Pocket Guide on Compliance

HIGHLY CONFIDENTIAL

POCKET GUIDE

on Compliance

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TABLE OF CONTENTS Market Manipulation
Fair Treatment of Financial Consumers
Our Values Sanctions
Supporting Maybank’s Mission Anti-Money Laundering and Countering
Our Commitment
Anti-Bribery and Corruption Financing of Terrorism
Personal Data Protection Whistleblowing
Insider Trading

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“Trust is the foundation on which successful, enduring and endearing
relationships are built. It is by doing the right thing by our customers, and
other stakeholders, that we fulfil our sense of purpose and are successful in
building trusted relationships that last through generations.”

- Datuk Abdul Farid Alias, in his Key Messages to Shareholders 2020.

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OUR VALUES

At Maybank, our T.I.G.E.R values define what we believe in and what We understand that a good compliance programme does not
we stand for. These are our essential guiding principles for our hearts belong solely to Group Compliance and cannot be achieved
and minds, for those situations where the rule book provides no without the commitment by everyone across the Group. As such,
answers. Integrity stands at the center of our T.I.G.E.R. values - this we believe that compliance is everyone’s responsibility and the
serves to remind us that as Maybankers, we are honest, professional Compliance Framework serves as a guide for all employees by
and ethical in our dealings. providing the key principles and guidelines for managing
compliance risk.
The role of a good compliance programme serves to uphold the
T.I.G.E.R values. Our mission at Group Compliance is to build the A good compliance programme consists of three lines of defence
capability and infrastructure to ensure businesses are conducted (LOD), each with its own key role to protect the bank from any
ethically by complying with all relevant laws and regulations. potential non-compliance risks:

We promote a compliance culture that inculcates a sense of • 1st LOD (Business): own and manage day-to-day compliance
responsibility in our staff to be vigilant against money laundering and risks
terrorist financing, and proactively play our part in maintaining public
confidence in the financial system. • 2nd LOD (Group Compliance & Group Risk): set compliance
standards and provide governance, oversight and compliance
advice

• 3rd LOD (Internal Audit): provide reasonable assurance via
independent assessment, review and validation

Throughout this document, we hope to share greater insights as
to the background and importance of various compliance
requirements for all Maybankers.

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SUPPORTING MAYBANK’S MISSION

Maybank’s mission is to humanise
financial services across Asia, by
providing access to financial services to
the people at fair terms and pricing, and
to be always at the heart of the

community.

Ensuring a strong Compliance Culture allows us to
serve our customers at fair terms and pricing.

Compliance requirements such as Data Protection, Financial Consumer Fair Treatment, Anti-
Bribery and Corruption and many others protect our customers and communities, in support

of our Maybank Mission to humanise financial services.

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OUR COMMITMENT

At Maybank, we are committed to…

• having zero tolerance against all forms of bribery and corruption
• protecting our customers’ information
• standing strong against insider trading and market manipulation

• fostering a high standard of business conduct and good trading room practices
• treating our customers fairly
• complying with relevant sanctions programmes
• combatting money laundering and terrorism financing
• whistleblowing where we are aware of any improper conduct

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ANTI-BRIBERY AND CORRUPTION

Did You Corruption is defined as “dishonest or fraudulent On a larger scale, corruption erodes trust through the effects of
Know? conduct by those in power, typically involving robbing the citizens of their freedom and participation in the
bribery”. Its origin can be traced back to the Latin democratic process, which eventually leads to the downfall of a
word “corrumpere” which means to spoil, bribe or nation.
destroy.
An exposed corruption scandal may put a nation on the global
In many places around the world, unfortunately it map for all the wrong reasons. This may cause large
is customary for corruption to be ingrained in the corporations to lack confidence in investing directly in the said
everyday lives of the people – whether to obtain nation, moving its operations to other more stable countries,
licenses to perform certain activities, or simply to thus creating higher unemployment rates in the corrupted
exercise the basic rights of a citizen. nation.

Such activities increase the burden of the common Already burdened by the costs of corruption, the citizens of a
people, causing a ripple effect of an increase in corrupted nation now has to face social problems caused by
cost of living, inequality of treatment and lack of high rates of unemployment and potentially higher number of
provision of basic services in the absence of criminal cases.
bribery.
Having our communities at heart, Maybank is committed
to conduct its business dealings with the highest level of
integrity. We have ZERO TOLERANCE for any forms of
bribery and corruption.

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ANTI-BRIBERY AND CORRUPTION

In our fight against corruption, we are strictly prohibited from the following in all of our dealings:

• Participating in any form of bribery and corruption including giving or receiving bribes.
• Engagements of Associated Persons and dealings with Customers or Third Parties to:

o Induce, obtain or retain business; or
o Gain an unfair advantage or influence a government or regulatory decision for Maybank; or
o Obtain any personal gain.
• Giving or receiving gifts and entertainment (including donations and sponsorships) to:
o Bribe; or
o Retain or gain a business advantage; or
o Obtain any personal gain.
• Any conflict of interest which could result in any bribery and corruption risk to Maybank

Check out the following for more information:
• Maybank Group Anti-Bribery and Corruption Policy
Resources • Maybank Group Anti-Bribery and Corruption Procedure

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PERSONAL DATA PROTECTION

Personal data is becoming one of the most At Maybank, we handle a significant amount of
valuable asset in today’s day and age. With its customer information in the course of providing
growing importance, it is critical for us to financial services and products. Proper handling
secure our customers’ and communities’ data of customer information is essential in building
to protect them from falling victims to various public trust and confidence in mitigating
scams and fraudulent cases. reputational damage to the Bank.

Did You In 2019 alone, RM390 million was lost due to It is therefore critical for us to protect our
Know? telecommunications and e-financial fraud in customers’ information at all times – personal
Malaysia. With just as little information as an data protection is a fundamental right of
individual’s name, date of birth and address, which we owe our customers.
fraudsters can cause a lot of financial harm to
an individual.

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PERSONAL DATA PROTECTION

We uphold the following responsibilities in the spirit of protecting our customers’ information:
• Maintain confidentiality of customer information and not use them for any reasons other than the specified

purposes
• Implement and comply with relevant controls relating to information and communication technology, accesses and

physical security
• Conduct necessary risk assessments to be aware of emerging risks, including when outsourcing processes are in

place
• If an information breach occurs, report, escalate and contain the breach via the necessary channels on a timely

basis

Where disclosure of customers’ information are sometimes required…
• We verify the authenticity of the request
• We obtain necessary approvals to disclose the information
• We comply with the relevant processes and maintain appropriate documentation

Check out the following for more information:
• Maybank Group Policy on Managing Customer Information and Permitted Disclosures

Resources

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INSIDER TRADING

Did You In 1987, a popular movie called “Wall Street” was Insider trading is an illegal act of trading
Know? made revolving a junior stockbroker, who gets investments based on information,
involved in insider trading only to face prison for the relating to a company, that is material,
crimes which he committed. Although the movie was price-sensitive and non-public.
made decades ago, insider trading still remains a
relevant topic today. Insider trading creates a disadvantage
and robs the other investors of
ImClone Scandal: Insider Trading revolving the opportunities for a fair trade.
Food and Drug Administration (FDA) Approval:
As a responsible corporate citizen,
In 2002, the founder of ImClone Systems Maybank is committed to strengthen
Incorporated (a biopharmaceutical company) was the public’s trust in the financial
arrested on insider trading charges. The founder services sector. To do this, we must
informed his family members to sell the shares of comply with relevant requirements to
ImClone just a few days before the FDA publicly curb insider trading.
announced that a drug being developed by ImClone
was not approved.

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INSIDER TRADING

When we are in possession of material non-public information…

WE MUST NOT… WE MUST…

 We must not perform or  Apply appropriate information
attempt to perform any barriers including physical barriers,
proprietary or personal access controls and information
trades relating to this technology security
information
 Handle information strictly on a
 We must not communicate need-to-know basis
or discuss this information
with anyone who has not  Seek necessary approvals if
been wall-crossed to access information needs to be transferred
this information else or accessed by other parties

 We must not influence or  Escalate and investigate any breach
advise anyone else to trade of information immediately
on this information

Check out the following for more information:
• Maybank Group Global Markets Dealers’ Code of Ethics and Conduct

Resources

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MARKET MANIPULATION

Did You One of the earliest financial fraud goes back to 300 Fast forward many years, multiple financial
Know? B.C. when Hegestratos, a Greek merchant, decides frauds have been committed including various
to defraud his lender. Hegestratos entered into a acts of market manipulation. Market
loan agreement where he would repay the loan with manipulation is an illegal act to artificially
interest upon delivery of the cargo, in this case, inflate or deflate the prices of investments for
corn. As part of the agreement, the lender could personal gain. The Libor Fixing and the FX
claim the boat and corn if Hegestratos could not Benchmark Manipulation scandals are examples
repay the loan. The boat in this case is the of large scale market manipulation activities
collateral. that changed the way financial markets
function. Apart from insider trading, many other
Intending to default on the repayment, Hegestratos activities that seek to manipulate the market
planned to sink his boat and sell the corn. In the jeopardize the integrity of our financial
absence of the collateral, the lender would lose out markets.
with nothing to claim from Hegestratos. Lo and
behold, Hegestratos ended up drowning while trying By ensuring that our dealers comply with
to escape upon being caught red-handed by his crew certain requirements within the Maybank
and passengers. Group Global Markets Dealers’ Code of Ethics
and Conduct, we seek to promote efficient
market practices to reflect our commitment
to having high standards of integrity in all our
dealings.

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INSIDER TRADING & MARKET MANIPULATION

Committed to protecting the integrity of our financial markets, our dealers…
• Must declare their personal trading to Compliance on a periodical basis or as and when requested to do so
• Must not make false or misleading statements which may be damaging to third parties or influence the market prices
• Must not engage in improper practices including fraudulent, deceptive or manipulative trading practices
• Must act honestly and in good faith when marketing and performing transactions according to our customers’ needs
• Must comply with the requirements governing the after-hours/off-premises dealings
Check out the following for more information:
• Maybank Group Global Markets Dealers’ Code of Ethics and Conduct

Resources

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FAIR TREATMENT OF FINANCIAL CONSUMERS

Maybank’s mission is to humanise We uphold the following in all of our dealings:
financial services across Asia, by
providing access to financial services to • We ensure that contracts with our customers are fair
the people at fair terms and pricing, • We provide our customers with clear, relevant and timely
and to be always at the heart of the
community. information on our products and services
• We exercise due care, skill and diligence when dealing
Upholding this mission, we are
committed to treating our customers with our customers
fairly by exercising due care, skill and • We provide suitable advice and recommendations to our
diligence in our dealings. We must
maintain high standards of responsible customers
and professional conduct at all times to • We preserve the confidentiality of all our customers’
maintain our customers’ trust and
confidence in us. information
• We handle our customers’ complaints and claims
The interests of our customers are an
integral part of our business and promptly, fairly and effectively
ensuring that we treat our customers
fairly is critical at all times. Check out the following for more information:
• Maybank Financial Consumer Fair Treatment Policy

Resources

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SANCTIONS

Did You The nuclear bombing in Hiroshima and To maintain international peace, the United
Know? Nagasaki in 1945 had devastating effects and Nations (UN) have established sanctions
continue to haunt the many survivors with which focus on nuclear non-proliferation,
leukemia, cancer and other side effects of counter terrorism and political settlement of
the radiation up until today. conflicts.

A nuclear weapon can destroy a whole city in As a responsible corporate citizen, it is
a short span of time and leave long-term imperative that Maybank complies with the
catastrophic effects. many sanctions programmes in an effort to
protect our communities from unnecessary
Similarly, terrorism also brings about harm.
significant harm – about 15,000 recorded
deaths in 2018 were caused by terrorism
activities.

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SANCTIONS

We uphold the following responsibilities in complying with sanctions requirements:
• We do not do business with any sanctions target listed in the relevant sanction programmes.
• We must escalate any transaction by a sanctions target to GFCC.
• We comply with the sanctions programmes issued by the Malaysian Ministry of Home Affairs, UN Security Council and

United States Department of the Treasury's Office of Foreign Assets Control
• We conduct necessary and timely sanctions screening during the course of our business
Check out the following for more information:
• Maybank Group Sanctions Policy
Resources • Maybank Group Sanctions Procedures

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ANTI-MONEY LAUNDERING &
COUNTERING FINANCING OF TERRORISM

Did You Money is laundered to conceal the In 1993, a 1,200-pound bomb was placed in a truck parked
Know? source of “dirty money” from illegal beneath the US World Trade Center, causing an explosion which
activities such as corruption, human killed 6 people and injured more than 1,000. Ramzi Yousef was
trafficking and drug trafficking. To sentenced to 240 years of prison for directing the execution in
avoid detection, criminals move the 1998. Upon conviction, he tells the court “I am a terrorist and
money quickly via the banking system. proud of it”.

As Maybankers, the first line of defence On 11 September 2001, the world is yet again shook by another
lies in our hands. We need to spot any much larger act of terrorism when four airplanes crashed into
suspicious activity, raise the red flag the World Trade Center by al-Qaeda terrorists causing
and stop criminals from laundering thousands of deaths. Closer to home, in 2016, a bar in Malaysia
funds. Only then, it will no longer be was attacked by men in the Islamic State in Iraq and Syria (ISIS)
lucrative to commit crimes that hurt using a grenade in the wee hours of the morning during the
us, our country and our children. Spain-Italy Euro 2016 match.

Anti-money laundering is the key to The fight against terrorism financing is critical to stop such
reducing criminal harm to our society. painful events to occur. As Maybankers, we have important roles
to play in the countering financing of terrorism.

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ANTI-MONEY LAUNDERING &
COUNTERING FINANCING OF TERRORISM

Committed to combatting money laundering, and terrorism financing, we must all…
• Immediately escalate any suspicious or unusual behaviour in the normal course of business to GFCC.
• Complete our Anti-Money Laundering & Countering Financing of Terrorism (AML & CFT) trainings on a timely basis.
Some of us with specific roles in upholding Maybank’s AML & CFT controls must ensure the following are
accurately assessed and recorded…
• Know-Your-Customer processes including risk profiling, name screening, customer due diligence and periodic

reviews
• Products, services and enterprise-wide risk assessments

Check out the following for more information:
• Maybank Group AML & CFT Policy
Resources • Maybank Group AML & CFT Procedures

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WHISTLEBLOWING You can raise your concerns via the following secured channels:

Now that we have a clearer view of the role and HOTLINE
importance of compliance, it is important for us • Malaysia:1-800-38-8833 (24 Hours Toll-Free)
to be aware of any potential improper conduct • Other Countries:+603 – 2026 8112 (Secured Voice Recording)
that may be attempted by an employee or • Click here for a list of toll-free lines in other countries.
representative of Maybank. Stopping improper
conduct can be as simple as speaking out EMAIL: [email protected]
whenever you are aware of or have reasonable
grounds to suspect that it has been committed. MAIL BOX/LETTER: Group Compliance, P.O. Box 11635, 50752
Kuala Lumpur
Improper conduct includes:
• Bribery and corruption While raising the concerns, you are encouraged to provide the
• Conflict of interest name of person(s) involved, date, time, nature, witness and
• Fraud, theft, or embezzlement, evidence of the event, where available.
• Breach of Maybank’s Code of Conduct
• Unauthorised disclosure of customer Rest assured that your identity will be kept confidential and
you will be protected from any repercussion when you make
information a disclosure in good faith.
• Abuse of power by an employee
• Failure to comply with legal and regulatory Check out the following for more information:
Resources • Maybank Group Whistleblowing Policy
obligations
• Concealment of any of the above or any 20

other improper conduct

Thank You