Amanah Raya Berhad
Transcription
Amanah Raya Berhad
Vision To be an institution of excellence in providing professional services in trust and estate administration, meeting customers’ satisfaction with a sense of social responsibility. Mission To ensure the highest standard of service to our entire customer. To ensure efficiency and profitability at par with other private trust companies. To provide cordial working environment for an efficient, well trained, highly motivated and competent staff to carry out their duties in a timely and professional manner. To strive in bringing new products and services to suit the ever changing needs of our customers. To strive towards strengthening the company’s capabilities and enhancing its image so as to maintain its position as the market leader in estate administration and trust services. AmanahRaya Integrity Plan CONTENTS 1. STATEMENTS OF COMMITMENT FROM THE CHAIRMAN AND THE MANAGING DIRECTOR 4 & 5 2. PURPOSE 6 3. BACKGROUND • The National Integrity Plan - The Role of Private Sector - Integrity Agenda 6 • Concept - Ethics - Ethics of Individual - Ethics of Organisations - Professional Ethics - Integrity - Integrity of Individual - Integrity of Organizations 4. AMANAHRAYA INTEGRITY PLAN (ARIP) • Objectives • People To Whom The Plan Applies • Integrated And Comprehensive Plan • Integrity And Trust • Integrity in Service Delivery • Creating an Integrity Culture • Corporate Governance Practices in AmanahRaya • Corporate Social Responsibility • Approach • Implementation 9 5. STRATEGY 19 6. CONCLUSION 20 7. ACTION PLAN 21 AmanahRaya Core Values INTEGRITY To uphold customers’ trust by discharging our duties fairly, honestly and sincerely. KNOWLEDGE Understand and be knowledgeable on AmanahRaya’s products, services and other related fields in order to achieve good results, effectively and efficiently. PRIDE Proud to be associated with AmanahRaya and its products and services. TEAMWORK Collective effort to achieve AmanahRaya’s goals. CUSTOMER SERVICE EXCELLENCE To continuously deliver excellent customer service. AmanahRaya Integrity Plan STATEMENT OF INTEGRITY COMMITMENT FROM THE CHAIRMAN OF AmanahRaya A manahRaya, which is the oldest and premier trust company in Malaysia, was formerly known as the Department of Public Trustee and Official Administrator when it first commenced operation on 1 May 1921. Subsequently, the Department was corporatized on 29 May 1995 and commenced its operation as Amanah Raya Berhad on 1 August 1995. Today, AmanahRaya’s professionalism, efficiency and dedication have helped the company to grow into being the principal brand for trustee services in both retail and corporate markets. In its continuous efforts to improve, AmanahRaya welcomes and supports the Government’s implementation of the National Integrity Plan (NIP) which was launched on 23 April 2004 by Prime Minister Dato’ Seri Abdullah Ahmad Badawi. The plan which was established to provide guidelines to all sectors in improving core values and integrity could not come at a more opportune time as AmanahRaya has set in motion various programs and activities which complements the NIP. The NIP emphasized the importance of the private and public sectors to include integrity agenda in their business operations. The strategy outlined by the Government under the NIP includes amongst others; strengthening integrity within the corporate sector, promote and strengthen business ethics and enhancing corporate social responsibility and accountability. AmanahRaya is certainly looking forward to be the first wholly-owned Government company to establish an integrity plan. The AmanahRaya Integrity Plan (ARIP) is formulated with the intention to provide a culture of professionalism and integrity as well as promote transparency and accountability. With the implementation of ARIP, the company hopes to strengthen the understanding amongst its workforce the value of ethics, integrity and importance of Corporate Governance. In taking the lead as the first Government owned company to implement the Integrity Plan, AmanahRaya hopes this paves the way for others to emulate its initiative. DATO’ HAJI DUSUKI AHMAD 4 AmanahRaya Integrity Plan STATEMENT OF MANAGING BUSINESS INTEGRITY FROM THE MANAGING DIRECTOR OF AmanahRaya I n its pursuit to sustain its position as the premier trust company in Malaysia, AmanahRaya has never neglected its responsibility as a good corporate citizen by carrying out its social obligations. AmanahRaya as a service provider in the areas of trust and estate administration has taken a giant leap in incorporating elements of integrity and values within the organization. In this respect, AmanahRaya introduced its core values namely Integrity, Knowledge, Pride, Teamwork and Customer Service Excellence in 2002 to inculcate an efficient and effective workforce. Subsequently, in 2004, AmanahRaya introduced its Risk Management Program to further enhance the company in monitoring and evaluating high risk activities. To further complement the project, AmanahRaya adopted the ISO 9001:2000 in 2005. In addition, AmanahRaya took the initiative to recruit Customer Service Associates to project and elevate its professional image and at the same time heed the Government’s call to provide employment for unemployed graduates. With the anticipated implementation of the AmanahRaya Integrity Plan (ARIP), the company hopes to further attain the public’s trust towards AmanahRaya as a company which promotes ethical values and integrity. In its first move towards this objective, AmanahRaya had appointed a Chief Integrity Officer to establish and execute the ARIP in line with the Government’s National Integrity Plan. To ensure the success of ARIP, an action plan was formulated encompassing the aspects of Education, Prevention, Enhancement and Punitive. It is hoped the initiatives that has been put in place will receive favourable support from all sectors so that we can succeed in creating a more professional and dynamic working environment in line with the Nation’s aspirations as embodied in The National Integrity Plan. DATO’ AHMAD RODZI PAWANTEH 5 AmanahRaya Integrity Plan PURPOSE The purpose of initiating the Plan is to foster and maintain public confidence in the company’s integrity. This is achieved through the provision of a framework to build an integrity culture in AmanahRaya by implementing the related objectives, strategies and program encompassed in the National Integrity Plan. BACKGROUND THE NATIONAL INTEGRITY PLAN On 23 April 2004, the Prime Minister Y.A.B Dato’ Seri Abdullah Bin Haji Ahmad Badawi launched the National Integrity Plan. It was formulated with the purpose of enhancing ethics and integrity so that it will become a way of life among the people. The Plan require all sectors, namely Government, private, political parties, religious institution, trade unions, NGOs and other groups to enhance their understanding of integrity and be committed to it. The Malaysian Government believes that this sector is the prime mover of the economic growth in the country. The main concern in the private sector with regard to integrity is corporate governance. The policy of the Malaysian economy and sustained prosperity has enabled foreign companies to operate in this country. Concurrently, it has also enabled the Malaysian private sector to venture globally in their business operations. The Role of the Private Sector The initiative of enhancing ethics and integrity in the private sector has resulted in the drafting of Malaysian Code on Corporate Governance (MCCG) in year 2000. Companies are required to be transparent by making disclosures as per the Listing Requirements. Annual Reports are required to include a statement concerning corporate governance, to indicate how the principles outlined in MCCG are applied and how far the code is being observed. The company must provide explanation for alternative practices that they have put in place. In addition, a set of Business Ethics known as Rukun Niaga Malaysia was introduced and implemented by the Ministry of Domestic Trade and Consumer Affairs in 2002. Rukun Niaga Malaysia outlined six principles for conducting business vis-à-vis:- Honesty in doing business; 6 AmanahRaya Integrity Plan responsibility toward clients, society and environment; being humane to all mankind; fairness to client; moderation in business conduct; and determination to succeed in business. Integrity Agenda The NIP emphasized the importance of the private sector to include the Integrity agenda in their business operations. The strategies to help the government in achieving the NIP target are as follows: a) Strengthen Corporate Sector Integrity. b) Promote and strengthen business ethics. c) Strengthen cooperation among all sectors through the concept of Malaysia Incorporated in Promoting Integrity. d) Strengthen cooperation between corporations and trade unions; and e) Enhancing corporate social responsibility and accountability. CONCEPT Ethics and integrity are two key words or concepts that run through the NIP. These concepts have been explained in NIP. Ethics Ethics is a set of moral values and principles which forms the standards guiding the code of conduct of individuals, organizations and professions. Ethics Of Individual Individual ethics consist of a set of values that guide the conduct and behavior of individuals, enabling them to differentiate between right and wrong, good and bad, and between what should and can be done, and what should not and cannot be done. These options will always be present in the course of carrying out one’s duty in daily life or in the course of interaction with others. 7 AmanahRaya Integrity Plan Ethics Of Organizations For those working organizations, organizational ethics serves as guidelines in the conduct of duties. These includes adherence to the principles of honesty, competency, trustworthiness, truthfulness, transparency, accountability and justice. Since organizations continuously interact with the public, organizational ethics also demands staff of the organization to uphold the Clients’ Charter. Professional Ethics Professional ethics is a code that provides guidelines for practitioners in various professions. Professions with code of ethics include medicine, law, accountancy, journalism and education. For example, a doctor or a judge is governed by his or her profession’s code of ethics. An editor or journalist is governed by the code of ethics in journalism which regulates the dissemination of information through the mass media. Those in the teaching profession are required to comply with the code of ethics for teachers. Integrity In general, integrity is a quality of excellence that manifested in a holistic and integral manner in individuals and organizations. Integrity is based on ethics and noble values and their concrete manifestation in daily lives. Integrity Of Individual Integrity of individual is the harmony between what an individual says and does. His or her actions are in accordance with moral and ethical principles as well as laws and regulations and do not go against public interest. They also reflect promptness, correctness and quality. Integrity Of Organizations The integrity of an organization is reflected in the formulation and implementation of its code of ethics, clients’ charter, and system or work procedures, as well as compliance with best practices. The organization’s code of ethics is constantly reiterated, internalized and upheld by members of the organization until it becomes second nature, and ultimately transforms into the culture for the organization as a whole. 8 AmanahRaya Integrity Plan AmanahRaya Integrity Plan (ARIP) OBJECTIVES To actively enhance a culture of professionalism and integrity in AmanahRaya To prevent the incidence of misconduct and corruption linkages to other. To ensure AmanahRaya’s integrity and transparency is sustained in daily practices through elements of honesty, efficiency and trustworthiness. PEOPLE TO WHOM THE PLAN APPLIES All Staff including AmanahRaya’s subsidiaries Any person engaged under a contract for services; or Any person engaged by the company for any activity. INTEGRATED AND COMPREHENSIVE PLAN The Plan is an integral part of the current reform process. It builds on existing mechanisms and links to other plans, policies and processes including: AmanahRaya’s Strategic Plan AmanahRaya’s Annual Business Plan AmanahRaya’s Corporate Values AmanahRaya’s Social Responsibility Risk Management Plan Corporate Governance Compliance AmanahRaya’s Annual Report AmanahRaya Integrity Plan (ARIP) is an integrated and comprehensive plan of action. The comprehensiveness of this plan is portrayed through the involvement of employees in the organization. The integrated approach requires the usage of multi-strategies to manage integrity. 9 AmanahRaya Integrity Plan INTEGRITY AND TRUST AmanahRaya believes demonstrating a high integrity organization is a key factor in establishing and maintaining customers’ confidence. Such confidence is essential. Confidence and trust can only improve if the actions and behaviours we express meet customers’ expectation. The society entrusts AmanahRaya with a special role, and in return rightly expects high standards of behaviour. We are committed to demonstrating a level of professionalism and integrity that the customers will be able to see and rely on. A major component of this is an overall integrity strategy. AmanahRaya’s vision cannot be achieved without the trust, cooperation and participation of the community. AmanahRaya is committed to developing this trust in a number of ways including the establishment of a culture of “no tolerance” towards white-collar crimes and providing a level of transparency in our systems and processes that builds confidence. INTEGRITY IN SERVICE DELIVERY The Integrity Plan is part of the management commitment to improve the quality of our service delivery. It will be undertaken at every level and encompass everything we do. AmanahRaya is committed to reforms that will strengthen the ethics and integrity of the organisation and vigorously target misconduct in a more coordinated way. These include a commitment to providing secure information systems, equity and ease of access to complaints processes, clarifying and monitoring standards and managing risks. CREATING AN INTEGRITY CULTURE AmanahRaya commits to creating an integrity culture through recruitment, selection, training and management practices. Every staff must develop a clear understanding of, and adherence to, sound ethical behaviour. CORPORATE GOVERNANCE PRACTICES IN AmanahRaya The Board of Directors is committed to ensuring that the highest standards of corporate governance are practiced throughout the Group as a fundamental part of discharging its responsibilities to protect and enhance shareholders’ value and the financial performance of the Group and the Company. 10 AmanahRaya Integrity Plan The Board currently consists of nine (9) members, comprising eight (8) Non-Executive Directors (including the Chairman) and one (1) Executive Director. The Directors bring a wide range of legal, business and financial experience relevant to the direction of an expanding trust company. The Chairman holds a Non-Executive position and is primarily responsible for the orderly conduct and working of the Board while the Managing Director is responsible for the day-to-day running of the business and implementation of Board policies and decisions with the support of the management team. The presence of Independent Non-Executive Directors provides an effective Board with a mix of industry specific knowledge and broad business and commercial experience. Directors are equally accountable and responsible and the role of these Independent Non-Executive Directors is particularly important in ensuring that the strategies proposed by the management are fully discussed and examined, complied with the Companies Act 1965 and Public Trust Corporation Act 1995 and/or any other regulations and also to take into account of the long term interests, not only of the shareholders, but also of employees, customers, vendors and the public at large with whom the Company conducts its business. The Board may seek advice from independent experts whenever necessary at the Company’s expense. To assist the Board in discharging their duties in reviewing the operations and performance of the Company efficiently, the Board has delegated some of its responsibilities to the following Committees:- CORPORATE GOVERNANCE PRACTICES IN AmanahRaya 11 AmanahRaya Integrity Plan CORPORATE SOCIAL RESPONSIBILITY As a responsible corporate citizen, AmanahRaya has undertaken various activities to provide assistance to the general public. One of the main activities that the company has continuously and consistently provided are donations and sponsorships towards the underprivileged, handicapped as well as individual organizations. Notwithstanding that, AmanahRaya has also answered the Government’s call in providing employment opportunities for unemployed graduates. In 2003, ARB was among the pioneer companies that supported the Capital Market Graduate Training Scheme (CMGTS), a program associated with Securities Commission in exposing the graduates to the capital market industry. Till date, ARB has accommodated almost 50 trainees from the program to undergo various exposures on Corporate Trust and Asset Management. In view of meeting customers’ requirements, ARB found a need to allocate reputable front-liners to entertain customers and ensure information is disseminated effectively. Hence, ARB formed its own customized program specifically catering this aspect known as ARB’s Customer Service Associate Scheme. This scheme allows the graduates to acquire knowledge and skills related to Customer Service and provide a comprehensive exposure on the trustee business. In March 2006, ARB marked another milestone with the signing of a Memorandum of Understanding with three local universities, Universiti Malaya, Universiti Technology MARA and Universiti Utara Malaysia for the “Jejak Graduan” program. This program encompasses two main groups, internship students and Executive Associates, both having different aims and objectives. Under this program, the Executive Associates will be exposed to ARB’s main operations and ultimately develop them as part of succession planning. It is ARB’s hope that with this continuous effort, a pool of skillful graduates will be able to contribute to society and utilize all the competencies gained to achieve their career goals. 12 AmanahRaya Integrity Plan Prevention Enhancement Punitive AmanahRaya Integrity Plan Strategic Planning Corporate Governance Risk Management Corporate Value & Social Business Ethics Responsibility NATIONAL INTEGRITY PLAN ( NIP ) 13 Diagram 1 VISION & MISSION AmanahRaya INTEGRITY PLAN Education AmanahRaya Integrity Plan Continuous Monitoring Design Control Identify Gap Risk Analysis Identify core Processes / Activities Diagram 2 INTEGRITY RISK MANAGEMENT PROCESS Formulate Action Plan 14 AmanahRaya Integrity Plan Diagram 3 AmanahRaya’s INTEGRITY FRAMEWORK 15 AmanahRaya Integrity Plan APPROACH To achieve the objectives, four (4) approaches will be used: EDUCATION Develop, plan and implement integrated programs to increase knowledge, awareness and skills of AmanahRaya employees in integrity management. PREVENTION Detect and identify weaknesses in practices, systems and work procedures and continue to increase the level of efficiency by eliminating opportunities for corruption, fraud and abuse of power. ENHANCEMENT This approach emphasizes on efforts to ensure compliance on work processes, systems, code ethics and client’s charter. It focuses on efforts to recuperate any person or organization exposed to and involved in activities that can tarnish the company’s integrity. It also involves efforts in giving recognition to parties who are committed in upholding AmanahRaya’s integrity. PUNITIVE Develop a mechanism that will increase the ability to detect and punish those involved in activities that will taint AmanahRaya’s integrity. IMPLEMENTATION MECHANISM The implementation of this plan needs an adjustment for the role and responsibility of the Personnel Committee. This committee will monitor the implementation of the Integrity Plan. The Personnel Committee’s Terms Of Reference (TOR) is extended. This committee is renamed as Personnel and Integrity Management Committee. 16 AmanahRaya Integrity Plan Terms Of Reference; Authorities; Composition Duties; Responsibilities 1. To recommend to the Board of Directors the remuneration packages of all non-executive directors in all forms inclusive of cash and non-cash benefits, options and privileges granted by the Company. 2. To review and recommend on annual basis all benefits and entitlements of all executive directors, and/or Managing Director/Chief Executive Officer. One (1) Non-Executive Independent Director – Chairman Two (2) Non-Executive Independent Directors – Members 3. To establish a formal and transparent procedure for the : a) The framework or broad policy for the remuneration and benefit structure of entire staff of the Company. Managing Director / Chief Executive Officer – By Invitation b) the scope and service agreements, termination payments and compensation commitments for the entire staff of the Company. Company Secretary – Secretary 4. To recommend for the approval of the Board of Directors of the policies relating to any performance related pay schemes for the Company e.g. Annual Bonus. 5. To nominate for the approval of the Board of Directors of the appointment, deployment, remuneration and other scope of services for the General Managers. 17 AmanahRaya Integrity Plan Terms Of Reference; Authorities; Composition Duties; Responsibilities 6. To be appellate body to review and decide on appeals by affected Managers against the convictions and sentences imposed by the Domestic Inquiries on them. 7. To approve the appointment and/or engagement of such advisers and consultants as proposed by the Management Committee in order to carry out and fulfill the above responsibilities. One (1) Non-Executive Independent Director – Chairman Two (2) Non-Executive Independent Directors – Members 8.** Adopting a Strategic Integrity Management Plan for the company. 9.** Overseeing the conduct of the company’s business to evaluate and ensure that the business is being managed properly with integrity. 10.** Identify principal fraud and corruption risks and establishing the appreciate systems to manage the indefinite it. Managing Director / Chief Executive Officer – By Invitation Company Secretary – Secretary 11.** Reviewing the adequacy and effectiveness of both the internal control and external Control system. Note: ** New Terms of Reference for the Personnel and Integrity Management Committee. 18 AmanahRaya Integrity Plan STRATEGY EDUCATION To enhance the Integrity awareness in AmanahRaya. Strategies • Organize Activities That Will Increase Knowledge And Awareness On Integrity PREVENTION To ensure the elements of accountability and transparency are practiced in the organization. Strategies • Increase Transparency In Management • Identify And Manage High Risk Areas Of Possible Fraud And Corruption. • Develop Efficient & Effective Rules And Work Procedures • Develop And Implement An Effective Code Of Ethics. ENHANCEMENT To ensure everybody and every department/ branch in the organization comply with the integrity management principles. Strategies • Enhancing The Practice Of Corporate Governance In Amanahraya. • Develop An Integrity Evaluation And Recognition System. • Develop An Effective Integrity Monitoring And Reporting System • Develop An Integrity Rehabilitation System • Integrity Testing System. PUNITIVE To create an environment that any criminal and unethical act can be detected. Strategy • Develop An Effective Detection And Investigation System 19 AmanahRaya Integrity Plan CONCLUSION The achievement of the various objectives in this plan depends on the support of the staff throughout the organization. The success factors are the leadership commitment, sound policies, effective communication and adequacy of resources. All leaders in the organization must hold fast to the principles of honesty, efficiency and trustworthiness. They must be able to mobilize and inspire their subordinates towards realizing the ARIP’s objectives. Effective communication is the means to build integrity into everything an organisation does. The integrity elements will only shape an organization’s culture if they are communicated by senior managers in ways that are relevant to other staff and integrated with all the operations of the company. Therefore the launching of ARIP should be the catalyst towards realizing the objective of enhancing integrity and enable the company to become an institution of excellence in providing professional services in trust administration and legacy management. 20 AmanahRaya Integrity Plan ACTION PLAN 21 AmanahRaya Integrity Plan EDUCATION Strategy 1: Organize Activities That Will Increase Knowledge And Awareness On Integrity NO. PROGRAM / ACTIVITY TARGET GROUP OBJECTIVE 1. Poster/bunting & lanyard All staff Integrity awareness 2. Organize Integrity Training Programs BOD and All staff. Instill Integrity awareness Including new staff and improve skill on managing integrity 3. 4. Spiritual session • ceramah agama • Qiamullail • Morning prayers (weekly) Lecture series • All staff Integrity awareness All staff Integrity awareness external/internal speakers 5. Chairman’s Remarks BOD& All Staff Integrity awareness 6. Develop AmanahRaya’s Integrity Training BOD & Staff To have an effective Integrity Training Program Package 7. All staff Website info. Integrity awareness & knowledge 8. All staff Distribute ARIP & Bulletin Integrity awareness & knowledge 9. All staff Essay competition Integrity awareness & knowledge 10. Integrity corner External parties Integrity awareness to the (i.e supplier, public customer etc). 22 AmanahRaya Integrity Plan NO. PROGRAM / ACTIVITY TARGET GROUP 11. Insert integrity in company’s advertisement External parties Integrity awareness to public & tender & supply documents 12 OBJECTIVE External parties Best practices statement Integrity awareness to public 13 Incorporating suitable messages in external External parties Integrity awareness to public. presentation. PREVENTION Strategy 1: Increase Transparency In Management NO. 1. PROGRAM / ACTIVITY TARGET GROUP Improve complaint & monitoring All Departments OBJECTIVE Complaints are settled within specified management period Customer satisfaction 2. Improve implementation on clients’ charter All Departments Customer satisfaction & transparency & report preparation Improve efficiency 3. All Staff Develop a written policy on giving and Give guideline to officers in dealing with dilemma acceptance of gifts. situations. 23 AmanahRaya Integrity Plan Strategy 2: Identify And Manage High Risk Areas Of Possible Fraud And Corruption. NO. 1. PROGRAM / ACTIVITY TARGET GROUP Corruption and Fraud Risk Management OBJECTIVE All high risk Continuous improvement Departments on current roles to prevent corruption Strategy 3: Develop Efficient & Effective Rules And Work Procedures NO. 1. PROGRAM / ACTIVITY TARGET GROUP All Departments Update customer service guidebook OBJECTIVE Transparency on systems & procedures 2. All Departments Improve IT application systems for main systems’ efficiency processes 3. Improvement in delivery All Departments Ensuring full implementation of ISO Operational excellence: Improve efficiency of 9001:2000 department’s operation system Strategy 4: Develop And Implement An Effective Code Of Ethics. NO. 1. PROGRAM / ACTIVITY TARGET GROUP All Staff Develop AmanahRaya Code of Ethics OBJECTIVE To ensure staff understand and practice good business behaviour. 24 AmanahRaya Integrity Plan ENHANCEMENT Strategy 1: Enhancing The Practice Of Corporate Governance In Amanahraya. NO. 1. PROGRAM / ACTIVITY TARGET GROUP OBJECTIVE Board of Directors. To assist BOD on the Board Policy Manual understanding of the Board Policy Manual. 2. Board of Directors. To give induction Directors’ Training programme for new recruits to the Board. 3. Board of Directors. To initiate an assessment Review on Mix of Skills. of the current skill set of BOD members to identify any gap in qualification and experience to drive the Company. Strategy 2: Develop An Integrity Evaluation And Recognition System NO. 1. PROGRAM / ACTIVITY TARGET GROUP OBJECTIVE Introduce the system of the triple bottom Board of Directors Improve AmanahRaya’s line: in addition to financial report and and AmanahRaya transparency and occupational safety report, AmanahRaya Management team accountability in corporate management should also introduce self disclosure report on corporate activities. 2. Implement the Performance Management AmanahRaya Top Enhance accountability System for top management Management among top management 25 AmanahRaya Integrity Plan NO. 3. PROGRAM / ACTIVITY TARGET GROUP OBJECTIVE All Depts Inculcate business ethics Organize Integrity Recognition Award/ All AmanahRaya Encourage staff involvement letter staff and inculcate honesty & Establish a policy on relationship with vendor and supplier 4. responsibility Strategy 3: Develop An Effective Integrity Monitoring And Reporting System NO. PROGRAM / ACTIVITY TARGET GROUP OBJECTIVE 1. Making Integrity as Permanent Agenda in Senior To supervise, implement & Management Meeting Management monitor the implementation of the Integrity Plan 2. 3. 4. 5. All AmanahRaya To instill loyalty, sense of staff / Vendor belonging & accountability Develop an internal reporting system and All AmanahRaya To Provide an effective Policy Staff reporting mechanism Develop information channel for whistle All AmanahRaya To provide proper channels blowers staff / Vendor of complaints Implement full asset declaration All AmanahRaya Improve AmanahRaya’s staff transparency Enforcement of Integrity Pledge 26 AmanahRaya Integrity Plan Strategy 4: Develop An Integrity Rehabilitation System NO. 1. 2. PROGRAM / ACTIVITY TARGET GROUP OBJECTIVE Implement counseling/ training program All AmanahRaya To enhance conscience in for problematic staff. staff the individual Staff profiling All AmanahRaya To achieve job person match staff Strategy 5: Integrity Testing System NO. 1. 2. 3. PROGRAM / ACTIVITY TARGET GROUP OBJECTIVE All AmanahRaya To evaluate the level of staff/ Vendor integrity in the Company All AmanahRaya To ensure compliance of Staff & Vendor process & procedures Audit on compliance to guidelines & All AmanahRaya To ensure proper practices Staff & Vendor implementation of the To organize integrity test. Implement mystery shopper guidelines & practices 27 AmanahRaya Integrity Plan PUNITIVE Strategy 1: Develop An Effective Detection And Investigation System NO. PROGRAM / ACTIVITY TARGET GROUP OBJECTIVE 1. Analyse and improve the present detection All AmanahRaya To have an effective mechanism. Staff / Vendor detection mechanism to detect criminal and unethical acts 2. Update the internal inquiry procedure. 28 All AmanahRaya To ensure compliance of Staff & Vendor process & procedures Rukun Niaga Malaysia Honesty in doing business Responsibility toward clients, society and environment Being humane to all mankind Fairness to client Moderation in business conduct Determination to succeed in business. 29