9.4 - Review by the anti-bribery compliance function : Ongoing assessments by compliance function

 The ISO 37001 Anti-Bribery Management Systems standard, instituted by the International Organization for Standardization in 2016, directs organizations globally in fortifying their anti-corruption frameworks. This standard is pivotal for both private and public entities of any size, focusing on active prevention, detection, and management of bribery risks.

How to Respond to This Question

To effectively conduct ongoing assessments of the anti-corruption management system, the compliance function should:

-   Establish Regular Audit Schedules  : Plan and implement regular audits to ensure continuous monitoring and assessment of the system’s effectiveness.

-   Use a Variety of Assessment Tools  : Incorporate diverse tools such as self-assessments, third-party audits, and feedback mechanisms to gather comprehensive data on system performance.

-   Evaluate Key Performance Indicators  : Define and review key performance indicators related to anti-corruption efforts to measure the effectiveness of the system continuously.

-   Update Compliance Strategies  : Based on the assessment outcomes, update the anti-corruption strategies and policies to address any identified gaps or risks.

-   Report to Senior Management  : Ensure that all findings and recommendations from the compliance assessments are reported to senior management for further action and decision-making.

For more detailed methodologies, organizations can refer to guidance from the [Agence Française Anticorruption](https://www.agence-francaise-anticorruption.gouv.fr) or standards such as ISO 37001, which provide frameworks for conducting effective compliance assessments.

Why It’s Important

Conducting ongoing assessments of the anti-corruption management system is crucial because:

-   Ensures Compliance  : Regular assessments help ensure that the organization complies with relevant laws and regulations, thus avoiding legal penalties.

-   Identifies Risks  : Continuous monitoring helps identify and mitigate potential corruption risks before they escalate into actual issues.

-   Enhances Credibility  : Demonstrating a commitment to rigorous compliance strengthens stakeholder trust and enhances the organization's reputation.

-   Drives Improvement  : Ongoing evaluations provide insights that help improve the effectiveness of the anti-corruption measures in place.

Examples

-   Example A  :

 -   Context  : A multinational corporation conducts quarterly compliance reviews.

 -   Action  : The compliance team uses analytics tools to assess transactions for signs of irregularities and tests the effectiveness of internal controls.

 -   Outcome  : The reviews lead to enhancements in the electronic monitoring system, significantly reducing the incidence of non-compliant transactions.

-   Example B  :

 -   Context  : A technology firm faces increased bribery risks in several high-risk markets.

 -   Action  : The compliance function implements a bi-annual risk assessment protocol, utilizing external consultants to evaluate and enhance the firm’s compliance measures.

 -   Outcome  : The firm revises its due diligence processes for third-party vendors, strengthening its defenses against potential bribery and corruption.

For further reading on effective compliance assessment practices, please explore resources from the [OECD](https://www.oecd.org) on anti-corruption standards and the [Transparency International Anti-Bribery Guidance](https://www.antibriberyguidance.org), which provide valuable insights and best practices for managing and assessing anti-corruption compliance functions.