KENANGA ANNUAL REPORT 2019

K E N A N G A I N V E S T M E N T B A N K B E R H A D A n n u a l R e p o r t 2 0 1 9 64 The Group Anti-Fraud, Bribery and Corruption Policy is reviewed and if required, revised periodically so as to ensure that the Group keeps abreast with any changes in industry practices, as well as the applicable laws and regulations. Any revisions made are presented to the Boards of the entities within the Group for endorsement and approval. The Group takes cognisance of the fact that at the heart of fighting fraud, bribery and corruption is to instil principles of ethics and integrity in everyday business and operations so employees reflect those values daily in all their undertakings at work as second nature. • Whistleblowing As an organisation that prioritises transparency and openness, GRCS sees the need to provide an adequate and a safe platform to enable the reporting of any breach or potential breach as more than mere checklist item. In this regard, we have in place the Group Whistleblowing Policy & Guidance Notes, which details out the framework that is adopted and provides detailed explanation on the Group’s position on whistleblowing and clarification on relevant pertinent points. This policy also sets out the various channels to report on any illegal or unethical practices. Ultimately, the goal of the Whistleblowing Policy & Guidance Notes is to safeguard the interests of the Group and that of its client and to assure all parties that there will not be any adverse repercussions or retaliations arising from any reports that are made in good-faith. Additionally, the Whistleblowing Explainer Video as further described below supplements this policy and highlights that everyone has a role to play to prevent misconduct or wrongdoing. • Personal Data Protection The Group appreciates the importance of safeguarding clients’ data and ensures that all necessary measures are in place to effectively and adequately fulfill its role in protecting clients’ data. We acknowledge that it is crucial to prevent data loss and in order to achieve this, we have adopted various preventive measures and controls including prescribing the manner the data are to be stored, as well as restricting access to the same. Awareness and continuous training of our employees is a key aspect in ensuring that clients’ data are handled securely and accurately. • Chinese Wall and Insider Trading One of the fundamental responsibilities of the Group is to safeguard the reservoir of non-public information that comes into its possession from misuse and exploitation that could potentially harm clients and even third parties. As such, the Group has in place the Group Chinese Wall Policy, which mandates effective arrangements, systems and procedures, aimed at insulating and controlling the flow of confidential information and material non-public price-sensitive information to prevent conflicts or employees from gaining an unfair advantage. The Group Chinese Wall Policy is also implemented robustly, including establishment of Control Room to vigorously monitor and supervise employee trading to avoid potential violations of the applicable law and regulations on insider trading and accordingly, contribute to overall market integrity and in combating market abuse. • Conflict Management The Group’s Conflict Management Policy provides for instances when conflict of interest arises and requires all employees to take steps to avoid such situations and prescribes the method to deal with conflicts. In this regard, employees are required to make the appropriate disclosures and manage conflicts of interests in a transparent and open manner. It is also imperative that clients are provided all essential information to be able to make well informed decisions relating to any conflict of interest that affects the provision of financial services by the Group. • Fair Competitive Practices The Group believes in competing fairly and ethically in the marketplace as everyone will benefit from fair, free, open and competitive markets. The Group competes strictly on the merits of its products and services and makes no attempts to restrain or limit trade and adheres with the Competition Act 2010. ETHICS AND COMPLIANCE STATEMENT