LSE’s Anti-Bribery and Corruption Policy applies to all of its directors, managers, employees, clients, contractors, suppliers, business associates and anyone with commercial interests or dealings with LSE. 

LSE adopts a ZERO TOLERANCE POLICY against bribery and corruption in any form in all its business dealings and relationships. LSE’s ABC Policy serves to document LSE’s commitment in adhering to ethical business practices and striving for a corruption free environment.

T.R.U.S.T. Principles

LSE’s ABC principles are guided by and based upon the Adequate Procedure Guidelines. These Adequate Procedure Guidelines were issued by the Prime Minister’s Department under the Malaysian Anti-Corruption Commission Act 2009 with the aim of assisting commercial organisations to understand and implement adequate ABC procedures.

The 5 principles enunciated in the Adequate Procedure Guidelines, and which form the core of this ABC Policy are as follows (“T.R.U.S.T Principles”):

T – Top Level Commitment

R – Risk Assessment

U – Undertake Control Measures

S – Systematic Review, Monitoring and Enforcement

T – Training and Communication

2.1     Objectives

LSE’s ABC Policy is intended to provide guidance to all Employees and Persons Associated on how to recognize and deal with any improper solicitation, bribery or other corrupt incidences encountered during the course of the Company’s Day to day operations and business activities.

The objectives of LSE’s ABC Policy are as follows:

  • to manifest the involvement and stance of the top-level management in establishing a culture of ethics and integrity across all levels within the Company and its group;
  • to signify in writing LSE’s acknowledgment of the ABC principles expended in the Adequate Procedure Guidelines and its commitment to adopt the same;
  • to provide greater definition regarding the forms of bribery and corruption and afford guidance to parties concerned on how to identify and deal with incidences or suspected incidences;
  • to identify and highlight the obligations of LSE, its Employees or Persons Associated with respect to applicable ABC laws and regulations in force from time to time; and
  • to establish a defence of adequate procedures against any allegation of non-compliance with applicable ABC laws.

2.2     Employees and Persons Associated

 LSE’s ABC Policy applies to all Employees and Persons Associated, and equally to private commercial dealings as well as dealings with the Public Officials. Every Employee and Person Associated with the Company are expected to read, understand and strictly adhere to the provisions set out in LSE’s ABC Policy at all times in the course of conducting the Company’s business.

 2.3     Third Party Business Associates

LSE seeks to build a strong relationship with all its third-party business associates and understands that such a relationship can only be established and long-lasting under a business environment free from bribery and corruption. Hence in the dealings with third parties, LSE approaches all engagements with a high level of integrity and professionalism. Third party business associates are asked to acknowledge LSE’s ABC commitments and are expected to refrain from taking part in any corrupt practices when establishing business relationships and conducting business with LSE.

2.4     Non-Compliance

All Employees must refrain from engaging in any bribery practice and must comply with all the provisions of LSE’s ABC Policy. The Employee(s) who failed to do so may face serious consequences of dismissal, fines, imprisonment or any other legal action being taken against the Employee for financial loss and/or damage in reputation faced by LSE. Persons Associated who fail to comply with any relevant provisions of LSE’s ABC Policy may also be subject to sanctions, penalties and/or other legal action that may properly and lawfully be taken by the Company. LSE shall also report all confirmed and proven incidences of corruption to the Commission, in which case the Employee or Person Associated concerned may be liable to prosecution.

2.5     Duty to Report

Any person who knows but fails to report an act of giving or offering of bribes is committing an offence under the Act. Hence all Employees and Persons Associated must report to the Company any suspicions on breaches of this ABC Policy by submitting the Whistleblowing Form via the whistleblowing channels, or deposit a sealed envelope at suggestion boxes (Gate 1 & Admin Building). LSE assures that mechanisms are in place to ensure that reporting can be made without risk of retaliation or fear of reprisal.

View LSE’s Anti-Bribery & Corruption (ABC) Policy and other policies HERE.



  • Any requests for gifts, gratuities, facility payments made by Public Officials.
  • Accepting any offers, bribes, entertainment & corporate hospitality in exchange for favorable results or advantages.
  • Any usual, frequent offers, monies, corporate entertainment & hospitality from the same business partner/ third party..


All LSE employees and members of the public can and should report a whistleblowing complaint on any wrongdoings that they have witnessed, reasonably suspect or have themselves experienced within LSE. 

These wrongdoings and misconducts may include, but are not limited to, activities related to bribery & corruption, abuse of power, conflict of interest,  mismanagement, misuse of company property, non-compliance with LSE or regulatory procedures and requirements.


No individual will be discriminated against or subject to any retaliation for raising genuine concerns or disclosing in good faith on any violation or suspected violation of any Improper Conduct. LSE is committed to protect Whistleblowers from any Detrimental Action resulting from a report made in good faith and will take the appropriate action to protect the Whistleblower in such event. All information received will be treated confidentially in accordance with LSE’s Whistleblowing SOP and Whistleblower Protection Act 2010 (Act 711).

How can you blow the whistle?

Fill-in the Whistleblowing Form (download form HERE), and submit the form through any of the following methods:

    • Via e-mail: 
    • Via mail: Seal form in envelope and deposit it in the Prihatin Boxes at LSE’s Gate 1 or Admin Building or by way of registered post/courier, clearly marked:
        “To be opened by the Compliance Officer/ABC Team Only”
      • c/o Labuan Shipyard & Engineering Sdn Bhd,
      • KM9, Jalan Rancha-Rancha,
      • 87000 Federal Territory of Labuan, Malaysia.
    • By submitting form directly to any one of the following persons in LSE’s Anti-Bribery & Corruption (ABC) Team:
        º Cik Rozana Rahmat – ABC Compliance Officer (Tel. ext. 125, E-mail:
        º Ms. Zyee F. Dullie – ABC Member (Tel. ext. 107/108, E-mail:
        º Mr. Fitzgerald Spencer James – ABC Member (Tel. ext. 189, E-mail:
        º Pn. Surayah Abd Rahman – ABC Member (Tel. ext. 101, E-mail: