INTEGRITY AND GOVERNANCE
MRT Corp’s Anti-Bribery Policy is intended to provide a framework in setting, reviewing, and achieving its anti-bribery objectives. This Policy is to demonstrate the commitment from the Board of Directors and Management in compliance with the requirements of ISO37001:2016 Anti-Bribery Management Systems (ABMS).
Anti-Fraud and Corruption Policy
To establish zero tolerance on fraud, bribery and corruption, and the procedures to be followed by MRT Corp employees, Turnkey Contractors (TC), Work Package Contractors (WPC), Business Associates if fraud, bribery or corruption is suspected or detected.
Note: Business Associates are referring to suppliers, vendors, contractors, consultants or any parties which have a business relationship with MRT Corp.
Actions Constituting Fraud and Corruption
For the purpose of this Policy, fraud and corruption will include the examples prescribed but will not be limited to the following:
|Type of Fraud||
|Bribery||Inducement offered directly or through intermediary to gain any commercial and/or personal advantage.|
|Facilitation payment||Payment made to a government official to facilitate approval or speed-up of some type of business transaction or activity.|
|Misuse of assets||
Responsibility for the Detection and Deterrence of Fraud and Corruption
All Head of Division/ Department are responsible to:
- Identify any internal and external risks in their areas of operation;
- Develop and maintain controls to prevent fraud and corruption;
- Ensure staff adhere to the existing procedures.
All employees of MRT Corp are responsible to:
- Act at all times in accordance with the highest standards of integrity;
- Ensure that existing procedures are followed to address the risk of fraud and corruptions;
- Ensure that MRT Corp reputation and its assets are safeguarded at all times.
- Report suspected fraud or any concern on improper behavior of any personnel in accordance with reporting procedures set out in MRT Corp Whistleblower Policy.
Responsibility of TC, WPC, Business Associates:
- Shall not attempt to seek bribe or involve in corrupt practice when conducting business with MRT Corp;
- Shall immediately lodge a report for such acts to Chairman of the Whistleblower Committee or to Chief Integrity and Governance Officer of MRT Corp if there is a request for commission or bribe made by employees of MRT Corp or other parties.
- Integrity Governance Department is responsible to review and conduct an investigation of all suspected fraudulent and corruption acts as well as other areas which breach MRT Corp’s policy and procedure;
- The investigation team will have free and unrestricted access to all company’s record, files and documents within the scope of the investigation;
- In accordance to the Whistleblower Policy, the findings of the investigation shall be reported to the Whistleblower Committee.
Breach of Policy
Any employee of MRT Corp who violates this Policy shall be subjected to disciplinary actions.
Any TC, WPC, Business Associates found violating this Policy may face termination in accordance to the terms in the Letter of Award (LOA) and or Contract. For the avoidance of doubt, this is subject to strict proof before the court of law.
No Gift Policy
MRT Corp has adopted the No Gift Policy and expects that MRT employees, Board Members and Business Associates to comply.
Business Associates or their representatives are not allowed to offer or give any gift, hospitality, entertainment either directly or indirectly to MRT Corp employees, Board Members or their families.
Board Members and Employees shall not accept any business meals or entertainment that may be interpreted as having been made with the intent to influence a business decision by MRT Corp. Thus, Board Members or Employees need to exercise proper care and judgment when receiving / providing entertainment to external parties.
To provide an avenue for stakeholders of MRT Corp to disclose any wrongdoings or irregularities in accordance with the procedures as provided under this policy and to provide protection for reporting such allegations.
Note: Stakeholders refer to employee, board members, shareholders and business associates
Protection from Retaliation and Reprisal
MRT Corp assures the Whistleblower that he/she would be protected from retaliation or reprisal. All complaints reported to MRT Corp are treated in strict confidence. The Whistleblower’s identity will not be revealed unless it is required by law.
The complaint is preferably in writing, submitted by hand, via post or email, to ensure that there is a clear understanding on the issues raised. The report should be sealed in an envelope if sent via post with “Private and Confidential” indicated and addressed to:
The Chairman of Whistleblower Committee
Mass Rapid Transit Corporation Sdn Bhd
Level 5, Menara I&P 1, 46 Jalan Dungun,
50490 Bukit Damansara, Kuala Lumpur.
Chief Integrity and Governance Officer via:
from Monday to Friday
during office hours
(8.30 am to 5.30 pm)
Set an Appointment
Appointment at the office
or any agreed location
Write a Letter
In writing to Chief Integrity
and Governance Officer, 6th
Floor, Menara I&P 1, 46
Jalan Dungun, 50490 Bukit
Damansara, Kuala Lumpur.
Whistleblower Protection Act 2010
In the event that there are discrepancies between this policy and
the Whistleblower Protection Act 2010, the Act shall prevail.