HOW TO

IMPLEMENT
AN INTEGRITY
PROGRAMME

A GUIDE FOR MDs/CEOs,

PETRONAS GROUP OF COMPANIES

PETROLIAM NASIONAL BERHAD (PETRONAS) 2013. All rights reserved. No part of this
document may be reproduced, stored in a retrieval system or transmitted in any form or
by any means (electronic, mechanical, photocopying, recording or otherwise) without the
permission of the copyright owner.

COMMITMENT TO INTEGRITY
MESSAGE FROM THE TOP MANAGEMENT

TAN SRI MOHD SIDEk BIN HASSAN

Chairman of the PETRONAS Board

TAN SRI DATO SHAMSuL AZHAR ABBAS

President & Group Chief Executive
Officer of PETRONAS

The principles of governance apply to any organisation whether it is a

nation, the largest multinational company or the smallest home-based
business. Corporate governance as described by the World Bank entails
promoting fairness, transparency and accountability. It refers to how
nations and businesses are responsibly governed and this includes all the
processes, systems and controls that are in place to progress and grow.
In Malaysia, governance is an important focus in the nations aspiration to become a high
income nation because corruption erodes public confidence in the ability of the Government
and other key institutions in maintaining a fair playing field for all participants, and could
dissuade private investment. As such, fighting corruption has been made a National Key Result
Area in the Government Transformation Programme (GTP).
Similarly, it is fundamental for PETRONAS, as one of the largest multinational companies in
the world, to ensure good governance because it is vital for its continued growth and business
sustainability. These principles of governance are in fact embedded in PETRONAS Shared
Values namely Loyalty, Integrity, Professionalism and Cohesiveness.
PETRONAS practices zero tolerance to corruption and has in place systems and processes that
support the Governments GTP NKRA anti-corruption agenda. A signatory to the Corporate
Integrity Pledge (CIP), the Company is therefore committed to infusing a high integrity culture
amongst its most valuable asset, its people.

The How to Implement an Integrity Programme: A Guide for MDs/CEOs,

PETRONAS Group of Companies is one of the tools that the Company has initiated to
provide practical and comprehensive steps on conducting integrity programmes to create
awareness both internally and externally of the values of ethics, integrity as well as drive a
governance mindset throughout the Group.
It is hoped that this guide will enhance the strong foundations upon which this organisation
was built to create a stronger impetus for the organisations continued success and to
safeguard its reputation as a responsible corporate citizen.

Contents
1. PETRONAS Vision................................................................................... 6
2. PETRONAS Mission ............................................................................... 6
3. PETRONAS Shared Values...................................................................... 6
4. About This Booklet................................................................................. 7
5. An Overview of PETRONAS Integrity Agenda: The Journey . ..............10
6. What is an Integrity Programme (IP)?.................................................10
7. Why is an IP Important?......................................................................11
8. The Roles of Leaders as an IP Champion..............................................12
9. Developing an IP..................................................................................12
10. Expectations and Targets.....................................................................16
11. Additional References and Resources on Anti-Corruption

Programme and Initiatives...................................................................16

APPENDIX A: Integrity Risk Assessment Flow Chart...................................17

HOW TO IMPLEMENT AN INTEGRITY PROGRAMME

A Guide for MDCEOs/CEOs, PETRONAS Group of Companies

1. PETRONAS Vision

To be a Leading Oil and Gas Multinational of Choice

2. PETRONAS Mission

We are a business entity.

Petroleum is our core business.
Our primary responsibility is to develop and add value to this
national resource.
Our objective is to contribute to the well-being of the people and
the nation.

3. PETRONAS Shared Values

Note: These values are universally accepted as desirable values. The

interpretation of these values should not be limited to the elaborations given
below.

3.1. Loyalty
Loyal to nation and corporation

Elaboration
Employees are steadfast and dedicated in contributing their energy, passion
and drive to the success of the corporation specifically and the nation as a
whole.

3.2. Integrity
Honest and upright

Elaboration
Maintain and safeguard the reputable image of the Company and its
employees.

3.3. Professionalism
Committed, innovative and proactive and always striving for excellence

Elaboration
A fully integrated multinational Company which consists of people who are
committed to achieving business excellence, in line with the Companys
business objectives, mission and best practices.

3.4. Cohesiveness
United in purpose and fellowship

Elaboration
Develop stronger feeling of unity in the Corporation, inter-OPUs, inter-sectoral
activities at work and the social levels.

HOW TO IMPLEMENT AN INTEGRITY PROGRAMME

A Guide for MDCEOs/CEOs, PETRONAS Group of Companies

4. An Overview of PETRONAS Integrity Agenda: The Journey

PETRONAS is committed to comply with high ethical standards and applicable

anti-corruption laws. This is in line with PETRONAS core values, business
principles and various internal policies which reflect the continuous focus
on making ethics and anti-corruption an integral part of PETRONAS
business operations. Such focus has helped promote strong ownership and
accountability of compliance and ethics at all levels.

4.1. Signatory to the Malaysian Corporate Integrity Pledge

PETRONAS signed the Malaysian Corporate Integrity Pledge (MCIP), on 31
January 2012, underpinning its commitment to uphold the Anti-Corruption
Principles. MCIP is one of the National Key Results Areas, or NKRA, under
Malaysias Government Transformation Programme, or the GTP. As a signatory,
PETRONAS makes a declaration that it will not commit corrupt acts; will work
towards creating a business environment that is free from corruption; and will
uphold the Anti-Corruption Principles in conducting its business as well as in its
interactions with its business partners and the Malaysian Government.

4.2. Appointment of a Chief Integrity Officer

PETRONAS appointed a Chief Integrity Officer (CIO) who is also the Malaysian
Anti-Corruption Commissions (MACC) Director of Community Education
Division. The appointment is on a secondment basis for a period of two
years and follows the terms of a Memorandum of Understanding (MOU) that
PETRONAS signed on 7 June 2012 with MACC to formalise a collaborative
initiative announced in March the same year towards ensuring a corruption
free business environment within the PETRONAS Group.

Among the main roles of the CIO are as follows:

i. Develop appropriate programmes and strategies to educate PETRONAS
staff and relevant stakeholders on integrity and ethics best practices; as
well as supervise and ensure the employees adhere to these practices.
ii. Examine and evaluate the practices, systems and procedures in PETRONAS.
iii. Advise on appropriate action plans to mitigate identified risks pertaining
PETRONAS various activities; report on the progress of initiatives
undertaken; and measure its effectiveness.

4.3. Business Ethics

The PETRONAS Code of Conduct and Business Ethics (CoBE) replaces the
2006 PETRONAS Code of Conduct and Discipline. The PETRONAS Guidelines
for Business Conduct. CoBE also accommodates developments in local and
international laws and practices as well as technological developments.
It is being implemented in phases in PETRONAS operations worldwide,
commencing with the PETRONAS Group in Malaysia on 1 April 2012.

The CoBE emphasises and advances the principles of discipline, good conduct,
professionalism, loyalty, integrity and cohesiveness that are critical to the
success of the PETRONAS Group and the well-being of its people. The CoBE
is part of the PETRONAS Groups overall Corporate Enhancement Programme

HOW TO IMPLEMENT AN INTEGRITY PROGRAMME

A Guide for MDCEOs/CEOs, PETRONAS Group of Companies

initiated in 2010, reflecting the increasing need for effective corporate

governance compliance measures in the conduct of the Groups businesses
domestically and worldwide.

The CoBE contains detailed policy statements on the standards of behaviour

and ethical conduct which include policies on conflict of interest as well as
fighting corruption and unethical practices. The CoBE is applicable to all
employees and Directors within the PETRONAS Group worldwide. PETRONAS
also expects that contractors, sub-contractors, consultants, agents,
representatives and others performing work or services for or on behalf of
PETRONAS will comply with the relevant parts of the CoBE when performing
such work or services.

In view of the CoBEs international application, some provisions of the

CoBE will be modified to adapt it to the requirements of the applicable local
jurisdictions. The CoBE will include separate Country Supplements to cater to
the applicable local legislation and customs. The CoBE includes a CoBE Guide
that sets out frequently asked questions and some Dos & Donts in relation
to certain specific situations. The CoBE, the Country Supplements (where
applicable) and the CoBE Guide are printed in booklet form and are distributed
to all employees. The booklets are also available on the PETRONAS website
as reference for third parties dealing with the Company as well as the general
public.

Since the launch of CoBE, PETRONAS has been running a series of workshops
for trainers across the Group to equip them with the knowledge and skills
to run workshops for employees in their respective businesses. The CoBE
workshop is also included as part of the induction programme for new
executives in the Company. Between 1 April 2012 and 31 December 2012,
27,003 employees have undergone face-to-face training on the CoBE, and
the Company plans to intensify the training programme by providing online
training to reach out to more employees in the future.

To further assist with the understanding of the CoBE, a helpdesk,

cobe@petronas.com.my, was created to answer queries from employees
and third parties dealing with PETRONAS.

As part of PETRONAS efforts to prevent corruption and unethical practices, the

Company also rolled out its No Gift Policy in April 2012. The introduction of
the policy is meant to avoid conflicts of interest or the appearance of conflicts
of interest for either party in on-going or potential business dealings between
PETRONAS and external parties.

4.4. Third Parties Dealing with The Company

Recognising the importance of instilling high ethical standards to not only
our employees but to parties that have business dealings with us, PETRONAS
rolled out the CoBE to its contractors, sub-contractors and others performing
work or services for the Company. A letter was issued to them by the Company

HOW TO IMPLEMENT AN INTEGRITY PROGRAMME

A Guide for MDCEOs/CEOs, PETRONAS Group of Companies

notifying them of the launch of the CoBE and the expectation that they comply
with the relevant parts of the CoBE when performing such work or services
Effective 1 April 2012, a specific provision on Conflict of Interest and Fighting
Corruption and Unethical Practices and Compliance with our CoBE have
been included in PETRONAS contracts with contractors, consultants, agents,
representatives and others performing work or services for or on behalf of
PETRONAS.

4.5. Anti-Bribery and Anti-Corruption Compliance Programme

In November 2012, the PETRONAS Executive Committee, and the Board
Governance and Risk Committee endorsed the PETRONAS Integrity Compliance
Framework. The main objective of the Framework is to instill all elements
related to the propagation of integrity and business ethics amongst all
PETRONAS stakeholders with particular focus given on PETRONAS employees.
It covers three pillars namely the policy; the system and procedures; and, the
people and culture. The Framework also outlines PETRONAS commitment,
to not only inculcate an integrity culture within the Company, but to also
encourage its business partners to combat corruption.

The latest initiative that PETRONAS has embarked on is the Anti-Bribery and
Anti-Corruption Policy and Guidelines Manual, or the PETRONAS ABC
Manual which sets out the Companys stance on zero tolerance pertaining to
bribery and corruption. The manual elaborates upon the integrity principles set
out in the CoBE, providing guidance to employees concerning how to deal with
issues that may arise in the course of day-to day business operations and it
comprises the following topics:

1. Introduction
2. Gift, Entertainment and Corporate Hospitality
3. Dealing with Public Officials
4. Corporate Social Responsibility, Sponsorship and Donations
5. Political Contributions
6. Facilitation Payment
7. Money Laundering
8. Dealing with Third Parties (Due Diligence of Contractors, Suppliers and
Joint Venture Partners)
9. Recruitment of Employees (Background Checks)
10. PETRONAS Whistleblowing Policy

Anti-Bribery and Anti-Corruption training sessions are provided to all

employees to ensure employees are constantly updated and knowledgeable
of the Companys policies as set out in the CoBE as well as the ABC Policy and
Guidelines.

4.6. Whistleblowing Policy and Procedure

On 1 April 2012, PETRONAS Whistleblowing Policy was rolled-out to provide an
avenue for all employees of PETRONAS and members of the public to disclose
any improper conduct in accordance with the procedures as provided under
the policy.

HOW TO IMPLEMENT AN INTEGRITY PROGRAMME

A Guide for MDCEOs/CEOs, PETRONAS Group of Companies

Under the Policy, a whistleblower will be accorded with protection of

confidentiality of identity, to an extent which is reasonably practicable. In
addition, an employee who whistleblows internally will also be protected
against any adverse and detrimental actions for disclosing any improper
conduct committed or about to be committed within PETRONAS, to an extent
which is reasonably practicable, provided that the disclosure is made in
good faith. Such protection is accorded even if the investigation later reveals
that the whistleblower is mistaken as to the facts as well as the rules and
procedures involved.

PETRONAS Whistleblowing Committee was set up in tandem with the Policy

roll out, to deliberate on the disclosure and decide on the next course of
action. The Committee meets at least once a month to discuss the action and
investigation taken on reports. The Committee also provides updates to the
Board.

5. About this BookLET

The How to Implement an Integrity Programme: A Guide for MDs/

CEOs, PETRONAS Group of Companies is a booklet that provides practical
and comprehensive steps that will enable all companies within the PETRONAS
Group to initiate an Integrity Programme in their respective organisations. This
booklet should be read and implemented together with the PETRONAS Shared
Values, PETRONAS Code of Conduct and Business Ethics (CoBE), PETRONAS
Integrity Compliance Framework, and the PETRONAS Anti-Bribery and AntiCorruption Policy and Guidelines.

An Integrity Programme (IP) demonstrates PETRONAS commitment to

ensure that an integrity culture is being adopted extensively in daily business
operations and complies with the relevant laws and regulations.

This booklet sets forth structured approaches through Education and

Awareness; Prevention, and Enhancement.

6. What is an Integrity Programme (IP)?

10

PETRONAS believes that the integration of a high integrity culture into the
corporate responsibility agenda sends a strong message that all organisations
within PETRONAS are responsible to address and manage the organisations
integrity. The IP is a tool that uses structured approaches to manage integrity
in the organisation. The key objective of an IP is to foster high integrity culture
among employees and prevent potential integrity issues in the company.

An IP will be based on the UK Bribery Act 2010 Guidance about procedures

which relevant commercial organisations can put into place to prevent persons
associated with them from acts of bribery (section 9 of the Bribery Act 2010).
The basic principles of an IP are as follows:

HOW TO IMPLEMENT AN INTEGRITY PROGRAMME

A Guide for MDCEOs/CEOs, PETRONAS Group of Companies

Principle 1: Proportionate Procedures to prevent potential integrity issue

which are clear, practical, accessible, effectively implemented

and enforced.

Principle 2: Top Leadership Commitment to fight corruption and foster the

culture of zero tolerance against all form of bribery and

corruption.

Principle 3: Risk Assessment on internal and external factors to identify

potential integrity issues.
Principle 4: Due Diligence in respect of the entities who will perform services

for or on behalf of the company in order to mitigate potential

integrity issues.
Principle 5: Communication and Training to ensure good understanding and

effective implementation of anti-corruption and bribery policy.
Principle 6: Monitoring and review of procedures and integrity programmes

for effective implementation.

7. Why is an Integrity Programme Important?

There are many advantages of having IP in an organisation. Some of the

significant benefits are as follows:
a. The IP will facilitate the Managements initiatives to increase internal
integrity and transparency within the organisation. The implementation
will raise awareness among employees and provide a means of control for
the Management.
b. By having an IP in place, it would constitute an effective tool to be
considered by the Court, in corruption cases that involve the organisation.
The IP can be considered by the Court as a mitigating factor in the
calculation of damages if the organisation has a proper anti-corruption
programme in place.
c. With the IP in place, an organisation can obtain a competitive advantage as
a preferred choice for customers, investors, shareholders, business
partners and the public. This adds value in rating and ranking evaluations
provided by international monitors.

Realising PETRONAS diversified nature of business, different companies

may implement integrity programmes differently to suit its business model.
Implementing integrity programmes in each company and operating units
(OPU) in PETRONAS is a collective action to sustain integrity values and
culture in PETRONAS. Collective action in this context is a matter of collectively
fighting unethical and corrupt practices through the IP. Hence, it is important
that the IP is monitored by an independent unit in the company to ensure that
the integrity system implemented is sufficient and sustained.

HOW TO IMPLEMENT AN INTEGRITY PROGRAMME

A Guide for MDCEOs/CEOs, PETRONAS Group of Companies

11

8. The Roles of Leaders as an IP Champion

PETRONAS believes that leaders must possess high ethics and integrity values.
Demonstration through leadership (top down) that shows leaders commitment
to comply with integrity and anti-corruption policies will make clear to
employees of the emphasis that the organisation attaches to countering
corruption. It also relays the organisations expectations of its employees as
well as the organisations support for employees in carrying out the integrity
programme and in standing up to corrupt demands, even if it may involve loss
of business. Leaders must acknowledge their role in shaping organisational
ethics and seize this opportunity to create a climate that can strengthen the
relationships and reputations on which their companies successes depend.

9. Developing an Integrity Programme

There are several approaches in developing an IP for a company and its design
may vary from one organisation to another. This booklet adopts a standard
approach which can be applied by all businesses within the PETRONAS Group.
Essentially, an effective and efficient IP must be measurable, visible and
implementable.

1
2
3
4
5

5 ANTI-CORRUPTION ELEMENTS
Commitment to promoting values of integrity, transparency and
good governance.
Strengthening internal systems that support corruption
prevention.

Complying with laws, policies and procedures.

Fighting any form of corruption.

Supporting corruption prevention initiatives by the Malaysian

Government and Malaysian Anti-Corruption Commission (MACC)
or other domestic anti-corruption agency.

There are four simple steps to develop an effective and efficient IP.
Set an
Integrity
Commitment
from the Top

12

Conduct an
Integrity Risk
Assessment

HOW TO IMPLEMENT AN INTEGRITY PROGRAMME

A Guide for MDCEOs/CEOs, PETRONAS Group of Companies

Develop an
Integrity
Programme

Review,
Report and
Monitor the
Action Plans

Step 1: Set an Integrity Commitment from the Top

A culture of integrity and compliance in an organisation starts at the top. For

a large organisation such as PETRONAS, setting a climate of integrity must
be astutely echoed by all its Leaders. Hence, the MDs/CEOs should clearly
communicate their stance on fighting corruption to all of their employees.
The organisation must demonstrate this commitment through its public
communications and actions that it will not tolerate corrupt behaviour by
its employees or business partners. This communication is part of creating
awareness and sending a message on how serious the management is about
preventing corruption.
Implementation
Leadership means communicating a clear message, acting with integrity and
leading by example. This includes speaking to employees through various
internal and external channels to convey the message. Communications
include internal memoranda circulated to each employee; a CEOs statement
on the organisations intranet; or keynote speeches from Heads of Business
Units during employee meetings. External communications include an integrity
message from the CEO in corporate publications.

Step 2: Conduct an Integrity Risk Assessment

Risk assessment is the foundation of an Integrity Programme. It is a proactive

approach that allows an organisation to understand and identify the risk
exposure with regards to the organisations business operations. It allows the
organisation to identify structural weaknesses that may facilitate corruption
as well as provide a framework that identify risk factors and measures. An
organisation that fails to mitigate corruption risks may affect the organisations
revenue, culture and reputation.

PETRONAS businesses should take into account their respective business

models and determine the associated risk exposure. An Integrity Risk
Assessment focuses on fraud risk exposure which includes bribery, corruption,
money laundering and criminal conspiracy, among others.

Implementation
Risk assessments for corruption can be simple and high level or, complex and
detailed. A risk assessment looks at business activities, location of business
activities, industries, local business conditions and customs, identifies
corruption risks inherent in those activities, and attempts to estimate the
likelihood of the occurrence of the risks and their impact on the organisation.
Finally and most importantly, the assessment looks for ways and means
to minimise the risks by providing appropriate counter measures. Having
identified the relevant areas of risk, the organisation shall define the need and
develop detailed policies that address the potential areas of corruption.
The best way to carry out this exercise is to organise a workshop comprising
the organisations management team, while HRM, Legal, the Corporate
Security Division, the Internal Audit, and the CIO are parties to be invited to

HOW TO IMPLEMENT AN INTEGRITY PROGRAMME

A Guide for MDCEOs/CEOs, PETRONAS Group of Companies

13

provide input and support in discussions. It is best to analyse past integrity

cases before the workshop begins to observe the trending as well as to
prioritise potential areas for discussion.

Step 3: Develop an Integrity Programme

The Risk Assessment exercise is a platform to develop an Integrity Risk

Management model and an Integrity Programme that suits the business.
Mitigation and preventive measures are to be developed to minimise the risks
identified in the assessment.

Having identified the relevant areas of risk, the organisation shall define the
need and develop the following action plans:
a) Detailed rules, procedures and policies that address the potential areas of
corruption.
b) Appoint a manager to devise, implement, monitor and improve the
programme under the oversight of senior leadership.
c) Provide communication and training to ensure that employees understand
the organisations policies and procedures as well as the leaderships
commitment.
d) Carry out regular reviews of the Integrity Programme including internal
audits, provide reports of results to senior management and the Board and
take necessary actions to improve the programme.

Implementation
An appropriate Integrity Programme should be developed based on the
problem statement identified in the risk assessment exercise. The action
plans should be mapped based on the impact and criticality of the problem to
establish priorities. Then, identify the implementation method and the person
who will carry out the action. It is important to ensure that the statement of
actions is simple, specific and direct to the point to avoid any confusion in the
future. The statement should be understood by all levels of staff at any time.
Remember that this exercise should provide better solutions and should not
clutter current system procedures with another set of hazy statements!

EDUCATION

PREVENTION

ENHANCEMENT

The action plans in the IP should cover three approaches as follows:

i. EDUCATION & AWARENESS PROGRAMME
Develop, plan and implement integrated communication and training
programmes to increase awareness and knowledge of PETRONAS employees,
to better understand integrity management.

14

HOW TO IMPLEMENT AN INTEGRITY PROGRAMME

A Guide for MDCEOs/CEOs, PETRONAS Group of Companies

Examples:
Begin meetings with an Integrity Moment; carry out lecture/tazkirah sessions
or morale programme series; organise Integrity Dialogue sessions with
messages relevant to the targeted audience and tailored to the risks and
needs; invite prominent figures to speak about integrity; conduct refresher
and dialogue sessions on PETRONAS CoBE, anti-bribery and corruption
policies; organise anti-corruption campaigns and use strategic communication
tools such as posters, buntings, website; and participate in voluntary integrity
or anti-corruption initiatives through collaboration with peers or civil society.
Record all activities and measure the effectiveness through employees
behavioural or perception change surveys.

ii. 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.

Examples:
Management can be assigned responsibilities and accountabilities to manage
integrity programmes and carry out the action plans. This includes conducting
yearly integrity risk assessments, planning internal accounting and auditing
procedures aimed at detecting and preventing corruption and to provide
assurance on controls functionality in work manuals and procedures. In
addition, action plans may include structuring training plans to acquire
knowledge and skills from courses such as corruption risk management,
identifying red flag areas, as well as introducing job-rotation in areas prone to
abuse of power and corruption due to familiarisation of functions. Report the
assessment findings and measure the effectiveness of mitigation plans and
programmes.

iii. ENHANCEMENT
This approach emphasises efforts to ensure compliance of Companys
processes, systems, code of ethics and clients charter. It focuses on efforts to
rehabilitate any person or organisation exposed to or are involved in activities
that could tarnish the Companys integrity. It also involves recognising parties
who are committed in upholding PETRONAS integrity.

Examples:
Develop an Effective Integrity Monitoring and Reporting System to evaluate
the design and quality of a system and benchmark to industry standards and
practices by internal and external parties. In addition, assign clear lines of
responsibility and accountability to management in all parts of the organisation
through an appraisal system for effective implementation of the programme
and avoidance of omissions or errors.

Provide reports on the guideline provided to employees and measure

compliance levels among the employees by setting control mechanisms such
as unannounced inspections.

HOW TO IMPLEMENT AN INTEGRITY PROGRAMME

A Guide for MDCEOs/CEOs, PETRONAS Group of Companies

15

 Step 4: Review, Report and Monitor the Action Plans

Monitoring and continuous improvement ensure that strengths and

weaknesses are identified and that the anti-corruption programme remains
effective and up-to-date in addressing changing risks.

Implementation
Monitoring compliance and implementing improvements should largely be
conducted by internal or external auditors, consultants or service providers.
Share the assessment results and other identified improvements across the
organisation to ensure employees know the results and understand how their
role contributes to the success of the programme. Leaders are responsible
to review the identified mitigation plans and monitor any changes made from
time to time. Benchmark the programmes, results and way of implementation
against best practices of peer organisations within the same industry.

10. EXPECTATIONS AND TARGETS

The establishment of an Organisational Integrity Programme is significant

milestone. Nevertheless, the implementation and monitoring of the action
plans will remain a serious challenge, owing to the complex and covert nature
of the issues. Hence, organisations are encouraged to come forward and seek
advice and views on the issues from the Office of the Chief Integrity Officer.
It is important to establish the correct foundation at an early stage to avoid
waste of resources.

In an effort to ensure this initiative remains active, visible and up-to date,
the organisation is encouraged to communicate the progress and
implementation of their respective programmes to the CIOs Office. This
Communication on Progress (COP) serves as a learning tool and an avenue
to express and discuss challenges and opinions on the IP and other relevant
matters.

11. ADDITIONAL REFERENCE AND RESOURCES ON ANTI CORRUPTION PROGRAMMES AND INITIATIVES

Relevant publications on Integrity Programmes as well as Anti-Corruption

Programmes and Initiatives can be found at:
1. Corporate Integrity System Malaysia website (www.cism.my)
2. Transparency International website (www.transparency.org)
3. The United Nations Global Compact: Anti-Corruption Reporting
Guidance
4. Good Practice Guidelines on Conducting Third-Party Due Diligence
(http://www.weforum.org/reports/good-practice-guidelines conducting-third-party-due-diligence)

16

HOW TO IMPLEMENT AN INTEGRITY PROGRAMME

A Guide for MDCEOs/CEOs, PETRONAS Group of Companies

APPENDIX A:

Integrity Risk Assessment Flow Chart

Select
Departments

Conduct analysis on Historical Integrity/Corruption

Cases from HRM, GIA, or MACC.
Set prioritisation on potential areas.

List of
Departments
Activities

List all department activities.

List of
Activities
Output

List of
Problems and
Impact

Preventive
measures

Review

List the output/deliverables of each activities.

List the problems that arise with regards to

corruption.
Impact is either Criminal or Governance and
compromises either quality or time.

Map the impact and criticality of problems to set

priority of action plan.
Identify the unit that will carry out the action plan.
Set up a monitoring system to measure and
communicate progress.

Review the plan periodically.

HOW TO IMPLEMENT AN INTEGRITY PROGRAMME

A Guide for MDCEOs/CEOs, PETRONAS Group of Companies

17

This page has been intentionally left blank.

PETROLIAM NASIONAL BERHAD (PETRONAS) (20076-K)

Office of the Chief Integrity Officer
Level 46, Tower 1, PETRONAS Twin Towers,
Kuala Lumpur City Centre
50088 Kuala Lumpur
Malaysia
D: 603 - 2331 4367 F: 603 - 2331 7050

www.petronas.com

This page has been intentionally left blank.