Reporting to Internal Stakeholders
Reporting to various internal stakeholders within the Bank is required, which include the Group Management Governance and Compliance Committee (“GMGCC”), Risk Management Committee (“RMC”) and the Board of Directors ("BOD") of respective Banking entities. Matters to be reported to the internal stakeholders should include the following:
- Any significant bribery and corrupt practices related matters that increase the bribery and corrupt practices risk exposure to the Bank;
- Any reputational and regulatory compliance issues relating to bribery and corrupt practices risk exposure to the Bank;
- Decisions pertaining to significant/material bribery and corruption matters;
- Significant weakness in, internal controls due diligence, monitoring, detection and audit processes and issues noted in the Bank that relates to bribery and corrupt practices matters and remedial actions to rectify them.
Reporting to Relevant Law Enforcement Agency
The Bank may be required to report any concerns to MACC and BNM upon detection of any bribery or corruption activities.