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Compliance

Compliance is a critical component of our investment management process

Pre-Trade Risk Management and Compliance Check

All Management, Compliance, and trade orders are implemented through the Electronic system

     – Portfolio managers execute all trade orders through the OMS trading system – Check the investment guidelines through the electronic system set up in advance

Real-time Fund Monitoring: Remove the potential breach

     – Compliance Team supervises whether the portfolio manager complies to the given regulations and investor’s guideline

Brokerage house Allocation

     – Trading team executes limitation of stock trade by using internal evaluation criteria and decides the allocation of trading orders to each broker – Monitor the appropriateness of execution and quality of execution

Post-Trade Risk Management and Compliance Check

The Risk Management and Compliance Team performs post-trade risk management and compliance checks in the PMS trading system and KASS fund administration system on a daily basis

Compliance Management

     – The team monitors any warning sign for possible breaches to prevent the portfolios from exceeding risk limit – If a portfolio manager commits a breach, the daily compliance report is sent to the portfolio manager and a rationale statement with a resolution schedule is required to be submitted – If a portfolio manager is close to committing a breach, an alert is sent to the portfolio manager

Reporting and Feedback

     – Confirmation is needed once such a breach is corrected – Compliance is an important part of an individual portfolio manager’s annual performance evaluation
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