99 KENANGA INVESTMENT BANK BERHAD Annual Report 2022 ETHICS AND COMPLIANCE STATEMENT Further to the dissemination of the frameworks, guidelines and circulars, GRCS follows up on actions required of the affected divisions or departments up to completion and ensures compliance with the revised or new requirements via our Regulatory Issuances Impact Review (“EDGE”) review exercise. In this regard, the EDGE serves as a tool to assist compliance of the divisions or departments with the requirements particularly where actions are required to be taken with regard to internal policies, procedures or controls. ENHANCED INITIATIVES ON ETHICS AND COMPLIANCE With the continued support of our Board and Senior Management, Kenanga had successfully undertook numerous initiatives in 2022 to further strengthen our internal controls. All new and ongoing initiatives were carefully considered, reviewed and reasonably challenged to guarantee positive acceptance and implementation. • Independent Review of Kenanga’s Anti-Bribery and Corruption (“ABC”) Compliance Program Kenanga had appointed Baker Tilly MH Consulting Sdn Bhd (“BTMHC”) as an independent third party to undertake an assessment on the effectiveness of ABC framework and compliance of Kenanga with the Guidelines on Adequate Procedures under Section 17A(5) of Malaysian Anti-Corruption Commission Act 2009 (“MACCA”) as well as Securities Commission Malaysia’s letter dated 16 March 2021 on Observations and Good Practices Relating to Compliance with Corporate Liability Provision (“SC’s Observations”). The independent review was conducted based on forty-one (41) observations criteria established pursuant to T.R.U.S.T principles of the Guidelines on Adequate Procedures and the outcome indicated that Kenanga has complied with forty (40) observations criteria (i.e. 97.6%). Generally, BTMHC’s observations and recommendations in relation to steps taken by Kenanga to address compliance with Section 17A of the MACCA as well as SC’s Observations concluded that ABC Compliance Program of Kenanga is reasonable and effective, in all material respects, in accordance with the Guidelines on Adequate Procedures. The only outstanding observation where Kenanga is rated as ‘Partially Compliant’ is in relation to group-wide corruption risk assessment which is ongoing. Notwithstanding the achievement by Kenanga as independently assessed by BTMHC, we recognise that best practices should always grow and evolve in tandem with and to meet the ever-changing business landscape. As such, Kenanga is committed to adapting to the business and regulation changes over time, and to remain compliant with the laws that govern our business while constantly developing and improving in accordance with the best standards of the industry. Overall Scoring: 40/41 Compliance Percentage: 97.56% 5/5 Top Level Commitment 7/8 Risk Assessment 9/9 Undertake Control Measures 5/5 Systematic Review, Monitoring & Enforcement 11/11 Training and Compliance
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