Anti-Bribery and Corruption-S. 17A Corporate Liability Perspective

14-15 Dec, 2021, Virtual Classroom Training

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S. Suresh Kumar LL. B (UK) is a trained and certified Risk Management professional in the area of Supply Chain Risk Management and Brand Protection. He attained his Bachelor’s Degree in Law from the University of Wolverhampton (UK). He then went on to be trained and certified as an auditor and practitioner in the specialized area of Risk Management under the auspices of United States of America Customs and Border Protection (Customs Trade Partnership Against Terrorism- CTPAT Standards); and; Transported Asset Protection Association (TAPA Standards), Asia. He is also a Human Resources Development Trainer certified by the Human Resources Ministry.


He is currently the Managing Director & partner of Paradigm Group of Companies (Paradigm Resources; Paradigm Training & Consultancy PLT), specialized in providing risk management / assessment services for internal / external associates; Consultation on Supply Chain Security Risk; Brand Standards / Management / Protection; Contract Management; Outsourcing & Subcontracting; and; Human Resources training and development programmes on various specialized topics, predominantly, Risk Management related subject matters, either on a one off or Project basis.


In view of this, he is now working in collaboration with the Malaysian Anti-Corruption Commission and the Malaysian Institute of Integrity on Community Development and Awareness programmes in relation to Anti Bribery and Corruption initiatives in Malaysia.


In his capacity as a trainer, he actively conducts trainings on the following topics:

  • Responsible Business Alliance (Formerly known as EICC)
  • RBA Internal Audit Methodology
  • Labour Laws – The Risk Management Perspective
  • Prosecution & Domestic Inquiry – Approach & Method
  • Enterprise Risk Management – Approach & Methodology (ISO 31000; ISO 9001:2015)
  • Crisis Management & Business Continuity– Synergy Workshop
  • Business Continuity Management – ISO 22301
  • Corporate Governance
  • Business Ethics and Compliance - A Risk Management Perspective
  • Human Resource Management – A Risk Management Perspective
  • Fraud Management – A Risk Management Perspective
  • Anti – Bribery & Corruption – Implementation, Compliance and Enforcement (MACC Act 2009); Anti Bribery Management System (ABMS) – ISO 37001:2016 – Awareness and Implementation
  • Anti – Bribery & Corruption – Section 17A Corporate Liability Perspective
  • Adequate Procedures & Corporate Liability – Implementation Programme
  • Whistle blower Protection Act 2010 – Awareness & Implementation
  • Fraud Management & Due Diligence Framework – A Risk Management Perspective
  • Investigation Skills & Techniques – A Risk Management Perspective
  • Loss Prevention Programme – Approach, Design & Execution Method
  • Contract Risk Management
  • SA8000 – Standards and Compliance Methodology


With his background of a law degree, he is able to invoke legal implications in his programmes to make it more comprehensive and value-added substance. In addition, his fluency in English and Bahasa Malaysia enables him to conduct training programmes effectively in both languages.


Prior to his involvement in this field, the facilitator has wide working experience throughout his 15 years of working career in the specialized area of Risk Management, Security Management and Investigations (HR, Security (Operational and Information Security) and Safety, Corporate Governance and Ethics). Being a Head of Department in each of these portfolios, he has acquired substantial job-related knowledge and experience in sectors comprising of Manufacturing, Telecommunications, Hospitality Management (Brand Standard & Management) and Contract Manufacturing (Brand Protection and Management). He is also a trained Workplace Counsellor and by virtue of his portfolio of having to deal with people of different job hierarchy, he has very profound people management skills, negotiation skills and effective interaction skills.

Venue Details

Virtual Classroom Training

Contact us

M - 012 2281 247

M - 019 363 7822 

M - 012 201 1247

A-28-5, 28th Floor, Menara UOA Bangsar, 
No.5, Jalan Bangsar Utama 1, 
59000 Kuala Lumpur

  • Part 1: Fundamentals On MACC ACT 2009 – Strategic Values

    • Laws and Standards governing Ethics, Bribery & Corruption
    • Definition Bribery & Corruption
    • Definition of Asset Misappropriation
    • Investigation Process and Procedures
    • Risk and Corporate Governance


  • Part 2: Guideline And Implementation Of No Consent Requirement & Adequate Procedures To Support MACC Act 2009 & 2018 (S. 17A & 17B)
    • No Consent
    • Adequate Procedures Encompass The Following
    • Developing and Implementing Anti Bribery and Compliance Programme
    • Due Diligence
    • Improving Ethical Behaviour in Business
    • Selection & Performance Management of Suppliers

This course is designed to give participants a solid understanding in bribery and corruption detection and prevention in Malaysia in accordance to the Malaysian Anti-Corruption Commission Act 2009 & 2018 (Amendment Act) and other relevant Laws in Malaysia and its application within the organization and the related industries & trade.


Effective 1st June 2020, Section 17A of MACC Act 2009 enables prosecution of commercial organizations involved in corruption activities unless these commercial organizations can establish the defense of…. NO CONSENT & ADEQUATE PROCEDURES


This session shall focus on, methods of establishing these defenses.

  1. Understanding background, structure and intent of Malaysian Anti-Corruption Act 2009 and Amendment Act 2018 (S. 17A).
  2. Interpreting the requirements for ‘adequate procedures’ as per MACC Act 2009 based on the principles of T.R.U.S.T.
  3. Understanding and learning methods of conducting due diligence within the parameters of legal provisions.
  4. Being able to identify existing / potential ethical conduct within the organization or emanating from 3rd party engagement, which may have an impact on Business Continuity activities.
  5. Understanding the Legal Impact(s) due to ineffective management of unethical business conduct.
  6. Defining malpractices & Spotting The Red Flags during the course of hiring, sourcing and contract management and also Account Payables.
  7. Describing the Plan-Do-Check-Act management system and how it relates Adequate Procedures.
  8. Understanding about Pre-Employment Screening & Whistle- Blowing.
  9. Understanding Malpractices Detection & Profile Auditing.
  10. Obtaining, collation and preservation of Digital Evidence.
  • Anyone involved in managing corporate governance and integrity practices of the organisation
  • Anyone involved in contracting of any kind, especially holding a portfolio for evaluating and sourcing for suppliers, contractors, etc. Whether a team member, project manager, or executive.
  • Highly Interactive Session, with a bilateral approach to the subject matter allowing participants to share incidences at respective work locations.
  • Breakout Sessions
  • Virtual Learning
  • Case Studies on various reported Cases
  • Ice Breaking / Monotony Breaking Sessions – Purpose of rejuvenating the mind


  • Laws and Standards governing Ethics, Bribery & Corruption
    - MACC Act 2009
    - Evidence Act 1950
    - Employment Act 1955
    - Contracts Act 1950
  • Definition Bribery & Corruption
  • Definition of Asset Misappropriation
  • Investigation Process and Procedures
    - Reporting - Initiating and investigation
    - Evidence (Verbal, Documentary, CCTV, Digital, Email, Eyewitness)
    - Domestic Inquiry and Prosecution
  • Case Studies
  • Risk and Corporate Governance
    - Fundamentals
    - Processes & SOPs
    - Ingredients
    - Environment, People and Opportunity
    - Dominant factor
    - Corporate governance in jeopardy
    - Generic reasons for bribery and Corruption
    - Risk (Reality vs Myth)
    - The risk domains in an organisation
    - Red Flags of Bribery & Corruption
12.30 Lunch


  • No Consent
    - Definition
    - How does a corporation show / prove no consent
  • Adequate Procedures Encompass The Following
    - Principles of T.R.U.S.T
    - IT and Physical Security
    - HR Processes & Procedures
    - Finance Processes (Accounts Receivable and Accounts Payable)
    - Claims Management
    - Inventory management
    - Zero Balancing - Record keeping and reporting
    - Credit Note Management
    - Disposal of obsolete and damaged goods – Scrapping Process, Writing Off Process
  • Developing and Implementing Anti Bribery and Compliance Programme
    - Top Down Exercise – Management Support
    - Due Diligence and Risk Management
    - Policy – Content Framework
    - Detailed policies for particular risk areas
    - 3rd Party communication & management
    - Internal Controls and documentation
    - Communication and training
    - Promoting and incentivizing ethics and compliance
    - Seeking guidance – Detecting and reporting violations addressing violations
    - Periodic reviews and evaluation of the anti- corruption programme
5:00 End of Day 1
  • Recap of Day 1
  • Due Diligence
    - Financial Records
    - Methods of Conducting Due Diligence in the hiring process (Human Resources)
    - Methods of Conducting Due Diligence in the sourcing and engagement of 3rd parties process
    (Procurement / Purchasing / Vendor Management) Laws governing Personal Data and Financial Records Searches (PDPA 2010, FSA 2013) and how to manage searches within the ambits of the law
    - Best practices
    - Maintaining Records for Due Diligence
    - Chain of Custody of records and evidence of Due Diligence
    - Digital and Manual Records – Evidential Weightage
    - Usage of 3rd Parties to conduct Due Diligence – Cogency and Integrity of Data
    - Evidential Burden
  • Improving Ethical Behaviour in Business
    - 3 Key Elements that Influences Ethical / Unethical Decisions in an Organisation
    ~ Individual Standards & Values
    ~ Managers & Co- Workers Influence
    ~ Opportunity (Codes & Compliance Requirements)
    - Corporate Governance (Organisational Policy)
12.30 Lunch
  • - HR Policies (Employee Relations & Code of Ethics)
    - Whistleblowing (Whistle- blower Protection Act 2010)
    - Standard Operating Procedures (SOP) Compliance in line with Business Ethics and Key Risk Indicators (KRI)
    - Joint Responsibility Approach
    - Compliance to related regulations, laws and standards.
  • Selection & Performance Management of Suppliers
    - Methodology
    - Reporting
    - Escalation Path
  • - Desktop Exercise
    - Corruption Risk Assessment
    - Group Presentation
5:00 End of Course