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FoR betteR GoveRnAnce Annual Report 2022 121

Compliance Process
Compliance activities are closely intertwined with compliance developments on the global front, existing legal
requirements as well as the KWAP’s policies and procedures. The following diagram illustrate the compliance process
and general approach taken in managing the compliance risk.

Identifying the relevant regulations and
Identification internal requirements that business units
need to comply with.
Identification
Assessing the relevant regulations and
Assessment internal requirements to ensure compliance
by business units.
Validation Asessment
Semi-annual and/or annual of periodic
attestation via Self Compliance Checklist
Attestation
and declare any incident of non-compliance
during the reporting period.
Monitoring
and Attestation
Reporting Monitoring Monitor the controls and process.
and Report any non-compliance incident to
Reporting Management.

Perform periodic compliance review to
Validation assess the veracity of approved Self-
Compliance Checklist via sample checks.

Value of Compliance
As business models change, new technologies emerge, The compliance culture has also been expanded to our
and new investment asset classes increase amidst the external fund managers (EFMs). Our EFMs are
intense focus on operational efficiencies. KWAP has required to declare on monthly basis on their
never been more exposed to such a myriad of risks. adherence to KWAP Investment Management
In this regard, KWAP’s Board and Senior Management Agreement and to immediately report to KWAP on any
have extended their full support and cooperation in moving breach of the approved Investment Mandate. This is to
the compliance to the front-line. They have done this by ensure that the EFMs are always adhering to the guidelines
establishing the tone from the top, which is quite simply, imposed on them. In addition, EFMs are also required
to comply with all rules and regulations and employ to declare on a monthly basis that the parameters of the
ethical behavior. All employees are aware that the Board compliance requirements are captured in the relevant
and Senior Management must take uncompromising system.
stance if such trust is breached. The compliance unit is
increasingly becoming a point-of-reference and advisor for
key strategic initiatives that KWAP embarks on.