ENHANCING COOPERATION AM ONG SECTORS IN CORRUPTIONPREVENTION STRATEGY:M ALAYSIAN EXPERINCE
DatoʼAbdul Wahab Bin Abdul Aziz

I. INTRODUCTION
The M alaysian Anti-Corruption Commission (MACC)has been in operation since the inception of
the Malaysian Anti-Corruption Act 2009 incorporated in the Laws of Malaysia Act 694 on the 8th ofJanuary 2009. Amongst the important provisions of the Act, under Section (7), being the functions ofofficers ofthe Commission,sub-section (c),(d)and (e)have been emphasised as,among other provisions,best practices and good governance.The said provisions mentioned specifically and categorically are
as follows:(c)to examine the practices, systems and procedures of public bodies in order to facilitate thediscovery of offences under this Act and to secure the revision of such practices, systems orprocedures as in the opinion of the Chief Commissioner may be conducive to corruption;(d)to instruct,advise and assist anyperson,on the latterʼs request,on ways in which corruption may
be eliminated by such person;(e)to advise heads of public bodies of any changes in practises,systems or procedures compatible
with the effective discharge of the duties of the public bodies as the Chief Commissioner thinks
necessary to reduce the likelihood of the occurence of corruption.
Having said that,the priority of the M alaysian Government is to promote good governance and bestpractises as the way forward in its agenda for a corruption free public and private environment. Big
conglomerates in the private sector who are actively trading in worldwide businesses suffer the wrathof corruption mostly,at least. As mentioned by Arvis and Berenbeim,the fact that corruption hinders
the development of the private sector is now widely accepted,to the point that many practitioners tend
to rank it as one of the most serious obstacles to business.
The M ACC is gigantically tasked with the minimization and,if possible,the total eradication of thedisease. Though a herculean and mammoth assignment, the war against corruption is a never ending
one.A top down or bottom up approach1 has to be adapted and adopted,depending on the level of thegovernmentʼ
s role, public awareness, freedom of the press and civil society. As for M alaysia, a top
down approach has been deployed to combat corruption.The level of print mediaʼ
s independence alsosays a lot about the strategy to be deployed against such a plague of unheard of or untold ofmagnitudinal scale.Many strategies have been deployed to combat corruption.Many more approaches
have been devised to eradicate bribery, the abuse of power, and deviations. M uch has been said anddone to address the said scourge,yet much more needs to be done to arrest this particular disease.This
menace has occurred since time immemorial.This scourge has often been seen and heard as a cancer
in society, be it in the first or third world countries. It spreads even faster in underdeveloped anddeveloping countries because the civil society and the populace face poverty and illiteracy, among
others.
Though these steps and measures involves massive operations and task forces,the real art of war
Director of the M alaysia Anti Corruption Academy (M ACA).
1Top down approach refers to governments playing the dominant role in fighting corruption whereas bottom up approachrefers to press freedom and civil society leading the war against corruption.Third world countries usually have top down
compared to first world countries adopting bottom up approach in the war against corruption.

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against corruption must certainly be grabbing the bull by its horns. Preventive measures are themeasurables of combating corruption in the twenty-first century. The old adage that prevention isbetter than cure is relevent and applicable in the present decade.This mode of operation is the in-thing
and the in situ typology.Being less messy and more desireable,this paradigm shift has been focussed
as the ideal weapon for the war against corruption. It has now widely accepted that corruption has
negative economic consequences (Hunt, Jennifer & Laszlo, Sonia:2005).
The MACC has a logo portraying captions of Fairness, Firmness and Trustworthyness. In simple
terms,the M ACC practices a culture of acting without fear or favour.The M ACC is also colour blind.
It pays no respect to social issues of colour,creed and culture.Being impartial,unbiased and unprejudiced has always been the utmost top criteria for the MACC in achieving its objectives and goals. It
has an unfair advantage over public and private entities in the sense that its services and goods are free,soverign and independent. However, more often than not, a public official usually abuses his public
position for private gain.2 Part and parcel to its priority in its tasks is the Corporate Integrity Pledge(CIP).
The meanings of the three key words have to be crystal clear and precise so as to further add value
to the value chain as well as innovate the very idea of a CIP. According to the Oxford Dictionary,“corporate”refers to the image of a company.Integrity has a far-fetched interpretation in having thequality of being honest and having strong moral principles.3 Among the necessary tenets of integrity
are openness, good governance,accountability and transparency.Some observers have equated integrity to being perfect and sound values.Others have even associated integrity with holy and godly.As
for the pledge,it refers to a promise or undertaking.These connotations have to be adhered to strictly
and sincerely.

II. WHAT IS A CIP?
The CIP is a document that allows a corporate entity in Malaysia to show their commitment insupporting the principles of corruption prevention. It is a statement (documented) by a company
voluntarily committing itself to uphold the Anti-Corruption Principles for Corporations. Hence, thesaid company which signs the pledge is making a unilateral declaration, amongst others:a) Will refrain from all forms of corrupt activities,meaning to say it will not commit corrupt actsb) Will work towards creating a business environment that is free from corruption.
c) Last but not least,it will uphold the Anti-Corruption Principles for Corporations in the conductof its business and in its interactions with its business and its interactions with its business
partners and the Government.
The initial originator of the CIP was the M ACC. It was the brainchild of a M inister in the Prime
M inisterʼs Department, the Right Honourable DatoʼIdris Jala4 who suggested that the M ACC spearhead the movement.He was personally brought into the Malaysian Cabinet by the Honourable Prime
M inister Dato SriʼM ohd Najib bin Tun Abdul Razak to enhance the performance ofgovernment-linked
companies which were in the red. The M ACC was made the custodian of the CIP in M arch 2011 andlater passed the baton to the Malaysian Institute of Integrity(IIM )who later on involved Transparency
International-Malaysian Chapter (TI-),Companies Corporation M alaysia (CCM),National Key Result
Areas (NKRA), Performance Management and Delivery Unit (PEMANDU), Securities Commission(SC)and M alaysian Stock Market (Bursa M alaysia).

2Official definition of corruption of the World Bank.
3Oxford Advanced Learnerʼ
s Dictionary, Eighth Edition:2010.
4He has served internationally and brought the last organization Shell M alaysia Berhad to greater heights and astronomi-

cal achievements. He has also transformed the M alaysian Airlines System and brought it to being a profitable entity.

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III. WHY SIGN THE CIP?
A. Effects/Benefitsa) A company will be making a clear stand of how it operates.This will be locked down in writing.
It is stating a bold statement on its vision and mission and its anti-corruption stance in its
business codes of conduct and ethics. Do the due diligence on them. Never instruct them to do
whatever it takes to get the job done. Horowitz, Bruce:2007).
b) It will encourage a company to work on their own anti-corruption programme and internal
systems and processes.This will be a guidance to the companyin its business interactions,should
it be faced with the possibility of condoning any payments or other activities that would amountto corruption.
c) It will certainly have a positive impact whereby increasing the level of confidence for domestic
and foreign investment.
d) A company can use this Pledge to set itself apart from its peers.It demonstrates that its business
operations do not include any hidden risks or costs that are associated with corrupt activities.
Ira Belkin,former China Legal Exchange Officer for the U.S.Department of Justice,took a hard
stand, saying there is never any justification of breaking the law. He said even if bribes are astandard way of doing business, you donʼt want to be the one person caught and prosecuted.
(Silverthorne, Sean:2005)
To sum up,the main objectives are achieving a zero tolerance for corruption as well as enhancing
integrity and formulating a corruption prevention programme. This dual approach has far reaching
aspirations and far-sighted, holistic approaches to put corruption in check as far as the business
community is concerned.
Having indulged in the above cost benefits and causal reltionships between the CIP signatories andthe MACC, the Anti-Corruption Principles for Corporations in Malaysia are as below:i)

It commits to promoting values of integrity, transparency and good governance.

ii) It strengthens internal systems, that support corruption prevention. The law should requireinterested directors to abstain from voting on transactions in which they have an interest.5(M cGee, Robert W:2009)iii) It complies with laws, policies and procedures related to fighting corruption.
iv) It fights all and any form of corruption.
v) It supports corruption prevention initiatives by the Malaysian Government and the MACC.

IV. HOW THE CIP IS PRINCIPLED?
i.

The first step is the signing of the pledge. The said companies sign the respective pledges attheir premises with the MACC. The pledge is a standard document with its respective anticorruption initiatives.

ii. Then,the companies work to self-assess their strength of their corporate integrity system.The
CIP ensures the level of corporate governance in place within the said companies.The company
also identifies an action plan to strengthen their internal systems. This is the self-assessment
stage.

5For a full report on Corporate Governance in Developing Economies of Africa, Asia and Latin America, see M cGee,

Robert W:2009 which incluides a case study on Malaysia.

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iii. The next stage of implementation is to close the relevent gaps.The action plans are implemented immediately by the company concerned. The said companies also adopt and adapt anticorruption business principles. The cases of corruption reported by the media tend almost
always to involve a private party (a citizen or a corporation) that pays or promises to pay,money to a public party (a politician or a public official, for example) in order to obtain anadvantage or avoid a disadvantage (Argandona, Antonio: 2003). These companies have toestablish infrastructure:Governance and Ethics Board Committee.Needless to say,conducting
training also has to be in the basket of deliverables.
iv. Finally,they have to do the necessary reporting which includes anti-corruption elements in theaudits. Companies also have to include reporting on anti-corruption measures in their annual
reports.
However it has to be borne in mind that however the CIP is principled,the syndrome of corruption
is a fact of life for all continents around the globe.Not onlydeveloped countries suffer from the various
syndromes of corruption,the developing,lesser developed and least developed countries also suffer inthese aspects of corruption. Johnston, M:2005 has categorised all the nations said above as having
characteristics and features clustered as elite cartels as the U.S, Germany and Japan, elite cartels as
South Korea, Italy and Botswana, oligarchs and clans as in the Phillipines and Malaysia and official
moguls as in Indonesia, China and Uganda.
The author has provided statistics and data for his illustrious work for classifying these countries
categorically.His book has been discussed widely and in indepth by Professor Nikos Passas on North
Eastern University,U.S.and Professor Claudia Baez Camargo of the Basel Institute of Governance for
the M ACS 2012-2014 programme at the United Nation Office of Drugs and Crimes in Vienna,Austria.

V. WHEN AND WHERE IS THE CIP M ONITOREDThe CIP is monitored annually.The Officers from the Consultancy Division make yearly checks onthese companies to ensure that the anti-corruption elements have been inculcated in their audit andaccoutancy procedures. These companies also have to report on latest and recent anti-corruption
initiatives as part of their ongonig anti-corruiption efforts.Theyalso have periodic pledge synchronization meetings to discuss their latest role play in absorbing new and innovative ideas for their existence.
Lastly,they too need to enclose implemented anti-corruption initiatives in their annual reports.Though
there is much global corporate governance,they too adopt best practises and good governance as a tool
to move forward.
The United States and Britain had adopted a shareholder-centric model of corporate governance(often referred to as the Anglo Saxon model).The Germans along with several other European nations,adopted a stakeholder-centric model of governance. The Japanese model was built around business
relationships, with Japanese banks, customers, and suppliers all influencing board-level decisions(Larcker, David F &Tayan, Brian:2007).

VI. TRAINING ASPECTS
Several training programmes and sessions have been introduced by the M alaysian Anti-Corruption
Academy to further enhance the Integrity Awareness Programme., being the Generic module andspecific module.There are also eight (8)integrity initiatives which have to be adhered to and compliedwith strictly so as to make the CIP and Certified Integrity officers to function effectively and efficiently. There is also an Ingrity Pact (IP) introduced to the companies who are engaged in procurement
activities with mostly government, non-government and government-linked companies.
The difference in the IP is that it is legally binding on the companies which provide goods,services
and supplies to the said companies.They may be barred,or suspended or blacklisted if they are known
or found guiltyofcorruption in service contracts,supplywhich involve these said agencies.An example
is Alcatel-Lucent SA which has been debarred for a certain time period from supplying and providing
services.

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M ACA is also being tasked to handle training for the Certified Integrity Officers (CeIO) for theprivate sector and public sector. The programme components for the CeIO introduce extensively theconcept of integrity, the practice of integrity, ethical compliance and monitoring as well as theformation and formulation of an Integrity Plan for their respestive departments. As far as learning
objectives are concerned, the CeIO, at the end of the programme will have had the opportunity to:i.

Plan effectively and make an accurate decision on any question or concerning integrity.

ii. Apply the integrity concepts, directly and effectively to the organizationʼ
s daily operations.
iii. Analyse methodologies for identifying, understanding, handling and response action.
The Corporate Integrity Development Centre (CIDC) has been tasked for such deliverables. The
participants have been tasked with managing their departmentʼ
s Integrity Plan and Code of Ethics/
Conduct which were not practised previously. MACA, with its CIDC has been accredited with thissuccess. The honourable Prime Minister of Malaysia has a personal hand on this programme.
The CeIO programme has been seen as attaining the aspirations as well as the accomplishing of thevision and mission of Malaysia to see a corrupt free country for the present generation and the future.
The event for international CeIOʼ
s on 21 October to 1 November 2013 is testimonial for the success of
the CeIO programme as it has gained recognition globallyas a milestone in the fight against corruption.
As such,M alaysia is a front runner and innovator in this field of adding value to the value chain in thefight against corruption.However it is just a first and foremost step for M alaysia but a giant quantum
leap for mankind.

VII. SUCCESS STORIES
Among the multinational conglomerates in Malaysia,and to name a few among the many,Tenaga
Nasional Berhad,Telekom M alaysia Berhad,Bank Islam Berhad and M alayan Banking Berhad havetaken bold and brave steps to make their signatures on a corrupt-free private, business environment.
Up to June 2013,the CIDC has churned out 115 Certified Integrity Officers from 39 private entities and
52 government agencies.
From the 39 private entities that have participated in the CeIO programme,a few of these agencies
too have signed the CIP and the Integrity Pact (IP).This,in turn,spearheads a positive momentum inthe fight against corruption.These particular individuals will inculcate and promote positve values in
integrity within their respective organizations.
Thereby,awareness in anti-corruption strategies is intact in these organizations so as to propel thebattle against corruption. Beginning from 1st August 2013, according to government circular number
6 of 2013, every government department has to have a mandatory Certified Integrity Officer who has
been trained by the MACA. The integrity unit in the government departments have been tasked topromote good values of integrity amongst their staff.
The Certified Integrity Officer also has to instil good governance among its staff,sustain integrity
through the office culture, and execute integrity tenets and principles in the said organizations. The
other said duties are the detection and confirmation of corrupt practises amongst staff as well as
revealing different breaches of crime to the relevent law enforcement agencies.
Also,the tasks include internal complaints administration against their own staff,compliance withlocal laws, rules and regulations besides tackling all forms of disciplinary problems amongst staff.
M ost of the initiatives to counter corruption have been in place since the inception of the CeIO and CIP.
Hence to be a world player in eradiocating corruption,the fight must be an ongoing one and a fightwhich is never yielding or surrendering. If for a single instance, we are caught off guard, that willundoubtedly be the ultimate downfall against the fight. Since the benchmarking has already been set
with high standards of integrity, the guard and fight against corruption must be ongoing without fail174

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or faulter.

VIII. CHALLENGESM ACA,and the CIDC,being the training arm against corruption as far as the CeIO is concerned,has
to nurture the cooperation of all concerned in the battle against corruption. The battle against
corruption might be won today,tomorrow,the day after tomorrow,next week or the following,but thelong war against corruption is a never ending one which requires persistence,efficacy and determination from all parties,especially from the bureaucracy to the politicians until civil society to the very
grassroots.
Each and every individual, organisation or corporation has to make positive contributions if the
war against corruption is to move forward rhythmically and forcefully. The momentum or drive
against corruption has to encompass all levels of society if it is to be a winner. The war against
corruption is anything but near an end. The fight against corruption is never over. The push against
corruption to eradicate it is but a dream.The journey to minimize corruption has to be a holistic one
yet empowering professionals to combat it on uphill terrain.

IX. CONCLUSION
A total of 284 companies have signed the CIP in Malaysia as of September 2013.Along with the CIP,
these companies have also undergone the Certified Integrity Officerʼ
s course which has nurtured themwith the necessary competencies in integrity, compliance, ethics, responsibility, conduct, governanceand also honesty.As Ntim & Soobaroyenʼ
s findings reveal,“
on average,better governed corporationsare (statistically significantly)more likely to pursue a more socially responsible agenda”as measured
by disclosure about specific CSR initiatives.Thereby,the CIP is definitely a step forward in enhancing
the integrity of a corporation.
Bibligraphy
Books
1. Campos, J.E.,& Pradhan. S, 2007:The many faces of corruption, Washington DC:World Bank.
2. Haller, D & Shore, C, 2005:Corruption, London:Pluto Press.
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University Press.
4. Klitgaard, R, Ronald Maclean Abaroa and H. Lindsey Parris, 2000: Corrupt Cities, ICP Press,
Washington D.C:World Bank Institute.
5. Klitgaard, R, 1990:Tropical Gangsters, USA:Perseus Books Group.
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7. Rose-Ackerman, S, 1999:Corruption and Government, New York:Cambridge University Press.
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10.Wain, B, 2009:Malaysian Maverick Mahathir Mohamad in Turbulent Times, UK:Macmillan.
11.W. McGee, R., 2009:Corporate Governance in Developing Economies, USA:Springer

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Annual Publications
1. Corruption Perception Index 1995-2012:Berlin:Transparency International.
Articles1. Arvis, J.F. & Berenbeim, R.E. Fighting Corruption in East Asia 2003: Solutions from the Private
Sector, Washington, D.C:World Bank.
2. Argandona, A., Private-to-Private Corruption, 2003, M adrid:IESE Business School.
3. Freeman,R.E.& M cVea,J,2002:A Stakeholder Approach to Strategic Management,USA:Universityof Virginia.
4. Friedman, M, 1970:The Social Responsibility of Business is to increase its profits, USA:The New
York Times M agazine.
5. Horowitz, B, Negotiating with extortionist government functionaries, 2007 Ecuador:Trace International.
6. Horowitz, B, Bridge Ogres, Little Fishes and Positive Deviants, 2006 Ecuador:Diplomate Thesis.
7. Hunt,J & Laszlo,S,Bribery: Who pays, Who refuses, What are the payoffs?,2005,US:NBER working
paper series.
8. Jensen, M.C., Value maximixation, Stakeholder theory, and the Corporate Objective Function, 2001,
US:Harvard Business School and Dartsmouth College.
9. Larcker,D.F.& Tayan,B.,Models of Corporate Governance: Whoʼs the fairest of them all?,2008 US;
Stanford Graduate School of Business
Statutes/Directives
1. M alaysian Anti-Corruption Commission Act, 2009
2. M alaysian Anti-Corruption Commission website: http://www.sprm.gov.my/>.
3. Government of M alaysia Service Circular Number 6 of 2013 on formation of an Integrity Unit in all
government agencies.
4. Government of M alaysia as Prime Ministerʼs directive Number 1 of 2011 on Certified Integrity
Officer programme.

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