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SUSTAINABILITY JOURNEY   HOW WE ARE GOVERNED   FINANCIAL STATEMENTS   ADDITIONAL INFORMATION  211


















                                                                          Commitment to Anti-Bribery and
                                                                          Anti-Corruption
                                                                 Adequate Procedures are the pillars of defense against
                                                                 corporate liability, particularly corruption offences. MSM has
                                                                 taken a holistic approach in implementing adequate procedures
                                                                 by adopting the principles (T.R.U.S.T):
           Main Board                                            •  Top Level Commitment
                                                                    -   Board, Executive Leadership & Management

           Board Committees                                      •  Risk Management
           •  Audit, Governance and Risk Committee                  -   Corruption Risk Management (CRM)
           •  Nomination and Remuneration Committee              •  Undertake Control Measures
           •  Investment and Tender Committee                       -   Establishment and review of policies and procedures

           Group Chief Executive Officer                         •  Systematic Review, Monitoring and Enforcement
                                                                    -   Regular review on performances, efficiency and
           Corporate Centre, Operations &                              effectiveness of the anti-corruption programme,
           Supporting Functions                                        and ensure the enforcement

                                                                 •  Training and Communication
                                                                    -   Governance, Integrity & Risk education, awareness and
                                                                       periodic communication
                                                                 MSM has embedded the principles of adequate procedures
                                                                 in the  Anti-Bribery Policy Statement and  Whistleblowing
                                                                 Policy which evidently available at MSM’s corporate
                                                                 website in compliance with Paragraph 15.29 (1) and (2) of
                                                                 Listing Requirements and guided by the Guidelines on
                                                                 Adequate Procedures, Section 17A (5) of the Malaysian
                                                                 Anti-Corruption Commission (MACC) Act 2009 (Amendment
                                                                 Act  2018).  There  are  three  (3)  key  focus  areas  were
                                                                 examined - Corruption, Fraud and Abuse of power.


                                                                       Anti-Bribery   Policy   Statement   and   Whistleblowing
                                                                       Policy are available on the Company’s corporate website at
                     Focus on Strong Governance                        http://www.msmsugar.com/our-company/corporate-governance


            We recognise that good governance is essential in assisting
            the business to deliver its strategy, generate shareholder value
            and safeguard shareholders’ long-term interests.
            An important area of focus for the Group during the year was
            to ensure our preparedness in meeting the requirements of
            Section 17A  of the MACC  Act  2009. The MACC  Act 2009,
            which was amended to introduce corporate liability for
            corruption offences of commercial organisations, was enforced
            on 1 June 2020.
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