104 WE ARE KENANGA LEADERSHIP MESSAGE VALUE CREATION MODEL KENANGA INVESTMENT BANK BERHAD ANNUAL REPORT 2023 ETHICS AND COMPLIANCE STATEMENT Whistleblowing As specified above, Kenanga Group has implemented the Group Speak Up Policy, enabling individuals to voice their concerns regarding any unlawful or irregular behaviours, practices, or omissions. Out of the eighty-six percent (86%) employees who participated in our biennial Survey on Ethics and Integrity Culture at Workplace 2022, more than ninety percent (90%) expressed confidence in their ability to raise concerns within Kenanga Group without fear of retaliation. This indicates effective communication by the Group regarding our commitment and resolve to address any unlawful or irregular behaviours, practices, or omissions appropriately. Gifts, Entertainment and Hospitality The Group Gifts, Entertainment, and Hospitality Policy (“GGEH Policy”) serves as a control mechanism for situations that may constitute a conflict of interest or could potentially create the appearance of such a conflict in Kenanga Group’s business dealings with external parties. This Policy elucidates Kenanga’s stance on giving and accepting gifts, entertainment, and hospitality in business transactions, while upholding the utmost standards of ethics and integrity. 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. Hence, the Group Chinese Wall Policy (“Chinese Wall Policy”) is developed to manage the flow of confidential and material non-public and price sensitive information (“MNPI”) between the divisions and departments of Kenanga. The Chinese Wall Policy outlines requirements in managing inside information and establishes internal control mechanisms to be adhered by all employees, in order to minimise the risk of insider trading and potential breach of laws and regulations. Every employee is required to maintain the confidentiality of all MNPI, which comes to their knowledge during the course of their employment and are not to pass any MNPI to any person, unless in accordance with the Chinese Wall Policy. Anti-Trust and Fair Competition Practices Kenanga Group is dedicated to conducting business with fairness, responsibility, and professionalism in all client interactions. The Board and Senior Management establish the ethical standards from the helm, fostering a robust culture of equitable business practices to ensure transparent, ethical, and prudent operations. The Group Competition Act Compliance Policy (“Competition Policy”) outlines the Group’s commitment to fair business practices and prohibits any actions that could be interpreted as anti-competitive. Additionally, the Competition Policy emphasises the importance of maintaining a clear and effective stance to prevent or minimise the risk of competition law violations, as well as aiding the Group’s in promptly identifying any such infringements that may occur. Managing Conflict of Interest The Group Conflict Management Policy (“Conflicts Policy”) outlines the policies and guiding principles for addressing conflicts of interest. It delineates two (2) main categories: personal and business-related conflicts of interest and specifies the scenarios that may fall under each category. This was implemented to emphasise the significance of identifying potential conflicts that may arise in carrying out employees’ entrusted responsibilities. In addition to the Conflicts Policy, the Group has adopted the Guidance on Conflict of Interest (“Conflicts Guidance”) to offer additional support in recognising and addressing personal and business-related conflicts of interest. This guidance reinforces the shared responsibility of all parties within the Group to identify, report, and address conflicts of interest effectively. Employees, departments, divisions, and subsidiaries within Kenanga Group must disclose any actual, potential, or perceived conflicts of interest, whether personal or business-related. This mandate is founded on the recognition that such conflicts may compromise the ability to act impartially and in the best interests of the Group, necessitating appropriate steps for effective management. In addition to outlining the threshold limits and approval procedures for gifts, entertainment, and hospitality that Kenanga employees may offer or receive, the GGEH Policy strictly prohibits employees from offering or accepting such items with the intent to exert undue influence on any party in exchange for business dealings.
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