IMPLEMENTATION FRAMEWORK
The Malaysian Anti-Corruption Commission Act 2009 established the MACC as the authority responsible for investigating and prosecuting corruption. In 2018, the Act was amended to introduce corporate liability, making a commercial organisation liable if any associated person engages in corrupt practices to secure business or advantage for the organisation.
A commercial organisation may defend itself by demonstrating that it had implemented adequate procedures to prevent such misconduct, underscoring the importance of strong internal controls to mitigate corruption risks.
In line with the MACC Amendment Act 2018, A&A has revised its Anti-Corruption Policy to incorporate these requirements and developed an implementation framework to ensure compliance with the criteria for adequate procedures.
The revised Anti-Bribery and Anti-Corruption (ABAC) Policy, effective 1 October 2025, was officially launched on 25 November 2025 through a formal pledge signing ceremony by the Governance Committee, underscoring the Firm’s commitment to integrity and compliance.
ANTI-BRIBERY AND ANTI-CORRUPTION (ABAC) POLICY STATEMENT
Azmi & Associates is committed to conducting business with the highest ethical standards, integrity, and accountability, while ensuring full compliance with all applicable laws and regulations in every jurisdiction where it operates. Guided by the Firm’s Code of Conduct (“COC”) and Employee Handbook, Azmi & Associates upholds principles of integrity, responsibility, accountability, respect, and courtesy in all interactions – with clients, business partners, authorities, and the public.
Every member of Azmi & Associates, including agents, individuals, or entities engaged under a contract of service or for service, as well as those involved in any business-related activity, whether formally or informally, is expected to uphold the values of integrity, honesty, and professionalism at the highest level. This commitment applies throughout their employment or engagement with the firm and whenever representing Azmi & Associates in business transactions with third parties.
In essence, Azmi & Associates is fully dedicated to:
• Adopting a zero-tolerance approach to any form of corruption.
• Cultivating human capital with strong ethical values and integrity.
• Acting in a fair, ethical, and honest manner in all dealings with employees and business associates.
• Complying with all applicable laws in the jurisdictions where it operates.
This Anti-Bribery and Anti-Corruption Policy Statement is complementary to and is to be read together with the following but not limited to:
• A&A Governance Committee Charter;
• A&A Codes of Conduct (“COC”);
• A&A Code of Ethics;
• A&A Anti-Bribery and Anti-Corruption Policy and Framework;
• A&A Treasury Policy
• A&A Employee Handbook
• A&A Whistleblower Policy
• A&A No Gifts Policy
• A&A Contract Documents Management
• A&A Procurement Procedures
• A&A Limits of Authority
• A&A Enterprise Risk Management Policy and Framework
• A&A Anti-Money Laundering (AML), Counter Financing of Terrorism (CFT) and Counter Proliferation Financing (CPF) Policy
• A&A Related Party Transaction Policies and Procedures; and,
• All other relevant A&A policies, frameworks, procedures, standards, rules and regulations.
Azmi & Associate’s Anti-Bribery and Anti-Corruption Policy Statement reflects our unwavering commitment to fostering a culture of integrity and ethical excellence among our employees and members. We embed our Vision, Values, Commitments, and Core Strengths into every aspect of our business practices, ensuring that ethical standards remain at the heart of all we do.
If you need any advisory support on ABAC, please contact:
Melinda Marie D’Angelus
Partner
Labour & Employment, Litigation & Arbitration Practice Group
melinda.dangelus@azmilaw.com