Standard Operating Procedure

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Organization:
Document No:
AMANAHRAYA INVESTMENT
MANAGEMENT SDN BHD
Revision No:
COMPLIANCE MONITOIRNG ON
FUNDS MANAGEMENT
Title:
PREPARED BY
QP-COMP-01
Date:
17/09/2014
NURUL AMIRA BINTI

RAMLI
Executive, Compliance
VERIFIED BY
RIDZA AHMAD
JALALUDIN
Head of Compliance
REVIEWED BY
RIDZA AHMAD
JALALUDIN
Head of Compliance
APPROVED BY
MEOR KHAIRI BAZID

Managing Director
REVISION
DATE
REVIEWED
REVIEWED
BY
FIRST
SECOND
THIRD
FOURTH
FIFTH
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Organization:
Document No:
MANAGEMENT SDN BHD
Title:
Item
QP-COMP-01
Revision No:
COMPLIANCE MONITORING ON
FUNDS MANAGEMENT
Date:
17/09/2014
Description
OBJECTIVE
Action by
The purpose of this Quality Procedure [QP] is to ensure compliance with

legal requirements and internal policy when conducting monitoring
activities. This also to validate the daily transaction performs under funds
management activities and to identify any inconsistency in a daily
transaction with both external and internal rules and policies stipulated.
This is an effort to preclude violation of both regulatory and policy
upheld.
SCOPE
Report on a daily, weekly and monthly monitoring perform by
Compliance department.
DEFINITION OF TERMS
AMLA
Anti-money Laundering
ARIM
AmanahRaya
Management
i.
ARUTF
i.
AmanahRaya Unit Trust

Fund
ii.
AmanahRaya
Trust Fund
iii.
AmanahRaya
Cash
Management Fund
iv.
AmanahRaya
Equity Fund
ii. ARSTF
iii. ARICMF
iv. ARCMF
v. ARIEF
Inevstment
Shaiah
Islamic
AMLO
Anti-money Laundering Officer for

ARIM i.e. Compliance Officer
CEMC
Credit &
Committee
Compliance
Referring
Equity
to
the
Management
Compliance
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Organization:
Document No:
MANAGEMENT SDN BHD
FUNDS MANAGEMENT
Title:
QP-COMP-01
Revision No:
Date:
17/09/2014
department at ARIM
Discretionary
Absence of C at the beginning of

code i.e. C0466D
Excel
Microsoft Excel is a spreadsheet

application developed by Microsoft
for Microsoft Windows and Mac
OS. It features calculation, graphing
tools, pivot tables, and a macro
programming language called Visual
Basic for Applications.
EPF
Employee Provident Fund
Fund Manager [FM]
The person(s) responsible for

implementing a fund's investing
strategy and managing its portfolio
trading activities at ARIM &
licensed with SC
GRMD
Group
Risk
Department
HEAD OF COMPLIANCE
Mr. Ridza
KWB
Kumpulan Wang Bersama
Marketing
Marketing department at ARIM
OzAsia system
Software deals with investment and

management of cash, equity, money
market, bonds and other financial
related instruments.
PTR
Portfolio Turnover Ratio
QP
Quality Procedure
SC
Securities Commission of Malaysia
Toms system
Trade order management solution
Management
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Organization:
Document No:
MANAGEMENT SDN BHD
FUNDS MANAGEMENT
Title:
QP-COMP-01
Revision No:
Date:
17/09/2014
REFERENCE
I.
Equity quality procedure;
II.
Marketing quality procedure;
III.
Compliance internal process flow on OzAsia system;
IV.
Unit trust fund/funds management policy;
V.
VI.
VII.
Guidelines on Anti-money Laundering [AMLA] from Bank

Negara Malaysia [BNM];
Anti-Money Laundering Act 2007; and
Guidelines on AMLA from Securities Commission of Malaysia
[SC]
RESPONSIBILITY
It is intended that this limitation of responsibility is not only apply to
arising parties mentioned in the action by column unless otherwise
based on circumstances to include those ARIM employees who are
directly or indirectly related to the circumstances mentioned in this QP.
Item
Description
Action by
OPENING OF ACCOUNT FUNDS MANAGEMENT

1. Marketing department shall create a new client file (for every
new client) which consist of details information pertaining to
Marketing
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Document No:
MANAGEMENT SDN BHD
Title:
FUNDS MANAGEMENT
QP-COMP-01
Revision No:
Date:
17/09/2014
clients portfolio and direct mandates i.e. account opening forms,

Portfolio Management Agreement [PMA], investment deposits
via cheque, telegraphic transfer and etc [Kindly refer to
Marketing department QP on account opening for details of
completed documents required].
2. Complete set of clients file, direct mandate and PMA shall be
given to Compliance department for safekeeping and Compliance
shall keep this file for at least 7 years based on the procedure of
record keeping. Incomplete documents shall be returned and
Marketing department is required to follow up with the potential
client.
3. Upon received direct mandate from Marketing (in form of paper);
Compliance to liaise with Fund manager responsible for new
client and to obtain confirmation on purported strategy to use.
Reference pertaining strategy to use, responsible FM, name and
details of client can be obtained from the direct mandate itself.
Compliance shall create new strategy as instructed by FM.
Creation of new strategy or to use the existing strategy stipulated
in the system both are carried out through OziaAsia system.
4. It is crucially vital for Compliance to be familiar with codes
appear on the system for ease reference and accuracy of
transferring instruction from FM to the system.
Marketing &
Compliance
Compliance &
Fund Manager
Compliance
Kindly refer to Flowchart 1 on the complete process of creating new

strategy or using the existing strategy in the OzAsia system.
STOP LOSS MONITORING

Compliance shall ensure that FM is in compliance with the Equity policy Compliance &
Fund Manager
based on the following stop loss policy:
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FUNDS MANAGEMENT
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b
c
QP-COMP-01
Revision No:
Date:
17/09/2014
Equity P
Stop Loss Policy
The fund managers representative shall
be required to inform the CIO
immediately whenever a stock price falls
25% below its average cost price. The
fund managers representative, the CIO
and MD must reach an agreement for the
next course of action, whereby the
Investment Committee shall also be
notified in the upcoming Investment
Committee meeting.
Trading
Domestic Stock: Cut loss shall be
executed once the average price of the
stock falls by 10%.
Foreign
Not more than 15% below its average
cost of price
Monitoring shall be conducted on a daily basis in the OzAsia system.
Sectors
Core
Holding
and
Thematic/
Momentum
Compliance
General reporting stages:

1. To update the Head of Compliance on the status of monitoring on a
daily task report and this daily report shall be sent via email to the Head
of Compliance at the end of office hour for record purposes.
2. To record any breaches identified in the log book*.
3. To accumulate daily information of monitoring report conducted in a
weekly report.
*any inconsistency found in the log book the daily email will prevail.
PROCEDURES
Compliance
Currently monitoring stop loss are based on the following accounts:

1
Kumpulan Wang Simpanan Pekerja [KWSP] C0423 [FM:Meor];
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Document No:
MANAGEMENT SDN BHD
FUNDS MANAGEMENT
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QP-COMP-01
Revision No:
Date:
17/09/2014
Kumpulan Majlis Raja-Raja yang Dipertua Negara C0299 [FM:

Qawiem];
Tabung Warisan Negeri Selangor C0497 [FM: Qawiem];

Perbadanan Kemajuan Negeri Selanor C405 [FM: Qawiem];
5
ARUTM For PB Trustee Services Berhad (ARIE) C0482 [FM: Yap

Jia];
KWB Shariah Equity C0391[FM: Yap Jia];

KWB Equity C0387 [FM: Meor];
University Malaya C0166 [FM: Yap Jia]; and
Lembaga Tabung Angkatan Tentera C0407 [FM: Qawiem].
Compliance &
Fund Manager
1
In monitoring this report, Compliance shall focus on the % on

change column on the report and shall ensure that this % on change
for every account under core holding, thematic and trading sections
are not beyond the limits stipulated in the policy as per the above
tabulation.
Compliance shall in a timely manner notify Fund manager

responsible for mandates found to be inconsistent with the policy to
obtain justification for the identified breach. Notification can be in
any forms of communication i.e. via email, phone call or to raise the
inconsistency during CEMC meeting. Fund manager or respective
person responsible for the mandate is required to provide immediate
justification and action plan as to mitigate such breaches.
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Organization:
Document No:
MANAGEMENT SDN BHD
FUNDS MANAGEMENT
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QP-COMP-01
Revision No:
Date:
17/09/2014
Information that is inconsistent with the policy upheld shall be

reported to the Head of Compliance and recorded in the log book*
error.
Compliance
The log book* error shall contains the following details*:
Date of breaches
Details
Action by compliance
Action by respective departments
By whom
Type of breach
Noted by
Information pertaining to daily monitoring conducted on stop loss shall

be recorded in the weekly report as well. Remarks shall be added at the
bottom of reporting when there is a breach yet has been rectified within
that week of reporting period.
Example:
Remarks*:
i. Note that technical breach under account Kumpulan
Wang Biasiswa Pengajian Tinggi Majlis Raja-Raja Yang
Dipertua [299] for stock FGV has been rectified on 1 st July
2014
*Note that this remarks section is not limited to notify on the rectification per se.
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Organization:
Document No:
MANAGEMENT SDN BHD
FUNDS MANAGEMENT
Title:
QP-COMP-01
Revision No:
Date:
17/09/2014
The weekly report for Stop loss shall contains the following details:
No
Stock code
Stock name
Total Cost
Market Value
G/L (Gain or loss)
% On change
Set up Limit
Sector
Date of Breach
Type of Breach*(it can be technical or error from Fund Manager)
Fund Manager
Action by Compliance
Action by respective person/department
Date of rectification
Compliance
Kindly refer to Flowchart 3 for details process flow of monitoring stop

loss in the OzAsia system.
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Organization:
Document No:
MANAGEMENT SDN BHD
Title:
FUNDS MANAGEMENT
QP-COMP-01
Revision No:
Date:
17/09/2014
SINGLE STOCK REPORT MONITORING

Compliance shall ensure that FM is in compliance with the Equity policy
pertaining to single stock exposure policy as per below:
Compliance &
Fund Manager
2.7.1
Minimum Criteria for Investment for Portfolio Size of Below RM3 million
Single Stock Exposure for investment below 3 million.
For an equity portfolio size of RM3 million and below, equity investment can be
allocated up to 20 different stocks (that are not affiliated to each other in terms of
shareholding structure) with a
maximum exposure of 25% of
Core Holding
Thematic
Trading
Limited to Limited to 7% For stocks already total account size to any single
10%
of of total NAV included in the stock.
total NAV of the account. Stock
Universe: 2.7.1
Criteria
for
of
the
2.5% of NAV For Minimum
account.
stocks outside the Investment for Portfolio Size of
(Amended
Stock
Universe: RM3 million and Above
July 2011
1.0% or RM10 Single Stock Exposure for
million, whichever investment 3 million and above
is lower.
(Amended
July
2011)
1. When report is retrieved via OzAsia system, Compliance shall

focus on error status with the absent of comment on the
comment section of the report. This indicates that there is a new
error identified on a particular stock yet comment need to be
added. Such comment need to be obtained from the responsible
Fund Manager of the stock. Comment from the Fund Manager
may include one of the following yet not limited to:
Compliance
i. technical breach due to clients instruction;

ii. technical breach due to market movement; and
iii.technical breach due to technical issue.
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Document No:
MANAGEMENT SDN BHD
FUNDS MANAGEMENT
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QP-COMP-01
Revision No:
Date:
17/09/2014
2. Monitoring shall be conducted on a daily basis in the OzAsia

system.
Compliance &
Fund Manager
3. Information that is inconsistent with the policy upheld shall be

reported to the Head of Compliance and recorded in the log book
error*.
4. Compliance shall in a timely manner notify Fund manager
responsible for mandates found to be inconsistent with the policy
to obtain justification for the identified breach. Notification can
be in any forms of communication i.e. via email, phone call or to
raise the inconsistency during CEMC meeting. Fund manager or
respective person responsible for the mandate is required to
provide immediate justification and action plan as to mitigate
such breaches.
Compliance
5. The log book* error shall contains the following details:
Date of breaches
Details
By whom
Type of breach
Noted by
6. Information pertaining to daily monitoring conducted on single

stock report shall be recorded in the weekly report as well.
Remarks shall be added at the bottom of reporting when there is a
breach yet has been rectified within that week of reporting period.
Example:
Remarks*:
Wang Biasiswa Pengajian Tinggi Majlis Raja-Raja
*Note that this remarks section is not limited to notify on the rectification.
Yang Dipertua [299] for stock FGV has been rectified
on 1st July 2014
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Organization:
Document No:
MANAGEMENT SDN BHD
FUNDS MANAGEMENT
Title:
QP-COMP-01
Revision No:
Date:
17/09/2014
No
Stock code
Stock name
Total Cost
Market Value
G/L (Gain or loss)
% On change
Set up Limit
Sector
Date of Breach
Fund Manager
Compliance &
Fund Manager
This weekly report comprises of daily monitoring conducted within a

week shall be reviewed by the Head of Compliance.
Kindly refer to Flowchart 2 for details process flow of adding comment
received from the Fund Manager in the OzAsia system.
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Organization:
Document No:
MANAGEMENT SDN BHD
QP-COMP-01
Revision No:
FUNDS MANAGEMENT
Title:
Date:
17/09/2014
CUSTOMER AND COMPANY CAPPING

Compliance shall act upon instruction received from the FM whos acting
via instruction received from client on the following purpose:
I.
II.
Compliance &
Fund Manager
to restrict purchase of stock/s; and/or

to restrict sale of stock/s; and/or
III.
to permit purchase of stock/s; and/or
IV.
to permit sale of stock/s.
For illustration purposes, Company A instructed FM not to proceed with

any purchase of stock B yet sale of existing stock B in hand is permitted
to be sold and conversely.
Capping functions to lock the stock for not being purchased or sold until
further notice or instruction received from client. In the event where there
is new FM in charge for the existing client, this capping will work
simultaneously.
Kindly refer to the Flowchart 4 on the complete process of customer and
company capping in the OzAsia system:
PROHIBITION
SECURITIES
Buyin
g
x
Sellin
g
x
2. Bursa Malaysia Berhad
3. Malaysian Resources Corp.

Berhad
4. Media Prima
5. Pharmaniaga Berhad
1. RHB Capital Berhad
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Organization:
Document No:
MANAGEMENT SDN BHD
QP-COMP-01
Revision No:
FUNDS MANAGEMENT
Title:
Date:
6. United Plantation Bhd
7. Plus Expressway Berhad
8. Malaysian Building Society

(MBSB)
9. Proton Holdings Berhad
17/09/2014
Diagram 1: Examples of prohibition on

securities
Compliance &
Fund Manager
FAIR VALUE AND EQUITY ORDER & CONFIRMATION

REPORT
pertaining to Best execution price policy as per below:
Item
In
6.1
Compliance Guidelines on Policies Governing

Investment Management
Best Execution Price:
a. ARIM must always provide the best possible
terms for a client when dealing and that the best
execution is monitored and documented.
b. When dealing ARIM should take due care and
ensure that price offered by a broker is the best
available taking into consideration the size and
nature of the transaction.
c. Prior to executing any investments for a client,
ARIM shall ensure that:
the investment transaction is carried out in
accordance with the clients mandate and
within limits prescribed in the PMA; and
the relevant account has sufficient assets to
meet the obligations of the transaction.
d. Best execution price is defined as the price,
which is within a reasonable spread of the last
traded price, reasonable being defined as within a
2% tolerance.
e. A price lying outside the spread price may still
satisfy best execution price, as the price will be
viewed in light of the liquidity and volatility of the
market concerned. The Fund Manager shall also
provide and explanation.
brief the burden is on the FM to ensure that every transaction performs

i.e. buying of stock shall not exceed 2% of the initial price offered;
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Document No:
MANAGEMENT SDN BHD
FUNDS MANAGEMENT
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Comparison is made between order price and confirm price on the

report for every stocks buy. Compliance may refer to the portfolio name
column to identify FM responsible of carrying out such transaction.
Kindly refer to the Flowchart 5 on the complete process of monitoring

Fair value in the OzAsia system:
Information that is inconsistent with the policy upheld shall be reported to
the Head of Compliance and recorded in the log book* error.
Compliance shall in a timely manner notify Fund manager responsible for
mandates found to be inconsistent with the policy to obtain justification
for the identified breach. Notification can be in any forms of
communication i.e. via email, phone call or to raise the inconsistency
during CEMC meeting. Fund manager or respective person responsible
for the mandate is required to provide immediate justification and action
plan as to mitigate such breaches.
Compliance
The log book* error shall contains the following details:
Date of breaches
Details
By whom
Type of breach
Noted by
Information pertaining to daily monitoring conducted on single stock

report shall be recorded in the weekly report as well. Remarks shall be
added at the bottom of reporting when there is a breach yet has been
rectified within that week of reporting period.
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Organization:
Document No:
MANAGEMENT SDN BHD
FUNDS MANAGEMENT
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QP-COMP-01
Revision No:
Date:
17/09/2014
Compliance
Example:
Remarks*:
2014
No
Stock code
Stock name
Total Cost
Market Value
G/L (Gain or loss)
% On change
Set up Limit
Sector
Date of Breach
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Document No:
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FUNDS MANAGEMENT
Title:
Fund Manager
QP-COMP-01
Revision No:
Date:
17/09/2014

Compliance &
Fund Manager
BROKER ALLOCATION
as per below:
Item
6.2
Compliance Manual
a. Approval from the Investment Committee must be
obtained for the appointment of a Broker.
b. ARIM shall only deal with brokers on its approval broker
list, which shall be evaluated annually. The evaluation shall
be coordinated by the Compliance Officer.
c. It is the responsibility of ARIM to exercise due diligence
as to whether the broker is fit and proper to carry out
investment business. When evaluating brokers the
following shall be considered: Credit risk
Investment idea
Sales service, including brokerage commission charged
Quality of research
Efficiency of execution and settlement
d. The execution of ARIMs trades shall not exceed 20% of
the total dealings in value in any one financial year.
Compliance
Monitoring on the broker allocation shall be conducted on a yearly basis

despite of this Compliance will internally conduct monitoring on a
monthly basis for record purposes.
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Organization:
Document No:
MANAGEMENT SDN BHD
FUNDS MANAGEMENT
Title:
QP-COMP-01
Revision No:
Date:
17/09/2014
If monthly report shown (specifically referring to the % amount at the left

end side of the report) that broker allocation exceed 20% of the total
dealings comparison is then made between reports of the current month
with the report of 4 months earlier.
Date of breaches
Details
By whom
Type of breach
Noted by
Compliance

broker allocation in the OzAsia system:
Information pertaining to monthly monitoring conducted on broker
allocation report shall be recorded in the weekly report as well. Remarks
shall be added at the bottom of reporting when there is a breach yet has
been rectified within that week of reporting period.
Example:
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Organization:
Document No:
MANAGEMENT SDN BHD
FUNDS MANAGEMENT
Title:
QP-COMP-01
Revision No:
Date:
17/09/2014
Remarks*:
2014
Compliance
No
Stock code
Stock name
Total Cost
Market Value
G/L (Gain or loss)
% On change
Set up Limit
Sector
Date of Breach
Fund Manager
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Document No:
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Title:
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QP-COMP-01
Revision No:
Date:
17/09/2014
Compliance &
Fund Manager
ASSET ALLOCATION:
Asset allocation refers to the allocation of asset based on client or
company mandate on the following allocations:
Compliance
i. equity; and
ii. cash
Compliance shall ensure that the set up table for both equity and cash are
not above or below the minimum or maximum % limits stipulated. Error
is identified whenever the words error is appeared at the remarks
column of the report.
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MANAGEMENT SDN BHD
FUNDS MANAGEMENT
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QP-COMP-01
Revision No:
Date:
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Date of breaches
Details
By whom
Type of breach
Noted by
Compliance

asset allocation in the OzAsia system.
Example:
Remarks*:
2014
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Document No:
MANAGEMENT SDN BHD
FUNDS MANAGEMENT
Title:
QP-COMP-01
Revision No:
Date:
17/09/2014
No
Stock code
Stock name
Total Cost
Market Value
G/L (Gain or loss)
% On change
Set up Limit
Sector
Date of Breach
Fund Manager
Compliance &
Fund Manager

OVERALL STOCK REPORT:

as per below:
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Document No:
MANAGEMENT SDN BHD
Title:
2.7.1
Collective
Minimum
Weighting
Requirement
(CMWR)
or Exposure
Limit
FUNDS MANAGEMENT
QP-COMP-01
Revision No:
Date:
17/09/2014
Minimum Criteria for Investment for

Portfolio Size of RM3 million and Above
Core
Thematic
Trading
Holding
CMWR
No restriction Shall
not
(in terms on CMWR exceed 10%
of market but maximum of total NAV
value) of collective
of
the
40% of weighting (in account.
total
terms
of
market
market value)
value of of 55% of
all equity total market
holding
value of all
at
all equity
time.
holding.
Compliance
Compliance &
Fund Manager
Appearance of asterisk symbol * indicate that there is error on the
report; and error may be formed due to the following factors yet not
limited to:
i. set up table above or below the set up limit; or
ii. no of main stock above or below the minimum or maximum number of
stock stipulated i.e. either stock hold exceed or limit exceeded.
Compliance to neglect error formed on Non-Discretionary account as this
non-discretionary account is based on client or company mandate and
shall focus on error identified on Discretionary account instead.
overall stock in the OzAsia system.

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Document No:
MANAGEMENT SDN BHD
FUNDS MANAGEMENT
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QP-COMP-01
Revision No:
Date:
17/09/2014

Date of breaches
Details
By whom
Type of breach
Noted by

Example:
Remarks*:
2014
No
Stock code
Stock name
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Document No:
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FUNDS MANAGEMENT
Title:
QP-COMP-01
Revision No:
Date:
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Total Cost
Market Value
G/L (Gain or loss)
% On change
Set up Limit
Sector
Date of Breach
Fund Manager

Compliance
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Document No:
MANAGEMENT SDN BHD
Title:
FUNDS MANAGEMENT
QP-COMP-01
Revision No:
Date:
17/09/2014
MONEY MARKET PLACEMENT FOR KWB:
Compliance will receive daily email from GRMD pertaining to Money

Market, Bond and Equity Reports in the intranet at http://172.16.7.22
accompanied by the summary of the report. Monitoring on this placement
shall be conducted on a weekly basis.
Compliance then will have to extract the data from ARIMs Intranet.
Kindly find the process to retrieve report from the intranet as follows:
1. Follow or click on the link given http://172.16.7.22; after the web
appear then Scroll down to reports section and select money market.
2. Money market daily report will appear. Then Compliance has to select
the current year report i.e. Report of 2014.
3. Then, money market daily report list out by months will appear.
Compliance to select report based on current month i.e. August14
4. Finally, report based on daily date will appear. Compliance to select
report based on the current date. i.e.ReportMM_05August14.xls
5. Open the report in Excel format. There are 4 sections in the Excel, yet
please refer specifically to the KWB limits.
6. On KWB limits section; Compliance shall focus on the concentration
limits as highlighted [usually in yellow] that indicates the highest
concentration limits of counterparty above all.
7. Choose top 3 counterparties with the highest amount of concentration
limits by ranking.
The next stage is to generate report from the OzAsia system by following
the procedure in the Flowchart 9.
Compliance
Report generate by OzAsia is compared with report retrieve from the

intranet to ensure consistency of reporting. Comparison specifically made
between the values of Money Market outstanding from GRMDs report
with value of principal amount retrieve from OzAsia system.
Note: Since todays report can only be generated on the following day thus
GRMDs report is dated based on the following date rather than the actual date
of reporting. For example, GRMDs report dated 8 th August 2014 reflected report
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Organization:
Document No:
MANAGEMENT SDN BHD
FUNDS MANAGEMENT
Title:
QP-COMP-01
Revision No:
Date:
17/09/2014
dated on 7th August 2014.

Example:
Remarks*:
2014
No
Stock code
Stock name
Total Cost
Market Value
G/L (Gain or loss)
% On change
Set up Limit
Sector
Date of Breach
Fund Manager
Compliance
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Document No:
MANAGEMENT SDN BHD
FUNDS MANAGEMENT
Title:
QP-COMP-01
Revision No:
Date:
17/09/2014

MONITORING MONEY MARKET PLACEMENT FOR OTHERS

ACCOUNT
This report is similar to money market placement for KWB. The
difference between these two reports is in terms of the financial
institution where for other accounts only two financial institutions are
being monitored which are Bank Islam (for shariah portfolio) and Hong
leong investment bank (for non-shariah portfolio). Others account means
that, all D and non-D account that managed by ARIM will consolidated as
one account (except for KWB and EPF clients). Monitoring for other
account shall be conducted on a weekly basis.
Kindly refer to the Flowchart 9 for the detail process flow of generating
report for other account in OzAsia system.
Note: to ensure that the money market placement is not more than 20% of total
NAV.

Example:
Remarks*:
2014
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Organization:
Document No:
MANAGEMENT SDN BHD
FUNDS MANAGEMENT
Title:
QP-COMP-01
Revision No:
Date:
17/09/2014
No
Stock code
Stock name
Total Cost
Market Value
G/L (Gain or loss)
% On change
Set up Limit
Sector
Date of Breach
Fund Manager
Fixed Income
& Compliance
Compliance

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FUNDS MANAGEMENT
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Revision No:
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BOND VALUATION AND BOND SOLD

Compliance shall remind Fixed Income department i.e. Daryl to provide
weekly updates by Fixed Income on Bond purchased and Bond Rating
Migration (i.e. period from 14th July to 18th July 2014), if any.
Upon retrieving this information from Fixed Income department,
Compliance shall compile the information into the weekly report
specifically on the bond purchase and bond migration sections. Both of
these sections will accumulate the number of bond purchase and bond
migration throughout the year.
The accuracy of information on the bond disposal received from Fixed
Income department can be verified by making comparison with the report
generate from the OzAsia system.
Kindly find the process of retrieving report on bond disposal through
OzAsia system on Flowchart 10.

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FUNDS MANAGEMENT
Title:
QP-COMP-01
Revision No:
Date:
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Example:
Remarks*:
2014
No
Stock code
Stock name
Total Cost
Market Value
G/L (Gain or loss)
% On change
Set up Limit
Sector
Date of Breach
Fund Manager
Fund Manager
& Compliance
Compliance
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Title:
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PORTFOLIO TURNOVER RATIO

Note that churning can be identified based on the excessive trading by a
broker in a client's account largely to generate commissions. Churning is
an illegal and unethical practice that violates both external and internal
rules. Frequent buying and selling of securities that does little to meet the
client's investment objectives may be construed as evidence of churning
as well. Churning can be identified through portfolio turnover ratio report
where Compliance shall ensure that monthly portfolio turnover ratio
report does not exceed 0.5%.
Below is the policy that shall be adhered with:
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FUNDS MANAGEMENT
Title:
Chapter 6
6.5 (b)
QP-COMP-01
Revision No:
Date:
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Compliance Guidelines on Policies Governing Investment Management

Churning: ARIM must not make deals on behalf of a client unless there are reasonable grounds for doing
so, with the deals being in the best interest of the clients therefore, any dealing with undue frequency
(churning) is prohibited.
Kindly refer to Flowchart 11 on how to generate report from the OzAsia

system.
When monitoring portfolio performance report, Compliance shall focus

on the current PTR for month (%) column (at the end of the report) as
report will accumulate information of the earlier months up to one
financial year and shall ensure that monthly portfolio turnover ratio report
does not exceed 0.5% of PTR. Instead of performing self-generating
report, Compliance may also use monthly PTR given by operation
department as reference as both referring to the same report. Monitoring
performs on both Shariah and conventional accounts.
Equity &
Compliance
Compliance
Example:
Remarks*:
2014
No
Stock code
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FUNDS MANAGEMENT
Title:
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Stock name
Total Cost
Market Value
G/L (Gain or loss)
% On change
Set up Limit
Sector
Date of Breach
Fund Manager

STOCK UNIVERSE
Compliance shall perform quarterly update on the list of stock universe
provided by Equities and Research department the comparison is then
made between the lists given by ERD with the list of stock universe in the
OzAsia system. The purpose is to ensure that every new stock purchased
is updated in the system.
Compliance
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Note: as per the common practice every new single stock initiated during CEMC
meeting shall be updated immediately.
Kindly refer to Flowchart 12 for the complete flow of generating report

from the OzAsia system.
Confirmation shall be obtained from ERD pertaining to any updates made
on the system.
Compliance
ANTI MONEY LAUNDERING

OBJECTIVE
Objectives of this document are to provide guidance to analysts for
execution of compliance duties in accordance with the AMLA. This
document is anticipated to be reviewed frequently and amended with new
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policies or procedures as required to continue improving AMLOs

analytical functions.
ARIM is committed to the highest standards of anti-money laundering
(AML) compliance and requires management and employees to adhere to
these standards to prevent use of ARIM products and services for money
laundering purposes. Adherence to this policy is the responsibility of all
employees.
RELATIONSHIP WITH EXISTING POLICIES

This document shall be read together with other documents issued by
Bank Negara Malaysia relating to compliance with AML/CFT
requirements guidelines issued by SC on AMLA & internal guidelines of
AMLA produced by ARIM.
Compliance &
Affected
departments
OVERVIEW
Compliance shall monitor AMLA via OzAsia System and Toms.
Marketing department as the front liner shall also adhere to this procedure
of accepting new clients and work hand in hand with the Compliance
department.
Compliance shall note that OzAsia system is use for the purpose of
monitoring transaction on the funds management section while Toms
system is use for monitoring transactions on Unit trust funds.
Compliance
OZASIA SYSTEM:
Daily report shall be generated from the OzAsia system as to monitor any
suspicious transaction relates to money laundering.
Report retrieved could describe transaction based on the following:
i.
Capital injection; or
ii. Creation of units; or
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iii. Initial investment.

High level of scrutiny shall be performed on the transaction conducted by
Individual that could trigger AMLA if the amount exceeds the limits
stipulated in the bank Negara Malaysia circulars.
If transaction performs by public company such as EPF then there will be
no suspicious of money laundering as this is a public company. Concern
shall be given to the corporation (private company) i.e. Chocolate chip
Sdn Bhd and individual i.e. Mohd Ismail.
PROCEDURE
Successful report generated will produce report with header Customer
Audit From xx.xx.20xx to xx.xx.20xx*
Code for of Individual or company can be found under the heading of
Ringgit Malaysia. Compliance shall refer to the list of Customer
summary portfolio to identify the undecoded name of individual or
company with the Fund manager responsible of handling such account.
*Since monitoring is conducted based on a daily basis therefore example of date
that will appear on the report; Customer Audit From 19 Aug 2014 to 19 Aug
2014.
Compliance shall then refer to the description of the report retrieved to

identify whether the transaction perform is capital injection, creation of
units or initial investment.
Highlight shall be given at the amount of money transacted that can be
retrieved under the column of amount or base amount or total for
ringgit malaysia.
Any suspicious transaction shall be reported to the Head of Compliance
and recorded in the log book* error.
Compliance shall in a timely manner notify marketing department i.e.
Puan Latifah to obtain justification for the suspicious transaction and to
suspend the suspicious account. Notification can be in any forms of
communication i.e. via email, phone call or face to face interaction.
Respective person responsible of performing such transaction is required
to provide immediate justification and action plan as to mitigate such
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suspicious transaction from occurring.

Compliance shall retrieved all the information pertaining to the suspected
individual or company i.e. the opening account form, due diligence form,
kyc form as to perform thorough investigation i.e. whether transaction
perform by this individual or company is compatible with their financial
standing and to come out with conclusion as to whether report received
from the executive compliance or marketing representative* suggesting
money laundering or not.
*report of suspicious transaction is not limited to compliance officer and
marketing representative only nevertheless the burden is equivalently shared
with all ARIM upon identifying suspicious transaction.
Upon thorough investigation and the head of compliance found out that
there is no money laundering in placed then record of all documents
retrieved from the investigation conducted shall be kept for at least 6
years based on the requirement of Bank Negara Malaysia.
However, upon thorough investigation Compliance found out that there is
suspicious money laundering hence Compliance is obliged to report to the
Bank Negara Malaysia by filling in the prescribed form of suspicious
transaction from Bank Negara Malaysia and lodged it to the Bank Negara
Malaysia. Compliance shall notify the Board of Directors too and
suspected account shall remain to be suspended until further notice from
Bank Negara Malaysia.
Information pertaining to daily monitoring conducted on funds

management shall be recorded in the weekly report specifically under the
section 6.0 AMLA Monitoring for direct mandate. Remarks shall be
Example:
Remarks*:
2014
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The weekly report shall contains the following details:
No
Stock name
Initial investment
Capital injection
Suspicious transaction
If there is no transaction for the day or for the whole week, Compliance
shall leave the report blank with indication of NIL and slashed out the
information table.
Such Information shall be reported to the Head of Compliance and
recorded in the log book* error as well.
Compliance
Date of breaches
Details
By whom
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Type of breach
Noted by
QP-COMP-01
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Compliance &
Affected
departments
Kindly refer to the process of generating report form the OzAsia system
as per the Flowchart 12.
Compliance
Marketing
department
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FUNDS MANAGEMENT
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TOMS SYSTEM:
This system is designed specifically to monitor transaction on the unit
trust funds as per below:
i.
ARUTF
ii.
ARSTF
iii.
ARICMF
iv.
ARCMF
v.
ARIEF
When generating the report via Toms; Compliance shall focus on the
name of company or individual that appears on the unit holder name,
joint holder name, agent name and bank description column.
Compliance shall note that transaction perform by which funds can be
identified on the header of the report generated i.e. AmanahRaya Islamic
Equity Fund.
Compliance shall focus on the investment amount invested by the client
whether it trigger the money laundering amount for individual and
company. Compliance may refer to the guidelines on Anti- Money
Laundering by Bank Negara Malaysia or Securities Commission of
Malaysia.
Compliance
Any suspicious transaction shall be reported to the Head of Compliance
and recorded in the log book* error.
Compliance shall in a timely manner notify marketing department i.e.
Puan Latifah to obtain justification for the suspicious transaction and to
suspend the suspicious account. Notification can be in any forms of
communication i.e. via email, phone call or face to face interaction.
Respective person responsible of performing such transaction is required
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to provide immediate justification and action plan as to mitigate such

suspicious transaction from occurring.
Compliance shall retrieved all the information pertaining to the suspected
individual or company i.e. the opening account form, due diligence form,
kyc form as to perform thorough investigation i.e. whether transaction
perform by this individual or company is compatible with their financial
standing and to come out with conclusion as to whether report received
from the executive compliance or marketing representative* suggesting
money laundering or not.
*report of suspicious transaction is not limited to compliance officer and
marketing representative only nevertheless the burden is equivalently shared
with all ARIM upon identifying suspicious transaction.
Upon thorough investigation and the head of compliance found out that
there is no money laundering in placed then record of all documents
retrieved from the investigation conducted shall be kept for at least 6
years based on the requirement of Bank Negara Malaysia. Compliance
shall keep all records and documents of daily transactions, in specific
files i.e. stop loss record file and equities and research department.
While Marketing department shall keep all records and documents of
transactions, in particular, those obtained during customer due diligence
procedures, for at least six years after the transaction has been completed
or after the business relations with the customer have ended.
In situations where the records are subject to on-going investigations or
prosecution in court, they shall be retained beyond the stipulated retention
period until it is confirmed by the Financial Intelligence Unit in Bank
Negara Malaysia, that such records are no longer needed.
In addition, the records kept must enable the reporting institution to
establish the history, circumstances and reconstruction of each
transaction. The records shall include at least:
the identity of the customer;
the identity of the beneficiary;
the type of transaction(e.g., deposit or withdrawal);
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the form of transaction (e.g., by cash or by cheque);
the instruction and the origin and destination of fund transfers;

and
the amount and type of currency.
However, upon thorough investigation Compliance found out that there is

suspicious money laundering hence Compliance is obliged to report to the
Bank Negara Malaysia by filling in the prescribed form of suspicious
transaction from Bank Negara Malaysia and lodged it to the Bank Negara
Malaysia. Compliance shall notify the Board of Directors too and
suspected account shall remain to be suspended until further notice from
Bank Negara Malaysia.
Information pertaining to daily monitoring conducted on funds

management shall be recorded in the weekly report specifically under the
section 6.0 AMLA Monitoring for unit trust fund. Remarks shall be added
at the bottom of reporting when there is a breach yet has been rectified
within that week of reporting period.
Example:
Remarks*:
Marketing &
Compliance

2014
The weekly report shall contains the following details:
No
Stock name
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Title:
Initial investment
Capital injection
Suspicious transaction
QP-COMP-01
Revision No:
Date:
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Marketing
If there is no transaction for the day or for the whole week, Compliance
shall leave the report blank with indication of NIL and slashed out the
information table.
Such Information shall be reported to the Head of Compliance and
recorded in the log book* error as well.
Date of breaches
Details
By whom
Type of breach
Noted by
Kindly refer to the process of generating report form the OzAsia system
as per the Flowchart 12.
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NEW CLIENT
Risk profiling shall be conducted through know your customer form,
enhanced due diligence form and account opening forms. These forms
must be filled up by every new client. Marketing side shall ensure that
forms are completed before submit to Compliance for verification
purposes.
Below are the list of forms required to be completed and given to
customer agreed to invest with ARIM and to be verified by the
compliance officer*:
-Fund application form
-Redemption form
-Product Highlight Sheet
-Suitability Assessment form
-Know Your Customer form
-FIMM pre investment form
-Qualified investor declaration form
*Note that documents are slightly varied depends on the types of investor i.e.
individual or company and type of investment whether in a wholesale or retail
fund.
None of the transaction shall be proceed without compliance verification

and client has 7 days to provide ARIM (based on ARIM internal policies
of accepting new client) with full disclosure of information and
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documents needed from the date of informing that documents or

information provided is incomplete. Marketing representative has the
obligation to follow up with the necessary clients.
For every new client injection or withdrawal will be signed-off by
Compliance upon received from the Marketing side. The responsibility is
on the Marketing department to ensure that log book* is signed in a
timely manner. The log book* is signed by Compliance officer and
verified monthly by the Head of Compliance.
CLIENTS COMPLAINT
ARIM is required to deal with complaints immediately within the

context of a formal complaints procedure. The complaints
procedure to be applied:
To both oral and written complaints

There are two types of complaint: Significant and nonsignificant complaints
a) Complaint: misleading, unsatisfactory or
unacceptable conduct of ARIM. Complaint
can be channelled via two mediums as
follows:
i) Management level
j) SC/FIMM or any other regulatory
level
b) Query: mere talking, not materially impact
to investment
In addition, ARIM shall ensure that
complaints from its clients are handled in a timely and

appropriate manner;
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clients complaints are satisfactorily resolved;

it maintains a register of complaints received and any
actions taken; and
the compliance officer has a copy of the register.
The process flow as follows:

a) If an oral or a written complaint is received, make a written note of the
detail as soon as possible
b) Forward one written copy of any complaint to the Compliance Officer
immediately
c) The Compliance Officer will log the complaint in the Complaints
Register, and determine whether the complaint is of a significant nature or
not;
d) Compliance will identify whether the complaint relates to a minor and

isolated mechanical or clerical error, the complaint is not deemed
significant or the complaint should still be dealt with as quickly as
possible, in the interests of good relations.
e) Both types of complaint received by the compliance Officer need to be
recorded and the Compliance Officer will provide a Complaint Form to
the staff who received the complaint for completion and further
investigation. (refer Appendix 1)
f) The complaint will be investigated by the Compliance Officer, who is
independent. In this context, independent means that the person
should have no involvement in the events given rise to the complaint.
g) When it becomes apparent that the complaint cannot be resolved
within 5 days, the Compliance Officer shall write a holding letter to the
client to advice the matter is still being investigated.
h) If the result of the investigation indicated that the complaint is
significant than the Compliance Officer is required to report to SC &
FIMM or EPF (if related) on quarterly basis.
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i) All significant complaint should be submitted to the Risk Management,

Compliance Committee [RMCC] for deliberation and action.
j) A complainant who is not satisfied may refer the complaint to the
Securities Commission [SC]/ [FIMM] and [EPF].
Alternatively client may also lodge their complaint to the following

regulators in the event of dissatisfied with ARIM ways of handling
complaint:
Clients Reporting Procedures

a) Securities Commission of Malaysia
If client suspect abuses Complaints concerning dealings in unit
trust in ARIM and is able to support claims, client may submit
complaint to the SC.
Complaint should include details such as:
Name of the complainant, mail and email addresses, and

telephone numbers.
The name, mail and email addresses, telephone numbers,

and any website address of party(ies) mentioned in the complaint
Specific details of how, why and when the matter

complained about arose
Complaints then will be referred to the appropriate department
within SC here a possible breach of securities laws is detected, the
matter will be referred to the Investigation Department of the SC
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for further investigations.

If client has a complaint regarding a monetary dispute not
exceeding RM100, 000.00 against a licensed intermediary, client
may be eligible to seek the assistance of the Securities Industry
Dispute Resolution Center (SIDREC). SIDREC is a body approved
by the SC to handle monetary claims by investors against
stockbrokers, futures brokers, fund managers and unit trust
management companies, amongst others, who are licensed under
the Capital Market and Services Act 2007, to conduct regulated
activities in Malaysia. Queries to SIDREC can be directed to.
The following is the sample of complaint form to SC:
http://www.sc.com.my/wpcontent/uploads/eng/html/invAffairs/complaintsForm.pdf
(Appendix ii)
b) Federation of Investment Managers of Malaysia

If client has a complaint against ARIM, client may lodge the
complaint by completing and submitting online FIMMs complaint
form
provided https://www.fimm.com.my/contact/complaintonline/ (Appendix iii)
Alternatively,
client
may
download
form
at
https://www.fimm.com.my/wpcontent/uploads/2013/06/Complaints-Form-Template-March2014.pdf (Appendix iv) and submit the completed FIMMs
complaint form to:
Legal, Secretarial & Regulatory Affairs
Federation of Investment Managers Malaysia
19-06-1, 6th Floor, PNB Damansara
No. 19, Lorong Dungun
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Damansara Heights
50490 Kuala Lumpur
Tel: 03-2092 3800
Fax: 03-2093 2700
E-mail: complaints@fimm.com.my
To allow complaint to be investigated properly, client should give
full and accurate information, including:
name, correspondence address, contact number and e-mail
address;
specific details of how, why and when the subject matter of

the complaint occurred
particulars of the member, distributor or consultant

complained against, including name, correspondence
address, contact number and e-mail address
documentary evidence that supports complaint
c) EPF [Complaint pertaining EPF MIS]
Oral complaint can be channelled via EPF call centre:
Telephone number: 03-89226000

Or any written complaint can be channelled via:
Fax number: 03-89226222 (Fax cover note)
Operating Hours
Monday to Friday: 8.00 am to 6.00 pm.
Closed on Saturdays, Sundays and Federal and Selangor Public Holidays.
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7.0
QUALITY RECORD
8.0
ATTACHMENT
9.0
DOCUMENT HISTORY
Date
19/09/2014
FLOWCHART
Revision No:
Date:
17/09/2014
NIL
Revision No.
10.
0
QP-COMP-01
Description
Issue for use
As attached
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NURUL AMIRA BINTI

MEOR KHAIRI BAZID

The purpose of this Quality Procedure [QP] is to ensure compliance with

AmanahRaya Unit Trust

Anti-money Laundering Officer for

Absence of C at the beginning of

Microsoft Excel is a spreadsheet

Employee Provident Fund

Fund Manager [FM]

The person(s) responsible for

Kumpulan Wang Bersama

Marketing department at ARIM

Software deals with investment and

Portfolio Turnover Ratio

Securities Commission of Malaysia

Trade order management solution

Equity quality procedure;

Marketing quality procedure;

Compliance internal process flow on OzAsia system;

Unit trust fund/funds management policy;

Guidelines on Anti-money Laundering [AMLA] from Bank

OPENING OF ACCOUNT FUNDS MANAGEMENT

clients portfolio and direct mandates i.e. account opening forms,

Kindly refer to Flowchart 1 on the complete process of creating new

STOP LOSS MONITORING

General reporting stages:

Currently monitoring stop loss are based on the following accounts:

Kumpulan Wang Simpanan Pekerja [KWSP] C0423 [FM:Meor];

Kumpulan Majlis Raja-Raja yang Dipertua Negara C0299 [FM:

Tabung Warisan Negeri Selangor C0497 [FM: Qawiem];

ARUTM For PB Trustee Services Berhad (ARIE) C0482 [FM: Yap

KWB Shariah Equity C0391[FM: Yap Jia];

In monitoring this report, Compliance shall focus on the % on

Compliance shall in a timely manner notify Fund manager

Information that is inconsistent with the policy upheld shall be

The log book* error shall contains the following details*:

Action by respective departments

Information pertaining to daily monitoring conducted on stop loss shall

G/L (Gain or loss)

Type of Breach*(it can be technical or error from Fund Manager)

Action by respective person/department

Kindly refer to Flowchart 3 for details process flow of monitoring stop

SINGLE STOCK REPORT MONITORING

1. When report is retrieved via OzAsia system, Compliance shall

i. technical breach due to clients instruction;

2. Monitoring shall be conducted on a daily basis in the OzAsia

3. Information that is inconsistent with the policy upheld shall be

5. The log book* error shall contains the following details:

Action by respective departments

6. Information pertaining to daily monitoring conducted on single

G/L (Gain or loss)

Type of Breach*(it can be technical or error from Fund Manager)

Action by respective person/department

This weekly report comprises of daily monitoring conducted within a

CUSTOMER AND COMPANY CAPPING

to restrict purchase of stock/s; and/or

to permit purchase of stock/s; and/or

to permit sale of stock/s.

For illustration purposes, Company A instructed FM not to proceed with

2. Bursa Malaysia Berhad

3. Malaysian Resources Corp.

1. RHB Capital Berhad

6. United Plantation Bhd