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

23 Aug, 2022, Remote Online Training - Public

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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

Remote Online Training - Public

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 False Claim
    • Risk and Corporate Governance
    • Improving Ethical Behavior in Business

    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
    • Importance of Record Keeping and Documentation
    • Bribery and Corruption Risk Assessment and Management


This course is designed to give participants an awareness of bribery and corruption detection and prevention in Malaysia in accordance to the Malaysian Anti-Corruption Commission Act 2009 and other relevant Laws in Malaysia and its application within the organization and the related industries & trade.

In 2018, amendments were made to the existing law to include the Corporate Liability provision, i.e S.17A. 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 an overview of methods of establishing these defenses.

  1. Comprehend The Background, Structure And Intent Of Malaysian Anti- Corruption Act 2009 And Amended Provision (S.17A)
  2. Interpret The Requirements For ‘Adequate Procedures’ As Per MACC Act 2009 Based On The Principles Of T.R.U.S.T
  3. Identify Samples Existing / Potential Ethical Conduct Within The Organization Or Emanating From 3rd Party Engagement, Which May Have An Impact On Business Continuity Activities
  4. Identify The Legal Impact(S) Due To Ineffective Management Of Unethical Business Conduct.
  5. Distinguish That Impacts Of Non-Compliance To The Malaysian Anti- Corruption Commission Act 2009 And Relevant Organizational Anti Bribery And Corruption Policies
  6. Differentiate The Definition Of Malpractices & Spotting The Red Flags During The Course Of Hiring, Sourcing And Contract Management And Also Account Payables
  7. Recognise The Importance 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
    Case Studies
  • Definition of False Claim
    Case Studies
  • Risk and Corporate Governance / Ethics
    - Fundamentals
    - Importance of Processes & SOPs
  • Improving Ethical Behavior in Business
    - 3 Key Elements that Influences Ethical / Unethical Decisions in an Organization
    o Individual Standards & Values
    o Managers & Co- Workers Influence
    o Opportunity (Codes & Compliance Requirements)
1.00 Lunch


  • No Consent
    - Definition
    - How does a corporation show / prove no consent
  • Adequate Procedures Encompass The Following
    - Principles of T.R.U.S.T
    ? o Top Level Management Involvement
    ? o Risk Assessment & Management
    ? o Undertaking Control Measures
    o ? Systematic Review of Processes
    o ? Training & Communication
  • Developing and Implementing Anti Bribery and Compliance Programme
    - 3rd Party communication & management
    o ? Engagement (Contract)
    o ? Performance Management
    o ? Consequence Management
    - Internal Controls and documentation
    o ? Hiring (Contract)
    o ? Performance Management
    o ? Consequence Management
    - Communication and training
    - Promoting and incentivizing ethics and compliance
    - Seeking guidance – Detecting and reporting violations
    - addressing violations
    - Compliance to HR Policies (Employee Relations & Code of Ethics)
    - Whistleblowing Policy and Procedure (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
  • Importance Of Record Keeping and Documentation
    - Chain of Custody of records and evidence
    - Digital and Manual Records – Evidential Weightage
    - Usage of 3rd Parties to conduct Due Diligence
    - Cogency and Integrity of Data
    - Evidential Burden
  • Bribery and Corruption Risk Assessment and Management
    - Critical Business Process Identification
    - Gap assessment and analysis methodology
    - Risk Description methodology
    - Severity Rating ( Impact & Likelihood Analysis)
    - Gap Closure ( Initiatives and Action Plans)
  • Mind Mapping and Summary

5:00 End of Course