Anti-Corruption

    Strict policy on anti-bribery and anti-corruption.

    As part of our commitment to conducting business ethically in compliance with the MACC Act 2009 and all applicable anti-bribery and corruption laws of every country in which we operate, we establish, document, implement and maintain an Anti-Bribery and Corruption Management System (ABCMS), which is certified by SIRIM, as per

    • the requirements and standards prescribed under the International Standards for the ISO 37001:2016 ABCMS issued by the International Organisation for Standardisation (ISO);
    • the requirements and standards prescribed under the Malaysian Standards for the MS ISO 37001:2016 ABCMS published by the Department of Standards Malaysia; and
    • the Guidelines on Adequate Procedures pursuant to Subsection (5) of Section 17A under the MACC Act 2009 issued by the Prime Minister’s Department.

    Governing Body

    Governing Body has the ultimate responsibility and authority for MPI’s activities, governance and policies, and to which top management reports and by which top management is held accountable.
    The Governing Body shall demonstrate leadership and commitment with respect to the ABCMS by

    • approving the organization’s anti-bribery policy;
    • ensuring that the organization’s strategy and Anti-Bribery and Corruption Policy are aligned;
    • cat planned intervals, receiving and reviewing information about the content and operation of the organization’s ABCMS;
    • requiring that adequate and appropriate resources needed for effective operation of the ABCMS are allocated and assigned;
    • exercising reasonable oversight over the implementation of the organization’s ABCMS by top management and its effectiveness.

    Internal Audit Committee

    ABCMS Internal Audit Committee conducts internal audits as and when necessary, but on an annual basis at the very least, to determine whether the ABCMS (i) conforms to the requirements of ABCMS Manual, and (ii) is effectively implemented and maintained.

    Top Management

    The Top Management has the overall responsibility for the implementation of and compliance with the ABCMS. The Top Management shall demonstrate leadership and commitment with respect to the ABCMS by

    • ensuring that the ABCMS, including policy and objectives, is established, implemented, maintained and reviewed to adequately address the organization’s bribery risks;
    • ensuring the integration of the ABCMS requirements into the organization’s processes;
    • deploying adequate and appropriate resources for the effective operation of the ABCMS;
    • communicating internally and externally regarding the Anti-Bribery and Corruption Policy;
    • communicating internally the importance of effective anti-bribery management and of conforming to the ABCMS requirements;
    • ensuring that the ABCMS is appropriately designed to achieve its objectives;
    • directing and supporting personnel to contribute to the effectiveness of the ABCMS;
    • promoting an appropriate anti-bribery culture within the organization;
    • promoting continual improvement;
    • supporting other relevant management roles to demonstrate their leadership in preventing and detecting bribery as it applies to their areas of responsibility;
    • encouraging the use of reporting procedures for suspected and actual bribery;
    • ensuring that no personnel will suffer retaliation, discrimination or disciplinary action for reports made in good faith, or on the basis of a reasonable belief of violation or suspected violation of the organization’s anti-bribery policy, or for refusing to engage in bribery, even if such refusal can result in the organization losing business (except where the individual participated in the violation);
    • at planned intervals, reporting to the governing body (if any) on the content and operation of the ABCMS and of allegations of serious or systematic bribery.

    Compliance Committee

    The Compliance Committee shall undertake the following roles and responsibilities

    • Overseeing the design and implementation by the organization of the ABCMS
    • Providing advice and guidance to personnel on the ABCMS, and issues relating to bribery
    • Ensuring that the ABCMS conforms to the requirements of our ABCMS Manual
    • Reporting at planned intervals, and on ad hoc basis on the performance (on the adequacy and implementation) of the ABCMS (including the results of investigation and audit) to the governing body, top management or suitable committee of the governing body or top management.
    • Assessing on a continual basis whether the ABCMS is:
      • Adequate to manage effectively the bribery risks faced by the organization
      • Being effectively implemented

    Members of the Compliance Committee shall be appointed by the Top Management.

    Training Materials

    Group Human Resources Department will provide materials for the anti-bribery and corruption training.

     

    Responsibility

    The Human Resources Department shall be responsible for providing adequate and appropriate anti-bribery and corruption training to all the employees. In conducting the training, the HR must take into consideration the various issues and risks, as well as the actions plans, as identified in the ABCMS Registers. Additionally, the training must address and cover the following:

    • an overview of the ABCMS (including the Anti-Bribery and Corruption Policy) and the employees’ duty to comply with the same;
    • the actual and potential bribery and/or corruption risks and issues that are relevant to the organization and each department in the organization, and how to recognise such circumstances;
    • the circumstances in which bribery and/or corruption can occur in relation to the employee’s duties and how to recognise such circumstances;
    • the consequences and damage which can occur to the employees and the organization as a result of any bribery and/or corrupt activity;
    • how to respond to solicitations and/or bribe offers and the benefits of responding (e.g. so that necessary actions and measures can be taken to prevent or mitigate, as the case may be, such bribery and/or corrupt activity);
    • how the employees can help prevent and avoid bribery and/or corrupt activity;
    • the reporting procedures as set out in the Anti-Bribery and Corruption Policy and encourage good faith reporting by employees;
    • how the employees can contribute to the effectiveness of ABCMS; and
    • the benefits of an improved ABCMS.

     

    Frequency

    The anti-bribery and corruption training shall be included in the orientation program for all new employees. Additionally, the HR shall carry out regular and continuous training for all employees. The training material is made available in relevant languages, including English, Bahasa, and Chinese.

    To ensure that the ABCMS is effectively communicated, we shall maintain a Register of ABCMS Communication Plan. The Top Management shall be responsible for the maintenance of such Register.

    The Responsible Persons shall also ensure that the language used for the awareness and training is suitable taking into consideration the language spoken and understood by the employees in the respective departments. The communication material is made available in relevant languages, including English, Bahasa, and Chinese.

    The documents/information to be communicated comprise of

    All bribery and corruption related risks whenever identified in the ABCMS Registers shall be assessed in accordance with the Risk Management Policy of the Group (HLMG). The Risk Management Policy was developed by the Group for the identification, evaluation, management and reporting of risks to minimise and/or contain the likelihood and consequences of its occurrence, and where appropriate, to provide for restoration and recovery in the event of harmful and damaging incidents.

    Upon assessment of such risks, we shall set out the actions that can and will be taken by us to prevent or mitigate, as the case may be, the occurrence of such risks.

    • Any employees may make reports of any such concerns to the Chairman of the Board Audit & Risk Management Committee of MPI Group. Click here for Whistleblowing Form.
    • Reports of any concern or suspicion may be made to the Head of Internal Audit or Head of Human Resources:

    Head of Internal Audit
    Level 31, Menara Hong Leong
    No. 6, Jalan Damanlela
    Bukit Damansara
    50490 Kuala Lumpur, Malaysia

    Email: tehboonang@hongleong.com.my

    OR

    Head of Human Resources
    Level 31, Menara Hong Leong
    No. 6, Jalan Damanlela
    Bukit Damansara
    50490 Kuala Lumpur, Malaysia

    Email: lalitaabdullah@hongleong.com.my