Annual Report 2010
Corporate Governance Statement

Corporate Governance Statement

 

The purpose of this statement is to provide investors with an insight into the CG practices of the Company in addition to compliance with paragraph 15.25 of the MMLR under the principled leadership of the Board. This statement serves as a testament of the Board's commitment to keep the corporate conscience alive in its continuous effort to strive for the highest standards of CG practice in Bursa Malaysia.
 
The Board of Directors

  1. Principal Responsibilities of the Board

  1. The Board has six specific responsibilities, as described below, which are discharged in the best interests of the Company, in pursuance of an integrated regulatory and commercial objective:

    1. Reviewing and adopting a strategic plan for the Company

      The Board plays an active role in the strategy development and planning process. At the end of each year, the management presents to the Board for approval the proposed strategy for the ensuing year. The process includes review and suggestion by the Board, leading to approval of the annual business plan and budget as well as the setting of corporate KPIs. The corresponding targets are used by the Board for evaluating the Company's actual performance.

      At an offsite meeting in October 2009, the NEDs reviewed and challenged the management in the light of current market issues, gave their input to modify the approach in line with the strategic objectives set for 2009-2011. In doing so, the Board considered the proposed priorities and initiatives aimed at developing a differentiated value proposition for Bursa Malaysia to enhance its competitiveness and to achieve its regulatory goals. This served as guidance in formulating and mapping the strategies into the 2010 Business and Regulatory Plans which were subsequently approved in November 2009.

      A mid-year review of the 2010 Plans was conducted by the Board in June 2010. The management presented the status of strategy implementation together with key initiatives undertaken in the first half of the year as indicated in the strategy dashboard and the CBS. The management also reported on the year-to-date financial performance for comparison against budget.

      The Board continuously focused its deliberations on business strategy, product development and market infrastructure for the securities, derivatives and Islamic markets.

      A similar process was adopted in November 2010 for the development of the 2011 Business and Regulatory Plans. The Board reviewed the sustainability, value and effectiveness of the implementation of the strategic plan in 2010, and discussed substantively the potential development areas for improving Bursa Malaysia's positioning as an investment and listing destination of choice.
    2. Overseeing the conduct of the Company's business to evaluate whether the business is being properly managed

      The Governance Model for the Group which is supported by the ALD was revised to reflect the flow of authority and functions of the CEO and management, including relevant business governance and rules committees, in accordance with the approved financial limits as set out in the ALD to facilitate an efficient approval process. The OC was removed from the Governance Model upon the expiry of the ESOS on 8 March 2010.

      The ALD sets out clearly the relevant matters which are reserved for the Board's approval, as well as those matters which the Board may delegate to the Board Committees1, the CEO and management to ensure an optimum structure and efficient decision-making in the organisation. The Group management governance framework is put in place to enable good business and regulatory governance in accordance with the approved policies and guidelines which remain within the Board's oversight.

      The key matters reserved for the Board's approval include the annual business plan and budget, dividend policy, business continuity plan, new issues of securities, strategic collaboration which involves business restructuring, acquisitions and disposals of companies within the Group, as well as disposals of significant fixed assets.

      Board Committees are entrusted with specific responsibilities to oversee the affairs of the Company, with authority to act on behalf of the Board in accordance with their respective TOR. At each Board meeting, the minutes of the Board Committee meetings are presented to the Board for information. The Chairman of the relevant Board Committee will also report to the Board on the key issues deliberated by the Board Committee at its meeting.

      The CEO is responsible for the day-to-day management of the business and operations of the Group in respect of both its regulatory and commercial functions. He is supported by the Leadership Team, as set out on pages 25 to 27 of the Annual Report. The CEO provides the Board with a monthly status report which includes a detailed summary of the Group's operating drivers and financial performance for the period as well as updates on key strategic initiatives and significant operational issues.

      As a measure to ensure the independence of the regulatory function, the CRO provides the Board with a separate status report on a regular basis, to inform the Board of actions taken by the Regulation group and provide updates on regulatory initiatives. In March 2010, the Board also reviewed the Annual Regulatory Report 2009 before the report was submitted to the SC. The Regulation group also kept the Board updated on the steps taken in response to the issues raised by the SC in the Regulatory Assessment Report of the previous year.

      In addition, the Board reviewed the findings of the 2009 Customer Satisfaction Survey conducted by an external research firm, Synovate. The survey showed improvement in the level of satisfaction among Bursa Malaysia's external stakeholders compared with the previous year, as well as the relevant business units or functional groups' contribution to the quality of business process, overall image and value. The outcome of the survey is used as guidance to focus on areas which require improvement.

      1. The Board Committees comprise three Governance Committees and four Regulatory Committees as set out in the Governance Model of Bursa Malaysia on page 80 of the Annual Report. The TOR and composition of each Board Committee is available at www.bursamalaysia.com.
    3. Identifying principal risks and ensuring the implementation of appropriate systems to manage these risks

      Through the RMC, the Board oversees the ERM framework of the Group. The RMC advises the AC and the Board on areas of high risk faced by the Group and the adequacy of compliance and control throughout the organisation. The RMC reviews the risk management policies formulated by management and makes relevant recommendations to the Board for approval. Further details on the RMC and the Company's ERM framework are set out on pages 74 to 75 of the Annual Report.
    4. Succession planning including appointing, training, fixing of compensation and, where appropriate, replacing senior management

      The Board has entrusted the NRC with responsibility to recommend candidates for appointment to the Board, Board Committees and key management positions, to determine compensation packages for these appointments, and to formulate the nomination, selection, compensation and succession policies for the Group. The Board is satisfied that the NRC, in its current form, effectively and efficiently discharges its functions and, accordingly, decided in February 2010 that there was no need to separate the nomination and remuneration functions into discrete Nomination and Remuneration committees.

      In September 2010, the NRC reviewed its TOR to reflect the nomination and remuneration matters separately for the purpose of clarity. As a result, it set out more expansively the practices undertaken by the NRC as authorised by the Board, to enhance Board effectiveness.

      In reviewing the Directors' succession in line with the Board's 9-year policy, the NRC proposed to the Board in July 2010 the establishment of data for a pool of potential directors. Each existing Board member was asked to provide names of persons he considered fit to be a director of the Company, thus providing for the continued effective functioning and progressive refreshing of the Board.

      With the expiry of the CEO's contract in January 2012, the Board established a Special Task Force (STF) in July 2010 to identify potential candidates for the CEO position. The STF first established selection criteria and essential qualities of a successor, including leadership skills, strategic thinking capability, ability to implement change and other relevant factors. A broad spectrum of both internal and external candidates was reviewed, taking into account background and working experience, set against the backdrop of the criteria. The STF presented its report together with a short-list of candidates for the NRC's consideration, which the NRC deliberated upon and, thereafter, gave its recommendations to the Board.

      The NRC also considered the final candidate's remuneration package as part of the CEO's appointment process, and further recommended the same to the Board for approval. In February 2011, the Board agreed with the NRC's recommendation on the selection of the final candidate to be the CEO in succession, based on his competencies, strength and achievements, which are viewed to be capable of driving Bursa Malaysia forward in the changing exchanges landscape.

      The NRC is also entrusted with the review of the human resources plan of Bursa Malaysia, including the succession management framework and activities, human resource initiatives and the annual manpower budget. In January 2010, the NRC embarked on a search and selection process for key management positions. The appointment of Global Head, Securities Markets was approved in July 2010 based on the revised organisation structure. Proposed candidate for the CMOO position was considered in December 2010 in view of replacing the retired CMOO.

      The NRC undertakes a yearly evaluation of the performance of key management personnel (except for the Head of Group IA/CIA who reports directly to the AC) whose remuneration is directly linked to performance. For this purpose, the 2009 CBS and KPIs results of the CEO, the COO and CRO were reviewed by NRC in February 2010. The AC assessed the performance of Head of Group IA, and further recommended the Head of GIA's 2009 Balanced Scorecard and KPIs results to the NRC for determination of his discretionary performance reward.

      In the fourth quarter of 2010, the NRC also reviewed the performance of the CRO for approving the renewal of the CRO's service contract together with her remuneration package for the next three years. The NRC further made recommendations to the SC with its approval on the CRO's appointment in accordance with the Guidance on the Regulatory Role of Bursa Malaysia.
    5. Developing and implementing an investor relations programme or shareholder communications policy for the Company

      Bursa Malaysia believes in building investor confidence through good CG, and the Company carried out its IR activities in accordance with the IR Policy which is available on Bursa Malaysia's website. A separate report on IR activities is provided on pages 56 to 57 of the Annual Report.
    6. Reviewing the adequacy and integrity of the Company's internal control systems and management information systems, including systems for compliance with applicable laws, regulations, rules, directives and guidelines

      The Board is ultimately responsible for the adequacy and integrity of the Company's internal control system. The details on the Company's internal control system and the review of its effectiveness are set out in the Internal Control Statement and Risk Management Statement on pages 71 to 73 and pages 74 to 75 of the Annual Report respectively.

  1. Constituting an Effective Board

    1. Board Balance and Independence

      The Board of Bursa Malaysia comprises 13 Directors. Four directors are PIDs, eight are Independent NEDs and there is one Executive Director, who is also the CEO. The four PIDs are appointed by the MOF in line with the requirements under the CMSA for the Company to act in the public interest, having particular regard to the need for the protection of investors in performing its duties as an exchange holding company. In addition, the PIDs and Independent NEDs are all independent of management and free from any business or other relationship which could materially interfere with the exercise of their independent judgement. Through the BEE Directors' Self and Peer Assessment, the NEDs have indicated their satisfaction with the level of independence of each of their peers and their ability to act in the best interest of the Company in decisionmaking. The Directors have made a valuable contribution to the Company through their business acumen, and the application of a wide range of functional knowledge and skills from their long-standing experience. They are drawn from differing backgrounds such as accountancy, law, regulation, business, finance, stock broking and risk management. The profile of each Director is set out in the Board of Directors' Profile on pages 18 to 24 of the Annual Report.

      The Board is satisfied with its existing number and composition. In this regard, the Board is of the view that the current size of the Board is appropriate given the unique composition of the Board comprising PIDs, as well as the governance and regulatory functions of an exchange holding company. It is also of the view that it has the right mix of skills, experience and strength in qualities which are relevant and enable the Board to carry out its responsibilities in an effective and competent manner.

      In Bursa Malaysia, the Chairman, who is a PID, leads the Board. In turn, the Board monitors the functions of the Board Committees in accordance with the respective TOR to ensure its own effectiveness, while the CEO manages the business and operations of the Company and implements the Board's decisions. The distinct and separate roles of the Chairman and CEO with a clear division of responsibilities, ensures a balance of power and authority, such that no one individual has unfettered powers of decision-making.

      For the foregoing reason, and given the Board's ability to act independently and objectively due to its unique composition with 1/3 PID and more than 1/3 NED, the existing structure was considered adequate to enable any concern on the Company to be conveyed or channelled to the Board for its deliberation. Nevertheless, in January 2011, the Board appointed Dato' Dr. Thillainathan to be the Senior Independent NED2 as an additional safeguard, to serve as a fallback point of contact for investors and shareholders when the normal channel of communication is considered to be inappropriate or inadequate.

      As at 31 December 2010, the Company has more than 60% public shareholding. None of the Directors are nominees of the Company's substantial shareholders, and the Company does not have any "significant shareholders" as defined under the CG Code3. In view of the composition of the Board and the calibre, expertise and experience of the Directors, the interests of investors including the Company's minority shareholders and the public are adequately protected and advanced.

      1. The contact details are set out in the Corporate Information on page 83 of the Annual Report.

  1. Board Structures and Procedures

    1. Board and Board Committee Meetings

      The Board of Directors' convened 12 meetings in 2010, out of which eight were scheduled in advance (including two Board offsite meetings) and four were special meetings. The Directors' attendance was as follows:

      Name of Directors Attendance
      Tun Mohamed Dzaiddin bin Haji Abdullah (Chairman) 11/12
      Dato' Tajuddin bin Atan 11/12
      Datuk Dr. Md Tap bin Salleh4 8/9
      Datuk Dr. Syed Muhamad bin Syed Abdul Kadir5 3/3
      Dato' Abdul Latif bin Abdullah6 3/3
      Datuk Haji Faisyal bin
      Datuk Yusof Hamdain Diego7
      7/7
      Datin Paduka Siti Sa'diah binti Sheikh Bakir 10/12
      Dato' Dr. Thillainathan a/l Ramasamy 11/12
      Dato' Sri Abdul Wahid bin Omar 9/12
      Izham bin Yusoff 10/12
      Dato' Wong Puan Wah @ Wong Sulong 12/12
      Cheah Tek Kuang 9/12
      Dato' Saiful Bahri bin Zainuddin 10/12
      Ong Leong Huat @ Wong Joo Hwa 10/12
      Dato' Yusli bin Mohamed Yusoff (CEO) 11/12

      In 2010, there were five NEDs meetings led by the Chairman of the Board, to discuss corporate and organisational issues with a view to enhancing the overall effectiveness of the Board. Issues of concern that were raised during the NEDs meetings were communicated to the CEO for his necessary action and management's continuous improvement.

      The Board annual meeting calendar is prepared and circulated to Directors before the beginning of each year. The calendar provides the scheduled dates for meetings of the Board, Board Committees and shareholders, major conferences hosted by the Company, as well as the closed period for dealings in securities by Directors based on the targeted date of announcement of quarterly results of the Group. The agenda of each Board meeting is finalised by the Chairman. Meeting papers are prepared by management in accordance with an existing agreed format which provides relevant facts, analysis and recommendation for supporting the proposals to enable informed decision-making by the Board. The agenda and papers for meetings are furnished to Directors and Board Committee members in advance to enable them to prepare for the meetings. At Board meetings, the management presents the papers, and consultants may be invited to provide further insight. The Chairman encourages constructive, healthy debate, and Directors are given the chance to freely express their views or share information with their peers in the course of deliberation. Any Director/Board Committee member who has a direct or deemed interest in the subject matter to be deliberated shall abstain from deliberation and voting on the same during the meeting.

      The Company Secretary ensures there is a quorum for all meetings and that such meetings are convened in accordance with the relevant TORs. The minutes prepared by the Company Secretary memorialise the proceedings of all meetings including pertinent issues, the substance of inquiry and response, members' suggestions and the decisions made. In doing so, the Company Secretary internalises the governance principles in the Company and keeps the Board updated on the followup action arising from the Board's decision and/or request at subsequent meeting. This allows the Board to perform its fiduciary duties and oversight role of the respective Board Committees' functions.

      1. Under the CG Code, a "significant shareholder" is defined as a shareholder with the ability to exercise a majority of votes for the election of directors. CMDF and MOF Inc, being the largest shareholders in Bursa Malaysia as at 31 December 2010 have equal shareholdings in the Company. Details of their shareholdings are set out in Statistics of Shareholdings as at 14 February 2011 on page 175 of the Annual Report.
      2. appointed as a PID on 1 April 2010.
      3. appointed as a PID on 5 August 2010.
      4. ceased to be a PID w.e.f. 1 April 2010.
      5. ceased to be a PID w.e.f. 9 June 2010.
    2. Supply of and Access to Information

      The Directors have individual and independent access to the advice and dedicated support services of the Company Secretary in ensuring effective functioning of the Board. The Directors may seek advice from the Leadership Team or management on issues under their respective purview. The Directors may also interact directly with, or request further explanation, information or update on any aspect of the Company's operations or business concerns from the Leadership Team. In addition, the Board may seek independent professional advice at the Company's expense on specific issues to enable the Board to discharge its duties in relation to the matters being deliberated. Individual Directors may also obtain independent professional or other advice in furtherance of their duties, subject to approval by the Chairman or the Board, depending on the quantum of the fees involved.
    3. Board Effectiveness Evaluation

      The Board has entrusted the NRC with the responsibility for carrying out the annual BEE. An external consultant is engaged to carry out the BEE every three years, and this exercise was last conducted in 2008. In 2010, the Company Secretary facilitated the NRC in carrying out the BEE exercise. The BEE was conducted via questionnaires, which comprise a Board and Board Committee effectiveness assessment, and a Directors and Board Committee members self and peer assessment. The NRC reviews the outcome of the BEE exercise, recommends to the Board action plans for improvement and follows up on the action plans.

      The Board assessed its effectiveness in the areas of composition, administration, accountability and responsibility, conduct, the performance of Chairman and CEO. The Board, through the Board Committee effectiveness assessment, examined the respective Board Committees, including their respective Chairmen, to ascertain whether their function and duties are effectively discharged in accordance with the TOR. The Directors self and peer assessment is intended to evaluate the mix of skills, experience and other relevant qualities the NEDs should bring to the Board, and takes into account the individual director's ability to exercise independent judgement at all times and their contribution to the effective functioning of the Board. The self and peer assessment process also examines the ability of each Board or Committee member to give material input at meetings and demonstrate a high level of professionalism and integrity in the decision-making process. The assessment results form the basis of the NRC's recommendation to the Board for the re-election of Directors at the next AGM.

      The Company Secretary collates the feedback and summarises the findings, with the assurance of anonymity, as part of the governance review process. The NRC analyses the BEE results and recommends to the Board an action plan for improvement in the areas identified in the BEE. Each Board and Board Committee member is provided with individual results together with a peer average rating on each area of assessment for personal development.
    4. Training of Directors

      The Company provides a dedicated training budget for Directors' continuing education. Relevant training (internal or external) programmes are arranged by the Company Secretary for the Directors and members of Board Committees. The Directors were also invited via e-mail to attend training on CG for continuous development and update on CG best practices. A series of talks was organised by Bursa Malaysia together with various professional bodies throughout the year, including 'Technical Week on Leading Governance' held in April 2010 and SC-Bursa Malaysia CG Week-Towards CG Excellence from 28 June 2010 to 2 July 2010.

      The Directors may also request to attend additional training courses according to their individual needs as a director or member of Board Committees on which they serve. In 2010, all Directors attended development and training programmes, the details of which are set out on pages 167 to 171 of the Annual Report. Each Director has attended at least three training sessions on capital market development in 2010 in accordance with the internal policy to keep abreast with industry developments and trends.

      Two newly appointed PID, Datuk Dr. Md Tap completed the Mandatory Accreditation Programme (MAP) in April 2010 whilst Datuk Dr. Syed Muhamad completed the MAP in May 2005 when he was first appointed as a director of a listed issuer in June 2005. They also attended the induction programme organised by the Company Secretary to familiarise themselves with the Group's business and governance processes. They were provided with a Directors' manual which contains the Group Governance Model, TOR and other applicable policy, guidance or guidelines for their easy reference.

      An offsite session was held on 9 December 2010 for the LC members to discuss on common area of breaches, enforcement actions and policies, as well as the proposed changes to the LR and Corporate Disclosure Guide. The MPC members also had an offsite session on 14 December 2010 to review its enforcement policies, enforcement impact on key breaches and to discuss on key area of changes proposed under the revamped business rules in relation to market participants.

  1. Appointments to the Board and Board Committees

    1. Appointments to the Board

      The NRC, which comprises one PID and four Independent NEDs, has the responsibility to make recommendations to the Board for the appointment of Directors other than PIDs. As part of this process, the NRC formulates the nomination and selection policies for the Board, and reviews candidates for appointment as Directors based on criteria such as their qualifications, skills, functional knowledge, experience, character, integrity and professionalism. The NRC also evaluates the candidate's ability to discharge his responsibilities as expected from an independent NED and whether the test of independence under the MMLR is satisfied, taking into account his character, integrity and professionalism.

      The Board has also approved the nine-year policy as guidance where an independent NED who has served for nine years on the Board, will be subjected to a rigorous review by the Board, to determine whether the Director can continue to be independent in character and judgement, and also to take into account the need for progressive refreshing of the Board.

      In 2010, there was no proposal of any candidate for directorship at the 33rd AGM which was subject to Article 71 of the AA and the SC's approval. However, two PIDs were newly appointed by the Minister of Finance pursuant to Section 10(1) of the CMSA in April and August 2010 respectively.
    2. Appointments to the Board Committees

      The NRC is responsible for reviewing candidates for appointment to the Board Committees, and makes recommendations to the Board for approval. The review is conducted on an annual basis and when the need arises. The Board Committee members' self and peer assessment results are used as reference by the NRC in recommending to the Board for approval of the appointment of the relevant Board Committees members for the ensuing term.

      In April 2010, the Board established an ad-hoc Board Committee, the Corporate Health Check Committee (CHCC), which comprised independent NEDs, to ascertain the general health condition and progress of Bursa Malaysia since its listing in 2005, and to determine factors which could potentially hinder effectiveness of the organisation. The CHCC's recommendations were approved by the Board to be implemented for the benefit and growth of the Company, which is also fundamental to good CG.

  1. Re-election of Directors

  1. Pursuant to Article 69 of the AA, an election of Directors other than the PID, shall take place each year at the AGM of the Company where one-third of the Directors who are longest in office shall retire and, if eligible, may offer themselves for re-election. The NRC is also responsible for making recommendations to the Board on the re-election of Directors through this process of retirement by rotation in accordance with the provisions of the AA. At the 33rd AGM held on 29 March 2010, four Directors retired by rotation and were re-elected to the Board by the shareholders.

    Pursuant to Section 129 of the CA, a Director who is over 70 years of age must retire at the AGM of the Company, and may be reappointed by shareholders with not less than a 3/4 majority. At the 33rd AGM, Tun Mohamed Dzaiddin bin Haji Abdullah, a PID was reappointed pursuant to this provision.

Directors' Remuneration

  1. Level and Make-up of Remuneration

  1. The current remuneration policy for the NEDs comprises the following:

    1. Directors' fees

      RM90,000 per annum for the Chairman and RM60,000 per annum for each NED (as approved by the shareholders at the 33rd AGM for FY2009).
    2. Meeting allowance for each Board or Board Committee8 meeting attended by a NED

      • RM3,000 for the Chairman of the Board;
      • RM1,500 for the other members of the Board;
      • RM1,500 for the Chairman of a Board Committee; and
      • RM1,000 for the other members of the Board Committees.

      The meeting allowance is also applicable to ad-hoc Board Committees and the Tender Evaluation Committee which the NEDs attend pursuant to the Company's policy and procedures.

      1. Information on the composition, number of meetings held and attendance of meetings of all Board Committees is set out on pages 81 to 82 of the Annual Report.
    3. Benefits-in-kind and emoluments

      NEDs are not entitled to participate in the ESOS or any incentive plan for employees of the Group. They are given other allowances such as travelling and mobile phone allowances comparable to other PLCs, particularly those in the financial sector, GLCs and selected stock exchanges. The Chairman is also given a monthly fixed allowance, revised to RM50,000 since 1 March 2010, in view of the scope of his responsibilities and the fact that he does not serve on the boards of any other PLCs or other market participants regulated by Bursa Malaysia to avoid COI.

      The Executive Director/CEO is not entitled to the above Director's fee nor is he entitled to receive any meeting allowance for the Board and Board Committee meetings he attends. The CEO's remuneration package comprises a monthly salary and other benefits/emoluments.

      In addition to the above, the Directors have the benefit of D&O Insurance in respect of liabilities arising from their acts committed in the capacity as D&O of Bursa Malaysia. However, the said insurance policy does not indemnify a Director or principal officer if he is proven to have acted negligently, fraudulently or dishonestly, or in breach of a duty or trust. The Directors and principal officers are required to contribute jointly to the premium of the D&O Insurance Policy.
  1. Procedure for Approving Board Remuneration

  1. The NRC is responsible for reviewing the remuneration of the NEDs and the Executive Director/CEO, and makes recommendations on the same to the Board for approval. In 2010, the Board approved the NRC's recommendation to maintain the existing remuneration policy, given that the Directors' fees were recently increased for FY2009 upon the shareholders' approval at the 33rd AGM. Accordingly, the Board agreed with the NRC's recommendation to maintain the remuneration of the NEDs as appropriate taking into account the fiduciary duties and time commitment expected of them.

    The CEO's remuneration package is linked to the performance of CBS and KPIs results for the previous year. In the evaluation, the NRC considers four perspectives: financial, customer, internal process, learning and growth. The CEO abstained from deliberation on his remuneration at the Board meeting.

    The last review of the CEO's remuneration package was conducted by the NRC in the third quarter of 2009, in conjunction with the renewal of his service contract taking into account pay mix trends and positioning across GLCs, financial institutions and investment banks, as well as regional exchanges. The same was recommended to the Board for decision.

  1. Disclosure of Board Remuneration

  1. Disclosure of each Director's remuneration is set out in the Annual Audited Financial Statements on page 126 of the Annual Report.

Shareholders

  1. Dialogue between the Company and Investors

  1. Bursa Malaysia communicates regularly with shareholders and investors through the annual report, quarterly financial reports and various announcements made via Bursa LINK. Financial and market statistics and press releases are placed on Bursa Malaysia's website to keep shareholders and investors informed on the Group's performance and operations. Analyst briefings are held twice a year, in connection with the half yearly and annual financial results, following announcements via Bursa LINK to ensure fair dissemination to the public generally. These briefings include a presentation, conference call as well as a Question and Answer session. The events are web-cast, and a transcript is also made available to all shareholders and investors on Bursa Malaysia's website. A detailed report on Investor Relations appears on pages 56 to 57 of the Annual Report.

  1. Annual General Meeting

  1. Although the AGM is mandated as an occasion for shareholders, the Chairman allowed representatives of the media to attend the 33rd AGM. All 13 Directors were present to account to the shareholders for their stewardship of the Company. The proceedings of the 33rd AGM included the CEO's presentation of the Company's operating and financial performance for 2009, the presentation of the external auditors' unqualified report to the shareholders, and a Question and Answer session in which the Chairman invited shareholders to raise questions on the Company's accounts and other items for adoption at the meeting, before putting a resolution to vote. The Directors, CEO/ management and external auditors were in attendance to respond to the shareholders' queries. The CEO also shared with the meeting the responses to the questions submitted in advance by the MSWG.

    Shareholders were invited to drop any additional questions in an enquiry box placed at the venue of 33rd AGM so that they might be responded to in writing after the meeting. The officers of the Company were also present to handle enquiries from shareholders.

    All NEDs abstained from voting on the resolution concerning their remuneration. The external auditors were on standby to act as scrutineers, but there was no demand for a poll. All the resolutions set out in the Notice of the 33rd AGM were put to vote by show of hands and duly passed. The outcome of the 33rd AGM was announced on the same day via Bursa LINK, which is accessible on Bursa Malaysia's website. The minutes of AGM were posted in the financial section of IR Portal.

    In response to the directive dated 19 February 2010 to all listed issuers, Bursa Malaysia had issued a letter to shareholders on 5 March 2010 together with Notice of 33rd AGM to inform the shareholders of the implementation of e-Dividend and its benefits in September 2010. The Company's representatives were available at the venue of 33rd AGM to brief the shareholders on the benefits of e-Dividend and the registration process in view of the commencement date of registration for e-Dividend on 19 April 2010.

  1. Corporate Sustainability

  1. The Board promotes good CG in the application of sustainability practices in Bursa Malaysia, the benefits of which will translate to better corporate performance. A detailed report on sustainability activities appears on pages 58 to 61 of the Annual Report.

Accountability and Audit

  1. Financial Reporting

  1. The Board ensures that shareholders are provided with a balanced and meaningful evaluation of the Company's financial performance, its position and its future prospects, through the issuance of Annual Audited Financial Statements and quarterly financial reports and corporate announcements on significant developments affecting the Company in accordance with the MMLR. In this respect, the financial statements are reviewed by the AC at its meetings, in the presence of external auditors and internal auditors, before being presented to the Board for approval. The CFO also presented to the AC and the Board slides containing details of revenues and expenses in the form of charts, for review of quarter-to-quarter and year-to-date financial performance against budget. The Chairman's Message and CEO's Message on pages 16 to 17 and pages 34 to 47 of the Annual Report provide additional analysis and commentary. The Directors' Responsibility Statement for the Annual Audited Financial Statements of the Company and Group is set out on page 87 of the Annual Report.

  1. Internal Control

  1. The Company continues to maintain and review its internal control procedures to ensure, as far as possible, the protection of its assets and its shareholders' investments. Details of the Company's internal control system and the framework are set out in the Internal Control Statement together with Risk Management Statement and AC Report on pages 71 to 73, pages 74 to 75 and pages 76 to 77 of the Annual Report respectively.

  1. Relationship with Auditors

  1. Bursa Malaysia's relationship with its external auditors is primarily maintained through the AC and the Board. The AC has explicit authority to communicate directly with external and internal auditors. The Head of Group IA reports directly to the AC and he/she is present at all AC meetings together with the relevant members of his staff. The CEO and management only attend the AC meetings upon invitation. The external auditors did not call for any other meeting with the AC apart from the review of financial statements. The AC held two meetings with the external auditors in 2010 to discuss management's cooperation in the audit process, the quality and competency in the financial reporting function, the state of affairs of the IA function and audit issues in relation to appropriate accounting treatment. These meetings were held without the presence of the Head/Acting Head of Group IA and internal auditors, the CEO and management. Further details on the AC in relation to the external auditors are set out in the AC Report on pages 76 to 77 of the Annual Report.

Other Areas

  1. Conflict of Interest

  1. In addition to being a business oriented listed entity, Bursa Malaysia has also discharged its obligation as a market regulator. In this regard, COI or potential COI may arise in the course of Bursa Malaysia or its subsidiaries carrying out their respective functions for commercial reasons or the proper performance of its statutory duties as an exchange holding company. Where Bursa Malaysia's own or any other interest conflicts with the public interest, the latter will prevail as Bursa Malaysia is bound by law to act in the public interest, having regard to the need for investor protection.

    Bursa Malaysia has continued to maintain the separation of business functions from its regulatory functions. This is to ensure that these functions operate independently, and that business units within Bursa Malaysia are not in a position to influence any supervisory or regulatory decisions made by Regulation. Furthermore, Bursa Malaysia has put into place arrangements and appropriate controls to identify and deal with COI. During the year, Bursa Malaysia has conducted briefing to staff to educate and instil greater awareness pertaining to the COI Guidelines. The Group IA has also performed review on compliance with certain internal processes and procedures, to ensure that conflicts are being properly identified and managed.

    In 2010, there was no actual COI arising between Bursa Malaysia's commercial interests and the proper performance of its regulatory duties.

  1. Related Party Transactions

  1. An internal compliance framework exists to ensure that the Company meets its obligations under the MMLR including obligations in connection with related party transactions. The Board, through the AC, reviews all related party transactions. A Director who has an interest in a transaction must abstain from deliberation and voting on the relevant resolution in respect of such transaction at the Board meeting. In 2010, there was no transaction entered into by Bursa Malaysia or its subsidiaries involving conflicts arising from the direct or indirect interest of a director or person connected with such director.

    A list of the significant related party disclosures between the Company and its subsidiaries, and between the Group and other related parties including relevant key management personnel for FY2010 is set out on pages 152 to 154 of the Annual Report.

  1. Code of Ethics

  1. The Company's Codes of Ethics for Directors and employees continue to govern the standards of ethics and good conduct expected from Directors and employees, respectively. The Code of Ethics for Directors, for example, includes principles relating to the Directors' duties, COI and dealings in securities. For employees, the Code of Ethics covers all aspects of the business operations of the Company such as confidentiality of information, dealings in securities, COI, gifts, gratuities or bribes, dishonest conduct, sexual harassment and the Company's whistle-blowing procedures.

    The management conducted a review on the Code of Ethics for employees with an aim to enhance effectiveness of the whistle-blowing mechanism and procedures. The management also undertook further review in the light of the Whistleblower Protection Act 2010 which came into effect on 15 December 2010.

  1. Dealing in Securities

  1. The Guidance to Directors for Dealings in Securities was revised in September 2010 to provide clarity to the procedures for compliance by Directors in accordance with the MMLR when dealing in securities of Bursa Malaysia during and outside the closed periods. The revision comprised the relevant provisions on the Directors' duty to make disclosure under the CA and CMSA using the prescribed form of notification for dealings in securities of Bursa Malaysia. The Guidance also provides that Directors must not deal in securities as long as they are in possession of price-sensitive information, consistent with CMSA which prohibits insider trading. In 2010, none of the Directors dealt in securities of Bursa Malaysia during closed periods, although they may do so under exceptional circumstances if deemed acceptable by the Chairman of the Board or, in his absence, the AC Chairman.

    The employees of the Company (including principal officers) are informed in advance through internal communication via e-mail before the commencement of each closed period, in which they are not allowed to trade as prescribed under the Securities Transaction Policy to curb insider trading and to avoid COI.

Compliance Statement

The Board is satisfied that in 2010 the Company has complied with the best practices of the CG Code save for the appointment of a Senior Independent NED, which took effect in January 2011.