Risk, Compliance & Integrity Management
Ensuring 
Accountability
in Every Decision
Risk, Compliance & Integrity Management
  • Risk & Compliance Management

    At Pelaburan Hartanah Berhad (PHB), we prioritize strong risk management and regulatory compliance to safeguard our business and stakeholders. Our approach aim to enhance resilience, safeguard stakeholders, and promote sustainable growth.

    Our Approach:

    • Risk Management: Identifying, assessing, and mitigating risks to protect and create value on our investments and operations.
    • Regulatory Compliance: Adhering to laws, industry standards, and corporate governance best practices.

  • Investment & Financial Risk

    PHB employs a top-down and bottom-up approach in identifying, evaluating, monitoring, and reporting investment and financial risks.

    A structured risk review and assessment is performed at the transactional level to provide approving authorities at the Management and the Board with independent party assessments to enhance the decision-making process and reduce the likelihood of uncalculated risks.

    This is complemented by independent reviews and monitoring of PHB’s key business areas, ensuring identification and mitigation of emerging financial risks.

  • Integrity & Governance

    At Pelaburan Hartanah Berhad (PHB), integrity and good governance are more than just principles – they are the foundation of everything we do. We are committed to fostering a culture of transparency, accountability, and ethical excellence.

    Our approach to inculcate the ethic and integrity culture is built on:

    • Driving Integrity from the Top – Tone from the top, driving a strong culture of integrity and ethical conduct at every level of organization.
    • Proactive Risk Management for Ethical Excellence – We proactively identify, assess and manage corruption risks across our business operations.
    • Robust Control Measures – PHB enforces strict anti-corruption policy including continuously improving our No Gift Policy and enhancement due diligence process and internal control measures to prevent misconduct and corruption risk.
    • Upholding Integrity Through Continuous Improvement – Regular reviews and thematic audits to ensure that our internal procedure adequate and effective.
    • Ethical Excellence – We cultivate a culture of integrity through ongoing training and awareness programs to improve integrity ownership and leadership within the organization.

    At PHB, we believe that integrity builds trust, and trust drives success. By embedding strong governance and ethical leadership into our corporate culture, we ensure that our growth is sustainable.

  • PHB Anti-Corruption Policy Statement

    The Group upholds a zero-tolerance policy towards all forms of corruption, including bribery, fraud, abuse of power, conflict of interest, breach of official duty, misconduct, misrepresentation, embezzlement, and theft. The Group are committed to promote the principle of good corporate governance and integrity in our business operations. This is in accordance with the Group’s core values “P.H.B”: PROFESSIONAL, HARMONIOUS and BOLD.

    The Group is committed to:

    • Conduct business dealings with the highest standard of ethics and integrity, in compliance with all applicable laws and regulations, including but not limited to Malaysian Anti-Corruption Commission (MACC) Act 2009, MACC (Amendment) Act 2018, Malaysian Penal Code (revised 1977) (and its amendments), Companies Act 2016 and other relevant laws and regulations.
    • Strictly prohibits any forms of corruption, abuse of power and conflict of interest, in accordance with MACC Act 2009 and other relevant laws and regulations.
    • Zero-tolerance approach towards breaches of official duty, misconduct, misrepresentation, embezzlement, and theft in accordance with MACC Act 2009 and other relevant laws and regulations.
    • Strengthen the values of integrity and good corporate governance in all business dealings in line with the PHB Anti-Corruption Policy, Code of Conduct and Business Ethics (CoBE), and “No Gift” Policy.
    • Promote the culture of transparency and confidentiality by providing an effective, adequate and secured whistleblowing reporting channel for any suspected corruption acts and conducts in line with the Whistleblower Protection Act 2010.
    • Prevent corruption by strengthening the internal control system through the compliance of systematic Anti-Bribery Management System (ABMS) and continually establish, maintain, periodically review, and improve its effectiveness and monitoring.
    • Empower the Integrity and Governance Unit to coordinate the monitoring and reporting requirement as per Prime Minister Directive No. 1/2018.

    The Board of Directors, employees and business associates have a collective responsibility to read, understand and comply with the Anti – Corruption Policy. Non-compliance or violation of this Policy may result in disciplinary and initiation of legal action in accordance with the MACC Act 2009 and PHB internal policies.

  • ISO 37001:2016 Anti-Bribery Management System (ABMS)

    Pelaburan Hartanah Berhad (PHB) has implemented and maintains the ISO 37001:2016 Anti-Bribery Management System (ABMS) as part of our commitment to the highest standards of integrity and governance.

    PHB has been certified by SIRIM QAS International since 2021 under Certificate No. ABMS 00193, reflecting our continuous effort to prevent, detect, and address bribery risks across the organisation.

    Our Commitment Under ISO 37001:2016 ABMS

    • Robust anti-bribery controls and clear ethical guidelines.
    • Effective due diligence on employees, vendors, and business associates.
    • Secure reporting and response mechanisms for misconduct.
    • Ongoing monitoring, training, and periodic audits to ensure system effectiveness.

    Through ISO 37001:2016, PHB reinforces a culture of transparency, accountability, and responsible business conduct in fulfilling our mandate as a trusted Bumiputera investment institution.

  • PHB Code of Conduct and Business Ethics (CoBE)

    Our Code of Conduct and Business Ethics (CoBE) serves as the cornerstone of our commitment to integrity, transparency, and ethical business practices. It sets clear expectations for all employees, stakeholders, and business partners, ensuring that every decision and action aligns with the highest standards of professionalism and accountability.

    This code outlines our principles on integrity, conflict of interest, anti-bribery and corruption, fair business practices, and responsible corporate conduct. By upholding these values, we foster a corporate culture built on trust, respect, and compliance with all applicable laws and regulations.

    At PHB, integrity is not just a principle – it is a way of doing business.

  • No Gift Policy

    PHB enforces a strict NO-GIFT POLICY to prevent undue influence, maintain objectivity and ensure professionalism in all business dealings.

  • Conflict of Interest Policy

    At Pelaburan Hartanah Berhad (PHB), integrity, transparency, and accountability are non-negotiable pillars of our corporate governance. Every employee is entrusted with the responsibility to act exclusively in PHB’s best interest, ensuring that personal considerations never compromise professional duties.

    A conflict of interest in any situation in which an individual is in a position to take advantage of his or her role at PHB for his or her personal benefit, including the benefit of his or her family and friends. This includes situations when personal, financial, or relational interests interfere with objective decision-making or create an impression of bias.

    Even without improper actions, the mere perception of a conflict can erode trust and damage credibility.

    To uphold the highest standards of integrity and accountability, any actual or potential conflict of interest must be disclosed immediately for proper assessment and action.

    At PHB, integrity is not just a value, it is our identity. We expect every employee to uphold the highest ethical standards in all business dealings, ensuring that trust and accountability remain the cornerstone of our success.

  • Vendor Integrity Pledge

    At Pelaburan Hartanah Berhad Group (“PHB Group”), we are committed to upholding the highest standards of integrity, transparency, and ethical business conduct in all our operations. In this regard, PHB Group expects its business partners to uphold the same principles in all engagements and dealings with PHB Group. 

    By engaging with PHB Group, the Vendors hereby pledge, warrant, and undertake the following:

    • To conduct all business dealings and transactions with PHB Group with the highest standards of integrity, honesty, transparency, and in full compliance with the principles of good corporate governance.
    • Not to, directly or indirectly, offer, promise, give, accept, solicit, or facilitate any gratification (as defined under the Malaysian Anti-Corruption Commission Act 2009) or engage in any corrupt practices, including bribery, for the purpose of obtaining, retaining, or securing any business advantage with or relating to the PHB Group.
    • To comply fully with all applicable anti-corruption and anti-bribery laws, regulations, and guidelines in Malaysia, including the Malaysian Anti-Corruption Commission Act 2009 (as amended), the Penal Code, and any relevant policies, codes of conduct, or directives issued by the PHB Group.
    • To promptly disclose to the PHB Group any actual, potential, or perceived conflict of interest arising from our organisation, directors, officers, employees, agents, subcontractors, or related parties in connection with any dealings with the PHB Group.
    • Not to engage in any form of bid rigging, collusion, price fixing, or anti-competitive arrangement, whether directly or indirectly, that may distort, manipulate, or improperly influence any procurement, tender, or contracting process conducted by or on behalf of PHB Group.
    • To immediately report to the PHB Group, via its designated whistleblowing channels, any known or suspected instances of bribery, gratification, conflict of interest, corrupt practices, or anti-competitive behaviour related to our dealings with the PHB Group.
    • To acknowledge and agree that any breach or violation of this undertaking may result in the imposition of appropriate legal, contractual, or administrative actions, including but not limited to termination of contracts, blacklisting, reporting to relevant authorities, and/or any other remedies available to PHB Group under applicable laws.

  • PHB Whistleblowing Policy Statement

    Pelaburan Hartanah Berhad and its subsidiary companies (the Group) is committed to uphold a high standard of integrity, transparency, and good corporate governance in the conduct of its operations. In view of this, the PHB Whistleblowing Policy has been established to encourage and provide an avenue for a whistleblower to raise concerns of any wrongdoing without fear of reprisals. This commitment is in alignment with the Group core values “P.H.B”: PROFESSIONAL, HARMONIOUS and BOLD.

    The Policy governs the disclosures, reporting and investigation of misconduct within the Group as well as the protection offered to the persons making those disclosures from detrimental action in accordance with Whistleblower Protection Act 2010.

    Reporting and Protection to Whistleblower
    Reports should be made through the Group’s established whistleblowing channels, as detailed in the PHB Whistleblowing Guideline. These channels guarantee confidentiality, anonymous reports, and protection from retaliation, in line with the provisions of the Whistleblower Protection Act 2010. The Group assures that every report received will be treated with the utmost seriousness, discretion, and good faith in accordance with legal and ethical standards.

    Whistleblowing Channels
    Whistleblower may submit a disclosure through any of the following channels:
    Whistleblowing email : wb@phb.com.my
    Whistleblowing hotline : +603 7711 3091

    Mailing address :
    Whistleblowing Secretariat
    [Attn: Integrity and Governance Unit (IGU)]
    Level 6, Block D, Dataran PHB,
    Saujana Resort, Section U2,
    40150 Shah Alam,
    Selangor Darul Ehsan.

  • Whistleblowing E-Form

    Please provide the following details if you wish to report Improper Conduct which are unlawful and are in breach of law and regulations that may adversely impact the Group. Please be assured that your report will be treated as confidential.

    Note: Please provide information as accurate as possible. The fields marked with (*) are required.

    Reporting Details

    Name of Alleged Person *

    Designation of Alleged Person *

    Department of Alleged Person *

    Company of Alleged Person *

    Incident Date & Time

    Location of Incident *

    Report

    Parties Involved (if any)

    Types of Allegation *

    Description of Complaint *

    1. Please describe the nature of your complaint. Include the details of the parties involved, date(s), time(s), location(s), etc. and any other relevant details.

    Name of witness (if any)

    2. Please provide details of witness(es) who can support your complaint e.g name, position, company etc.

    Attachments

    3. Please state and attach the documents and other evidences to support your complaint, if any.

    Details of Individual Lodging the Report

    Name

    Designation

    Department

    Company

    Telephone Number

    Email Address

  • Whistleblowing Policy
  • Whistleblowing E-Form
  • Whistleblowing Policy

    Generic Policy Statement

    PELABURAN HARTANAH BERHAD GROUP (“PHB Group”) is expected to uphold the highest standard of integrity as it is one of the components of the Company’s core values. PHB Group aspires to enhance its commitment to the corporate governance by fostering an environment where integrity and ethical behaviour is maintained and any legislations relating thereto are reflected accordingly.

    In line with this commitment, the PHB Group has formulated this Whistleblowing Policy (this “Policy”) in accordance with the Whistleblower Protection Act 2010 to provide a structured reporting channel and guidance to all employees and external parties to report instances of unethical behavior, fraud, misconduct, bribery or violation of the PHB Group’s Policies, Guidelines and Procedures without fear of reprisals, victimisation, discrimination and/ or being disadvantaged, provided that the disclosure is made in good faith.

    Definition and Applicability

    Whistle-blowing is the act of combatting corruption and other wrongdoings by encouraging and facilitating disclosures of information that one reasonably believes to be evidence of illegal, immoral or illegitimate practices including but not limited to contravention of any laws or regulations such as, information that involves mismanagement, corruption, abuse of authority or conduct, or any other wrongdoing carried out by an individual or group of individuals within the organisation that is not in the public interest. Such an act by the said individual(s) may be punishable by any legislated law of Malaysia. For the purposes of this Policy, all such acts shall come to be known as improper conduct (as defined under the Whistleblower Protection Act 2010)

    Who Can Disclose the Concerns:

    Any of the following Person(s) can make a disclosure of Concerns.

    Internal Whistle-blower

    • PHB employees, including employees on permanent, contract, temporary, assignment, or secondment basis, agents and consultants appointed by or working for PHB, direct or indirectly, who has concern of improper conduct by another employee/ director of the company; and


    External Whistle-blower

    • Any external party or member of the public, individual or group of people or institution who has concern of the improper conduct committed by an employee/ director of PHB Group.

    Reporting Procedures

    This policy is intended to complement the normal channel of communication and reporting lines within PHB, as described in the Code of Business Ethics (“CoBE”).

    What to disclose:

    A disclosure on improper conduct (Concerns) may be made if the whistle-blower has reasonable believe that the alleged wrongdoers engaged, or is prepared to engage in conduct prohibited by PHB or applicable laws and regulations.

    Improper conduct (Concerns) constitutes one or more the following wrongdoings by any person in the conduct of the Company’s affairs, as per the following list (this list is not exhaustive):

    • Any act of giving or receiving of any gratification or reward in the form of cash or in-kind value for performing a task in relation to his/ her job description as described under the Anti-Corruption Policy;
    • Forgery or alteration of company’s information and data;
    • Misappropriation or embezzlement of funds, securities, supplies, or other assets belongs to the company;
    • Giving, solicitating or accepting of a bribe or a favor in exchange for direct or indirect personal benefit as described under Anti-Corruption Policy;
    • Exchange of gifts directly or indirectly both within and outside of the work premises in the course of their official duties and business dealings which may influence in a decision-making process as described under Anti-Corruption Policy;
    • Giving, solicitating or accepting facilitation payment either directly or indirectly to expedite and facilitate performance by authorities as described under Anti- Corruption Policy;
    • Make or offer to make, any monetary or such other benefits in-kind, as a political contribution to political parties, political party officials or candidates for political office as described under Anti-Corruption Policy;
    • Impropriety in handling or reporting of money or financial transactions;
    • A third-party request that you provide employment or some advantage to a friend or relative;
    • Receiving an invoice from a third party that appears to be non-standard or customised;
    • A third-party request or requires the use of an agent, intermediary, consultant, distributor or supplier that is not typically used by or known to the Company;
    • Changing the criminal origin or nature of money or assets by hiding in legitimate business dealings and financial terrorism as described in Anti-Corruption Policy;
    • Profiteering as a result of insider trading/knowledge;
    • Failure to comply with the provisions of relevant laws and regulations where the wrongdoer knowingly disregards, or does not comply with such provisions;
    • Financial malpractice or account churning;
    • Breach/ violation of the PHB Group’s Policy, Guidelines and Procedures;
    • Abuse of power and position for personal gain; and
    • Any act that poses danger to the health, safety and lives of PHB Group’s employees and/ or the public or environment.


    Concerns may occur in the course of the company’s business or affairs or at any workplace, i.e. any related workplace to the company’s business or affairs, for example, on the company’s premises, at an event organised by PHB, or during a conference attended by the company's employees in the course of their work. If a Person is unsure whether a particular act or omission constitutes a wrongdoing under this Policy, the Person is encouraged to seek advice from Integrity and Governance Unit (IGU) of Risk, Compliance and Integrity Management Department.

    When to disclose:

    A whistle-blower shall come forward with any information or document(s) that they, reasonably believes in and discloses a wrongdoing, which is likely to happen, is being committed or has been committed.

    The whistle-blower needs to demonstrate that they have reasonable grounds for the concerns. However, the whistle-blower is not expected to first obtain substantial evidence of proof beyond reasonable doubt, or even be able to identify a particular person to which the disclosure relates, when making a disclosure.

    If the whistle-blower knows as a matter of fact that there are reasonable grounds of suspicion that a wrongdoing is going to take place, such genuine concerns shall be raised at an early stage.

  • Whistleblowing E-Form

    Please provide the following details if you wish to report Improper Conduct which are unlawful and are in breach of law and regulations that may adversely impact the Group. Please be assured that your report will be treated as confidential.

    Note: Please provide information as accurate as possible. The fields marked with (*) are required.

    Reporting Details

    Name of Alleged Person *

    Designation of Alleged Person *

    Department of Alleged Person *

    Company of Alleged Person *

    Incident Date & Time

    Location of Incident *

    Report

    Parties Involved (if any)

    Types of Allegation *

    Description of Complaint *

    1. Please describe the nature of your complaint. Include the details of the parties involved, date(s), time(s), location(s), etc. and any other relevant details.

    Name of witness (if any)

    2. Please provide details of witness(es) who can support your complaint e.g name, position, company etc.

    Attachments

    3. Please state and attach the documents and other evidences to support your complaint, if any.

    Details of Individual Lodging the Report

    Name

    Designation

    Department

    Company

    Telephone Number

    Email Address

Level 6, Block E, Dataran PHB, Saujana Resort, Section U2, 40150 Shah Alam, Selangor Darul Ehsan, Malaysia.

© 2025 Pelaburan Hartanah Berhad 200601013065 (732816-U). All Rights Reserved.
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