Adequate Procedures and Gap Analysis

In 2018, the National Centre for Governance, Integrity, and Anti-Corruption Centre (GIACC) introduced the Guidelines on Adequate Procedures under subsection (5) of Section 17A of the Malaysian Anti-Corruption Commission Act 2009 (MACC Act). These guidelines provide a framework for commercial organizations to establish measures to prevent corrupt practices within their business activities. They are built on five core principles, which can serve as a reference for developing anti-corruption policies, procedures, and controls.

Enhancing Adequate Procedures through Gap Analysis

While many organizations have implemented internal control systems, gaps may remain in addressing Adequate Procedures and effectively mitigating corruption risks. Increasingly, boards and management teams are prioritizing the monitoring and effectiveness of anti-corruption policies and procedures to ensure the prevention, detection, and response to bribery and corruption.

Objectives of Our Gap Analysis

At VisionEthics, our gap analysis aims to:

• Evaluate Compliance Readiness: Conduct a comprehensive analysis to assess organizational readiness in meeting the requirements of Section 17A Corporate Liability Provision and the Adequate Procedures Guidelines.
• Benchmark Against Standards: Use the Adequate Procedures Guidelines and ISO 37001:2016 Anti-Bribery Management System (ABMS) as benchmarks.
• Provide Detailed Reporting: Summarize findings and present a detailed gap analysis report, including actionable recommendations for management and the Board of Directors.
• Support Policy Development: Offer guidance in drafting and refining anti-corruption policies and procedures to address any identified gaps effectively.

Our Approach

We perform an in-depth gap analysis to evaluate existing anti-bribery and anti-corruption documentation within your organization. Our approach includes:

1. Document Review: We assess current documentation against the Adequate Procedures Guidelines and ISO 37001:2016 ABMS requirements.
2. Stakeholder Interviews: We engage process owners through interview sessions to clarify practices and gather additional insights.
3. Gap Analysis Report: A comprehensive report outlining identified gaps, their implications, and actionable recommendations for closing them.
4. Recommendations: We provide guidance for implementing improvements and enhancing your organization’s anti-corruption measures.

Additionally, VisionEthics incorporates international best practices and guidelines during the assessment to ensure thorough coverage of anti-corruption risks.

Value Drivers of the Gap Analysis

Our gap analysis is structured around the following key elements to ensure the effectiveness of Adequate Procedures:

• Customized Compliance Checklist: We develop a tailored checklist to assess the depth and coverage of anti-corruption measures within the organization.
• Key Compliance Areas:
  ◦ Documentation of anti-corruption policies and procedures.
  ◦ Effectiveness in mitigating corruption risks.
  ◦ Monitoring and evaluation processes to foster a culture of integrity.

Key Focus Areas

Our gap analysis rigorously examines your organization’s:

• Regulatory Compliance: Ensuring adherence to local and international anti-corruption laws and best practices.
• Policy Implementation: Assessing the completeness and effectiveness of existing anti-corruption policies and procedures.
• Cultural Integration: Encouraging a culture of integrity through ongoing monitoring and evaluation.

Benefits of Our Approach

By partnering with VisionEthics, organizations can:

• Ensure Compliance: Address regulatory gaps and align with legal requirements.
• Strengthen Anti-Corruption Framework: Build a robust framework based on international best practices, such as ISO 37001:2016.
• Safeguard Reputation: Protect your organization’s integrity and reputation against corruption risks.

Conclusion

Our approach to Adequate Procedures and Gap Analysis helps organizations proactively manage corruption risks, aligning with both regulatory guidelines and international standards. By leveraging our expertise, we ensure a comprehensive solution that enhances integrity and compliance across your business.

 

VisionEthics will guide your organization through the 5 Adequate Procedures Principles, represented by T.R.U.S.T., ensuring a seamless implementation process. From conducting a gap analysis to executing company-wide anti-corruption measures, we offer the expertise and support you need.