EPPA4716 INTEGRATED CASE STUDY

Semester 2 2015/2016

CASE STUDY: TRANSMILE GROUP BERHAD

PREPARED FOR:

DATIN DR. ZAINI BINTI EMBONG

PREPARED BY:

TAN BEE KUN A140209

LAU KAR LING A139789

WAH JUN YEW A142341

NUR HALIZA AMIRAH BT HALEMI A140099

NUR SHABIRAH BT SALIMAN A136723

KOO YUH JYE A139477

Content
Description Page
1.0 Introduction 2

2.0 Board of Directors 3-6

3.0 Audit Committee 7-10

3.1 Role of Audit Committee
3.2 Issue about the Integrity of Audit Committee
3.3 The issue of Effectiveness and Independence
3.4 Issue of Competency

4.0 Internal Auditor 11-12

5.0 External Auditor 13-29

5.1 Issue on Low Audit Fee
5.2 Issue the Long Term Relationship between Deloitte& Touch
and Transmile Group
5.3 Issue of Deloitte Judgement towards Transmile Due to Their
Long Relationship
5.4 Issue of late report fraud to BOD within 2 and half months
5.5 Audit Procedure and Practices

6.0 Research Analysts 30-32

7.0 Conclusion 33

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1.0 Introduction
The case study is about a company, Transmile Group Berhad who encounter
with accounting scandal where it causes the company to face suspension and de-
listing on Bursa Malaysia Securities Berhad. The overstated of revenue and profits
had resulted in negative consequences to both the company and its shareholders due
to the issue of corporate governance and business ethics.

Transmile Group Berhad is an investment holding company who involved in

the provision of air freight, aircraft engineering and maintenance services.The
company was founded by Gan Boon Aun in November 1993 and was later listed on
the Bursa Malaysia Securities Berhad on 27 June 1997. Operationally, Transmile had
maintained regular flights between Peninsular Malaysia and East Malaysia as well as
some major cities in the Asia Pacific. With a wide range network of operations,
Transmile reported increasing revenues and profits since 1998 until 2006. The strong
showing in revenue and profit were tracked by its share price which had risen
substantially.

However, in 2007, the external auditor of the company, Deloitte &Touche

declined to approve the annual accounts for lacking of certain supporting documents.
These has caused the company failed to adhere the deadline in submitting its audited
annual accounts for the financial year ended 31 December 2006 to Bursa Malaysia for
public release. Thus, the company faces suspension and de-listing.

The culprits to the accounting scandal may include the audit committee, the
board of director, the internal auditor, the external auditor and the research analysts.
However, in our opinion, we strongly believe that the external auditor is the main
culprits who cause the accounting scandal in the company due to few issues against
the regulations and accounting standards caused by the external auditor during their
audit works.

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2.0 The Board of Directors (BOD)
The Board of Directors is a body of elected or appointed member by
shareholder who will be responsible for monitoring the running company on behalf of
the shareholder for the benefit of the shareholder. Based on the corporate governance
principles, the responsibilities of the board of directors is monitoring managerial
performance and achieving an adequate return for shareholders, while preventing
conflicts of interest and balancing competing demand on the corporation.

The Board of Directors must able to exercise objective and independent

judgement to effectively complete their responsibilities. The board of directors also
responsible to oversee the risk management system and systems designed to ensure
that the corporation obeys applicable laws, including tax, competition, labour,
environmental, equal opportunity, health and safety laws. The board is not only
accountable to the company and its shareholders but also has a duty to act in their best
interests.

As stated in the Corporate Governance Principles and also the Transmile

Group Berhas’s annual report that the responsibilities of the BOD included overseeing
and monitoring of the performance of management and the business of the Group,
setting strategic and succession plan, developing and implementing shareholder
communication policy, managing risks and putting in place adequate internal control
and reporting procedures. The BOD are allowed to delegated some of the
responsibilities to several agents but they still need to held fully responsible on the
overall monitoring and overseeing the performance of the company.

However, in practice the board of directors of Transmile Group Berhad have

left all their responsibilities to the agents where they believe that it would conduct the
business with proper corporate governance and keep all directors informed. This was
against the principles of the corporate governance and also the policy of the company
that stated in the annual report.

It shows that the BOD never fulfill their responsibilities to the company and
shareholders. As BOD of a listed company, the BOD have no obey to the Corporate

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Governance Principles where they need to held fully responsible on the overall
monitoring and overseeing the performance of the company. The BOD had break the
trust of the shareholders and the principles of the corporate governance. The BOD
pass all the responsibilities to the agents and just with an assuming that the business
with be conducted properly according to the corporate governance. BOD also against
the principles of corporate governance where disclosure of information which is not
true and fair. As stated in annual report BOD have the fully responsibilities in
overseeing the company but in real the BOD did not practice it.

The corporate governance principles stated that, the board members should be
able to commit themselves effectively to their responsibilities and the boards should
regularly carry out evaluations to appraise their performance and assess whether they
possess the right mix of background and competences. Training and evaluation are
suggested to make sure for the competency of the boards. However, this two principle
are also not being practicing by Transmile.

Refer to corporate governance, the boards should consider setting up

specialized committee to support the full board in performing its functions,
particularly in respect to audit and depending upon the company’s size and risk
profile, also in respect to risk management and remuneration. When committees of the
board are established, their mandate, composition and working procedures should be
well defined and disclosed bythe board. Besides, in order to fulfill the responsibilities
given, the boards should have access to accurate, relevant and timely information. In
the case of the Transmile, the boards had formed the Audit Committee to assist them
in term of the statutory duties and responsibilities relating to accounting and reporting
practice of the company and subsidiaries.

The committee also play a role in serving as a bridge in the communication

network between internal and external auditors and the boards. However, the
committee had fail to fulfil their responsibilities where they the committee have been
informed about the serious accounting issues found in the company’s unaudited 4th
quarter of 2006 report on 14th and 15th February of 2007 and they hide this from the
boards. The boards only know the issues on 4th May 2007 via a letter from external
auditor. This end up that the boards had fail to fulfil their responsibilities in

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overseeing the performance of the company and the company had breached the
Listing Requirement of the Exchange. The reputation of the company also affected as
the public was believe that the boards with the assistance of Audit committee will
ensure for the quality of reporting. However, it was not as what the public expected.

The boards have the responsibilities to oversee the risk management system to
ensure the internal control of the company. The boards of Transmile had passed the
responsibilities to the Audit committee to determine the adequacy of the company’s
internal control system. Since year 2014, Transmile had outsource the internal control
function however the sales and finance division was not under the service of the
internal control. It was happened since year 2014, the boards of Transmile had fail to
fulfil their responsible in risk management.

The sales and finance division are vital division related to revenue. The boards
should have to make sure adequate internal control on the divisions and also the
whole company. The fraud was happened since year 2014 where the sales is
overstated from year 2014 to years 2016. Inadequate of internal control in sales and
finance division should be one of the reason that letting a chance for the fraud to be
conduct. The boards fail their responsibilities in risk management in the company and
fail to appoint a committee which are competence in carry out the responsibilities
given.

In conclusion, the boards of director have the responsibilities on the fraud that
occurred. The boards play an important role in overseeing the management and
performance of the company. They have to ensure and implement adequate internal
control for the company to prevent any fraud. “Prevention is better than cure”, even
though the BOD have formed a special audit to investigate the issues found after
informed by the external auditor. However, it have been late for them to notice.

We are recommend that the BOD should practice the principles of corporate
governance. The boards should carry out their responsibilities at their own instead of
pass all the responsibilities to the agents. The boards should have the self-awareness
in carry out their duty and be more proactive in communication with the audit
committee, internal and external auditors. The boards have to make sure the

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information reached is relevant and in a right timing. The boards have to make sure
the audit committee and auditors being appoint are competence in carry out the
responsibilities given. Evaluation of the boards should be implemented too to ensure
for the quality of monitoring of the management of the company.

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3.0 Audit Committee
The members of audit committee in Transmile Group Berhadare:
 Mr. Chin KeemFeung, the head of the audit committee
 Mr.Shukri bin Sheikh Abdul Tawab, independence non- executive of Transmile
Group
 Mr.Khiudin bin Mohd@ Bidin, former executive director ofTransmile Group

Under Section 320.5 Companies Act an audit committee is required for all
companies listed on the Bursa Malaysia Securities. Under the Bursa Malaysia
requirements, the audit committee should comprise at least three directors, and all
members must not be executive directors of the company or any related corporation.

Section 94 of the Companies Act determines that the audit committee must
consist of at least three members who must be directors of the company and not:
 be involved in the day to day management of the company for the past financial
year;
 be a full-time employee for the company for the past 3 financial years;
 be a material supplier or customer of the company such that a reasonable and
informed third party would conclude in the circumstances that the integrity,
impartiality or objectivity of that director is compromised by that relationship; and
 be related to anybody who falls within the above criteria.

The audit committee can consist of as many members as the company wishes
to appoint (but at least three), but each member must meet the criteria and must be a
director of the company. The audit committee may utilise advisors and obtain
assistance from other persons inside and outside of the company. The audit committee
may also invite knowledgeable persons to attend its meetings. However, the formally
appointed members of the audit committee entitled to vote and fulfil the functions of
the audit committee will have to meet the criteria (non-executive independent
directors) in accordance with the prescribed requirements.

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3.1 Role of Audit Committee
Audit committee is a selected number of members of a company’s board of
directors whose responsibilities include helping auditors remain independent of
management. Audit Committee in Transmile play a lot of roles rather than only
carrying their statutory duties and responsibilities relating to accounting and reporting
practices of the company and its subsidiaries. Based on the Annual Report in 2005,
audit committee also evaluates and monitors the financial process. They also provides
assurance that financial information provided by management is relevant, reliable and
timely. Besides, audit committee also determine the adequacy of the company’s
internal control system.

3.2 Issues about the Integrity of Audit Committee

Integrity is one of pre-require in auditing. It is essential that auditor act, and
are seen to act, with integrity, it is only need an honesty, it needs a broad range of
related qualities such as fairness, candour, courage, intellectual honesty and
confidentiality.

Integrity needs an auditor not affected, and not seen to be affected by conflict
or interest. Conflict may arise from personal, financial, business, employment and
other relationships which the audit engagement team, the audit firm or its partners or
staff have with the audited entity and its connected parties.

Integrity is very important since the director and management are rely on
auditor information obtained during the auditing since it is confidential. Without
integrity, there is danger that director and management will fail to disclose such
information to the director and the effectiveness of the audit will thereby be impaired.

In Transmile case, one of the audit committee is the former executive director
of the company. This is against the Act of Companies, which will have conflict
interest that will affected the independent of the member. The audit committee were
alerted several times by external auditor which is Deloitte & Touch about the
accounting issue found in the company’s unaudited 4th quarter of 2006 report. Even
though the audit committee knowing the external auditor’s concern, they are still

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ignore the concern and went to seek board of director consideration to release
unaudited annual report. What making the situation more worst is, audit committee
and top executives did not inform the BOD about the unaudited report. Here, we can
see that the audit committee have no integrity, they have failed in perform their
fiduciary duties to alert the board.

3.3The issue of Effectiveness and Independence

Independence in auditing means taking an unbiased viewpoint in the
performance of audit tests, the evaluation of the results and issuance of audit reports.
For example if an auditor is an advocate for the client, a banker or anyone else, he or
she cannot be considered independent.

They are two type of independence in fact and independence in appearance

(Section 290.6, MIA Law). Independence in fact existed when the auditor is actually
able to maintain an unbiased attitude throughout the audit, whereas independence in
appearance is the result of other’s interpretation of this independence. The value of
auditing depends heavily on the public perception of the independence.Theauditors
not only must be independence in fact, but they must also be independence in
appearance. If auditors are independence in fact but users believe them to be
advocates for the client, most of the value of the audit function will be lost.

In this case, public believe with the present of the independence director in
audit committee, the quality of monitoring would be increased but what happen is
opposite, that is the independence auditor had knowingly permitted the making of
misleading statements to Bursa Malaysia which breached the Listing Requirement of
the Exchange when the unaudited report on fourth quarter of financial year ended has
been released.

3.4 Issue of Competency

Competence is closely related to due care in the performance of professional
duties. Competence requirement means that a member should have formal education
in accounting, adequate practical experience for the work being performed, and
continuing professional education. While due care means that member is a

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professional responsible for fulfilling his or her duties diligently and carefully. Due
care includes consideration of the completeness of the working papers, the sufficient
of audit evidence, and the appropriateness of the audit report. As a professional, the
auditor must avoid negligence and bad faith, but the auditor is not expected to make
perfect judgments in every instance. Under MIA law Section 410, the law implies an
accountant to observe the professional’s technical and ethical standards, strive
continually to improve competence and the quality of service through Continuing
Professional Education (CPE) and discharge professional responsibility to the best of
his or her ability.

The audit committee have been assign to determine the adequacy of the
internal control of the Transmile. Prior to year 2004, audit committee was helping the
Internal Audit Department in overseeing the internal control system. Beginning from
the middle of year 2004, the internal audit function of Transmile have been outsource.
The internal service that been outsource was not cover the sales and finance division
and also reviewing of the financial statement. As the audit committee of a listed
company, the member should be have the competency in overseeing the internal
control. The audit committee should have the ability and knowledge in determine the
adequacy of internal control in the company. However, the audit committee had failed
to meet the competency. They should know the lack of internal control in the sales
and finance division. They have failed the responsibilities being given.

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4.0 Internal Auditor
In middle of 2004, Transmile had outsourced its internal audit function to
Moores Rowland Risk Management Sdn Bhd, which is an independent professional
firm. Prior to 2004, the Audit Committee was assisted by the Internal Audit
Department in overseeing the internal control system of the company.

The role internal audit is to provide independent assurance that includes

detecting and preventing fraud, testing internal control, and monitoring compliance
with company policy and government regulation. Internal auditor reports to the board
and senior management who are within the organizations governance structure. A
small business might not be able to afford to have an own internal auditor but for
Transmile, it came to question why a large capitalized company to outsource its
internal audit works to a third party, Moores Rowkland Risk Management Sdn Bhd
against norm of having it done internally.
Accordance to International Standard for Professional Practice of Internal Auditing
(IPPF), engagements must be performed with proficiency and due professional care
(IPPF 1200).

From IPPF 1220 – Due Professional Care

Internal auditors must apply the care and skill expected of a reasonably prudent and
competent internal auditor. Due professional care does not imply infallibility.

IPPF 1220. A1- Internal auditors must exercise due professional care by considering
the:
 Extent of work needed to achieve the engagement objectives
 Relative complexity, materiality, or significance of matters to which assurance
procedures are applied
 Adequacy and effectiveness of governance, risk management and control
processes
 Probability of significant errors, fraud, or noncompliance, and
 Cost of assurance in relation to potential benefits.

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 Generally, internal auditors help organisations to succeed. The assurance part
of internal auditor’s work involves telling managers and governors how well the
systems and processes designed to keep the organisation on track are working. Then,
internal auditor offer consulting help to improve those systems and processes where
necessary. Internal auditors should deal with issues that are core important to the
survival and success of any organisation. Unlike external auditors, they look beyond
financial risks and statements to consider wider issues such as the organisation's
reputation, growth, its impact on the environment and the way the company treats its
employees.

When it comes to activities that relate to internal control, the internal audit
function had to evaluate the internal control by reviewing controls, evaluating their
operation and recommending improvements thereto. In doing so, the internal audit
function provides assurance on the control.For example if a line manager is concerned
about a particular area of responsibility, working with the internal auditor could help
to pinpoint improvements or perhaps a major new project is being undertaken, the
internal auditor can help to ensure that project risks are clearly identified and
approached with action taken to administer them.

However, Audit Committee had limited the scope of auditing of Moores only
on several specific areas and not expanded to some critical areas such as the sales and
finance divisions of the company. Hence, it did not cover the review of financial
statement. Therefore, the internal auditor’s work did not cover the review of financial
statement.

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5.0 External Auditor
5.1Issue on Low Audit Fees
The Malaysian Institute of Accountants (“MIA”), had in 2010, issued a
Recommended Practice Guide 7 (Revised) on the charging of audit fees. This is a
replacement to the earlier practice guide issue in 2007. All auditors in Malaysia are
required to abide by this practice guide. The purposes of issuing this Practice Guide
are because of the following reasons:
i. Increased in compliance burden due to higher auditing standards requirements
ii. Increased in operating costs, mainly salaries
iii. To ensure auditors professionalism are not affected due to “price wars” among
auditors

As a response to stakeholder concerns about downward pressure on fees being

a factor potentially adversely impacting audit quality, there are important
considerations in the Code of Ethics for Professional Accountants (the Code) for
auditors in relation to the setting of audit fees. This Code will be relevant to auditors
when considering tendering for a new audit engagement, or when proposing or
agreeing fees for recurring audit engagements. It may also be of interest to those
charged with governance, preparers, regulators and audit oversight bodies, investors,
and others with an interest or role in auditors’ work and their independence.

In this case, Deloitte & Touche have quoted its client an audit fee, which was
comparatively low. This could be Deloitte & Touche’s strategy to continue secure
auditing assignments from Transmile. Yet, from another point, it could be seen as fear
of losing the client, especially with the intense competition from the other audit firms.
According to the accountants, evidence of low audit fees by Deloitte & Touche could
be found in the case of Transmile where in 2006 and 2005, the fees were RM150,000
and RM73,000 when revenue were RM655.8 million and RM356.4 million
respectively. However, when the audit was taken over by KPMG in 2007, the fees
shot up to RM280,000 while the revenue dropped to RM616.2 million. The practice
of setting the fees so low could compromise the principle of competence and due care
as auditors might be in difficulty to perform their duties satisfactory.

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 In my opinion, Deloitte & Touche should not quoted Transmile a low audit fee
just because of fear of losing Transmile or to continue secure auditing assignments
from Transmile. Although Deloitte & Touche have a long-term relationship with
Transmile for a number of years, based on the Code of Ethics for Professional
Accountants, auditors should set an audit fee which is reasonable and acceptable
without affected by other factors such as the relationship between auditors and clients.
Besides, the low audit fees might give the wrong impression to other people that the
quality of the audited report is bad and it might affect the reliability of users on the
audited report. Based on the Recommended Practice Guide 7 (Revised), it gives a
guidelines to auditors on the charging of audit fees in order to increase in compliance
burden due to higher auditing standards requirements, increase in operating costs,
mainly salariesand to ensure auditors professionalism are not affected due to “price
wars” among auditors. Therefore, Deloitte & Touche should consider this guideline in
order to set a reasonable audit fee to clients as reduced audit fees can present
problems in terms of quality and it might raise auditor independence issues or may be
ineffective.

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5.2 Issue the Long Term Relationship between Deloitte& Touch and
Transmile Group
Other than competence and due care, another things to concern was the
integrity and theindependence of external auditor. As referred to the case Deloitte&
Touch and Transmile Group have a very long relationship that is more than a decade.
This can be proven or supported by the statement given by ChalyMah Chee Kheong,
Chief Executive Officer (CEO) for Asia- Pacific of Deloitte& Touch said “We have
been serving them for a number of years, even before their initial public offering”.

What bothers in this case is the relationship between Deloitte and Transmile
Group. This relationship could to a certain extent, pose familiarity threat. Familiarity
could negatively affect the auditor’s independence of mind and therefore their
auditing quality. Chief Consultant at Alliance IFA (M) Sdn. Bhd explained, “When
the auditor go for a job, there is a presumption in their mind that everything is in good
faith”. The value of auditing depends heavily on the public perception of the
independence of auditor. In auditing process there are two types of independence that
are independence in fact and independence in appearance.

Independence in fact exist when the auditors be able to maintain unbiased

attitude throughout the audit, whereas independence in appearance is the result of
others’ interpretation of this independence. Deloitte might look independence in fact,
but independence in appearing they were not. This is due they already served with
Transmile Group for number of years before Transmile was listed in KLSE. The long
relationship definitely could effects auditor independence and the quality of audit
report. This can be supported when Deloitte& Touch seemed to be relying on the
auditing fees of the Transmile Group, especially with the intense of competition in the
market, and it could be the reason why they have been hesitating to report the
overstatement to the authority.

The concept of independence is abstract and easily be misinterpreted or

manipulated. Relationship with clients, direct or indirect, financial or otherwise can be
perceived to impair both form of independence.

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 While integrity means adherence to moral and ethical principles, soundness of
moral, character or simply honesty. Every professional job need to integrity. For
example, a medical doctor is expected to have high integrity, objectivity to observe
professional standard and have to act in public interest. However, one difference
between auditors and others professional s need not be concerned about is the
remaining and independent. Independence must certainly be most critical
characteristic.

In my opinion, the action replace Deloitte with KPMG is a correct and

appropriate action since Transmile was eroded by the irregularities. Yes, it’s true that
Deloitte might be the firm which discovered the problem but it’s still not justifiable to
continue its service as the problem was tracked back to 2005 and the quantum was
huge.

This is not a small issue such as student who didn’t do his homework, but a
catastrophe which turned shareholders’ investment into red overnight. Even a student
who didn’t do his assigned homework would probably be punished, so Deloitte
should consider itself lucky to be able to continue its business without a single cent
poorer.

Transmile first notified in Bursa Malaysia that its auditors had trouble
verifying its account for the year ended 31 December 2006 on May 7, due to the
absence of some documents. Mah (executive of Asia-pacific) said in the course of an
audit, the external auditors rely only on the company’s management and board of
directors, who are tasked with the governance and overall responsibility of the
company.

Regardless whether the accounting irregularities was discovered because of a

sudden stringent audit process by Deloitte or because the worms were too huge to be
kept inside the can, the fact remains that Deloitte has failed in his duty to protect the
shareholders.

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5.3 Issue of Deloitte Judgement towards Transmile Due to Their
Long Relationship
Deloitte already served the Transmile Group for over than 10 years. During
their tenure to Transmile, of course the management will know the in and out of
auditing procedures done by the external auditor, Deloitte, so the issue here is there
might be the high possibility of management of Transmile manipulate the information
given by their company to Deloitte

They can hire their accounting department to create fictitious invoice and
dummy sale and so on, in other words, Transmile can abuse Deloitte as they know
how auditor works since they know very well how Deloitte works. In year 2004 and
2005, the report is released but the fraud cannot be detected. This might be due the
company might change their full set cycle of supporting document. The change of full
set cycle of supporting document can affect the materiality
How the materiality affected?

Let say the materiality is 1% of the revenue which is equal to RM12 million (
for the example) and auditors needed 60 samples of transaction that material and in
the year 2004 or 2005 and only find 25 samples material, so the remaining 35 samples
will take randomly on any the sales. Transmile might make the fictitious sale that
below their benchmark that is RM120 000. Therefore it will fall under “non-key item”
for sale. The sample is a lot but auditors can only choose a few.

Even auditors choose the samples without supporting document in 2004 and
2005, Deloitte might change the selected sample due to their long term relationship.
Any selected sample which are “non-key item”, the external auditor may just change
the sample if they found that the sample are lack of some supporting document.
Because of their long term relationship, the external auditor are believe that there will
be a possibility accept any explanation from management about the lack of document,
and they will just change the sample as they tend to bias towards materiality. If
Deloitte maintain use 1% materiality for more than ten years, no wonder the report in
2005 and 2004 can be released even they do not have enough supporting documents.

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As the management can be easy to manipulate and the judgement of external auditor
will be affected due to the long term relationship and trust towards the company.

5.4 Issue of late report fraud to BOD within 2 and half months
According to its 2005 Annual Report, the role played by Deloitte and Touche
was to “evaluate the overall financial statements presentation and ensure that they are
prepared in accordance with statutory requirements”. One of the roles of external
auditors in corporate governance is protecting the interests of shareholders. This is
possible because external audition reports are conducted independent of the
company’s influence. External auditors report the state of a company's finance and
attest to the validity of financial reports that may have been released. They ensure that
the board receives accurate and reliable information.

In this case, Deloitte &Touche had held regular discussions with the
management and the audit committee to address the accounting issues when they were
first discovered, but was to no avail. Finally, on 4 May 2007, via a letter, Deloitte
&Touche informed the BOD that they declined to approve the annual accounts as they
had not been able to obtain “relevant supporting documentation from the management
on certain transactions relating to trade receivables and related sales and additions to
property, plant and equipment so as to enable them to satisfy themselves on fairness
or validity of those transactions”. In response, on 7 May 2007, the BOD appointed
Moores Rowland Risk Management to conduct a special audit on issues raised by
Deloitte &Touche. An unaudited annual account was released in 2006 to Bursa
Malaysia was made but the report was released without the auditor’s concern over the
accounting issue had breached the Listing Requirements of the Exchanges and what
was more unfortunate is about how Deloitte react or responded to the matters. Deloitte
had failed in fiduciary duties to alert the board on the warning raised sooner after the
release of the unaudited results on 15 February 2007.

One of the roles of external auditors in corporate governance is protecting the

interests of shareholders. They ensure that the board receives accurate and reliable
information. In this matter Deloitte should informed BOD sooner in order to
protecting the interests of shareholders. If an external auditor detects fraud, it is his

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responsibility to bring it to the management's attention and consider withdrawing
from the engagement if management does not take appropriate actions. Normally,
external auditors review the entity's information technology control procedures when
assessing its overall internal controls. They must also investigate any material issues
raised by inquiries from professional or regulatory authorities, such as the local taxing
authority. As we can see after Deloitte informed BOD, BOD immediately appointed
special audit. So if Deloitte had informed earlier, maybe Transmile may be listed
company by now with released the audited financial report

Furthermore, Deloitte also should inform the security commission about this
matter. According to the Section 99E of Security Industry Act stated that “if an
auditor is of the professional opinion that there has been a breach of security laws or
rules of the exchange or any matter which may adversely affect the financial position
of the listed company, the auditor must immediately submit a written report on the
matter to the security commission”. The Securities Commission Malaysia (SC) is a
statutory body entrusted with the responsibility of regulating and systematically
developing the Malaysia’s capital markets. It has direct responsibility in supervising
and monitoring the activities of market institutions and regulating all persons licensed
under the Capital Markets and Services Act 2007. Therefore, before releasing the
unaudited report, SC had been informed and the action of charging audit committee
can be done earlier. However, Deloitte had failed to inform them.

The question that arises is whether there is a possibility conspiracy between

Deloitte and the audit committee of Transmile. There could be a tremendous pressure
on the auditor not to report to the security commission as per requirement of the
Section 99E since the audit committee played a role in selecting auditors, determining
their remuneration, dismissal or retention could be implicated if found guilty. The
conspiracy issue reinforced when the external auditors informed of the rejection of the
latest report is two months and 20 days late compared to the date of unaudited report
was release that is on 15 February 2007. Deloitte supposed told directly to the BOD
regardless after being ignored many time by the audit committee and top management
about unaudited reports.

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 In conclusion, Deloitte had failed to fulfil their role as external auditor of
listed company and protecting the interests of shareholders. Being late for 2 months
after releasing the unaudited report to Bursa Malaysia to Board of Directors and also
Security Commissions is unacceptable. Deloitte could have done earlier and save the
company for being delisting by 2011.

5.5 Audit Procedures and Practices

Integrity and Independance
Issue on the Materiality when audit work is performed
ISA 320 Para 9: Materiality Level for the Financial Statement as a Whole
When establishing the overall audit strategy, the auditor shall determine a materiality
level for the financial statements as a whole for purposes of:
(a) Determining the nature, timing and extent of risk assessment procedures
(b) Identifying and assessing the risks of material misstatement
(c) Determining the nature, timing and extent of further audit procedures.

ISA 320 Para 10: Materiality Levels for Particular Classes of Transactions,
Account Balances or Disclosures
When establishing the overall strategy for the audit, the auditor shall also consider
whether, inthe specific circumstances of the entity, there are particular classes of
transactions, accountbalances or disclosures for which misstatements of lesser
amounts than the materiality level forthe financial statements as a whole could
reasonably be expected to influence the economicdecisions of users taken on the basis
of the financial statements. In such circumstances, theauditor shall determine the
materiality levels to be applied to those particular classes oftransactions, account
balances or disclosures.

ISA 320 Para 11: Amounts Lower than the Materiality Level or Levels for
Purposes of Assessing Risks and Designing Further Audit Procedures
The auditor shall determine an amount or amounts lower than the materiality level for
the financial statements as a whole (and an amount or amounts lower than the
materiality level for particular classes of transactions, account balances or disclosures,

20
if applicable) for purposes of assessing the risks of material misstatement and
designing further audit procedures to respond to assessed risks.

Based on the case Transmile, Deloitte have been serving Transmile for more
than a decade and there was this concern about Deloitte independence due to the
long–term relationship. This long-standing relationship could however to a certain
extent pose the familiarity threats. Familiarity, could negatively affect auditors’
independence of mind and therefore their auditing quality.

If the auditor remain unchanged their method in determining materiality for

Transmile for over the decade, this could lead to management of Transmile abusing.
For example if Deloitte using 1% of revenue as the materiality level for the financial
statement as a whole and management of Transmile decided to “cook the book”,
culprits could create fictitious invoice under the materiality level once they has
forecast their revenue for the particular year.

During sampling test, it is divided into 2 parts which is key-value item and
non key value item. Key-value item consists of item above the material level and non
key-value item consist of item below the material level of the company. For every
single key-value item, auditors have to do vouching the entire cycle supporting
documents. Where else for non key-value item, this group of item consists of
numerous amounts of transactions and audit will only pick samples by sampling
method. Therefore if Deloitte does not change method of determine materiality, there
is opening opportunity for the management to abuse and create fictitious invoice for
dummy sales under the materiality level.

Besides, the familiarity with Transmile can cause auditor to change samples of
non-key value item when they did are unable to vouch full set of supporting
documents for the samples selected and hence this affect the integrity of auditor.
Using the same method and style to determine materiality over the decade could lead
to fraud among management level of clients. Therefore, determining the materiality of
a company during the planning of audit is very important.

21
Issue on the Sample Selection
ISA 530 Para. 6, 7, 8:
i. When designing an audit sample, the auditor shall consider the purpose of the
audit procedure and the characteristics of the population from which the sample
will be drawn.
ii. The auditor shall determine a sample size sufficient to reduce sampling risk to an
acceptably low level.
iii. The auditor shall select items for the sample in such a way that each sampling
unit in the population has a chance of selection.

ISA 530 Para. A4:

Audit sampling enables the auditor to obtain and evaluate audit evidence about some
characteristic of the items selected in order to form or assist in forming a conclusion
concerning the population from which the sample is drawn. Audit sampling can be
applied using either non-statistical or statistical sampling approaches.

Generally, every audit firms have created their own template for calculation of
samples during sampling test. Within this template, an auditor will key in account
balance of the item in financial statement, materiality, risk of material misstatement,
and multiplier of samples. Automatically, template will calculate the numbers of
samples selected for testing.

In the case, Deloitte have been auditing Transmile for over a decade and have
been a long-standing relationship. Usually when auditors have good faith in their
clients due to long term relationship, they will tend to reduce the multiplier and risk of
material misstatement. If the risk of material misstatement (RMM) and multiplier of
samples being reduce to relatively low, number of samples selected to be tested will
be little too. If this were to happen, the chances of selecting the samples which is
fictitious invoice in case of Transmile will be low especially when the item is fall
inside non-key value item. For example, selecting 60 samples from 10,000 samples
will have less chance selecting the fictitious invoice and selecting 250 samples from
10,000 will have more chance an auditor came to detect the fictitious invoice.

22
Issue on why Auditor did not Report to SecuritiesCommission
Security Industry Act Para. 99E: Duties of Auditor of Listed Companies
(1) If an auditor, in the course of the performance of his duties as an auditor of a listed
corporation, is of the professional opinion that there has been a breach or non-
performance of any requirement or provision of the securities laws, a breach of any of
the rules of the stock exchange or any matter which may adversely affect to a material
extent the financial position of the listed corporation, the auditor shall immediately
submit a written report on the matter:
i. in the case of a breach or non-performance of any requirement or provision of
the securities laws, to the Commission
ii. in the case of a breach or non-performance of any of the rules of a stock
exchange, to the relevant stock exchange and the Commission
iii. in any other case which adversely affects to a material extent the financial
position of the listed corporation, to the relevant stock exchange and the
Commission.

Deloitte have found out serious accounting issues in the unaudited 4th Quarter
2006 report of Transmile 14th February 2007. Yet, Deloitte did not report the serious
accounting issues that might be adversely affects to a material extent the financial
position of Transmile to Securities Commission. The question here is whether it is
because the tremendous pressure on auditor not to report to Securities Commission as
per requirement of the Section 99E since audit committees which played a role in
selecting auditors, determining their remuneration, dismissal or retention could be
implicated if found guilty.

Although, auditor are appointed to audit Transmile by Audit Committee but it

is the responsibility of auditor to uphold integrity and independence as they
responsible not to audit committee but to the every shareholders of Transmile.
Therefore, whenever a serious accounting issue is found out by auditor, a
management letter must be send to board of directors to get clarification at very first
place and not by after two over months, 4th May 2007. If the board of directors were
to ignore, auditors still have to be responsible to other minority shareholders that does
not hold any position in the company by reporting it Securities Commissions.

23
Issue on the Level of Reliable of the External Auditor towards the
Internal Control
The International Standard on Auditing ISA 530 Audit Sampling is guidance for
auditor when they decided to use audit sampling in audit procedure. It consists of
statistical and non-statistical sampling method where auditor can use to design and
select the audit sample, performing test of control, test of detail and evaluating the
results from the sample. The sample size determine by auditor have to reduce the
sampling risk to a low level which are acceptable. The auditor shall select items for
the sample in a way that each sampling unit inside the population have the chance to
be choose.

The higher the sampling risk willing accepted by auditor the lower the sample
size will be selected. Sampling risk is normally related to the internal control, the test
of control and the test of detail that will conducted by the auditor. For tests of controls
normally auditor will makes an assessment of the expected rate of deviation based on
the auditor’s understanding of the relevant controls or on the examination of a small
number of items from a population.

The purpose of assessment is to design audit sample and to determine sample

size. If the expected rate of deviation is unacceptably high, the auditor will normally
decide not to perform tests of controls. Similarly, for tests of details, the auditor
makes an assessment of the expected misstatement in the population. If the expected
misstatement is high, 100% examination or use of a large sample size may be
appropriate when performing tests of details.

From the ISA 530, we are clear that the auditor in selecting the sample size for
testing is always depend on sample risk that willing to accept and always related to
the effectiveness of the internal control of a company. Normally, the more assurance
the auditor intends to obtain from the operating effectiveness of controls, the lower
the auditor’s assessment of the risk of material misstatement will be, and the larger
the sample size will need to be. When the auditor’s assessment of the risk of material

24
misstatement at the assertion level includes an expectation of the operating
effectiveness of controls, the auditor is required to perform tests of controls.

In the case of Transmile, since year 2004, the internal controlof the company
have been outsourced to Moores Rowland Risk Management Sdn Bhd. However, the
sales and finance division of the company are not under the area of service for the
internal audit. It means that the internal control for the sale and finance division is less
as compared to other division in the company. We always clear that sales is always
directly affected to the revenue of a business. Transmile have been overstated its
revenue in a total of RM530 million since year 2004 till year 2006. This amount had
turn the Transmile financial position from a gain to a loss. So, we are questioning on
the quality audit work that been done by the external auditor, Deloitte.

The external auditor should be noted that the sales and finance division are not
included in the outsource service of internal audit since year 2014. It means that the
audit work especially the audit procedure, test of control, test of detail and the level of
accepted sample risk will be different as compared to before year 2004 due to the
change of the effectiveness control of the divisions. We will questioning are the
external auditor doing differently since year 2004 in order to obtain more assurance.
However, from the explanation of the ChalyMah Chee Kheong (CEO Deloitte), we
believe that external audit still performing inadequate of audit work in this case.

Mah explain that their audit work tend to bias towards large items which are
material, and he further explain that the responsibilities of ensuring proper internal
control system and accurate accounting record lies with the directors and management
of a company. From the explanation of Mah, it can be seen that audit work done by
the external auditor was tend to rely or highly rely on the internal control of the
company. We can believe that this trust of Deloitte towards management of Transmile
might due to their long term relationship. We believe that Deloitte designing the audit
procedure tend to referring to the prior year (before year 2004) working style. That
will be the possible reason why Deloitte unable to discover the overstatement in year
2004 and year 2005. Referring to the ISA 530, the effectiveness of the internal control
will affected the level of sample risk of the audit procedure. Since year 2004, the

25
structure of the internal control of Transmile have been changed. The audit procedure
designed should be different.

Therefore, we are believe that external auditor have the big responsibilities on
this matter which their inadequate audit work since 2004 have make them fail to
discover or prevent the fraud.As an auditor conducting an audit in accordance with
ISA is responsible for obtaining reasonable assurance that the financial statements
taken as a whole are free from material misstatement, whether caused by fraud or
error.In accordance with ISA 330, the auditor shall design and perform further audit
procedures whose nature, timing and extent are responsive to the assessed risks of
material misstatement due to fraud at the assertion level.

Issue on Communicate to the Board of Directors

Referring to the ISA 240, the external auditor has the obligation to communicate to
the management level and with those charged with corporate governance when they
have identify the possibility of fraud during conducting of the audit work. If the
auditor has identified a fraud or has obtained information that indicates that a fraud
may exist, the auditor need to communicate these matters on a timely basis to the
appropriate level of management in order to inform those with primary responsibility
for the prevention and detection of fraud of matters relevant to their responsibilities.

If the auditor suspects fraud involving management, the auditor shall

communicate these suspicions to those charged with governance and discuss with
them the nature, timing and extent of audit procedures necessary to complete the audit.
The auditor shall communicate with those charged with governance any other matters
related to fraud that are, in the auditor’s judgment, relevant to their responsibilities.

As stated in the ISA 240, we noted that the timely basis is a vital element
when the external auditor informed the management level or those charged with
corporate governance there are possibility of fraud. Based on the Transmile case, the
external auditor have fail to meet the timely basis when they communicate to the
Board of Directors. On 14th and 15th February 2007 external auditor have informed
the Audit Committee of the Transmile relate to the serious accounting issue found in

26
the fourth quarter 2006 unaudited report. The issue was not immediately highlighted
to the BOD. After two and half months, on 4th May 2007 external auditor only
communicate to the BOD about the accounting issue found.

The timely basis was not follow by the external auditor. They do not have any
further action during the two and the half months. The decision of audit committee
failed in fiduciary duties to alert the board on the warning raised had given to a
suspicion that something sinister was going on. The external auditor should able to
identify the suspicion that something sinister was going on among the audit
committee. The external auditor should inform the board in a timely basis. The
external auditor should have further action within the two month. Therefore, the
external auditor had fail their responsibilities to inform the board on timely basis.

Issue on Communication to Securities Commission

Referring to the ISA 240, external auditor can communicate to Regulatory and
Enforcement Authorities when if they found that the fraud in a company which is
involving the managementand also those charged with corporate governance. If the
auditor has identified or suspects a fraud, the auditor shall determine whether there is
a responsibility to report the occurrence or suspicion to a party outside the entity.

Although the auditor’s professional duty to maintain the confidentiality of

client information may preclude such reporting, the auditor’s legal responsibilities
may override the duty of confidentiality in some circumstances. In the exceptional
circumstances where the auditor has doubts about the integrity or honesty of
management or those charged with governance, the auditor may consider it
appropriate to obtain legal advice to assist in determining the appropriate course of
action.

Based on the case Transmile, with the explanation from Mah, “I don’t believe
we have done a bad job as far as Transmile is concerned. At the end of the day, it was
our stringent audit processes that led us to discover the accounting irregularities. If
our quality of work were really that bad, we probably would not have discovered
them.” It shows that external audit was able to identify the overstatement or the fraud.

27
 Based on the Section 99E of the Securities Industry Act, “if an auditor is of
the professional opinion that there has been a breach of securities laws or rules of the
exchange or any matter which may adversely affect the financial position of the listed
company, the auditors must immediately submit a written report on the matter to the
Securities Commission.” With the explanation of Mah, the external auditor had failed
to follow the ISA 240 and also the Section 99E. We will questioning why there are no
have further action from the external auditor during the two and the half months
period. The external auditor are able to identify the overstatement which will
adversely affect the financial position of Transmile, however a written report was not
submitted to the Securities Commission. Therefore, the auditor have failed their
responsibilities in this audit work done procedure.

Issue On Audfit Rotation

Referring to the By-Laws (On Professional Ethics, Conduct and Practice) of the
Malaysian Institute of Accountants Section 290: Independence – Audit and Review
Engagement, stated that in respect of an audit of a public interest entity, an individual
shall not be a key audit partner for more than five years. After such time, the
individual shall not be a member of the engagement team or be a key audit partner for
the client for two years.

During that period, the individual shall not participate in the audit of the entity,
provide quality control for the engagement, consult with the engagement team or the
client regarding technical or industry-specific issues, transactions or events or
otherwise directly influence the outcome of the engagement.Key audit partners whose
continuity is especially important to audit quality may, in rare cases due to unforeseen
circumstances outside the firm’s control, be permitted an additional year on the audit
team as long as the threat to independence can be eliminated or reduced to an
acceptable level by applying safeguards.

Based on the case Transmile, the external auditor, Deloitte have served
Transmile for more than 10 years. Referring to the Section 290, there should be
rotation of the partner and also the audit team in Deloitte to serve the Transmile
Group Berhad. Rotation of the key audit partner and audit team beside to maintain the

28
independence and integrity, it is also for the purpose of maintaining the quality of
audit work done. With the explanation of Mah, Deloitte have high familiarly with the
operation of the Transmile. The audit team from Deloitte will be tend to more relies
and tend to more confident to the management of the Transmile. It is the nature of
human, things will be easier when we have high familiarly. Deloitte failed to discover
the overstatement in year 2004 and year 2005 we can believe that the trust and
familiarly towards Transmile had affected their professionalskepticism and judgment
throughout the audit process.

29
6.0The Research Analysts
Transmile had always been one of the favorite companies for investors and
analysts alike. Its share price had risen by 428.3% since 2003 and the role of analysts
had always maintained bullish views on Transmile.

The role of analyst is to prepare investigative reports on equity securities. The

research carried out by the research analyst is in an effort to investigate, examine,
discover or revise facts, principles and theories. The analyst prepares the report could
contain an analysis of equity securities of companies or industries.
Accordance to the rule 3400 Research Restriction and Disclosure Requirements, it
establishes requirements that analysts must follow when issuing research reports or
making suggestions. These requirements defined that the minimum procedure
requirements that Dealer Members must be fulfil to minimize potential conflicts of
interest. Therefore, disclosure requirements under Rule 3400 must be clear and
comprehensive.

In this case, the research analysts did not do their study or research completely
and had caused few mistakes or errors that had led the investors to think that the
analysts’ reports are reliable. These mistakes have influenced the investors’ decision
making in making investments and have caused the unconscious herd instinct. The
following are the mistakes done by the analysts.

i. Indicatorsthat could have material effect on the investors’ decisions in

making investment were missing from analysts’ reports

While many analysts were focused on the earnings and company’s prospects,
there were other indicators that could have a material effect on the investors’
decisions to invest in the company but were largely missing from many analysts’
reports. The analysts should be alert on the unusual growth and the amount showed in
the financial statement as these might be the indicator that could have a material effect
on the investors’ decisions to invest in the company. In addition, the analysts should
perform additional works and research to ensure if there are possible indicators that is
material to the investors’ decision making. Analysts should also go in deep to study

30
and investigate the company before compiling their report. They should go to the
company for site visit, meet up with the staffs, and contact the CEO of the company in
order to find out the possible indicators. The analysts play an important role in stock
market, most of the investors will make their decision whether to invest in that
particular company based on their report. Thus, all the reports that they prepare need
to be complete and obtain as many information as possible including the indicators
that could have material effect on the investors’ decisions in making investment.

ii. Lack of prudential and alert on Transmile’s trade receivables

Despite being a strong growth company, Transmile had not really been able to
turn its sales into cash. Transmile’s trade receivable had been building over the years
with trade receivables for 2006 were reported at RM381.2 million, which was a 243%
jump or RM270.1 million more than the previous year, while growth in 2005 was 5%
and 2004, 46.1%. With revenue recorded increase of 80% or RM439.1 million during
the same year 2006, receivables accounted for much more of the company’s revenue
growth. Since trade receivables could have influence on the profitability reported, it
would be prudent for analyst to be on the alert as these trade receivables could easily
be reclassified as doubtful debts.

Based on the article from Business Times by Kang Siew Li, it stated that “An
analyst who declined to be named said it appears that there was a deliberate attempt to
manipulate the account with a plan to deceive the board or shareholders.” Analysts
should be alert on these issue earlier and alert on Transmile’s trade receivables since
there are unusual growth rates or increments in Transmile’s financial statement. But,
the analysts have failed to do so in assessing the performance of Transmile. In
addition, Transmile said that following the final report, the assets of the company will
be adjusted downwards with the adjustments primarily in property, plant and
equipment, investment in associated company and trade receivables. Hence,it is
prudent for analyst to be on the alert as these trade receivables could easily be
reclassified as doubtful debts.

iii. The unconscious herd instinct caused by the assessments by the analysts
With such favorable assessments by the analysts, the influence on the share
price went without saying, as “when research houses are upbeat on a stock, most

31
 others tend to follow suit. And when investors are buying into a counter, others too
think it must be a good idea. It is called the unconscious herd instinct,” says a
seasoned investor. The analysts should take the responsibility and think one step
ahead of the effects that will cause if they publish their report. The analysts are like a
guidance for the investors because many investors will make the decision based on
the assessment made by the analysts. Besides, investors should not blame analysts if
they are losing money as the analysts are just giving their professional opinion based
on their study and research. Hence, the investor should know the risks when they
invest in this particular company based on the analysts’ report only.

iv. High reliability on the publicly available information without verification

Analysts too relied on the publicly available information obtained from
sources believed to be reliable but had not been independently verified by them, thus
no guarantee as to its accuracy, completeness or correctness. Meanwhile, investors
were supposed to seek financial advice regarding the appropriateness of investing in
the share assessed by the research house in its report. The assessments were actually
intended for information purposes only and not to be construed as an invitation to buy
or sell the shares referred.

Based on the articles from Asia Times, it indicated that “analysts wonder
whether it was merely a case of poor accounting standards or if management was
trying to hide something in the accounts. If it was merely bad bookkeeping, which
could be easily rectified, auditors most likely would not have held back on signing the
accounts,” they say. In my opinion, the analysts should have not rely on the audited
report only but perform some other procedures to obtain other reliable information to
verify and make an accurate assessment on the performance of Transmile as the
investors rely on these assessments made by the analysts.

In conclusion, research analysts can contribute to the reason of delisting

because analysts play a vital role in providing clear and reliable report to the potential
investor in order to help investor do their decision making based on the performance
of Transmile. It is important that research analysts possess professional skepticism
whereanalyst should question all things that happened towards the company. This
helps analyst to make sure that all review that they make is reliable.

32
7.0 Conclusion
There are many issues against the laws caused by the culprits. These culprits
should take their responsibilities in order to help and assist the company to handle the
problem faced by the company which is suspension and de-listing. The potential
factors should be solved as soon as possible so that the interest of the shareholders of
the company can be protected.
The potential factors may consists of the engagement of Transmilein the
illegal actionwhich is to cover up somefacts by reporting a higher profit than the
actual one. Whereas,the opportunistic action taken by the analysts and investorsis
investing in a growth potential business where they should actually be alert of overly
strong growth in companies, weakness in the internal control systems as well as
operational systems. The analysts and investors should not only rely on the publicly
available information but to do more studies and researches before making any
decisions.

In conclusion, it’s the responsibility of a listed company and its directors and
chief executive to prepare and present financial statements in accordance with
approved accounting standards issued or adopted by the Malaysian Accounting
Standards Board (MASB). Failure to fulfill this obligation is an offence. Furthermore,
the culprits should carry out their responsibilities and comply with regulations and
accounting standards in order to protect the innocent parties such as shareholders and
investors.

33
References
1. Kang Siew Li. “Transmile Audit Shows Losses in 2005, 2006.” Business
Times 19 June 2007.
http://www.malaysianbar.org.my/business_news/transmile_audit_shows_losse
s_in_2005_2006.html

2. Anil Netto. “Cooking the Books in Malaysia.” Asia Times 30 May 2007. Asia
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http://www.atimes.com/atimes/Southeast_Asia/IE30Ae01.html

3. Corporate Governance
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4. Corporate Governance
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5. International Standard on Auditing 530 Audit Sampling, December, 2009

http://www.ifac.org/system/files/downloads/a027-2010-iaasb-handbook-isa-
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6. International Standard On Auditing 240, 15 December, 2010

https://www.frc.org.uk/Our-Work/Publications/APB/ISA-240-The-auditor-s-
responsibilities-relating-to.pdf

7. MIA Handbook, Section 290

http://www.mia.org.my/handbook/bylaws/pIB290-150.html

8. International Auditing and Assurance Standards Board, ISA 320 & ISA 450,
15 Febraury 2007
www.paab.co.za/index.php/component/docman/doc.../255-ed-015-02

9. MIA Tchnical Staff, “Materiality in Planing & Performing Audit”, April,2012

http://www.mia.org.my/new/downloads/professional/audit/staff/2012/MI
A_Staff_Alert_No2_2012_Materiality_in_Planning_and_Performing_the
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10. International Auditing & Assurance Standards Board, “ISA 530, Audit
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https://www.icaew.com/~/media/corporate/files/technical/audit%20and%20ass
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drafted%20isa%20530.ashx

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11. “Auditors: To whom are the responsible?” , 25 September 2009
http://www.stuff.co.nz/business/blogs/stirring-the-pot/2904615/Auditors-To-
whom-are-they-responsible

12. “Amendments To Securities Laws”, 5 January 2004

http://www.sc.com.my/amendments-to-securities-laws/

35