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.