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CORPORATE DISCLOSURE ON BUSINESS INTEGRITY IN ASEAN 21 July, 2016

RESEARCH CONDUCTED BY

2

SUPPORTED BY

AGENDA

▸ Background▸ Methodology & Limitations▸ Findings for Top 50 Companies per Country▸ Top 10 Companies with Highest Disclosure Rates

3

1.BACKGROUND

4

36

50

35

85

38

0

20

40

60

80

100

Indonesia(88th)

Malaysia(54th)

Philippines(95th)

Singapore(8th)

Thailand(76th)

2015 Corruption Perception IndexRankings & Scores

5

2.METHODOLOGY & LIMITATIONS

6

DATA COLLECTION

Scoring1 = Fully Satisfied0.5 = Partly Satisfied0 = Not Satisfied

Questionnaire13 questions from Transparency International’s study: Transparency in Corporate Reporting

Limitations▸ Language barriers▸ Absence of public

disclosure▸ Ambiguous cases

Sources▸ Companies website▸ Annual reports,

Sustainability reports, Corporate governance reports

▸ Code of Conduct

Company SelectionTop 50 companies in 5 ASEAN countries by market capitalisations

▸ Indonesia▸ Malaysia▸ Philippines▸ Singapore▸ Thailand

7

3.FINDINGS FOR TOP 50 COMPANIES PER COUNTRY

8

Aspect 2External Commitment to Anti-Corruption

▸ Question 5▸ Question 6▸ Question 8▸ Question 9▸ Question 13

Aspect 1Internal Commitment to Anti-Corruption

▸ Question 1▸ Question 2▸ Question 3▸ Question 4▸ Question 7

Aspect 3Reporting & Monitoring

▸ Question 10▸ Question 11▸ Question 12

ASPECTS & QUESTIONS

9

ASPECT 1INTERNALCOMMITMENT TO ANTI-CORRUPTION

Question 1 Does the company have a publicly stated commitment to anti-corruption?

Question 2 Does the company publicly commit to be in compliance with all relevant laws, including anti-corruption laws?

Question 3 Does the company leadership demonstrate support for anti-corruption?

Question 4 Does the company’s code of conduct/anti-corruption policy explicitly apply to all employees and directors?

Question 7 Does the company have in place an anti-corruption training programme for its employees and directors?

10

11

QUESTION 1STATEMENT ON ANTI-CORRUPTION

1319 17

35 3395 11

5 628 26 22

10 11

0

10

20

30

40

50

Indonesia Malaysia Philippines Singapore Thailand

Q1. Does the company have a publicly stated commitment to anti-

corruption?

Fully satisfied Partly satisfied Not satisfied

35%43% 45%

75% 72%

54%

0%

20%

40%

60%

80%

100%


Q1. Average Level of Disclosure

12

100%

85%

98% 98% 100%

96%

0%

20%

40%

60%

80%

100%



50

37

49 49 50

11

2 1 0

0

10

20

30

40

50


Q2. Does the company publicly commit to be in compliance with all relevant laws, including anti-corruption laws?


QUESTION 2COMMITMENT TO COMPLY WITH LAWS & REGULATIONS

13

8%14%

7%13%

47%

18%

0%

20%

40%

60%

80%

100%



4 7 3 5

23

13

146 43 46 42

26

0

10

20

30

40

50


Q3. Does the company leadership demonstrate support for anti-

corruption?


QUESTION 3LEADERSHIP SUPPORT FOR ANTI-CORRUPTION

14

27 2934

11

43

22 1712

31

51 4 4 8

2

0

10

20

30

40

50


Q4. Does the company’s code of conduct/anti-corruption policy explicitly

apply to all employees and directors?


QUESTION 4 CODE OF CONDUCT TO ALL DIRECTORS & EMPLOYEES

76% 75%80%

53%

91%

75%

0%

20%

40%

60%

80%

100%



15

30%

60%

46%

33%

55%

45%

0%

20%

40%

60%

80%

100%



QUESTION 7: ANTI-CORRUPTION TRAINING FOR EMPLOYEES & DIRECTORS

155 2

18

28

30

36

29

19

21

5 919

13

0

10

20

30

40

50


Q7. Does the company have in place an anti-corruption training programme for

its employees and directors?


ASPECT 2EXTERNAL COMMITMENT TO ANTI-CORRUPTION

Question 5 Does the company’s anti-corruption policy explicitly apply to persons who are not employees but are authorised to act on behalf of the company or represent it?

Question 6 Does the company’s anti-corruption programme apply to non-controlled persons or entities that provide goods or services under contract?

Question 8 Does the company have a policy on gifts, hospitality and expenses?

Question 9 Is there a policy that explicitly prohibits facilitation payments?

Question 13 Does the company have a policy on political contributions that either prohibits such contributions or if it does not, requires such contributions to be publicly disclosed?

16

QUESTION 5 THIRD PARTY ACTING ON BEHALF OF THE COMPANY

112 14

1016 16

38 3540

34 34

0

10

20

30

40

50


Q5. Does the company’s anti-corruption policy explicitly apply to persons who are

not employees but are authorised to act on behalf of the company or represent it?


12% 16%10%

16% 16%14%

0%

20%

40%

60%

80%

100%



17

11%17% 19%

27%20%

19%

0%

20%

40%

60%

80%

100%



111

15 1927

20

3934 31

2330

0

10

20

30

40

50


Q6. Does the company’s anti-corruption programme apply to non-controlled persons

or entities that provide goods or services under contract?


QUESTION 6THIRD PARTY PROVIDER OF GOODS OR SERVICES

18

19

63%

39%

61%

50%

84%

59%

0%

20%

40%

60%

80%

100%



25

13 1423

39

13

13

33

4

612

24

3

23

5

0

10

20

30

40

50


Q8. Does the company have a policy on gifts, hospitality and expenses?


QUESTION 8 GIFTS, HOSPITALITY, AND EXPENSES

19

413 9

1

36

13

9

4838 40

2432

0

10

20

30

40

50


Q9. Is there a policy that explicitly prohibits facilitation payments?


QUESTION 9 PROHIBITION OF FACILITATION PAYMENT

3%

21%14%

39%

27%

19%

0%

20%

40%

60%

80%

100%



20

21

42%

11% 12%

25%

67%

31%

0%

20%

40%

60%

80%

100%



20

5 612

322

1 0

1

328

44 4437

15

0

10

20

30

40

50


Q13. Does the company have a policy on political contributions that either prohibits such contributions or if it does not, requires such contributions to be publicly disclosed?


QUESTION 13 POLITICAL CONTRIBUTIONS

ASPECT 3REPORTING & MONITORING

Question 10 Does the programme enable employees and others to raise concerns and report violations (of the programme) without risk of reprisal?

Question 11 Does the company provide a channel through which employees can report suspected breaches of anti-corruption policies, and does the channel allow for confidential and/or anonymous reporting?

Question 12 Does the company carry out regular monitoring of its anti-corruption programme to review the programme’s suitability, adequacy and effectiveness, and implement improvements as appropriate?

22

23

40%

66%

78% 80%

54%64%

0%

20%

40%

60%

80%

100%



20

3339 40

27

30

1711 10

23

0

10

20

30

40

50


Q10. Does the programme enable employees and others to raise concerns and report

violations (of the programme) without risk of reprisal?


QUESTION 10 PROTECTION OF WHISTLEBLOWER

24

51%60%

50%

68%

52%56%

0%

20%

40%

60%

80%

100%



2026

1021 22

118

30

26

8

19 1610

3

20

0

10

20

30

40

50


Q11. Does the company provide a channel through which employees can report

suspected breaches of anti-corruption policies, and does the channel allow for

confidential and/or anonymous reporting?


QUESTION 11: TWO-WAY COMMUNICATION CHANNELS FOR WHISTLEBLOWER

25

34%

15%

32% 31%

56%

34%

0%

20%

40%

60%

80%

100%



1 5 49

17

32

5

24 13

22

17

40

2228

11

0

10

20

30

40

50


Q12. Does the company carry out regular monitoring of its anti-corruption

programme to review the programme’s suitability, adequacy and effectiveness, and implement improvements as appropriate?


QUESTION 12: REGULAR MONITORING OF ANTI-CORRUPTION PROGRAMME

26

39% 40% 43%47%

57%

45%

0%

10%

20%

30%

40%

50%

60%


Overall Level of Disclosure

Average level of disclosure rate per country

Average level of disclosure rate across 5 countries

What does this mean for ASEAN?

27

4.TOP 10 COMPANIES WITH HIGHEST DISCLOSURE RATES

28

Bank Central Asia Tbk Pt Jasa Marga (Persero) Tbk Pt

Bank CIMB Niaga Tbk Pt Kalbe Farma Tbk Pt

Bank Negara Indonesia Perser Lippo Karawaci Tbk Pt

Bank Pan Indonesia Tbk Pt Perusahaan Gas Negara Perser

Bank Rakyat Indonesia Perser Semen Indonesia Persero Tbk Pt

Bayan Resources Group Vale Indonesia Tbk

Blue Bird Tbk Pt Waskita Karya Persero Tbk Pt

Bumi Serpong Damai Pt XL Axiata Tbk Pt

INDONESIA

*Some companies share the same scores with each other.29

Astro Malaysia Holdings Bhd IOI Corp Bhd

Axiata Group Bhd KLCCP Stapled Group

British American Tobacco Malaysia Bhd Lafarge Malaysia Bhd

Digi.Com Bhd Nestle Malaysia Bhd

Felda Global Ventures Holdings Bhd Petronas Chemicals Group Bhd

Hartalega Holdings Bhd Petronas Dagangan Bhd

IHH Healthcare Bhd Petronas Gas Bhd

*Some companies share the same scores with each other.

MALAYSIA

30

Ayala Corp Manila Water Co Inc

BDO Unibank Inc Metro Pacific Investments Corp

D&L Industries Inc Security Bank Corp

DMCI Holdings Inc Semirara Mining & Power Corp

Holcim Philippines Inc Travellers International Hotel Group Inc

International Container Terminal Services Inc

PHILIPPINES

*Some companies share the same scores with each other.31

City Developments Ltd Sembcorp Marine Ltd

DBS Group Holdings Ltd SIA Engineering Co Ltd

Keppel Corp Ltd Singapore Airlines Ltd

Oversea-Chinese Banking Corp Ltd Singapore Technologies Engineering Ltd

Sembcorp Industries Ltd United Overseas Bank Ltd


SINGAPORE

32

Advanced Info Service Pcl Electricity Generating Pcl

Bangchak Petroleum Pcl Intouch Holdings Pcl

Bts Group Holdings Pcl Ptt Exploration & Production Pcl

Central Plaza Hotel Pcl Ptt Public Company Limited

Charoen Pokphand Foods Pcl Thai Oil Pcl

Delta Electronics Thailand Pcl True Corp Pcl


THAILAND

33

TOP 10 HIGHEST DISCLOSURE RATE ACROSS ASEAN

Advanced Info Service Pcl Thailand

Bangchak Petroleum Pcl Thailand

Electricity Generating Pcl Thailand

Intouch Holdings Pcl Thailand

Sembcorp Industries Ltd Singapore

Sembcorp Marine Ltd Singapore

SIA Engineering Co Ltd Singapore

Singapore Technologies Engineering Ltd Singapore

Thai Oil Pcl Thailand

True Corp Pcl Thailand

34

ASEAN CSR Network (ACN)

▸Jerry Bernas▸Nguyen Thi Phuong Thao▸Anh Van Vo▸Thomas Thomas▸Zatan Tan▸Melissa Chong▸Angela Tan▸Ester Tjahjadi

Centre for Governance, Institutions and Organisations (CGIO)

▸CGIO Research Team: Prof Lawrence Loh and Cheryl Wang Yu▸CGIO Admin Staff: Verity Thoi, Jamilah Binte Ramli▸Student Research Assistants: Fang Chun Chun, Gabriel Wan, Edward Bingei

CREDITS

35

CREDITS

Special thanks to the creators of these resources:▸ Presentation template by SlidesCarnival▸ View of KL Sentral, Hilton and Le Meridian at dusk by

Akira Mitsuda (2008)▸ Map of Southeast Asia (orthographic projection) by

Keepscases▸ Checkmark by To Uyen from Noun Project

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http://www.slidescarnival.com/

https://en.wikipedia.org/wiki/File:KL_Sentral_at_Night.jpg

https://en.wikipedia.org/wiki/File:Southeast_Asia_(orthographic_projection).svg

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