| 4. In which ways is the initiative creative and innovative?
IIP is unique as it is a master plan that enables IRBM to strategize and implement action plans with clear targets, objectives, outcomes and charts the progress of the integrity awareness, education, practice and culture of the organization.
The creative approaches are:
(i) Concrete but easy staff integrity assurance mechanisms for all.
(ii) Used different vibrant colors for different strategies in IIP 2.0 for easy remembrance.
(iii) Games simulation and integrity videos for fun learning.
(iv) Encourages Feel Good Integrity corner to all offices.
(v) Quizzes before and ends of Integrity presentation to test understanding.
(vi) Celebrity and personalities deliver integrity topics as crowd puller.
The innovative approaches are:
(i) Cost savings as it is developed in-house by IRBM.
(ii) Buy-in from top management.
(iii) Appoint Integrity Care Officers as Integrity Champion (change agent).
(iv) Ease of reporting through control self-assessment by implementation agencies.
(vii) Integrity awareness posted through IRBM Portal (web-base) under “Integrity”.
(viii) Management Integrity Data System (SPEDi) to monitor integrity issues.
(v) Easy guidelines and instruction for ease of implementation.
(vi) Flexibility and faster feedback through OCS (conferencing) and simple feedback template.
(vii) Constant engagement with other agencies (smart partnership) for best practices.
| 5. Who implemented the initiative and what is the size of the population affected by this initiative?
The Integrity and Risk Management Department (IRMD) is the agency entrusted with coordinating all programs and activities pertaining to integrity in IRBM. The program is conducted by Departments, states and branches (Implementing Agencies) across the country and they report half yearly to IRMD. Administration of all reports is done by IRMD. Control self-assessment is done by the Implementing Agencies and IRMD monitors the progress and propose recommendations for improvement. Progress report is prepared by IRMD and presented to a special committee called Integrity and Governance Committee chaired by the CEO of IRBM. Assurance on the level of integrity of the organization is also presented to the Board of IRBM periodically.
IIP has been implemented wholly to the 11,000 Hasilians and all benefitted from this initiative. The initiative does not stop at IRBM but also encompasses others in the Malaysian society which include extended employee’s family, CSR with community, taxpayers, tax practitioners, tax agents under the IIP Strategy 6, “To enhance integrity through General Approach”. The General Approach involve the following six components:
a. Family institution;
c. Civil society;
d. Socio-culture institution;
e. Religious institution; and
f. Economic institution
The six components involve the key features below:
a. Building a whole, loving and happy family that prospers on the foundation of good values;
b. Creating a safe and prosperous environment within and outside the family;
c. Improve internalization of continuous learning;
d. Inculcating good values through community/ club activities;
e. Develop social networking between IRBM, external organizations and the public;
f. Reinforce inter cooperation between IRBM, other government agencies and interested NGOs to promote enhancement integrity;
g. Develop knowledgeable, skillful, ethical, responsible employees with integrity;
h. Increase cooperation, mutual understanding and mutual respect between different faiths; and
i. Enhance and streamline taxation management ethics amongst taxpayers and tax agents.
| 6. How was the strategy implemented and what resources were mobilized?
The framework for implementation was set to be in-line with the IRBM 2009-2013 Corporate Strategic Plan. We also seek technical advice from the Malaysian Institute of Integrity as an oversight who is also the custodian of the national integrity agenda for Malaysia. Programs/activities were defined, customized or changed base on IRBM’s needs at the time to commensurate with IIP strategies. In order to achieve the objective of IRBM’s Integrity Action Plan and especially the organizational vision and mission, improvement were done to IIP programs/activities based on current situations and development was done through workshops and simulations.
IIP is implemented through the following six strategies:
Strategy 1 : To enhance the effectiveness of governance;
Strategy 2 : To enhance effectiveness of service delivery system;
Strategy 3 : To enhance awareness programs against abuse of power, misappropriation and corruption;
Strategy 4 : To enhance administration of a fair system;
Strategy 5 : To enhance management of human resource; and
Strategy 6 : To enhance integrity through the general approach.
All six strategies mentioned here are being implemented, reported across the country by the Departments & Divisions in headquarters, states offices and branches (Implementing Agencies), and once received, Integrity Division, IRMD will analyzed, measured, monitored and report to top management. To ensure the above strategies are implemented effectively, various programs and activities have been planned as listed in IRBM’s Integrity Action Plan (Part 2, IIP 2.0). We appoint Integrity Care Officers as integrity facilitators at all departments and branches level to facilitate on the reporting. Under the governance structure, a Chief Integrity Officer [also the Deputy CEO (Compliance)] was appointed to oversee the matter of integrity.
IRBM will undertake the following four approaches in implementing the programs for each strategy in order to achieve the objective which has been set.
Develop and implement planned, comprehensive and effective ethics and integrity training programs to increase knowledge and awareness of IRBM employees with regard to appreciating and cultivating wholesome values.
Increase the effectiveness of internal control systems to detect and identify weaknesses in work procedure practices and system. This is to prevent any opportunity which may lead to corruption, misappropriation and abuse of power.
To ensure employees of IRBM comply with work procedures and systems, code of ethics and client charter. Recognition programs are in place to acknowledge IRBM employees who show high level of integrity, whereas those who do not fully comply will be given guidance.
To develop effective detection and investigation systems in order to detect unethical actions and practices, and penalize accordingly if found guilty.
With the development of IIP, an effort to inculcate integrity at all levels of employees is more structured, systematic, planned and focused. Based on the six integrity core values and ten secondary core values the Integrity Plan Model of IRBM is developed (see Figure 3). IIP is published as reference for strategies and action plan to all Implementing Agencies. We also gave copies of IIP to our counterpart like Malaysian Institute of Integrity, Malaysian Anti-Corruption Commission and Integrity Unit, Ministry of Finance Malaysia. IIP is developed in-house by IRBM officials and the direct cost is printing the IIP’s book of 200 copies which come out to about RM10,000. Other financial implication is for formal training which is allocated yearly. IRBM finance the project.
| 7. Who were the stakeholders involved in the design of the initiative and in its implementation?
The Integrity Division, Integrity and Risk Management Department, IRBM is the owner of IIP. Workshops were done with the Malaysian Institute of Integrity (IIM) for technical assistant in ensuring IIP it is developed in a systematic and holistic manner. Technical advice was also seek from The Malaysian Anti-Corruption Commission in matters pertaining to abuse, misappropriation of powers and corruption. Selected IRBM employees (focus group), under the purview of IRMD, who undertakes to develop IIP were send to numerous courses and training sessions with the Malaysian Institute of Integrity, the Malaysian Anti-Corruption Academy, Malaysian Institute of Internal Audits and Malaysian Institute of Corporate Governance especially in the area of integrity, accountability, transparency, internal control, risk management and good governance.
A working committee was formed in 2009 to develop IIP (2009 – 2013) which comes from key departments like human resource, legal, corporate affairs, investigation and integrity and also representative from the Malaysian Institute of Integrity. Many workshops were done to ensure all objectives, strategies and action plans met the standards. IIP was approved by the Chairman of The Board who is also the Chief Finance Secretary, Ministry of Finance Malaysia. IIP was launched in the December 2009 by the Second Minister of Finance. IRBM is an agency under the Ministry of Finance. In December 2014, the new version IIP 2.0 (2014 – 2018) was launched by the President of the Malaysian Institute of Integrity who represented the Minister in The Prime Minister’s Department holding the portfolio Integrity and Governance. See Figure 4 and 5 below on the launching of the IIP by our stakeholders.
| 8. What were the most successful outputs and why was the initiative effective?
The initiative was effective based on the following outputs:
(i) Effective monitoring system
Management Integrity Data System (SPEDi) (see Figure 6) is developed to monitor the integrity issues of each individual staff at all level. Report is generated according to frequency and type of issues, which branch, what year of occurrence and current status of individual case.
(ii) High regards by external parties
The presence of esteemed speakers at IRBM’s yearly Integrity Convention/ Integrity Day:
a. DYMM Raja Nazrin Shah (Now Sultan 0f Perak and Deputy King of Malaysia)
b. DYMM Sultan Muhammad V, Sultan of Kelantan (now the King of Malaysia)
c. Ybhg. Tan Sri Abu Kassim, Chief Commissioner Malaysian Anti-Corruption Commission
d. Ybhg. Dato’ Dr Mohd Tap Salleh, President Institute Integrity Malaysia
e. Ybhg. Tan Sri Megat Najmuddin Megat Khas, President Malaysian Institute of Corporate Governance
To quote Ybhg Tan Sri Abu Kassim, during the signing ceremony of the IRBM Corporate Integrity Pledge 2013:
“MACC is proud that IRBM is committed in enhancing integrity and combating corruption as well as being supportive of anti-corruption initiatives implemented by the Government and MACC. The IRBM increased in collection denotes high integrity in IRBM”.
(iii) Benchmarking by external agencies and sharing of knowledge
Benchmarking was done by Malaysian Head of Registrar Office, Federal Court and University Technology Mara Malaysia in 2015. Deliver the topic Safeguarding Integrity in Tax Administration to international delegates at the CATA Technical Conference 2015. Deliver topic on Work Ethics and Integrity: IRBM Perspective to international participants during the Malaysian Tax Academy international courses and local seminar organized by Malaysian Association of Tax Accountant.
(iv) Good overall integrity performance of IRBM
From the date of implementation of Values Audit Evaluation System, there is a mark increase in index score. IRBM Composite Index Values Rating are 69.27 (2011), 80.35 (2012), 80.13 (2013) and 88.09 (2014) where the Index Score of 80-89 is good. The report generated is also submitted to Malaysian Anti-Corruption Commission and INTEGRITY.
(v) Excellent international evaluation
IRBM were assessed in the year 2015 and scored excellent (see Figure 7) in four areas under Transparency and Accountability by TADAT (Tax Administration Diagnostic Assessment Tools), an organization comprising IMF, World Bank etc. In-placed a strong:
a. Independent external oversight of IRBM.
b. Adequate internal controls to protect the system administration from error and fraud.
c. Level of assurance provided by internal audit.
d. Staff integrity assurance mechanisms.
| 9. What were the main obstacles encountered and how were they overcome?
Problems were encountered during the implementation and these were overcome as described below:
(i) Commitment, mindset change and acceptance
Commitment, mindset change, acceptance and ownership were main problems as indicated by delay in feedback on action plans implementation from some of the implementing agencies. There were needs for monitoring (phone calls, emails, face to face discussions and reminders) to implementing agencies to ensure timely feedback. There were cases of feedback beyond the stipulated deadlines. These problems were addressed and overcome by activities that include integrity talks, advisory, discussions and annual Integrity Convention program to guide implementing agencies. Role of the management, officers and the Integrity Care Officers were synergized to achieving the objectives of the initiatives. Motivating and rewarding performance of implementing agencies were undertaken through award of certificates of excellence to achievers who scored beyond 91.00% for implementing their action plans. This initiative was successful for instance in 2012, 53.85% implementing agencies received “Excellent” certificate awards compared to 2011 (17.65%) or 32.94% (2010).
(ii) Integrity training
There was limited integrity training of IIP initiatives initially. This was overcome and addressed by the IRBM administrative circular in 2012 for integrity training policy. This initiative was a collaboration with the training arm of IRBM; the Malaysian Tax Academy and the Human Resource Department. Implementing agencies were committed to integrity training in their respective Department/Region/Branch/Investigation Branch. Integrity training medium were enhanced including the production of integrity videos in 2013 (titled Curang) and 2014 (titled Diam) using in-house talent. Improvements were undertaken for integrity training module as seen by the enhanced Integrity Training Module; Part I (Integrity Enculturation) was attended by IRBM Integrity Care Officers in March 28 to April 2016. This enhancement is ongoing in 2017 for Part II (Financial Management and Procurement) and Part III (Human Management and Integrity Communication).