MPGIA: Governance, Integrity & Anti-Corruption in the Oil & Gas Sector Workshop
Section 17A of the MACC Act 2009, the T.R.U.S.T. framework and “Tatacara Mencukupi”, delivered by Dr. Muhammad Shamshinor Bin Abdul Azzis, CeIO & ISO 37001 Lead Auditor.
📅 1 December 2026 📍 Miri 🕗 Check-in 8:00 AM · Ends 5:00 PM
🎟 Limited to 50 seats
⏳ Early Bird until 12:01 a.m. 16 Nov 2026
The era of plausible deniability is over.
Under Section 17A of the SPRM Act 2009, your company can be guilty of a bribe your board never knew about. “Adequate procedures” and documented training are now your only defence.
What would one bribe cost your company?
Enter the value of a bribe paid by any employee, agent or vendor to win business for your organisation.
Guilty, whether or not top management knew.
Section 17A(6) makes a commercial organisation liable when any person associated with it (employee, agent or vendor) offers, promises or gives a bribe to obtain or retain business for it. This is absolute liability. Management’s knowledge or approval does not matter.
The trigger
An employee or associate pays a bribe to win a tender.
The condition
The act is intended to benefit the organisation.
The fall
The company and top management are prosecuted automatically.
The only lifeline: adequate procedures.
Section 17A(5) gives a statutory defence. If charged, a company can show it had adequate procedures in place to prevent the corrupt act. But the burden of proof is now on the company, not the prosecutor.
Intent is irrelevant. Procedure is everything.
The judge does not ask what you wanted to do. The judge looks at what you actually implemented and documented before the incident.
T.R.U.S.T.: the blueprint for a legal defence.
Five principles, guided by the ISO 37001 Anti-Bribery Management System. These are not suggestions. They are the building blocks of your defence.
Top level commitment
Management sets the tone from the top.
Risk assessment
Identify the red zones where corruption risk is high.
Undertake control measures
Put policies in place, such as a Gift Policy, and carry out due diligence.
Systematic review
Monitor and audit the system.
Training and communicationThe nerve centre
Without it, the other four principles are dead documents. A policy that employees do not understand is worthless in court.
Why traditional training fails.
Physical and hybrid models cannot deliver defensible training at scale. If a sales executive gives a client a holiday thinking it is “just PR”, the company is liable. It never communicated the Gift Policy effectively.
The logistics trap
Physical sessions cannot scale to thousands of staff across shifts. They cause work stoppage and carry heavy venue and travel costs.
The forgetting curve
Per Ebbinghaus, retention drops sharply within 48 hours of a single intensive workshop. A one-off seminar is a temporary injection, not a cure.
The documentation gap
Paper attendance sheets are easily lost or falsified, and prosecutors may deem them insufficient.
The strategic shift: asynchronous micro-credentials.
Online, self-paced, bite-sized learning is presented as a mandatory shift for legally defensible compliance, not merely a training option.
Ironclad auditability
A Digital Audit Dashboard records who logged in, how long they engaged and their assessment scores. If SPRM investigates, you can produce a digital receipt proving a specific employee was trained on a specific date.
Scalability and flexibility
Staff learn at their own pace. No operational downtime, and it respects time zones and shift work.
Retention
Modules of 5 to 10 minutes, regular quizzes and interactive scenarios keep topics like Conflict of Interest and Political Contributions fresh.
Third-party coverage
Extend the system to vendors, suppliers and agents, the associated persons whose actions can create liability for you.
The judge sees the procedure you have executed, not your good intentions.
Compliance is not a KPI for HR. It is the legal insurance policy for the Board of Directors. Move from tick-the-box paper exercises to a culture of continuous, digital learning, and turn policy into an operational habit.
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