Introduction & Scope
المقدمة والنطاق
Al Amal Investment Company KSCC ("Al Amal," "we," "us," "our") is a Kuwaiti Shareholding Company committed to the highest standards of integrity, transparency, and ethical conduct. This Conflict of Interest Policy outlines our framework for identifying, managing, and disclosing conflicts of interest that may arise in the course of our investment activities.
The main focus of the company is acquiring strategic investments in selective enterprises, industries and investment-vehicles seeking growth and capital appreciation, all in accordance with the provisions of Islamic Shari'a and in accordance with the Regulations and instructions of the Kuwait Capital Market Authority, Central Bank of Kuwait and Kuwait Ministry of Commerce and Industry.
This policy applies to all directors, officers, employees, and contractors of Al Amal.
Legal & Regulatory Framework
الإطار القانوني والتنظيمي
This policy is designed to comply with:
- Capital Markets Authority (CMA) of Kuwait — Law No. 7/2010 and its amendments, including corporate governance regulations (Module 15).
- Central Bank of Kuwait (CBK) — Directives on conflict of interest for regulated entities.
- Kuwait Ministry of Commerce and Industry — Corporate governance code provisions.
- Islamic Shari'a principles — As overseen by our Shari'a Supervisory Board.
- International standards — IOSCO principles where applicable.
Identification of Conflicts
تحديد التضاربات
Conflicts of interest may arise in various circumstances, including but not limited to:
- Personal Trading — Employees or directors trading for their own account in securities held by client portfolios.
- Related Party Transactions — Investments involving directors, officers, or their close relatives.
- Outside Business Activities — Directors or employees serving on boards of portfolio companies or other entities.
- Allocation of Opportunities — Conflicts between client accounts, proprietary accounts, or co-investments.
- Gifts & Entertainment — Receiving gifts or entertainment that could influence business decisions.
- Family Relationships — Hiring or supervising relatives.
Management & Mitigation Measures
إجراءات الإدارة والتخفيف
Al Amal has established the following measures to manage and mitigate conflicts of interest:
- Segregation of Duties — Separation of investment management, trading, and compliance functions.
- Information Barriers — Restricted access to material non-public information.
- Disclosure Obligations — Directors and employees must annually disclose outside interests, holdings, and potential conflicts.
- Pre-approval Requirements — Personal trading and outside board service require pre-approval from Compliance.
- Gift & Entertainment Policy — Acceptance of gifts over the prescribed KD value is prohibited.
- Fair Allocation Policies — Written policies for allocating investment opportunities across client accounts.
Governance & Oversight
الحوكمة والرقابة
The Board of Directors and the Audit Committee have ultimate responsibility for overseeing conflicts of interest. The Compliance Department is responsible for implementing and monitoring this policy. Material conflicts are reported to the Audit Committee at least quarterly.
The Shari'a Supervisory Board reviews potential conflicts involving Shari'a compliance and ensures that no conflict arises between commercial interests and Shari'a principles.
Disclosure & Reporting Obligations
التزامات الإفصاح والتقارير
Al Amal discloses material conflicts of interest to affected clients in a timely manner. Disclosures are made in writing and include the nature of the conflict and the steps taken to mitigate it. Where conflicts cannot be managed effectively, Al Amal will decline to act or obtain client consent.
Regulatory disclosures are made to the CMA and CBK as required by law, including annual compliance reports.
Contact Us
تواصل معنا
For questions about this Conflict of Interest Policy or to report a potential conflict, please contact our Compliance Officer:
Compliance Officer
Qibla Q2 Building 114 Office 27 Ground Floor,
P.O. Box 200, Safat 13002, Kuwait City
Anonymous Reporting — Confidential reports may be submitted through our Report a Concern Page. All reports are treated in strict confidence.
