What is ISO 37001:2016 Anti-Bribery Management System?

ISO 37001:2016 is an international standard that sets forth requirements and provides guidance for establishing, implementing, maintaining, and improving an Anti-Bribery Management System (ABMS) within an organization. The standard is designed to help organizations prevent, detect, and address bribery-related activities.

ISO 37001 follows a risk-based approach, emphasizing the importance of understanding bribery risks specific to an organization and implementing appropriate controls to mitigate those risks. The standard provides a framework for organizations to establish anti-bribery policies, procedures, and controls to prevent bribery at all levels of their operations.

Some key elements of ISO 37001 include:

·       Leadership commitment

·       Risk assessment

·       Policies and procedures

·       Due diligence

·       Training and communication

·       Monitoring and investigation

·       Continuous improvement

Organizations can demonstrate their commitment to combating bribery, enhance their reputation, and improve their ability to conduct business with integrity with the help of ISO 36001 as it provides a systematic approach to managing bribery risks and helps organizations establish a strong anti-bribery framework.

Requirements of ISO 37001:2016

Anti-bribery policy: Organizations must establish an anti-bribery policy that is appropriate to the nature and scale of their operations. The policy should reflect the organization's commitment to comply with anti-bribery laws and regulations and its objectives for preventing bribery.

Leadership commitment: Top management is responsible for demonstrating leadership and commitment to the ABMS. This includes ensuring that the anti-bribery policy is communicated, understood, and implemented throughout the organization.

Anti-bribery risk assessment: Organizations must conduct a thorough assessment of bribery risks they face. This assessment should consider internal and external factors, including the industry, geographical locations, business associates, and the nature of the organization's operations.

Due diligence: Organizations should implement due diligence procedures to assess the bribery risks associated with their business associates, such as agents, suppliers, contractors, and joint venture partners. Due diligence should be performed during the selection and ongoing relationship with these parties.

Anti-bribery controls: Controls and measures should be established to mitigate identified bribery risks. These controls may include policies, procedures, and guidelines to prevent and detect bribery, as well as appropriate financial and non-financial controls

Financial and commercial controls: Organizations should implement financial and commercial controls to ensure the transparency and integrity of their financial reporting, record-keeping, and financial transactions.

Reporting and investigation: Procedures should be in place to encourage the reporting of potential bribery incidents and protect whistleblowers. Organizations should establish a process for investigating and appropriately addressing reported incidents.

Training and awareness: Adequate training and awareness programs should be provided to employees and other relevant parties to ensure their understanding of the organization's anti-bribery policies, procedures, and controls.

Communication: Organizations should establish effective internal and external communication channels to raise awareness of the ABMS and promote a culture of integrity and anti-bribery.

Monitoring and review: Regular monitoring and review of the ABMS should be conducted to evaluate its effectiveness and identify opportunities for improvement. Internal audits and management reviews are essential components of this process.

Continuous improvement: Organizations should strive for continuous improvement of their ABMS by taking corrective actions, implementing lessons learned, and updating their policies and procedures as necessary.

This standard is intended to help organizations establish a comprehensive framework for preventing, detecting, and addressing bribery within their operations. Compliance with these requirements demonstrates an organization's commitment to ethical business practices and anti-bribery efforts.

Benefits of ISO 37001:2016

Enhanced reputation and credibility: Certification to ISO 37001 demonstrates an organization's commitment to combating bribery and promoting ethical business practices. It enhances the organization's reputation and credibility in the eyes of stakeholders, including customers, business partners, investors, and regulatory bodies.

Improved risk management: ISO 37001:2016 requires organizations to conduct a thorough bribery risk assessment and implement appropriate controls. By identifying and mitigating bribery risks, organizations can better protect themselves from legal, financial, and reputational damages associated with bribery incidents.

Legal and regulatory compliance: This international standard is designed to align with international anti-bribery laws and regulations, such as the Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act. Implementing the standard helps organizations ensure compliance with these legal requirements, reducing the risk of legal penalties and sanctions.

Better business opportunities: Many government agencies, corporations, and international organizations prefer to engage with suppliers and business partners that have implemented robust anti-bribery measures. ISO 37001 can provide a competitive advantage, opening up new business opportunities and partnerships.

Improved internal controls and governance: The standard emphasizes the importance of establishing strong internal controls and governance mechanisms to prevent bribery. Implementing these measures can lead to improved transparency, accountability, and overall corporate governance within the organization.

Increased employee awareness and commitment: ISO 37001 requires organizations to provide anti-bribery training and awareness programs to employees. This helps to raise awareness about bribery risks and encourages a culture of integrity and ethical behavior among employees at all levels of the organization.

Effective third-party management: The standard emphasizes due diligence on business associates and the implementation of controls to prevent bribery in the supply chain. This enables organizations to select and manage reliable and trustworthy business partners, reducing the risk of being associated with bribery activities through third parties.

Continuous improvement: It promotes a cycle of continuous improvement through regular monitoring, evaluation, and review of the ABMS. This allows organizations to identify areas for improvement, implement corrective actions, and stay updated with evolving bribery risks and best practices.

Audit checklist for ISO 37001:2016 Anti-Bribery Management System

Leadership and commitment:

·       Is there evidence of top management's commitment to the ABMS?

·       Has an anti-bribery policy been established and communicated effectively?

·       Are roles and responsibilities defined for anti-bribery management?

Risk assessment and due diligence:

·       Has a comprehensive bribery risk assessment been conducted?

·       Is there evidence of due diligence procedures for assessing and managing business associates?

·       Are the results of risk assessments and due diligence activities documented?

Anti-bribery controls and procedures:

·       Are there documented procedures to prevent and detect bribery?

·       Are there controls in place to address bribery risks identified in the risk assessment?

·       Are financial and commercial controls implemented to ensure transparency and integrity?

Training and awareness:

·       Has training on anti-bribery policies and procedures been provided to employees?

·       Are there records of training sessions and attendance?

·       Is there evidence of ongoing awareness campaigns to promote a culture of integrity?

Reporting and investigation:

·       Are reporting mechanisms in place to encourage the reporting of potential bribery incidents?

·       Is there a documented procedure for investigating reported incidents?

·       Are whistleblower protection measures established and communicated?

Compliance with laws and regulations:

·       Is there evidence of compliance with applicable anti-bribery laws and regulations?

·       Are records maintained regarding compliance with legal requirements?

·       Are measures in place to stay updated on changes in anti-bribery laws and regulations?

Monitoring and review:

·       Is there evidence of internal audits to assess the effectiveness of the ABMS?

·       Are records of audits, including findings and corrective actions, maintained?

·       Is there a process for management review of the ABMS and its performance?

Continuous improvement:

·       Are corrective actions implemented to address identified non-conformities?

·       Are there mechanisms to capture and implement lessons learned?

·       Is there evidence of regular reviews and updates to the ABMS?

How to apply for ISO 37001:2016?


To apply for ISO 37001:2016 (ABMS) certification, follow these general steps:

Familiarize yourself with the standard: Obtain a copy of ISO 37001:2016 and thoroughly review its requirements, guidance, and implementation guidelines. Understand the scope and objectives of the standard to assess its applicability to your organization.

Conduct a gap analysis: Assess your organization's current anti-bribery practices and management system against the requirements of ISO 37001. Identify any gaps or areas that need improvement to meet the standard's criteria.

Develop an implementation plan: Based on the gap analysis, create a detailed plan outlining the steps, resources, and timeline required to implement an effective ABMS. Assign responsibilities to team members who will lead the implementation process.

Establish an anti-bribery policy: Develop an anti-bribery policy that reflects your organization's commitment to prevent bribery. Ensure the policy aligns with standard requirements and communicates your organization's stance against bribery to all stakeholders.

Implement the ABMS: Execute the implementation plan by establishing and implementing the necessary processes, procedures, controls, and documentation to meet the requirements of ISO 37001. This includes conducting a thorough risk assessment, implementing anti-bribery controls, providing training and awareness programs, and establishing reporting mechanisms.

Conduct internal audits: Perform regular internal audits to assess the effectiveness of your ABMS and identify areas for improvement. Ensure that the audit process is independent, objective, and covers all relevant aspects of the standard.

Corrective actions and improvements: Address any non-conformities identified during the internal audits by implementing appropriate corrective actions. Continuously monitor the performance of the ABMS and make improvements as necessary to enhance its effectiveness.

Select a certification body: Choose an accredited certification body that specializes in ISO 37001 certification. Research and select a reputable certification body based on their experience, expertise, and industry reputation.

Certification audit: Engage the chosen certification body to conduct an external certification audit. The audit will evaluate your ABMS's conformity with ISO 37001 requirements. It typically involves document review, interviews, and on-site inspections to assess the effectiveness and implementation of the ABMS.

Certification decision: Based on the certification audit results, the certification body will make a decision regarding the certification. If your ABMS meets the requirements, you will be awarded ISO 37001 certification.

Continual improvement and surveillance audits: After certification, maintain and continually improve your ABMS. The certification body may conduct surveillance audits at regular intervals to ensure ongoing compliance with the standard.

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