Ethics & Governance
At Kenanga Group, ethical culture forms the foundation of everything we do and shapes all that we aspire to be
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
The Group Code of Ethics and Conduct for Employees reflects the ethics and values that form the underlying foundation of the business and operations of Kenanga Group. The Code 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 with external parties. The Code is periodically reviewed for its adequacy and effectiveness, and approved by the Board, as when the need arises.
The Code reflects values of ethics and integrity of Kenanga Group, and is principled on ensuring the highest standards of professional conduct from its vendors. The Code sets out the minimum standards of general business conduct and ethical practices expected of all vendors who engage with or undertake work for Kenanga Group.
Our robust Know Your Vendor Assessment requires vendors to undergo an extensive due diligence process that reviews risk indicators including corruption including anti-money laundering risk that culminates in a score that serves as a guide for Kenanga to manage its front-end risk. The Code is communicated to all our vendors and vendors are required to understand and adhere to our Group Code of Conduct for Vendors.
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.
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:
- Establish the context for BCM within Kenanga Group;
- Articulate the vision and objectives of overall BCM program;
- Establish a common strategy that enables a uniform understanding and consistent approach to BCM; and
- Define the oversight structure and articulate the roles of the individual BU/SU/branch/ subsidiary.
The Group Conflict Management Policy provides guidance towards identifying and managing personal conflict of interest and business-related conflict of interest that are relevant to activities of Kenanga Group. In this regard, the Policy sets out key matters in relation to conflict of interest to ensure that businesses and operations of Kenanga Group are done in compliance with high standards of ethics and integrity.
The Group Gifts, Entertainment and Hospitality Policy clarifies the position of gifts, entertainment and hospitality in the conduct of business while ensuring that the highest standards of ethics and integrity in Kenanga Group are preserved. The Policy specifies the appropriate treatments for incoming and outgoing gifts, entertainment and hospitality, and provide clear guidance on managing potential conflict or non-compliance issues that may arise in this respect.
Cyber Security
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: –
- Cyber risk management strategy of prevention, detection, and response to cyber threats; and
- Communication and publication of the Group’s cyber security standards to its internal and external stakeholders
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:
- Providing a framework for the DLP implementation and clear communication on all DLP activities within KIBB as well as its reporting requirements;
- Defining the roles and responsibilities within KIBB and the outlining procedures in implementing DLP;
- Ensuring consistent and acceptable DLP implementation within KIBB;
- Detailing a standardized methodology for DLP implementation;
- Providing a centralized consolidation of DLP implementation data.
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.
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
Anti-Money Laundering & Counter Financing of Terrorism (“AML/CFT”) Policy of Kenanga Group (“Group AML/CFT Policy”):
- 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.
- 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.
The Group Anti-Fraud, Bribery and Corruption Policy emphasises Kenanga Group’s zero-tolerance approach to all forms of fraud, bribery and corruption. The same stance applies to any person who carries out business or undertake business activities with, for and on behalf of Kenanga Group including provision of goods or services and they must not act corruptly or be involved in fraudulent activities in dealing with any other person.
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.
Kenanga Group’s Speak Up Framework is for the reporting of any concerns made in good faith about behaviour, conduct, practice, deeds and/or omissions that might be either unlawful or irregular that implicates Kenanga Group, by any party without fear of reprisal.
The Group Competition Act Compliance Policy echoes the national effort in advancing economic development by promoting and protecting the process of competition thereby protecting the interest of clients. The Policy provides essential knowledge to understand and apply the Competition Act 2010 in carrying out business activities of Kenanga Group.
Client Experience
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.
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.
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.
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 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
Kenanga Investors Group developed 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.The ESG blueprint and framework for integration of ESG/responsible investment into investment strategy were approved by KIB’s Board and Investment Sub-committee.
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.
Diversity, Inclusion and Wellbeing
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 Committed to promoting gender diversity in the workforce and aligning our Board’s representation in accordance with the updated MCCG 2021 requirement
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.
We are in compliance with the Children and Young Persons (Employment) Act 1966, where no child under the age of 15 years old and/or young person under the age of 18 years old, are under the Company’s employment.
We adhere to Malaysian labour laws and regulations consistent with the national statutory minimum wage and we offer competitve salaries especially in relation to the industry average and based on candidate’s skills and competencies. All our employment terms and conditions are currently in English and translation into Bahasa Malaysia shall be provided upon request.
We adopt non-discriminatory approach and equal opportunity throughout the Group’s HR practices including process related to recruitment, performance management, learning and development as well as remuneration packages.
We are committed towards providing an inclusive culture that supports all employees, regardless of their respective race, religion, gender, age, ethnicity, disability and/or nationality, social status, as well as education or qualification, and declaration on sexual orientation is not a practice in Kenanga. Our decisions are premised on business needs and prospective candidate’s merit.
Talent Attraction and Management
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.
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.
The Company is committed in ensuring continuous compliance with the current and the amended Employment Act.
We are committed to ensure that we will be fully complying with the working hours and overtime set by the regulators. We have come out with internal control to ensure overtime does not exceed the law requirement. We also provide flexible work time arrangement for our employees to perform duties.
This Policy is necessary for the organisation in order to have competitive edge while catering for societal norm changes and family dynamics. There are three types of flexible work arrangement that are available for Kenanga employees including Flexible Work Times, Part Time Work, and Block Time Off Due to Personal or Family Reasons.
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.
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.
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.
Our Performance Management System is accessible and applies to employees of all levels with identical scoring process and mechanism regardless of their respective race, religion, gender, age, ethnicity, disability and/or nationality, social status, as well as education or qualification, and declaration on sexual orientation is not a practice in Kenanga. Our senior management employees’ Balance Score Card development and appraisal are independently reviewed by the respective Board Committees, Group Governance, Nomination & Compensation Committee and respective Boards. Our decisions are premised on business needs and prospective candidate’s merit.
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.
We support the youth employability initiatives initiatives steered by the Government such as under Penjana and Jamin Kerja schemes. In addition, for many years, we have successfully placed many students from local and foreign universities for internship program under various departments in Kenanga Group.
We are committed to ensure that we will be fully complying with the amended Employment Act which will be implemented in January 2023. This means any employment of interns within a period of 6 to 24 months shall be accorded with the Sections as per the Employment Act.
Community Investment
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.
Kenanga continuously strives to promote open, two-way communication with our employees. Employees are encouraged to share their views and concerns through dialogues and discussions. We continue to empower and uplift local communities by supporting social enterprises through targeted community investment in line with our business values and strategy as well as improving outreach activities through employee volunteerism. We have set specific targets to achieve 2000 volunteering hours by 2025.
Climate Impact
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 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