MSM Malaysia Holdings Berhad Annual Report 2021

Training is provided for staff and suppliers to build awareness and necessary capacity to identify and counter relevant forms of bribery and corruption activities in our business dealings. For new business counterparties, employees must ensure due diligence is conducted to understand the business and background and to determine the origin and destination of money, property, and services as required under the CoBCE. In addition, a Corruption Risk Management (CRM) exercise was conducted for the Group. This is to ensure we continue to identify potential corruption risks in our operations. As defence against corporate liability for corruption offences committed by person associated with MSM, as defined under Section 17A of the MACC Act 2009 (Amendment Act 2018) MSM is putting in place measures as per Guidelines on Adequate Procedures. The performance of our anti-corruption initiatives is reviewed every quarter by our Management, Board Committee and Board. We evaluate the progress and success of our initiatives through a number of channels, including obtaining stakeholder feedback, benchmarking and performance tracking. We pay particular attention to the yearly assessments conducted by corporate governance watchdogs such as the Malaysian Institute of Corporate Governance (MICG) and Minority Shareholders Watch Group (MSWG). The MSM Anti-Bribery Policy Statement is available on the Company’s website at www.msmsugar.com MSM has taken a holistic approach to develop and implement adequate procedures by adopting the following principles (T.R.U.S.T): T Top Level Commitment by Board, Executive Leadership & Management Risk Management through Corruption Risk Management (CRM) Undertake Control Measures via the establishment and review of policies and procedures Training and Communication on Governance, Integrity & Risk education, awareness and periodic communication Systematic Review, Monitoring and Enforcement which includes regular review on performances, efficiency and effectiveness of the anti-corruption programme, and ensure the enforcement R U T S One successful initiative under Anti-Bribery and Anti-Corruptionwas the quicktake up and 100% signing ofthe Integrity Pledge. SUSTAINABILITY JOURNEY HOWWE ARE GOVERNED FINANCIAL STATEMENTS ADDITIONAL INFORMATION 179

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