Integrity and Governance Unit for Companies and GLCs
A Cabinet directive announced in October 2018 gave government-linked companies a two-year grace period to set up an Integrity and Governance Unit (IGU), placed under board oversight, with the Malaysian Anti-Corruption Commission (MACC) regulating how its core functions are implemented and reported. The Chief Integrity Officer role is often filled by an MACC officer on secondment, and in some groups the function has since grown into a unit at a higher reporting level. Companies that are not GLCs are building the same kind of unit voluntarily, usually driven by Section 17A of the MACC Act, under which a commercial organisation is liable for corruption committed by an associated person unless it can show adequate procedures were in place. This two-day course is built for appointed IGU heads and officers, board members and company secretaries overseeing a GLC subsidiary, and HRD Corp SBL-Khas claimable for eligible employers.
This two-day course is for board members, company secretaries, risk, compliance and HR leaders, and the officers nominated to lead or sit on an Integrity and Governance Unit or Committee at companies and GLCs. Day one covers mandate, placement and the Chief Integrity Officer role. Day two works through the unit's core functions, a risk assessment and a whistleblowing process, ending in a workshop that drafts the unit's charter and work plan. It pairs with Corporate Governance and Integrity, Section 17A Adequate Procedures: Evidence and Defence and Whistleblower Protection (Act 711). Public sector agencies should see the companion course, Integrity and Governance in the Public Service.
HRD Corp SBL-Khas Claimable
Corporate IGU vs Public Sector Integrity Unit
| Companies and GLCs | Public Service | |
|---|---|---|
| Legal basis | 2018 Cabinet directive (GLCs); Section 17A MACC Act (private companies) | Pekeliling Perkhidmatan Bilangan 6 Tahun 2013 |
| Unit head | Chief Integrity Officer, often an MACC secondee | Head of Integrity Unit, CeIO accredited |
| Reports to | The board or a board committee | Secretary-General or Head of Department, and MACC three times a year |
| Oversight body | MACC (regulates how core functions are implemented) | MACC Agency Integrity Management Division |
| HRD Corp claimable | Yes, SBL-Khas | Not applicable, agencies do not pay the levy |
Programme Agenda
Day 1, 9:00 AM - 9:15 AM
Welcome and Programme Overview
Introduction to the session, objectives, and housekeeping.
Day 1, 9:15 AM - 10:15 AM
Why Companies and GLCs Are Building an Integrity and Governance Unit
The 2018 Cabinet directive for GLCs, the two-year grace period, board oversight and MACC-regulated reporting. Section 17A of the MACC Act as the driver for private companies, and how the role has grown from a single integrity officer into a unit or group.
Day 1, 10:15 AM - 10:30 AM
Break
Day 1, 10:30 AM - 11:30 AM
Mandate, Placement and Independence
Where the unit sits so it can look at senior management without a conflict, terms of reference, resourcing, and the reporting line to the board or a board committee rather than to management.
Day 1, 11:30 AM - 12:30 PM
The Chief Integrity Officer Role
Responsibilities, the secondment model used by some GLCs, internal appointment for private companies, the competencies the role needs, and how it differs from compliance and internal audit.
Day 1, 12:30 PM - 1:30 PM
Lunch
Day 1, 1:30 PM - 3:15 PM
Core Functions of the Unit
Adapting the six functions used in the public sector model, governance, a discipline secretariat role where delegated, integrity strengthening, detection and verification, compliance, and complaints management, to a corporate structure.
Day 1, 3:15 PM - 3:30 PM
Break
Day 1, 3:30 PM - 4:45 PM
Governance and Board Oversight
Board and board committee oversight, management information the board should ask for, and protecting the unit's independence when its work touches senior management.
Day 1, 4:45 PM - 5:00 PM
Day 1 Close
Recap and what to review before day two.
Day 2, 9:00 AM - 9:15 AM
Day 1 Review
Recap of day one and the questions it left open.
Day 2, 9:15 AM - 10:15 AM
Integrity Risk Assessment
Identifying corruption and integrity risk across the business, mapping it to existing controls, and prioritising the unit's work programme against the highest risks.
Day 2, 10:15 AM - 10:30 AM
Break
Day 2, 10:30 AM - 12:30 PM
Whistleblowing and Complaints Management
Designing the intake channel, triage, confidentiality, protection for the reporter, and escalation. How this connects to the Whistleblower Protection Act 2010.
Day 2, 12:30 PM - 1:30 PM
Lunch
Day 2, 1:30 PM - 3:15 PM
Detection, Verification and Response
Handling a report from first notice to closure, working with internal audit and HR, and the boundary between the unit's own verification and a criminal investigation by the authorities.
Day 2, 3:15 PM - 3:30 PM
Break
Day 2, 3:30 PM - 4:45 PM
Workshop: Build Your Unit's Charter and Work Plan
Teams draft a terms of reference, a reporting line, and a 12 month work plan for the unit, including how it would demonstrate adequate procedures under Section 17A.
Day 2, 4:45 PM - 5:00 PM
Wrap-Up and Q&A
Key takeaways, next steps, and close.
Key Outcomes
- Explain why GLCs and companies are setting up Integrity and Governance Units
- Set the unit's mandate, placement and reporting line
- Describe the Chief Integrity Officer role and how it is resourced
- Design the unit's core functions as a connected work programme
- Build a whistleblowing and complaints handling process
- Produce a unit charter and work plan the board can approve
Training Mode Physical / Online / Hybrid / e-learning
HRD Corp SBL-Khas Claimable
Level Intermediate. For board members, company secretaries, risk, compliance and HR leaders, and officers nominated to lead or sit on an Integrity and Governance Unit or Committee at companies and GLCs.
Duration 2 Days (16 Hours) | 9:00 AM to 5:00 PM daily
Venue In-house at the client's premises, or delivered via the client's preferred platform (Microsoft Teams, Zoom, or equivalent)
Assessment A unit charter, reporting line and 12 month work plan drafted in the workshop, plus a written knowledge check
Certificate Certificate of Completion issued to all participants upon full attendance