Determinants of an Effective Anti-Bribery and Anti-Corruption (ABAC) Culture in Malaysian Public Listed Companies: A Conceptual-Based Framework

This paper integrates statutory provisions, regulatory guidance, corporate governance standards, and literatures to ascertain the determinants of an effective anti-bribery and anti-corruption (ABAC) culture within Malaysian Public Listed Companies (PLCs). The introduction of corporate liability via Section 17A of the Malaysian Anti-Corruption Commission (MACC) Act 2009 has catalyzed a shift from compliance-centric activities to a more profound examination of organizational culture. This study classifies the determinants of an effective ABAC culture into “hard” factors (legal, structural, and procedural) and “soft” factors (behavioral, cultural, and leadership). Drawing parallels from seminal management theories, this paper proposes a refined Dual-Factor ABAC Culture Model, which posits that while “hard” factors function as essential safeguards to prevent misconduct, “soft” factors are the primary drivers that cultivate a sustainable culture of integrity. The analysis culminates in a conceptual framework that integrates these cultural enablers with institutional safeguards, offering a governance-ready diagnostic instrument for PLCs, regulators, and practitioners aiming to embed integrity as a strategic asset.