Anti-Bribery Management Systems (ISO 37001)

Course overview

Course outline

1. 1Day 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
2. 2Day 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
3. 3Day 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
4. 4Day 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
5. 5Day 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