Integrity & Governance

INTEGRITY AND GOVERNANCE

ANTI-BRIBERY POLICY

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).

View ABMS Certificate

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	Fraudulent Activity
Asset Misappropriation:
Cash	Stealing from petty cash Stealing incoming cash or cheques
False Payment	Creating false payment order; Falsifying authorized signature and submit for payment process; Submitting false expense claims or any false reimbursement.
Cheque fraud	Theft of company cheques or cheques by other personnel in the company; Tampering the payee / amount on company cheques / cheques of personnel.
Non-Cash Fraud:
Fixed assets	Theft of fixed assets including computers and other IT related items; Theft of proprietary or confidential information.
Procurement	Falsified documents to obtain payment; Marked up invoices; Disclosed contract details, pricing of bidders to a preferential bidder; Rigged of tenders or inserting certain criteria in favour of a particular vendor; Intercepted payments of suppliers.
Corruption:
Kickbacks	Kickbacks by a supplier in return for the supplier receiving favourable treatment; Preferential treatment of customers in return for a kickback; Excessive prices or fees paid where they are not justified; Creating a contract on project for own benefit without justification.
Personal Interest	Collusion with customers/suppliers; Favour a supplier in which the employee has a financial interest; Employee setting up on own company for personal gain.
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.
Non-Financial Fraud:
Employment records	Falsified employment credentials e.g. qualifications and acedemic results; Falsified medical certification
Misuse of assets	Assets misused (renting company’s equipment to a third party for personal gain); Theft, damage, misappropriation of the company’s assets (stationeries, equipment, vehicles, building); Misuse of any information considered confidential to MRT Corp directly or indirectly to any person or company for personal gain or without proper authorization.

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.

Investigation Responsibilities

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.

Whistleblower Policy

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.

Reporting Channel

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: