INTRODUCTION ANTI-BRIBERY & CORRUPTION: WHAT MANAGEMENT NEEDS TO KNOW

This one-day training program is designed to provide mid-level managers with essential knowledge and practical skills to prevent bribery and corruption within their areas of responsibility. It highlights the role of managers as the “link” between top leadership and frontline staff in ensuring compliance, ethical decision-making, and the implementation of anti-corruption controls.

LERNING OBJECTIVES

• Understand the legal and regulatory framework on bribery and corruption (Malaysian & international).
• Recognize common bribery and corruption risks in daily operations.
• Learn management responsibilities in detecting, preventing, and reporting bribery.
• Strengthen ethical decision-making in handling business pressures.
• Build confidence in implementing company anti-bribery & corruption (ABC) policies.

WHO SHOULD ATTEND

• Mid-level Managers and Department Heads
• Supervisors and Functional Leads
• Compliance and Risk Officers at operational levels
• Team Leaders with oversight responsibilities
• Managers involved in procurement, finance, HR, and contracts

LERNING METHODOLOGY

• Interactive lectures and facilitated discussions
• Case studies on bribery and corruption scenarios
• Group workshops for risk identification
• Role-playing for ethical decision-making
• Action planning for implementing ABC practices

COURSE OUTLINE 

Ice Breaking – Activity 1 (ABC Dilemma Scenario)

Participants discuss a real-life inspired situation involving a potential bribery request to highlight pressures faced by managers.

Session 1: Understanding Bribery & Corruption

• Defining bribery, facilitation payments, and corruption
  • Malaysian Anti-Corruption Commission (MACC) Act & corporate liability provisions (Section 17A)
  • Global standards: ISO 37001 Anti-Bribery Management Systems
  Activity 2 (Knowledge Quiz): Test participants’ understanding of bribery concepts and laws.

Session 2: The Role of Mid-Level Management in ABC Compliance

• Responsibilities as the link between leadership and staff
  • Implementing and enforcing company ABC policies
  • Ensuring reporting, whistleblowing, and escalation mechanisms
  Activity 3 (Policy Gap Analysis): Groups review a sample policy and suggest improvements.

Session 3: Identifying Bribery & Corruption Risks

• Red flags in procurement, contracts, sponsorships, and HR processes
  • Third-party risks: suppliers, agents, and contractors
  • Tools for managers to monitor risks effectively
  Activity 4 (Risk Mapping Workshop): Teams map corruption risks within a simulated department.

Session 4: Ethical Decision-Making Under Pressure

• Frameworks for handling ethical dilemmas
  • Balancing targets, deadlines, and compliance obligations
  • Case studies of real-world corruption failures at management level
  Activity 5 (Role Play – The Manager’s Choice): Participants role-play responding to a bribery solicitation.

Session 5: Building a Culture of Integrity from the Middle

• Leading by example – “tone from the middle”
  • Encouraging staff to speak up without fear
  • Integrating integrity into team KPIs and performance reviews
  Activity 6 (Case Analysis): Review a case where mid-level management failed to prevent bribery and extract key lessons.

Session 6: Action Planning & Personal Commitment

• Developing a practical 3–6 month ABC action plan for their departments
  • Strengthening monitoring and reporting channels
  Activity 7 (Integrity Pledge): Each manager commits to one action they will implement immediately.

Wrap Up – Summary & Reflection

• Recap of key learning points
  • Open Q&A session
  • Closing reflection on the role of managers in anti-bribery governance