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CHAIRMAN’S           DELIVERING            MSM           MANAGEMENT DISCUSSION    GROUP FINANCIAL
                  STATEMENT             VALUE               OVERVIEW            & ANALYSIS            REPORT


           INTERNAL POLICIES,

           PROCEDuRES AND GuIDELINES






           a)   Establishment of MSM Group’s Limit of Authorities (LOA).

           b)    Revision of Financial Closing and Reporting Requirement Policy, Investment Policy and Property, Plant and Equipment Policy
           c)   Establishment of Anti-Bribery Policy Statement

               •    The  Anti-Bribery  Policy  Statement  has  been  approved  on  15  June  2020  (revised  on  05  March  2021)  and  been
                   uploaded in the web (http://www.msmsugar.com/our-company/corporate-governance).

               •   The policies involved as follows:
                       Whistleblowing Policy (WB)
     120               Asset/Personal Declaration Interest Policy (APID)
                       External Gift, Entertainment and Hospitality Policy (External GEH)
       MSM MALAYSIA HOLDINGS BERHAD   Annual Report 2020
                       Sponsorship and Donation Policy
                       Code of Business Conduct Ethics for Employees (COBCE)

           d)   Adequate procedure
               Education and awareness programme

               The education and awareness programme has been conducted starting March, 2020 until July, 2020 in which the scope of
               training covered the following:
               •   Understanding on Corporate Liability (Latest MACC (Amendment) Act 2018 Section 17A)

               •   Understanding Guidelines on Adequate Procedures
               •   Whistleblowing

               •   ISO 37001 Anti-Bribery Management System
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