Compliance

आंतरिक नियंत्रण

At BNB Asset Management, internal control begins before a trade is made. From pre-trade checks (pre-compliance) through ongoing monitoring to follow-up improvement, we manage client assets within a structure in which management and compliance verify each other.

इस पृष्ठ का हिन्दी संस्करण तैयार हो रहा है। तब तक सामग्री अंग्रेज़ी में दिखाई जा रही है।

Internal Control Overview

Built on an advanced risk management framework and a rigorous compliance oversight system, BNB Asset Management places the protection of investors' assets as its foremost value and contributes to the transparent development of the capital markets. In line with the purpose of the amended Act on Corporate Governance of Financial Companies, the Company has introduced a ‘Responsibilities Map’ and an ‘Accountability Management Manual,’ transparently institutionalizing each executive's areas of responsibility for internal control and risk management.

Through this, the Company realizes an advanced accountability governance in which internal control and risk management operate organically and continuously throughout management.

  1. Regulatory Compliance

    Strict adherence to relevant laws and internal regulations

  2. Proactive Risk Management

    Systematic monitoring and preventive action

  3. Responsible Management

    Clear definition of each individual's duties and authority

  4. Transparent Processes

    Fair and transparent procedures with continuous improvement

Three Layers Protecting Client Assets

Client assets do not depend on a single safeguard. Checks within the investment process, compliance oversight independent of management, and the statutory structure outside the Company verify one another, layer upon layer.

  1. Checks Within the Process

    Within the Process

    Before trading, the investment team enters pre-compliance items into the trading system, and the Compliance Team verifies compliance with laws and internal rules at each stage: before, at the time of, and after investment. Asset allocation and limits, risk management, and asset valuation are deliberated separately by three specialized committees.

  2. Independent Compliance Oversight

    Independent Oversight

    The Compliance Officer also serves as Chief Risk Officer (CRO) and Chief Privacy Officer, and continuously reviews conflicts of interest and regulatory compliance from a position independent of the investment organization. The appointment and dismissal of the Compliance Officer and the Chief Risk Officer are announced through disclosures.

  3. Verification Outside the Company

    External Structure

    Fund assets are held and administered by a trustee (custodian), separately from the Company's own assets, and administrative work such as NAV calculation is handled by a fund administrator. The Company's financial statements are audited by an external auditor, and quarterly business reports and key management matters are announced through disclosures.

  • These three layers exist to manage risk in the investment process and to hold assets separately; they do not guarantee investment principal or returns.

Internal Control Structure

By combining a pre-compliance-centered risk-blocking framework with a company-wide culture of internal control accountability, we build an unwavering management environment that protects client assets.

  1. Prevention

    Early identification of risk and pre-compliance review

  2. Continuous Monitoring

    Ongoing monitoring and regular internal audits

  3. Immediate Response/Improvement

    Immediate resolution of events and establishment of recurrence-prevention management guidelines

Internal Control and Risk Management Framework

With top management comprising the Board of Directors and the CEO at its apex, the Company operates an independent Compliance Officer—who concurrently serves as Chief Risk Officer (CRO) and Chief Privacy Officer—together with the Compliance Team as the executing organization.

In addition, the Company organically combines three specialized committees by function that deliberate on and control field-specific risks in depth, thereby operating a seamless internal control system.

Control and Decision-Making BodyKey Roles and Principal Matters for Deliberation and Resolution
Investment Review Committee
  • Enactment and amendment of asset management operating regulations, and approval of exceptional management
  • Formulation of asset allocation strategies for each fund and company-wide, and setting of risk limits by investment asset class
  • Determination of effective asset allocation ratios, and setting of derivatives (futures/options) trading limits and delegation of authority for each fund
  • Approval of target fund durations and of limits by investment target for bond and liquidity assets
Risk Management Working Committee
  • Working-level deliberation on risk management policies and risk criteria across proprietary assets and collective investment property
  • Formulation and resolution of company-wide crisis management measures and business continuity plans (BCP) in preparation for market shocks and other events
  • Preliminary risk review and approval for new business initiatives and the development of new products such as new funds
  • Deliberation on the grounds for deferral when permitted risk limits are exceeded, and resolution of subsequent mandatory measures
  • Deliberation on matters relating to the deferral of redemptions due to the impairment of collective investment property
  • Final decision-making on whether to defer the stop-loss execution for positions with realized losses of 30% or more
Collective Investment Property Valuation Committee
  • Establishment of structures to ensure the independence, consistency, and transparency of the fair valuation of collective investment property
  • Establishment of fair-value valuation methodologies for non-marketable assets (assets with no market price, such as Pre-IPO holdings)
  • Deliberation on and application of the selection and replacement of external bond valuation firms and the appropriateness of the prices they provide
  • Strict classification of impaired assets such as defaulted bonds, and determination of asset valuation amounts
  • Deliberation on the cause analysis and the official correction/disclosure procedures when valuation errors of collective investment property occur

Internal Control Process by Investment Stage

Grounded in rigorous risk management and compliance adherence, BNB Asset Management manages client assets safely and creates trusted value.

Pre-InvestmentDuring InvestmentPost-Investment
Investment Team
  • Sourcing/reviewing investment ideas
  • Company analysis and formulation of investment strategy
  • Entry of pre-compliance items
  • Trade execution and portfolio management
  • Management within risk limits
  • Performance analysis and post-investment management
  • Reporting when issues arise
Compliance Team
  • Review of investment appropriateness
  • Advance verification of compliance with laws and internal regulations
  • Real-time monitoring
  • Periodic review of compliance items
  • Post-event monitoring
  • Internal audits and identification of improvements
PI Team
  • Prior approval of proprietary asset management
  • Verification of conflicts of interest
  • Proprietary asset management and proprietary trading
  • Ex-ante/ex-post controls
  • Verification and reporting of transaction records
  • Management including post-event monitoring
Committees
  • Deliberation by the Investment Review Committee
  • Risk Management Working Committee (deliberation on risk limits and issues)
  • Collective Investment Property Valuation Committee (deliberation on valuation and disclosure)

How We Manage Conflicts of Interest

A conflict of interest arises when an asset manager could place the interests of the firm or its employees ahead of those of its clients. BNB first puts structures in place so that conflicts do not arise, and where one may arise, we inform you in advance.

  1. Information Barriers

    We maintain information barriers (Chinese walls) between departments to structurally block flows of information that could give rise to conflicts of interest.

  2. Controls on Proprietary Investment

    Proprietary investments require prior approval and a conflict-of-interest review, and proprietary trading is subject to ex-ante and ex-post controls and verification of transaction records.

  3. Advance Notice

    Where a potential conflict of interest is identified, we inform the investor concerned in advance and proceed with the transaction only after taking the measures needed to ensure that investor protection is not compromised.

  4. Training and Disclosure

    We provide related training for officers and employees at least once a year, and we have publicly disclosed the key elements of our conflict-of-interest management and information barrier policies (2021-09-01).

Five Compliance Principles

  1. Strict compliance with laws and internal regulations

  2. Prevention of conflicts of interest and fair dealing

  3. Accurate information provision and transparent reporting

  4. Protection of client information and confidentiality

  5. Continuous monitoring and improvement

A presenter pointing at charts on a large screen while colleagues listen at a meeting table

Relevant Laws and Internal Regulations

  1. Relevant Laws and Regulations

    • Financial Investment Services and Capital Markets Act
    • Act on Corporate Governance of Financial Companies
    • Regulations related to collective investment schemes, among others

  2. Internal Regulations

    • Internal Control Standards
    • Risk Management Standards
    • Code of Ethics for Officers and Employees
    • Conflict-of-Interest Management and Information Barrier Regulations
    • Guidelines on the Prevention of Unfair Trading
    • Internal Control Standards for Financial Consumer Protection
    • Personal Information Protection Guidelines and Privacy Policy, among others

Internal Controls You Can Verify Through Disclosures

Internal control should be verifiable on the record. The original documents for the disclosures below are available under Disclosures on our website.

Key disclosures related to internal control
DisclosureDate postedDescription
Appointment and dismissal of the Compliance Officer and Chief Risk Officer2026-03-05Disclosure of the appointment of the Compliance Officer and Chief Risk Officer under the Act on Corporate Governance of Financial Companies
Notice of appointment of external auditor2026-07-30Notice of the appointment of the external auditor under the Act on External Audit of Stock Companies
Disclosure of key elements of conflict-of-interest management and information barriers2021-09-01Key elements of the internal control standards on conflict-of-interest management and information barriers under the Financial Investment Services and Capital Markets Act (FSCMA)
Notice on the establishment and implementation of the internal control standards for financial consumer protection and the financial consumer protection standards2021-09-24Standards established following the enforcement of the Financial Consumer Protection Act (effective 2021-09-25)
Quarterly business reportEvery quarterMost recent: business report for Q1 of FY2026 (2026-08-13)
  • Dates posted reflect the Disclosures section of our website as of October 2026.