Anti-Bribery & Corruption
Training (Section 17A)
Since 1 June 2020, Section 17A of the Malaysian Anti-Corruption Commission Act 2009 has held commercial organisations liable for corruption committed on their behalf — regardless of whether senior management knew. The only statutory defence is proving your organisation had Adequate Procedures in place, and training is one of the five required elements. This is a statutory compliance programme, sourced through Prime Orator's accredited compliance training network and typically delivered as a 1-day, on-site session.
Section 17A Changed the Risk for Every Malaysian Organisation
Corporate Liability Is Strict
Under Section 17A, an organisation can be held liable for a bribe paid on its behalf even if senior management never knew about it.
Personal Exposure for Leadership
Directors and senior management carry personal exposure if a commercial organisation cannot demonstrate Adequate Procedures were in place.
Everyday Risk Areas
Gifts, hospitality, facilitation payments and vendor relationships are where corruption risk most commonly and quietly enters a business.
Training Is Part of the Defence
Training and communication is one of the required elements of Adequate Procedures — not a nice-to-have, but part of the actual legal defence.
Structured across three audiences, since Section 17A exposure differs by role:
By the end of the programme, participants will be able to:
- Explain Section 17A liability and the Adequate Procedures defence in plain terms.
- Recognise bribery and corruption red flags in daily work.
- Know exactly how and where to raise a concern.
The T.R.U.S.T. Principles
Official government guidance issued around the Adequate Procedures defence is commonly summarised around five principles. This programme is structured to walk through each one.
Top-Level Commitment
Visible, sustained commitment from the board and senior management to a zero-tolerance position on bribery and corruption.
Risk Assessment
Regular, documented assessment of where corruption risk sits across the organisation's operations, markets and relationships.
Undertake Control Measures
Practical controls — approval limits, gift and hospitality policies, due diligence on third parties — built around the risks identified.
Systematic Review, Monitoring & Enforcement
Ongoing review of controls, monitoring for red flags, and consistent enforcement when policies are breached.
Training & Communication
Staff at every level understand the policy, recognise red flags, and know how to raise concerns — the focus of this programme.
Interactive Curriculum Exploration
Click on any module to preview its targeted topics and learning outcomes.
Section 17A and Corporate Liability
What the MACC Act 2009's Section 17A actually says, who counts as an "associated person," and why the organisation — not just the individual — carries the liability.
Targeted Training Competencies
Programme Agenda
Typically run as a single, focused day — the running order below is confirmed to your team's needs at booking.
Session 1 — Section 17A & Corporate Liability
What the offence covers, who is exposed, and why "we didn't know" is not, on its own, a defence.
Session 2 — Adequate Procedures & T.R.U.S.T.
Unpacking the five principles and where your organisation currently sits against each one.
Session 3 — Red Flags in Practice
Working through realistic scenarios in payments, approvals and vendor management.
Session 4 — Gifts, Hospitality & Procurement Risk
Applying policy to edge cases that come up in day-to-day vendor and client relationships.
Session 5 — Speaking Up & Governance
Whistleblowing channels, escalation paths, and the board/senior management oversight role.
HRD Corp Claiming & Delivery Options
Recommended
HRD Corp SBL-Khas
Claimable framing against your levy when your training plan is pre-approved through e-TRiS. Terms confirmed at the time of booking.
Request Quotation
Customisable
In-House / Group
Delivered on-site at your premises, scoped to your existing policies, risk areas and reporting lines.
Contact Us
Open Enrolment
Public Session
Join a scheduled public cohort alongside participants from other Malaysian organisations.
Contact Us
Frequently Asked Questions
Ready to close the gap on your Adequate Procedures defence?
We arrange Anti-Bribery & Corruption training for Malaysian organisations through our accredited compliance training network, with a general HRD Corp claimable framing consistent with our other programmes.