114 Kenanga Investment Bank Berhad Annual Report 2021 Our Sustainability Approach About This Report We Are Kenanga Message From Chairman and GMD • Managing Conflict of Interest Conflict of interest may occur whenever interest of an individual within Kenanga Group in a particular subject may lead to actions, activities or relationships that undermine and may place the Group at a disadvantage. This is a critical aspect and of importance to Kenanga Group as we are committed to preserve the interests of our stakeholders. As such, Kenanga Group expects all directors and employees to act towards the Group’s fundamental interests. Such relationship is based on mutual trust and the expectation that ultimately, the interests of Kenanga Group, our stakeholders and that of our directors and employees are all aligned. To address the situation, the Group Conflict Management Policy (“Conflicts Policy”) sets forth the policies and guiding principles in managing conflicts of interest. The Conflict Policy was revamped in 2021 to introduce two (2) broad categories of personal and business-related conflicts of interest and detail out the situations that may constitute the same. This was done to make clear the importance of identifying the various potential conflicts that may arise in the execution of the responsibilities entrusted upon Kenanga Group’s employees. Supplementary to the Conflict Policy, the Guidance on Conflict of Interest (“Conflicts Guidance”) was also introduced to provide clarity and assist the employees on management of personal and business-related conflicts of interest within Kenanga Group. The Conflicts Guidance further reinforces the primary responsibility of all parties in the Group in identifying, reporting and managing conflicts of interest. • Code of Conduct for Employees Kenanga Group places high importance not only to compliance with regulatory requirements and internal policies and procedures but also to the application of ethical principles in carrying out our business activities. In this regard, our employees are the most valuable assets in ensuring such objectives are met. The Group Code of Ethics and Conduct for Employees (“Employees Ethics Code”) sets out the general expected behaviour from the employees and provides guidance for the employees’ conduct in regard to a given situation or circumstance. It prescribes principles and standards to be observed in Kenanga Group and reflects the ethics and values that form the underlying foundation of the business and operational activities of the Group. The Employees Ethics Code also advocates the ideals to be observed so as to maintain the highest standards of professionalism, integrity and conscientiousness in all dealings by the employees with each other as well as with external parties. It is an integral part to demonstrate how things are done in Kenanga Group. • Code of Conduct for Vendors Kenanga Group recognises the importance of having a written code of conduct for its vendors who provide goods and services in relation to the business and operations of the Group. This is important to clearly specify responsibilities of the vendors to comply with the Group’s internal policies, as well as the applicable regulatory requirements. The Group Code of Conduct for Vendors (“Vendors Conduct Code”) has been introduced to stipulate the general business conduct and ethical practices expected of all vendors, who engage with or undertake work for Kenanga Group. The Vendors Conduct Code has also been made fundamental clause in legal agreements signed with the vendors as well as an essential element of Kenanga Group’s tender documents in order to provide potential vendors with prior notice on the principles and standards required of them. • Chinese Wall and Insider Trading Kenanga Group has an obligation to ensure that information pertaining to its business and clients, and all activities of the clients remain confidential. As such, the Group Chinese Wall Policy (“Chinese Wall Policy”) has been put in place to establish information barrier between the divisions and departments of the Group to prevent and/or control the flow of confidential and material non-public and price sensitive information (“MNPI”).
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