Module Overview
Corruption continues to drain economies and damage corporate reputation, with Malaysia not spared from this global challenge. The introduction of Section 17A of the MACC Act has shifted the landscape by imposing corporate liability on organisations for corrupt practices by their employees or associates – even if top management did not authorise or consent. To safeguard against this, companies must demonstrate they have implemented Adequate Procedures, guided by the TRUST Principles. This training equips participants with both the legal awareness and practical tools needed to strengthen their organisation’s anti-bribery and anticorruption (ABAC) framework, foster a culture of integrity, and ensure compliance is embedded in day-to-day operations.
Programme Objective
- Explain the scope and impact of Section 17A MACC Act, including how corporate and individual liability applies in real-world situations.
- Apply the TRUST Principles to assess corruption risks within their own department and identify gaps in existing controls.
- Demonstrate practical responses to ethical dilemmas (e.g., gifts, facilitation payments, third-party dealings) that align with Adequate Procedures and organisational values.
Course Outline
Introduction & Objectives
- Why ABAC matters (global cost of corruption, Malaysian context).
- Programme objectives expected outcomes.
- Icebreaker: “What corruption risk worries you most in your role?”
Section 17A & Corporate Liability
- Individual vs Corporate liability.
- Section 17A explained:
- Who is an “associated person”?
- Penalties (fines, imprisonment, reputational loss).
- Defence: Adequate Procedures.
- Case Study: R v Skansen
- Activity 1: If this happened in your organisation, what process/values failed?
TRUST Principles in Practice
- Walkthrough of T.R.U.S.T. with real examples.
- Linkage to MS 2764:2022 & ISO 37001
- Activity 2: Participants map their department’s risks against the TRUST framework.
Ethical Dilemmas
- Ethical Blindness
- Fear of Finding Out
- Bonus segment: Fraud Triangle
From Policy to Culture
- Positioning organisation’s vision, mission & values in ABAC.
- “Heart, Hand & Habit” framework → embedding culture.
- Participants take ABAC pledge.
Wrap-Up & Action Points
- Recap on takeaways on S17A & TRUST.
- Each participant commits to 1 ABAC action in their role.
- Subject Evaluation
Who Should enroll?
- Directors, CEOs & Senior Managers
- Compliance, Legal, Risk & Audit Officers
- HR, Operations & Procurement Leaders
- Department Heads and Managers involved in governance and third-party dealings