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INTEGRITY - Coggle Diagram

- - - - Applies to all employees
      - Employees MUST NOT
        
        Offer
        
        Solicit
        
        Give
        
        Accept
      - Declare gifts
        
        above RM 500
        
        declare in the register of Gifts app (required PGCE approval)
        
        below RM500
        
        no action required
    - - 2.Company-to-company exchange
      - 3.Official event gifts
      - 1.Festive gifts/ hampers
      - 4.Gifts as nominee director
      - 5.Guest speaker tokens
      - 6.Branded company/ event items
    - - 1.Cash or cash equivalents
      - 2.Valuable items & gratuity
      - 3.Rebates
      - 4.Interest
      - 5.Entertainment, social events, vacation, leisure treatment
      - 6.Free/ sponsored travel, trips & holidays
      - 7.Loan and debt settlement
    - - new-RM 500 old-RM100
    - - Allowed to give/accept
      - No need for approval & declaration
      - Under permissible conditions
        
        5.Supports business interest
        
        6.Refusal/Decline - cause offence
        
        3.Reasonable & work related
        
        7.No conflict of interest
        
        2.Not solicited
        
        9.Does not harm PNB reputation
        
        1.Infrequent
        
        4.Given in good faith
        
        8.No appearance of preferential treatment
  - - - 1.Solicitation, accepting or giving bribe or any illegal gratification
      - 2.Fraud, dishonesty, cheating, falsification
      - 3.Wrongdoings
      - 4.Conflict of interest
      - 4.Any violation of established policies and procedures
    - - 1.Email to CIgO
      - 2.Email to Chairman of BCC
      - 3.Dedicated phone line
      - 4.Whistleblowing form through PNB Websites
    - - Lodgement by Whistleblower
      - Recording & Registration
      - Screening Process
      - Deliberation & Consent
      - Reporting to Relevant Authorities
    - - Details of misconduct
        
        What happen
        
        When
        
        Where
        
        How
      - Person involved
        
        Name
        
        Position
        
        Department
      - Supporting Evidence
- - - - 5.Avoid favoritism and nepotism
      - 4.No false claims / declarations
      - 3.No forgery and making false documents
      - 2.Reduce / avoid the misuse of power
      - 1.Not to give / offer bribery
  - - - STAGE 1 :Sign off - during report duty
        
        Responsible party : New/each employee
      - STAGE 2 : Yearly Renewal
        
        Responsible party : Employees of 13 identifies BUs
    - - STAGE1 : Sign off - during appointment as Member
        
        Responsible party : PNB BOD/ Investment/ Tender/ Procurement Committees/ Company Secretary/ Secretariat
    - - STAGE 1 : Sign of - during registration as PNB suppliers /PSP
      - STAGE 2: Upon renewal of registration
      - STAGE 3 : Upon submission of tender/ quotation document by bidder
      - STAGE4 : Upon issuance of LOA
- - - - Top Level Commitment
        
        Maintain and periodically review the level of compliance with Guidelines by Securities Commission
        
        Maintain and periodically review PNB Stewardship and Sustainability Framework
        
        Review Integrity Charter and Framework
        
        Maintain periodically review ABC policies
        
        Implement adequate procedure ABMS programme
        
        Held regular structures training and awareness programme
        
        Ensure Integrity Representatives with stipulated functions in jobs descriptions
      - Risk Assessment
        
        Conduct Annual Review of Corruption Risk Assessment via Enterprise Risk Management System
        
        Establish a system procedure (SOP) for annual assessment of CRM
        
        Report result of CRM with action plans included
        
        Execute necessary evaluation process on relevant business proposals via due diligence process
      - Undertake Control Measures
        
        Conduct due diligence using established format on relevant parties : new hires, BOD, suppliers, contractors
        
        Monitor and take appropriate action on submitted complaints
        
        Continuously review Whistleblowing Policy
        
        Execute various integrity declarations for the execution of respective stakeholders
        
        Monitor and review Employees Handbook
        
        Monitor and review the training needs and awareness programme for staff members
        
        Conduct regular monitoring and revies the performance of ASNB agents via established scorecard
      - Systematic Review, Monitoring and Enforcement
        
        Monitor all business units on adoption of necessary initiatives
        
        Ensure review of Anti-Corruption programme are conducted regularly
        
        Ensure the review conducted by qualified and independent party
        
        Execute consequence management framework on staff that are found to be non compliant.
      - Training & Communication
        
        Conduct Integrity awareness programme for BOD, employees, business associates on ABC policies via :
        
        K-HUB
        
        Survey & quizzes
        
        Corporate training programme , seminar & in-house courses
        
        Induction (new hire)
        
        IRAC week
        
        Execute Integrity training module for all employees
        
        Collaborate with other organisations within PNB investee companies to increase integrity awareness
        
        Send consistent and frequent reminders to all employees via email blasts
        
        Communicate ABC policies to business associates to emphasized on PNB stand on cultivating culture of integrity
- - - - Performance Monitoring
      - Real Estate Investment
      - Trading & Dealing
      - Portfolio Construction
      - Investment Strategy
      - Other Related Activities
      - Investment Analysis
  - - - Board Level Committee
      - Management Level Committee
  - - - Corruption Risk Register
    - - OACP
  - - - ABMS Internal Audit Report
      - Integrity Review Report
- - - - 2018
        
        Establishment of IGU unit in GLCs, company owned by government
        
        Supervision by BPIA
        
        Submission of semi annual report to MACC
      - 2022
        
        Declaration asset
        
        by GLC, GLIC heads and chiefs
    - - 2.Transparency
        
        Establishment of an Independent Committee
      - 3.Initiatives
        
        2.Organisational Anti-Corruption Plan (OACP)
        
        3.Referral Policy
        
        1.Capacity & Capability Building
        
        Mandatory Training
        
        Certified Integrity Officer (CeIO)
        
        Recommended Certification Programme
        
        ISO 37001:2016 ABMS
        
        4.Whistle Blower Policy & Protection
        
        5.Internal Control & Compliance System
        
        6.Integrity Pact for Business Operation
        
        7.Code of Business Ethics
      - 1.Infrastructure
        
        Core functions of IGU
        
        Annual Budgeting
        
        Establishment of IGU
        
        Manpower & Resources of IGU
      - 4.Reporting : Dedicated Annual Report
    - - Implementation Mechanism for IGU
        
        3.Appointment of IGO
        
        4.Capacity Building for IGO
        
        5.CeIO Programme
        
        2.Organisational Risk Rating
        
        1.Network of Integrity & Governance Management
        
        6.Reporting by IGU
      - Core Functions of IGU
      - Role of Implementor
        
        2.CIGO
        
        3.Integrity and Governance Officer
        
        4.Head of Organisation
        
        5.Independent Committees
        
        1.Bahagian Pengurusan Integriti Agensi (BPIA)
        
        6.Board of Directors
    - - 5 Principles (T.R.U.S.T)
        
        1.Top Level Commitment
        
        2.Risk Assessment
        
        3.Undertake Control Measures
        
        4.Systematic, Review, Monitoring & Enforcement
        
        5.Training & Communication
  - - - 1.Leadership Engagement
      - 2.Integrity Culture
      - 3.Training & Communication
    - - 1.Corruption risk assessment
      - 2.Corruption risk management
      - 3.Corruption risk monitoring
      - 4.Integrity reporting
      - 5.Integrity governance
  - - - 2.Detection and Verification
      - Integrity Strengthening
      - 1.Complaints Management
      - Governance
    - - Internal
        
        Board Compliance Committee of PNB Group
        
        Quarterly
        
        What we report
        
        OACP Status
        
        Advisory, EDD & eSTK
        
        Activities of the 4 Core Functions of IGU
        
        Integrity Strengthening
        
        2.Detection & Verification
        
        Integrity Governance
        
        Complaints Management
        
        ABMS Updates
        
        5.Integrity Review
      - External
        
        Semi-Annual Reporting to MACC
- - - - Disciplinary action : termination
    - - Removal from panel, withdrawal of business
      - Blacklisting
      - Termination / suspension / discontinuation
  - - - Integrity, diligence, care & professionalism
      - Discrimination & harassment
      - Safe & sound working environment
      - Communication & social media policy
      - Dealing with confidential information
      - Strict prohibition of substance abuse
    - - Our stand against corruption
      - No Gift policy
      - Hospitality & entertainment
      - Political contributions
      - Managing clients' assets & information
    - - Due diligence on third parties
      - Protection of PNB Group's assets
      - Avoidance of conflict of interest
      - CSR, donation & sponsorship
      - Dealings with public officials
      - AMLA