Anti-Bribery Management Systems (ISO 37001)

Introduction

Bribery distorts markets, undermines trust and exposes organisations to criminal penalties, debarment and lasting reputational damage. Anti-bribery laws in many countries hold organisations liable for bribes paid by employees or intermediaries unless they can show adequate procedures to prevent them.

This Anti-Bribery Management Systems training course explains how to design, implement and maintain an anti-bribery management system aligned with ISO 37001, the international standard for anti-bribery management. Participants learn the structure and requirements of the standard, how to assess bribery risk, implement proportionate controls, conduct due diligence, manage gifts and hospitality, and monitor and audit the system.

The course also covers leadership commitment, the role of the compliance function, investigations and the steps involved in preparing for certification.

Course Objectives

By the end of this training course, participants will be able to:

• Explain the legal and business case for anti-bribery controls
• Describe the structure and key requirements of ISO 37001
• Conduct a bribery risk assessment
• Design anti-bribery policies, procedures and controls
• Apply due diligence to business associates and personnel
• Manage gifts, hospitality, donations and sponsorships
• Monitor, audit and review an anti-bribery management system
• Prepare an organisation for ISO 37001 certification

Target Audience

This training course is suitable for a wide range of professionals, including:

• Compliance and ethics officers
• Legal counsel and in-house lawyers
• Internal auditors
• Risk and governance professionals
• Procurement and sales managers
• Managers preparing for ISO 37001 certification

Training Methodology

The course mixes explanation of the standard with practical workshops. Participants carry out a bribery risk assessment, draft policy elements, apply due diligence to business associates, evaluate gifts and hospitality cases and plan an internal audit of the system. Case studies illustrate enforcement actions and lessons learned.

Target Competencies

• Bribery risk assessment
• Anti-bribery control design
• Business associate due diligence
• Gifts and hospitality judgement
• Management system auditing
• Certification readiness

Day One: Bribery Risks and the Legal Framework

• Forms of bribery: direct, indirect, facilitation payments and kickbacks
• Overview of major international anti-bribery laws
• Corporate liability and adequate procedures defences
• Business impact of bribery on organisations and society
• Lessons from significant enforcement cases
• The role of ISO 37001 in demonstrating good practice
• Quiz: recognising bribery in business scenarios

Day Two: Structure and Requirements of ISO 37001

• The management system structure and high-level clauses
• Context of the organisation and scope of the system
• Leadership, top management commitment and governing body roles
• The anti-bribery compliance function and its independence
• Anti-bribery policy and objectives
• Resources, competence, training and awareness
• Exercise: defining the scope of an anti-bribery system

Day Three: Risk Assessment and Operational Controls

• Bribery risk assessment methods and criteria
• Financial and non-financial controls against bribery
• Controls over sales agents, distributors and intermediaries
• Procurement and contract controls
• Gifts, hospitality, donations and sponsorships
• Raising concerns and whistleblowing arrangements
• Workshop: conducting a bribery risk assessment

Day Four: Due Diligence and Investigations

• Due diligence on business associates and transactions
• Due diligence on personnel in high-risk roles
• Anti-bribery commitments in contracts
• Handling red flags and refusing or terminating relationships
• Investigating and dealing with suspected bribery
• Documentation and record keeping requirements
• Exercise: due diligence on a proposed sales agent

Day Five: Monitoring, Audit and Certification

• Monitoring and measuring system performance
• Planning and conducting internal audits of the system
• Management review and governing body review
• Nonconformity, corrective action and continual improvement
• Preparing for certification audits
• Sustaining an effective anti-bribery culture
• Personal action plan for anti-bribery management