ABMS Audit Checklist

NORTHPORT (MALAYSIA) BHD

ISO 37001:2016 ANTI-BRIBERY MANAGEMENT SYSTEM INTERNAL AUDIT
ABMS AUDIT CHECKLIST FOR [CORPORATE SERVICE]

Area of Audit Commercial, Customer Service & VTC

Audit Team Audit Team Leader – Hairizad Azali

Auditor (1) – Nurul Izzati Mohd Noor
Auditor (2) – Mohd Jabir Arifin

Audit Date 10 August 2022

ISO 37001 Topics/Item to check Evidence Auditee Response Audit Finding

Clause No. Reference C/NC/OFI

GENERAL

5.2 AB Policy Is AB Policy available in ABMS policy Syazlin Policy is available and all staffs C
7.4 the work area, and are & poster are aware with ABMS policy
Communicatio staffs aware of the
n ABMS policy?

5.3.1 Roles & Any gifts receive this Gift Syazlin Sample of declaration form C
responsibilities year? Declaration taken for Chinese New Year and
8.7 Gifts, Form Hari Raya. Forms are well kept
hospitality, Request to provide gift by auditee.
donations & declaration list.
similar benefits
8.6 AB Is all current staff Corruption Syazlin Sighted. All signed. C
commitments already sign pledge or Pledge
Ikrar Bebas Rasuah

8.6 AB JD to include in ABMS JD Syazlin Sighted. All complied. C

commitments clause

4.5 Bribery Request auditee to CRM Syazlin Auditee provides CRM reporting. C
Risk provide CRM for document All is updated by quarterly basis.
Assessment Commercial Div.

Request to brief on Org Chart Syazlin/ Well briefed by auditees on C

commercial roles & Shadzril department’s roles &
responsibilities and to Elmy responsibilities. Org chart was
provide departmental provided.
org chart

Request to provide CRM CRM Report Syazlin/ CRM document sighted. All are C
report for Commercial Shadzril in compliance.
Department. Elmy

4.5 Bribery How does the Related Shadzril Gift declaration form, to record C
Risk Commercial documents Elmy any gifts, gratuities, and favors
Assessment department establish received from clients, customer,
control over the bribery suppliers, contractors and any
risk? related parties. (monthly report)
All document related to waiver,
Free Storage, TSA & discount in
general will go throught stage by
Page 1 of 5
ISO 37001 Topics/Item to check Evidence Auditee Response Audit Finding
Clause No. Reference C/NC/OFI
stage approval ie, (prepared,
reviewed and approved)

VTC

4.5 Bribery risk Has the AB assessment AB MR max xxxx

assessment Briefing and explained assessment
to the employee: -
5.1.2 (Top  When is last
management) update
 Who is PIC
update
 AB assessment
is include in JD
of all staff
8.1 To brief how vehicle Vehicle Zaid Jaleh Briefed by auditee on the vehicle C
Operational inspection being carried Checklist inspection process i.e. checking
planning & out for export and IID on chassis/engine number &
control import Gate Pass year of manufacturer.

VTC Clerk/Supervisor did a joint

inspection with the appointed
contractor using the Vehicle
Checklist at VTC storage area.

8.1 Any awareness to the LOA Max SM Marine Supplies Sdn Bhd is
Operational contractor on AB the only contractor for VTC.
planning & policy? They are aware since it is under
control Clause Termination in the LOA,
and the contractor need to
review all clauses prior contract
acceptance.

What criteria to appoint Criteria is based on xxxx

Memo
as VTC contractor?

The sample received xxxx

LOE (1) –
showed SM Marine had 5/4/21
extended for two times LOE (2) –
since 2021. Request to 4/4/22
provide the user’s
justification for the
extension of the
contract.

9.1 Monitoring, Request to provide CPE CPE Zaid Jaleh CPE for the previous three C
measurement, for VTC’s contractor months was provided with
analysis and scores of 80.5% (May), 78.8%
evaluation (June) and 78.8%( July). No
abnormal data was found.

Any non-performance CPE Zaid Jaleh Rarely short in supply of C

CPE for current manpower, therefore, none
contractor under performed for the current
contractor.

Page 2 of 5
ISO 37001 Topics/Item to check Evidence Auditee Response Audit Finding
Clause No. Reference C/NC/OFI
9.3 Is the CPE being CPE Zaid Jaleh CPE result are discussion with C
Management assessed in accordance VTC team.
review to the anti-bribery risk?

How does the CPE being Based on volume no of vehicle

carried out? handled against requested for by
VTC. Supply of requested
manpower and additional
manpower if needed.

MANAGING BUSINESS PROPOSAL

Request to briefly SOP Shadzril Customers will express their C

explain the Elmy interest to the Commercial rep
process/activity or vice versa, and the
involved in the work Commercial Key Account
scope Manager will produce a business
proposal for the official business
engagement.

Request to provide Email Shadzril C

sample of Elmy
communication
between KAM &
customer

Evaluation criteria for Business Shadzril Based on volumes commitment C

business proposal proposal Elmy for estimated years given by
memo customers

How business Customer Shadzril Commercial will provide tier C

commitment being Business Elmy incentive as a basis to the
evaluated? Commitment business commitment from
Tier list customer.
Benchmark
Any waiver Waiver Shadzril Consideration based on waiver C
consideration? request Elmy submission by customer.
Request will get xxxx
Committee and CEO’s approval.

Criteria for waiver Shadzril Commercial will review C

consideration Elmy customer’s credibility and any
related issues.
Page 3 of 5
ISO 37001 Topics/Item to check Evidence Auditee Response Audit Finding
Clause No. Reference C/NC/OFI

Request to provide Syazlin/ It was included in each C

rebate scheme Shadzril customer’s Terminal Service
Elmy Agreement (TSA). No
standardization of the rebate
scheme. TSA was not provided
due to P&C.

Mr Mark

ITT

How does the Mr Mark XXX C

commercial department
ITT personnel
determine the
selection/nomination
of:
a) The trucking
services?
b) The mode of
transportation by rail?
c) The mode of
transportation by
barge?

What are the XXX C

implemented controls
of this process?

Is there verification on XXX C

the cargo and load
being carried out?

Request to provide a ITT request XXX

sample of the related
documents in this
process.

Request to provide CPE CPE Shamsuri Auditee provides CPE for 5 C

for ITT’s contractor contractors namely:
a) [nama contractor]
b)
c)
d)
e)

CPEs for the previous 3 months

were taken as samples. All is
satisfactory.
Any non-performance CPE Shamsuri Happened in February 2022 due C
CPE for current to xxxx [kena tgk CPE balik]
contractor

Page 4 of 5
ISO 37001 Topics/Item to check Evidence Auditee Response Audit Finding
Clause No. Reference C/NC/OFI
Any reminder CPE Shamsuri Yes, Sent and acknowledged via C
submitted to contractor email for both parties.

Page 5 of 5