Professional Documents
Culture Documents
A-19-13A, Level 19, Menara UOA Bangsar, No. 5, Jalan Bangsar Utama 1,
Bangsar, 59000 Kuala Lumpur
By RAMSCOTT ACADEMY
INTRODUCTION
This is the 2nd Edition of the Malaysian Property Management Standards (PMS) and
is effective from 1st June 2016. It shall supersede all previous editions of the PMS that
has been issued by the Board of Valuers, Appraisers and Estate Agents Malaysia
including the Standards that came into effect on 1st of June 2010. In addition, the
PMS shall prevail over any circulars issued by the Board prior to it, in the event there
is any conflict between them.
The management of real estate involves many facets from managing accounts
and finances of the real estate, tenant relations, staff and vendor's management
code and regulatory compliance, insurance matters, health and safety issues to
general maintenance. The Property Manager should be well versed in his role and
provide a high standard of service to his Client. As a property professional, the
Property Manager must be competent in real estate finance, building construction
and maintenance, real estate laws and taxation as well as general management.
In Malaysia, the Valuers, Appraisers and Estate Agents Act 1981 (Act 242) defines
property management as,
"the management, maintenance and control of any land, building and any
interest therein, excluding the management and maintenance of property-
based businesses, on behalf of the owner for a fee..."
The Strata Management Act 2013 [Act 757] and its regulations address the
management and maintenance of the common properties comprising common
areas, facilities and amenities in strata titled buildings and lands. This Act spells out
the statutory duties and powers of the developers, Joint Management Bodies,
Management Corporations and Subsidiary Management Corporations in the
management and maintenance of the common properties in stratified
development areas and that gave rise to the need for professional Property
Managers for the management and maintenance of common properties.
When entrusted with the management of a property, the Property Manager has
fiduciary obligations to act lawfully, competently, diligently, impartially and in
accordance with the Client's instructions and objectives. Fiduciary obligations
represent the highest level of responsibility under the law in a service industry. In the
case of property management services, "Trust", "Integrity", "Honesty" "Fairness" and
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"Professionalism" underpin this specialist service dispensed by the Property
Manager.
Each Standard deals with a certain aspect of property management. Within each
standard is an INTRODUCTION to the Standard which sets out the broad objectives,
the STATEMENTS OF STANDARD and followed by EXPLANATIONS in the last section.
These Standards aims to cover the key aspects of property management but
should not be taken as exhaustive. It is expected for Property Managers to use
these Standards and adhere to the principles and directives carefully to achieve
the required standards of property management. The Standards are mandatory
and shall come into force on 1 June 2016. Property Managers are required to
adhere to the Standards strictly.
The Standards are based on the prevailing laws of Peninsula Malaysia. In the states
of Sabah and Sarawak, the Standards will have to be guided by the relevant
prevailing laws of the respective states of Sabah and Sarawak.
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CONTENTS
Introduction .............................................................................................................................. i
STANDARD 1 ....................................................................................................................... 1
STANDARD 2 ........................................................................................................................ 4
STANDARD 3 ........................................................................................................................ 6
STANDARD 4 ........................................................................................................................ 8
Building Management
STANDARD 5 ...................................................................................................................... 10
Maintenance Management
STANDARD 6 ..................................................................................................................... 15
Financial Management
STANDARD 7 ...................................................................................................................... 19
Administrative Management
STANDARD 8 ...................................................................................................................... 22
Insurance Management
STANDARD 9 ...................................................................................................................... 26
STANDARD 10 .................................................................................................................... 28
Tenancy/Lease Management
STANDARD 11 .................................................................................................................... 30
Facilities Management
The following definitions and meanings in the Standards are based on the
prevailing laws of Peninsula Malaysia. In the states of Sabah and Sarawak, the
Standards will have to be guided by the relevant prevailing laws of the respective
states of Sabah and Sarawak.
"Act 318" means the Strata Title Act 1985 (as amended);
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(b) provided for in any additional by-laws
made under section 32, 70 or 71 of Act
757;
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land, includes the original proprietor of
the lot before the subdivision, and
includes the executors, administrators
and successors-in- title and permitted
assigns of such person or body of
persons, and in a case where the person
or body of persons is under liquidation,
includes such person or body appointed
by a court of competent jurisdiction to
be the provisional liquidator or liquidator;
"Local authority area" means any area in a State that has been
declared by the State Authority to be a local
authority in accordance with section 3 of the
Local Government Act 1976 [Act 171]]
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means the committee of the management
corporation elected under section 56 of Act
757;
STANDARD 1
1.1.0 INTRODUCTION
1.1.2 This Standard specifies the duties, qualification and code of conduct of
the Property Manager so that the Client as well as the general public
are assured of a high standard of service that will be provided by
professional property managers.
1.2.1 The Property Manager shall comply with the provisions of Act 242, Act
318 and Act 757 as well as all relevant regulations, standards, guidelines
and circulars issued by the Board and other relevant authorities.
1.2.3 The Property Manager shall ensure that all contracts of the service
providers, contractors, vendors and suppliers are signed by the Client
unless the Property Manager is required and authorized in writing by the
Client to sign any of the contracts on behalf of the Client.
1.2.4 The Property Manager shall sign important reports and documents
prepared by him.
1.2.5 The Property Manager shall be honest and independent and shall
adhere to the code of conduct and ethics under Act 242 and other
relevant statutes and regulations.
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1.3.0 EXPLANATIONS
1.3.1 Section 19(c) of Act 242 stipulates that no one other than those
registered with the Board of Valuers, Appraisers and Estate Agents shall
be authorised to practise property management for a fee.
1.3.4 The Property Manager shall deliver his services professionally and
observe the professional ethics and code of conduct expected of him
as a professional outlined as below:
i. adhere and advocate within the industry to the spirit of
conforming to and complying with all applicable laws and
regulations;
ii. shall practice his profession with honesty, integrity and shall always
act in the best interest of the Client;
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vii. maintain the high standards of his profession and cooperate with
the Board to protect the public against fraud, misrepresentation
and unethical practices in property management and any other
act or omission by persons practising property management
which may bring disrepute to the profession;
The above guidelines and code of ethics are not exhaustive and serves
as a guide.
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MALAYSIAN PROPERTY MANAGEMENT STANDARDS
STANDARD 2
2.1.0 INTRODUCTION
2.2.1 The Property Manager shall enter into a written Agreement with his
Client in respect of his appointment as a Property Manager.
2.2.2 The Property Manager shall ensure that the Property Management
Agreement includes the following:
2.2.3 The Property Manager shall ensure that the Property Management
Agreement shall incorporate the following fiduciary obligations to the
client without any modification to the wording below:
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ii. In the discharge of his fiduciary duties and obligations to the
client, the Property Manager shall be prohibited from receiving
any form of commission or money or kickback directly or indirectly
from the contracts with or without the awareness of his client in
order to protect the client's interest and the integrity and
professionalism of the Property Manager.
2.3.0 EXPLANATIONS
2.3.1 An executed Agreement with the Client ensures all scope of work in the
services are understood and mutually agreed upon in the interest of
both parties. The scope of work in the services covered by the Property
Manager may include but not limited to the following:
i. Handing/Taking Over;
ii. Building Management;
iii. Maintenance Management;
iv. Financial Management;
v. Administrative Management;
vi. Insurance Management;
vii. Health, Safety & Emergency Management;
viii. Tenancy/Lease Management.
ix. Facilities Management
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MALAYSIAN PROPERTY MANAGEMENT STANDARDS
STANDARD 3
3.1.0 INTRODUCTION
3.2.1 The Property Manager shall prepare and set out clearly a defined
checklist to ensure the successful handing/ taking over of the relevant
assets, documents and records with regards to the maintenance and
management of the property.
3.2.2 In the taking over of the property, it is important to check and ensure
that all the relevant documents and financial records of the property
together with the audited accounts are handed over.
3.2.3 Upon taking over the property, the Property Manager shall carry out a
general inspection audit to establish the current state of repair and
condition of the building, infrastructure, installation and facilities,
required rectification of defects and deficiencies to ensure proper
upkeep of the property. This shall be documented in the form of a
Building Condition Report. If there is a need to carry out any form of test
or investigation requiring specialized knowledge, skill, equipment or
instrument, the Client shall, at his own cost, appoint a specialist
consultant to conduct such test or investigation.
3.2.4 The Property Manager shall implement the deed of mutual covenants,
house rules or by-laws, as the case may be, established for the property
management of the property. As and where necessary, the Property
Manager shall advise and assist the Client to review and make
amendments to the deed of mutual covenants, house rules or by-laws,
as the case may be.
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3.3.0 EXPLANATIONS
3.3.4 If there is any serious defect suspected in the civil and structural
components or the mechanical and electrical components of the
building or the common property, as the case may be, during the
general inspection audit of the building, the Client shall, at his own cost,
appoint the original appointed project engineering consultant or any
other specialist engineering consultant to carry out a detailed
engineering investigation together with proposal for remedial works.
3.3.5 The Building Condition Report is useful for the planning, budgeting and
carrying out of maintenance, repairing, refurbishment and upgrading
works; and also for the drawing up of a preventive maintenance plan. A
copy of the Building Condition Report duly signed by the Property
Manager will be given to the Client.
3.3.6 Deed of mutual covenants, house rules or by-laws, as the case may be,
are drawn up for the proper administration of multi-occupied buildings
especially of common facilities and amenities and for their smooth and
safe operation.
3.3.7 It is good practice that all Building Condition Reports, records and
documents are updated and reviewed for subsequent handover to the
Client or his agent upon the expiry/termination of the Property
Management Contract. This ensures a smooth and professional transition
to the next Property Manager.
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MALAYSIAN PROPERTY MANAGEMENT STANDARDS
STANDARD 4
BUILDING MANAGEMENT
4.1.0 INTRODUCTION
4.2.3 It is the duty of the Property Manager to design and implement the
relevant policies and procedures for the property and ensure all
necessary controls are in place.
4.2.4 The Property Manager shall prepare, review and implement standard
operating procedures (SOP) for the administration of the site office, site
personnel, vendors and service contractors.
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4.3.0 EXPLANATIONS
4.3.2 The Property Manager has the responsibility to ensure competent and
skilled staff are employed and deployed according to the agreed
appropriate organizational structure. The cost of the management
office personnel shall be borne by the Client. He shall recommend and
propose the appropriate organisational structure for the Client's
approval.
4.3.3 Building operational policies and systems ensure all aspects of building
maintenance, repairs and supervision are undertaken within the
parameters of the Client's expectations. It lays the foundation for the
efficient carrying out of daily operational work. The Property Manager
shall also liaise and co-ordinate with other consultants, external
contractors and relevant Government agencies on maintenance and
renovation works.
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MALAYSIAN PROPERTY MANAGEMENT STANDARDS
STANDARD 5
MAINTENANCE MANAGEMENT
5.1.0 INTRODUCTION
i. Corrective Maintenance;
ii. Planned Maintenance;
iii. Service Providers.
ii. The Property Manager shall monitor and supervise all works in
accordance with the conditions of the award of such works;
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5.2.2 PLANNED MAINTENANCE
ii. The Property Manager shall monitor and supervise the planned
maintenance works to ensure they are being undertaken in
accordance with the pre-agreed schedule and scope of work
and is completed with good workmanship;
iii. The Property Manager shall keep proper records of operating and
maintenance manuals and ensure timely renewal of all licenses,
permits and certificates;
iv. The Property Manager shall also keep abreast and be well
acquainted with all relevant laws, amendments or additions to
any codes and/or standards introduced and advise the Client
accordingly.
i. The Property Manager shall ensure that only qualified, skilled and
experienced specialist service providers are appointed for the
provision of the specific services. The Property Manager shall
manage, administer and supervise all appointed service providers,
taking necessary action to ensure a high level of competency
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and professional service is provided and that the Client's interests
are protected;
5.2.4 PROCUREMENT
The Property Manager shall recommend an appropriate
purchasing/procurement procedure for the client's approval in
implementing maintenance plan.
5.3.0 EXPLANATIONS
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accordance to the manufacturer's recommendation (e.g operating
hours, maintenance, warranties, etc.)
The Property Manager shall formulate job specifications in order to recruit the
most suitable candidate.
The service contract is an agreement between the Client and the service
provider. It is the duty of the Property Manager to enforce the terms of the
contract for service. He must ensure that all works are done in accordance
with the stipulated terms and conditions. The Property Manager shall ensure
that the Client's interest is protected in the event of any claims arising from the
failure or negligence on the contractor's part to fulfil the terms of the contract.
Any deviation from the terms and conditions and specifications should be
attended to and any defects should be immediately rectified.
The common types of Building Services include but are not limited to the
following:-
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10) Water features 24) Sewerage
11) General repairs 25) Supervising engineer
12) Gondola 26) Swimming pool
13) Insurance 27) Water features
14) IT equipment 28) Water proofing
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MALAYSIAN PROPERTY MANAGEMENT STANDARDS
STANDARD 6
FINANCIAL MANAGEMENT
6.1.0 INTRODUCTION
ii. Monitoring outgoings for the property and making the payments out of
the income or charges derived from the property or as approved by the
Client; including payment of GST, quit rent, and other relevant taxes;
6.2.1 The Property Manager shall administer the finances of the property on
behalf of the Client according to the contractual requirements and
obligations as agreed between the Client and the Property Manager.
The Property Manager owes the Client a duty of care and must conduct
his duties diligently and responsibly in accordance to his fiduciary
obligations.
6.2.2 The Property Manager shall assist his Client to maintain the property
management account operated by his Client, unless instructed
otherwise.
6.2.3 For subdivided or intended subdivided building and land under the
Act 757, the Property Manager shall assist the Client to open and
administer a trust account which is operated by the Client known as the
Maintenance Account for the collection of Charges and other
recoverable charges imposed by the developer, Joint Management
Body, Management Corporation or Subsidiary Management
Corporation, as the case may be, and the disbursements thereof.
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6.2.4 For subdivided or intended subdivided building and land under the
Act 757, the Property Manager shall assist the Client to open and
administer a trust account which is operated by the Client known as the
Sinking Fund Account for the collection of sinking fund contributions
imposed by the Developer, Joint Management Body or Management
Corporation, as the case may be, and the disbursements thereof.
6.2.5 The Property Manager shall be responsible for the preparation of the
Annual Budget covering income and expenditure of the property for the
Client's approval.
6.2.6 The Property Manager shall advise and determine the appropriate rate
and apportionment of service charge or Charges and sinking fund
contributions to be levied in accordance to agreed amounts and
relevant legislations for the Client's approval.
6.2.7 The Property Manager shall prepare and maintain proper and accurate
financial records which shall be transparent and accessible to the Client
and other authorised persons.
6.2.9 The Property Manager shall prepare the Annual Account and ensure
that this is professionally audited by an approved company auditor
appointed by the Client at the Client's cost.
6.2.10 The Property Manager shall implement proper measures for credit
control and debt recovery on a timely basis including taking
appropriate actions such as issuing of reminders, imposing of interest
charges and advising on the necessity of taking legal action.
6.3.0 EXPLANATIONS
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property management to maintain transparency and avoid
confusion.
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property, replacement of plant and machinery and other
forms of capital expenditure for purposes as provided under
the Act 757 are paid from this capital expenditure account.
A financial report shall be submitted to the Client on an an
agreed periodic basis and the annual account at the end
of each financial year.
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MALAYSIAN PROPERTY MANAGEMENT STANDARDS
STANDARD 7
ADMINISTRATIVE MANAGEMENT
7.1.0 INTRODUCTION
7.1.2 The Property Manager has to put in place an administrative system with
suitable personnel to handle the above functions.
7.1.3 Subject to prior agreement with the client, the Property Manager may
assist the Joint Management Body, Management Corporation or
Subsidiary Management Corporation to organize and facilitate the
committee meetings and/or the general meetings.
7.2.1 The Property Manager shall compile and keep proper records, manuals,
drawings, service contracts and all other necessary documents.
7.2.2 The Property Manager shall compile and keep proper records and
inventory listing of office equipment, tools and stocks used for operations
and maintenance.
7.2.4 The Property Manager shall ensure the application and timely renewal
as well as adherence to conditions of relevant licenses, permits and
certificates.
7.2.5 The Property Manager shall ensure the timely settlement of statutory
payments, utilities bills, outgoings and expenses.
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7.2.7 The Property Manager shall keep an approved petty cash account and
ensure its proper utilisation and control.
7.2.8 The Property Manager shall have proper system for human resource
management - selection, recruitment, employment, administration,
records, training, payroll and statutory contributions.
7.2.9 The Property Manager shall provide a list of emergency contacts for
owners, tenants and occupiers.
7.2.10 In a stratified development area, the Property Manager will assist the
Joint Management Committee, Management Committee or Subsidiary
Management Committee to convene and facilitate the committee
meetings in compliance with the Second Schedule of the Act 757.
7.2.11 Subject to an agreed fee with the developer, the Property Manager
may provide consultation, advice and assistance to the developer so as
to convene and facilitate the first annual general meeting for Joint
Management Body or Management Corporation pursuant to the
Act 757.
7.2.12 Subject to agreed fees with the Management Corporation, the Property
Manager may provide consultation, advice and assistance to the
Management Corporation so as to establish the Subsidiary
Management Corporation and to convene and facilitate the first
annual general meeting for Subsidiary Management Corporation
pursuant to the Act 757 and the
Act 318.
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7.3.0 EXPLANATIONS
7.3.1 A systematic and efficient administrative system will help the property
Manager to ensure the smooth operation of the building's facilities and
services. With effective and comprehensive records and documents,
the property Manager is able to make recommendations and decisions
on property management matters.
7.3.2 It is prudent for the Property Manager to inform the Client if there is
insufficient fund or cash flow to meet any payments due in respect of
bills or for the purposes of renewals of licenses, permits and certificates
and the consequences thereof.
7.3.3 The Property Manager being an expert professional in property
management practice will be in the best position to provide the
necessary advice and consultation to –
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MALAYSIAN PROPERTY MANAGEMENT STANDARDS
STANDARD 8
INSURANCE MANAGEMENT
8.1.0 INTRODUCTION
8.1.1 The Property Manager may assist the Client in the procurement of
adequate insurance cover to protect the interest of the Client.
8.1.2 Various insurance policies are available for insuring property against
perils. The Property Manager must have knowledge of such insurance
policies as well as an understanding on the adequacy of coverage,
insurance premium and insurance claims.
8.2.1 The Property Manager may assist the Client on the various perils that
affect the property and types of coverage available.
8.2.2 The Property Manager may assist the Client to procure adequate
coverage for the different perils to protect the interest of the Client.
8.2.3 The Property Manager shall enable for proper and timely billing of the
insurance premium to be made to all owners who are liable to pay for it
based on an agreed apportionment.
8.2.4 The Property Manager shall report damages and losses as and when
they occur and assist to make the appropriate claims to the insurers in
accordance with the insurance policies and procedures.
8.2.5 The Property Manager shall ensure that monies received from any claim
is fully utilized for the purpose for which it was claimed for and all monies
received are deposited into the appropriate Client's or trust account, as
the case may be.
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8.3.0 EXPLANATIONS
The Property Manager shall coordinate with the Client to procure the
relevant insurance policies to insure the property against the various
perils. He must ensure the proper types of insurance policies are taken
out.
i. Fire insurance
Fire insurance cover shall include cost of demolition and removal
of debris and reinstatement or rebuilding. The Property Manager
shall recommend to his Client to seek the advice of the relevant
professionals in ascertaining the insurance value of the property.
In such an event, the Client may commission and bear the cost of
a valuation report prepared for fire insurance purposes.
In the case of strata titled building, the Act 757 under subsection
94(2) provides that, for the purpose of determining the
reinstatement value of the building that is required to be insured
for fire insurance, a reinstatement valuation of the building shall
be obtained from a registered valuer at least once every five
years.
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In the case of strata titled land parcels, section 97 of Act 757
provides that each parcel owner or proprietor shall be responsible
to insure his building on the land parcel as the building is deemed
to be his private property.
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viii. Fidelity guarantee insurance
All risks insurance is to cover all other possible and optional perils
existing in the aforesaid insurance policies.
8.3.2 Others
ii. The Property Manager shall inform the Client of the services
offered by insurance brokers who provide more extensive advice
on insurance matters and on any other insurance products
available. The fees and all other incidental cost for the
appointment of the brokers or any other consultants are to be
borne by the Client.
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MALAYSIAN PROPERTY MANAGEMENT STANDARDS
STANDARD 9
9.1.0 INTRODUCTION
9.1.1 In every property, there exists the possibility of incidents and accidents
occurring which may create emergencies and risks to the occupiers and
invitees in the property.
9.1.2 As part of good property management practice, the safety and well-
being of the occupiers and invitees in a property should be of prime
concern to the Property Manager.
9.1.3 This section covers the Property Manager's scope in the management of
the health, safety and emergency issues for the property.
9.1.4 Some types of risks, hazards and emergencies that may affect properties
include:
v. Structural failure;
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9.2.0 STATEMENTS OF STANDARD
9.2.1 The Property Manager shall keep abreast and ensure compliance at all
times of the various legislations and regulations that relates to the health
and safety of the occupiers and invitees in a property.
9.2.2 The Property Manager shall be aware of and be able to identify the
possible risk and safety issues which may affect the property he
manages and takes necessary measures to prevent or reduce or
mitigate the possible risk.
9.3.1 It is prudent for the Property Manager to develop a safety and security
programme that meets the Client's and occupiers' needs. Such a
programme is to prevent safety and security breaches and to detect
them should they occur and follow through with proper actions to
minimise harm to people and damage to property.
9.3.2 It is important that the Property Manager ensures that the property
under his care complies with the requirements of the Department of
Occupational Safety and Health (DOSH), the Occupational Safety
Health Act 1994 (OSHA) and other related Acts. DOSH will ensure
thorough enforcement and promotional works that employers and
employees always practise safe and healthy work culture as well as
comply with existing legislation, guidelines and codes of practice. OSHA
provides the legislative framework to secure the safety, health and
welfare among the Malaysian workforce and to protect them against
risks on safety or health in connection with the activities of the personnel
at work.
9.3.3 Where appropriate, the Property Manager shall advise the Client on the
appointment of safety personnel
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MALAYSIAN PROPERTY MANAGEMENT STANDARDS
STANDARD 10
TENANCY/LEASE MANAGEMENT
10.1.0 INTRODUCTION
10.2.1 The Property Manager shall ensure that all dealings and
transactions are ethical and transparent with his Client's best
interests protected at all times.
10.2.5 The Property Manager shall ensure that the covenants expressed
or implied, are observed by the tenant or the lessee, under the
tenancy/lease agreement throughout the duration of the
tenancy/lease. He shall diligently monitor and enforce the
covenants without fear or favour at all times.
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10.2.6The Property Manager shall coordinate that the delivery of vacant
possession and handing/taking over are properly executed when
tenants are moving in or moving out. This may include full
reinstatement of the demised premises to its original condition.
10.3.0 EXPLANATIONS
10.3.1 The Property Manager plays an important role as the link between
the landlord/lessor and the tenant/lessee. Whilst ensuring that the
tenant /lessee has quiet enjoyment of the demised premises, the
Property Manager must also ensure that the tenant/lessee
observes all house rules or by-laws and complies with all his
obligations under the tenancy/lease agreement.
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MALAYSIAN PROPERTY MANAGEMENT STANDARDS
STANDARD 11
FACILITIES MANAGEMENT
11.1.0 INTRODUCTION
11.1.1 Facilities management is the integration of processes within an
organisation to maintain and develop the agreed services which
support and improve the effectiveness of its primary activities.
11.1.4 The Property Manager may carry out facilities management for
the Client who does not require any of the services in the billing
and collection of rental and service charges or Charges.
11.1.5 At the operational level, it is the role of the Property Manager in his
capacity as Facilities Manager to ensure compliance in all the
aspects of building operations to create an optimal, safe and cost
effective environment for the occupiers to function. Such areas of
facilities management include the following but not limited to:
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11.2.0 STATEMENTS OF STANDARD
11.2.1 Upkeep And Cleaning
Building fire poses the highest risk to loss of life and has the
potential to damage or shut down a businesses and livelihoods of
a building and its occupiers. As prevention against building fire,
the building will have in place inspection, maintenance and
repairs, replacement and upgrading, and testing of all the fire
safety installation, equipment and systems, records keeping and
certificates of compliance.
M&E activities fall into two basic categories - planned (i.e. routine
maintenance) and unplanned (i.e. breakdowns). Manuals and
specification documents should be used as a guide when
developing a maintenance program which should clearly outline
what needs servicing and when, as well as general routine
maintenance tasks, who will undertake them and when. This
particular area is covered in detail under Standard 5 -
Maintenance Management.
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11.2.5 Maintenance, Testing And Inspections
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to vending, catering, pantry or a place where staff can make a
drink and take a break from their desk.
11.2.11Energy Management
Efficient use of energy and water may minimise the impact on the
environment and optimise the expenditure of the property.
Property Manager, where necessary shall control and conserves
energy and water through monitoring the use of energy and
water.
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11.3.0 EXPLANATIONS
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