115 How We Are Governed Financial Statements Shareholders’ Information Additional Information The Chinese Wall Policy establishes guidelines to avoid the risk of possible breach of insider trading provisions and protect client’s confidentiality, and ultimately serve to prevent possible conflicts of interest issues. In managing the exposure or misuse of confidential and MNPI, the employees’ trading is also monitored and supervised. This will further help avoid potential violations of insider trading law and regulations therefore, contribute to overall market integrity. • Gifts, Entertainment and Hospitality No matter how well-meaning or well-intentioned a gift is, the potential exists for impropriety or the appearance of impropriety to be present. A gift policy ensures that employees adhere to the code of conduct in giving or accepting gifts or other tokens of appreciation. The Group Gifts, Entertainment and Hospitality Policy (“Gifts Policy”) has been adopted to address such issues and reinforces the commitment of Kenanga Group in ensuring the highest standards of ethics and integrity amongst employees. The Gifts Policy guides the employees on the manner in which any gifts, entertainment or hospitality is to be dealt with towards ensuring that business and operations of the Group are conducted in a transparent manner. • Whistleblowing Kenanga Group acknowledges whistleblowing as an important means allowing the Group to be alerted of any actual or potential improper conduct that may compromise integrity, competence and professionalism of the Group. It provides a mechanism for employees or external parties to raise concerns through well-defined and accessible confidential disclosure channels. As part of good corporate governance, Kenanga Group has adopted the Group Whistleblowing Policy and Guidance Notes that sets out avenues for legitimate concerns to be reported, and to be objectively investigated and addressed. Any individuals will be able to raise concerns about illegal, unethical or questionable practices in confidence and without the risk of reprisal. • Anti-Trust and Fair Competition Practices Kenanga Group is committed to acting fairly, responsibly and professionally when dealing with its clients. The Board and Senior Management set the tone from the top as the moral compass of the Group, inculcating a strong culture of fair business dealing to ensure that we operate in a transparent, ethical and sound manner. The Group Competition Act Compliance Policy (“Competition Policy”) specifies the principles of fair business dealing of Kenanga Group and prohibits any practices that may be construed as anti-competitive. The Competition Policy is also built on ensuring an effective and clear stand to prevent or minimise the risk of competition law infringements and to help the Group to promptly detect any infringements that do occur. • Common Reporting Standard (“CRS”) In compliance with the CRS requirements, Kenanga Group had submitted the financial account information of nonresident clients to the Inland Revenue Board of Malaysia (“IRBM”) in July and September 2021 respectively. The submission involved eighty-seven (87) entities and funds of Kenanga Group that have been registered with the IRBM for CRS purposes.
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