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SUSTAINABILITY JOURNEY   HOW WE ARE GOVERNED   FINANCIAL STATEMENTS   ADDITIONAL INFORMATION  179

















            Training is provided for staff and suppliers to build awareness   MSM has taken a holistic approach to develop and
            and necessary capacity to identify and counter relevant forms   implement adequate procedures by adopting the following
            of bribery and corruption activities in our business dealings.     principles (T.R.U.S.T):
            For new business counterparties, employees must ensure
            due diligence is conducted to understand the business and   Top Level Commitment by Board, Executive Leadership
            background  and  to  determine  the  origin  and  destination  of  T  & Management
            money, property, and services as required under the CoBCE.

                  The MSM Anti-Bribery Policy Statement is available on the   R  Risk Management through Corruption Risk Management
                  Company’s website at www.msmsugar.com              (CRM)


            In addition, a Corruption Risk Management (CRM) exercise   Undertake Control Measures via the establishment and
            was conducted for the Group. This is to ensure we continue to   U  review of policies and procedures
            identify potential corruption risks in our operations.

            As defence against corporate liability for corruption offences   Systematic Review, Monitoring and Enforcement which
            committed by person associated with MSM, as defined   S  includes regular review on performances, efficiency and
            under Section 17A of the MACC  Act 2009 (Amendment       effectiveness of the anti-corruption programme, and
            Act 2018) MSM is putting in place measures as per Guidelines   ensure the enforcement
            on Adequate Procedures.
                                                                     Training and Communication on Governance, Integrity &
            The performance of our anti-corruption initiatives is reviewed   T
            every quarter by our Management, Board Committee         Risk education, awareness and periodic communication
            and Board.  We evaluate the progress and success of our
            initiatives through a number of channels, including obtaining
            stakeholder feedback, benchmarking and performance
            tracking.  We  pay  particular  attention  to  the yearly
            assessments   conducted  by   corporate  governance
            watchdogs  such as  the  Malaysian  Institute  of  Corporate   ONE SUCCESSFUL INITIATIVE
            Governance  (MICG)  and Minority Shareholders  Watch
            Group (MSWG).                                           UNDER ANTI-BRIBERY AND
                                                                    ANTI-CORRUPTION WAS

                                                                    THE QUICK TAKE UP AND 100%

                                                                    SIGNING OF THE INTEGRITY

                                                                    PLEDGE.
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