CASE STUDIES

On this page, we have included a sample of case studies covering some of the programmes we have delivered for a wide variety of clients, from SMEs up to some of Malaysia’s biggest companies. The examples shown are just a small selection of our corpus of work, with many other solutions delivered successfully over our years of experience both in Malaysia and internationally.

A high level of expertise is needed to establish the effective measures a genuine “adequate procedures” programme requires for a company to have in place as a valid defence under the MACC Act Section 17A. Trident’s vision is to provide top-quality, impactful services of excellence in the field of anti-corruption to help companies successfully safeguard themselves, their directors and management against the serious consequences of corruption.

For more details about Trident and our extensive experience please explore our website at www.trident-integrity.com or email us at ask@trident-integrity.com. Our CEO Dr Lovatt can also be contacted directly via his email mark.lovatt@trident-integrity.com.

A major insurance company was looking for a high-quality consultancy to establish their MACC Act Section 17A adequate procedures, with an emphasis on Corruption Risk Management (CRM). Following a competitive tender, Trident was selected to do the job. The TRUST framework of the Malaysian Government’s Guidelines was used to establish the integrity programme based on best practice, tailored to the operations of the company. The project began with a gap analysis exercise, followed by the development and implementation of the programme.

The CRM exercise was required as part of the initiative to strengthen the corporate governance in corruption prevention. The CRM approached utilises the ISO 31000:2010 risk assessment methodology to ensure it is done in line with international risk management standards. Trident conducted corruption risk awareness training sessions, where selected members were trained to be the facilitators for the main CRM workshop and to be their department’s corruption risk liaison person on CRM in the future. Following that, a 2-day workshop was conducted with heads of departments to identify their potential corruption risks, including schemes and root causes. Making use of the results of the corruption risk assessment, Trident worked with the company to develop the control measures needed to manage the risks identified.  The company’s current policies and procedures were reviewed and suitable amendments made, with new materials developed where needed, all of which were designed to be practical and effective.

The CRM approach utilises the ISO 31000:2010 risk assessment methodology to ensure it is done in line with international risk management standards. Following Trident’s standard procedures a corruption risk awareness session was held as a pre-workshop preparation session. This was followed by a train-of-trainers session, where selected members were trained to be the facilitators for the main CRM workshop and to be their department’s corruption risk liaison person on CRM in the future. Further to that, a 2-day workshop was conducted with heads of departments to identify their potential corruption risks, including schemes and root causes. Making use of the results of the corruption risk assessment, Trident worked with the company to develop the control measures needed to manage the risks identified.  The company’s current policies and procedures were reviewed and suitable amendments made, with new materials developed where needed, all of which were designed to be practical and effective.

Trident also assisted the company to establish the review, monitoring and enforcement approach for the adequate procedures. This included the auditing plan which was developed in conjunction with the Internal Audit Department. Trident then worked with the company to prepare and action the training and communication plan. Tailor-made training materials were developed for the company and training initiated, with Dr Lovatt taking the lead. Trident also worked with the company to establish the communication plan to reach the company’s personnel and business associates. This was to ensure that the company’s position on anti-corruption, the reporting channel and the importance of compliance are well communicated.

The programme concluded with Dr Lovatt conducting an interactive 3 hour Board training session attended by all directors. The training explained the legislation, their tailored new adequate procedures programme, and their own roles and responsibilities going forward. Innovation and new technologies for their consideration were also presented. A full hour of open discussion followed, demonstrating the engagement of the Board and their strong interest in the subject matter. Dr Lovatt was commended on the programme and training session, with directors indicating their interest in continuing the working relationship with Trident.

A major power company in Malaysia, in fact one of the largest in the region, appointed Trident to implement a Corporate Integrity System leading to ISO 37001 Anti-Bribery Management System (ABMS) certification. As the company moved towards developing its international presence, the importance of establishing a comprehensive anti-corruption programme became paramount. The programme was crucial to safeguard the company against the dangers of corruption as it expanded into new markets, to protect the strong culture of integrity internally which had been built up over many years, and to establish best practice anti-corruption procedures in procurement. A well-developed anti-corruption framework was also important to provide assurance to both national and international stakeholders that the company is fully committed to maintaining the highest standards of business integrity.

It was a comprehensive project, taking a full two years to complete. The project was divided into seven stages, starting with the foundation including stakeholder mapping and bribery risk assessment going through to ISO 37001 certification. Trident worked closely with the head of the Integrity Department to develop the draft materials, conduct the reviews and updating, gain business acceptance and finalise the materials. Demonstrating the quality, suitability and value-add of the programme to the company’s senior management was important to ensure buy-in was strong and the implementation went smoothly.

A benchmarking integrity survey was done in the early stages of the programme to assess the Level of Integrity of the company, including the awareness amongst the 35,000 personnel and supply chain on anti-corruption. This was repeated at the end of the two years project to assess the impact of the programme so far and identify areas where further communication and training were needed.

After the BOD approval for the controls was secured, Trident assisted the company in delivering the awareness, training and communication plan. This was to ensure that the company’s stand on anti-bribery was properly communicated to the employees and business associates.

Once all the policies, procedures and other controls were in place and communicated, Trident established the review and improvement plan for the ISO 37001, which included the internal audit and continual improvement programme, and assisted the company with the first round of internal audits and management reviews. With these in place, the company was ready for certification.

Following the Stage 1 and Stage 2 audits, Trident reviewed the ISO certification body’s report and assisted the company in remedying the minor issues identified. In 2018, the company obtained its first ISO 37001:2016 Anti-Bribery Management System certification. Since then, the programme has achieved international recognition as a best practice example of an anti-corruption programme for a state-owned enterprise, and was featured as a case study by Princeton University.

One of the largest highway operators in Malaysia engaged the services of Trident to develop the policies and procedures, governance structure, training and communication needed to prepare for ISO 37001:2016 certification. Trident analysed their current policies and procedures to identify specific controls to put in place or update, and began the implementation.

The controls were based on the best practices in the industry. Using our co-working approach, Trident prepared the materials which were then reviewed and updated by the client team, and returned to Trident for further development. Technical components of the programme were worked out through discussion to make sure they were practical and relevant for the company’s operation. The finalised materials were then presented to the Board for approval, following which training and communication commenced.

For the training element, Trident used a “Train the Trainer” approach whereby Trident assisted in the development of the initial set of materials tailored to the company and conducted the first round of training for all key personnel. The company’s own team then continued the training using the materials provided for all personnel. This became a highly successful programme, with strong awareness and buy-in from the operational teams.

Trident also assisted the company in producing a comprehensive Anti-Bribery and Corruption Manual which includes the key points of the anti-corruption policies, scenarios, do’s and don’ts for communication purposes. The manual was published on the company’s website and has since proved to be a best practice example for emulation by other companies.

Trident’s standard co-working approach helped to build the company’s in-house capacity. This has proved useful as the team involved thoroughly understood how and why the policies and procedures were developed and were able to explain to the operational teams why certain things mattered: an important step forward in building the company’s own integrity strength.

For the ISO 37001:2016 certification process, the company undertook the necessary audits and was successfully certified in 2020.

A major property company was seeking expert consultancy to review the corruption risk assessment methodology based on the MACC’s methodology, and conduct a Corruption Risk Management (CRM) exercise to identify and manage down the corruption risks of the company. The company had already conducted an initial corruption risk assessment but was seeking an independent review by top anti-corruption specialists to gain assurance for the Board that their methodology was the best and the risk assessment was done to a high degree of excellence. Trident was appointed.

Trident worked with the company to determine the risk parameters and other materials to be used for the corruption risk assessment using the CRM approach, which uses ISO 31000 for risk assessments as its basis. Interviews were conducted with people from key positions to identify the likely risks and help prepare for the workshop. Trident then conducted a corruption risk assessment workshop over two days to identify, review and update the corruption risks.

Following the workshop the results were compiled into a set of completed corruption risk templates and presented to the company’s top management, with all the necessary materials provided. The end result provided an enhanced corruption risk management methodology, an up-to-date risk register, and strong awareness developed in the company of the importance of corruption risk management now that the MACC Act Section 17A is in force. The risks assessment was also used as the basis for enhancing its corporate liability adequate procedures and, in due course, ISO 37001 certification.

An oil and gas company based in Malaysia with the parent company in the United Kingdom appointed Trident to develop their adequate procedures programme. Trident worked on adapting and enhancing their anti-corruption policies and procedures adopted from the parent company to ensure they met the requirements of the MACC Act guidelines, and developing new controls were necessary.

The programme started by conducting a gap analysis to identify areas to establish or improve, followed by the corruption risk assessment. The results of these two work items were used as a basis to develop or enhance the policies, procedures and other items needed to mitigate the risks effectively.

Once all the gaps were closed and relevant controls put in place, Trident assisted in the training and communication of the anti-corruption policies and procedures. Following that, Trident conducted an audit to check on the progress of the implementation of those controls. This audit enabled the company to identify any weaknesses in the implementation process and to rectify those issues accordingly.

The approach taken produced a high-quality programme which adopted the materials from the parent company while tailoring and enhancing them to meet the requirements and challenges of operations in Malaysia. The HQ also took note of the items developed and is considering how to use them for other subsidiaries in the group.

A major telecommunications company was seeking to test the level of understanding and awareness of the company’s policies and procedures relating to corruption both internally and with its business associates. As an expert in the field, Trident was appointed to deliver the survey.

Using online survey engine, Trident prepared a bespoke survey tailored specifically to the client’s needs. Specific questions were asked, which if answered in the affirmative resulted in additional logic sequences guiding the participant through a set of additional questions to gain more information. This was particularly important for identifying whether personnel or business associates were under pressure from various parties to pay bribes. Since the survey was conducted by independent external party under conditions of confidentiality, participants were able to reveal information which would almost certainly would not otherwise have been disclosed.

The results of the survey were compiled into a report which made interesting reading for the management. Areas of concern could then be addressed by the Compliance Department and the company’s integrity programme significantly enhanced.

A major GLC with 35,000 personnel was interested to understand more about the Level of Integrity of the company. This involved Trident conducting an Integrity Survey for the company’s own staff and also its supply chain using a tailored survey approach specific to the areas of interest the company was seeking to know more about.

Prior to the survey, Trident worked with the Integrity Department and Corporate Communications team to prepare a series of messages through multiple sources to maximise the response rate. Following the communications exercise the survey was launched, with several reminders sent to the targeted participants to maximise take-up.

Once the survey was completed the data was anonymized and prepared for presentation. The result was of great interest to the top management and enabled the Integrity Department to focus its activities on areas which needed to be addressed. The survey and resulting action plan significantly enhanced the Level of Integrity of the company and also created a benchmark for the company to use in future to assess the ongoing impact of its integrity programme and consequent Level of Integrity.

A major communications company in Malaysia needed to assess its current position in relation to the adequate procedures requirements under the MACC Act, UK Bribery Act and US FCPA due to the international nature of its operations.  The company engaged Trident to conduct a gap analysis across all three sets of legal requirements. Trident conducted an in-depth research exercise covering the relevant international sources to produce a comprehensive checklist for all three areas. Trident then reviewed the policies, procedures and other materials the company had in place to produce the gap analysis report. This was then presented to the Board by Dr Lovatt, with a detailed discussion on what the report revealed and what steps should be taken to close the gaps.

The exercise proved to be extremely useful for the company in identifying the gaps specific to each law and then to prioritise the closure of the gaps based on their urgency. The closure of all the gaps by the company was important in order to maintain solid business relationships with overseas business partners and to protect the company, the Board and management against a corruption-based prosecution.

A major conglomerate was seeking an expert opinion regarding its current status and readiness for ISO 37001 ABMS certification. Trident was selected to conduct the gap analysis.

Trident used a comprehensive checklist developed in-house, based on ISO 37001 and supplemented by Trident’s extensive experience in implementing anti-corruption systems. The checklist was used to grade the current policies and procedures in terms of readiness for ISO 37001 certification, with a colour-coded mind map used to present the overall picture at a glance. Detailed information on the specific items was also provided, enabling the compliance team to understand what needed to be done to close the gaps and prepare for certification.

Trident also developed a bespoke bribery risk assessment tool for internal use across the company. This was designed to be used by business unit heads to identify their major corruption risks and assess the mitigating factors in order to determine their net corruption risk ratings, for reporting to the HQ. Following testing the instrument was sent to all the subsidiaries around the world. Trident also provided technical support for the bribery risk assessment as the exercise progressed. Using the results produced by the business units, Trident produced customised graphs and charts which were used to present the company-wide picture to the Board. The risk assessment helped the company to identify its bribery risk areas across over 130 business units, update the bribery risk data and evaluate the effectiveness and sufficiency of controls currently in place at the company. The instrument continues to be in use to this day.

As there are an increasing number of Small and Medium Enterprises (SMEs) seeking to implement the Adequate Procedures Programme on a tight budget, Trident has developed a low-cost package which provides high quality materials, a set number of consultancy hours and quality training at a very reasonable cost.

For one particular SME in the construction industry, Trident provided a complete set of templates for them to develop and tailor it to their company with Trident’s assistance. Using the consultancy hours, Trident assisted the company in developing certain policies which required particular expertise such as Gifts and Entertainment and the Whistleblowing procedure. In this package, Trident also conducted two rounds of training for the company’s personnel. As Trident provides the training deck in PowerPoint format as part of the package, the company can later utilise it to conduct their own in-house training. Overall, this short term project proved to be successful as the client was very satisfied with the seamless project working arrangements that enabled the company to establish the adequate procedures programme within a short time and low budget.

A highway operator was preparing for a tendering exercise to build two major new roads. Value: RM10 billion. The operator wanted a specialist company to conduct a tendering procedures best practice review to identify if there were any weaknesses in the process which could expose the company to corruption losses. They also wanted to do a similar exercise for their standard procurement procedures, to see where improvements based on best practice could be identified and the process strengthened.

Trident conducted extensive research and prepared two best practice review instruments, one tailored to their large tendering programme and the second for their standard procurement operations. The reviews were conducted, with detailed recommendations for improvement identified. The company took onboard the items identified, and proceeded to tender the projects successfully.

Case 1: Adequate procedures including Corruption Risk Assessment (CRA) for an international group including a financial Institution

A group based in Kuala Lumpur which includes a financial institution under Bank Negara was looking for a high-quality consultant to establish their MACC Act Section 17A adequate procedures, with the Corruption Risk Assessment forming a key component of the programme. Trident was appointed to do the job.

The CRA exercise was required as part of the initiative to strengthen the corporate governance in corruption prevention. The CRA approached utilises the ISO 31000:2010 risk assessment methodology to ensure it is done in line with international risk management standards.

Trident conducted extensive desk-based research to identify where the likely corruption risks would occur for the various operations of the group, which has operations in the US, the UK, Thailand and Malaysia, and what schemes and root causes were likely create the risks. The Trident team then prepared a set of pre-populated corruption risk templates for review and updating by the heads of department of the company. The HODs from the business units were trained on the principles of corruption risk, the MACC Act (with a focus on Section 17A) and how to complete the risk templates. The HODs then adopted the templates for their own use, updated the materials provided by Trident, and submitted them for a 2nd round of review. This was conducted through co-working between Trident and the client’s team. The templates were then finalised.

Making use of the results of the corruption risk assessment, Trident worked with the company to develop the control measures needed to manage the risks identified.  The company’s current policies and procedures were reviewed and suitable amendments made, with new materials developed where needed, which were designed to be practical and effective.

Following the CRA exercise and follow-on work, the company was well set up with its full set of adequate procedures, giving assurance to the Board that they had done all that could be reasonability expected and more to safeguard the company, themselves and the management against corruption risk and a Section 17A prosecution.

 

Case 2: Bribery Risk Assessment tool for a major conglomerate

Trident developed a bespoke bribery risk assessment tool for internal use across the company. This was designed to be used by business unit heads to identify their major corruption risks and assess the mitigating factors in order to determine their net corruption risk ratings, for reporting to the HQ. Following testing the instrument was sent to all the subsidiaries around the world. Trident also provided technical support for the bribery risk assessment as the exercise progressed. Using the results produced by the business units, Trident produced customised graphs and charts which were used to present the company-wide picture to the Board. The risk assessment helped the company to identify its bribery risk areas across over 130 business units, update the bribery risk data and evaluate the effectiveness and sufficiency of controls currently in place at the company. The instrument continues to be in use to this day.

 

Case 3: Corruption Risk Management programme for a major property developer

A major property company was seeking expert consultancy to review the corruption risk assessment methodology based on the MACC’s methodology, and conduct a Corruption Risk Management (CRM) exercise to identify and manage down the corruption risks of the company. Trident was appointed.

Trident worked with the company to determine the risk parameters and other materials to be used for the corruption risk assessment using the CRM approach, which uses ISO 31000 for risk assessments as its basis. Interviews were conducted with people from key positions to identify the likely risks and help prepare for the workshop. Trident then conducted a corruption risk assessment workshop over two days to identify, review and update the corruption risks. Following the workshop the results were compiled into a set of completed corruption risk templates and presented to the company’s top management. The risks assessment was used as the basis for enhancing its corporate liability adequate procedures and, in due course, ISO 37001 certification.