Integrity & Governance

We will continue to drive transparency, strict adherence to policies and ethical standards, as well as fulfill our commitment to good corporate governance.

Anti-Bribery Management System (ABMS)

Eight companies from PROLINTAS Group of Companies (PROLINTAS) have successfully attained the internationally recognised ISO 37001:2016 certification for its Anti-Bribery Management System (ABMS) from SIRIM QAS. The certification was awarded after a rigorous and comprehensive assessment of the Group’s anti-bribery policies and procedures, and PROLINTAS has met and exceeded the standard’s requirements.

Governance

Among some of the initiatives prepared for the implementation of Section 17A (Corporate Liability) by PROLINTAS Integrity Department:

 

PROLINTAS protects the privacy of all its employees, business partners and consumers. PROLINTAS handles personal data responsibly and in compliance with all applicable privacy laws. This Data Protection (“Policy”) sets out the basis upon which PROLINTAS Group of Companies (“we”, “us” or “our”) may collect, use, disclose or otherwise process personal data of employees and job applicants in accordance with the Personal Data Protection Act (“PDPA”).

PROLINTAS recognises that gift giving is part and parcel of the Malaysian culture. In delivering integrity and good governance in conducting business, PROLINTAS explicitly prohibits personal gifts from either party due to its potential or perceived consequences. Nevertheless, corporate gifts are acceptable if it complies with policies and guidelines set forth in the Integrity Policies and Procedures. PROLINTAS maintains a “No Gift Policy” where personal gifts are concerned.

The Anti-Bribery and Corruption Policy (“ABC Policy” and/or “the Policy”) has been developed as part of the PROLINTAS Anti-Bribery Management System which has been aligned with the requirements set out in the ISO 37001:2016. This Policy is applicable to all PROLINTAS personnel (covering all PROLINTAS employees and the PROLINTAS Group of Companies’ Board of Directors) who would need guidance in dealing with improper solicitation, bribery and other corrupt activities that they may come into contact with during the course of their work for PROLINTAS. PROLINTAS is committed to upholding all laws relevant to countering bribery and corruption in each of the jurisdictions in which it operates.

The existence of conflict of interest poses a significant threat to the high integrity standard that PROLINTAS Group of Companies upholds. PROLINTAS Group of Companies’ personnel should avoid any conflict of interest situation or the perception of such conflicts to protect both the company and the personnel’s reputation. Personnel are prohibited from misusing their position or authority in the company to pursue their private interests.

A facilitation payment is a certain type of payment made to a public or government official that acts as an incentive for the official to complete some action or process expeditiously, to the benefit of the party making the payment. This policy is aligned to the PROLINTAS Anti-Bribery policy and provides procedures to eliminate or control facilitation payments and to ensure that the company complies with anti-corruption laws.

PROLINTAS strictly prohibits staff and directors from soliciting hospitality nor are they allowed to accept hospitality that is excessive, inappropriate, illegal or given in response to, in anticipation of, or to influence a favorable business decision, particularly from parties engaged in a tended or competitive bidding exercise such as contractors, vendors, suppliers and etc.

This code sets out the above standards, which PROLINTAS expects from all suppliers to conform to, as part of their engagement conditions. By signing the S-COC declaration form, the supplier agrees to the terms and principles of the policy. S-COC shall form a part of any contract entered into PROLINTAS with the supplier.

PROLINTAS Group of Companies will engage suppliers to assist in the delivery of services to its customer (supplier or suppliers which shall include the supplier’s staff, agent and representative). And it is important that those suppliers adhere to the standards of behavior and conduct that PROLINTAS expects of its own staff, personnel, management and director (member of PROLINTAS).

Charitable donations are commonly in the form of cash, but can also take the form of real estate, motor vehicles, appreciated securities, clothing and other assets or services. Charitable donations can present a corruption risks as they involve payment made without tangible return and may be used as subterfuge or route for bribery. This policy is to establish a protocol for acts of charitable donations in order to maintain the integrity of the organisation and resist any approaches of bribery through the use of charitable donations.

Sponsorship is the purchase of the right to associate the sponsor’s name and products with the sponsored organisation’s service, product or activity in return for negotiated benefits. Sponsorships unlike charitable contributions are made for business objectives and usually for brand or reputation management purposes. They can present a corruption risk as they involve payments made for services or benefits that are often hard to measure or track. This policy is to establish a protocol for sponsorships in order to maintain the integrity of the organisation and resist any approaches of bribery through the use of sponsorships.

A request made by an influential individual or organisation asking for special privileges to be given to an individual, company or organisation. Support requests are problematic as they give the beneficiary of the support request an un-competitive advantage over its competitors. Further corruption risks arise as the beneficiaries may have offered inducements to the issuers of the support requests. The purpose of this policy is to provide guidance to its users on the appropriate procedures in relation to support requests.

Political contribution is a contribution of gift, subscription, loans, advance, or deposit of money or anything of value, made for any political purpose. It may include any contract, promise, or agreement, gifts of property, services, sponsorship of tables at events, advertising and promotional activities endorsing a political party, express or implied whether or not legally enforceable, any payment by any person, other than a candidate or a political party or affiliated organisation, of compensation for the personal services of another person which are rendered to any candidate or political party or affiliated organisation without charge for any political purpose.

PROLINTAS’ Whistleblower Policy has been established to ensure that a process is available to any individual who, in good faith, wishes to report a concern regarding any accounting, audit, procurement, contract or other violation of Code of Business Ethics and Conduct (CoBE) or other business practices that appears to be illegal, unethical or improper. The whistleblower will be protected from any recrimination, retaliation or harassment, and that the report can be made on a completely confidential basis, submitted directly to Integrity Department. It is the responsibility of all who work at PROLINTAS to bring any illegal, unethical or improper practices to the attention of the management.

Due Diligence is the process to identify and review the legal, financial and corporate position of any new contractors, service providers, business partners, suppliers and any other third parties with whom PROLINTAS Group of Companies (“PROLINTAS”) contemplate or has existing business relations and/ or contracts. The purpose of this Due Diligence Policy and Procedure (“DDPP”) is to ensure that all contemplated and/or existing contractors, service providers, business partners, suppliers and any other third parties are fit and capable of performing their obligations under any contemplated and/or existing contract.

Integrity pact is an agreement between the entity offering the contract and the company / companies bidding for it, that all parties will abstain from bribery, collusion and other corrupt practices in the period leading up to the award and during the contracting period. The purpose of this policy is to provide guidance to its users on the appropriate procedures when implementing integrity pacts in procurement and contracting.

Integrity Enhancement

Integrity Enhancement

Integrity knowledge and awareness must be continuously enhanced, refreshed, reinforced and communicated to all PROLINTAS employees as well as business partners to ensure integrity and governance objectives can be fulfilled.

Detection & Verification

Detection & Verification

This function is responsible to detect and verify complaints on potential misconduct and violation of code of conduct and ethics (CoBE), (S-COC), Anti-Bribery Policy, and to ensure that appropriate follow-up actions are taken.

Compliance

Compliance

An effective integrity and compliance program for PROLINTAS is designed to support and guide the business towards making decisions aligned with the mission, vision and values of the organisation as well as the major compliance risks and regulations governing it.

Disciplinary

Disciplinary

Integrity Department will take necessary punitive actions against employees who do not comply with or breach any of the policies especially in managing ethical conduct, integrity and anti-corruption measures.

Complaints Management

Complaints management addresses all complaints/information of criminal misconduct and violations of the code of conduct and ethics in the organisation. Integrity Department (“ID”) officers are responsible for the efficiency of the Complaints Management system.

whistleblower@prolintas.com.my
03-21642450

Integrity Department
Projek Lintasan Kota Holdings Sdn Bhd
Peti 2, Tingkat 21, Menara PNB
201-A, Jalan Tun Razak
50400 Kuala Lumpur.

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