the Group's assets from has been reviewed by our external auditor in accordance
any unforeseen events that could result in material loss. with Paragraph 15.23 of Bursa Listing’s Main Market Listing
Senior Management conducts a yearly policy renewal Requirements for the financial year under review. Their limited
exercise to review the coverage of these assets, as assurance review was performed in accordance with Audit
recorded in the current fixed assets register. and Assurance Practice Guide (“AAPG”) 3 issued by the
Malaysian Institute of Accountants. AAPG 3 does not require
H Internal audit function the external auditor to form an opinion on the adequacy
and effectiveness of the risk management and internal
Internal audit (“IA”) engagements are carried out control system of our Group.
in accordance with the annual IA plan approved by
the ARC, taking into account feedback from Senior
CONCLUSION
Management and the GCEO. GIA evaluates the
selected areas under the IA scope in terms of risk
The system of internal control provides reasonable, rather
exposures, compliance with approved policies and than absolute, assurance that the Group will not be adversely
procedures, as well as relevant laws and regulations, affected by any event that could be reasonably foreseen as
and is benchmarked against available best practises it strives to achieve its business objectives. However, the Board
where applicable. also notes that no system of internal control can provide
absolute assurance in this regard, or absolute assurance
Where significant gaps in the governance, risk against the occurrence of material errors, losses, fraud or
management, and internal control processes are other irregularities.
identified during the engagements, GIA makes
recommendations to Senior Management on potential The Board and Senior Management are committed to
improvements in the design and effectiveness of operating a sound system of internal control and the
existing processes. The ARC takes note of the review internal control system will continue to be reviewed, updated
results (which include the state of internal controls and improved upon in line with changes in the operating
and control improvements required), and these results environment.
are then shared with Senior Management to ensure
the Group’s internal control system is continuously For the financial year under review and up to the date of
improved. Follow-up assessments are carried out to issuance of the financial statements, the Board is satisfied
determine the status of management’s implementation with the adequacy, integrity and effectiveness of the Group’s
of the GIA recommendations; these are also reported system of risk management and internal control. No material
to the ARC. losses, contingencies, or uncertainties have arisen from
any inadequate or failure of the Group’s system of internal
Additionally, GIA reviews reports prepared by external control that would require separate disclosure in the Group’s
consultants, if any. Annual Report.
GIA strives to continuously adhere to the mandatory The Board believes that, in the absence of any evidence
elements of The Institute of Internal Auditors’ International to the contrary, the system of internal controls, including
Professional Practices Framework, including the Core the financial, operational and compliance controls and
Principles for the Professional Practice of Internal risk management system, maintained by the Group’s
Auditing, the International Standards for the Professional management, were in place throughout the financial year
and up to and as of the date of the report, are adequate
Practices of Internal Auditing, and the Code of Ethics.
to meet the needs of the Group in its current business
environment.
This statement is made in accordance with a resolution of

the Board dated 17 April 2023.
93
OUR
FINANCIALS
Directors' Report 95
Financial Statements 109
Statement By Directors 191
Statutory Declaration 191
Independent Auditors' Report 192
DIRECTORS’ REPORTS
The Directors hereby submit their report together with the audited financial statements of the Group and of the Company for
the financial year ended 31 December 2022.
PRINCIPAL ACTIVITIES
The principal activity of the Company is investment holding, whilst the principal activities of the Group are credit reporting
agency, digital software related services including software development, outsourcing and provision of training services.
Details of the principal activities of the subsidiaries are shown in Note 14 to the financial statements.
There have been no significant changes in the nature of the principal activities of the Group and of the Company during
the financial year.
FINANCIAL RESULTS
Group Company
RM’000 RM’000
Profit for the financial year 71,718 78,138
DIVIDENDS
The dividends declared since the end of the previous financial year were as follows:
RM’000
In respect of the financial year ended 31 December 2021:

- Single-tier tax exempt third interim dividend of 0.33 sen per share on 2,200,000,000 ordinary shares, paid
on 25 February 2022 7,260
In respect of the financial year ended 31 December 2022:

- Single-tier tax exempt first interim dividend of 0.325 sen per share on 2,310,000,000 ordinary shares, paid
on 10 June 2022 7,507
- Single-tier tax exempt second interim dividend of 0.59 sen per share on 2,310,000,000 ordinary shares,
paid on 13 September 2022 13,629
- Single-tier tax exempt third interim dividend of 0.60 sen per share on 2,310,000,000 ordinary shares, paid
on 14 December 2022 13,860
42,256
Subsequent to the financial year, on 31 January 2023, the Company declared a fourth interim single-tier tax-exempt dividend
of 0.36 sen per ordinary shares amounting to RM8.32 million in respect of the financial year ended 31 December 2022 which
was paid on 15 March 2023. The financial statements for the financial year ended 31 December 2022 do not reflect these
dividends. Upon declaration, the cash dividend payment will be accounted for in equity as an appropriation of retained
earnings during the financial year ending 31 December 2023.
RESERVES AND PROVISIONS
All material transfers to or from reserves and provisions during the financial year have been disclosed in the financial
statements.
95
OUR FINANCIALS
SHARE CAPITAL
During the financial year, the issued and paid-up ordinary share capital of the Company was increased from RM412.5 million
to RM584.0 million by way of issuance of 110,000,000 new ordinary shares at an issue price of RM1.58 per share pursuant to
the private placement exercise which was completed on 3 March 2022. Following the allotment of new shares, the Company’s
total number of share capital has increased to 2,310,000,000 shares.
Other than the above, there were no changes in the authorised, issued and paid-up capital of the Company during the
financial year.
DIRECTORS
The Directors in office during the financial year and during the period from the end of the financial year to the date of the
report are:
Tan Sri Izzuddin bin Dali

Dato’ Noorazman bin Abd Aziz
Erick Hamburger Barraza (appointed on 30 September 2022)
Loh Kok Leong
Lynette Yeow Su-Yin
Su Puay Leng
Wong Pau Min (alternate director to Loh Kok Leong)
Datuk Azizan bin Haji Abd Rahman (resigned on 7 March 2022)
Dennis Colin Martin (resigned on 30 September 2022)
DIRECTORS OF SUBSIDIARIES
Pursuant to Section 253 of the Companies Act 2016, the Directors of the subsidiaries (excluding Directors who are also
Directors of the Company) in office since the beginning of the financial year to the date of the report are as follows:
Chin Kuan Weng

Wong Pau Min
Omar Mahmoud
Chan Chee Hoo (resigned on 15 April 2023)
Puvendran A/L Sangaran (appointed on 15 April 2023)
DIRECTORS’ BENEFITS
Since the end of the previous financial year, no Director of the Company has received or become entitled to receive a benefit
(other than benefits included in the aggregate amount of emoluments received or due and receivable by the Directors as
shown below) by reason of a contract made by the Company or a related corporation with the Director or with a firm of
which he/she is a member, or with a company in which the Director has a substantial financial interest.
96
DIRECTORS’ BENEFITS (CONTINUED)
The aggregate amount of emoluments received or due and receivable by the Directors of the Company during the financial
year are as follows:
Group Company
RM’000 RM’000
Fees 456 456

Wages, salaries and bonuses 654 197
1,110 653
There was no benefit-in-kind provided to Directors of the Company during the financial year.
Neither during nor at the end of the financial year was the Company or any of its subsidiaries a party to any arrangements
whose object was to enable the Directors to acquire benefits by means of the acquisition of shares in, or debentures of, the
Company or any other body corporate.
DIRECTORS’ INTERESTS IN SHARES AND DEBENTURES
According to the Register of Directors’ Shareholdings required to be kept under Section 59 of the Companies Act 2016,
none of the Directors who held office at the end of the financial year held any shares or debentures in the Company or its
subsidiaries or its holding company or subsidiaries of the holding company during the financial year except as follows:
Number of ordinary shares in the Company

As at
1.1.2022/
date of As at
appointment Acquired Sold 31.12.2022
Tan Sri Izzuddin bin Dali 130,000 - - 130,000

Dato’ Noorazman bin Abd Aziz 200,000 - - 200,000
Erick Hamburger Barraza 150,000 - - 150,000
Loh Kok Leong 300,000 - - 300,000
Lynette Yeow Su-Yin 300,000 - - 300,000
Su Puay Leng 300,000 - - 300,000
Wong Pau Min 700,000 - (200,000) 500,000
INDEMNITY AND INSURANCE FOR DIRECTORS AND OFFICERS
The Company has effected Directors’ and Officers’ Liability Insurance for the Directors of the Group and of the Company, for
up to a maximum of RM20.0 million for any one claim and in aggregate, at a total premium cost of RM40,290 in the current
financial year.
97
OUR FINANCIALS
STATUTORY INFORMATION ON THE FINANCIAL STATEMENTS
Before the financial statements of the Group and of the Company were prepared, the Directors took reasonable steps:
(a) to ascertain that proper action had been taken in relation to the writing off of bad debts and the making of allowance
for impairment of doubtful debts and satisfied themselves that all known bad debts had been written off and that
adequate allowance had been made for doubtful debts; and
(b) to ensure that any current assets, which were unlikely to be realised in the ordinary course of business including the
values of current assets as shown in the accounting records of the Group and of the Company had been written down
to an amount which the current assets might be expected so to realise.
At the date of this report, the Directors are not aware of any circumstances:
(a) which would render the amounts written off for bad debts or the amount of the allowance for impairment of doubtful
debt in the financial statements of the Group and of the Company inadequate to any substantial extent; or
(b) which would render the values attributed to current assets in the financial statements of the Group and of the Company
misleading; or
(c) which have arisen which render adherence to the existing method of valuation of assets or liabilities of the Group and
of the Company misleading or inappropriate.
At the date of this report, there does not exist:
(a) any charge on the assets of the Group and of the Company which has arisen since the end of the financial year which
secures the liabilities of any other person except as disclosed in Note 23 to the financial statements; and
(b) any contingent liabilities of the Group and of the Company which has arisen since the end of the financial year except
as disclosed in Note 31 to the financial statements.
No contingent or other liability of the Group and of the Company has become enforceable or is likely to become enforceable
within the period of twelve months after the end of the financial year which, in the opinion of the Directors, will or may affect
the ability of the Group and of the Company to meet its obligations when they fall due.
At the date of this report, the Directors are not aware of any circumstances not otherwise dealt with in this report or the
financial statements of the Group and of the Company which would render any amount stated in the financial statements
misleading.
In the opinion of the Directors:
(a) the results of the Group’s and of the Company’s operations during the financial year were not substantially affected by
any item, transaction or event of a material and unusual nature; and
(b) there has not arisen in the interval between the end of the financial year and the date of this report any item, transaction
or event of a material and unusual nature likely to affect substantially the results of the operations of the Group and of
the Company for the financial year in which this report is made.
IMMEDIATE HOLDING AND ULTIMATE HOLDING COMPANIES
The Directors regard Inodes Limited (“Inodes”), incorporated in British Virgin Islands as the immediate holding company and
Creador II, LLC, incorporated in Mauritius as the ultimate holding company.
98
SUBSIDIARIES
Details of subsidiaries are set out in Note 14 to the financial statements.
AUDITORS’ REMUNERATION
Details of auditors’ remuneration are as follows:
Group Company
RM’000 RM’000
Auditors’ remuneration
- fees for statutory audit to PricewaterhouseCoopers PLT (LLP0014401-LCA & AF 1146) 427 192
- fees for other services to member firms of PricewaterhouseCoopers PLT 182 108
609 300
AUDITORS
The auditors, PricewaterhouseCoopers PLT (LLP0014401-LCA & AF 1146), have expressed their willingness to accept re-
appointment as auditors.
This report was approved by the Board of Directors on 17 April 2023. Signed on behalf of the Board of Directors:
TAN SRI IZZUDDIN BIN DALI ERICK HAMBURGER BARRAZA

DIRECTOR DIRECTOR
Kuala Lumpur
99
OUR FINANCIALS
STATEMENTS OF COMPREHENSIVE INCOME

Group Company
2022 2021 2022 2021
Note RM’000 RM’000 RM’000 RM’000
CONTINUING OPERATIONS
Revenue 5 194,781 153,166 91,845 64,461
Cost of sales (30,154) (19,190) - -
Gross profit 164,627 133,976 91,845 64,461
Other (expenses)/income (1,513) 375 (1,633) 259
Selling and marketing expenses (33,185) (29,243) (148) (227)
Administrative expenses (63,696) (54,015) (7,759) (9,382)
Finance income 6 519 412 82 195
Finance costs 6 (4,345) (5,679) (4,185) (5,617)
Share of profits of associates 15 23,274 7,217 - -
Profit before tax 7 85,681 53,043 78,202 49,689
Tax expense 10 (13,963) (9,338) (64) (59)
Profit from continuing operations 71,718 43,705 78,138 49,630
DISCONTINUED OPERATIONS
Loss from discontinued operations 35 - (1,134) - -
Profit for the financial year 71,718 42,571 78,138 49,630
Other comprehensive income/(loss):
Items that will be subsequently reclassified to
profit or loss:
Exchange differences on translation of foreign
operations 1,489 (6,742) - -
Share of other comprehensive loss of
associate accounted for using equity
method (59) (13) - -
Exchange differences on translation of
discontinued operations - 392 - -
Items that will not be subsequently reclassified
to profit or loss:
Exchange differences on translation of foreign
operations - 171 - -
Share of other comprehensive income of
associate accounted for using equity
method 2,410 - - -
Other comprehensive income/(loss) for the
financial year 3,840 (6,192) - -
Total comprehensive income for the financial
year 75,558 36,379 78,138 49,630
100
STATEMENTS OF COMPREHENSIVE INCOME

Group Company
2022 2021 2022 2021
Note RM’000 RM’000 RM’000 RM’000
Profit/(loss) for the financial year attributable to:

Owners of the Company
- from continuing operations 71,718 43,705 78,138 49,630
- from discontinued operations - (583) - -
71,718 43,122 78,138 49,630
Non-controlling interests - (551) - -
71,718 42,571 78,138 49,630
Total comprehensive income/(loss) for the
financial year attributable to:
Owners of the Company
- from continuing operations 75,558 36,950 78,138 49,630
- from discontinued operations - (191) - -
75,558 36,759 78,138 49,630
Non-controlling interests - (380) - -
75,558 36,379 78,138 49,630
Earnings per share for profit attributable to

ordinary equity holders of the Company:
- Basic/diluted (sen) 32
- Continuing operations 3.1 2.1 - -
- Discontinued operations - - - -
3.1 2.1 - -
The notes on pages 109 to 192 form part of these financial statements.
101
OUR FINANCIALS
STATEMENTS OF FINANCIAL POSITION

AS AT 31 DECEMBER 2022
Group Company
2022 2021 2022 2021
Note RM’000 RM’000 RM’000 RM’000
NON-CURRENT ASSETS
Property, plant and equipment 11 12,697 14,694 12 21

Right-of-use assets 12 3,033 4,631 133 205
Intangible assets 13 86,575 79,176 - -
Investments in subsidiaries 14 - - 342,828 342,828
Investments in associates 15 574,620 172,904 504,618 118,712
Other investment 16 - 17,664 - 17,664
Receivables, deposits and prepayments 18 554 554 26 26
Deferred tax assets 17 972 1,237 - -
TOTAL NON-CURRENT ASSETS 678,451 290,860 847,617 479,456
CURRENT ASSETS
Receivables, deposits and prepayments 18 39,299 25,161 114 107

Other investments 16 5,048 26,000 5,048 15,000
Amount due from related parties 19 2 1,422 - -
Amount due from subsidiary 22 - - 807 1,050
Tax recoverable 33 9 21 -
Cash and bank balances 20 12,406 17,131 3,395 2,147
TOTAL CURRENT ASSETS 56,788 69,723 9,385 18,304
CURRENT LIABILITIES
Payables and accruals 21 31,374 21,755 1,636 2,062

Contract liabilities 5 7,508 8,208 - -
Contingent consideration 34 12,157 - 12,157 -
Lease liabilities 12 1,606 1,546 73 70
Amount due to related parties 19 1,891 144 - -
Borrowings 23 9,972 - 9,972 -
Taxation 16,294 7,970 - 18
TOTAL CURRENT LIABILITIES 80,802 39,623 23,838 2,150
NET CURRENT (LIABILITIES)/ASSETS (24,014) 30,100 (14,453) 16,154
102
STATEMENTS OF FINANCIAL POSITION

AS AT 31 DECEMBER 2022
Group Company
2022 2021 2022 2021
Note RM’000 RM’000 RM’000 RM’000
NON-CURRENT LIABILITIES

Contingent consideration 34 - 9,267 - 9,267
Deferred tax liabilities 17 71 100 - -
Provision for restoration costs 24 678 612 - -
Borrowings 23 139,489 - 139,489 -
TOTAL NON-CURRENT LIABILITIES 141,731 13,079 139,552 9,403
NET ASSETS 512,706 307,881 693,612 486,207
EQUITY
Share capital 25 584,047 412,524 584,047 412,524

Reverse acquisition reserve (193,528) (193,528) - -
Equity contribution from shareholder 315 315 315 315
Other reserves 26 (2,542) (6,426) - 5,797
Retained earnings 124,414 94,996 109,250 67,571
TOTAL EQUITY 512,706 307,881 693,612 486,207
103
Ordinary shares Other reserves
104
Equity Foreign
contribution Reverse currency Fair
Number of Share from acquisition translation value Retained Total
shares capital shareholders reserve(1) reserve reserve earnings equity
Group ‘000 RM’000 RM’000 RM’000 RM’000 RM’000 RM’000 RM’000
As at 1 January 2022 2,200,000 412,524 315 (193,528) (6,669) 243 94,996 307,881
OUR FINANCIALS
Issuance of new shares (Note 25) 110,000 173,800 - - - - - 173,800

Share issuance expenses (Note 25) - (2,277) - - - - - (2,277)
Profit for the financial year - - - - - - 71,718 71,718
Other comprehensive income/(loss) - - - - 1,458 2,426 (44) 3,840
Transaction with owners:
Dividends paid (Note 30) - - - - - - (42,256) (42,256)
As at 31 December 2022 2,310,000 584,047 315 (193,528) (5,211) 2,669 124,414 512,706
STATEMENTS OF CHANGES IN EQUITY
Note:
(1)
The reverse acquisition reserve was created during the acquisition of CTOS Business Systems Sdn. Bhd. ("CBS"), CTOS Data Systems Sdn. Bhd. ("CDS") and Automated Mail Responder Sdn. Bhd.
("AMR") by the Company in 2014. CBS was identified as the accounting acquirer in accordance with MFRS 3 “Business Combination”. The difference between the issued equity of the Company
and issued equity of CBS together with the deemed purchase consideration of subsidiaries other than CBS is recorded as reverse acquisition reserve.
Ordinary shares Other reserves
Retirement
benefit Total
Equity Foreign reserve attributable
contribution Reverse currency and to owners Non-
Number Share from acquisition translation fair value Retained of the controlling Total
of shares capital shareholders reserve(1) reserve reserve earnings Company interest equity
Group ‘000 RM’000 RM’000 RM’000 RM’000 RM’000 RM’000 RM’000 RM’000 RM’000
As at 1 January 2021 100,000 197,994 315 (193,528) (145) 100 106,025 110,761 4,967 115,728
Subdivision of shares
(Note 25) 1,900,000 - - - - - - - - -
Issuance of new shares
(Note 25) 200,000 220,000 - - - - - 220,000 - 220,000
Share issuance expenses
(Note 25) - (5,470) - - - - - (5,470) - (5,470)
Profit/(loss) for the financial
year - - - - - - 43,122 43,122 (551) 42,571
Other comprehensive (loss)/
income - - - - (6,363) - - (6,363) 171 (6,192)
Distribution of subsidiaries
(Note 35) - - - - (161) 143 (13,135) (13,153) (4,587) (17,740)
Dividends paid (Note 30) - - - - - - (41,016) (41,016) - (41,016)
As at 31 December 2021 2,200,000 412,524 135 (193,528) (6,669) 243 94,996 307,881 - 307,881
CTOS Digital Berhad
Note:
(1)
The reverse acquisition reserve was created during the acquisition of CTOS Business Systems Sdn. Bhd. ("CBS"), CTOS Data Systems Sdn. Bhd. ("CDS") and Automated Mail Responder Sdn. Bhd.
("AMR") by the Company in 2014. CBS was identified as the accounting acquirer in accordance with MFRS 3 “Business Combination”. The difference between the issued equity of the Company
Annual Repor t 2022
105
and issued equity of CBS together with the deemed purchase consideration of subsidiaries other than CBS is recorded as reverse acquisition reserve.
Equity
106
contribution
Number Share from Other Retained Total
of shares capital shareholders reserves earnings equity
Company Note ‘000 RM’000 RM’000 RM’000 RM’000 RM’000
As at 1 January 2022 2,200,000 412,524 315 5,797 67,571 486,207

Issuance of new shares 25 110,000 173,800 - - - 173,800
OUR FINANCIALS
Share issuance expenses 25 - (2,277) - - - (2,277)

Profit and total comprehensive income for the
financial year - - - - 78,138 78,138
Dividends paid 30 - - - - (42,256) (42,256)
Reclassification of share-based payment reserve to
retained earnings - - - (5,797) 5,797 -
As at 31 December 2022 2,310,000 584,047 315 - 109,250 693,612
As at 1 January 2021 26 100,000 197,994 315 5,797 74,012 278,118
Subdivision of shares 25 1,900,000 - - - - -

Issuance of new shares 25 200,000 220,000 - - - 220,000

Share issuance expenses 25 - (5,470) - - - (5,470)
Profit and total comprehensive income for the
financial year - - - - 49,630 49,630
Distribution of subsidiaries 35 - - - - (15,055) (15,055)
Dividends paid 30 - - - - (41,016) (41,016)
As at 31 December 2021 2,200,000 412,524 315 5,797 67,571 486,207
STATEMENTS OF CASH FLOWS

Group Company
2022 2021 2022 2021
Note RM’000 RM’000 RM’000 RM’000
CASH FLOWS FROM OPERATING ACTIVITIES
Profit/(loss) before tax

Continuing operations 85,681 53,043 78,202 49,689
Discontinued operations - (970) - -
85,681 52,073 78,202 49,689
Adjustments for:
Allowance for impairment of receivables - net 28(c) 298 304 - -
Depreciation of property, plant and
equipment 11 5,264 5,989 9 6
Depreciation of right-of-use assets 12 1,598 1,729 72 12
Amortisation of intangible assets 13 1,628 880 - -
Dividend income (1,346) - (89,909) (62,013)
Interest income (108) (156) (12) (22)
Distribution income from money market fund (61) (258) (22) (173)
Fair value gain on other investments (350) - (48) -
Loss/(gain) on disposal of property, plant and
equipment 4 (4) - -
Accretion of provision for restoration costs 24 17 9 - -
Changes in fair value of contingent
consideration payable 2,890 (177) 2,890 (177)
Interest expense 6 4,178 5,616 4,178 5,616
Lease interest 12 150 81 7 1
Share of profits of associates 23,274 (7,217) - -
Defined benefit plan expense - 49 - -
Loss on foreign exchange 19 4,417 47 4,477
Operating cash flows before working capital

changes 76,588 63,335 (4,586) (2,584)
Changes in working capital:

Receivables, deposits and prepayments 14,504 (3,070) (31) 519
Payables and accruals 12,214 5,820 (426) 1,541
Contract liabilities (700) 1,310 - -
Related parties balances 3,167 (1,646) - -
Amounts due from subsidiaries - - 258 (989)
Cash flow generated from/(used in) operations 76,765 65,749 (4,785) (1,513)
Interest received 108 156 12 22

Tax paid (5,427) (3,283) (103) (38)
Tax refunded - 6 - 1
Share based payment - (113) - -
Defined benefit plan contribution - (373) - -
Dividend received 29 12,649 5,195 89,909 62,013
Net cash flows generated from operating

activities 84,095 67,337 85,033 60,485
107
OUR FINANCIALS
STATEMENTS OF CASH FLOWS

Group Company
2022 2021 2022 2021
Note RM’000 RM’000 RM’000 RM’000
CASH FLOWS FROM INVESTING ACTIVITIES
Purchase of property, plant and equipment 11 (5,278) (2,587) - (27)

Purchase of intangible assets 13 (9,561) (2,038) - -
Proceeds from disposal of property, plant and
equipment - 27 - -
Distribution income from money market funds 453 215 94 148
Acquisition of subsidiary, net of cash acquired 34 - (28,018) - (32,000)
Investments in associate 15 (336,259) (26,802) (336,259) (26,802)
Purchase of other investments 16 (31,983) (17,664) (31,983) (17,664)
Investment in money market funds - net 16 20,952 (26,000) 9,952 (15,000)
Net cash outflow on distribution of subsidiaries 35 - (3,147) - -
Net cash flows used in investing activities (361,676) (106,014) (358,196) (91,345)
CASH FLOWS FROM FINANCING ACTIVITIES
Restricted cash for term loan facility 20 (1,692) 1,435 (1,692) 1,435
Proceeds from issuance of shares 25 173,800 220,000 173,800 220,000
Payment of share issuance expenses 25 (2,277) (5,470) (2,277) (5,470)
Dividends paid 30 (42,256) (41,016) (42,256) (41,016)
Drawdown of borrowings 23 224,210 32,000 224,210 32,000
Repayment of borrowings 23 (73,628) (170,646) (73,628) (170,646)
Payment of lease liabilities 12 (1,697) (1,885) (77) (13)
Transaction cost paid 23 (2,528) (627) (2,528) (627)
Interest paid 23 (2,771) (3,092) (2,771) (3,092)
Advances to a subsidiary 22 - - (15) -
Net cash flows generated from financing

activities 271,161 30,699 272,766 32,571
NET (DECREASE)/INCREASE IN CASH AND CASH

EQUIVALENTS (6,420) (7,978) (397) 1,711
EFFECT OF EXCHANGE RATE CHANGES 3 173 (47) (40)
CASH AND CASH EQUIVALENTS AT THE BEGINNING

OF THE FINANCIAL YEAR 17,131 24,936 2,147 476
CASH AND CASH EQUIVALENTS AT THE END OF

THE FINANCIAL YEAR 20 10,714 17,131 1,703 2,147
108
NOTES TO THE FINANCIAL STATEMENTS

31 DECEMBER 2022
1 GENERAL INFORMATION
The principal activity of the Company is investment holding, whilst the principal activities of the Group are credit
reporting agency, digital software related services including software development, outsourcing and provision of
training services.
The Directors regard Inodes Limited (“Inodes”), incorporated in British Virgin Islands as the immediate holding company
and Creador II, LLC, incorporated in Mauritius as the ultimate holding company.
The address of the registered office and principal place of business of the Company are as follows:
Registered office Principal place of business
Unit 30-1, Level 30, Tower A Unit 1-12, Level 8, Tower A

Vertical Business Suite Vertical Business Suite
Avenue 3, Bangsar South Avenue 3, Bangsar South
No. 8, Jalan Kerinchi No. 8, Jalan Kerinchi
59200 Kuala Lumpur 59200 Kuala Lumpur
2 BASIS OF PREPARATION
The financial statements of the Group and of the Company have been prepared in accordance with the Malaysian
Financial Reporting Standards (“MFRS”), International Financial Reporting Standards and the requirements of the
Companies Act 2016 in Malaysia. The financial statements have been prepared under the historical cost convention
except as disclosed in the summary of significant accounting policies in Note 3 to the financial statements.
The preparation of financial statements in conformity with MFRS requires the use of certain critical accounting estimates
and assumptions that affect the reported amounts of assets and liabilities and disclosure of contingent assets and
liabilities at the date of the financial statements, and the reported amounts of revenues and expenses during the
reported financial period. It also requires the Directors to exercise their judgement in the process of applying the Group’s
and the Company’s accounting policies. Although these estimates and judgement are based on the Directors’ best
knowledge of current events and actions, actual results may differ.
As at 31 December 2022, the Group and the Company were in net current liabilities positions of RM24.0 million and
RM14.5 million respectively which was mainly contributed by the Group’s and the Company’s tax payable, contingent
consideration and borrowings as at 31 December 2022. The Group and the Company have prepared the financial
statements on a going concern basis premised upon the sufficiency of cash flows to enable the Group and the
Company to meet their liabilities as and when they fall due and to carry out their operations without a significant
curtailment. See Note 28(b) for details.
The areas involving a higher degree of judgement or complexity, or areas where assumptions and estimates are
significant to the financial statements are disclosed in Note 4 of the financial statements.
109
OUR FINANCIALS

31 DECEMBER 2022
2 BASIS OF PREPARATION (CONTINUED)
(a) Standards, amendments to published standards and interpretations that are effective to the Group and the
Company
The amendments and improvements to published standards that are effective for the Group’s and the Company’s
financial year beginning on or after 1 January 2022 are as follows:
• Amendment to MFRS 16 ‘COVID-19-Related Rent Concessions beyond 30 June 2021’

• Amendments to MFRS 116 ‘Proceeds before Intended Use’
• Amendments to MFRS 3 ‘Reference to the Conceptual Framework’
• Amendments to MFRS 137 ‘Onerous Contracts – Cost of Fulfilling a Contract’
• Annual Improvements to MFRS 9 ‘Fees in the '10 per cent' test for Derecognition of Financial Liabilities’
• Annual Improvements to Illustrative Example accompanying MFRS 16 ‘Leases’: Lease Incentives
The adoption of the above amendments did not have any impact on the amounts recognised in prior periods
and are not expected to significantly affect the current or future periods.
(b) Standards, amendments to published standards and interpretations that are applicable to the Group and the
Company but not yet effective
A number of new standards and amendments to standards and interpretations are effective for financial year
beginning on or after 1 January 2023. None of these are expected to have a significant effect on the financial
statements of the Group and the Company except the following:
• Amendments to MFRS 112 ‘Deferred Tax related to Assets and Liabilities arising from a Single Transaction’
(effective 1 January 2023) clarify that the initial exemption rule does not apply to transactions where both
an asset and a liability are recognised at the same time such as leases and decommissioning obligations.
Accordingly, entities are required to recognise both deferred tax assets and liabilities for all deductible and
taxable temporary differences arising from such transactions.
• Amendments to MFRS 16 ‘Lease Liability in a Sale and Leaseback’ (effective 1 January 2024) specify the
measurement of the lease liability arises in a sale and leaseback transaction that satisfies the requirements
in MFRS 15 ‘Revenue from Contracts with Customers’ to be accounted for as a sale. In accordance with the
amendments, the seller-lessee shall determine the “lease payments” or “revised lease payments” in a way
that it does not result in the seller-lessee recognising any amount of the gain or loss that relates to the right
of use it retains.
The amendments shall be applied retrospectively to sale and leaseback transactions entered into after the
date when the seller-lessee initially applied MFRS 16.
• Amendments to MFRS 101 ‘Classification of liabilities as current or non-current’ (effective 1 January 2024)
clarify that a liability is classified as non-current if an entity has a substantive right at the end of the reporting
period to defer settlement for at least 12 months after the reporting period. If the right to defer settlement of
a liability is subject to the entity complying with specified conditions (for example, debt covenants), the right
exists at the end of the reporting period based on its compliance with the conditions required on or before
the reporting date (even if tested only after period end). Conditions that an entity is required to comply only
within 12 months after the reporting period do not affect the classification of liability as current or non-current
at reporting date.
The assessment of whether an entity has the right to defer settlement of a liability at the reporting date is not
affected by expectations of the entity or events after the reporting date.
The amendments shall be applied retrospectively.
The amendments above are not expected to have a material impact to the Group and the Company.
110

31 DECEMBER 2022
3 SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES
The following accounting policies have been applied consistently in dealing with items that are considered material in
relation to the financial statements.
(a) Basis of consolidation
(i) Subsidiaries
Subsidiaries are all entities (including structured entities) over which the Group has control. The Group
controls an entity when the Group is exposed to, or has rights to, variable returns from its involvement with
the entity and has the ability to affect those returns through its power to direct the relevant activities of the
entity. Subsidiaries are fully consolidated from the date on which control is transferred to the Group. They are
deconsolidated from the date that control ceases.
The Group applies the acquisition method to account for business combinations when the acquired sets of
activities and assets meet the definition of a business. The Group determines that it has acquired a business
when the acquired set of activities and assets include an input and a substantive process that together
significantly contribute to the ability to create outputs. The consideration transferred for the acquisition of
a subsidiary is the fair values of the assets transferred, the liabilities incurred to the former owners of the
acquiree and the equity interests issued by the Group. The consideration transferred includes the fair value of
any asset or liability resulting from a contingent consideration arrangement and fair value of any pre-existing
equity interest in the subsidiary. Identifiable assets acquired and liabilities and contingent liabilities assumed
in a business combination are, with limited exceptions, measured initially at their fair values at the acquisition
date. The Group recognises any non-controlling interest in the acquiree on an acquisition-by-acquisition
basis, either at fair value or at the non-controlling interest’s proportionate share of the recognised amounts
of acquiree’s identifiable net assets.
The excess of the consideration transferred, the amount of any non-controlling interest in the acquiree
and the acquisition-date fair value of any previous equity interest in the acquiree over the fair value of
the identifiable net assets acquired is recognised as goodwill. If the total of consideration transferred, non-
controlling interest recognised and previously held interest measured is less than the fair value of the net
assets of the subsidiary acquired in the case of a bargain purchase, the difference is recognised directly in
profit or loss. See accounting policy Note 3(e)(i) on goodwill.
Acquisition-related costs are expensed as incurred.
If the business combination is achieved in stages, the carrying value of the acquirer’s previously held equity
interest in the acquiree is remeasured to fair value at the acquisition date, any gains or losses arising from
such re-measurement are recognised in profit or loss.
Any contingent consideration to be transferred by the Group is recognised at fair value at the acquisition
date. Subsequent changes to the fair value of the contingent consideration that is accounted for as an
asset or liability is recognised in accordance with MFRS 9 in profit or loss. Contingent consideration that is
classified as equity is not remeasured, and its subsequent settlement is accounted for within equity.
Inter-company transactions, balances and unrealised gains on transactions between Group companies are
eliminated. Unrealised losses are also eliminated unless the transaction provides evidence of an impairment
of the transferred asset. Accounting policies of subsidiaries have been changed where necessary to ensure
consistency with the policies adopted by the Group.
Non-controlling interests in the results and equity of subsidiaries are shown separately in the consolidated
statement of comprehensive income, statement of changes in equity and statement of financial position
respectively.
111
OUR FINANCIALS

31 DECEMBER 2022
3 SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES (CONTINUED)
(a) Basis of consolidation (continued)
(ii) Changes in ownership interests in subsidiaries without change of control
Transactions with non-controlling interests that do not result in loss of control are accounted for as transactions
with equity owners of the Group. A change in ownership interest results in an adjustment between the carrying
amounts of the controlling and non-controlling interests to reflect their relative interests in the subsidiary. Any
difference between the amount of the adjustment to non-controlling interests and any consideration paid or
received is recognised in equity attributable to owners of the Group.
(iii) Disposal of subsidiaries
When the Group ceases to consolidate because of a loss of control, any retained interest in the entity is
remeasured to its fair value with the change in carrying amount recognised in profit or loss. This fair value
becomes the initial carrying amount for the purposes of subsequently accounting for the retained interest
as an associate, joint venture or financial asset. In addition, any amounts previously recognised in other
comprehensive income in respect of that entity are accounted for as if the Group had directly disposed of
the related assets or liabilities. This may mean that amounts previously recognised in other comprehensive
income are reclassified to profit or loss. Gains or losses on the disposal of subsidiaries include the carrying
amount of goodwill relating to the subsidiaries sold.
(iv) Associates
Associates are all entities over which the Group has significant influence but not control or joint control,
generally accompanying a shareholding of between 20% and 50% of the voting rights. Investments
in associates are accounted for using the equity method of accounting. Under the equity method, the
investment in an associate is initially recognised at cost, and adjusted thereafter to recognise the Group’s
share of the post-acquisition profits or losses of the associate in profit or loss, and the Group’s share of
movements in other comprehensive income of the associate in other comprehensive income. Dividends
received or receivable from an associate are recognised as a reduction in the carrying amount of the
investment. When the Group’s share of losses in an associate equals or exceeds its interests in the associate,
including any long-term interests that, in substance, form part of the Group’s net investment in the associate,
the Group does not recognise further losses, unless it has incurred legal or constructive obligations or made
payments on behalf of the associate. The Group’s investment in associates includes goodwill identified on
acquisition.
The Group determines at each reporting date whether there is any objective evidence that the investment
in the associate is impaired. An impairment loss is recognised for the amount by which the carrying amount
of the associate exceeds its recoverable amount. The Group presents the impairment loss adjacent to ‘share
of profit/(loss) of an associate’ in the statement of comprehensive income.
Profits and losses resulting from upstream and downstream transactions between the Group and its associate
are recognised in the Group’s financial statements only to the extent of unrelated investor’s interests in the
associates. Unrealised losses are eliminated unless the transaction provides evidence of an impairment of
the asset transferred. Accounting policies of associates have been changed where necessary to ensure
consistency with the policies adopted by the Group.
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(a) Basis of consolidation (continued)
(iv) Associates (continued)
When the Group ceases to equity account its associate because of a loss of significant influence, any retained
interest in the entity is remeasured to its fair value with the change in carrying amount recognised in profit or
loss. This fair value becomes the initial carrying amount for the purposes of subsequently accounting for the
retained interest as a financial asset. In addition, any amount previously recognised in other comprehensive
income in respect of the entity is accounted for as if the Group had directly disposed of the related assets or
liabilities. This may mean that amounts previously recognised in other comprehensive income are reclassified
to profit or loss.
If the ownership interest in an associate is reduced but significant influence is retained, only a proportionate
share of the amounts previously recognised in other comprehensive income is reclassified to profit or loss
where appropriate.
Dilution gains or losses arising in investments in associates are recognised in profit or loss.
The cost of acquiring an additional stake in an associate is added to the carrying amount of associate
and equity accounted. Goodwill arising on the purchase of additional stake is computed using fair value
information at the date the additional interest is purchased. The previously held interest is not remeasured.
When the Group increases its stake in an existing investment and the investment becomes an associate
for the frst time, the cost of an associate acquired in stages is measured as the sum of the fair value of the
interest previously held plus the fair value of any additional consideration transferred as of the date when
the investment became an associate. Any gain or loss on re-measurement of the previously held stake is
recognised in profit or loss or other comprehensive income if election has been made under MFRS 9. Any
acquisition-related costs are expensed in the periods in which the costs are incurred. Goodwill is determined
on acquisition date, based on the difference between the cost of the investment (which comprise of both
fair value of consideration transferred for additional interest and fair value of interest previously held) and the
Group’s share of fair value of the associate’s net assets.
(b) Investments in subsidiaries and associates in separate financial statements
In the Company’s separate financial statements, investments in subsidiaries and associates are carried at cost
less accumulated impairment losses. The cost includes any contingent consideration to be transferred by the
Company and is recognised at fair value at the acquisition date. Subsequent changes to the fair value of the
contingent consideration that is deemed to be an asset or liability is recognised in accordance with MFRS 9 in
profit or loss. Contingent consideration that is classified as equity is not remeasured, and its subsequent settlement
is accounted for within equity.
Where an indication of impairment exists, the carrying amount of the investment is assessed and written down
immediately to its recoverable amount. See accounting policy Note 3(g) on impairment of non-financial assets.
On disposal of investments in subsidiaries and associates, the difference between disposal proceeds and the
carrying amounts of the investments are recognised in profit or loss.
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(c) Foreign currencies
(i) Functional and presentation currency
Items included in the financial statements of each of the Group’s entities are measured using the currency of
the primary economic environment in which the entity operates (the “functional currency”). These financial
statements are presented in Ringgit Malaysia (“RM”), which is the Company’s functional and presentation
currency.
(ii) Transactions and balances
Foreign currency transactions are translated into the functional currency using the exchange rates prevailing
at the dates of the transactions or valuation where items are remeasured. Foreign exchange gains and losses
resulting from the settlement of such transactions and from the translation at year-end exchange rates of
monetary assets and liabilities denominated in foreign currencies are recognised in profit or loss. However,
exchange differences are deferred in other comprehensive income when they arose from qualifying cash flow
or net investment hedges or are attributable to items that form part of the net investment in a foreign operation.
Foreign exchange gains and losses that relate to borrowings and cash and cash equivalents are presented
in profit or loss within administrative expenses. All other foreign exchange gains and losses are presented in
profit or loss on a net basis within other income/(expenses).
Changes in the fair value of monetary securities denominated in foreign currency classified as debt
instruments classified as at fair value through other comprehensive income (“FVOCI”) are analysed between
translation differences resulting from changes in the amortised cost of the security and other changes in the
carrying amount of the security. Translation differences related to changes in amortised cost are recognised
in profit or loss, and other changes in carrying amount are recognised in other comprehensive income.
Non-monetary items that are measured at fair value in a foreign currency are translated using the exchange
rates at the date when the fair value was determined. Translation differences on assets and liabilities carried
at fair value are reported as part of the fair value gain or loss. Translation differences on non-monetary
financial assets and liabilities such as equities held at fair value through profit or loss are recognised in
profit or loss as part of the fair value gain or loss. Translation differences on non-monetary financial assets,
such as equities classified as at fair value through other comprehensive income, are included in other
comprehensive income.
(iii) Group companies
The results and financial position of all the Group entities (none of which has the currency of a hyperinflationary
economy) that have a functional currency different from the presentation currency are translated into the
presentation currency as follows:
• assets and liabilities for each statement of financial position presented are translated at the closing
rate at the date of that statement of financial position;
• income and expenses for each statement of comprehensive income are translated at average
exchange rates (unless this average is not a reasonable approximation of the cumulative effect of the
rates prevailing on the transaction dates, in which case income and expenses are translated at the
rates on the dates of the transactions); and
• all resulting exchange differences are recognised as a separate component of other comprehensive
income.
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(c) Foreign currencies (continued)
(iii) Group companies (continued)
Goodwill and fair value adjustments arising on the acquisition of a foreign entity are treated as assets and
liabilities of the foreign entity and translated at the closing rate. Exchange differences arising are recognised
in other comprehensive income.
On consolidation, exchange differences arising from the translation of any net investment in foreign entities,
and of borrowings and other financial instruments designated as hedges of such investments, are recognised
On the disposal of a foreign operation (that is, a disposal of the Group’s entire interest in a foreign operation,
or a disposal involving loss of control over a subsidiary that includes a foreign operation, a disposal involving
loss of joint control over a joint venture that includes a foreign operation, or a disposal involving loss of
significant influence over an associate that includes a foreign operation), all of the exchange differences
relating to that foreign operation recognised in other comprehensive income and accumulated in the
separate component of equity are reclassified to profit or loss, as part of the gain or loss on disposal. In the
case of a partial disposal that does not result in the Group losing control over a subsidiary that includes a
foreign operation, the proportionate share of accumulated exchange differences are re-attributed to non-
controlling interests and are not recognised in profit or loss. For all other partial disposals (that is, reductions in
the Group’s ownership interest in associates or joint ventures that do not result in the Group losing significant
influence or joint control) the proportionate share of the accumulated exchange difference is reclassified to
profit or loss.
(d) Property, plant and equipment
Property, plant and equipment are stated at historical cost less accumulated depreciation and impairment losses.
The cost of an item of property, plant and equipment initially recognised includes its purchase price, import duties,
non-refundable purchase taxes and any cost that is directly attributable to bringing the asset to the location and
condition necessary for it to be capable of operating in the manner intended by management.
Subsequent costs are included in the asset’s carrying amount or recognised as a separate asset, as appropriate,
only when it is probable that future economic benefits associated with the item will flow to the Group and the
Company and the cost of the item can be measured reliably. The carrying amount of the replaced part is
derecognised. All other repairs and maintenance are recognised as expenses in profit or loss during the financial
period in which they are incurred.
Gains or losses on disposals are determined by comparing proceeds with carrying amount and are included in
other income/(expenses) in profit or loss.
Property, plant and equipment are depreciated on the straight-line method to write off the cost of property, plant
and equipment to their residual values over their estimated useful lives at the following annual rates:
Computers 20% - 33%

Office equipment 20% - 33%
Renovation 15% - 20%
Furniture and fittings 15% - 33%
Motor vehicles 20% - 25%
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(d) Property, plant and equipment (continued)
Work-in-progress will be reclassified to the respective categories of property, plant and equipment and depreciated
when the assets are ready for their intended use.
At each reporting date, the Group and the Company assess whether there is any indication of impairment. If
such indications exist, an analysis is performed to assess whether the carrying amount of the property, plant and
equipment is fully recoverable. A write down is made if the carrying amount exceeds the recoverable amount. See
accounting policy Note 3(g) on impairment of non-financial assets.
(e) Intangible assets
The Group acquires intangible assets either as part of a business combination or through separate acquisition.
Intangible assets acquired in a business combination are recorded at their fair values at the date of acquisition
and recognised separately from goodwill. On initial acquisition, management judgement is applied to determine
the appropriate allocation of purchase consideration to the assets being acquired, including goodwill and
identifiable intangible assets.
Intangible assets that are considered to have a finite life are amortised on a straight-line basis over the period of
expected benefit. Intangible assets that are considered to have an indefinite economic useful life are not amortised
but tested for impairment on an annual basis, or where an indication of impairment exists. See accounting policy
Note 3(g) on impairment of non-financial assets.
(i) Goodwill
Goodwill arises from a business combination and represents the excess of the aggregate of fair value of
consideration transferred, the amount of any non-controlling interest in the acquiree and the fair value of
any previous equity interest in the acquiree over the fair value of the net identifiable assets acquired and
liabilities assumed on the acquisition date. If the fair value of consideration transferred, the amount of non-
controlling interest and the fair value of previously held interest in the acquiree are less than the fair value of
the net identifiable assets of the acquiree, the resulting gain is recognised in profit or loss.
Goodwill is not amortised but it is tested for impairment annually or more frequently if events or changes in
circumstances indicate that it might be impaired, and carried at cost less accumulated impairment losses.
For the purpose of impairment testing, goodwill acquired in a business combination is allocated to each of
the cash generating units (“CGUs”), or groups of CGUs, that is expected to benefit from the synergies of the
combination. Each unit or group of units to which the goodwill is allocated represents the lowest level within
the entity at which the goodwill is monitored for internal management purposes. Goodwill is monitored at the
operating segment level. The carrying value of goodwill is compared to the recoverable amount, which is the
higher of value in use and the fair value less costs of disposal. Any impairment is recognised immediately as
an expense and is not subsequently reversed.
(ii) Database and customer relationships
Separately acquired database are shown at historical cost. Database and customer relationships acquired
in a business combination are recognised at fair value at the acquisition date. The acquired database
and customer relationships have a finite useful life and are carried at cost less accumulated amortisation.
Amortisation is calculated using the straight-line method over the expected life of the database and
customer relationships, not exceeding 5 years.
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(e) Intangible assets (continued)
(iii) Brand names and trademarks
Separately acquired brand names and trademarks are shown at historical cost. Brand names and trademarks
acquired in a business combination are recognised at fair value at the acquisition date. Brand names and
trademarks have a finite useful life and are carried at cost less accumulated amortisation. Amortisation is
calculated using the straight-line method to allocate the cost of brand names and trademarks over their
estimated useful lives of 20 years.
(iv) Licenses fee
Separately acquired licenses are shown at historical cost. Licenses have a finite useful life and are carried at
cost less accumulated amortisation. Amortisation is calculated using the straight-line method to allocate the
cost of licenses over their estimated useful lives of 3 years.
(v) Computer software
Costs associated with maintaining computer software programmes are recognised as an expense as
incurred. Development costs that are directly attributable to the design and testing of identifiable and
unique software products controlled by the Group are recognised as intangible assets when the following
criteria are met:
• it is technically feasible to complete the software product so that it will be available for use;
• management intends to complete the software product and use or sell it;
• there is an ability to use or sell the software product;
• it can be demonstrated how the software product will generate probable future economic benefits;
• adequate technical, financial and other resources to complete the development and to use or sell the
software product are available; and
• the expenditure attributable to the software product during its development can be reliably measured.
Directly attributable costs that are capitalised as part of the software product include the software
development employee costs and an appropriate portion of relevant overheads.
Other development expenditures that do not meet these criteria are recognised as an expense as incurred.
Development costs previously recognised as an expense are not recognised as an asset in a subsequent
period.
Computer software development costs recognised as assets are amortised using the straight-line method
from the point at which the asset is ready for use over their estimated useful lives, which does not exceed 5
years.
Some computer software is part of a system that cannot operate without being integrated with the related
hardware. The Group treats this computer software as property, plant and equipment as it is an integral
part of the property, plant and equipment. The Group uses judgement to assess which element is more
significant. When the software is not an integral part of the related hardware, computer software is treated as
an intangible asset.
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(f) Financial instruments
A financial instrument is any contract that gives rise to both a financial asset of one enterprise and a financial
liability or equity instrument of another enterprise.
A financial asset is any asset that is cash, a contractual right to receive cash or another financial asset from
another enterprise, a contractual right to exchange financial instruments with another enterprise under conditions
that are potentially favourable, or an equity instrument of another enterprise.
A financial liability is any liability that is a contractual obligation to deliver cash or another financial asset to
another enterprise, or to exchange financial instruments with another enterprise under conditions that are
potentially unfavourable.
Financial assets
(i) Classification
The Group and the Company classify their financial assets to be measured at amortised cost.
The classification depends on the entity’s business model for managing the financial assets and the
contractual terms of the cash flows.
The Group and the Company reclassify debt investments when and only when its business model for
managing those assets changes.
(ii) Recognition and derecognition
Regular way purchases and sales of financial assets are recognised on trade-date, the date on which the
Group and the Company commit to purchase or sell the asset. Financial assets are derecognised when the
rights to receive cash flows from the financial assets have expired or have been transferred and the Group
and the Company have transferred substantially all the risks and rewards of ownership.
(iii) Measurement
At initial recognition, the Group and the Company measure a financial asset at its fair value plus, in the
case of a financial asset not at fair value through profit or loss (“FVTPL”), transaction costs that are directly
attributable to the acquisition of the financial asset. Transaction costs of financial assets carried at FVTPL are
expensed in profit or loss.
Financial assets with embedded derivatives are considered in their entirety when determining whether their
cash flows are solely payment of principal and interest (“SPPI”).
Debt instruments
Subsequent measurement of debt instruments depends on the Group’s and the Company’s business model
for managing the asset and the cash flow characteristics of the asset. Assets that are held for collection
of contractual cash flows where those cash flows represent SPPI are measured at amortised cost. Interest
income from these financial assets is included in other income/(expenses) using the effective interest rate
method. Any gain or loss arising on derecognition is recognised directly in profit or loss and presented in
other income/(expenses) together with foreign exchange gains and losses. Impairment losses are presented
within administrative expenses in the statement of comprehensive income.
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(f) Financial instruments (continued)
Financial assets (continued)
(iv) Subsequent measurement - impairment
The Group and the Company assess on a forward looking basis the expected credit loss (“ECL”) associated
with its debt instruments carried at amortised cost. The impairment methodology applied depends on
whether there has been a significant increase in credit risk.
The Group and the Company have few types of financial instruments that are subject to the ECL model:
• trade receivables;
• other receivables;
• deposits;
• amount due from subsidiaries; and
• amount due from related parties.
While cash and cash equivalents are also subject to the impairment requirements of MFRS 9, the identified
impairment loss was immaterial.
ECL represents a probability-weighted estimate of the difference between present value of cash flows
according to contract and present value of cash flows the Group and the Company expect to receive, over
the remaining life of the financial instrument.
The measurement of ECL reflects:
• an unbiased and probability-weighted amount that is determined by evaluating a range of possible

outcomes;
• the time value of money; and
• reasonable and supportable information that is available without undue cost or effort at the reporting
date about past events, current conditions and forecasts of future economic conditions.
(a) General 3-stage approach for other receivables, deposits, amount due from subsidiaries and amount
due from related parties
At each reporting date, the Group and the Company measure ECL through loss allowance at an
amount equal to 12 month ECL if credit risk on a financial instrument or a group of financial instruments
has not increased significantly since initial recognition. For all other financial instruments, a loss
allowance at an amount equal to lifetime ECL is required.
(b) Simplified approach for trade receivables
The Group and the Company apply the MFRS 9 simplified approach to measure ECL which uses a
lifetime ECL for all trade receivables.
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(iv) Subsequent measurement - impairment (continued)
Significant increase in credit risk
The Group and the Company consider the probability of default upon initial recognition of asset and
whether there has been a significant increase in credit risk on an ongoing basis throughout each reporting
period. To assess whether there is a significant increase in credit risk, the Group and the Company compare
the risk of a default occurring on the asset as at the reporting date with the risk of default as at the date of
initial recognition. It considers available reasonable and supportable forward-looking information.
The following indicators are incorporated:
• actual or expected significant adverse changes in business, financial or economic conditions that are
expected to cause a significant change to the debtor’s ability to meet its obligations;
• actual or expected significant changes in the operating results of the debtor; and
• significant changes in the expected performance and behaviour of the debtor, including changes in
the payment status of debtor in the group and changes in the operating results of the debtor.
Regardless of the analysis above, a significant increase in credit risk is presumed if a debtor is more than 30
days past due in making a contractual payment.
Definition of default and credit-impaired financial assets
The Group and the Company define a financial instrument as default, which is fully aligned with the definition
of credit-impaired, when it meets one or more of the following criteria:
Quantitative criteria:
The Group and the Company define a financial instrument as default, when the counterparty fails to make
contractual payment within 90 days of when they fall due.
Qualitative criteria:
The debtor meets unlikeliness to pay criteria, which indicates the debtor is in significant financial difficulty. The
Group and the Company consider the following instances:
• the debtor is in breach of financial covenants;

• it is becoming probable that the debtor will enter bankruptcy or other financial reorganisation; or
• the debtor is insolvent.
Financial instruments that are credit-impaired are assessed on individual basis.
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(iv) Subsequent measurement - impairment (continued)
Write-off
• Trade receivables
Trade receivables is written off when there is no reasonable expectation of recovery. Indicators that
there is no reasonable expectation of recovery include, amongst others, the failure of a debtor to
engage in a repayment plan with the Group and the Company, and a failure to make contractual
payments for a period of greater than 365 days past due.
Impairment losses on trade receivables is presented within administrative expenses in the statement of
comprehensive income. Subsequent recoveries of amounts previously written off are credited against
the same line item.
• Other receivables, amount due from subsidiaries and amount due from related parties
The Group and the Company write off financial assets, in whole or in part, when they have exhausted
all practical recovery efforts and have concluded there is no reasonable expectation of recovery. The
assessment of no reasonable expectation of recovery is based on unavailability of debtor’s sources
of income or assets to generate sufficient future cash flows to repay the amount. The Group and the
Company may write-off financial assets that are still subject to enforcement activity.These are presented
within administrative expenses in the statement of comprehensive income. Subsequent recoveries of
amounts previously written off will result in impairment gains.
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Financial liabilities
(i) Classification and measurement
The Group and the Company classify their financial liabilities in the following categories: at fair value through
profit or loss, other financial liabilities and financial guarantee contracts. Management determines the
classification of financial liabilities at initial recognition.
The Group’s and the Company’s financial liabilities at fair value through profit or loss comprise deferred
contingent consideration arising from business combination. The fair value of the contingent consideration
is calculated as the present value of estimated future cash flow using a discount rate that is adjusted for
projection and credit risk. Fair value gain and loss is presented in profit or loss within other income.
Other financial liabilities are non-derivative financial liabilities. Other financial liabilities are initially recognised
at fair value plus transaction costs and subsequently carried at amortised cost using the effective interest
method. Changes in the carrying value of these liabilities are recognised in profit or loss.
The Group’s and the Company’s other financial liabilities comprise payables (including amount due to
related parties) and borrowings in the statement of financial position. Financial liabilities are classified as
current liabilities, except for maturities greater than 12 months after the reporting date, in which case they
are classified as non-current liabilities.
The Group and the Company do not hold any financial guarantee contracts.
(ii) Recognition of financial liabilities
Financial liabilities are recognised when the Group and the Company become a party to the contractual
provisions of the instrument.
(iii) Derecognition of financial liabilities
Financial liabilities are derecognised when the liability is either discharged, cancelled, has expired or has
been restructured with substantially different terms.
(iv) Offsetting of financial assets and financial liabilities
Financial assets and financial liabilities are offset and the net amount reported in the statement of financial
position when there is a legally enforceable right to offset the recognised amounts and there is an intention
to settle on a net basis, or realise the asset and settle the liability simultaneously. The legally enforceable right
must not be contingent on future events and must be enforceable in the normal course of business and in
the event of default, insolvency or bankruptcy.
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(g) Impairment of non-financial assets
Assets that have an indefinite useful life, for example goodwill or intangible assets not ready to use, are not
subject to amortisation and are tested annually for impairment. The Group also assesses goodwill, intangible
assets with indefinite useful life and other assets that are subject to amortisation for impairment whenever events
or changes in circumstances indicate that the carrying amount may not be recoverable. An impairment loss
is recognised for the amount by which the carrying amount of the asset exceeds its recoverable amount. The
recoverable amount is the higher of an asset’s fair value less costs of disposal and value in use. For the purposes
of assessing impairment, assets are grouped at the lowest levels for which there are separately identifiable cash
flows which are largely independent of the cash inflows from other assets or groups of assets (cash-generating
units). Non-financial assets other than goodwill that suffered an impairment are reviewed for possible reversal of
the impairment at each reporting date.
The impairment loss is charged to profit or loss unless it reverses a previous revaluation in which case it is charged to
the revaluation surplus. Impairment losses on goodwill are not reversed. In respect of other assets, any subsequent
increase in recoverable amount is recognised in profit or loss unless it reverses an impairment loss on a revalued
asset in which case it is taken to revaluation surplus reserve.
(h) Fair value estimation
The fair value of the financial assets, financial liabilities and derivative financial instruments are estimated for
recognition and measurement or for disclosure purposes.
In assessing the fair value of financial instruments, the Group and the Company make certain assumptions and
applies the estimated discounted value of future cash flows to determine the fair value of financial instruments.
The fair values of financial assets and financial liabilities are estimated by discounting future cash flows at the
current interest rate available to the respective companies for similar financial instruments.
The face values for financial assets and financial liabilities with a maturity of less than one year are assumed to be
approximately equal to their fair values.
(i) Trade and other receivables
Trade receivables are amounts due from customers for goods sold or services performed in the ordinary course of
business. Other receivables generally arise from transactions outside the usual operating activities of the Group.
If collection is expected in one year or less (or in the normal operating cycle of the business if longer), they are
classified as current assets. If not, they are presented as non-current assets.
Trade receivables are recognised initially at the amount of consideration that is unconditional unless they contain
significant financing components, where they are recognised at fair value plus transaction costs. Other receivables
are recognised initially at fair value plus transaction costs.
After recognition, trade and other receivables are subsequently measured at amortised cost using the effective
interest method, less loss allowance. See accounting policy Note 3(f)(iv) on impairment of financial assets.
(j) Cash and cash equivalents
For the purpose of the statement of cash flows, cash equivalents are held for the purpose of meeting short-term
cash commitments rather than for investment or other purposes. Cash and cash equivalents comprise cash
on hand, deposits held at call with financial institutions, other short term, highly liquid investments with original
maturities of 3 months or less that are readily convertible to known amounts of cash and which are subject to an
insignificant risk of changes in value.
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(k) Payables
Payables, including accruals, represent liabilities for goods received and services rendered to the Group and
the Company prior to the end of the financial year and which remain unpaid. Payables are classified as current
liabilities if payment is due within one year or less. If not, they are presented as non-current liabilities.
Payables are recognised initially at fair value and subsequently measured at amortised cost using the effective
interest method.
(l) Current and deferred income tax
Tax expenses for the period comprise current and deferred tax. The income tax expense or credit for the period
is the tax payable on the current period’s taxable income based on the applicable income tax rate for each
jurisdiction adjusted by changes in deferred tax assets and liabilities attributable to temporary differences and to
unused tax losses. Tax is recognised in the profit or loss except to the extent that it relates to items recognised in
other comprehensive income or directly in equity. In this case, the tax is also recognised in other comprehensive
income or directly in equity, respectively.
The current income tax charge is calculated on the basis of the tax laws enacted or substantively enacted at the
end of the reporting period in the countries where the Group and its associates operate and generate taxable
income.
Management periodically evaluates positions taken in tax returns with respect to situations in which applicable
tax regulation is subject to interpretation. It establishes provisions where appropriate on the basis of amounts
expected to be paid to the tax authorities. This liability is measured using the single best estimate of the most likely
outcome.
Deferred tax is recognised in full, using the liability method, on temporary differences arising between the amounts
attributed to assets and liabilities for tax purposes and their carrying amounts in the financial statements. However,
deferred tax is not accounted for if it arises from initial recognition of an asset or liability in a transaction other than
a business combination that at the time of the transaction affects neither accounting nor taxable profit or loss.
Deferred tax assets and liabilities are measured at the tax rates that are expected to apply in the period when the
asset is realised or the liability is settled taking into consideration of the expiry date of tax incentive, based on the
tax rates and tax laws substantially enacted at the balance sheet date.
Deferred tax assets are recognised to the extent that it is probable that future taxable profit will be available against
which the deductible temporary differences, investment tax allowance or unused tax losses can be utilised.
Deferred tax assets are recognised on deductible temporary differences arising from investments in subsidiaries,
associates and joint arrangements only to the extent that it is probable the temporary difference will reverse in the
future and there is sufficient taxable profit available against which the deductible temporary difference can be
utilised.
Deferred tax liability is recognised for all taxable temporary differences arising on investments in subsidiaries
except where the timing of the reversal of the temporary differences is controlled by the Group and it is probable
that the temporary difference will not reverse in the foreseeable future.
Deferred and current tax assets and liabilities are offset when there is a legally enforceable right to offset current
tax assets against current tax liabilities and when the deferred tax assets and liabilities relate to taxes levied by the
same taxation authority or either the taxable entity or different taxable entities where there is an intention to settle
the balances on a net basis.
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(m) Provision for restoration costs
Provisions are recognised when the Group and the Company have a present legal or constructive obligation as
a result of past events, when it is probable that an outflow of resources will be required to settle the obligation and
when a reliable estimate of the amount can be made.
Provisions are measured at the present value of management’s best estimate of the expenditures expected to
be required to settle the obligation by discounting the expected future cash flows at a pre-tax rate that reflects
current market assessments of the time value of money and the risks specific to the obligation. The increase in the
provision due to passage of time is recognised as finance costs.
Provision for restoration costs is the estimated costs of dismantling and removing the fixtures and effects to restore
the rental premises back to its original state and condition.
(n) Employee benefits
(i) Short term employee benefits
Wages, salaries, paid annual leave and sick leave, bonuses and non-monetary benefits that are expected
to be settled wholly within 12 months after the end of the period in which the employees render the related
service are recognised in respect of employees’ services up to the end of the reporting period and are
measured at the amounts expected to be paid when the liabilities are settled. The liabilities are presented
as payables and accruals in the statement of financial position. The Group and the Company recognise
provision where contractually obliged or where there is a past practice that has created a constructive
obligation.
(ii) Post-employment pension benefits
The Group and the Company have various post-employment pension benefit schemes in accordance with
local conditions and practices in the countries in which the Group and the Company operate. These benefits
plans are either defined contribution or defined benefit plans.
A defined contribution plan is a pension plan under which the Group and the Company pay fixed
contributions into a separate entity (a fund) on a mandatory, contractual or voluntary basis and the Group
and the Company have no legal or constructive obligations to pay further contributions if the fund does
not hold sufficient assets to pay all employees benefits relating to employee service in the current and prior
periods.
Defined benefit plan is a pension plan that is not a defined contribution plan. Defined benefit plans define
an amount of pension benefit that an employee will receive on retirement, usually dependent on one or
more factors such as age, years of service and compensation.
Defined contribution plans
The Group's and the Company’s contributions to defined contribution plans are recognised in profit or loss in
the period to which they relate. Once the contributions have been paid, the Group and the Company have
no further payment obligations.
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31 DECEMBER 2022
(n) Employee benefits (continued)
(ii) Post-employment pension benefits (continued)
Defined benefit plans
The liability or asset recognised in the statement of financial position in respect of defined benefit pension
plans is the present value of the defined benefit obligation at the end of the reporting period less the
fair value of plan assets. The defined benefit obligation is calculated annually by independent actuaries
using the projected unit credit method. The present value of the defined benefit obligation is determined
by discounting the estimated future cash outflows using interest rates of high-quality corporate bonds
that are denominated in the currency in which the benefits will be paid, and that have terms to maturity
approximating to the terms of the related obligation. In countries where there is no deep market in such
bonds, the market rates on government bonds are used.
The current service cost of the defined benefit plan reflects the increase in the defined benefit obligation
resulting from employee service in the current year. It is recognised in profit or loss in employee benefit
expense, except where included in the cost of an asset.
Actuarial gains and losses arising from experience adjustments and changes in actuarial assumptions are
recognised directly in other comprehensive income in the period in which they arise.
The net interest cost is calculated by applying the discount rate to the net balance of the defined benefit
obligation and the fair value of plan assets. This cost is included in employee benefit expense in the
statements of comprehensive income.
Changes in the present value of the defined benefit obligation resulting from plan amendments or
curtailments are recognised immediately in profit or loss as past service costs.
(iii) Share-based payments
The Group and the Company operate an equity-settled, share-based compensation plan under which
the Company and its subsidiaries receive services from employees as consideration for equity instruments
(options) of the Company, pursuant to the Employee Share Option Scheme (“ESOS”). The fair value of the
options granted in exchange for the services of the employees are recognised as employee benefit expense
over the vesting period with a corresponding increase to share option reserves within equity. The total amount
to be expensed is determined by reference to the fair value of the options granted:
• including any market performance conditions (for example, an entity’s share price);
• excluding the impact of any service and non-market performance vesting conditions (for example,
profitability, sales growth targets and remaining an employee of the entity over a specified time period);
and
• including the impact of any non-vesting conditions (for example, the requirement for employees to
save or holding of shares for a specific period of time).
Non-market vesting conditions and service conditions are included in assumptions about the number of
options that are expected to vest.
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31 DECEMBER 2022
(n) Employee benefits (continued)
(iii) Share-based payments (continued)
The total expense is recognised over the vesting period, which is the period over which all of the specified
vesting conditions are to be satisfied. At the end of the reporting period, the Group revises its estimates
of the number of options that are expected to vest based on the non-market vesting conditions and
service conditions. It recognises the impact of the revision to original estimates, if any, in profit or loss, with a
corresponding adjustment to share option reserve in equity.
In circumstances where employees provide services in advance of the grant date, the grant date fair value is
estimated for the purposes of recognising the expense during the period between service commencement
period and grant date.
When the options are exercised, the Company issues new shares. The proceeds received net of any directly
attributable transaction costs are credited to equity when the options are exercised. When options are not
exercised and lapsed, the share option reserve is transferred to retained earnings.
In its separate financial statements of the Company, the grant by the Company of options over its equity
instruments to the employees of subsidiary in the Company are treated as a capital contribution to the
subsidiary. The fair value of options granted to employees of the subsidiary in exchange for the services of
the employees to the subsidiary are recognised as investment in subsidiary, with a corresponding credit to
equity of the Company.
If an equity-settled award is cancelled, it is treated as if it had vested on the date of cancellation, and any
expense not yet recognised for the award is recognised immediately. However, if a new award is substituted for
the cancelled award, and designated as a replacement award on the date that it is granted, the cancelled
and new award are treated as if they were a modification of the original award.
If an equity award is cancelled by forfeiture, when the vesting conditions (other than market conditions)
have not been met, any expense not yet recognised for that award, as at the date of forfeiture, is treated as
if it had never been recognised. At the same time, any expense previously recognised on such cancelled
equity awards are reversed from the accounts effective as at the date of forfeiture.
Any payment made to employees on the cancellation or settlement of the grant is accounted for as the
repurchase of an equity interest, i.e. as a deduction from equity, except to the extent that the payment
exceeds the fair value of the equity instruments granted, measured at the repurchase date. Any such
excess is recognised as an expense. However, if the share-based payment arrangement included liability
components, the Group remeasures the fair value of the liability at the date of cancellation or settlement.
Any payment made to settle the liability component is accounted for as an extinguishment of the liability.
The dilutive effect, if any, of outstanding options is reflected as additional share dilution in the computation
of earnings per share.
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31 DECEMBER 2022
(o) Leases
Accounting by lessee
Leases are recognised as right-of-use (“ROU”) asset and a corresponding liability at the date on which the leased
asset is available for use by the Group and the Company (i.e. the commencement date).
Contracts may contain both lease and non-lease components. The Group and the Company allocate the
consideration in the contract to the lease and non-lease components based on their relative stand-alone prices.
(i) Lease term
In determining the lease term, the Group and the Company consider all facts and circumstances that create
an economic incentive to exercise an extension option, or not to exercise a termination option. Extension
options (periods after termination options) are only included in the term if the lease is reasonably certain to
be extended (or not to be terminated).
The Group and the Company reassess the lease term upon the occurrence of a significant event or change
in circumstances that is within the control of the Group and the Company and affects whether the Group
and the Company are reasonably certain to exercise an option not previously included in the determination
of lease term, or not to exercise an option previously included in the determination of lease term. A revision
in lease term results in remeasurement of the lease liabilities. See accounting policy below on reassessment
of lease liabilities (refer to (iv) below).
(ii) ROU assets
ROU assets are initially measured at cost comprising the following:
• the amount of the initial measurement of lease liability;

• any lease payments made at or before the commencement date less any lease incentive received;
• any initial direct costs; and
• decommissioning or restoration costs.
ROU assets are subsequently measured at cost, less any accumulated depreciation and impairment loss, if
any. The ROU assets are generally depreciated over the shorter of the asset’s useful life and the lease term
on a straight-line basis. If the Group and the Company are reasonably certain to exercise a purchase option,
the ROU asset is depreciated over the underlying asset’s useful life. In addition, the ROU assets are adjusted
for certain remeasurement of the lease liabilities.
ROU assets are presented as a separate line item in the statement of financial position.
(iii) Lease liabilities
Lease liabilities are initially measured at the present value of the lease payments that are not paid at that
date. The lease payments include the following:
• fixed payments (including in-substance fixed payments), less any lease incentive receivable;
• variable lease payments that are based on an index or a rate, initially measured using the index or rate
as at the commencement date;
• amounts expected to be payable by the Group and the Company under residual value guarantees;
• the exercise price of a purchase and extension options if the Group and the Company are reasonably
certain to exercise that option; and
• payments of penalties for terminating the lease, if the lease term reflects the Group and the Company
exercising that option.
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31 DECEMBER 2022
(o) Leases (continued)
Accounting by lessee (continued)
(iii) Lease liabilities (continued)
Lease payments are discounted using the interest rate implicit in the lease. If that rate cannot be readily
determined, which is generally the case for the leases in the Group and the Company, the lessee’s incremental
borrowing is used. This is the rate that the individual lessee would have to pay to borrow the funds necessary
to obtain an asset of similar value to the ROU in a similar economic environment with similar term, security
and conditions.
Lease payments are allocated between principal and finance cost. The finance cost is charged to profit or
loss over the lease period so as to produce a constant periodic rate of interest on the remaining balance of
the liability for each period.
The Group and the Company present the lease liabilities as a separate line item in the statement of financial
position. Interest expense on the lease liability is presented within the finance costs in the statement of
comprehensive income.
(iv) Reassessment of lease liabilities
After the commencement date, a lessee shall remeasure the lease liability to reflect changes to the lease
payments by using a revised discount rate if either:
• a change in lease term due to the lessee exercises an option (purchase/termination/extension) in a

different way than the Group and the Company have previously determined was reasonably certain;
or
• a change in lease term due to an event occurs that contractually obliged/prohibits the lessee from
exercise the option.
In contrast, a lessee shall use an unchanged discount rate to remeasure lease liability to reflect changes to
lease payments if either:
• a change in the amounts expected to be payable under a residual value guarantee; or

• a change in future lease payments resulting from a change in an index or rate used to determine those
payments.
A lessee shall recognise the amount of the remeasurement of the lease liability as an adjustment to the
ROU. However, if the carrying amount of the ROU is reduced to zero and there is a further reduction in the
measurement of the lease liability, a lessee shall recognise any remaining amount of the remeasurement in
profit or loss.
(v) Short-term leases and leases of low value assets
Short-term leases are leases with a lease term of 12 months or less. Low-value assets comprise IT equipment
and small items of office equipment. Payments associated with short-term leases of equipment and vehicles
and all leases of low-value assets are recognised on a straight-line basis as an expense in profit or loss.
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31 DECEMBER 2022
(p) Revenue recognition
Revenue from contracts with customers
(i) Provision of services
The Group’s revenue arises from a range of products including subscriptions fees for access to the Group’s
online credit risk management platform, sale of reports, trade referencing and monitoring services, CTOS
electronic Know-Your-Customer (“eKYC”) services, CTOS Application and Decisioning (“CAD”) services, fraud
bureau services and portfolio reviews.
The Group recognises revenue when it satisfies a performance obligation by transferring control of a promised
product or service to a customer. The Group determines whether goods or services are distinct, and therefore
separate performance obligations, when there are multiple promises in a contract.
At the inception of the contract, the Group determines the consideration or transaction price that it expects
to be entitled in exchange for transferring promised goods or services to the customer, which may include
fixed consideration and variable consideration. Variable consideration is included in the transaction price
only to the extent that it is highly probable that a significant reversal in the amount of cumulative revenue
recognised will not occur when the uncertainty associated with the variable consideration is subsequently
resolved. The total consideration is allocated to the performance obligations identified based on their
standalone selling price, and is recognised when those performance obligations are satisfied and the
control of goods or services is transferred to the customer, either over time or at a point in time.
Credit reporting services
Revenue from subscription of the Group’s online credit risk management platform is from fixed subscription
fees. The Group recognises revenue from the fixed subscription fees on a straight-line basis over the
subscription period. The subscription can be renewed monthly or annually.
Revenue from sales of reports (CTOS digital reports and external reports) is recognised when control of the
reports are transferred to the customers.
Revenue from trade referencing and monitoring services is from fixed monthly subscription fees, which are
recognised over the period in which the services are performed.
Revenue from fraud bureau services is from fixed subscription fees, which are recognised at the point in time
when the results are transferred to the customers.
Revenue from comprehensive portfolio reviews and analytics is recognised when control of the review results
or deliverables are transferred to the customers.
The eKYC services that are provided in a bundled contract comprise multiple promises which may include
the sale of software licenses, setup and installation services at the customer’s premises, document verification,
facial recognition, bureau file verification, knowledge-based authentication services (collectively “verification
services”) and maintenance and technical services. The Group accounts for each service in the bundled
contract as separate performance obligations as the services are not inputs to a combined item that the
customer has contracted to receive. The Group can fulfil its promise to transfer each of the goods or services
separately and does not provide any significant integration, modification, or customisation services.
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31 DECEMBER 2022
(p) Revenue recognition (continued)
Revenue from contracts with customers (continued)
(i) Provision of services (continued)
Credit reporting services (continued)
For each of the verification services, revenue is recognised at the point in time when the verification services
are completed and the results are shared with the customer. Bundled contracts usually comprise fixed and
variable considerations. The transaction fees for the verification services are variable depending on the
volume of transactions. Accumulated experience is used to estimate the volume of the verification services
using the expected value method. The transaction price is allocated to each performance obligation based
on the stand-alone selling prices. Where these are not directly observable, they are estimated based on the
expected cost-plus margin.
For eKYC contracts which only comprise sales of verification services, revenue is recognised when the
verification services are completed and the results are shared with the customers.
For CAD contracts that consist of multiple promises such as credit decisioning results and access to the
Group’s hosted loan management systems, the Group determines that each promise is distinct and
are therefore separate performance obligations. These contracts usually comprise fixed and variable
considerations. The transaction fees for the credit decisioning results are variable depending on the volume
of transactions. Accumulated experience is used to estimate the volume of the verification services using
the expected value method. The transaction price is allocated to each performance obligation based on
the stand-alone selling prices. Where these are not directly observable, they are estimated based on the
expected cost-plus margin. The Group recognises revenue from access to the hosted loan management
systems over the service period, while revenue from credit decisioning results is recognised at the point in
time when the results are shared with the customers.
For CAD contracts which only comprise credit decisioning results, revenue is recognised when the credit
decisioning results are completed and shared with the customers.
Sale of software licenses
The Group recognises revenue from the sale of software license at the point in time when control of the
software license has been transferred to the customer.
When another party is involved in providing the software licenses to the customer, the Group is a principal
as it controls the software licenses before they are transferred to the customers. As the principal, the Group
recognises as revenue on the gross consideration allocated to the software licenses with the corresponding
direct costs of satisfying the contract.
Installation and maintenance services
The Group recognises revenue from installation services over time as and when the installation progresses.
Revenue in respect of maintenance and technical services are recognised over the period the maintenance
and technical services are performed.
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31 DECEMBER 2022
(p) Revenue recognition (continued)
Revenue from contracts with customers (continued)
(ii) Contract liabilities
Contract liability is the unsatisfied obligation by the Group to transfer goods or services to customer for which
the Group has received the consideration in advance or has billed the customer.
Revenue from other sources
(i) Interest income
Interest income is recognised on a time proportion basis, taking into account the principal outstanding and
the effective interest rate over the period to maturity, when it is determined that such income will accrue to
the Group and the Company.
(ii) Dividend income
Dividend income is recognised when the Company’s right to receive payment is established.
(q) Incremental costs incurred to obtain or fulfil a contract
The Group has elected the practical expedient by recognising the costs incurred to obtain a contract as an
expense where the costs incurred to obtain a contract are in respect of contracts with amortisation period of less
than one year.
(r) Share capital
(i) Classification
Ordinary shares are classified as equity. Other shares are classified as equity and/or liability according to the
substance of the contractual arrangement of the particular instrument.
(ii) Share issue costs
Incremental costs directly attributable to the issue of new shares or options are deducted against equity.
(iii) Dividends to shareholders of the Group
Liability is recognised for the amount of any dividend declared, being appropriately authorised and no
longer at the discretion of the Group, on or before the end of the reporting period but not distributed at the
end of the reporting period.
Distributions to holders of an equity instrument is recognised directly in equity.
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31 DECEMBER 2022
(s) Borrowings
Borrowings are initially recognised at fair value, net of transaction costs incurred. Borrowings are subsequently
carried at amortised cost. Any difference between initial recognised amount and the redemption amount is
recognised in profit or loss over the period of the borrowings using the effective interest method.
Borrowing costs that are directly attributable to the acquisition, construction or production of qualifying assets are
capitalised as part of the cost of the assets. Other borrowing costs are recognised in profit or loss in the period in
which they are incurred.
Fees paid on the establishment of loan facilities are recognised as transaction costs of the loan to the extent that
it is probable that some or all of the facility will be drawn down. In this case, the fee is deferred until the drawdown
occurs. To the extent there is no evidence that it is probable that some or all of the facility will be drawn down, the
fee is capitalised as a prepayment for liquidity services and amortised over the period of the facility to which it
relates.
Borrowings are removed from the statement of financial position when the obligation specified in the contract
is discharged, cancelled or expired. The difference between the carrying amount of a financial liability that has
been extinguished or transferred to another party and the consideration paid, including any non-cash assets
transferred or liabilities assumed, is recognised in profit or loss within finance costs.
Interest expense, losses and gains relating to a financial instrument, or a component part, classified as a liability
is reported within finance costs in the statement of comprehensive income.
Borrowings are classified as current liabilities unless the Group and the Company have an unconditional right to
defer settlement of the liability for at least 12 months after the end of the reporting period.
(t) Earnings per share
(i) Basic earnings per share
Basic earnings per share is calculated by dividing:
• the profit attributable to owners of the Group, excluding any costs of servicing equity other than ordinary
shares, and
• by the weighted average number of ordinary shares outstanding during the financial year, adjusted for
bonus elements in ordinary shares issued during the year and excluding treasury shares.
(ii) Diluted earnings per share
Diluted earnings per share adjusts the figures in the determination of basic earnings per share to take into
account:
• the after income tax effect of interest and other financing costs associated with dilutive potential
ordinary shares, and
• the weighted average number of additional ordinary shares that would have been outstanding
assuming the conversion of all dilutive potential ordinary shares.
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(u) Segment reporting
Operating segments are reported in a manner consistent with the internal reporting provided to the chief operating
decision-makers. The chief operating decision-makers, who are responsible for allocating resources and assessing
performance of the operating segments, have been identified as the Group Chief Executive Officer, Group Chief
Financial Officer, Chief Executive Officer and Chief Operating Officer of the respective subsidiaries.
(v) Administrative expenses
The nature of expenses classified within administrative expenses are those which are not directly attributable to
revenue generating activities of the Group but are part of the Group’s overall operating activities. The expenses
classified within administrative expenses includes staff cost other than staff cost for sales and marketing employees,
depreciation expenses of property, plant and equipment and ROU assets, IT support expenses, professional fees
and foreign exchange gain or loss amongst others.
(w) Distribution of non-cash assets to owners
The distribution of a non-cash asset that is ultimately controlled by the same party or parties (that is, common
control) before and after the distribution is based on the book value of the non-cash asset that is being distributed.
At the Group level, the distribution has been reflected as a distribution of the net assets at their carrying amounts
to the equity owners of the Company with a corresponding charge to retained earnings.
(x) Discontinued operations
A discontinued operation is a component of the entity that has been disposed of or is classified as held for
sale and that represents a separate major line of business or geographical area of operations, is part of a
single coordinated plan to dispose of such a line of business or area of operations, or is a subsidiary acquired
exclusively with a view to resale. The results of discontinued operations are presented separately in the statement
of comprehensive income.
4 CRITICAL ACCOUNTING ESTIMATES AND JUDGEMENTS
Estimates and judgements are continually evaluated by the Directors and are based on historical experience and other
factors, including expectations of future events that are believed to be reasonable under the circumstances.
The Group and the Company make estimates and assumptions concerning the future. The resulting accounting
estimates will, by definition, rarely equal the related actual results. To enhance the information content of the estimates,
certain key variables that are anticipated to have material impact on the Group’s and the Company’s results and
financial position are tested for sensitivity to changes in the underlying parameters. The estimates and assumptions that
have a significant risk of causing a material adjustment to the carrying amounts of assets and liabilities within the next
financial year are outlined below.
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31 DECEMBER 2022
4 CRITICAL ACCOUNTING ESTIMATES AND JUDGEMENTS (CONTINUED)
(a) Revenue recognition for contracts with customers
Identification of performance obligations (“PO”)
For the various models of the eKYC contracts and certain types of CAD contracts, they are considered to be
bundled solutions that consist of multiple products and services promised to the customers. The Group accounts
for individual products and services separately as separate performance obligations if they are distinct promised
products and services, i.e. if a product or service is separately identifiable from other items in the bundled solution
and if a customer can benefit from it separately. The Group exercises judgements in determining whether the
products and services are considered distinct and are separate performance obligations for the eKYC and CAD
revenue contracts. This determination will affect the allocation of consideration in the contract and revenue
recognised for each performance obligation.
The Group recognises the revenue at a point in time or over time depending on when the control over the
provision of services are transferred to the customers. The Group also exercises judgement on the timing when the
control is transferred to determine the timing of recognition.
Determining stand-alone selling price (“SSP”)
The Group has exercised judgement in estimating the SSP of each PO in the eKYC and CAD revenue contracts,
given that the SSPs for products and services are not directly observable in the market. The Group has used a cost
plus margin approach, by incorporating the expected cost of satisfying a PO and an appropriate margin for the
particular product or service.
Determining transaction price
The Group has determined that the volume of transactions that are highly probable for each revenue contract
as the basis to estimate the variable volume and consideration in determining the variable consideration it will
be entitled to from respective contracts. The estimates of variable consideration should be updated at the end of
each reporting period and any changes are accounted for as a change in estimates (adjustments to revenue)
in the period in which the transaction price changes.
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5 REVENUE
Group Company
2022 2021 2022 2021
Note RM’000 RM’000 RM’000 RM’000
Provision of services: (a)

- digital reports 78,949 55,525 - -
- subscriptions and monitoring services 85,832 80,914 - -
- comprehensive portfolio review and
analytics 15,323 9,398 - -
- digital solutions 14,677 7,329 - -
- other services - - 3,281 2,448
- dividend income from subsidiaries and
associates - - 88,564 62,013
194,781 153,166 91,845 64,461
(a) Revenue from contracts with customers
Group Company
2022 2021 2022 2021
RM’000 RM’000 RM’000 RM’000
Timing of revenue recognition:

- at a point in time 104,228 68,971 3,281 2,448
- over time 90,553 84,195 - -
Revenue from contracts with customers 194,781 153,166 3,281 2,448
The Group serves three distinct types of customers, namely Key Accounts, Commercial and Direct-to-Consumer.
Key Accounts customers comprise of the Group's highest revenue-generating customers as well as other selected
customers, such as those with complex requirements or well-recognised brands. Commercial customers comprise (i)
the Group’s Malaysian segment commercial customers other than Key Accounts customers and (ii) all of CTOS Basis
Sdn. Bhd.’s, a wholly owned subsidiary of the Company, customers which are all commercial customers included within
the international segment. Direct-to-Consumer comprise the Group’s retail consumers.
The disaggregation of revenue by types of customers are as follows:
Group
2022 2021
RM’000 RM’000
Type of customers:
- Key Accounts 74,767 53,589
- Commercial - Malaysia 91,415 83,205
- Commercial - International 13,320 7,260
- Direct-to-Consumer 15,279 9,112
Total 194,781 153,166
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31 DECEMBER 2022
5 REVENUE (CONTINUED)
(b) Contract liabilities related to contracts with customers
The Group has recognised the following contract liabilities related to contracts with customers:
Group
2022 2021
Note RM’000 RM’000
Contract liabilities (i),(iii) 7,508 8,208
(i) Significant changes in contract liabilities
Group
2022 2021
Contract liabilities
Balance at the beginning of the year 8,208 6,681
Acquisition of subsidiary 34 - 376
Distribution of subsidiary 35 - (163)
Revenue recognised that was included in the contract liability
balance at the beginning of the year (8,208) (7,057)
Increases due to cash received, excluding amounts recognised
as revenue during the year 7,508 8,367
Foreign currency translation difference - 4
Balance at the end of the year 7,508 8,208
(ii) Asset recognised from costs to obtain or fulfil a contract
The Group has elected the practical expedient to recognise contract cost incurred related to contracts with
an amortisation period of less than one year as an expense when incurred.
(iii) Unsatisfied performance obligations
In the previous financial years, the Group applied the practical expedient in MFRS 15 and did not disclose
information about recognising performance obligations that have original expected duration of one year or
less.
As of 31 December 2022, the aggregate amount of the transaction price allocated to the remaining
performance obligations for eKYC and CAD contracts amounts to RM3.8 million (2021: RM5.4 million) and
the Group will recognise this revenue as and when the services are performed, which is expected to occur
over the next 12 to 36 months.
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31 DECEMBER 2022
5 REVENUE (CONTINUED)
(b) Contract liabilities related to contracts with customers (continued)
(iii) Unsatisfied performance obligations
The Group expects that the transaction price of RM2.5 million (2021: RM2.4 million) allocated to unsatisfied
performance obligations as of 31 December 2022 will be recognised as revenue within the next 12 months.
The remaining allocated transaction price of RM1.3 million (2021: RM3.0 million) will be recognised over the
next 24 to 36 months.
The Group applied the practical expedient in MFRS 15 for all other contracts with periods of one year or less
and the unsatisfied performance obligations for these contracts are not disclosed.
6 FINANCE INCOME AND FINANCE COSTS
Group Company
2022 2021 2022 2021
Note RM’000 RM’000 RM’000 RM’000
Finance income
Interest income 108 154 12 22
Distribution income from money market
funds 61 258 22 173
Fair value gain on other investments 350 - 48 -
519 412 82 195
Finance costs
Interest expense on:
- bank borrowings 4,178 5,608 4,178 5,608
- lease liabilities 150 54 7 1
Accretion of provision for restoration costs 24 17 9 - -
Others - 8 - 8
4,345 5,679 4,185 5,617
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31 DECEMBER 2022
7 PROFIT BEFORE TAX
The following items have been charged/(credited) in arriving at the profit before tax:
Group Company
2022 2021 2022 2021
Note RM’000 RM’000 RM’000 RM’000
Allowance for impairment of receivables

- net 28(c) 298 222 - -
Auditors’ remuneration
- fees for statutory audit to
PricewaterhouseCoopers PLT 427 285 192 99
- fees for audit related services(1) 106 214 98 175
- fees for other services(2) 76 94 10 17
- fees for statutory audit to other auditors 8 5 - -
Depreciation of property, plant and
equipment 5,264 5,853 9 6
Depreciation on right-of-use assets 1,598 1,540 72 12
Amortisation of intangible assets 1,628 731 - -
Search charges and data fees 17,440 14,291 - -
Advertising, promotion and sales
commission expenses 9,599 8,803 148 228
IT support expenses 8,694 6,591 2 2
Legal and professional fees 2,484 2,496 439 68
Rental of buildings 233 240 - -
Realised loss on foreign exchange 11 4,297 42 4,316
Unrealised loss/(gain) on foreign
exchange 19 (54) 47 40
Bad debts recovered (63) - - -
Staff cost (including Directors’
remuneration) 9 55,484 44,876 3,919 3,088
Loss/(gain) on disposal of property, plant
and equipment 4 (4) - -
Interest income 6 (108) (154) (12) (22)
Notes:
(1)
Fees incurred mainly in connection with performance of quarter review, agreed-upon procedures and purchase price allocation review paid or
payable to PricewaterhouseCoopers PLT (LLP0014401-LCA & AF 1146) and member firms of PricewaterhouseCoopers International Limited.
(2)
Fees incurred for assisting the Group in connection with tax compliance and tax advisory services paid or payable to member firms of
PricewaterhouseCoopers International Limited.
139
OUR FINANCIALS

31 DECEMBER 2022
8 DIRECTORS’ REMUNERATION
The Directors of the Company in office during the financial year are as follows:
Tan Sri Izzuddin bin Dali

Dato’ Noorazman bin Abd Aziz
Erick Hamburger Barraza (appointed on 30 September 2022)
Loh Kok Leong
Lynette Yeow Su-Yin
Su Puay Leng
Wong Pau Min (alternate director to Loh Kok Leong)
Datuk Azizan bin Haji Abd Rahman (resigned on 7 March 2022)
Dennis Colin Martin (resigned on 30 September 2022)
The aggregate amount of emoluments received/receivable by the Directors of the Company during the financial year
are as follows:
Group Company
2022 2021 2022 2021
RM’000 RM’000 RM’000 RM’000
Fees 456 451 456 327

Wages, salaries and bonuses 654 1,422 197 791
1,110 1,873 653 1,118
There was no benefit-in-kind provided to Directors of the Company during the financial year.
9 STAFF COST (INCLUDING DIRECTORS’ REMUNERATION)
Group Company
2022 2021 2022 2021
RM’000 RM’000 RM’000 RM’000
Fees 456 451 456 327

Wages, salaries and bonuses 48,801 39,252 3,090 2,563
Defined contribution plan 6,227 5,159 373 189
55,484 44,876 3,919 3,088
140

31 DECEMBER 2022
10 TAX EXPENSE
Group Company
2022 2021 2022 2021
Note RM’000 RM’000 RM’000 RM’000
Continuing operations
Current tax:
- current year 18,801 10,045 74 59
- (over)/under accruals in prior years (5,074) 331 (10) -
Deferred tax:
- origination and reversal of temporary
differences 17 236 (1,038) - -
13,963 9,338 64 59
Discontinued operations
Tax expense 35 - 164 - -
13,963 9,502 64 59
The Company’s subsidiary, CDS is entitled to pioneer status incentives under the Promotion of Investments Act (“PIA”)
1986 for MSC Malaysia Qualifying Activities. As a result, certain CDS’s profits are exempted from tax for a period of 10
years, beginning on 9 November 2016. However, based on the provisions of the PIA 1986, the incentive’s effective period
is only for the first 5 years. CDS can enjoy an extension of a second 5-year incentive period by applying to the Malaysian
Investment Development Authority (“MIDA”).
The tax relief period under CDS’s MSC Pioneer Certificate is from 9 November 2016 to 8 November 2021. However,
pursuant to the Grandfathering and Transitional Guidelines issued by Malaysia Digital Economy Corporation (“MDEC”)
which became effective on 1 January 2019, such tax relief period will only last until 30 June 2021. CDS requires approval
from MDEC or the relevant authorities to continue enjoying these tax incentives from 1 July 2021 until 8 November 2021
(the “Transitional Period”).
CDS has on 26 May 2022 received the approval letter from MIDA via MDEC on Transition to the MSC Malaysia Status
Services Incentive under Income Tax (Exemption) (No. 10) Order 2018 [P.U. (A) 389/2018], Income Tax Act 1967, which
grants tax incentives for the whole of the Transitional Period.
CTOS has submitted a new application to MDEC in accordance with the new conditions stipulated in the approval
letter, for an extension of tax exemption period for the next five years until 2026.
141
OUR FINANCIALS

31 DECEMBER 2022
10 TAX EXPENSE (CONTINUED)
On 28 July 2022, CDS has received the approval in principle from the Ministry of Finance (“MOF”) via MDEC on the
extension of income tax exemption under Section 127(3)(b) of the Income Tax Act 1967. The approval in principle is
applicable until the amendment of provisions for the extension of the second 5-year period under P.U. (A) 389/2018 is
approved and gazetted.
Pending the gazettement of P.U. (A) 389/2018, CDS’ tax expense for the financial year ended 31 December 2022 was
computed using the corporate income tax rate of 24%. In the financial year ended 31 December 2021, CDS’ tax expense
for the period 9 November 2021 to 31 December 2021 was computed using the corporate income tax rate of 24%.
Tax expense for the taxation authorities in the Philippines is calculated at the rate prevailing in that jurisdiction.
The explanation of the relationship between the tax expenses and profit before tax is as follows:
Group Company
2022 2021 2022 2021
% % % %
Numerical reconciliation between the Malaysian

tax rate and effective tax rate
Malaysian tax rate: 24 24 24 24
Tax effects of:
- pioneer status tax exemption - (10) - -
- income not subject to tax - - (28) (30)
- expenses not deductible for tax purposes 5 6 4 6
- share of profits of associates (7) (3) - -
- (over)/under accruals in prior years (6) 1 - -
Effective tax rate 16 18 - -
142
11 PROPERTY, PLANT AND EQUIPMENT
Office Furniture Motor Work in

Computers equipment Renovation and fittings vehicles progress Total
Group RM’000 RM’000 RM’000 RM’000 RM’000 RM’000 RM’000
2022
Cost
As at 1 January 28,594 582 5,117 48 60 2,714 37,115

Additions 1,832 29 55 7 - 1,348 3,271
Disposals (1,385) - - - - - (1,385)
Reclassifications 924 - - - - (924) -
As at 31 December 29,965 611 5,172 55 60 3,138 39,001
Accumulated depreciation
As at 1 January 17,334 530 4,469 28 60 - 22,421

Charge to statement of
comprehensive income 4,742 21 493 8 - - 5,264
Disposals (1,381) - - - - - (1,381)
As at 31 December 20,695 551 4,962 36 60 - 26,304
Net book value 9,270 60 210 19 - 3,138 12,697
CTOS Digital Berhad
Annual Repor t 2022
143
31 DECEMBER 2022
11 PROPERTY, PLANT AND EQUIPMENT (CONTINUED)
144
Office Furniture Motor Work in
Computers equipment Renovation and fittings vehicles progress Total
31 DECEMBER 2022
2021
OUR FINANCIALS
Cost
As at 1 January 30,046 902 5,184 85 124 1,962 38,303

Additions 2,138 18 21 3 - 2,152 4,332
Disposals (4,241) (329) (28) (64) - - (4,662)
Reclassifications 1,400 - - - - (1,400) -
Distribution of subsidiary (778) (9) (63) 24 (66) - (892)
Currency translation differences 29 - 3 - 2 - 34
As at 31 December 28,594 582 5,117 48 60 2,714 37,115
Accumulated depreciation
As at 1 January 16,663 843 3,734 58 94 - 21,392

Charge to statement of
comprehensive income 5,116 22 824 10 17 - 5,989
Disposals (4,218) (329) (28) (64) - - (4,639)
Distribution of subsidiary (234) (6) (63) 24 (53) - (332)
Currency translation differences 7 - 2 - 2 - 11
As at 31 December 17,334 530 4,469 28 60 - 22,421
Net book value 11,260 52 648 20 - 2,714 14,694

31 DECEMBER 2022
11 PROPERTY, PLANT AND EQUIPMENT (CONTINUED)
Company
Accumulated Net book
Cost Depreciation value
RM’000 RM’000 RM’000
Computers
At 1 January 2022 27 (6) 21

Additions - (9) (9)
At 31 December 2022 27 (15) 12
At 1 January 2021 - - -
Additions 27 (6) 21
At 31 December 2021 27 (6) 21
12 LEASES
(i) The statement of financial position shows the following amounts relating to leases:
Right-of-use assets
Group
Cost depreciation value
Buildings Note RM’000 RM’000 RM’000
At 1 January 2022 4,905 (274) 4,631

Expired (5) 5 -
Charged to statement of comprehensive income 7 - (1,598) (1,598)
At 31 December 2022 4,900 (1,867) 3,033
At 1 January 2021 5,577 (3,506) 2,071

Acquisition of subsidiary 34 5 - 5
Distribution of subsidiary 35 (1,058) 416 (642)
Additions 4,899 - 4,899
Expired (4,556) 4,556 -
Charged to statement of comprehensive income - (1,729) (1,729)
Currency translation differences 38 (11) 27
At 31 December 2021 4,905 (274) 4,631
145
OUR FINANCIALS

31 DECEMBER 2022
12 LEASES (CONTINUED)
(i) The statement of financial position shows the following amounts relating to leases (continued):
Right-of-use assets (continued)
Company
Buildings Cost depreciation value
Note RM’000 RM’000 RM’000
At 1 January 2022 217 (12) 205

Charged to statement of comprehensive income 7 - (72) (72)
At 31 December 2022 217 (84) 133
At 1 January 2021 - - -
Additions 217 - 217
Charged to statement of comprehensive income 7 - (12) (12)
At 31 December 2021 217 (12) 205
Lease liabilities
Group Company
2022 2021 2022 2021
RM’000 RM’000 RM’000 RM’000
Current 1,606 1,546 73 70

Non-current 1,493 3,100 63 136
As at 31 December 3,099 4,646 136 206
(ii) Nature of the lessee’s leasing activities and restrictions or covenants imposed by leases
The Group and the Company leases various office spaces. Rental contracts are typically made for fixed periods of
3 years but may have extension options.
Lease terms are negotiated on an individual basis and contain a wide range of different terms and conditions.
The lease agreements do not impose any covenants, but leased assets may not be used as security for borrowings.
(iii) Variable payments terms
The Group and the Company do not have any variable payment terms on their lease agreements.
146

31 DECEMBER 2022
12 LEASES (CONTINUED)
(iv) Extension options and termination options
Extension and termination options are included in lease contracts across the Group and the Company. Extension
and termination options are included, when possible, to provide greater flexibility. The majority of extension and
termination options held are exercisable only by the Group and not by the respective lessors.
In cases in which the Group and the Company are not reasonably certain to exercise an optional extended lease
term, payments associated with the optional period are not included within lease liabilities. As at 31 December
2022, the Group and the Company did not exercise any extension option, therefore no financial effect recognised
in lease liabilities.
Potential future rental payments to periods following the exercise date of extension options are summarised below.
Potential future lease payments not included in lease liabilities (undiscounted)

2024 2025 2026 2027 Total
RM’000 RM’000 RM’000 RM’000 RM’000
At 31 December 2022/
At 31 December 2021
Group
Office space 267 1,604 1,604 1,336 4,811
Company
Office space 13 77 77 63 230
(v) Movement in lease liabilities arising from financing activities as follows:
Group Company
2022 2021 2022 2021
RM’000 RM’000 RM’000 RM’000
At 1 January 4,646 2,251 206 -

Acquisition of subsidiary - 6 - -
Additions - 4,899 - 217
Repayment of lease liabilities (1,697) (1,885) (77) (13)
Distribution of subsidiary (Note 35) - (736) - -
Non-cash changes:
- interest expense 150 81 7 1
- currency translation differences - 30 - -
At 31 December 3,099 4,646 136 206
147
OUR FINANCIALS

31 DECEMBER 2022
13 INTANGIBLE ASSETS
Database
and
customer Computer
Goodwill relationship License fee software Total
Group RM’000 RM’000 RM’000 RM’000 RM’000
2022
As at 1 January 74,642 698 - 3,836 79,176

Additions - 3,925 - 5,102 9,027
Amortisation charge for the
financial year - (497) - (1,131) (1,628)
As at 31 December 74,642 4,126 - 7,807 86,575
Cost 74,642 7,844 1,443 9,597 93,526

Accumulated amortisation - (3,718) (1,443) (1,790) (6,951)
As at 31 December 74,642 4,126 - 7,807 (86,575)
Database
and Brand
customer name and Computer
Goodwill relationship trademark License fee software Total
Group Note RM’000 RM’000 RM’000 RM’000 RM’000 RM’000
2021
As at 1 January 46,062 256 676 - 2,578 49,572

Acquisition of subsidiary 34 36,735 873 - - - 37,608
Additions - - - - 2,572 2,572
Amortisation charge for the
financial year - (199) (15) - (666) (880)
Distribution of subsidiaries 35 (8,369) (241) (687) - (672) (9,969)
Currency translation
differences 214 9 26 - 24 273
As at 31 December 74,642 698 - - 3,836 79,176
Cost 74,642 3,919 - 1,443 4,495 84,499

Accumulated amortisation - (3,221) - (1,443) (659) (5,323)
As at 31 December 74,642 698 - - 3,836 79,176
148

31 DECEMBER 2022
13 INTANGIBLE ASSETS (CONTINUED)
Impairment testing for cash-generating units (“CGU”) containing goodwill
For the purpose of impairment testing, the carrying amount of goodwill is allocated to CGUs identified at the operating
segments, which are the Malaysian and International operations as disclosed in Note 34.
The recoverable amount of a CGU is determined based on value in use calculations. These calculations use pre-
tax cash flow projections based on internally approved financial forecasts covering five years period which reflect
management’s expectations of revenue and earnings before interest, taxes, depreciation and amortisation (“EBITDA”)
based on past experience and future expectations of business performance.
A segment-level summary of the Group's net book value of goodwill allocation is as follows:
Group
2022 2021
RM’000 RM’000
Malaysia 37,906 37,906

International 36,735 36,735
The key assumptions used in the value in use calculations are as follows:
Malaysia
For the financial year ended 31 December 2022
a) revenue growth ranging from 15% to 30%for the next five years financial forecast period;
b) EBITDA margin ranging from 35% to 47% for the next five years financial forecast period;
c) pre-tax discount rate of 11.65%; and
d) terminal growth rate of 3.9%.
a) revenue growth ranging from 5% to 24% for the next five years financial forecast period;
b) EBITDA margin ranging from 33% to 36% for the next five years financial forecast period;
c) pre-tax discount rate of 10.49%; and
d) terminal growth rate of 3.2%.
There is no reasonably possible change in a key assumption on which management has based the determination of
the CGU’s recoverable amount that would cause the CGU’s carrying amount to exceed its recoverable amount.
149
OUR FINANCIALS

31 DECEMBER 2022
13 INTANGIBLE ASSETS (CONTINUED)
Impairment testing for cash-generating units (“CGU”) containing goodwill (continued)
The key assumptions used in the value in use calculations are as follows (continued):
International
(a) average revenue growth of approximately 24% for the next five years financial forecast period;
(b) average EBITDA margin of approximately 63% for the next five years financial forecast period;
(c) pre-tax discount rate of 11.71%; and
(d) terminal growth rate of 3.9%.
(a) average revenue growth of approximately 13% for the next five years financial forecast period;
(b) average EBITDA margin of approximately 62% for the next five years financial forecast period;
(c) pre-tax discount rate of 10.4%; and
(d) terminal growth rate of 3.2%.
There is no reasonably possible change in a key assumption on which management has based the determination of
the CGU’s recoverable amount that would cause the CGU’s carrying amount to exceed its recoverable amount.
14 INVESTMENTS IN SUBSIDIARIES
Company
2022 2021
RM’000 RM’000
Unquoted shares, at cost 336,918 336,918

Fair value of share options granted, over the Company’s equity instruments for
employees of subsidiaries 5,910 5,910
342,828 342,828
150

31 DECEMBER 2022
14 INVESTMENTS IN SUBSIDIARIES (CONTINUED)
The information on the subsidiaries are as follows:
Group’s effective interest

Name Principal activities 2022 2021
Incorporated in Malaysia
CTOS Data Systems Sdn. Bhd. Credit reporting agency and other digital 100% 100%
(“CDS”) 1 software related services
CTOS Business Systems Sdn. Bhd. Software developer and other related 100% 100%
(“CBS”) 1 services
Automated Mail Responder Sdn. Bhd. Dormant 100% 100%
(“AMR”) 1
CTOS IDS Sdn. Bhd. (“IDS”) 1
Outsourcing and training services 100% 100%
Enfo Sdn. Bhd. (“Enfo”) 2
Investment holding 100% 100%
CTOS Insights Sdn. Bhd. Investment holding 100% 100%
(“CTOS Insights”) 2
CTOS Basis Sdn. Bhd. Credit reporting service, business 100% 100%
(“CTOS Basis”) 1 information service, credit bureau,
marketing list, market research, industry
studies and related consultation services
Incorporated in Singapore
CIBI Holdings Pte. Ltd. Investment holding - -

(“CIBI Holdings”) 3
Incorporated in the Philippines
Subsidiary of CIBI Holdings Pte. Ltd.

CIBI Information, Inc. (“CIBI”) 2
Credit information bureau, business - -
information reporting and data analytics
services such as pre-employment check
1
Audited by PricewaterhouseCoopers PLT (LLP0014401–LCA & AF 1146) (“PwC Malaysia”), auditors of the Company.
2
The financial statements of these companies are audited by firms other than the auditors of the Company.
3
The financial statements of these companies are audited by member firms of PricewaterhouseCoopers International
Limited which are separate and independent legal entities from PwC Malaysia.
151
OUR FINANCIALS

31 DECEMBER 2022
15 INVESTMENTS IN ASSOCIATES
Group Company
2022 2021 2022 2021
RM’000 RM’000 RM’000 RM’000
Unquoted shares 513,960 126,497 504,618 118,712

Share of post-acquisition results and
reserves 60,660 46,407 - -
Share of net assets of associates 574,620 172,904 504,618 118,712
The details of the associates are as below:
Group’s effective interest

Name Principal activities 2022 2021
Incorporated in Malaysia
Associate held through Enfo and

CTOS Insights
Experian Information Services Provision of credit reporting business, 26% 26%
(Malaysia) Sdn. Bhd. (“Experian”) credit bureau and information services
Associate held by the Company
Juris Technologies Sdn. Bhd. Software development 49% -
(“JurisTech”)
RAM Holdings Berhad (“RAM”) Investment holding 57.675% -
Incorporated in Thailand
Associate held by the Company

Business Online Public Company Service provider and developer of local 24.825% 22.65%
Limited (“BOL”) and global financial information system
and as an online and offline business
information service provider as well
as consulting service and database
management
Incorporated in the Philippines
Associate held by CIBI

Consumer CreditScore Philippines, Inc. Credit sourcing company - -
(“CCSP”)
152

31 DECEMBER 2022
(a) Acquisition of equity interest in associates
BOL
On 6 August 2021, the Company acquired additional 21,743,300 ordinary shares in BOL, representing 2.65% of
the total paid up share capital of BOL, for a total cash purchase consideration of THB208.7 million (equivalent
to RM26.8 million). The acquisition was completed on 10 August 2021. Upon completion of the acquisition, the
shareholdings in BOL increased to 185,844,400 ordinary shares, representing 22.65% of the equity interest in BOL.
On 9 March 2022, the Company acquired additional 17,846,200 ordinary shares in BOL, representing 2.175% of
the total paid up share capital of BOL, for a total cash purchase consideration of THB205.2 million (equivalent to
RM26.2 million). Upon completion of the acquisition, the shareholdings in BOL increased to 203,690,600 ordinary
shares, representing 24.825% of the equity interest in BOL. The acquisition was completed on 11 March 2022.
JurisTech
On 4 March 2022, the Company completed the acquisition of 490,000 ordinary shares in JurisTech, representing
49% of the total issued and paid up share capital of JurisTech, for a total cash consideration of RM205.8 million.
Upon completion of the transaction, JurisTech becomes an associate of the Company.
RAM
During the financial year, the Company acquired a total of 4,955,000 ordinary shares in RAM, representing 49.55%
of the total issued and paid up share capital of RAM, for a total cash consideration of RM136.2 million as follows:
Number of
additional Additional Total cash
ordinary shares equity interest consideration
Date of acquisition acquired acquired RM’million
4 February 2022 350,000 3.50% 10.5

25 April 2022 560,000 5.60% 14.6
9 May 2022 200,000 2.00% 6.9
2 September 2022 1,990,000 19.90% 51.3
19 September 2022 80,000 0.80% 2.3
3 October 2022 1,565,000 15.65% 44.6
4 October 2022 210,000 2.10% 6.0
4,955,000 49.55% 136.2
153
OUR FINANCIALS

31 DECEMBER 2022
15 INVESTMENTS IN ASSOCIATES (CONTINUED)
(a) Acquisition of equity interest in associates (continued)
RAM (continued)
In the previous financial year, the Group’s investment of 8.125% equity interest in RAM was classified as an investment
in financial instrument measured at FVOCI as disclosed in Note 16. The Group increased its stake in RAM during
the financial year and has significant influence over RAM by virtue of the Group having effective shareholding
of more than 20% in RAM with effect from 2 September 2022 and the right to appoint a board representative in
the Board of Directors of RAM. As a result, the Group’s investment in RAM which was previously classified as other
investment is reclassified to investment in associate with effect from 2 September 2022.
Subsequently, the Group’s shareholdings in RAM increased to 55.575% on 3 October 2022 and 57.675% on 4
October 2022. At the end of the financial year, the Group holds 57.675% equity interest in RAM. Notwithstanding the
Group’s effective shareholding of more than 50% in RAM, the Group does not have control over RAM and the ability
to direct the relevant activities of RAM. This is because the power to direct the relevant activities resides with the
Board of Directors of RAM and the decisions on relevant activities are approved via a simple majority irrespective
of the equity interest of the shareholders who appointed the directors. The Group does not have the ability to
appoint majority of the directors in RAM due to the terms of the Board Charter of RAM which requires at least
75% independent and non-executive directors and the Constitution of RAM which requires any appointment of
board members to be approved by the Securities Commission Malaysia (“SC”), or if required, such other relevant
authority. Therefore, the Group continues to have significant influence in RAM and account for this investment as
an associate.
(b) Disposal of associate
On 11 February 2021, CIBI, a 51% owned subsidiary of CIBI Holdings, which in turn is a wholly owned subsidiary
of the Company, had entered into a Deed of Assignment to dispose of its entire 20% equity interest in CCSP for a
total consideration of PHP8,333 equivalent to RM702. The Group’s investment in CCSP was fully impaired as at 31
December 2020. The gain on completion of the disposal is insignificant.
(c) Contingent liabilities
There are no contingent liabilities relating to the Group’s interest in the associates.
154

31 DECEMBER 2022
15 INVESTMENTS IN ASSOCIATES (CONTINUED)
(d) Summarised financial information
The tables below provide summarised financial information for the associates of the Group which are accounted
for using the equity method. The information disclosed reflects the amounts presented in the financial statements
of the associates and not the Group’s share of those amounts. They have been amended to reflect adjustments
made by the Group when using the equity method, including fair value adjustments.
Experian BOL JurisTech RAM

2022 2021 2022 2021 2022 2022
RM’000 RM’000 RM’000 RM’000 RM’000 RM’000
Summarised
statement of
financial position
Current assets 44,347 37,798 71,609 67,171 27,973 155,004

Non-current assets 4,025 2,047 102,577 87,730 41,278 113,883
Current liabilities (14,583) (11,342) (29,051) (26,356) (15,071) (17,043)
Non-current liabilities (648) (25) (16,730) (14,171) (11,305) (23,113)
Net assets 33,141 28,478 128,405 114,374 42,875 228,731
Group’s share in % 26% 26% 24.825% 22.65% 49% 57.675%
Group’s share of net
assets 8,617 7,404 31,876 25,906 21,009 131,921
Goodwill 51,796 51,796 113,221 87,798 188,897 27,282*
Carrying amount at
end of financial
period/year 60,413 59,200 145,097 113,704 209,906 159,203
Quoted fair value - - 288,976 362,428 - -
* Based on provisional purchase price allocation exercise performed
Experian BOL JurisTech RAM

4.3.2022 to 2.9.2022 to
2022 2021 2022 2021 31.12.2022 31.12.2022
RM’000 RM’000 RM’000 RM’000 RM’000 RM’000
Summarised
statement of
comprehensive
income
Revenue 50,143 40,124 87,560 84,197 52,826 26,653

Profit for the financial
period/year 4,622 6,179 23,431 25,178 18,880 9,271
Other comprehensive
income/(loss) - - 9,893 (57) - -
Share of total
comprehensive
income of associate 1,212 1,606 9,815 5,598 9,251 5,347
155
OUR FINANCIALS

31 DECEMBER 2022
16 OTHER INVESTMENTS
Group Company
2022 2021 2022 2021
Note RM’000 RM’000 RM’000 RM’000
Non-current
Unquoted equity investment (a) - 17,664 - 17,664
Current
Investment in money market funds 5,048 26,000 5,048 15,000
(a) In the previous financial year, the Company acquired a total of 812,500 ordinary shares in RAM, representing
8.125% of the total issued and paid-up share capital of RAM for a total cash consideration of RM17,663,750. During
the financial year, the Group increased its stake in RAM and the investment in RAM is classified as an associate
with effect from 2 September 2022 as disclosed in Note 15.
17 DEFERRED TAXATION
Deferred tax assets and liabilities are offset when there is a legally enforceable right to set off current tax assets against
current tax liabilities and when the deferred taxes relate to the same tax authority. The following amounts, determined
after appropriate offsetting, are shown in the statement of financial position:
Group
2022 2021
RM’000 RM’000
Deferred tax assets 972 1,237

Deferred tax liabilities (71) (100)
The analysis of deferred tax assets and deferred tax liabilities is as follows:
Group
2022 2021
RM’000 RM’000
Deferred tax assets:

- to be recovered after more than 12 months 350 690
- to be recovered within 12 months 2,254 2,637
2,604 3,327
Deferred tax liabilities:

- to be settled after more than 12 months (944) (1,570)
- to be settled within 12 months (759) (620)
(1,703) (2,190)
Deferred tax assets (net) 901 1,137
156

31 DECEMBER 2022
17 DEFERRED TAXATION (CONTINUED)
The analysis of deferred tax assets and deferred tax liabilities is as follows (continued):
Group
2022 2021
As at 1 January 1,137 1,080
Acquisition of subsidiary 34 - (120)

- contract liabilities - 90
- intangible assets - (210)
Distribution of subsidiary 35 - (704)

- receivables - (396)
- intangible assets - 280
- contract liabilities - (30)
- defined benefit plan - (62)
- unutilised business losses - (454)
- others - (42)
(Charged)/credited to profit or loss: (236) 867

- provisions and accruals 1 69
- property, plant and equipment 149 (826)
- right-of-use assets 366 (1,012)
- contract liabilities (169) 1,612
- lease liabilities (353) 981
- unutilised business losses - (71)
- defined benefit plan - (10)
- receivables (209) 120
- intangible assets (21) (5)
- others - 9
Credited to other comprehensive income: - 14

- currency translation differences - 14
As at 31 December 901 1,137
157
OUR FINANCIALS

31 DECEMBER 2022
17 DEFERRED TAXATION (CONTINUED)
The movements in deferred tax assets and liabilities during the financial year comprise the following:
Group
2022 2021
RM’000 RM’000
Deferred tax assets (before offsetting):

- provisions and accruals 84 83
- property, plant and equipment 7 23
- contract liabilities 1,801 1,970
- lease liabilities 712 1,065
- receivables - 209
2,604 3,350
Offsetting (1,703) (2,213)
Deferred tax assets (after offsetting) 901 1,137
Deferred tax liabilities (before offsetting):
- property, plant and equipment (771) (936)
- right-of-use assets (696) (1,062)
- intangible assets (236) (215)
(1,703) (2,213)
Offsetting 1,703 2,213
Deferred tax liabilities (after offsetting) - -
18 RECEIVABLES, DEPOSITS AND PREPAYMENTS
Group Company
2022 2021 2022 2021
Note RM’000 RM’000 RM’000 RM’000
Non-current
Deposits 554 554 26 26
Current
Trade receivables and accrued revenue (a) 31,121 19,404 - -
Allowance for impairment
- trade receivables 28(c) (1,141) (1,276) - -
Trade receivables - net 29,980 18,128 - -

Other receivables 128 93 - 24
Deposits 290 223 6 6
Prepayments 8,901 6,717 108 77
39,299 25,161 114 107
(a) Information about the impairment of trade receivables and the Group’s exposure to credit risk is disclosed in Note
28(c).
158

31 DECEMBER 2022
19 AMOUNT DUE FROM/(TO) RELATED PARTIES
The amount due from/(to) related parties are trade in nature, unsecured, interest free and with credit periods of up to
45 days. The amount is denominated in RM.
20 CASH AND BANK BALANCES
Cash and cash equivalents at the end of the financial year comprise the following:
Group Company
2022 2021 2022 2021
RM’000 RM’000 RM’000 RM’000
Cash and bank balances 12,406 17,131 3,395 2,147

Less: Restricted cash (1,692) - (1,692) -
Cash and cash equivalents 10,714 17,131 1,703 2,147
Restricted cash comprise amounts held in a debt service reserve account associated with the term loan facilities.
The credit quality of bank balances can be assessed by reference to external credit ratings as follows:
Group Company
2022 2021 2022 2021
RM’000 RM’000 RM’000 RM’000
Local licensed banks(1):

- AAA 5,378 8,313 202 374
- AA1 6,986 - 3,193 -
- AA2 - 8,481 - 1,773
- AA3 37 331 - -
- Unrated 5 6 - -
12,406 17,131 3,395 2,147
Note:
(1)
Source: Ratings provided by RAM Ratings Services Berhad.
159
OUR FINANCIALS

31 DECEMBER 2022
21 PAYABLES AND ACCRUALS
Group Company
2022 2021 2022 2021
RM’000 RM’000 RM’000 RM’000
Current
Trade payables and accruals 8,351 3,141 - -
Other payables and accruals 10,848 10,388 789 1,373
Deposits payable to customers 2,231 2,197 - -
Duties and tax payable 2,050 1,667 1 -
Payroll liabilities 2,569 1,827 105 96
Payroll accruals 5,325 2,535 741 593
31,374 21,755 1,636 2,062
Trade and other payables of the Group and the Company carry credit periods ranging from 0 to 60 days
(2021: 0 to 60 days).
22 AMOUNT DUE FROM SUBSIDIARIES
The amount due from subsidiaries are unsecured, interest free and are repayable on demand. The amount is
denominated in RM.
Reconciliation of amount due from a subsidiary from financing activities:
Company
2022 2021
RM’000 RM’000
At 1 January - -
Advances to a subsidiary 15 -
At 31 December 15 -
23 BORROWINGS
Group Company
2022 2021 2022 2021
Note RM’000 RM’000 RM’000 RM’000
Current
Term loan (a) 9,972 - 9,972 -
Revolving credit (b) - - - -
9,972 - 9,972 -
Non-current
Term loan (a) 139,489 - 139,489 -
Total borrowings 149,461 - 149,461 -
160

31 DECEMBER 2022
23 BORROWINGS (CONTINUED)
(a) Term loan
(i) Term loan facility RM70.0 million
The Company entered into a RM70.0 million loan facility agreement on 28 March 2022. The term loan was
fully drawn down on 29 March 2022 to fund the acquisition of JurisTech and incurred transaction costs of
RM0.8 million. The term loan is repayable on a quarterly basis commencing on 31 March 2024 with final
maturity on 31 March 2029.
This term loan bears interest at a variable rate of 4.29% as at reporting date, based on a rate of 1.0% above
Cost of Funds.
Proceeds from the occurrence of certain mandatory prepayment events which includes 100.0% net dividend
received in respect of the BOL pledged shares shall be utilised to repay the total outstanding loan balance.
(ii) Term loan facility RM104.2 million
The Company entered into a RM110.0 million supplemental master facilities agreement on 23 August 2022.
The Company has drawn down RM92.7 million and RM11.5 million of the term loan in September 2022 and
October 2022 respectively to fund the acquisition of RAM and incurred transaction costs of RM1.2 million. The
balance undrawn facility amount of RM5.8 million has been cancelled on 1 November 2022. The term loan
is repayable on a quarterly basis commencing on 2 December 2022 with final maturity on 31 August 2027.
This term loan bears interest at a variable rate of 4.03% as at reporting date, based on a rate of 1.0% above
Cost of Funds.
All proceeds arising from the mandatory prepayment events shall be utilised to repay the total outstanding
loan balance.
(iii) Term loan facility USD22.1 million
USD22.1 million of the USD term loan facility was drawn down on 28 October 2020 and is repayable in
quarterly instalments commencing on 28 January 2021 with final maturity on 28 October 2025.
This term loan bears interest at a variable rate of 2.48% in July 2021, based on rate of 2.0% above Cost of
Funds.
Upon the occurrence of certain mandatory prepayment events which includes a change in equity interests of
the holding companies in the Company or an initial public offering (“IPO”), the lender has the right to cancel
the term loan facility and the total outstanding loan balance will become immediately due and payable. In
the event of an IPO, the proceeds derived from the IPO shall be utilised to repay the total outstanding loan
balance.
This term loan was early settled on 23 July 2021 utilising the IPO proceeds.
161
OUR FINANCIALS

31 DECEMBER 2022
(a) Term loan (continued)
(iv) Term loan facility RM45.6 million
RM45.6 million of the term loan facility was drawn down on 28 October 2020 and is repayable in quarterly
instalments commencing on 28 January 2021 with final maturity on 28 October 2025.
This term loan bears interest at a variable rate of 4.32% in July 2021, based on a rate of 2.0% above Cost of
Funds.
Upon the occurrence of certain mandatory prepayment events which includes a change in equity interests
of the holding companies in the Company or an IPO, the lender has the right to cancel the term loan facility
and the total outstanding loan balance will become immediately due and payable. In the event of an IPO,
the proceeds derived from the IPO shall be utilised to repay the total outstanding loan balance.
(v) Term loan facility RM32.0 million
The Company entered into a RM32.0 million loan facility agreement on 21 December 2021. The Company
has drawn down RM28.7 million and RM3.3 million of the term loan on 4 January 2021 and 18 February 2021
respectively to fund the acquisition of CTOS Basis and incurred transaction costs of RM0.6 million. The term
loan is repayable on a quarterly basis commencing on 5 April 2021 with final maturity on 3 December 2025.
This term loan bears interest at a variable rate of 4.32% in July 2021, based on a rate of 2.0% above Cost of
Funds.
Upon the occurrence of certain mandatory prepayment events which includes a change in equity interests
of the holding companies in the Company or an IPO, the lenders have the right to cancel the term loan
facilities and the total outstanding borrowings will become immediately due and payable. In the event of an
IPO, the proceeds derived from the IPO shall be utilised to repay the total outstanding borrowings.
(b) Revolving credit
The Company entered into a revolving credit facility on 22 February 2022 that provides for borrowings of up
to a maximum aggregate principal amount of RM50.0 million with a variable rate of 3.74% per annum and is
repayable on demand.
162

31 DECEMBER 2022
(b) Revolving credit (continued)
Reconciliation of borrowings from financing activities:
Group Company
2022 2021 2022 2021
RM’000 RM’000 RM’000 RM’000
As at 1 January - 132,320 - 132,320

Drawdown during the financial year 224,210 32,000 224,210 32,000
Repayment (73,628) (170,646) (73,628) (170,646)
Transaction costs (2,528) (627) (2,528) (627)
Interest on borrowings 4,178 5,608 4,178 5,608
Interest paid (2,771) (3,092) (2,771) (3,092)
Loss on foreign exchange - 4,437 - 4,437
As at 31 December 149,461 - 149,461 -
Term loan facility of RM70.0 million, RM104.2 million and Revolving credit
In accordance with the facilities agreement, during the tenure of the banking facility, the Company and its subsidiaries
were restricted from undertaking any further financing and other forms of indebtedness from any financial institutions
without prior written consent of the lenders.
The borrowings were secured against:
(a) Charge over designated accounts
- by way of first party first legal charge over all designated accounts of the Borrower, inclusive of Proceeds
Account and Finance Service Reserve Account ("FSRA").
(b) Charge over Associates’ shares
- by way of fixed charge by way of Deed of Share Pledge over 57.675% of RAM Shares and assignment of all
dividend payments from the Pledged Shares; and
- by way of fixed charge by way of Deed of Share Pledge over 22.65% of BOL Shares and assignment of all
dividend payments from Pledged Shares.
(c) Joint, several and irrevocable Corporate Guarantee
- Fresh Corporate Guarantee of up to RM70 million and RM104.2 million by the following companies:
i. CTOS Data Systems Sdn. Bhd.

ii. CTOS Business Systems Sdn. Bhd.
iii. CTOS IDS Sdn. Bhd.
iv. Enfo Sdn. Bhd.
v. CTOS Insights Sdn. Bhd.
163
OUR FINANCIALS

31 DECEMBER 2022
Term loan facility of USD22.1 million, RM45.6 million and RM32.0 million
In accordance with the facilities agreement, the Company and its subsidiaries were restricted from, amongst others:
(a) disposing or acquiring any assets unless the prior consent of the lenders have been obtained other than those
permitted in the facilities agreement.
(b) incurring or to remain outstanding any financial indebtedness other than existing borrowings or to provide any
loans and guarantees other than those permitted in the facilities agreement.
(c) making any payment and/or cash distribution including dividends, save for the dividend payments made for
Inodes to repay its principal and interest under Inodes’ financing facility.
The borrowings were secured against:
(a) Debentures
- by way of fixed and floating charges over all the assets, properties and undertakings (both movable and
immovable, present and future) of the Company. The amount of the Company’s assets charged as of 31
December 2020 is RM317.9 million.
(b) Charge over designated accounts
- by way of first party first legal charge over all designated accounts of the Borrower, inclusive of Proceeds
Account and Debt Service Reserve Account (“DSRA”).
(c) Charge over Associates’ shares
- by way of first party pledge over 20% the BOL Shares acquired and held by the Company; and
- by way of third party first legal charge by way of Deed of Share Pledge over 26% of Experian Shares.
(d) Charge over subsidiary’s shares
- by way of first party first legal charge by way of Deed of Share Pledge over 100% of the CTOS Basis share
acquired and held by the Company.
(e) Cross Corporate Guarantee
- Cross Corporate Guarantee of up to USD22.1 million, RM45.6 million and RM32.0 million by the following
companies:
i. CTOS Data Systems Sdn. Bhd.

ii. CTOS Business Systems Sdn. Bhd.
iii. CTOS IDS Systems Sdn. Bhd. (formerly known as Intellidata Solutions Sdn. Bhd.)
iv. Enfo Sdn. Bhd.
v. CTOS Insights Sdn. Bhd.
164

31 DECEMBER 2022
Contractual terms of borrowings
Contractual Functional
interest rate at currency/
reporting date currency Total carrying
(per annum) exposure amount 2023 2024 2025-2027
Maturity profile
At 31 December <1 year 1-2 years 2-5 years
2022 % RM’000 RM’000 RM’000 RM’000
Term loan 1.0% + COF(1) RM 149,461 9,972 62,810 76,679
Note:
(1)
COF denotes Cost of Fund
24 PROVISION FOR RESTORATION COSTS
Group
2022 2021
RM’000 RM’000
As at 1 January 612 603

Capitalised in property, plant and equipment 49 -
Accretion expense included in finance costs 17 9
As at 31 December 678 612
165
OUR FINANCIALS

31 DECEMBER 2022
25 SHARE CAPITAL
Group and Company

Number Number
of shares 2022 of shares 2021
’000 RM’000 ’000 RM’000
Issued and fully paid:
Ordinary shares:
At 1 January 2,200,000 412,524 100,000 197,994
Subdivision of shares - - 1,900,000 -
Issuance of shares during the year 110,000 173,800 200,000 220,000
Share issuance expenses - (2,277) - (5,470)
At 31 December 2,310,000 584,047 2,200,000 412,524
On 10 June 2021, the Company had undertaken a subdivision of the existing 100,000,000 ordinary shares in issue into
2,000,000,000 ordinary shares.
On 19 July 2021, the Company had a public issue of 200,000,000 new ordinary shares in conjunction with the IPO of
the Company. Following the allotment of new shares, the Company’s total number of share capital has increased to
2,200,000,000 shares.
On 3 March 2022, the Company undertook a private placement of 110,000,000 new ordinary shares at an issue price
of RM1.58 per share with share issuance express of RM2,276,500. Following the allotment of new shares, the Company’s
total number of share capital has increased to 2,310,000,000 shares.
166

31 DECEMBER 2022
26 OTHER RESERVES
Group
2022 2021
RM’000 RM’000
Foreign currency translation reserve

At 1 January (6,669) (145)
Currency translation differences arising from translation of:
- subsidiary - 392
- associate 1,458 (6,755)
Reclassification of foreign currency translation reserve to retained earnings (Note 35) - (161)
At 31 December (5,211) (6,669)
Retirement benefit reserve

At 1 January - (143)
Reclassification of retirement benefit reserve to retained earnings (Note 35) - 143
At 31 December - -
Fair value reserve

At 1 January 243 243
Other comprehensive (loss)/income:
- loss on change in value of debt investment designated at FVOCI - net of income tax (28) -
- gain on changes in value of equity investments designated at FVOCI - net of
income tax 2,454 -
At 31 December 2,669 243
Total other reserves (2,542) (6,426)
Company
2022 2021
RM’000 RM’000
Share-based payments reserve
At 1 January 5,797 5,797

Reclassification of share-based payment reserve to retained earnings (5,797) -
At 31 December - 5,797
The share-based payment reserve arose from share options granted to eligible executives of the subsidiary in the Group
pursuant to the ESOS. Terms of the scheme are disclosed in Note 3(n)(iii).
Foreign currency translation reserve is used to record exchange differences arising from the translation of financial
statements of a subsidiary and an associate whose functional currency differs from the Group’s presentation currency.
167
OUR FINANCIALS

31 DECEMBER 2022
27 FINANCIAL INSTRUMENTS BY CATEGORY
Group Company
2022 2021 2022 2021
Note RM’000 RM’000 RM’000 RM’000
Financial assets at amortised cost
Receivables and deposits (excluding

prepayments) 18 30,952 18,998 32 56
Other investments 16 5,048 43,664 5,048 32,664
Amount due from related parties 19 2 1,422 - -
Amount due from subsidiaries 22 - - 807 1,050
Cash and bank balances 20 12,406 17,131 3,395 2,147
48,408 81,215 9,282 35,917
Financial liabilities at amortised cost
Payables and accruals (excluding

statutory liabilities) 21 21,435 15,725 789 1,373
Amount due to related parties 19 1,891 144 - -
Contingent consideration 12,157 9,267 12,157 9,267
Borrowings 23 149,461 - 149,461 -
188,043 29,782 162,543 10,846
168

31 DECEMBER 2022
28 FINANCIAL RISK MANAGEMENT
The Group’s and the Company’s financial risk management policy seeks to ensure that adequate financial resources
are available for the development of the Group’s and of the Company's businesses whilst managing its interest rate risk,
credit risk, liquidity risk and cash flow risk. The Group and the Company operate within clearly defined guidelines that
are approved by the Directors and the Group’s and the Company's policy is to not engage in speculative transactions.
(a) Market risk
Market risk is the risk that the fair value or future cash flow of the financial instruments that will fluctuate because of
changes in market prices. The various components of market risk that the Group and the Company are exposed
to are discussed below.
(i) Foreign exchange risk
The objectives of the Group’s and of the Company’s currency risk management policies are to allow the
Group and the Company to effectively manage the foreign exchange fluctuation against its functional
currency that may arise from future commercial transactions and recognised assets and liabilities. The
Group and the Company monitor the movement in foreign currency exchange rates closely to ensure their
exposures are minimised.
The currency exposure of financial assets and financial liabilities of the Group and of the Company that are
not denominated in the functional currency are set out below:
Currency Exposure
USD SGD EUR Others
RM’000 RM’000 RM’000 RM’000
Group
At 31 December 2022
Receivables 3,541 291 1,139 -

Cash and bank balances 334 8 * *
Payables (141) (10) * -
Net exposure 3,734 289 1,139 *
At 31 December 2021
Receivables 535 212 638 -

Cash and bank balances 583 214 - *
Payables (545) (8) * *
Net exposure 573 418 638 *
169
OUR FINANCIALS

31 DECEMBER 2022
28 FINANCIAL RISK MANAGEMENT (CONTINUED)
(a) Market risk (continued)
(i) Foreign exchange risk (continued)
The currency exposure of financial assets and financial liabilities of the Group and of the Company that are
not denominated in the functional currency are set out below (continued):
Currency Exposure
USD Others
RM’000 RM’000
Company
At 31 December 2022
Cash and bank balances 25 *
At 31 December 2021
Cash and bank balances 23 *
* Less than RM1,000
The sensitivity of the Group's and the Company’s profit after tax for the financial year and equity to a
reasonably possible change in the USD, SGD and EUR exchange rate against the functional currencies, of
RM, with all other factors remaining constant and based on the composition of assets and liabilities at the
reporting date are set out as below:
Impact on profit after tax for the financial year ended

Group Company
2022 2021 2022 2021
RM’000 RM’000 RM’000 RM’000
At 31 December
USD/RM
- strengthened 10% 373 57 2 2
- weakened 10% (373) (57) (2) (2)
SGD/RM
- strengthened 10% 29 42 - -
- weakened 10% (29) (42) - -
EUR/RM
- strengthened 10% 114 64 - -
- weakened 10% (114) (64) - -
The impact on profit after tax for the financial year are mainly as a result of foreign currency gain/losses on
translating of USD, SGD and EUR denominated receivables, cash and bank balances and payables.
170

31 DECEMBER 2022
(a) Market risk (continued)
(ii) Interest rate risk
The Group’s and the Company’s interest rate risk arises from revolving credit and term loan carrying variable
interest rates.
The net exposure of financial liabilities of the Group and Company to interest rate risk and the periods in
which the borrowings mature or reprice (whichever is earlier) are as follows:
Weighted
average
effective
interest rate Total
at reporting carrying
date amount Floating interest rate
<1 year 1-2 years 2-5 years
% RM’000 RM’000 RM’000 RM’000
Group and Company
At 31 December 2022
Term loan 4.29 48,734 - 48,734 -

Term loan 4.03 100,727 9,972 14,076 76,679
149,461 9,972 62,810 76,679
Interest rate sensitivity
This is mainly attributable to the Group’s and the Company’s exposure to interest rates on its variable rate
borrowings. The assumed movement in basis points for interest rate sensitivity analysis is based on the
currently observable market environment.
As at 31 December 2022, the sensitivity of the Group’s and Company’s profit after tax to a reasonably possible
change in interest rates with all other factors held constant and based on the composition of liabilities with
floating interest rates at the reporting date are as follows:
Impact on profit after

tax for the financial
year ended
Group RM’000
31 December 2022
Interest rate
- increased by 1% (1,495)
- decreased by 1% 1,495
The impact on profit after tax for the financial year is mainly as a result of interest expenses on floating rate
borrowings.
171
OUR FINANCIALS

31 DECEMBER 2022
(b) Liquidity risk
The objectives of the Group’s and the Company’s liquidity risk management policies are to monitor rolling forecasts
of the Group’s and the Company’s liquidity requirements to ensure it has sufficient cash to meet operational needs
and availability of funding to cater for growth and expansion. Liquidity risk can be mitigated by forecasting and
monitoring cash flow regularly, optimising working capital and managing credit facilities effectively.
The undiscounted contractual cash flow of the financial instruments as at the reporting date are as follows:
Total
undiscounted
Carrying contractual
amount cash flow <1 year 1-2 years 2-5 years
RM’000 RM’000 RM’000 RM’000 RM’000
31 December 2022
Group
Payables and accruals 21,435 21,435 21,435 - -

Amount due to related parties 1,891 1,891 1,891 - -
Lease liabilities 3,099 3,221 1,696 1,426 99
Contingent consideration 12,157 12,157 12,157 - -
Term loan 149,461 165,143 14,465 68,688 81,990
188,043 203,847 51,644 70,114 82,089
Company
Payables and accruals 789 789 789 - -

Lease liabilities 136 141 77 64 -
Contingent consideration 12,157 12,157 12,157 - -
Term loan 149,461 165,143 14,465 68,688 81,990
162,543 178,230 27,488 68,752 81,990
31 December 2021
Group

Amount due to related parties 144 144 144 - -
Lease liabilities 4,646 4,920 1,697 1,697 1,526
Contingent consideration 9,267 9,671 - 9,671 -
29,782 30,460 17,566 11,368 1,526
Company

Lease liabilities 206 218 77 77 64
Contingent consideration 9,267 9,671 - 9,671 -
10,846 11,262 1,450 9,748 64
172

31 DECEMBER 2022
(b) Liquidity risk (continued)
Cash flows forecasts for the 12 months period after the year end were prepared taking into account the operational
requirements, and capital commitments of the Group and the Company. Based on the assessment, there are
sufficient cash flows to enable the Group and the Company to meet their liabilities as and when they fall due and
to carry out its operations without a significant curtailment of operations. Therefore, the Directors have prepared
the financial statements of the Group and the Company on a going concern basis.
The Group and the Company have access to the following undrawn borrowing facilities at the end of the reporting
date:
Group and Company

2022 2021
RM’000 RM’000
Floating rate
Revolving credit 50,000 -
(c) Credit risk
The objectives of the Group’s and of the Company’s credit risk management policies are to manage its exposure
to credit risk from deposits, cash and bank balances, receivables and derivative financial instruments. It does not
expect any third parties to fail to meet their obligations given the Group’s and the Company’s policy of selecting
creditworthy counterparties. The Group and the Company do not have any derivative financial instruments as at
the reporting date.
Trade and other receivables
Credit risks of trade and other receivables are controlled by the application of credit approvals, limits and
monitoring procedures. Credit risks are minimised and monitored via limiting the Group’s and the Company’s
dealings with creditworthy business partners and customers. Trade and other receivables are monitored on an
ongoing basis via the Group’s and the Company’s management reporting procedures. For amounts due from
subsidiary and related parties, the exposure to bad debts is not significant since the subsidiary and the related
parties do not have historical default.
Concentration of credit risk
The Group and the Company have no significant concentration of credit risk as the Group’s and the Company’s
policy limits the concentration of financial exposure to any single counterparty.
173
174
(c) Credit risk (continued)
Impairment of trade receivables

31 DECEMBER 2022
The Group applies the MFRS 9 simplified approach to measuring ECL which uses a lifetime expected loss allowance for all trade receivables.
OUR FINANCIALS
To measure the ECL, trade receivables have been grouped based on shared credit risk characteristics and the days past due. The expected loss rates
are determined based on 3-year historical ageing profile and the corresponding historical credit losses experienced within this period.
The historical loss rates are adjusted to reflect forward-looking information on macroeconomic factors affecting the ability of the customers to settle
the receivables. Some of the factors which the Group has identified include Malaysian Consumer Price Index and exchange rate of RM:USD and has
adjusted the historical loss rates based on expected changes in such factors.
On that basis, the loss allowances as at 31 December 2022 and 31 December 2021 were determined as follows for trade receivables:
Current to 31 to 60 61 to 90 91 to 120 121 to 150

30 days days days days days > 150 days
At 31 December 2022 past due past due past due past due past due past due Total
0.01% - 0.01% - 0.01% - 0.01% - 0.01% - 0.01% -

(1)
Expected loss rate 0.40% 1.84% 6.76% 16.84% 32.2% 100.0%
Gross carrying amount:

- trade receivables 24,295 3,462 2,016 393 229 726 31,121
Less allowance:
- trade receivables (103) (50) (121) (63) (155) (649) (1,141)
Note:
(1)
The expected loss rate comprises customers with different risk profiles.
Impairment of trade receivables (continued)
On that basis, the loss allowances as at 31 December 2022 and 31 December 2021 were determined as follows for trade receivables (continued):
Current to 31 to 60 61 to 90 91 to 120 121 to 150

30 days days days days days > 150 days
At 31 December 2021 past due past due past due past due past due past due Total
0.01% - 0.01% - 0.01% - 0.02% - 0.05% - 0.13% -

(1)
Expected loss rate 3.68% 4.13% 9.46% 21.74% 41.06% 99.75%
Gross carrying amount:

- trade receivables 17,799 833 116 74 35 547 19,404
Less allowance:
- trade receivables (655) (34) (11) (16) (15) (545) (1,276)
Note:
(1)
The expected loss rate comprises customers with different risk profiles.
CTOS Digital Berhad
Annual Repor t 2022
175
31 DECEMBER 2022
OUR FINANCIALS

31 DECEMBER 2022
Impairment of trade receivables (continued)
Movement on the Group’s loss allowances for receivables is as follows:
Group
2022 2021
RM’000 RM’000
As at 1 January 1,276 1,338

Charged to statement of profit or loss 298 304
Amount written off (433) (409)
Distribution of subsidiary - 43
As at 31 December 1,141 1,276
Deposits, cash and bank balances
For deposits, cash and bank balances and short-term investments, the Group and the Company seek to ensure
that cash assets are invested safely and profitably by assessing counterparty risks and allocating placement
limits for various creditworthy financial institutions. The Group and the Company consider the risk of material loss
in the event of non-performance by the above parties to be unlikely. The Group’s and the Company’s maximum
exposure to credit risk is equal to the carrying value of those financial instruments.
Other receivables and deposits
Other receivables and deposits are considered to have low risk of defaults and historically there were minimal
instances where contractual cash flow obligations have not been met. The identified impairment loss was
immaterial.
(d) Capital risk management
The Group’s and the Company’s primary objective of capital risk management is to maintain an optimal capital
base to support the businesses and maximise shareholders value. The Directors monitor the debt levels to maintain
an optimum debt-to-equity ratio that complies with the debt covenants. The Group manages the capital structure
and makes adjustment to it, in light of changes in economic condition including the interest rate movements. To
maintain and adjust the capital structure, the Group may adjust dividend payment to shareholders, return capital
to shareholders or issue new shares.
During the financial year ended 31 December 2022, the Company had entered into borrowing facilities agreements
as disclosed in Note 23 and Note 28(b) to the financial statements. The external lenders of the term loan facility
of RM70.0 million and RM104.2 million require the Group to maintain financial covenant ratios on its Finance
Service Coverage Ratio (“FSCR”), gearing covenant and maintain a positive Tangible Net Worth at all times. These
financial covenant ratios have been fully complied with by the Group for the financial year ended 31 December
2022.
176

31 DECEMBER 2022
(d) Capital risk management (continued)
The Group's net debt-to-equity ratio as of the reporting date is as follows:
Group
2022 2021
Total borrowings 23 149,461 -

Cash and cash equivalents (excluding restricted cash) 20 (10,714) (17,731)
Net debt/(cash) 138,747 (17,731)
Total equity 512,706 307,881
Net debt-to-equity ratio (times) 0.27 *
* The net-debt-to-equity ratio for the Group is not presented as the Group is in a net cash position.
There were no changes in the Group's approach to capital management during the financial year. Other than
the securities on borrowings as disclosed in Note 23 in the financial year ended 31 December 2022, the Group is
not subject to any other externally imposed capital requirements.
(e) Offsetting financial assets and financial liabilities
(i) Financial assets
There is no offsetting arrangement in 2021 and 2022.
(ii) Financial liabilities
There is no offsetting arrangement in 2021 and 2022.
(f) Fair value estimation
Fair values are categorised into different levels in a fair value hierarchy based on the inputs used in the valuation
technique as follows:
Level 1 - quoted prices (unadjusted) in active markets for identical assets or liabilities;
Level 2 - inputs other than quoted prices included within Level 1 that are observable for the asset or liability, either
directly (i.e. as prices) or indirectly (i.e. derived from prices); and
Level 3 - inputs for the asset or liability that are not based on observable market data (i.e. unobservable inputs).
a. Financial instruments carried at amortised cost
The carrying amounts of financial assets and liabilities of the Group and the Company at the reporting date
approximated their fair values.
177
OUR FINANCIALS

31 DECEMBER 2022
(f) Fair value estimation (continued)
b. Financial instruments carried at fair value
The following table represents the assets and liabilities measured at fair value, using the respective valuation
techniques at the end of reporting date:
Group Company
Level 1 Level 3 Level 1 Level 3
RM’000 RM’000 RM’000 RM’000
31 December 2022
Current asset
Other investments
- investment in money market funds 5,048 - 5,048 -
Current liability
Contingent consideration - 12,157 - 12,157
31 December 2021
Non-current asset
Other investment - 17,664 - 17,664
Current asset
Other investments
- investment in money market funds 26,000 - 15,000 -
Non-current liability
Contingent consideration - 9,267 - 9,267
The fair value is calculated based on market approach using market multiples, financial information of the
equity investments and a discount/premium applied in the valuation. Fair value gain and loss is presented
The fair value of the contingent consideration is calculated as the present value of estimated future cash
flow using a discount rate that is adjusted for projection and credit risk. Net fair value loss of RM2.9 million
(2021: net fair value gain of RM0.2 million) was recognised in profit or loss within other (expenses)/income
during the financial year.
178

31 DECEMBER 2022
29 RELATED PARTIES
In addition to related party disclosures mentioned elsewhere in the financial statements, set out below are other
significant transactions, balances and commitments. The related party transactions described below were carried out
on agreed terms with the related parties.
Credisense Limited (“Credisense”), being an entity connected to the immediate holding company, Inodes, is principally
engaged in software development. Credisense has been providing services to CDS pursuant to a master software
license and service agreement dated 8 June 2018 comprising software, consultancy, training, maintenance and
support. Inodes ceased to hold interest in Credisense with effect from 27 October 2022.
CIBI Holdings, being an entity connected to certain directors of the Company, is an investment holding company. CDS
provides advisory and support services relating to credit bureaus to CIBI Holdings from September 2021.
Outsource Network Contact Center and Back Office Services Inc. (“ONET”) and Equicom Shared Services, Inc., being
subsidiaries of a person connected to the Company’s former subsidiary, CIBI, provides outsourcing services such as
contact center, human capital management and accounting services to CIBI.
2022 2021
RM’000 RM’000
Significant related parties transactions
Group
Purchase of services:
- software services from JurisTech 1,883 -
- professional services from Credisense 927 941
- outsourcing services from ONET - 66
Sale of services:
- advisory and support services to CIBI Holdings 1,808 1,420
Significant inter-company transaction
Company
Amount charged to subsidiaries:

- management fees 3,281 2,448
Inodes, the immediate holding company of the Company bears certain listing expenses arising from the Offer for Sale
shares in connection with the IPO exercise undertaken by the Company during the financial year ended 31 December
2021. The total listing expenses incurred by Inodes for the financial year ended 31 December 2021 approximates RM9.5
million.
Dividends from subsidiaries
During the financial year ended 31 December 2022, the dividend income recognised by the Company from investment
in subsidiaries amounted to RM89.9 million (2021: RM62.0 million) was received in cash.
179
OUR FINANCIALS

31 DECEMBER 2022
29 RELATED PARTIES (CONTINUED)
Key management personnel remuneration
Key management personnel are those persons having authority and responsibility for planning, directing and controlling
the activities of the entity, directly or indirectly, including any Director of that entity (both executive and non-executive).
The aggregate amount of emoluments received/receivable by key management personnel including Directors of the
Company during the financial year is as follows:
Group Company
2022 2021 2022 2021
RM’000 RM’000 RM’000 RM’000
Fees 456 451 456 327

Salaries and other short-term employee benefits 5,068 4,680 1,692 1,586
Defined contribution plan 352 336 181 97
5,876 5,467 2,329 2,010
30 DIVIDENDS
2022
Single-tier Amount of
tax-exempt dividends,
dividend per single-tier
share tax-exempt
sen RM’000
Dividends paid in respect of the financial year ended 31 December 20211:

- third interim ordinary, paid on 25 February 2022 0.330 7,260

- first interim ordinary, paid on 10 June 2022 0.325 7,507
- second interim ordinary, paid on 13 September 2022 0.590 13,629
- third interim ordinary, paid on 14 December 2022 0.600 13,860
1.515 34,996
1.845 42,256
Notes:
1
Dividend per share is calculated based on 2,200,000,000 ordinary shares.
2
180

31 DECEMBER 2022
30 DIVIDENDS (CONTINUED)
On 31 January 2023, the Company declared a single-tier tax-exempt interim dividend of 0.36 sen per ordinary shares
amounting to RM8.32 million in respect of the financial year ended 31 December 2022 which was paid on 15 March
2023.
The financial statements for the financial year ended 31 December 2022 do not reflect these dividends as it was
declared subsequent to year end. These dividends will be accounted for in equity as an appropriation of retained
earnings during the financial year ending 31 December 2023.
2021
Single-tier Amount of
tax-exempt dividends,
dividend single-tier
per share tax-exempt
sen RM’000

- first interim ordinary, paid on 21 January 2021 5.250 5,250
- second interim ordinary, paid on 5 April 2021 9.000 9,000
- third interim ordinary, paid on 22 June 2021 8.000 8,000
22.250 22,250

- first interim ordinary, paid on 3 September 2021 0.533 11,726
- second interim ordinary, paid on 10 December 2021 0.320 7,040
0.853 18.766
23.103 41,016
Notes:
1
Dividend per share is calculated based on 100,000,000 ordinary shares.
2
181
OUR FINANCIALS

31 DECEMBER 2022
31 CAPITAL COMMITMENTS AND CONTINGENT LIABILITIES
(a) Capital commitments
Significant capital expenditure contracted for at the end of reporting date but not recognised as liabilities is as
follows:
2022 2021
RM’000 RM’000
Contracted:
- property, plant and equipment 776 319
- intangible assets 2,011 1,240
2,787 1,559
(b) Contingent liabilities
In the normal course of business, there are contingent liabilities arising from legal recourse sought on the Group’s
credit reporting operations. There were no material losses anticipated as a result of these legal cases.
(i) In January 2020, CDS, a wholly owned subsidiary of the Company was served a Writ by a Plaintiff on the
basis of an alleged negligence in reporting credit information. CDS reiterates through its defence that it is
a licensed entity under the Credit Reporting Agencies Act 2010 (the “Act”) and has conducted its business
pursuant to and in compliance of the Act. The Court has fixed the matter for Full Trial on 11 and 12 May 2023.
(ii) In February 2022, CDS was served a Writ by a Plaintiff on the basis of an alleged inaccuracy in reporting
credit information and that the said reporting was not consented. CDS reiterates through its defence that it
is a licensed entity under the Act and has conducted its business pursuant to and in compliance of the Act.
The Court had dismissed the Plaintiff’s Application for Summary Judgement. On 31 January 2023, the Plaintiff
had withdrawn the case against CDS without liberty to file afresh.
(iii) In July 2022, a Plaintiff filed an action seeking for a Court Order and/or Injunction against CDS (First Defendant)
to delete and/or withdraw the credit information under the “Special Attention Account” status in his credit
report that relates to the “Temporary Overdraft” facility granted by a financial institution (Second Defendant)
to the Plaintiff. In addition, the Plaintiff further seeks an Order against the Second Defendant to withdraw the
publication and/or any upload of credit information under the “Special Attention Account” status relating
to the “Temporary Overdraft” facility in CDS and other credit reporting agency in Malaysia including Bank
Negara Malaysia (“BNM”) through BNM Central Credit Reference Information System (“CCRIS”) database.
The Full Trial was duly conducted and completed. The Court has fixed matter for the delivery of Decision on
28 April 2023.
(iv) In October 2022, CDS was served with a Writ by a Plaintiff claiming negligence in CDS’ credit report which
had contained the Plaintiff’s bankruptcy proceeding that was annulled by the Court. The Plaintiff seeks
damages, a public apology and an order to restrain CDS from making and/or publishing the information.
CDS maintained that it has the right to publish the bankruptcy proceeding and the status update on the
annulment in the credit report within the timeframe as allowed under the Act. The Court has fixed the matter
for Hearing of the Plaintiff’s application to amend its Statement of Claim on 16 May 2023.
182

31 DECEMBER 2022
32 EARNINGS PER SHARE
Basic and diluted earnings per share of the Group is calculated by dividing the profit attributable to the owners of the
Company by the weighted average numbers of ordinary shares in issue during the financial year.
Group
2022 2021
Profit/(loss) attributable to the owners of the Company (RM’000)

- Continuing operations 71,718 43,705
- Discontinued operations - (583)
71,718 43,122
Weighted average number of ordinary shares (‘000) 2,200,000 2,000,000

Adjusted for increase in number of shares on 19 July 2021 (‘000) - 90,959
Adjusted for increase in number of shares on 3 March 2022 (‘000) 91,315 -
2,291,315 2,090,959
Basic/diluted earnings per ordinary share (sen)

- Continuing operations 3.1 2.1
- Discontinued operations - -
3.1 2.1
33 OPERATING SEGMENTS
The Group is primarily engaged in credit reporting, digital software related services including software development,
outsourcing and provision of training. Management has determined the operating segments to be based on the
management reports reviewed by the chief operating decision makers (“CODM”) that are used to make strategic
decisions, for which discrete financial information is available. For management purposes, the Group is organised into
two reportable segments based on their geographical locations. The reportable segments are summarised as follows:
(i) Malaysia which comprise the provision of credit reporting services (sale of reports, monitoring and trade referencing
services and other services), sale of software licenses and provision of installation and maintenance services to 3
types of customers, namely Key Accounts, Commercial and Direct-to-Consumer; and
(ii) International which comprise the provision of comprehensive commercial credit reports and bulk commercial
data sales by CTOS Basis to international customers.
183
OUR FINANCIALS

31 DECEMBER 2022
33 OPERATING SEGMENTS (CONTINUED)
The provision of credit reporting services (sale of reports) by CIBI previously included in the International segment is
presented as discontinued operations following the completion of the distribution on 15 June 2021.
The performance of the operating segments is measured based on segment profit calculated as profit for the relevant
financial year plus tax expense, finance costs, depreciation and amortisation, share-based payment expense and
foreign exchange losses less interest income, foreign exchange gains and share of profits of associates.
The share of results of associates represents the business of a service provider, developer of local and global financial
information system and as an online and offline business information service provider as well as consulting service
and database management in Thailand and business of a credit reporting, credit bureau and information services in
Malaysia.
The CODM also reviews the revenue of the Malaysia and International segments by type of customers as disclosed
in Note 5. All assets are managed based on their geographical locations. Capital expenditure comprises additions to
property, plant and equipment, right-of-use (“ROU”) assets and intangible assets.
184
33 OPERATING SEGMENT (CONTINUED)
Business segments (continued)
With the distribution of CIBI to the Company's shareholders with effect from 15 June 2021, the CODM focused on review of continuing operations only. A
reconciliation of the segment revenue and segment profit for continuing operations only are set out below:
2022 2021
Malaysia International Elimination Total Malaysia International Elimination Total
RM’000 RM’000 RM’000 RM’000 RM’000 RM’000 RM’000 RM’000
CONTINUING OPERATIONS
Revenue
Sales to external customers 181,461 13,320 - 194,781 145,906 7,260 - 153,166
Inter-segment sales 3,279 546 (3,825) - 274 244 (518) -
Total revenue 184,740 13,866 (3,825) 194,781 146,180 7,504 (518) 153,166
Gross profit 153,488 11,139 - 164,627 127,700 6,276 - 133,976
Segment profit 64,883 8,524 - 73,407 58,986 4,474 - 63,460
Depreciation and amortisation (8,234) (256) - (8,490) (7,938) (186) - (8,124)

Finance costs (4,345) - - (4,345) (5,679) - - (5,679)
Dividend income 1,346 - - 1,346 - - - -
Interest income 70 38 - 108 124 30 - 154
Distribution income from money
market funds 61 - - 61 258 - - 258
Fair value gain on other investments 303 47 - 350 - - - -
Share of profits of associates 15,810 7,464 - 23,799 1,606 5,611 - 7,217
Realised and unrealised (losses)/
gains on foreign exchange - net (90) 60 - (30) (4,394) 151 - (4,243)
Profit before taxation 69,804 15,877 - 85,681 42,963 10,080 - 53,043
CTOS Digital Berhad
Tax expense (11,826) (2,137) - (13,963) (8,250) (1,088) - (9,338)

Profit from continuing operations 57,978 13,740 - 71,718 34,713 8,992 - 43,705
DISCONTINUED OPERATIONS
Loss from discontinued operations - (1,134)
Profit for the financial year 71,718 42,571

Annual Repor t 2022
185
31 DECEMBER 2022
33 OPERATING SEGMENT (CONTINUED)
186
Business segments (continued)
With the distribution of CIBI to the Company's shareholders with effect from 15 June 2021, the CODM focused on review of continuing operations only. A
reconciliation of the segment revenue and segment profit for continuing operations only are set out below: (continued)
31 DECEMBER 2022
OUR FINANCIALS
2022 2021
Malaysia International Elimination Total Malaysia International Elimination Total
RM’000 RM’000 RM’000 RM’000 RM’000 RM’000 RM’000 RM’000
Assets 538,726 196,513 - 735,239 202,974 157,609 - 360,583
Other disclosures
Non-cash item* (other than
depreciation and amortisation) 282 35 - 317 4,681 (97) - 4,584
Capital expenditure arising from:
- acquisition of subsidiary - - - - - 37,613 - 37,613
- property, plant and equipment,
ROU assets and intangible
assets additions 10,294 1,955 - 12,249 11,589 37 - 11,626
* Included in non-cash items are allowance for impairment of receivables - net and unrealised (gain)/loss on foreign exchange.

31 DECEMBER 2022
33 OPERATING SEGMENTS (CONTINUED)
Geographical segments
Non-current assets
Non-current assets are determined according to the country of the operating segment. Non-current assets exclude
financial instruments and deferred tax assets.
2022 2021
RM’000 RM’000
Malaysia 531,828 175,364

Thailand 151,256 113,704
676,925 289,068
Borrowings and lease liabilities
2022 2021
RM’000 RM’000
Malaysia 152,560 4,646
Information about a major customer
There is no single customer that contributed 10% or more of the Group's revenue throughout the reported financial
years.
34 BUSINESS COMBINATION
Acquisition of subsidiary
On 8 December 2020, the Company entered into a Sale and Purchase Agreement (“SPA”) to acquire the entire equity
interest in CTOS Basis comprising 1,000,000 ordinary shares for an upfront purchase consideration of RM32.0 million and
an earn-out payment that is computed based on the revenue target of CTOS Basis. The earn-out payment is computed
based on two times the total revenue of CTOS Basis for the financial year ended 30 June 2020, adjusted in proportion
to the achievement of the revenue target for the year of January 2022 to December 2022. As stated in the SPA, for an
estimated revenue target of RM14.0 million (“Revenue Target”), the earn-out payment will be RM8.0 million. The earn-out
payment will be adjusted accordingly based on the actual Revenue Target achieved and is not capped. The earn-out
payment is accounted for as a contingent consideration and is payable no later than 30 March 2023. The acquisition
was completed on 4 January 2021.
The Group and the Company have estimated a contingent consideration of RM9.4 million, by applying a discount
rate of 3.8% and assumed a probability-adjusted revenue of CTOS Basis of between RM15.7 million and RM18.5 million
for the next 2 years on the date of acquisition. The potential undiscounted amount payable under the arrangement is
between RM8.8 million and RM10.4 million for actual revenue target between RM15.7 million and RM18.5 million.
187
OUR FINANCIALS

31 DECEMBER 2022
34 BUSINESS COMBINATION (CONTINUED)
Acquisition of subsidiary (continued)
Details of the net assets acquired, goodwill and cash flows as of 4 January 2021 arising from business combination are
as follows:
Book value Fair value

RM’000 RM’000
Intangible assets - 873

Right-of-use assets 5 5
Deferred tax assets 90 90
Trade debtors 846 846
Other receivables, deposits and prepayments 62 62
Cash and cash equivalents 3,982 3,982
Trade payables (154) (154)
Other payables and accruals (54) (54)
Contract liabilities (376) (376)
Lease liabilities (6) (6)
Taxation (349) (349)
Deferred tax liabilities - (210)
Net identifiable assets acquired 4,046 4,709
Goodwill arising on acquisition 36,735

Less: Contingent consideration (9,444)
Cash consideration 32,000

Less: Cash and cash equivalents of subsidiary acquired (3,982)
Net cash outflow of the Group on acquisition of subsidiary 28,018
The goodwill represents the synergies to be realised in the Group’s credit reporting business moving forward. The
acquisition of CTOS Basis is mainly attributable to the expansion of the Group’s range of reports to include international
business reports and provides the Group with a complementary base of international customers in industries such as
insurance, services and credit reporting who are located primarily in Asia Pacific and Europe. It will not be deductible
for tax purposes.
The fair value of acquired trade receivables is RM0.8 million. The gross contractual amount for trade receivables due is
RM0.8 million recognised on acquisition.
In relation to the acquisition, the Group has recognised non-recurring acquisition related costs of RM0.3 million, which
was expensed and included within administrative expenses in the profit or loss.
The revenue and net income of CTOS Basis included in the consolidated statement of comprehensive income for the
year from the date of acquisition of 4 January 2021 to 31 December 2021 amounted to RM7.5 million and RM3.5 million,
respectively and would not have been materially different if the acquisition had occurred on 1 January 2021.
188

31 DECEMBER 2022
35 DISTRIBUTIONS OF SUBSIDIARIES AND DISCONTINUED OPERATIONS
On 15 June 2021, the Company completed the distribution amounting to RM15.1 million by way of dividend-in-specie of
4,900,001 ordinary shares in CIBI Holdings held by the Company, representing the entire equity interest in CIBI Holdings,
to the existing shareholders of the Company (“Distribution”). CIBI Holdings holds a 51% equity interest in CIBI, a credit
bureau incorporated in the Philippines. Upon completion of the Distribution, CIBI Holdings and CIBI ceased to be
subsidiaries of the Company. All the assets and liabilities of CIBI Holdings and CIBI are derecognised and distributed to
the owners of the Company based on their carrying values with the corresponding charge to retained earnings.
Details of net assets and net cash outflow arising from the distribution of the subsidiaries are as follows:
2021
Note RM’000
Property, plant and equipment 560

Right-of-use assets 12 642
Intangible assets 13 9,969
Receivables, deposits and prepayments 7,433
Deferred tax assets 17 704
Cash and cash equivalents 3,147
Payables and accruals (3,794)
Contract liabilities 5 (163)
Lease liabilities 12 (736)
Provision for defined benefit plan (22)
Total net assets 17,740
Non-controlling interest (i) (4,587)
Net assets of subsidiaries 13,153
Other reserves transferred to retained earnings (18)

- foreign currency translation reserve 26 (161)
- retirement benefit reserve 26 143
Total charge to retained earnings 13,135
Cash and cash equivalents of subsidiaries 3,147
Net cash outflow of the Group on distribution of subsidiaries 3,147
189
OUR FINANCIALS

31 DECEMBER 2022
35 DISTRIBUTIONS OF SUBSIDIARIES AND DISCONTINUED OPERATIONS (CONTINUED)
Details of the financial performance for the financial period ended 15 June 2021 are as follows:
1.1.2021-
15.6.2021
RM’000
Revenue 7,732
Cost of sales (2,112)
Gross profit 5,620

Other expenses (26)
Selling and marketing expenses (2,978)
Administrative expenses (3,561)
Finance income 2
Finance costs (27)
Loss before tax (970)
Tax expense (164)
Loss from discontinued operations

- Owners of the Company (583)
- Non-controlling interests (551)
(1,134)
Other comprehensive income from discontinued operations

- Owners of the Company 392
- Non-controlling interests 171
563
Total comprehensive loss from discontinued operations

- Owners of the Company (191)
- Non-controlling interests (Note (ii)) (380)
(571)
190

31 DECEMBER 2022
Summarised statement of cash flows for the financial period ended 15 June 2021 are as follows:
1.1.2021-
15.6.2021
RM’000
Cash flows from operating activities (2,252)

Cash flows from investing activities (178)
Cash flows from financing activities (209)
Effects of exchange rate changes 109
Net decrease in cash and cash equivalents (2,530)
The financial information (before intercompany eliminations) of CIBI that has material non-controlling interest (“NCI”)
to the Group is as follows:
(i) Summarised statement of financial position as at 15 June 2021:
As at
15.6.2021
RM’000
NCI percentage 49%
Non-current assets 4,361

Current assets 9,666
Non-current liabilities (225)
Current liabilities (4,442)
Net assets 9,360
Net assets attributable to NCI 4,587
(ii) Summarised statement of comprehensive income for the financial period ended 15 June 2021:
1.1.2021-
15.6.2021
RM’000
Revenue 7,732
Loss for the financial period (1,124)
Other comprehensive expense 349
Total comprehensive loss (775)
Loss allocated to NCI (380)
191
OUR FINANCIALS

31 DECEMBER 2022
The financial information (before intercompany eliminations) of CIBI that has material non-controlling interest (“NCI”) to
the Group is as follows (continued):
(iii) Summarised statement of cash flows for the financial period ended 15 June 2021:
1.1.2021-
15.6.2021
RM’000
Cash flows from operating activities (2,233)

Cash flows from investing activities (178)
Cash flows from financing activities (209)
Effects of exchange rate changes 109
Net decrease in cash and cash equivalents (2,511)
The non-controlling interest was derecognised following the distribution of the immediate holding company of CIBI as
dividend-in-specie on 15 June 2021.
36 SUBSEQUENT EVENTS
On 31 January 2023, the Company declared a fourth interim single-tier tax-exempt dividend of 0.36 sen per ordinary
shares amounting to RM8.32 million in respect of the financial year ended 31 December 2022 which was paid on
15 March 2023.
The financial statements for the financial year ended 31 December 2022 do not reflect these dividends. Upon declaration,
the cash dividend payment will be accounted for in equity as an appropriation of retained earnings during the financial
year ending 31 December 2023.
37 AUTHORISATION FOR ISSUE OF FINANCIAL STATEMENTS
The financial statements have been authorised for issue by the Board of Directors in accordance with a resolution of the
Directors on 17 April 2023.
192
STATEMENT BY DIRECTORS PURSUANT TO

SECTION 251(2) OF THE COMPANIES ACT 2016
We, Tan Sri Izzuddin bin Dali and Erick Hamburger Barraza, two of the Directors of CTOS Digital Berhad, do hereby state that, in
the opinion of the Directors, the accompanying financial statements set out on pages 100 to 192 are drawn up so as to give
a true and fair view of the Group and of the Company as at 31 December 2022 and financial performance of the Group
and of the Company for the financial year ended 31 December 2022 in accordance with the Malaysian Financial Reporting
Standards, International Financial Reporting Standards and the requirements of the Companies Act 2016 in Malaysia.
Signed by the Board in accordance with a resolution of the Directors dated 17 April 2023.
TAN SRI IZZUDDIN BIN DALI ERICK HAMBURGER BARRAZA

DIRECTOR DIRECTOR
Kuala Lumpur
STATUTORY DECLARATION PURSUANT TO

SECTION 251(1) OF THE COMPANIES ACT 2016
I, Erick Hamburger Barraza, the Director primarily responsible for the financial management of CTOS Digital Berhad, do
solemnly and sincerely declare that the financial statements set out on pages 100 to 192 are, to the best of my knowledge
and belief, correct, and I make this solemn declaration conscientiously believing the same to be true, and by virtue of the
provisions of the Statutory Declarations Act, 1960.
ERICK HAMBURGER BARRAZA
Subscribed and solemnly declared by the abovenamed at Kuala Lumpur before me, on 17 April 2023.
Before me,
COMMISSIONER FOR OATHS
193
OUR FINANCIALS
INDEPENDENT AUDITORS' REPORT

TO THE MEMBERS OF CTOS DIGITAL BERHAD
REPORT ON THE AUDIT OF THE FINANCIAL STATEMENTS
Our opinion
In our opinion, the financial statements of CTOS Digital Berhad (“the Company”) and its subsidiaries (“the Group”) give a
true and fair view of the financial position of the Group and of the Company as at 31 December 2022, and of their financial
performance and their cash flows for the financial year then ended in accordance with Malaysian Financial Reporting
Standards, International Financial Reporting Standards and the requirements of the Companies Act 2016 in Malaysia.
What we have audited
We have audited the financial statements of the Group and of the Company, which comprise the statements of financial
position as at 31 December 2022 of the Group and of the Company, and the statements of comprehensive income, statements
of changes in equity and statements of cash flows of the Group and of the Company for the financial year then ended, and
notes to the financial statements, including a summary of significant accounting policies, as set out on pages 100 to 192.
Basis for opinion
We conducted our audit in accordance with approved standards on auditing in Malaysia and International Standards on
Auditing. Our responsibilities under those standards are further described in the “Auditors’ responsibilities for the audit of the
financial statements” section of our report.
We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion.
Independence and other ethical responsibilities
We are independent of the Group and of the Company in accordance with the By-Laws (on Professional Ethics, Conduct and
Practice) of the Malaysian Institute of Accountants (“By-Laws”) and the International Ethics Standards Board for Accountants’
International Code of Ethics for Professional Accountants (including International Independence Standards) (“IESBA Code”),
and we have fulfilled our other ethical responsibilities in accordance with the By-Laws and the IESBA Code.
Our audit approach
As part of designing our audit, we determined materiality and assessed the risks of material misstatement in the financial
statements of the Group and of the Company. In particular, we considered where the Directors made subjective judgements;
for example, in respect of significant accounting estimates that involved making assumptions and considering future events
that are inherently uncertain. As in all of our audits, we also addressed the risk of management override of internal controls,
including among other matters, consideration of whether there was evidence of bias that represented a risk of material
misstatement due to fraud.
We tailored the scope of our audit in order to perform sufficient work to enable us to provide an opinion on the financial
statements as a whole, taking into account the structure of the Group and of the Company, the accounting processes and
controls, and the industry in which the Group and the Company operate.
194

REPORT ON THE AUDIT OF THE FINANCIAL STATEMENTS (CONTINUED)
Key audit matters
Key audit matters are those matters that, in our professional judgement, were of most significance in our audit of the financial
statements of the Group and of the Company for the current financial year. These matters were addressed in the context of
our audit of the financial statements of the Group and of the Company as a whole, and in forming our opinion thereon, and
we do not provide a separate opinion on these matters.
Group
Key audit matters How our audit addressed the key audit matters
Assessment on carrying value of goodwill We performed the following audit procedures on the value-
in-use (“VIU”) calculations:
Refer to Note 3(e) - Summary of significant accounting
policies: Intangible assets and Note 13 - Intangible assets • Assessed the appropriateness of the CGUs to which
goodwill is allocated in accordance with MFRS 136;
As at 31 December 2022, the carrying values of the Group’s
goodwill allocated to the Malaysian and International • Checked the mathematical accuracy of the five-
operations cash generating units (“CGUs”) were RM37.9 year VIU cash flows and agreed the cash flows to the
million and RM36.7 million respectively. The Group is financial budget for 2023 approved by the Directors and
required to test goodwill for impairment annually based on projections for the next four years;
the requirements of MFRS 136 “Impairment of Assets”.
• Discussed with management on the key assumptions
We focused on this area as the estimation of the recoverable used in the five-year VIU cash flows which include the
amount requires significant assumptions and judgements revenue growth rate, EBITDA margin, discount rate and
on the future cash flows. Key assumptions include revenue terminal growth rate;
growth rate, earnings before interest, taxes, depreciation and
amortisation (“EBITDA”) margin, terminal growth rate and • Assessed the reliability of management’s estimates
discount rate. by comparing the historical forecast for 2022 to actual
results;
Based on the annual impairment test performed, the
Directors concluded that no impairment is required. The key • Compared the revenue growth rates and EBITDA
assumptions and sensitivities are disclosed in Note 13 to the margins in the projection periods to historical results and
financial statements. understand management’s forecasts of revenue and cost
components to derive the revenue growth and EBITDA
margin;
• Checked the reasonableness of the discount rate and

terminal growth rate with the assistance of our valuation
experts by benchmarking to entities with similar risk
profiles and market information; and
• Checked the sensitivity analysis performed by

management on the discount rate and revenue growth
rate.
Based on the procedures performed above, we did not find

any material exceptions to the Directors’ conclusion that the
goodwill is not impaired as at 31 December 2022.
195
OUR FINANCIALS

Key audit matters (continued)
Group (continued)
Acquisition of additional equity interest in RAM Holdings We performed the following audit procedures:
Berhad
• Read the signed Share Purchase Agreement (“SPA”) with
Refer to Note 3(a)(iv) – Summary of significant accounting respective parties for the acquisitions of additional equity
policies: Basis of consolidation: Associates and Note 15 - interests in RAM;
Investments in associates
• Reviewed management’s accounting treatment for
In the previous financial year, the Group’s investment in RAM the acquisition of additional equity interest of RAM and
was accounted for as an investment in financial instrument the classification of the investment as an associate in
measured at fair value through other comprehensive income accordance with the relevant accounting standards;
(“FVOCI”) in accordance with MFRS 9 “Financial Instruments”.
During the financial year, the Group increased its stake in RAM • Evaluated management’s assessment of the share of
and the investment in RAM is classified as an associate with results using the equity method of accounting; and
effect from 2 September 2022 as disclosed in Note 15 to the
financial statements. • Reviewed the adequacy of disclosures in the financial
statements.
As at 31 December 2022, the Group holds 57.675% equity interest
in RAM. Notwithstanding the Group’s effective shareholding of Based on the procedures performed above, we did not
more than 50% in RAM, the Group does not have control over find any material exceptions to the Director’s assessment
RAM and the ability to direct the relevant activities of RAM. The on the accounting of the Group’s investment in RAM as an
assessment of classification of RAM is included in Note 15(a) to investment in associate.
the financial statements. The Group has therefore accounted for
this investment as an associate in accordance with MFRS 128
“Investments in associates and joint ventures”.
As at 31 December 2022, the carrying value of the Group’s

investment in RAM was RM159.2 million. A provisional purchase
price allocation ("PPA") was performed by management
resulting in a goodwill of RM27.3 million, which was included in
the carrying value of the investment of associate.
We focused on this area due to the significant management

judgement involved in assessing whether the Group has control
over RAM in accordance with MFRS 10 “Consolidated Financial
Statements”.
196

Key audit matters (continued)
Group (continued)
Acquisition of equity interest in Juris Technologies Sdn. Bhd. We performed the following audit procedures:
Refer to Note 3(a)(iv) – Summary of significant accounting • Read the Shareholders’ Agreement for the acquisition
policies: Basis of consolidation: Associates and Note 15 - of JurisTech and assessed management’s accounting
Investments in associates treatment for the acquisition of JurisTech in accordance
with MFRS 128 “Investments in associates and joint ventures”;
On 4 March 2022, the Company completed the acquisition
of 490,000 ordinary shares in Juris Technologies Sdn. Bhd. • Reviewed the PPA assessment performed by management
(“JurisTech”), representing 49% of the total issued and paid with the assistance of our valuation experts, including
up share capital for JurisTech, for a total cash consideration of the appropriateness of the fair value of the consideration
RM205.8 million. transferred and the identifiable assets acquired and
liabilities assumed and the goodwill recognised;
Upon completion of the acquisition, the investment in JurisTech
is accounted for as an investment in associate. Goodwill • Evaluated management’s assessment of the share of
relating to the acquisition of JurisTech of RM188.9 million was results using the equity method of accounting including
included in the carrying value of the investment in JurisTech. alignment to Group accounting policies; and
As at 31 December 2022, the carrying value of the Group’s
investment in JurisTech was RM209.9 million. • Reviewed the adequacy of disclosures in the financial
statements.
We focused on this area due to the quantitative impact of
the acquisition on the consolidated financial statements and Based on the procedures performed above, we did not find
that the PPA exercise, which involves the fair valuation of the any material exceptions to the Director’s assessment on the
consideration transferred, the identification of the acquired accounting of the acquisition of JurisTech as an investment
assets and liabilities and their respective fair values requires the in associate.
use of significant management judgement and estimates.
Assessment of funding requirements and ability to meet We performed the following audit procedures:
short term obligations
• Checked management’s cash flow forecasts for the Group
Refer to Note 28(b) - Financial risk management: Liquidity risk and the Company to the annual budget approved by the
Directors and extended up to 12 months from the date
As at 31 December 2022, the Group and the Company were of the financial statements, which includes operating,
in a net current liabilities position of RM24.0 million and investing and financing cash flows;
RM14.5 million respectively which was mainly contributed
by the Group and the Company’s tax payable, contingent • Discussed with management on key assumptions used in
consideration and borrowings as at 31 December 2022. the cash flow forecasts including expected revenue growth
rates, operating expenditures and capital expenditures,
Cash flow forecasts for the 12 months period after the year cash collection trends, payment profiles and significant
end were prepared taking into account the operational transactions that may occur in developing the cash flow
requirements and capital commitments of the Group and forecasts for the Group and the Company;
the Company. Based on the assessment, there are sufficient
cash flows to enable the Group and the Company to meet • Checked the borrowing repayment terms of the Group
their funding requirements. As at 31 December 2022, the against the loan agreements;
Group and the Company have undrawn borrowing facilities
amounting to RM50.0 million. • Checked the extent of undrawn facilities available to the
Group and the Company; and
We focused on this area due to the inherent uncertainties and
the judgement taken by management in forecasting future • Reviewed management’s assessment of compliance with
cash flows and determining the availability of funding to fund debt covenants.
the operations of the Group and the Company for the next 12
months from the date of the financial statements. Based on the procedures performed above, we did not find any
material exceptions to the Directors’ assessment that the Group
and the Company will be able to meet its short term obligations.
We have determined that there are no key audit matters to report for the Company.
197
OUR FINANCIALS

Information other than the financial statements and auditors’ report thereon
The Directors of the Company are responsible for the other information. The other information comprises the Directors’ Report
and Statement of Risk Management and Internal Control, and other sections of the 2022 Annual Report, but does not include
the financial statements of the Group and of the Company and our auditors’ report thereon.
Our opinion on the financial statements of the Group and of the Company does not cover the other information and we do
not express any form of assurance conclusion thereon.
In connection with our audit of the financial statements of the Group and of the Company, our responsibility is to read
the other information and, in doing so, consider whether the other information is materially inconsistent with the financial
statements of the Group and of the Company or our knowledge obtained in the audit or otherwise appears to be materially
misstated.
If, based on the work we have performed on the other information that we obtained prior to the date of this auditors’ report,
we conclude that there is a material misstatement of this other information, we are required to report that fact. We have
nothing to report in this regard.
Responsibilities of the Directors for the financial statements
The Directors of the Company are responsible for the preparation of the financial statements of the Group and of the
Company that give a true and fair view in accordance with Malaysian Financial Reporting Standards, International Financial
Reporting Standards and the requirements of the Companies Act 2016 in Malaysia. The Directors are also responsible for such
internal control as the Directors determine is necessary to enable the preparation of financial statements of the Group and
of the Company that are free from material misstatement, whether due to fraud or error.
In preparing the financial statements of the Group and of the Company, the Directors are responsible for assessing the
Group’s and the Company’s ability to continue as a going concern, disclosing, as applicable, matters related to going
concern and using the going concern basis of accounting unless the Directors either intend to liquidate the Group or the
Company or to cease operations, or have no realistic alternative but to do so.
Auditors’ responsibilities for the audit of the financial statements
Our objectives are to obtain reasonable assurance about whether the financial statements of the Group and of the
Company as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditors’ report that
includes our opinion. Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conducted in
accordance with approved standards on auditing in Malaysia and International Standards on Auditing will always detect a
material misstatement when it exists. Misstatements can arise from fraud or error and are considered material if, individually
or in the aggregate, they could reasonably be expected to influence the economic decisions of users taken on the basis of
these financial statements.
As part of an audit in accordance with approved standards on auditing in Malaysia and International Standards on Auditing,
we exercise professional judgement and maintain professional scepticism throughout the audit. We also:
(a) Identify and assess the risks of material misstatement of the financial statements of the Group and of the Company,
whether due to fraud or error, design and perform audit procedures responsive to those risks, and obtain audit evidence
that is sufficient and appropriate to provide a basis for our opinion. The risk of not detecting a material misstatement
resulting from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery, intentional omissions,
misrepresentations, or the override of internal control.
198

Auditors’ responsibilities for the audit of the financial statements (continued)
As part of an audit in accordance with approved standards on auditing in Malaysia and International Standards on Auditing,
we exercise professional judgement and maintain professional scepticism throughout the audit. We also: (continued)
(b) Obtain an understanding of internal control relevant to the audit in order to design audit procedures that are appropriate
in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the Group’s and of the
Company’s internal control.
(c) Evaluate the appropriateness of accounting policies used and the reasonableness of accounting estimates and
related disclosures made by the Directors.
(d) Conclude on the appropriateness of the Directors’ use of the going concern basis of accounting and, based on
the audit evidence obtained, whether a material uncertainty exists related to events or conditions that may cast
significant doubt on the Group’s or on the Company’s ability to continue as a going concern. If we conclude that a
material uncertainty exists, we are required to draw attention in our auditors’ report to the related disclosures in the
financial statements of the Group and of the Company or, if such disclosures are inadequate, to modify our opinion. Our
conclusions are based on the audit evidence obtained up to the date of our auditors’ report. However, future events or
conditions may cause the Group or the Company to cease to continue as a going concern.
(e) Evaluate the overall presentation, structure and content of the financial statements of the Group and of the Company,
including the disclosures, and whether the financial statements of the Group and of the Company represent the
underlying transactions and events in a manner that achieves fair presentation.
(f) Obtain sufficient appropriate audit evidence regarding the financial information of the entities or business activities
within the Group to express an opinion on the financial statements of the Group. We are responsible for the direction,
supervision and performance of the group audit. We remain solely responsible for our audit opinion.
We communicate with the Directors regarding, among other matters, the planned scope and timing of the audit and
significant audit findings, including any significant deficiencies in internal control that we identify during our audit.
We also provide the Directors with a statement that we have complied with relevant ethical requirements regarding
independence, and to communicate with them all relationships and other matters that may reasonably be thought to bear
on our independence, and where applicable, actions taken to eliminate threats or safeguards applied.
From the matters communicated with the Directors, we determine those matters that were of most significance in the audit
of the financial statements of the Group and of the Company for the current financial year and are therefore the key audit
matters. We describe these matters in our auditors’ report unless law or regulation precludes public disclosure about the
matter or when, in extremely rare circumstances, we determine that a matter should not be communicated in our report
because the adverse consequences of doing so would reasonably be expected to outweigh the public interest benefits of
such communication.
199
OUR FINANCIALS

REPORT ON OTHER LEGAL AND REGULATORY REQUIREMENTS
In accordance with the requirements of the Companies Act 2016 in Malaysia, we report that the subsidiaries of which we
have not acted as auditors, are disclosed in Note 14 to the financial statements.
OTHER MATTERS
This report is made solely to the members of the Company, as a body, in accordance with Section 266 of the Companies Act
2016 in Malaysia and for no other purpose. We do not assume responsibility to any other person for the content of this report.
PRICEWATERHOUSECOOPERS PLT PAULINE HO

LLP0014401-LCA & AF 1146 02684/11/2023 J
Chartered Accountants Chartered Accountant
Kuala Lumpur
17 April 2023
200
ANALYSIS OF SHAREHOLDINGS
AS AT 31 MARCH 2023
STATISTICS OF ORDINARY SHAREHOLDINGS
Class of Shares : Ordinary Shares

Total Number of Issued Shares : 2,310,000,000
Voting Rights : One vote for each ordinary share held
DISTRIBUTION OF SHAREHOLDINGS
No. of No. of
Size of Holdings Holders % Shares %
1 – 99 40 0.25 680 0.00

100 - 1,000 3,788 23.76 2,631,380 0.11
1,001 - 10,000 8,725 54.72 40,146,608 1.74
10,001 - 100,000 2,678 16.80 84,203,373 3.65
100,001 - 115,499,999 (*) 711 4.46 1,927,017,959 83.42
115,500,000 and above (**) 1 0.01 256,000,000 11.08
Total 15,943 100.00 2,310,000,000 100.00
Notes:
* less than 5% of issued shares
** 5% and above of issued shares
SUBSTANTIAL SHAREHOLDERS
(As per Register of Substantial Shareholders)
Direct Indirect
No. of No. of
Name of Shareholders Shares held % Shares held %
Inodes Limited 339,034,800 14.68 - -

Creador II, LLC - - 339,034,800 1
14.68
Employees Provident Fund Board 268,428,700 11.62 - -
Abrdn plc - - 124,994,900 2
5.41
Abrdn Holdings Limited (formerly known as Aberdeen
Asset Management PLC) - - 124,994,9003 5.41
Abrdn Malaysia Sdn Bhd - - 123,276,300 4
5.34
Notes:
1
Deemed interest through shares held by Inodes Limited pursuant to Section 8(4) of the Companies Act 2016.
2
Deemed interest through shares held by the registered holder who is a custodian appointed by one or more funds managed by one or more
subsidiaries of ABRDN PLC pursuant to Section 8(4)(c) of the Companies Act 2016.
3
Deemed interest through shares held by the registered holder who is a custodian appointed by one or more funds managed by one or more
subsidiaries of ABRDN Holdings Limited (formerly known as Aberdeen Asset Management PLC) pursuant to Section 8(4)(c) of the Companies Act
2016.
4
Deemed interest through shares held by the registered holder which is a custodian appointed by one or more funds managed by ABRDN Malaysia
Sdn Bhd.
201
OTHER INFORMATION
AS AT 31 MARCH 2023 (CONTINUED)
DIRECTORS’ SHAREHOLDINGS
(As per Register of Directors’ Shareholdings)
Direct Indirect
No. of No. of
Name of Shareholders Shares held % Shares held %
Tan Sri Izzuddin Bin Dali 130,000 0.006 - -

Dato’ Noorazman bin Abd Aziz 200,000 0.009 - -
Nirmala A/P Doraisamy - - - -
Lynette Yeow Su-Yin 300,000 0.013 - -
Loh Kok Leong 300,000 0.013 - -
Su Puay Leng 300,000 0.013 - -
Erick Hamburger Barraza 150,000 0.006
Wong Pau Min (Alternate Director to Loh Kok Leong) 500,000 0.022
LIST OF TOP 30 HOLDERS
No. Name Holdings %
1 Amsec Nominees (Asing) Sdn Bhd 256,000,000 11.08

Pledged Securities Account - Ambank (M) Berhad For Inodes Limited
2 Citigroup Nominees (Tempatan) Sdn Bhd 103,237,200 4.47
Employees Provident Fund Board
3 CIMSEC Nominees (Tempatan) Sdn Bhd 72,683,700 3.15
CIMB For Chung Tze Keong (PB)
4 CIMB Group Nominees (Asing) Sdn Bhd 67,611,800 2.93
Creador II, LLC For Inodes Limited
5 Maybank Investment Bank Berhad 63,720,000 2.76
IVT (13)
6 Amanahraya Trustees Berhad 58,999,996 2.55
Amanah Saham Bumiputera
Employees Provident Fund Board (Aberdeen)
8 Permodalan Nasional Berhad 39,439,700 1.71
Exempt AN For AIA Bhd
Kumpulan Wang Persaraan (Diperbadankan) (Aberdeen)
11 Cartaban Nominees (Tempatan) Sdn Bhd 31,892,700 1.38
PBTB For Takafulink Dana Ekuiti
12 HSBC Nominees (Asing) Sdn Bhd 29,388,200 1.27
HSBC BK PLC for EAM Long-only Emerging Markets Master Fund Limited
Employees Provident Fund Board (Nomura)
Exempt AN for Bank of Singapore Limited (Local)
Employees Provident Fund Board (Aham Am)
202
AS AT 31 MARCH 2023 (CONTINUED)
No. Name Holdings %
16 Cimsec Nominees (Tempatan) Sdn Bhd 25,990,300 1.12

CIMB For Chung Tze Wen (PB)
Urusharta Jamaah Sdn Bhd (2)
18 CIMB Group Nominees (Tempatan) Sdn Bhd 22,860,300 0.99
CIMB Bank Berhad (EDP 2)
19 Hong Leong Assurance Berhad 20,442,000 0.88
As Beneficial Owner (Life Par)
20 Cartaban Nominees (Asing) Sdn Bhd 18,710,100 0.81
SSBT Fund W4B3 For Wasatch Emerging Markets Small Cap Fund
21 Amanahraya Trustees Berhad 18,350,000 0.79
Public Islamic Select Treasures Fund
JPMSE LUX For JPMorgan Funds
23 Cartaban Nominees (Asing) Sdn Bhd 17,695,000 0.77
The Bank of New York Mellon For Commonwealth of Pennsylvaniapublic School
Employees' Retirement System
24 JCL Credit Leasing Sdn Bhd 16,500,000 0.71
JPMCB NA For Vanguard Emerging Markets Stock Index Fund
Employees Provident Fund Board (Aberislamic)
27 Maybank Nominees (Tempatan) Sdn Bhd 15,029,400 0.65
MTrustee Berhad for Principal Dali Equity Growth Fund (UT-CIMB-Dali) (419455)
28 Maybank Securities Nominees (Asing) Sdn Bhd 15,000,000 0.65
Maybank Investment Bank Berhad for Inodes Limited
JPMCB NA for JPMorgan ASEAN Fund (BK EastAsia TST)
30 Lembaga Tabung Angkatan Tentera 14,758,300 0.64
TOTAL 1,206,347,496 52.22
203
OTHER INFORMATION
NOTICE OF ANNUAL GENERAL MEETING
NOTICE IS HEREBY GIVEN THAT the 2023 Annual General Meeting of CTOS Digital Berhad (“CTOS Digital” or the “Company”)
(“AGM”) will be conducted on a fully virtual manner through live streaming and online remote meeting platform of TIIH
Online provided by Tricor Investor & Issuing House Services Sdn Bhd via its website at https://tiih.online or https://tiih.com.my
(Domain registration number with MYNIC: D1A282781) on Friday, 26 May 2023 at 9.30 a.m. to transact the following
businesses:-
AGENDA
Ordinary Business
1. To receive the Audited Financial Statements for the financial year ended 31 December 2022 (Please refer to
together with the Reports of the Directors and Auditors thereon. Explanatory Note 1)
2. To re-elect Lynette Yeow Su-Yin who retires pursuant to Clause 76(3) of the Company’s (Resolution 1)
Constitution.
3. To re-elect Erick Hamburger Barraza who retires pursuant to Clause 78 of the Company’s (Resolution 2)
Constitution.
4. To approve the payment of Directors’ fees for an amount not exceeding RM535,000 from (Resolution 3)
27 May 2023 until the next AGM of the Company.
5. To approve the payment of Directors’ benefits for an amount not exceeding RM15,000 from (Resolution 4)
27 May 2023 until the next AGM of the Company.
6. To re-appoint PricewaterhouseCoopers PLT as Auditors of the Company and to authorise the (Resolution 5)
Directors to fix their remuneration.
Special Business
To consider and, if thought fit, to pass, with or without modifications, the following Ordinary
Resolution of the Company:-
7. ORDINARY RESOLUTION
PROPOSED RENEWAL OF AUTHORITY FOR SHARE BUY-BACK (Resolution 6)
“THAT subject always to the Companies Act 2016 (“the Act”), the Constitution of the
Company, the Main Market Listing Requirements of Bursa Malaysia Securities Berhad (“Bursa
Securities”) (“Listing Requirements”) and all other applicable laws, guidelines, rules and
regulations, the Company be and is hereby authorised, to the fullest extent permitted by
law, to purchase such number of issued shares in the Company as may be determined by
the Directors of the Company from time to time through Bursa Securities upon such terms
and conditions as the Directors may deem fit and expedient in the interest of the Company
provided that:
(i) the aggregate number of issued shares in the Company (“Shares”) purchased
(“Purchased Shares”) and/or held as treasury shares pursuant to this ordinary
resolution does not exceed ten per centum (10%) of the total number of issued shares
of the Company as quoted on Bursa Securities as at point of purchase; and
204
(ii) the maximum fund to be allocated by the Company for the purpose of purchasing the
shares shall not exceed the aggregate of the retained profits of the Company based
on the latest audited financial statements and/or the latest management accounts
(where applicable) available at the time of the purchase,
(“Proposed Share Buy-Back”)
AND THAT the authority to facilitate the Proposed Share Buy-Back will commence immediately
upon passing of this Ordinary Resolution and will continue to be in force until:
(i) the conclusion of the next Annual General Meeting of the Company following at which
time the authority shall lapse unless by ordinary resolution passed at the meeting, the
authority is renewed, either unconditionally or subject to conditions;
(ii) the expiration of the period within which the next annual general meeting of the
Company is required by law to be held; or
(iii) revoked or varied by ordinary resolution passed by the shareholders of the Company
at a general meeting,
whichever occurs first, but shall not prejudice the completion of purchase(s) by the Company
of its own Shares before the aforesaid expiry date and, in any event, in accordance with
the Listing Requirements and any applicable laws, rules, regulations, orders, guidelines and
requirements issued by any relevant authorities.
AND THAT the Directors of the Company be and are hereby authorised, at their discretion,
to deal with the Purchased Shares until all the Purchased Shares have been dealt with by
the Directors in the following manner as may be permitted by the Act, Listing Requirements,
applicable laws, rules, regulations, guidelines, requirements and/or orders of any relevant
authorities for the time being in force:
(i) To cancel all or part of the Purchased Shares;
(ii) To retain all or part of the Purchased Shares as treasury shares as defined in Section
127 of the Act;
(iii) To distribute all or part of the treasury shares as dividends to the shareholders of the
Company;
(iv) To resell all or part of the treasury shares;
(v) To transfer all or part of the treasury shares for the purposes of or under the employees’
share scheme established by the Company and/or its subsidiaries;
(vi) To transfer all or part of the treasury shares as purchase consideration;
(vii) To sell, transfer or otherwise use the shares for such other purposes as the Minister may
by order prescribe; and/or
(viii) To deal with the treasury shares in any other manners as allowed by the Act, Listing
Requirements, applicable laws, rules, regulations, guidelines, requirements and/or
orders of any relevant authorities for the time being in force.
205
OTHER INFORMATION
AND THAT the Directors of the Company be and are authorised to take all such steps as
are necessary or expedient [including without limitation, the opening and maintaining of
central depository account(s) under Securities Industry (Central Depositories) Act, 1991,
and the entering into all other agreements, arrangements and guarantee with any party or
parties] to implement, finalise and give full effect to the Proposed Share Buy-Back with full
powers to assent to any conditions, modifications, variations and/or amendments (if any)
as may be imposed by the relevant authorities.”
8. To transact any other business of which due notice shall have been given in accordance
with the Companies Act 2016.
By Order of the Board
JOANNE TOH JOO ANN [LS 0008574] SAW HUI YING [MAICSA 7065214]
SSM PC NO.: 202008001119 SSM PC NO.: 202108000465
Company Secretary Company Secretary
Kuala Lumpur Kuala Lumpur
Dated: 26 April 2023
206
Notes:
1. IMPORTANT NOTICE
The 2023 Annual General Meeting (“AGM”) will be conducted on authorised nominee refers to an authorised nominee defined under
a fully virtual manner through live streaming and online remote the Securities Industry (Central Depositories) Act 1991 (“Central
meeting platform of TIIH Online provided by Tricor Investor & Issuing Depositories Act”) which is exempted from compliance with the
House Services Sdn Bhd (“Tricor”) via its website at https://tiih.online provisions of Section 25A(1) of the Central Depositories Act.
or https://tiih.com.my (Domain registration number with MYNIC:
D1A282781). 7. Where a member appoints more than one (1) proxy, the proportion of
shareholdings to be represented by each proxy must be specified in
Shareholders are strongly advised to participate and vote remotely at the instrument appointing the proxies.
the AGM through live streaming and online remote voting using the
Remote Participation and Voting facilities provided by the Company's 8. The appointment of a proxy may be made in a hard copy form or
Share Registrar, Tricor. by electronic means in the following manner and must be received
by the Company not less than forty-eight (48) hours before the time
Please read these Notes carefully and follow the Procedures in the appointed for holding the General Meeting or adjourned general
Administrative Guide for the AGM in order to participate remotely meeting at which the person named in the appointment proposes to
vote:
2. For the purpose of determining who shall be entitled to attend this
General Meeting, the Company shall be requesting Bursa Malaysia (i) In hard copy form
Depository Sdn Bhd to make available to the Company, a Record of
Depositors as at 19 May 2023. Only a member whose name appears The original Proxy Form and the power of attorney or other authority,
on this Record of Depositors shall be entitled to attend this General if any, under which it is signed or a notarially certified or office copy
Meeting or appoint a proxy to attend, speak and vote on his/her/its of that power or authority shall be deposited at the office of Tricor
behalf. at Unit 32-01, Level 32, Tower A, Vertical Business Suite, Avenue 3,
Bangsar South, No. 8, Jalan Kerinchi, 59200 Kuala Lumpur, Malaysia,
3. A member entitled to attend and vote at this General Meeting is or its Customer Service Centre at Unit G-3, Ground Floor, Vertical
entitled to appoint a proxy or attorney or in the case of a corporation, Podium, Avenue 3, Bangsar South, No. 8, Jalan Kerinchi, 59200
to appoint a duly authorised representative to attend, participate, Kuala Lumpur, Malaysia.
speak and vote in his place. A proxy may but need not be a member
of the Company. (ii) Electronically via TIIH Online
4. A member of the Company who is entitled to attend and vote at a The Proxy Form can be electronically lodged with Tricor via TIIH
General Meeting of the Company may appoint not more than two (2) Online at https://tiih.online. Please follow the procedures set out in
proxies to attend, participate, speak and vote instead of the member the Administrative Guide.
at the General Meeting.
9. For a corporate member who has appointed an authorised
5. Where a member of the Company is an authorised nominee as representative, please deposit the original certificate of appointment
defined in the Central Depositories Act, it may appoint not more of corporate representative with Tricor at the addresses stated in Note
than two (2) proxies in respect of each securities account it holds 8(i) above, before the time appointed for holding this general meeting
in ordinary shares of the Company standing to the credit of the said or adjourned meeting.
securities account.
10. Last date and time for lodging the Proxy Form is Wednesday, 24 May
6. Where a member of the Company is an exempt authorised nominee 2023 at 9.30 a.m.
which holds ordinary shares in the Company for multiple beneficial
owners in one securities account (“omnibus account”), there is no 11. Shareholders are advised to check the Company’s website
limit to the number of proxies which the exempt authorised nominee and announcements from time to time for any changes to the
may appoint in respect of each omnibus account it holds. An exempt administration of the 2023 AGM.
207
OTHER INFORMATION
EXPLANATORY NOTES ON ORDINARY BUSINESS
1. Agenda item No. 1 - Audited Financial Statements for the Financial Year Ended 31 December 2022
The Audited Financial Statements is meant for discussion only as an approval from shareholders is not required pursuant to the provision
of Section 340(1) of the Companies Act, 2016. Hence, this item on the Agenda is not put forward for voting by shareholders of the
Company.
2. Resolutions 1 and 2 – Re-election of Directors
Please refer to the Statement Accompanying the Notice of AGM for information.
3. Resolutions 3 and 4 – Payment of Directors’ Fees and Benefits
Pursuant to Section 230(1) of the Companies Act, 2016, the fees of the directors and any benefits payable to the directors of a listed
company and its subsidiaries shall be approved at a general meeting.
The Proposed Resolution 3 is to facilitate the payment of Directors’ fees calculated based on the current board size for the period from
27 May 2023 up to the next Annual General Meeting. In the event the Directors fees proposed are insufficient (due to enlarged Board
size), approval will be sought at the next Annual General Meeting for additional fees to meet the shortfall.
The Proposed Resolution 4 for the Directors’ Benefits are meeting allowances for the Board Investment Committee (“BIC”). Meeting
allowances are calculated based on the estimation of six meetings to be held during the period from 27 May 2023 up to the next
Annual General Meeting. In the event the proposed amount is insufficient (e.g., due to more meetings), approval will be sought at the
next Annual General Meeting for additional fees to meet the shortfall.
4. Resolution 5 – Re-appointment of Auditors
The Board, through the Audit and Risk Committee (“ARC”) has considered the re-appointment of PricewaterhouseCoopers PLT (“PwC”)
as the Auditors of the Company. The factors considered by the ARC in making the recommendation to the Board to table the re-
appointment of PwC at the 2023 AGM are disclosed in the Corporate Governance Overview Statement of this Annual Report.
EXPLANATORY NOTES ON SPECIAL BUSINESS
5. Resolution 6 – Proposed Renewal of Authority for Share Buy-Back
The proposed Resolution 6, if passed, will empower the Company to purchase up to ten per centum (10%) of the issued share capital
of the Company through Bursa Malaysia Securities Berhad.
For further information, please refer to the Statement to Shareholders dated 26 April 2023.
208
STATEMENT ACCOMPANYING
Pursuant to Paragraph 8.27(2) of The Main Market Listing Requirements of
Bursa Malaysia Securities Berhad
Election/Appointment as Directors
There are no individuals standing for election/appointment as Directors at the 2023 Annual General Meeting (“AGM”).
Lynette Yeow Su-Yin and Erick Hamburger Barraza are standing for re-election as Directors of the Company and being eligible,
have offered themselves for re-election at the 2023 AGM. Their profiles are set out on pages 23 and 26 of the 2022 Annual
Report.
The Board has through the Nomination and Remuneration Committee (“NRC”), considered the assessment of Lynette Yeow
Su-Yin and Erick Hamburger Barraza that was conducted in accordance with the Director Assessment Framework and agreed
that they met the criteria as prescribed by Paragraph 2.20A of the Main Market Listing Requirements of Bursa Securities on
character, experience, integrity, competence and time to effectively discharge their roles as Directors. Both Directors have
also met the relevant requirements under the fit and proper assessment and confirmed that they do not have any conflict of
interest or potential conflict of interest, including interest in any business that is in competition with the Group The NRC and
the Board had also undertaken an annual assessment on the independence of Lynette Yeow Su-Yin.
In addition to the above, the Board supports and recommended the re-election of Lynette Yeow Su-Yin and Erick Hamburger
Barraza as Directors of the Company based on the following:-
1. Lynette Yeow Su-Yin
Ms Lynette Yeow was appointed as the Independent Non-Executive Director of the Company on 1 October 2020. She is
a lawyer by profession and have extensive experience in corporate and securities laws, mergers and acquisitions and
capital markets. The Board is of the view that the Group has benefitted from having Ms Lynette Yeow on the Board given
her experience and constructive comments made during the Board meetings.
2. Erick Hamburger Barraza
Mr Erick Hamburger was appointed as the Group Chief Executive Officer on 1 April 2022 and was subsequently
appointed as the Executive Director of Company on 30 September 2022. He has over 28 years of vast experience
in corporate strategy and international credit reporting sector. His leadership roles in credit bureaus across several
emerging economies will benefit the Group.
Tan Sri Izzuddin Bin Dali who retires by rotation pursuant to Clause 76(3) of the Constitution of the Company, has expressed
his intention not to seek for re-election and hence, he will retire at the conclusion of the 2023 AGM.
209
OTHER INFORMATION
ADMINISTRATIVE NOTES
for the 2022 Annual General Meeting (“AGM”)
Date : Friday, 26 May 2023

Time : 9.30 a.m.
Online Meeting Platform : https://tiih.online
Precautionary Measures Against the Coronavirus Disease (“COVID-19”)
• In line with the Guidance and Frequently Asked Questions (FAQs) on the Conduct of General Meetings for Listed Issuers
issued by the Securities Commission Malaysia (including any amendment(s) that may be made from time to time)
(SC Guidance), the AGM of the Company will be conducted fully virtual through live streaming and online remote
platform provided by Tricor Investor & Issuing House Services Sdn Bhd (“Tricor”) in Malaysia via its TIIH Online website at
https:// tiih.online. Members are to attend, speak (including posing questions to the Board of Directors of CTOS via real
time submission of typed texts) and vote (collectively, “Participate”) remotely at this AGM via Remote Participation and
Voting (“RPV”) facilities provided by Tricor.
• According to the Revised Guidance Note and FAQs on the Conduct of General Meetings for Listed Issuers issued by the
Securities Commission Malaysia on 7 April 2022, an online meeting platform located in Malaysia is recognised as the meeting
venue and all meeting participants of a fully virtual general meeting are required to participate in the meeting online.
• We strongly encourage you to attend the AGM via the RPV facilities. You may also consider appointing the Chairman of
the Meeting as your proxy to attend and vote on your behalf at the AGM.
• Given the current “Transition to Endemic” phase, the Company will continue to observe whether there is any new
procedures, guidelines or measures may affect the administration of the AGM as set out in this Administrative Guide
and requiring material change to the proceedings of the meeting, the Company will issue announcement on the same
accordingly.Kindly check the Company’s website for announcements on the latest update (if any) in relation to the
AGM.
Remote Participation and Voting
• The RPV facilities are available on Tricor’s TIIH Online website at https://tiih.online.
• Shareholders are to attend, speak (in the form of real time submission of typed texts) and vote (collectively,“participate”)
remotely at the AGM using RPV facilities from Tricor.
• Kindly refer to Procedures for RPV as set out below for the requirements and procedures.
Procedures to Remote Participation and Voting via RPV Facilities
• Please read and follow the procedures below to engage in remote participation through live streaming and online
remote voting at the AGM using the RPV facilities:
Before the AGM Day
Procedure Action
i. Register as a user with • Using your computer, access to website at https://tiih.online. Register as a user
TIIH Online under the “e-Services” select the “Sign Up” button and followed by “Create Account
by Individual Holder”. Refer to the tutorial guide posted on the homepage for
assistance.
• Registration as a user will be approved within one (1) working day and you will be
notified via e-mail.
• If you are already a user with TIIH Online, you are not required to register again.
You will receive an e-mail to notify you that the remote participation is available for
registration at TIIH Online.
210
Before the AGM Day (Continued)
Procedure Action
ii. Submit your request to • Registration is open from Wednesday, 26 April 2023 until the day of AGM on Friday, 26
attend AGM remotely May 2023. Shareholder(s) or proxy(ies) or corporate representative(s) or attorney(s)
are required to pre-register their attendance for the AGM to ascertain their eligibility
to participate the AGM using the RPV facilities.
• Login with your user ID (i.e. e-mail address) and password and select the corporate
event: “(REGISTRATION) CTOS 2023 AGM”.
• Read and agree to the Terms & Conditions and confirm the Declaration.
• Select “Register for Remote Participation and Voting”.
• Review your registration and proceed to register.
• System will send an e-mail to notify that your registration for remote participation is
received and will be verified.
• After verification of your registration against the Record of Depositors as at 19 May
2023, the system will send you an e-mail on or after 24 May 2023 to approve or
reject your registration for remote participation.
(Note: Please allow sufficient time for approval of new user of TIIH Online and registration for the RPV.)
On the AGM Day
Procedure Action
i. Login to TIIH Online • Login with your user ID and password for remote participation at the AGM at any time
from 8.30 am i.e. 1 hour before the commencement of meeting at 9.30am on Friday,
26 May 2023.
ii. Participate through Live • Select the corporate event: “(LIVE STREAM MEETING) CTOS 2023 AGM” to engage
Streaming in the proceedings of the AGM remotely.
If you have any question for the Chairman/Board, you may use the query box to
transmit your question. The Chairman/Board will try to respond to questions submitted
by remote participants during the AGM. If there is time constraint, the responses will
be e-mailed to you at the earliest possible, after the meeting.
iii. Online remote voting • Voting session commences from 9.30am on Friday, 26 May 2023 until a time when the
Chairman announces the end of the session.
• Select the corporate event: “(REMOTE VOTING) CTOS 2023 AGM” or if you are on
the live stream meeting page, you can select “GO TO REMOTE VOTING PAGE” button
below the Query Box.
• Read and agree to the Terms & Conditions and confirm the Declaration.
• Select the CDS account that represents your shareholdings.
• Indicate your votes for the resolutions that are tabled for voting.
Confirm and submit your votes.
iv. End of remote participation • Upon the announcement by the Chairman on the conclusion of the AGM, the Live
Streaming will end.
211
OTHER INFORMATION
Note to users of the RPV facilities:
1. Should your registration for RPV be approved, we will make available to you the rights to join the live stream meeting
and to vote remotely. Your login to TIIH Online on the day of meeting will indicate your presence at the virtual meeting.
2. The quality of your connection to the live broadcast is dependent on the bandwidth and stability of the internet at your
location and the device you use.
3. In the event you encounter any issues with logging-in, connection to the live stream meeting or online voting on the
meeting day, kindly call Tricor Help Line at 011-40805616 / 011-40803168 / 011-40803169 / 011-40803170 for assistance
or e-mail to [email protected] for assistance.
Entitlement to Participate and Appointment of Proxy
• Only members whose names appear on the Record of Depositors as at 19 May 2023 shall be eligible to attend, speak
and vote at the AGM or appoint a proxy(ies) and/or the Chairman of the Meeting to attend and vote on his/her behalf.
• In view that the AGM will be conducted on a virtual basis, a member can appoint the Chairman of the Meeting as his/
her proxy and indicate the voting instruction in the Proxy Form.
• If you wish to participate in the AGM yourself, please do not submit any Proxy Form for the AGM. You will not be allowed
to participate in the AGM together with a proxy appointed by you.
• Accordingly, proxy forms and/or documents relating to the appointment of proxy/corporate representative/ attorney
for the AGM whether in hard copy or by electronic means shall be deposited or submitted in the following manner not
later than Wednesday, 24 May 2023 at 9.30am:
(i) In Hard copy:
By hand or post to the office of the Share Registrar, Tricor Investor & Issuing House Services Sdn Bhd at Unit 32-01,
Level 32, Tower A, Vertical Business Suite, Avenue 3, Bangsar South, No. 8, Jalan Kerinchi, 59200 Kuala Lumpur or its
Customer Service Centre at Unit G-3, Ground Floor, Vertical Podium, Avenue 3, Bangsar South, No. 8, Jalan Kerinchi,
59200 Kuala Lumpur;
(ii) By Electronic form:
All shareholders can have the option to submit proxy forms electronically via TIIH Online and the steps to submit
are summarised below:
Procedure Action
i. Steps for Individual Shareholders
Register as a User with • Using your computer, please access the website at https://tiih.online.
TIIH Online Register as a user under the “e-Services”. Please refer to the tutorial guide
posted on the homepage for assistance.
• If you are already a user with TIIH Online, you are not required to register
again.
212
Entitlement to Participate and Appointment of Proxy (Continued)
(ii) By Electronic form: (Continued)
Procedure Action
i. Steps for Individual Shareholders (Continued)
Proceed with submission of • After the release of the Notice of Meeting by the Company, login with your
form of proxy user name (i.e. email address) and password.
• Select the corporate event: “CTOS 2023 AGM - SUBMISSION OF PROXY
FORM”.
• Read and agree to the Terms and Conditions and confirm the Declaration.
• Insert your CDS account number and indicate the number of shares for
your proxy(s) to vote on your behalf.
• Appoint your proxy(s) and insert the required details of your proxy(s) or
appoint the Chairman as your proxy.
• Indicate your voting instructions – FOR or AGAINST, otherwise your proxy will
decide on your votes.
• Review and confirm your proxy(s) appointment.
• Print the form of proxy for your record.
ii. Steps for corporation or institutional shareholders
Register as a User with • Access TIIH Online at https://tiih.online.
TIIH Online • Under e-Services, the authorised or nominated representative of the
corporation or institutional shareholder selects the “Sign Up” button and
followed by “Create Account by Representative of Corporate Holder”.
• Complete the registration form and upload the required documents.
• Registration will be verified, and you will be notified by email within one (1)
to two (2) working days.
• Proceed to activate your account with the temporary password given in
the email and re-set your own password.
(Note: The representative of a corporation or institutional shareholder must register as a
user in accordance with the above steps before he/ she can subscribe to this corporate
holder electronic proxy submission. Please contact our Share Registrar if you need
clarifications on the user registration.)
Proceed with submission of • Login to TIIH Online at https://tiih.online.

form of proxy • Select the corporate event name: “CTOS 2023 AGM - SUBMISSION OF
PROXY FORM”.
• Agree to the Terms & Conditions and Declaration.
• Proceed to download the file format for “Submission of Proxy Form” in
accordance with the Guidance Note set therein.
• Prepare the file for the appointment of proxies by inserting the required
data.
• Login to TIIH Online, select corporate event name: “CTOS 2023 AGM -
SUBMISSION OF PROXY FORM”.
• Proceed to upload the duly completed proxy appointment file.
• Select “Submit” to complete your submission.
• Print the confirmation report of your submission for your record.
213
OTHER INFORMATION
Voting at Meeting
• The voting at the AGM will be conducted on a poll pursuant to Paragraph 8.29A of the Main Market Listing Requirements
of Bursa Malaysia Securities Berhad (“Bursa Malaysia”). The Company has appointed Tricor to conduct the online
voting.
• Shareholders can proceed to vote on the resolutions before the end of the voting session which will be announced by
the Chairman of the Meeting and submit your votes at any time from the commencement of the AGM at 9.30am. Kindly
refer to “Procedures to Remote Participation and Voting via RPV Facilities” provided above for guidance on how to vote
remotely via TIIH Online.
Door Gift or Food Voucher
• There will be no door gifts or food vouchers for attending the AGM.
No Recording or Photography
• Unauthorized recording and photography are strictly prohibited at the AGM
Pre-Meeting Submission of Questions to the Board of Directors
• The Board recognises that the AGM is a valuable opportunity for the Board to engage with shareholders. In order
to enhance the efficiency of the proceedings of the AGM, shareholders may in advance, before the AGM, submit
questions to the Board of Directors via Tricor’s TIIH Online website at https://tiih.online, by selecting “e-Services” to login,
post your questions and submit it electronically no later than Wednesday, 24 May 2023 at 9.30am. The Board of Directors
will endeavor to address the questions received at the AGM.
Annual Report and Circular to Shareholders
The following documents are available for downloading from our corporate website at www.ctosdigital.com or by scanning
the QR code:
1. Annual Report 2022

2. Corporate Governance Report 2022
3. Statement on Proposed Renewal of Share Buy-Back Mandate
4. Notice of the 2023 AGM
5. Proxy Form
6. Administrative Details
In an effort to support green environment, we encourage shareholders to refer to the electronic copy of the abovementioned
documents. You may request for a printed copy of the abovementioned documents at https://tiih.online by selecting
“Request for Annual Report/Circular” under the “Investor Services” or through telephone/e-mail to our Share Registrar, Tricor
Investor & Issuing House Services Sdn Bhd as given below.
Enquiry
• If you have any enquiry prior to the meeting, please call our Share Registrar, Tricor at +603-2783 9299 during office hours
i.e. from 8.30 a.m. to 5.30 p.m. (Monday to Friday), or alternatively email to [email protected].
214
CDS Account No. No. of shares held
PROXY FORM
I/We Tel:
[Full name in block, NRIC/Passport/Company No.]
of
being member(s) of CTOS DIGITAL BERHAD (“CTOS Digital” or the “Company”), hereby appoint:
Full Name (in Block) NRIC/Passport No. Proportion of Shareholdings
No. of Shares %
Address
and
Full Name (in Block) NRIC/Passport No. Proportion of Shareholdings
No. of Shares %
Address
or failing him/her, the Chairman of the Meeting as my/our proxy(ies) to vote for me/us on my/our behalf at the 2023 Annual General
Meeting of CTOS Digital which will be conducted as a fully virtual meeting through live streaming, online remote participation and
voting via the online meeting platform hosted on the TIIH Online System (“TIIH Online”) at https://tiih.online (“Meeting Platform”)
on Friday, 26 May 2023 at 9:30 a.m. or any adjournment thereof.
My/Our proxy is to vote as indicated below:
No. Agenda Resolution For Against

1. To re-elect Lynette Yeow Su-Yin who retires pursuant to Clause 76(3) of the Company’s Resolution 1
Constitution.
2. To re-elect Erick Hamburger Barraza who retires pursuant to Clause 78 of the Company’s Resolution 2
Constitution.
3. To approve the payment of Directors’ fees for an amount not exceeding RM535,000 Resolution 3
from 27 May 2023 until the next AGM of the Company.
4. To approve the payment of Directors’ benefits for an amount not exceeding RM15,000 Resolution 4
from 27 May 2023 until the next AGM of the Company.
5. To re-appoint PricewaterhouseCoopers PLT as Auditors of the Company and to Resolution 5
authorise the Directors to fix their remuneration.
6. To approve renewal of Authority for Share Buy-Back Resolution 6
Please indicate with an “X” in the space provided whether you wish your votes to be cast for or against the resolutions. In the
absence of specific direction, your proxy will vote or abstain as he thinks fit.
Signed this day of
Signature*
Member
* Manner of execution:
(a) If you are an individual member, please sign where indicated.
(b) If you are a corporate member which has a common seal, this proxy form should be executed under seal in accordance with the constitution of your
corporation.
(c) If you are a corporate member which does not have a common seal, this proxy form should be affixed with the rubber stamp of your company (if any) and
executed by:
(i) at least two (2) authorised officers, of whom one shall be a director; or
(ii) any director and/or authorised officers in accordance with the laws of the country under which your corporation is incorporated.
Notes:
1. For the purpose of determining who shall be entitled to attend this General Meeting, the Company shall be requesting Bursa Malaysia Depository
Sdn Bhd to make available to the Company, a Record of Depositors as at 19 May 2023. Only a member whose name appears on this Record of
Depositors shall be entitled to attend this General Meeting or appoint a proxy to attend, speak and vote on his/her/its behalf.
2. A member entitled to attend and vote at this General Meeting is entitled to appoint a proxy or attorney or in the case of a corporation, to appoint
a duly authorised representative to attend, participate, speak and vote in his place. A proxy may but need not be a member of the Company.
3. A member of the Company who is entitled to attend and vote at a General Meeting of the Company may appoint not more than two (2) proxies
to attend, participate, speak and vote instead of the member at the General Meeting.
4. Where a member of the Company is an authorised nominee as defined in the Central Depositories Act, it may appoint not more than two (2) proxies
in respect of each securities account it holds in ordinary shares of the Company standing to the credit of the said securities account.
5. Where a member of the Company is an exempt authorised nominee which holds ordinary shares in the Company for multiple beneficial owners
in one securities account (“omnibus account”), there is no limit to the number of proxies which the exempt authorised nominee may appoint in
respect of each omnibus account it holds. An exempt authorised nominee refers to an authorised nominee defined under the Securities Industry
(Central Depositories) Act 1991 (“Central Depositories Act”) which is exempted from compliance with the provisions of Section 25A(1) of the Central
Depositories Act.
6. Where a member appoints more than one (1) proxy, the proportion of shareholdings to be represented by each proxy must be specified in the
instrument appointing the proxies.
Please fold here
Affix
Stamp
CTOS DIGITAL BERHAD

Registration no : 201401025733
(1101823-A)
c/o Tricor Investor & Issuing House

Services Sdn Bhd
Unit 32-01, Level 32, Tower A
Vertical Business Suite, Avenue 3
Bangsar South, No. 8 Jalan Kerinchi
59200 Kuala Lumpur
Please fold here
7. The appointment of a proxy may be made in a hard copy form or by electronic means in the following manner and must be received by the
Company not less than forty-eight (48) hours before the time appointed for holding the General Meeting or adjourned General Meeting at which
the person named in the appointment proposes to vote:
(i) In hard copy form
The original Form of Proxy and the power of attorney or other authority, if any, under which it is signed or a notarially certified or office copy of
that power or authority shall be deposited at the office of Tricor Investor & Issuing House Services Sdn Bhd ("Tricor") at Unit 32-01, Level 32, Tower
A, Vertical Business Suite, Avenue 3, Bangsar South, No. 8, Jalan Kerinchi, 59200 Kuala Lumpur, Malaysia, or its Customer Service Centre at Unit
G-3, Ground Floor, Vertical Podium, Avenue 3, Bangsar South, No. 8, Jalan Kerinchi, 59200 Kuala Lumpur, Malaysia.
(ii) Electronically via TIIH Online
The Form of Proxy can be electronically lodged with Tricor via TIIH Online at https://tiih.online. Please follow the procedures set out in the
Administrative Guide.
8. For a corporate member who has appointed a representative instead of a proxy to attend this meeting, please bring the ORIGINAL certificate of
appointment executed in the manner as stated in this proxy form if this has not been lodged at the Company’s registered office earlier.
9. Last date and time for lodging the Proxy Form is Wednesday, 24 May 2023 at 9.30 a.m.

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INSIDE THIS REPORT

WE ARE CTOS DIGITAL ACCELERATING

Analysis of Shareholdings 192

THE 2023 Icon can be found in this

BOARD OF DIRECTORS AUDIT & RISK COMMITTEE

Tan Sri Izzuddin Bin Dali Nirmala A/P Doraisamy

COMPANY SECRETARIES REGISTERED OFFICE SHARE REGISTRAR

MISSION AND VISION

Our mission is to empower individuals and

ACCELERATING DIGITAL GROWTH

Please visit our website www.ctosdigital.com

CTOS DATA SYSTEMS

5 YEARS FINANCIAL HIGHLIGHTS

FINANCIAL SUMMARY (RM'000) 2018 2019 2020 2021 2022

Revenue 110,465 129,141 133,225 153,166 194,781

* Includes discontinued operations

REVENUE Key Accounts Commercial - Malaysia

YoY growth Commercial banks and leading Small-medium enterprises

PROFIT BEFORE TAX

Direct-to-Consumer Commercial - International

sen (“CTOS Basis”)

Based on dividend per share declared in respect

FINANCIAL SUMMARY (RM'000) 2018 2019 2020 2021 2022

PBT 31,791 41,246 42,796 53,043 85,681

(iii) share-based payment expense;

"CTOS Digital’s business is

All key business units

Profit After Tax and Minority

during challenging circumstances and automate their processes to drive business

OVERVIEW PERFORMANCE REVIEW AND DIVIDENDS

SUSTAINABILITY IN CTOS DIGITAL

CTOS Digital’s commitment towards sustainability is intertwined with

Data privacy and security are becoming

LOOKING AHEAD NEW LEADERSHIP & ACKNOWLEDGEMENTS

Erick Hamburger’s appointment as Group Chief Executive Officer commenced

FOREWORD BY OUR GROUP CEO

"I am truly delighted to introduce

2022 was a transformative year for consumers FY2022 KEY HIGHLIGHTS

CUSTOMER DESCRIPTION DIGITAL SOLUTIONS OFFERED

Identification When a customer identifies a • CTOS CreditFinder

Customer/ The initial step of determining whether • CTOS IDGuard

Application After a prospective customer is • CAD

Management Within a business’ portfolio of existing • CTOS Credit Manager

Recovery The stage in the customer lifecycle • CTOS Credit Manager

We mainly serve customers across three key segments:

57.675% in RAM Holdings Berhad, a leading provider of independent credit ratings,

REVIEW OF FINANCIAL PERFORMANCE

Statement of Comprehensive Income

While FY2022 carried various uncertainties from geopolitical tensions to inflationary

Updates on Business Segments

Key Accounts Commercial

The emergence of digital

STRATEGIC ACQUISITIONS RENEWAL OF PIONEER STATUS

CTOS Data Systems (“CDS”), the main

1 Cybersecurity risks 5 Regulatory Risks

3 Foreign Currency Exchange Rate risks

The Company’s share of profit or loss from BOL is denominated

Loss of CTOS Data Systems’ Pioneer Status and/or

If the Pioneer Status of CTOS Data Systems is revoked or