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122 KUMPULAN WANG PERSARAAN (DIPERBADANKAN) FoR BEttER GovERNANcE

RISK MANAGEMENT
AND COMPLIANCE

Chinese Wall Policy Compliance Visits to EFMs

KWAP has implemented Chinese Wall Policy since 2014. KWAP has implemented visits to respective EFMs since
KWAP’s Chinese Wall Policy was introduced to establish 2017 and have successfully completed the first cycle of
procedures to control the flow of material non-public and visits to domestic EFMs in 2020. We are currently in the
price sensitive information within KWAP to minimise the second cycle and the EFM visits are conducted annually,
risk of insider trading and potential breach of laws and with visits to up to six domestic EFMs, at most. The objective
regulation. It also helps to ensure that the possession of of these visits are to ensure that the EFMs’ activities and
material non-public and price sensitive information does practices comply with the approved Investment Mandates,
not give rise to the risk or perceived risk of a conflict and to ensure their internal risk controls are in place.
between the public interest, KWAP interest and the
employee’s personal interest. Regulatory Compliance Depository
The Compliance team has established a Regulatory
Automated Self-Compliance Checklist
Compliance Depository for KWAP and its subsidiaries.
KWAP has implemented automated self-compliance It was published on the KWAP Intranet Portal in September
checklist where all attestation process is performed via a 2022. It is an online depository which allows users to
compliance system. The compliance system covers both search the regulatory requirements that are applicable
regulatory and internal requirements. The self-compliance to all departments in KWAP and KWAP subsidiaries.
checklist will be filled in by respective department’s The depository covers regulations, which include but are not
compliance liaison officers and approved by their Head limited to Acts of Parliament, Minister of Finance’s Decrees,
of Department via the system. The attestation exercise is Pekeliling Perkhidmatan and regulatory requirements
performed on a biannual basis for all investment-related issued by regulatory bodies.
departments and annually to other departments including
KWAP’s subsidiaries. Know Your Counterparty screening
The compliance team performs Know Your Counterparty
Compliance Review Exercise
(KYC) screening and checking for KWAP’s counterparties.
To ensure we are doubly confident in our compliance This screening exercise is to identify financial crime
process, KWAP has embarked in an initiative called namely Anti-Money Laundering/Counter Financing of
Compliance Review, where periodic review exercises are Terrorism (AML/CFT), regulatory risk and reputational risk
conducted on departments within KWAP. The purpose of for counterparties that may put KWAP in a bad light. This
this exercise is to ensure the veracity of the self-compliance is a step taken by compliance to ensure the team captures
checklists declared and submitted by the respective any Red Flags as KYC screening checks the real identity or
departments via the compliance system. This exercise background of the counterparties, detect potential
is conducted through performing sample tests on the financial fraud, political exposure or corruption, and
requirements stipulated in the self-compliance checklist. prevents KWAP from being used for criminal activities like
money laundering.