39 SUSTAINABILITY REPORT 2018/2019 02 S E C T I O N GRI 205-3 CORPORATE INTEGRITY FGV has established and implemented policies on the following: Anti-Bribery Policy Statement Whistleblowing Referral Asset/Personal Interest Declaration (APID) External Gift, Entertainment and Hospitality (GEH) Conflict of Interest Sponsorship & Donation Management of Classified Documents Code of Business Conduct and Ethics for Employees (CoBCE) CORPORATE GOVERNANCE FGV is committed to adhering to the highest standards of ethical conduct and integrity in all our business activities. We have in place a number of policies and plans that communicate our principles on bribery, gifting, corruption, code of conduct and integrity, all of which can be found on FGV’s website. We continually work to inculcate a culture of integrity through awareness programmes, training workshops and integrity clinics that focus on good governance and anti-corruption. Our Corruption Risk Management (CRM) system continuously tracks and checks our operations for corruption risks. Our CRM is reviewed twice a year to ensure that it is up to date. In addition, we also conduct Internal Anti-Corruption Audits on specified sites and locations to ensure that we continue to identify potential corruption risks in our operations. Over the past two years, FGV has been focusing on improving its anti-bribery systems. In August 2018, a new Group Anti-Bribery Policy Statement was published, which communicated our commitment to transparent and ethical conduct and the elimination of solicitation and bribery. We also started aligning our Anti-Bribery Management System (ABMS) with the internationally recognised ISO 37001:2016 standard, which provides guidance to organisations on establishing, implementing, maintaining and enhancing anti-corruption programmes. At FGV, we emphasise three areas: fraud, abuse of power and corruption. We have made sure that all potentially vulnerable areas, from tendering processes to payments to vendors and even the hiring of employees, are now covered by our ABMS. FGV has identified the companies to be included in CRM risk register preparation for assessment of corruption risks. In 2019, FGV completed 25 CRM risk registers in accordance with the ABMS auditor’s scope of certification. The standard meets the requirements set out in Section 17A of the MACC Act 2009 and the Guidelines on Adequate Procedures which will take effect from 1 June 2020. Early adoption of this standard means that FGV will be ahead of the curve and ready when the new regulations take effect. As a testament to our efforts, FGV received the internationally recognised ISO 37001:2016 certification for its ABMS on 17 December 2019. It was acknowledged as the first plantation company to roll out ABMS across the Group comprehensively. 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) and the results of our internal employee surveys, which indicate the level of satisfaction in our anti-bribery initiatives. Embedding the culture of integrity is a priority and a continuous effort. We take all incidents reported in 2018/2019 very seriously and there are severe consequences for any employees involved in integrity offences. FGV has zero tolerance for fraud, abuse of power and corruption and will continue to embody the principles of the ABMS in our day-to-day activities.
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