Integrity, Conflict of Interest and Anti-Bribery Awareness Training

Welcome and Programme Overview

Introduction to the session, objectives, and housekeeping.

Why This Sits With You

Section 17A corporate liability in plain terms: who counts as an associated person, why the burden of proof sits with the organisation, and what adequate procedures has come to mean in practice. The personal liability that attaches to directors and management by default. The MACC Act offences that apply to individuals, including the ones that catch the person who accepted rather than the person who offered. Malaysian enforcement patterns and what they tell you about risk.

Break

Conflict of Interest

The part most people get wrong. Actual, potential and perceived conflicts, and why perception alone is enough to cause the damage. The common shapes: family and close relationships in procurement and recruitment, outside business interests and second jobs, directorships and shareholdings, post-employment moves to a supplier or competitor, and the relative hired two levels down. Why the misconduct is almost always the non-disclosure rather than the interest itself. The declare, record, recuse and monitor sequence, and what a manager is obliged to do the moment a declaration lands on their desk.

Gifts, Entertainment and Hospitality

Where the line sits between a courtesy and an inducement: timing relative to a live decision, value, frequency, transparency, and whether it would survive being published. Festive and cultural giving in the Malaysian context, handled without pretending the context does not exist. Sponsored travel, training and conferences. Corporate hospitality during a tender window. The no-gift policy and its workable exceptions, the gift register, and how to refuse without causing offence to a long-standing counterpart. Participants score a set of real scenarios and compare answers.

Lunch

Facilitation Payments, Intermediaries and Third Parties

Why facilitation payments are simply bribes under Malaysian law regardless of how routine they feel, and how to handle the situations where one is expected. The third-party exposure that Section 17A actually targets: agents, consultants, freight forwarders, distributors and joint venture partners acting on your behalf. Red flags in due diligence, commission structures with no commercial logic, and the contractual and audit rights that keep a third party from becoming your liability.

Procurement, Approvals and Everyday Pressure Points

Where integrity risk concentrates in normal work: specification writing that favours one bidder, vendor selection, direct negotiation and emergency purchase justifications, variation orders, invoice approval and expense claims. Segregation of duties, and why a single approver is a control failure rather than an efficiency. Handling pressure from a superior, a client or an official, and what to do when the instruction comes from someone senior enough to end the conversation.

Break

Speaking Up and Whistleblowing

The internal channels and how they are meant to work. What the Whistleblower Protection Act 2010 protects and, importantly, what it does not. Anonymity in practice in a small team where the source is obvious. Protection from retaliation, and what actually happens after a report is made. Why most people stay silent, and what an organisation has to demonstrate to change that. The manager's obligation when a concern is raised informally in a corridor rather than through the channel.

Grey Zone Workshop

Participants work through ambiguous cases drawn from Malaysian workplaces, decide between declare, refuse, escalate or proceed, and defend the call to the room.

Wrap-Up and Q&A

Key takeaways, next steps, and close.