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ENRICHING PERFORMANCE AND COMMITMENTS ENRICHING ACCOUNTABILITY AND INTEGRITY ENRICHING RESILIENCE AND SUSTAINABLE GROWTH OTHER INFORMATION

Value of Compliance officers and approved by their Head of Department/
Function via the system. The attestation exercise is
Business models change, new technologies emerge performed on a bi-annual basis for all the investment-
and new investment asset classes are adopted. All related departments/functions and annually for other
amidst an intense focus on operational efficiencies and departments/functions including KWAP’s subsidiaries.
accompanied by a dynamic global and local compliance
environment. KWAP has never been more exposed to Compliance Review Exercise
such a myriad of risks. In this regard, KWAP’s Board and To ensure we are doubly confident in our compliance
Senior Management have extended their full support process, KWAP employs a programme we call
and cooperation in moving compliance to the front line. “Compliance Review”, where periodic review exercises
They have done this by establishing the tone from the are conducted on departments and functions within
top, which is quite simply, to comply with all rules and KWAP. This exercise ensures the veracity of the Self-
regulations and employ ethical behavior. All employees Compliance Checklists declared and submitted by the
are aware that the Board and Senior Management respective departments/functions via the compliance
take an uncompromising stance on compliance. The system. This exercise is conducted through performing
Compliance Section is also increasingly becoming a sample tests on the requirements stipulated in the
point-of-reference and advisor for key strategic initiatives Self-Compliance Checklist. It has been successful
that KWAP embarks on.
in identifying potential compliance pain points and
The compliance culture has also been expanded to providing a solution to resolve these issues.
our External Fund Managers (EFMs). Our EFMs are Risk and Compliance Visits to EFMs
required to declare on a monthly basis, their adherence
to the KWAP Investment Management Agreement and KWAP has implemented visits to respective EFMs
to immediately report to KWAP on any breach of the since 2017 and has successfully completed the second
approved Investment Mandate. This is to ensure that the cycle of visits to domestic EFMs and initiated visits to
EFMs are always adhering to the guidelines imposed on international EFMs in 2023. The objective of the visits is
them. In addition, EFMs are also required to declare on to ensure that the EFMs’ activities and practices comply
an annual basis that the parameters of the compliance with the approved Investment Mandates and to ensure
requirements are captured in their relevant systems. their internal risk controls are in place. Furthermore, the
visit to international EFMs offered KWAP opportunities
Chinese Wall Policy
to learn about the best practices or new developments
KWAP has implemented Chinese Wall Policy since 2014. adopted on risk and compliance controls.
KWAP’s Chinese Wall Policy was introduced to establish Know Your Counterparty (KYC) Screening
procedures to control the flow of material non-public and
price sensitive information within KWAP to minimise the The Compliance team performs KYC screening and
risk of insider trading and potential breach of laws and checking for KWAP’s counterparties using a third-party
Capital Markets and Services Act (CMSA). It also helps screening platform. This screening exercise is to identify
to ensure that the possession of material non-public and financial crime (i.e. Anti-Money Laundering / Counter
price sensitive information does not give rise to the risk Financing of Terrorism (AML/CFT)), regulatory risk and
or perceived risk of a conflict between the public interest, reputational risk for counterparties that may put KWAP
KWAP’s interest and the employee’s personal interest. in a bad light. This is a step taken to ensure we capture
any Red Flags as KYC screening checks the real identity
Automated Self-Compliance Checklist
or background of the counterparties, detect potential
KWAP has implemented an automated Self-Compliance financial fraud, political exposure, or corruption, and
Checklist where all the attestation processes are prevents KWAP from being used for criminal activities
performed via a compliance system. The compliance like money laundering or terrorist financing. In 2023,
system covers both regulatory and internal requirements. the Compliance team had taken an initiative to review
The Self-Compliance Checklist will be filled in by the and enhance the KYC screening process, including the
respective department/function’s compliance liaison relevant intellectual documents and control mechanisms.

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