ISO 37001

ISO 37001

ISO 37001

A Practical Guide to Enhancing Organizational Integrity

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Organizational context

4.1 -Operational Framework

4.2 - Understanding the needs and expectations of stakeholders

4.3 - Determining the scope of the anti-bribery management system

4.4 - Anti-bribery management system

4.5 - Bribery risk assessment : Identification of Risks

4.5 - Bribery risk assessment : Sources of risks

4.5 - Bribery risk assessment : Identification of Risks

4.5 - Bribery risk assessment : Framework: relationships & control

4.5.2 - Analysis and Evaluation

4.5.3 - Existing Controls

4.5.4 - Monitoring and review

Leadership

5.1.1 - Commitment demonstrated by governing body

5.1.1 - Approval of anti-corruption policy

5.1.1 - Alignment of strategy and anti-corruption policy

5.1.1 - Review of anti-corruption management system

5.1.1 - Resource allocation

5.1.1 - Control over implementation and effectiveness

5.1.2 - Establishment and maintenance of the system

5.1.2 - System review

5.1.2 - Resource allocation

5.1.2 - Control and effectiveness

5.1.2 - Integration into management processes

5.1.2 - Communication strategies

5.1.2 - Promotion of anti-corruption culture

5.1.2 - Support for management functions

5.1.2 - Resource allocation for anti-corruption

5.1.2. - Anti-corruption communication strategies

5.1.2 - Promotion of reporting mechanisms

5.1.2 - Protection against retaliation

5.1.2 - Reporting to governing Body

5.2 - Anti-bribery policy : Explicit prohibition of corruption

5.2 - Anti-bribery policy : Compliance with laws

5.2 - Anti-bribery policy : Tailoring policy to organizational objectives

5.2 - Anti-bribery policy : Framework for anti-corruption objectives

5.2 - Anti-bribery policy : Manifestation of commitment

5.2 - Anti-bribery policy : Encouragement of reporting

5.2 - Anti-bribery policy : Continuous improvement

5.2 - Anti-bribery policy : Compliance function authority

5.2 - Anti-bribery policy : Consequences for non-compliance

5.3.1 - Top management responsibility

5.3.1 - Assignment of responsibilities and authorities

5.3.1 - Managerial compliance

5.3.2 - Anti-bribery compliance function : Role and authority

5.3.2 - Anti-bribery compliance function : Resource allocation

5.3.2 - Access to governing body and top management

5.3.3 - Decision maker conflict of interest : Managing conflicts of interest

Planning

6.1 - Ensuring system objectives achievement

6.1 - Preventing adverse effects

6.1 - Monitoring and evaluating system effectiveness

6.1 - Planning for risk management and improvement

6.2 - Anti-bribery objectives and planning to achieve them : Establishing anti-corruption objectives

6.2 - Anti-bribery objectives and planning to achieve them : Aligning objectives with policy

6.2 - Anti-bribery objectives and planning to achieve them : Measurability of objectives

6.2 - Anti-bribery objectives and planning to achieve them : Objectives reflecting organization and risks

6.2 - Anti-bribery objectives and planning to achieve them : Ensuring objectives are achievable

6.2 - Anti-bribery objectives and planning to achieve them : Organizing objective monitoring

6.2 - Anti-bribery objectives and planning to achieve them : Communicating objectives

6.2 - Anti-bribery objectives and planning to achieve them : Updating objectives

6.2 - Anti-bribery objectives and planning to achieve them : Retaining documentation on objectives

6.2 - Anti-bribery objectives and planning to achieve them : Specifying action plans for objectives

Resources & Competence

7.1 - Resource identification for system maintenance

7.2.1 - Competence : Determining personnel competencies

7.2.1 - Competence : Competency measures and evaluation

7.2.1 - Competence : Ensuring appropriate competencies

7.2.1 - Competence : Documenting competency evaluations

7.2.2.1 - Compliance with employment conditions

7.2.2.1 - Distribution and training on policy

7.2.2.1 - Disciplinary procedures for policy violations

7.2.2.1 - Protection for non-participation or reporting

7.2.2.2 - Procedures for high-risk positions

7.3 - Awareness and training : Regular anti-corruption training

7.3 - Awareness and training : Training high-risk business associates

7.3 - Awareness and training

7.4 - Communication : Internal and external communication process

7.4 - Communication : Policy availability and communication

7.5.1 - Documented information : Retention of required documented information

7.5.2 - Documented information : Accuracy of documented information

7.5.3 - Documented information : Documented information protection

7.5.3 - Documented information : Control of externally originated information

Operation and planning

8.1 - Operation and planning : Planning and control of anti-corruption processes

8.2 - Due diligence : Assessment of corruption risk

8.3 - Financial controls : Financial controls against corruption

8.4 - Non-financial controls : Non-financial controls against corruption

8.5.1 - Controls and due diligence for controlled organizations and business associates : Enforcement of anti-corruption system for associates

8.5.2 - Controls and due diligence for controlled organizations and business associates : Evaluating associates' anti-corruption controls

8.6 - anti-bribery commitments : Commitment of business associates to prevent corruption

8.7 - Gifts, donations and benefits : Procedures against improper benefits

8.8 - Managing inadequate anti-bribery controls : Handling unmanageable corruption risks

8.9 - Raising concerns : Facilitating corruption reporting

8.9 - Raising concerns : Confidentiality of reporting process

8.9 - Raising concerns : Allowance for anonymous reports

8.9 - Raising concerns : Protection against retaliation for reporting

8.9 - Raising concerns : Establishing a corruption concern point of contact

8.9 - Raising concerns : Familiarizing personnel with reporting procedures

8.10 - Investigating and dealing with cases of bribery : Investigating reported corruption concerns

8.10 - Investigating and dealing with cases of bribery : Actions required upon discovering corruption

8.10 - Investigating and dealing with cases of bribery : Empowering investigators

8.10 - Investigating and dealing with cases of bribery : Ensuring cooperation in investigations

8.10 - Investigating and dealing with cases of bribery : Reporting investigation outcomes to compliance

8.10 - Investigating and dealing with cases of bribery : Confidentiality of investigation results

8.10 - Investigating and dealing with cases of bribery : Independence of investigators

Performance evaluation, monitoring, measurement, analysis

9.1 - Determining monitoring needs and responsibilities

9.1 - Retaining monitoring and measuring documentation

9.1 - Evaluating anti-corruption outcomes

9.2.1 - Internal audit : Conducting internal audits

9.2.2 - Internal audit : Planning audit programs

9.2.3 : Internal audit : Audit design principles

9.2.4 - Internal audit : Ensuring auditor independence

9.3.1 - Management reviews : Conducting management reviews

9.3.1 - Management reviews : Outcomes of management reviews

9.3.1 - Management reviews : Communicating review results to governance body

9.3.2 - Management reviews : Governance body reviews of the system

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

9.4 - Review by the anti-bribery compliance function : Compliance function reporting frequency

10.1 - Improvement: Non-conformity and corrective action : Reacting to non-compliance

10.1 - Improvement: Non-conformity and corrective action : Implementing corrective actions

10.2 - Continuous improvement : Improving the management system

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