MISC continues to reinforce our commitment of ensuring high standards of compliance and ethics practices throughout the Group. The MISC Group Compliance and Ethics Programme, part of the MISC Sustainability Strategy under the Governance & Business Ethics pillar - outlines the policy, action plans and deliverables to ultimately create a culture within the Company that embodies ethical conduct and commitment to integrity in all business dealings.
Under this programme, MISC has rolled out Operational Guidelines on Third Party Due Diligence as part of the enhancement of its risk assessment and improved its Compliance Unit resources. A comprehensive training programme on anti-bribery and corruption for all employees, Management and the Board is currently in progress.
The MISC Group Policy Statement on Anti-Bribery and Corruption, which is made as a part of the MISC Board Charter, was adopted in 2016. Compliance monitoring measures have also been enhanced with the establishment of the Gift Register, the Whistle-Blowing Register and the Conflict of Interest Register for all employees.
Business Conduct & Ethics
Business ethics and ethical conduct embedded as a cultural component within the organisation.
2018 Progress Update
- Continuous communication and awareness programmes through the ‘See Speak Support’ Campaign, to raise awareness on the MISC Code of Conduct and Business Ethics (CoBE) and Whistleblowing.
- Completed Compliance and Ethics Benchmark Review and Culture Survey internally where MISC has exceeded targeted compliance maturity level of 3 in 2018.
- Rolled out and implemented training programmes for employees as follows:
- CoBE training included in induction session for new employees.
- Introduction of annual refresher training course through e-Learning with a short video and mandatory assessment.
- CoBE awareness session for third parties to MISC, with focus on MISC’s vendors, included as part of the
agenda for MISC Group Contractors HSSE Forum on 15 November 2018.
- Specific training on anti-bribery legislation and adequate
procedures for directors.
- Ensuring adequate compliance resources through expansion and restructuring of compliance function and appointment of Compliance Champions from all business units/ service. Training sessions were also conducted for appointed Compliance Champions.
- Commenced ISO 37001:2016 Anti-Bribery Management System Certifcation exercise. The following has been completed:
- MISC Anti-Bribery Management System Manual.
- Internal Audit Review.
- Top Management and Governing Body reviews.
- Stage 1 Audit by SIRIM.
- Stage 2 Audit by SIRIM.
- Successfully certified by SIRIM on 28 January 2019.
- Enhancement of the Supply Chain Management by:
- Finalising the Declaration and Integrity Pledge and CoBE for Third Party Service Providers.
- Commencing Vendor Risk Assessment.
- Developed and launched Whistleblowing (WB) Management System (We Care) for users to report on any wrongdoings.
- Formalisation of the Human Rights Working Group to address Human Rights issues and develop related policies and statement.
- To continue with quarterly “See Speak Support“ awareness programmes.
- Continuous improvements to achieve level 4 maturity by 2020 in all compliance and ethics areas.
- Continue to monitor, review and assess the eﬀectiveness of compliance and ethics initiatives including the communications and awareness programmes.
- Continuation of the:
- CoBE annual refresher training course for employees.
- CoBE awareness and training sessions for Third Party Service Providers.
- CoBE training for Board Members.
- Compliance champions to be appointed to cover all jurisdictions where MISC operates.
- Implementation of the areas for improvements following the Stage 2 ISO 37001 Anti Bribery Certifcation Audit.
- ISO 37001:2016 Anti Bribery Certifcation exercise to be completed for the subsidiaries.
- Continue to ensure third parties sign the Declaration and Integrity Pledge and comply with COBE for third party service providers or its equivalent.
- Continue with Vendor Risk Assessments.
- To develop framework and criteria for high risk vendor audits.
- Continuous WB awareness session on availability of WB reporting channels.
- Continuous management of the WB complaints in line with WB Policy and Procedures.
- Continuous improvements of the WB Management procedures.
- Continuous Quarterly Reporting to BARC on WB matters.
- Adoption of a Human Rights Commitment, development of Modern Slavery Policy and Annual Modern Slavery Statement.
- Conduct Social Risk assessments and due diligence on human rights for identified high risk operations as identified through the Social Risk assessments.
Board Oversight on Sustainability
Formal inclusion of sustainability on the Board agenda.
2018 Progress Update
- Planning and development for the inclusion of Sustainability on Board agenda according to Bursa guidelines.
- Present to BOD on MISC Sustainability Programmes and Initiatives.