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ENRICHING PERFORMANCE AND COMMITMENTS  ENRICHING ACCOUNTABILITY AND INTEGRITY  ENRICHING RESILIENCE AND SUSTAINABLE GROWTH  OTHER INFORMATION


          INtEGRItY AND GOVERNANCE





          At KWAP, we hold an unwavering commitment to integrity   KWAP ORGANISAtIONAL ANtI-CORRuPtION PLAN
          and stand firmly against corruption in all its forms. We   2021 - 2025
          implement  relevant  controls and  measures  to  prevent
          corruption, continuously promote the importance of   We have established and launched KWAP Organisational
          integrity  among  our  employees  and  stakeholders,  and   Anti-Corruption  Plan  2021  -  2025  (KWAP  OACP)  on  24
          espouse good governance practices to safeguard the   February 2021. The KWAP OACP consists of 57 initiatives,
          interests of the organisation for the sustainability of its   targeted to be undertaken and completed within a period
          business. For the year 2023, these were evident through   of 5 years. These initiatives aimed to address integrity,
          the following key accomplishments and/or undertakings:  governance as well as corruption issues and risks within
                                                            KWAP. As at the end of 2023, which is the third year of the
          Penarafan Semula Risiko Tahun 2023 - Badan        KWAP OACP implementation, 70% or 40 out of the total
          Berkanun Persekutuan (BBP) Kementerian Kewangan   initiatives have been completed.
          oleh Suruhanjaya Pencegahan Rasuah Malaysia
          (SPRM)                                            ANtI-BRIBERY AND CORRuPtION POLICIES

          In 2020, the Malaysian Anti-Corruption Commission   Several existing and new policies, procedures and
          (MACC) categorised KWAP as a High-Risk organisation. .   guidelines have been reviewed and developed to ensure
          However, following the 2023 evaluation, KWAP has been   they are up-to-date and remain effective for good
          reclassified as  a  Low  Risk organisation  based  on  the   governance and corruption prevention. These include:-
          MACC’s assessment. The result of this evaluation serves   i.   Policy on Support Letter
          as a testament to amongst others, KWAP’s commitment
          in implementing anti-corruption controls and measures      This new policy was established as part of KWAP
          for the past three years.                            Anti-Bribery and Corruption Policy (ABC Policy)
                                                               which stipulates KWAP’s stance on receiving, issuing,
          ISO 37001: 2016 ANtI-BRIBERY MANAGEMENt              and requesting Support Letter from/to any external
          SYStEM
                                                               individual/organisation.
          KWAP  has  been  certified  with  ISO  37001:2016  Anti-  ii.  Whistleblowing Policy
          Bribery Management System (ABMS) since 3 December
          2021 which is part of our continuous efforts in ensuring      The policy was amended to improve on the
          efficient business operations through the management   effectiveness of the established whistleblowing
          of bribery and corruption risks. For 2023, KWAP had   mechanism, particularly on the deliberation and
          completed its second ABMS surveillance audit covering   decision making of whistleblowing cases.
          its departments operating in Kuala Lumpur and Cyberjaya
          offices as well as KWAP’s subsidiaries, namely, KWEST   iii.  Anti-Bribery and Corruption Policy (ABC Policy)
          Sdn Bhd and Prima Ekuiti (UK) Limited.
                                                               The definition of “corruption” in the ABC Policy was
                                                               refined to provide better clarity, contributing towards,
                                                               for instance, improved Fraud and Corruption Risk
                                                               Assessment process.












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