KENANGA ANNUAL REPORT 2020

66 3 1 2 4 5 6 7 HOW WE ARE GOVERNED Kenanga Group’s AML/CFT/TFS policy and procedure have incorporated the required practices, control measures, guidance and direction in adherence to all related laws, regulations, guidelines and industry best practices towards ensuring the management of Kenanga Group’s financial crime risks to mitigate potential regulatory and reputational risk. In line with the latest development, AML/CFT/TFS procedure has been further enhanced to effectively communicate the organisation’s expected standards to all relevant stakeholders while addressing the new threats and vulnerabilities, and numerous AML/CFT/TFS programmes have been rolled out to closely monitor the level of AML/ CFT adherence to meet the regulatory expectations. Keeping in pace with the digitalisation era, Kenanga Group also continuously enhances its management information system for timely detection, monitoring and reporting of suspicious activities in accordance with a Risk Based Approach. • Whistleblowing The importance of having an adequate and secure channel to facilitate both employees and third parties to make reports pertaining to any breach or suspected breach of laws, regulations or internal policies and procedures within Kenanga Group cannot be understated. Through the Group Whistleblowing Policy & Guidance Notes, Kenanga Group assures its stakeholders and general public that a sound and an effective whistleblowing framework is in place. Specifically, the whistleblowing framework stipulates, among others, the manner reports may be made, the safeguards, such as confidentiality and non-retaliations, that are accorded to persons making bona fide reports and the steps Kenanga Group undertakes towards ensuring that reports received are thoroughly investigated and the appropriate actions are taken. • Managing Conflict of Interest The workplace is one of the most common places where conflicts of interests may occur and it is important that the employees of Kenanga Group understand the nature and types of conflict of interest that they may come across in carrying out their responsibilities. The Group Conflicts Management Policy provides the principles and standards to observe and emphasises the ethical duty all employees of Kenanga Group have in order to ensure that their direct or indirect personal interests are not inconsistent with or interferes in any way with those of Kenanga Group. The Group Conflicts Management Policy sets forth the procedures for disclosing such conflicts of interest so that they may be reviewed, approved, managed, and monitored and escalated appropriately. In addition, it also provides common situations of conflicts of interest to enhance the employees understanding and so that they can identify the same if it arises. • Chinese Wall and Insider Trading Kenanga Group has in place the Group Chinese Wall Policy which is applicable to all employees within the Group that are likely to have access to confidential or material non-public price sensitive information. The Group Chinese Wall Policy establishes relevant guidelines to control the flow of confidential information or material non-public price sensitive information within Kenanga Group, to avoid the risk of possible breach of insider trading provisions, protect client confidentiality, as well as, manage conflict of interest. Towards this, the Control Room monitors and supervises employee trading to avoid potential violations of the applicable law and regulations on insider trading and accordingly, contributing to overall market integrity. • Competing Fairly and Ethically Kenanga Group believes that fair competitive practices lead to efficiencies and improvement of quality of products and services. Premised on this, the Group Competition Act Compliance Policy stresses on the importance of applying the principles and rules as provided in the applicable Malaysian competition laws, policies and guidelines. The Group Competition Act Compliance Policy is integrated to align with Kenanga Group’s businesses and operations, including dealings with any third parties. The Group Competition Act Compliance Policy is also built on ensuring an effective and clear stand against anti-competitive practices to prevent or minimise the risk of competition law infringements from occurring and to help Kenanga Group to promptly detect any infringements that do occur. • Common Reporting Standards (“CRS”) In year 2020, Kenanga Group had submitted the financial account information of non-resident clients to the Inland Revenue Board of Malaysia ( “IRBM” ) in August and November 2020 respectively in order to comply with the CRS requirement. The submission involved 77 entities and funds of Kenanga Group registered with the IRBM for CRS purposes. ETHI CS AND COMPL IANCE STATEMENT