Key Policies, Frameworks and Commitment Statements

At Kenanga, we have implemented a suite of policies and frameworks to instil ethically-sound business practices and high levels of integrity, in compliance with applicable laws, regulations and best practices.

Good Governance

Group Code of Ethics and Conduct for Employees

This Group Code of Ethics and Conduct for Employees (“Employees Ethics Code”) prescribes principles and standards that are observed in Kenanga Investment Bank Berhad and its subsidiaries (collectively “Kenanga Group”). This Employees Ethics Code reflects the ethics and values that form the underlying foundation of the business and operations of Kenanga Group and therefore, an integral part to demonstrate how things are done in Kenanga Group.

This Employees Ethics Code sets out the general expected behaviour from Employees of Kenanga Group and provides guidance for Employees’ conduct in regard to a given situation or circumstance. It also advocates the ideals to observe so as to maintain the highest standards of professionalism, integrity and conscientiousness in all dealings by Employees with each other as well with external parties.

The Employees Ethics Code is designed with the following objectives:

  1. To demonstrate Kenanga Group’s commitment and dedication to upholding its good name and to further drive Kenanga Group’s reputation of undertaking fair and ethical practices while continuously ensuring compliance with regulatory requirements
  2. To convey to both internal and external parties that Kenanga Group operates on principles of ethics and integrity which shall not be compromised under any circumstances and thus, maintain the confidence and trust of its stakeholders;
  3. To uphold the highest standards of personal integrity and professionalism amongst Employees and in this regard, to guide them to live up to such ethos by promoting and raising the Employees’ awareness and understanding of principles of ethics and integrity.
Group Code of Conduct for Vendors

The Group Code of Conduct for Vendors (“Vendors Conduct Code”) sets out the minimum standards in relation to the general business conduct and ethical practices expected of all vendors who engage with or undertake work for KIBB and its subsidiaries (collectively “KIBB Group”). This Vendors Conduct Code reflects KIBB Group’s values of ethics and integrity, and is principled on ensuring the highest standards of professional conduct from its vendors.

The Vendors Conduct Code is designed with the following objectives:

  1. KIBB Group is committed to unyielding standards of ethics and integrity in its business practices and relationships not only with its stakeholders but also with third parties who provide goods and services to KIBB Group. In this connection, it is paramount that principles of honesty, fairness and transparency guide KIBB Group’s dealings with the third parties.
  2. Over the years, KIBB Group has observed that the standard of its relationships with the third parties often has an impact on the quality of its client relationships. The quality of the products and services provided by the third parties would largely affect the characteristics of KIBB’s Groups offerings.
  3. This Vendors Conduct Code is aimed at helping KIBB Group and its vendors to build trusting and open relationship with the goal of developing a professional and efficient working rapport that will lead to mutually beneficial outcomes for all parties concerned

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E-Procurement Procedure

The key objective of this Policy is to ensure that the Group put in place a clear and centralised purchasing process after taking into consideration of the control and operational efficiency requirements for day to day purchasing activities.

Business Continuity Management Framework Policy

There are many possible risks that may threaten the business of Kenanga Group. The risks may include traditional emergency such as fires, floods as well as risks from physical and cyber terrorism, cyber-crime, computer and telecommunications failures, theft, employee sabotage and labour strike. Any of these risks are disruptive to the business and may have cascading effects on the infrastructure of Kenanga Group. BCM is important for the timely recovery of the business or service from an outage or disruption.

The BCM framework is designed with the following objectives:

  1. Establish the context for BCM within Kenanga Group;
  2. Articulate the vision and objectives of overall BCM program;
  3. Establish a common strategy that enables a uniform understanding and consistent approach to BCM; and
  4. Define the oversight structure and articulate the roles of the individual BU/SU/branch/ subsidiary.

Cyber Security

Cyber Security Policy

Kenanga Group is committed in ensuring that its business and operations are conducted within a safe and secure cyber and technology environment.

The policy documents Kenanga Group’s commitment to the management of cyber risk in providing appropriate levels of cyber security controls and to comply with the applicable laws, rules, regulations, and guidelines.

Cyber Security Policy (hereafter referred to as this ”Policy”) shall act as minimum requirements that emphasizes the significance of the appropriate management of cyber risk within Kenanga Group which includes but not limited to: –

  1. Cyber risk management strategy of prevention, detection, and response to cyber threats; and
  2. Communication and publication of the Group’s cyber security standards to its internal and external stakeholders
Data Loss Prevention Framework

This framework provides an overview on the directions, requirements and standards that shall be complied for Data Loss Prevention (DLP) implementation.

The objective of this Data Loss Prevention (DLP) Framework are as follows:

  1. Providing a framework for the DLP implementation and clear communication on all DLP activities within KIBB as well as its reporting requirements;
  2. Defining the roles and responsibilities within KIBB and the outlining procedures in implementing DLP;
  3. Ensuring consistent and acceptable DLP implementation within KIBB;
  4. Detailing a standardized methodology for DLP implementation;
  5. Providing a centralized consolidation of DLP implementation data.
Group Confidential Information Policy

The Group Confidential Information Policy (this “Policy”) stipulates policies for managing Confidential Information of the Group in order to comply with regulators’ requirements and safeguard the Group’s interest.

Retention, Archiving and Destruction Policy

This Policy aims to provide the guiding principles and rules for all personnel of Kenanga Group on the minimum required standard for data/information retention, archiving and destruction in accordance with the relevant laws and regulation

Regulatory Compliance

Group Anti-Money Laundering and Counter Financing of Terrorism (AML/CFT) Policy

Anti-Money Laundering & Counter Financing of Terrorism (“AML/CFT”) Policy of Kenanga Group (“Group AML/CFT Policy”):

  1. Is drawn up in accordance with the Anti-Money Laundering, AntiTerrorism Financing and Proceeds of Unlawful Activities Act 2001 (“ACT”) , Bank Negara Malaysia (“BNM”)s’ Guidelines on AML/CFT – Banking and Deposit-Taking Institutions (Sector 1) (“BNM’s Guidelines on AML/CFT for Sector 1”) and SC’s Guidelines on Prevention of Money Laundering and Terrorism Financing for Capital Market Intermediaries (“SC’s Guidelines”), and intended to comply with high standards of AML/CFT practice in all jurisdictions in which Kenanga Group operates with the objective to build a stronger and consistent AML/CFT compliance regime and culture through a group-wide policy.
  2. Sets the minimum standards on AML/CFT compliance and intended to ensure all employees of Kenanga Group understand and comply with the requirements and obligations as outlined in this Policy.
Group Anti-Fraud, Bribery and Corruption Policy

KIBB Group is committed to ensure that all its businesses and operations are conducted lawfully, ethically and with integrity. As part of this commitment, all forms of fraud, bribery and corruption (hereinafter collectively referred to as ‘financial crimes’) will not be tolerated.
This Policy emphasises zero tolerance of KIBB Group on the financial crimes. The same stance applies to all Third Parties who must ensure that they do not act corruptly or involve in fraudulent activities in dealing with any other person.

Objectives:

  1. The Policy articulates KIBB Group’s commitment to prohibit the financial crimes, and to comply with the applicable laws, rules, regulations and guidelines.
  2. The Policy specifies principles and standards for identifying and preventing the potential financial crimes in order to protect the integrity and reputation of the Group.
  3. The Policy provides a framework for anti-fraud, bribery and corruption programme of the Group.
  4. The Policy serves to communicate and publicise anti-fraud, bribery and corruption principles and standards of the Group to internal and external stakeholders.

More Information Here

Group Conflict Management Policy

The Policy sets out key matters in this area to ensure Kenanga Group’s businesses and operations are done in compliance with high standards of ethics and integrity.

The objective of this Policy are as follows:

  1. To set out an explanation of what constitutes conflict of interest and describing the types of conflict of interest which includes various situations or instances that may give rise to the same;
  2. To provide guidance to the Directors and Employees on the expectations imposed by Kenanga Group in identifying conflict of interest situations;
  3. To specify the appropriate steps to be taken by the Directors and Employees in preventing or managing conflict of interest situations; and
  4. To cater for the maintenance of an established and well-defined framework in dealing with conflict of interest situations within Kenanga Group.
Group Chinese Wall Policy

This Policy outlines Kenanga Group’s principles on Chinese Wall rule, handling and controlling of Material Non-Public and Price Sensitive Information (“MNPI”), and prevention of Insider Trading through effective trading restrictions on dealing in Securities.

This Policy also sets out the requirements of a high standard of care, skill and a culture of compliance to ensure that MNPI are properly handled within Kenanga Group’s business operations.

The primary objective of this Policy is to establish the relevant control mechanisms in managing the flow of MNPI within Kenanga Group while minimalise the risk of possible breach of any provisions on Insider Trading and conflict of interest as stipulated under CMSA, FSA, IFSA, Rules of Bursa Malaysia Securities Berhad and other rules, regulations and guidelines issued by the relevant authorities from time to time.

Group Whistleblowing Policy and Guidance Note

This Policy serves to guide Employees of Kenanga Group with a clear and safe internal reporting avenue irrespective of seniority, rank or status, to raise Concerns within Kenanga Group or any action that could be detrimental to the reputation or business of Kenanga Group and/or that may compromise the interest of shareholders, clients or the public without fear of retaliation.

Whistleblowing serves as a supplement to the formal system of corporate accountability wherein it is another safety net that is aimed at operating when other forms of accountability fail.

The objective of this Policy is to:

  1. Set out Kenanga Group’s framework for the reporting of any Concerns about behavior, conduct, practice, deeds and/or omissions that might be either unlawful or irregular (collectively called “Malpractice”) within Kenanga Group.
  2. Provide all Kenanga Group Employees with the essential knowledge to understand how to utilize this reporting tool.

This Policy also provides safeguards to Whistleblowers meeting the required conditions from retaliation as a result of having made the disclosure or blown the whistle. This safeguard shall be of great concern to the Whistleblowers and is the turnkey for the effectiveness of this Policy.

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Group Gifts, Entertainment and Hospitality Policy

This Group Gifts, Entertainment and Hospitality Policy (“GGEH Policy”) reinforces the commitment of Kenanga Investment Bank Berhad and its subsidiaries (collectively, “KIBB Group”) in ensuring the highest standards of ethics and integrity amongst Employees in relation to their conduct concerning the offering or accepting of Gifts, Entertainment or Hospitality to or from Third Parties.

The objectives of this GGEH Policy are:

  1. To provide clarity on and highlight KIBB Group’s position in relation to Employees offering and accepting Gifts, Entertainment or Hospitality to or from any Third Party;
  2. To communicate to the Employees the manner in which any Gifts, Entertainment or Hospitality is to be dealt with towards continuously ensuring that business and operations of KIBB Group are conducted in a transparent manner; and
  3. To ensure that KIBB Group’s policies and procedures are consistent with and aligned to its overall standards of ethics and integrity and to raise the Employees’ awareness of the same.

This Policy also provides safeguards to Whistleblowers meeting the required conditions from retaliation as a result of having made the disclosure or blown the whistle. This safeguard shall be of great concern to the Whistleblowers and is the turnkey for the effectiveness of this Policy.

Group Competition Act Compliance Policy

The Group Competition Act Compliance Policy (“Policy”) document is to:

  1. Set out Kenanga Group’s compliance framework with regards to the Competition Act 2010 (“CA 2010”), in which our internal procedures for compliance and possible infringements are incorporated; and
  2. Provide all Kenanga Group employees with basic guidance and essential knowledge to understand how the CA 2010 applies to the business activities of the Kenanga Group, in order to identify and avoid arrangements or conduct/behavior which are or may be prohibited under the CA 2010.

Client Experience

Advertising Policy

The Group Advertisement Policy (this “Policy”) aims at facilitating compliance of the Group to the relevant laws, rules, guidelines and directives that are in force with regards to promoting products or services in the form of advertising to the public. This Policy signifies the Group’s acknowledgement and commitment of their roles and responsibilities to prevent the Group from any penalties or disciplinary actions from the regulators.

Social Media Policy

The Group Advertisement Policy (this “Policy”) aims at facilitating compliance of the Group to the relevant laws, rules, guidelines and directives that are in force with regards to promoting products or services in the form of advertising to the public. This Policy signifies the Group’s acknowledgement and commitment of their roles and responsibilities to prevent the Group from any penalties or disciplinary actions from the regulators.

Media Relations Policy

The Group Media Relations Policy (this “Policy”) establishes guiding principles and a framework within Kenanga Investment Bank Berhad and its subsidiaries (“the Group”) in its engagement with print, electronic and broadcast media, with the exception of advertisement and social media. For advertisement and social media, please refer to the Group Advertisement Policy and Group Social Media Policy.

This Policy covers the Group’s dissemination of information to members of the media, ensuring it is accurate, relevant, consistent and coordinated. Adherence to this Policy assists the Group in maintaining a professional and constructive relationship with the media. This Policy applies to all official media communications including but not limited to, press releases, media enquiries, interviews, media briefing and press conferences.

Group Complaint Handling Policy & Procedure

This procedure defines the directions, requirements and service standards in complaints handling.

The objective of this procedure is to standardize the procedure of handling complaints for Kenanga Group (“Group”).

Digitalisation

iLeap Application Governance Policy

iLeap Application Governance Policy iLeap is a low-code application development platform which may be used to develop applications for business uses in an efficient and convenient manner. This workflow software provides application development platform in a modern way by offering simplified tools to create and develop enterprise application for all staffs of Kenanga Group as it requires minimal IT knowledge to operate and utilized. This Procedure shall serve as a governance guide on the development of iLeap applications.

Responsible Investing

ESG Blueprint and ESG Integration Framework

Kenanga Investors Group developed an ESG Blueprint and ESG Integration Framework to embed ESG factors into its investment process throughout the investment life cycle. Its ESG integration strategies are underpinned by effective screening mechanisms while practising active stewardship by engaging with stakeholders and exercising our voting rights in investee companies.

Statement on Application of the Principles of the Malaysian Code for Institutional Investors

Kenanga Investors Group (“Kenanga Investors” or “KIG”), our Group’s asset and wealth management division, is committed to work with asset owners, regulators and a broad spectrum of market participants to embed ESG into the heart of our investment process. KIG has been a signatory to the Malaysian Code for Institutional Investors (“Code”) since 2017, which aims to set out the broad principles of effective stewardship by institutional investors such as their disclosure of stewardship policies, monitoring and engagement with investee companies, as well as, managing conflict of interests. KIG also recently secured membership at the Institutional Investors Council (“IIC”), in a bid to demonstrate its commitment to the ESG cause.

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Diversity, Inclusion and Wellbeing

Preventing and Eradicating Sexual Harassment in the Workplace Procedure

The Group should be a safe, comfortable and conducive work environment for all employees. All employees should be treated with dignity and respect and everyone has a responsibility to uphold these values to create a supportive work environment. Sexual harassment adversely affects work performance, productivity, morale and therefore, the general work environment. It also adversely affects the Group’s corporate image. All forms of sexual harassment in the workplace will not be tolerated and the Group is committed to helping to prevent and eradicate it.

It is all in our interests to see that this issue be addressed promptly and effectively. The establishment of this Code of Practice on sexual harassment will allow everyone to be able to identify its occurrence and be aware of their responsibilities and the steps required to tackle any incident of harassment should it arise.The aim of this Code of Practice is to provide guidelines in preventing and eradicating sexual harassment in the workplace.

Gender Diversity Policy Statement

Gender Diversity Policy Statement Committed to promoting gender diversity in the workforce and aligning our Board’s representation in accordance with the updated MCCG 2021 requirement

Human Rights Policy Statement

Human Rights Policy Statement Zero tolerance of any violation of human rights, including forced and compulsory labour, child labour, as well as, discrimination with respect to employment in our operations in compliance with the applicable employment and labour law and practices

Talent Attraction and Management

Human Rights Policy Statement

Employees of KIBB Group are expected to maintain good discipline and comply with the law and the Company’s rules, policies and procedures, including but not limited to the Group Code of Ethics and Conduct for Employees at all times. Discipline can promote the objectives of the Group as well as the well-being and safety of its Employees.

This Policy serves to promote a disciplined and conducive work environment where misconduct of Employees within the KIBB Group is dealt with in a fair and equitable manner.

Learning and Development Policy

For Kenanga Group (“Group”), the training and continued professional development of our employees is crucial to the continued success of the business. Learning and Development (“L&D”) in Kenanga shall focus on enhancing employees’ efficiencies through quality learning programs and initiatives.

The Policy governs the Talent & Learning Management Section (“GHR-TLM”) in providing effective learning and talent development services and initiatives that will contribute towards a positive career and/or personal development experience of Kenanga Group’s employees. The Policy provide guidelines to employees in participating in courses that are obligatory and those that will enhance their self-development and performance at the workplace.

Flexible Work Arrangement Policy

This Policy serves to promote a disciplined and conducive work environment where misconduct of Employees within the KIBB Group is dealt with in a fair and equitable manner. Employees of KIBB Group are expected to maintain good discipline and comply with the law and the Company’s rules, policies and procedures, including but not limited to the Group Code of Ethics and Conduct for Employees at all times. Discipline can promote the objectives of the Group as well as the well-being and safety of its Employees.

Group Procedure on Recruitment and Staffing Management

Recruitment and Staffing Management policies are designed to provide Kenanga Group with candidates who are fit and proper for various positions within the organisation. Successful implementation of the Group Policy on Recruitment and Staffing Management (this “Policy”) includes effective manpower planning and budget, timely recruitment to fill vacant or newly created positions where suitable candidates could not be sourced or trained internally, identification of key personnel who could be trained, promoted or deployed for positions under planned expansion and manpower requirements.

This Policy serves as a guidance for all employees and Board of Directors on Recruitment and Staffing Management policies that is implemented throughout Kenanga Group.

Compensation and Benefits Policy

The Group’s most important asset is its people. Therefore, the Group places great emphasis in providing a good Reward Structure (compensation and benefits scheme) which is competitive within the Financial Services Industry as well as providing job enrichment to attract, retain and motivate its employees.

This Policy serves to regulate the compliance of Compensation and Benefits Policy on a basis that is consistently implemented within the Group.It also acts as a ready source of reference for the Management and employees with regards to the Compensation and Benefits Policy of the Group.

Group Policy on Performance Management System

The Group Policy on Performance Management System (the Policy) serves to provide an environment where all Employees understand the impact of their contributions to the achievement of Kenanga Investment Bank Berhad Group ’s business goals and are provided the opportunity for ongoing personal growth.

This goal is accomplished through an effective performance management system (PMS) that guides the way we plan, manage, review and reward performance, support career development of employees and address performance that does not meet expectations.

Anti-Discrimination Policy Statement

Anti-Discrimination Policy Statement A strictly non-discriminatory approach for all HR practices throughout the Group, including processes related to recruitment, redundancy, training and development allocations, as well as remuneration packages.

Community Investment

Sponsorship Policy

The Policy aims to establish the framework and guidelines within Kenanga Investment Bank Berhad and its Group of Companies for sponsorship alliances between Kenanga Investment Bank Berhad and its Group of Companies and other sectors, e.g. corporations, foundations, individuals, professional associations, government/regulatory agencies, non-government organisations etc. Sponsorship is part of the medium to build and strengthen partnerships between an organisation and its various stakeholders. Such alliances should complement our Corporate Social Responsibility (“CSR”) credo/structure, create awareness of Kenanga as a caring corporation and also generate branding exposure.

Our Approach to Community Engagement

Empower and uplift local communities by supporting social enterprises including improving outreach through employee volunteerism

Climate Impact

Climate Change Risk Management Framework

Climate change is one of the key developing sustainability topics in the financial services industry, presenting both significant risks and emerging opportunities. The Climate Change Risk Management Framework (this “Framework”) focuses on responsible financing and investment, taking into consideration of the climate change risk impact on customers and investment assets.

The objective of this Framework is to embed climate change-related risk considerations into the governance process, business strategy and operations, reporting and disclosure as well as risk management system of Kenanga Investment Bank Berhad and its subsidiaries (the “Group”).

Our Approach to Managing Operational Environmental Footprint

Our Approach to Managing Operational Environmental Footprint Committed to reduce our operational environment footprint of our business activities by optimising our energy and resource consumption, adopting responsible waste management practices and empowering our employees as well as, our vendors, to be environmental stewards