MACC Act Section 17A · ISO 37001
Show your procedures are adequate — before you have to.
An independent review of your anti-bribery framework against the Section 17A adequate procedures guidelines, with a clear plan to close the gaps.
- Bribery and corruption risk assessment
- Adequate procedures gap review against the government's T.R.U.S.T. guidelines
- Whistleblowing channel and investigation protocol design
- Third-party integrity due diligence and ISO 37001 support
Senior, certified GRC team · Think Risk International Sdn Bhd, Kuala Lumpur · part of the Think Risk group
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- ISO 9001
- ISO 14001
- ISO 45001
- ISO/IEC 27001
- ISO 31000
- ISO 37001
- ISO 22301
- COSO
- IIA IPPF
- Section 17A MACC Act
- ISPS Code
What you get
Fraud Investigation & Integrity
- ISO 37001
- MACC Act s17A
- Fraud risk assessment and fraud control planning
- Investigation of suspected fraud, misconduct and policy breach
- Whistleblowing channel and investigation protocol design
- Section 17A adequate procedures review and ISO 37001 systems
- AML/CFT programme review and compliance testing
- Third-party and vendor integrity due diligence
How it runs
Five steps, every time.
- 1
Scope & plan
Objective, scope, criteria and reporting line agreed; workplan mapped to your risks.
- 2
Evidence
Document review, data interrogation, walkthroughs and interviews where the work is done.
- 3
Analyse
Findings rated on a defensible risk basis, root cause separated from symptom.
- 4
Report
Decision-ready findings, business impact and a corrective action plan with owners and dates.
- 5
Embed
Capability transfer so your team sustains it; actions and KPIs handed over in StrategyX.
FAQ
Before you ask.
What is a Section 17A adequate procedures review?
Under Section 17A of the MACC Act 2009, a company can be liable for corruption by people associated with it unless it shows adequate procedures were in place. We review your anti-bribery framework against the government's guidelines, assess bribery risk and close the gaps — with ISO 37001 where you want certification.
How quickly can you start an investigation?
Investigations are mobilised at short notice and scoped to the allegation. Send an enquiry marked urgent and we will respond as a priority.
Who will actually do the work?
Our senior team in Kuala Lumpur, supported by the group's audit and compliance specialists in Australia and the Philippines where the work calls for it. You will know who is on your engagement before it starts.
Ready when you are.
One short form. A personal reply from our team — no obligation.
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