CORPORATE DISCLOSURE ON BUSINESS INTEGRITY IN ASEAN 21 July, 2016
RESEARCH CONDUCTED BY
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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
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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
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3.FINDINGS FOR TOP 50 COMPANIES PER COUNTRY
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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
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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%
Indonesia Malaysia Philippines Singapore Thailand
Q1. Average Level of Disclosure
12
100%
85%
98% 98% 100%
96%
0%
20%
40%
60%
80%
100%
Indonesia Malaysia Philippines Singapore Thailand
Q2. Average Level of Disclosure
50
37
49 49 50
11
2 1 0
0
10
20
30
40
50
Indonesia Malaysia Philippines Singapore Thailand
Q2. Does the company publicly commit to be in compliance with all relevant laws, including anti-corruption laws?
Fully satisfied Partly satisfied Not satisfied
QUESTION 2COMMITMENT TO COMPLY WITH LAWS & REGULATIONS
13
8%14%
7%13%
47%
18%
0%
20%
40%
60%
80%
100%
Indonesia Malaysia Philippines Singapore Thailand
Q3. Average Level of Disclosure
4 7 3 5
23
13
146 43 46 42
26
0
10
20
30
40
50
Indonesia Malaysia Philippines Singapore Thailand
Q3. Does the company leadership demonstrate support for anti-
corruption?
Fully satisfied Partly satisfied Not satisfied
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
Indonesia Malaysia Philippines Singapore Thailand
Q4. Does the company’s code of conduct/anti-corruption policy explicitly
apply to all employees and directors?
Fully satisfied Partly satisfied Not satisfied
QUESTION 4 CODE OF CONDUCT TO ALL DIRECTORS & EMPLOYEES
76% 75%80%
53%
91%
75%
0%
20%
40%
60%
80%
100%
Indonesia Malaysia Philippines Singapore Thailand
Q4. Average Level of Disclosure
15
30%
60%
46%
33%
55%
45%
0%
20%
40%
60%
80%
100%
Indonesia Malaysia Philippines Singapore Thailand
Q7. Average Level of Disclosure
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
Indonesia Malaysia Philippines Singapore Thailand
Q7. Does the company have in place an anti-corruption training programme for
its employees and directors?
Fully satisfied Partly satisfied Not satisfied
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?
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QUESTION 5 THIRD PARTY ACTING ON BEHALF OF THE COMPANY
112 14
1016 16
38 3540
34 34
0
10
20
30
40
50
Indonesia Malaysia Philippines Singapore Thailand
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?
Fully satisfied Partly satisfied Not satisfied
12% 16%10%
16% 16%14%
0%
20%
40%
60%
80%
100%
Indonesia Malaysia Philippines Singapore Thailand
Q5. Average Level of Disclosure
17
11%17% 19%
27%20%
19%
0%
20%
40%
60%
80%
100%
Indonesia Malaysia Philippines Singapore Thailand
Q6. Average Level of Disclosure
111
15 1927
20
3934 31
2330
0
10
20
30
40
50
Indonesia Malaysia Philippines Singapore Thailand
Q6. Does the company’s anti-corruption programme apply to non-controlled persons
or entities that provide goods or services under contract?
Fully satisfied Partly satisfied Not satisfied
QUESTION 6THIRD PARTY PROVIDER OF GOODS OR SERVICES
18
19
63%
39%
61%
50%
84%
59%
0%
20%
40%
60%
80%
100%
Indonesia Malaysia Philippines Singapore Thailand
Q8. Average Level of Disclosure
25
13 1423
39
13
13
33
4
612
24
3
23
5
0
10
20
30
40
50
Indonesia Malaysia Philippines Singapore Thailand
Q8. Does the company have a policy on gifts, hospitality and expenses?
Fully satisfied Partly satisfied Not satisfied
QUESTION 8 GIFTS, HOSPITALITY, AND EXPENSES
19
413 9
1
36
13
9
4838 40
2432
0
10
20
30
40
50
Indonesia Malaysia Philippines Singapore Thailand
Q9. Is there a policy that explicitly prohibits facilitation payments?
Fully satisfied Partly satisfied Not satisfied
QUESTION 9 PROHIBITION OF FACILITATION PAYMENT
3%
21%14%
39%
27%
19%
0%
20%
40%
60%
80%
100%
Indonesia Malaysia Philippines Singapore Thailand
Q9. Average Level of Disclosure
20
21
42%
11% 12%
25%
67%
31%
0%
20%
40%
60%
80%
100%
Indonesia Malaysia Philippines Singapore Thailand
Q13. Average Level of Disclosure
20
5 612
322
1 0
1
328
44 4437
15
0
10
20
30
40
50
Indonesia Malaysia Philippines Singapore Thailand
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?
Fully satisfied Partly satisfied Not satisfied
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%
Indonesia Malaysia Philippines Singapore Thailand
Q10. Average Level of Disclosure
20
3339 40
27
30
1711 10
23
0
10
20
30
40
50
Indonesia Malaysia Philippines Singapore Thailand
Q10. Does the programme enable employees and others to raise concerns and report
violations (of the programme) without risk of reprisal?
Fully satisfied Partly satisfied Not satisfied
QUESTION 10 PROTECTION OF WHISTLEBLOWER
24
51%60%
50%
68%
52%56%
0%
20%
40%
60%
80%
100%
Indonesia Malaysia Philippines Singapore Thailand
Q11. Average Level of Disclosure
2026
1021 22
118
30
26
8
19 1610
3
20
0
10
20
30
40
50
Indonesia Malaysia Philippines Singapore Thailand
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?
Fully satisfied Partly satisfied Not satisfied
QUESTION 11: TWO-WAY COMMUNICATION CHANNELS FOR WHISTLEBLOWER
25
34%
15%
32% 31%
56%
34%
0%
20%
40%
60%
80%
100%
Indonesia Malaysia Philippines Singapore Thailand
Q12. Average Level of Disclosure
1 5 49
17
32
5
24 13
22
17
40
2228
11
0
10
20
30
40
50
Indonesia Malaysia Philippines Singapore Thailand
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?
Fully satisfied Partly satisfied Not satisfied
QUESTION 12: REGULAR MONITORING OF ANTI-CORRUPTION PROGRAMME
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39% 40% 43%47%
57%
45%
0%
10%
20%
30%
40%
50%
60%
Indonesia Malaysia Philippines Singapore Thailand
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?
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4.TOP 10 COMPANIES WITH HIGHEST DISCLOSURE RATES
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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
*Some companies share the same scores with each other.
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
*Some companies share the same scores with each other.
THAILAND
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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
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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
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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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