Anti-corruption Services



Scope of Service


Briefing to top management on corruption laws in Malaysia

Briefing on the Malaysian Anti-Corruption Act 2009 and other laws against the background of global trends and how the new s.17A of the Act engages the private sector in a corruption avoidance programme.


Preliminary advice

General advice on the implementation of adequate procedures in the company complying with the official guideline.


Preparing an announcement to the company on the implementation of s. 17A procedures

Announcement to introduce employees of the company to the new procedures and their role in the implementation of the procedures.


Establishing how the company conducts its business.

The object of this discussion is to determine the company's interaction with suppliers, purchasers, and agents (provisionally described herein as associates) and categories of staff in the company who interact with the outsiders. This information will also serve to assess the risks of corruption.


Establishing the profiles of associates applying the new law

Discussion with company representatives on the ownership structures of associates and their links with government or government agencies, if any.


Assist in creating an anti-corruption policy for the company.

The full version will be prepared to specifications in the Guidelines on Adequate Procedures issued by the Prime Minister’s Department, provisions of the MACC Act as well as the best practices adopted in this country and overseas by companies to fight corruption.

To satisfy the Adequate Procedures provisions of the Act, the proposed policy will also be directed at third parties who perform services for or on behalf of the company.


Advise top management of the company on their responsibilities in complying with the MACC Act.

Top management will be advised through meetings and a document prepared for that purpose that will list and explain their responsibilities in putting in place the adequate measures.


Risk assessment.

Carry out a preliminary risk assessment and set procedures for the same to be carried out periodically by the company.


Due Diligence to satisfy s. 17A defence

The due diligence provisions will be developed in the context of the operations of the company and with input from the directors and management of the company.


Reporting (whistleblowing) channels

Advice on the establishment of an anonymous reporting channel for staff and external parties.


Review of governance and organisational structure to implement adequate procedures

With the Management of the company, to review and make corruption proof the company’s existing decision-making processes and the recruitment and management of staff.


Communication strategies.

Establish communication strategies within the organisational structure of the company to comply with the new regulations.


Prepare training programs for company personnel at 3 levels.                                                  

Develop training programmes for senior management, all staff and third parties providing services to the companies.

14. Reviewing recruitment procedures, contracts of employment and business contracts. Our services include review and drafting of employment terms and a review of general business agreements to conform to the company's procedures for corruption prevention.