Manager, Integrity Management

Job Purpose

• Manage and drive the implementation of the Group's Organisational Anti-Corruption Plan ("OACP") and its related policies and programs.
• Lead and/or assist in investigation into Bribery and Corrupt allegations.
• Anti Bribery and Corruption trainer.
• Being the key liaison person with regulators such as MACC.

Job Responsibilities

• Integrity Related Policies and Procedures
• Manage, maintain and keep up to date the following key Anti Bribery and Corruption ("ABC") policies and programs:
• ABC Policy, procedures and systems.
• Gift, Travel and Entertainment policy procedures and systems.
• Sponsorship and Donation procedures and systems.
• Whistleblowing policies procedures and systems.
• Any other ABC related policies, procedures and systems.

On a periodic basis, review and propose any improvement to both policies, procedures, processes and systems to keep the program up to date with regulatory requirements, good practices and relevant to the business operation.

Develop, lead and provide the necessary training, briefing employees and identified external stakeholders to ensure a better understanding of the importance of ethical behavior and compliance with relevant ABC policies and standards.

• OACP
• Execute the approved Group's OACP plans and programs as planned.
• Work with other internal and external stakeholders to ensure the objectives of each OACP plan is achieved.
• Escalate issue(s) related to the OACP implementation to Head of Corporate Compliance & Integrity ("HCCI") and Chief Risk, Integrity Officer ("CRICO").
• Provide the necessary report (status or otherwise) on the progress of the implementation plans.
• Assist and provide the necessary feedback in the preparation of updated OACP plans as and when they fall due.

• ABC Risk Management
• Manage and keep the ABC risk assessment methodology of the Group updated with good standards applicable.
• Assist and manage in the ABC risk assessment on new product and operational areas of the Group.
• Review and provide the necessary challenge to the ABC risk assessed by business units and support functions of the Group (including those reported periodically to the Group).
• For key corruption risk of the Group, periodically assess the effectiveness of the mitigation controls.
• Update the risk assessment due to changes in the Group operations and/or introduction of new products or access to new territory, where applicable.
• Prepare the necessary ABC risk report as required for Management and/or Board review.

• Whistleblowing ("WB") management
• Manage the whistleblowing framework and program for the Group.
• Keep the whistleblowing program and process up to date with good practices, applicable regulations. Ensure the updated process is relevant and effective for Group's wide implementation.
• Assist Group Corporate Assurance ("GCA") on the operationalization of the whistleblowing tools and systems, where required.
• Highlight any issues and/or improvement required of the WB process.

• Investigation into allegation of Bribery and Corruption
• Lead/assist in the investigation into allegations of bribery and corruption (as received by the Group).
• Work with GCA on investigation, including coordination with internal and external legal advisors, where required.
• Prepare the necessary investigation report.
• Liaise with the relevant authority (e.g., MACC) where required.

• Regulator/MACC Liaison
• Act as the key liaison person with regulator/MACC.
• Prepare the necessary IGU reports that will be submitted to MACC for internal review and approval.

• Best Practice Management
• Stay informed about current integrity/ABC risks, emerging trends, and best practices within the industry.
• Conduct research and analysis of external developments related to integrity risks (e.g., ethical misconduct, regulatory changes, whistleblower protections) and provide insights to the CRICO, HCCI or other management as needed.

• Reporting
• Prepare and provide the necessary ABC and other reports for HCCI and CRICO review.

• Other functions (department role)
• Assist the HCCI and CRICO in the delivery of key mandates, objectives according to GCO annual plan / the Group's OACP / KPI.
• Provide regular and timely updates to HCCI and CRICO on the status of ABC programs and tasks undertaken, ensuring all work is progressing in line with expectations.
• Oversee and support team members (if any) involved in ABC programs, ensuring that they execute their tasks objectively and independently. Ensure assignments are carried out effectively, with high standards of quality, consistency, and thoroughness in reporting of all review issues and recommendations.
• Provide necessary information, assistance, and coordination with other team members in Risk and Compliance to ensure that the department programs are executed in a timely and efficient manner.
• Assist the HCCI and CRICO in establishing and maintaining clear working relationships with operational teams to ensure there is no overlap or duplication of functions and responsibilities in managing integrity risks, ethical compliance, and internal controls.
• Perform other duties as assigned, when required.

Education/ Professional Qualification

• Possess at least a Professional Degree/Certificate, Bachelor's Degree, Post Graduate Diploma, Diploma, Advanced/Higher/Graduate Diploma.
• Legal/Regulatory, Risk, Governance and Audit related education will be an added advantage.

Professional Experience

• At least 10 years of relevant work experience in positions related to integrity management, enforcement, or anti-corruption, with a strong background in investigating, and managing corruption risks and ethical violations.
• Experience in dealing with various levels of internal and external stakeholders.
• Experience in law enforcement or regulatory bodies, such as the Malaysian Anti-Corruption Commission (MACC), will be an added advantage.
• Ability to work well independently and in a team environment.