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RISK MANAGEMENT POLICY
                    GROUP LEGAL SERVICES DEPARTMENT
                         LAND & GENERAL BERHAD

A.    Risk Management Policy

      1.     Providing legal services to the various departments and subsidiaries so as
             adherence to the various legislation in Malaysia are met with. This are not
             limited to the Housing Developers Act but encompasses the Company’s Act,
             Securities Industries Act and the Listing Requirements of the Kuala Lumpur
             Stock Exchange.

      2.     Assisting the Corporate Services Department in obtaining approval from
             relevant authorities in the corporate exercises undertaken by the Group.

      3.      Render legal advice to the in house departments by undertaking research.

To provide legal advice and services within the Group. To minimise the risks of legal
action being taken against the Group and that all legal action concerning the Group are
monitored.
B.     Factors Affecting Risk Management

Internal factors and measures to mitigate risks

              Internal factors                              Measures to mitigate risks

                                                  •
1. Ambiguous instructions                             To confirm the instructions (where
                                                      necessary received so that a clear
                                                      understanding of the task at hand is
                                                      obtained before proceeding with the matter
                                                      at hand.

                                                  •   To check with the ‘process owner’ that the
                                                      instructions have been carried out.


                                                  •
2.      Non Adherence/compliance with                 To advice the relevant subsidiaries and
the Companies Act, the KLSE LR, the                   departments to comply with the relevant
Securities Industry Act, Housing                      laws and relevant authorities’ guidelines
Development Act and Local Authorities                 and regulations.
regulations and procedures.
                                                  •   Upgrading of legal knowledge by attending
                                                      workshops and seminars.


                                                  •
1. Inadequate     facilities   for   record           Ensure that there are adequate facilities for
   keeping.                                           document keeping and record keeping.

2. Inherent risks with the PC with access         •   Proper security protocol is maintained for
   to the Internet associated with hackers.           the PC.

C.     External factors and measures to mitigate risks

 External factors                                 Measures to mitigate risk

1. Inadequate and poor delivery of legal •            To achieve sound advice, the fees
   opinion(s) and agreement(s) from                   payable should be adequate, taking into
   external solicitors.                               consideration the level of expertise and
                                                      experience of the solicitors concerned.


                                                  •
2. Changes in policies and legislation by             Monitor government policy through the
   the Government.                                    mass media.

                                                  •   Participate in meetings and briefing
                                                      sessions organised by relevant authorities

                                                  •   Maintain good rapport with regulatory
agencies.



D.     Measures to Mitigate Risks

Internal factors

1.     Ambiguous instructions or facts received.

       In order to effectively represent the Group, the personnel tasked with the matter is to
       confirm the instructions received so that a clear understanding of the task at hand is
       obtained before proceeding with the matter at hand and to check with the ‘process
       owner’ that the instructions have been carried out.

       In order for the Department to prepare the necessary documents and agreements, clear
       and unambiguous instructions on the matter should be given.

2. Non Adherence/compliance with the Companies Act, the KLSE LR, the Securities
   Industry Act, Housing Development Act and Local Authorities regulations and
   procedures.

       In order to mitigate this, proper briefing on the legislation involved should be
       undertaken. Towards this end, the Legal Department liaises with external solicitors on
       the latest updates on the law which would be made known to the Chief Operating
       Officers. Another method employed is continuous upgrading of legal knowledge by
       attending workshops and seminars.

3.     Inadequate facilities for record keeping

       Facilities for record keeping are important support service for the Group. This also
       serves as a historical record of transactions undertaken by the Group. At present there
       are adequate facilities for storage.

4.     Inherent risks with the PC with access to the Internet associated with hackers.

       On the PC’s this is done in conjunction with the Information and Communication
       Technology Department. There are basically four steps to be taken to ensure the
       security of the computer system. They include and are not limited to maintaining the
       Firewall/Anti virus systems, controlling and monitoring the Internet/web applications
       and the Intranet systems. Duplicating the files on to floppy disks regularly and
       maintaining secrecy of the passwords.

       External factors

1.     Inadequate and poor delivery of legal opinion(s) and agreement(s) from external
       solicitors.

       To obtain sound advice, the fees payable should be adequate, taking into consideration
       the level of expertise and experience of the solicitors concerned. It should be noted that
the Legal personnel in the Group relies on outside solicitors for various advises and
     opinions. This would be in relation to the corporate exercises undertaken by the Group.
     This can be mitigated by engaging senior counsels/solicitors; however in so engaging
     this would mean that the legal fees charged by the senior counsels/solicitors would be
     on a higher side due to their expertise and experiences.

2.   Changes in policies and legislation by the Government.

     Monitor government policy through the mass media. Participate in meetings and
     briefing sessions organised by relevant authorities and maintaining good rapport with
     the regulatory agencies.

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Risk Management Policy

  • 1. RISK MANAGEMENT POLICY GROUP LEGAL SERVICES DEPARTMENT LAND & GENERAL BERHAD A. Risk Management Policy 1. Providing legal services to the various departments and subsidiaries so as adherence to the various legislation in Malaysia are met with. This are not limited to the Housing Developers Act but encompasses the Company’s Act, Securities Industries Act and the Listing Requirements of the Kuala Lumpur Stock Exchange. 2. Assisting the Corporate Services Department in obtaining approval from relevant authorities in the corporate exercises undertaken by the Group. 3. Render legal advice to the in house departments by undertaking research. To provide legal advice and services within the Group. To minimise the risks of legal action being taken against the Group and that all legal action concerning the Group are monitored.
  • 2. B. Factors Affecting Risk Management Internal factors and measures to mitigate risks Internal factors Measures to mitigate risks • 1. Ambiguous instructions To confirm the instructions (where necessary received so that a clear understanding of the task at hand is obtained before proceeding with the matter at hand. • To check with the ‘process owner’ that the instructions have been carried out. • 2. Non Adherence/compliance with To advice the relevant subsidiaries and the Companies Act, the KLSE LR, the departments to comply with the relevant Securities Industry Act, Housing laws and relevant authorities’ guidelines Development Act and Local Authorities and regulations. regulations and procedures. • Upgrading of legal knowledge by attending workshops and seminars. • 1. Inadequate facilities for record Ensure that there are adequate facilities for keeping. document keeping and record keeping. 2. Inherent risks with the PC with access • Proper security protocol is maintained for to the Internet associated with hackers. the PC. C. External factors and measures to mitigate risks External factors Measures to mitigate risk 1. Inadequate and poor delivery of legal • To achieve sound advice, the fees opinion(s) and agreement(s) from payable should be adequate, taking into external solicitors. consideration the level of expertise and experience of the solicitors concerned. • 2. Changes in policies and legislation by Monitor government policy through the the Government. mass media. • Participate in meetings and briefing sessions organised by relevant authorities • Maintain good rapport with regulatory
  • 3. agencies. D. Measures to Mitigate Risks Internal factors 1. Ambiguous instructions or facts received. In order to effectively represent the Group, the personnel tasked with the matter is to confirm the instructions received so that a clear understanding of the task at hand is obtained before proceeding with the matter at hand and to check with the ‘process owner’ that the instructions have been carried out. In order for the Department to prepare the necessary documents and agreements, clear and unambiguous instructions on the matter should be given. 2. Non Adherence/compliance with the Companies Act, the KLSE LR, the Securities Industry Act, Housing Development Act and Local Authorities regulations and procedures. In order to mitigate this, proper briefing on the legislation involved should be undertaken. Towards this end, the Legal Department liaises with external solicitors on the latest updates on the law which would be made known to the Chief Operating Officers. Another method employed is continuous upgrading of legal knowledge by attending workshops and seminars. 3. Inadequate facilities for record keeping Facilities for record keeping are important support service for the Group. This also serves as a historical record of transactions undertaken by the Group. At present there are adequate facilities for storage. 4. Inherent risks with the PC with access to the Internet associated with hackers. On the PC’s this is done in conjunction with the Information and Communication Technology Department. There are basically four steps to be taken to ensure the security of the computer system. They include and are not limited to maintaining the Firewall/Anti virus systems, controlling and monitoring the Internet/web applications and the Intranet systems. Duplicating the files on to floppy disks regularly and maintaining secrecy of the passwords. External factors 1. Inadequate and poor delivery of legal opinion(s) and agreement(s) from external solicitors. To obtain sound advice, the fees payable should be adequate, taking into consideration the level of expertise and experience of the solicitors concerned. It should be noted that
  • 4. the Legal personnel in the Group relies on outside solicitors for various advises and opinions. This would be in relation to the corporate exercises undertaken by the Group. This can be mitigated by engaging senior counsels/solicitors; however in so engaging this would mean that the legal fees charged by the senior counsels/solicitors would be on a higher side due to their expertise and experiences. 2. Changes in policies and legislation by the Government. Monitor government policy through the mass media. Participate in meetings and briefing sessions organised by relevant authorities and maintaining good rapport with the regulatory agencies.