awareness training ISO 37001:2016 danang suryo freelance auditor, trainer consultan ISO 37001:2016, 9001, 14001, 18001, 22000, 22301, 27001,37001,45001, 50001 and smk3 . per day 2,5 juta 081567796679 08112999715

1. Implementation ISO 37001:2016
Danang Suryo Wardhono
081567796679/08112999715

2. Perkenalan Diri
▪ Name: Danang SuryoWardhono ST MM
▪ Occupation:
▪ RegisteredTrainer /auditor PECB,Trainer/ auditor management system
for certification body LRQA, Mutu Certification International, RINA,
Afnor Indonesia, IAPMO,TUV rheinland, pusdiklat gadjahmada, Bina
Profesi Institute, mutu institute, NQA,WQA, ITSTeknosains, ISQ,
Sucofindo etc
▪ LA IRCA /PECB certified ISO 9K, 14K, 18K, 22K, 22301, 27K, 37k, 45, 50 k
(waiting result), smk3 auditor, halal, BRC versi 8 auditor conversion, PAK
KPK etc
▪ Telp/WA: 081567796679, 08112999715
▪ danangsuryowardhono@gmail.com

3. Purpose of this Course
▪Understanding basic concept of Anti
bribery Management System
▪High level structure
▪Clause ISO 37001:2016
▪Minimum documentation needed

4. Learning outcome
▪ Participant will understand:
1. Purposes and benefit of ABMS (anti bribery Management System) ISO 37001:2016
2. Structure of ISO 37001:2016
3. PDCA (clausal 4-10)
4. Operation control

5. Training outline of day 1
topic time
Welcome and introduction 8.30-09.00
Anti bribery management system introduction 09.00-10.00
Clausal 1-4, scope, normative reference, terms and definitions,
context organization
10.00-12.00
Lunch 12.00-13.00
Clausal 5-7 leadership, planning, support 13.00-15.00
Break 15.00-15.15
Clausal 8 operation 15.15-16.15
Clausal 9 -10 performance evaluation , improvement 16.15-16.45
Wrapping and Closing 16.45-17.00

6. Training outline of day 2
Topic time
Refreshment clausal 4-10 08.00-10.00
Workshop e.g. Bribery Risk Assesment 10.00-12.00
Lunch 12.00-13.00
Group presentation 13.00-15.00
Break 15.00-15.15
Wrapping and closing 15.15-16.00

7. Background corruption in Indonesia
▪ Impact of corruption
▪ Definition
▪ Related compliance

31. CONTOH
• MALSUIN BUKU
ADMINISTRASI
• NGANCURIN BUKTI
• NGEBIARIN ORANG LAIN
NGERUSAK BUKTI
• NGEBANTU ORANG LAIN
NGERUSAK BUKTI

36. CONTOH
•
•

39. CONTOH
• PEMBORONG CURANG
• PENGAWAS PROYEK NGEBIARIN ANAK
BUAHNYA CURANG
• REKANAN TNI/POLRI CURANG
• PENGAWAS REKANAN TNI/POLRI CURANG
• PENERIMA BARANG TNI/POLRI
MEMBIARKAN KECURANGAN
• PNS NYEROBOT TANAH

43. CONTOH
• PN YANG NGIKUTAN PENGADAAN
BARANG YANG MUSTINYA DIA URUS

46. CONTOH
•PN MEMERIMA GRATIFIKASI GA LAPOR KPK

52. EDANG M KENDANA
Widyaiswara BPSDM Kemendagri
Hp. 0822 6066 2667
Email.kangedang@gmail.com
Rumah
Jl Ace Sukarna V No.17
Pasir Mulya Bogor

53. ENY SADYANTRI
Auditor Madya Inspektorat Kota Bogor
Hp. 0856 59320 999
Email.
mutiara.ensa@yahoo.com

54. ISO 37001:2016

55. • ISO 37001 is the new global standard for anti-bribery and corruption (ABC)
management systems. This means that, for the first time, there is an
internationally-recognized minimum set of measures for an organization to
have in place to prevent and detect bribery.
• It is designed for use in both the public and private sector, and we expect
to see international adoption by public sector organizations, that will, in
turn, require that organizations wanting to do business with them are
certified to the same standard.
• Source PECB white paper Navigant, ISO 37001: A GAME CHANGER FOR
BRIBERY COMPLIANCE

58. 1 Scope
• This document specifies requirements and provides guidance for
establishing, implementing, maintaining, reviewing and improving an anti-
bribery management system.
• This document is applicable only to bribery. It sets out requirements and
provides guidance for a management system designed to help an
organization to prevent, detect and respond to bribery and comply with
anti-bribery laws and voluntary commitments applicable to its activities.
• This document does not specifically address fraud, cartels and other anti-
trust/competition offences, money-laundering or other activities related to
corrupt practices, although an organization can choose to extend the scope
of the management system to include such activities.

59. 3 Terms and definitions
3.1 bribery
• offering, promising, giving, accepting or soliciting of an undue
advantage of any value (which could be financial or non-financial) ,
directly or indirectly, and irrespective of location(s) , in violation of
applicable law, as an inducement or reward for a person acting or
refraining from acting in relation to the performance (3.16) of that
person’s duties
• 3.5 management system
• set of interrelated or interacting elements of an organization (3.2) to
establish policies (3.10) and objectives (3.11) and processes (3.15) to
achieve those objectives

60. • 3.7 governing body
• group or body that has the ultimate responsibility and authority for
an organization’s (3.2) activities, governance and policies and to
which top management (3.6) reports and by which top management
is held accountable
• 3.8 anti-bribery compliance function
• person(s) with responsibility and authority for the operation of the
anti-bribery management system (3.5)

61. • 3.29conflict of interest
• situation where business, financial, family, political or personal
interests could interfere with the judgment of persons in carrying out
their duties for the organization (3.2)
• 3.30 due diligence
• process (3.15) to further assess the nature and extent of the bribery
risk (3.12) and help organizations (3.2) make decisions in relation to
specific transactions, projects, activities, business associates (3.26)
and personnel

62. • 3.26 business associate
• external party with whom the organization (3.2) has, or plans to
establish, some form of business relationship
• 3.27 public official
• person holding a legislative, administrative or judicial office, whether
by appointment, election or succession, or any person exercising a
public function, including for a public agency or public enterprise, or
any official or agent of a public domestic or international
organization, or any candidate for public office

63. 4. Context of the organization
• 4.1 Understanding the organization and its context
• 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
• Intention: Building an understanding and documenting the organization, as
well as the needs and expectations of its stakeholders. It stresses the
crucial risk assessment step in which the bribery risks are identified,
assessed and prioritized. The risk assessment must be documented, and
reviewed on a regular basis, including in the event of a significant change
to the structure or activities of the organization

64. • The organization should be aware that external and internal issues
can change, and therefore, should be monitored and reviewed. An
organization might conduct reviews of its context at planned intervals
and through activities such as management review.

65. • In planning their anti-bribery system, organizations must take steps to
identify and assess their bribery risks. Organizations are encouraged
to categorize risks into different levels, from low to high. For example
“Agents or intermediaries who interact with the organization’s clients
or public officials on behalf of it are likely to pose a “medium” or
“high” bribery risk, particularly if they are paid on a commission or
success fee basis.”

66. • The organization can then determine the type and level of anti-
bribery controls which apply to each risk category, and assess
whether existing controls are adequate. If not, the controls can be
appropriately improved. The organization may change the nature of
the transaction, project, activity or relationship such that the nature
and extent of the bribery risk is reduced to a level that can be
adequately managed by existing, enhanced or additional anti-bribery
risk controls. It follows that activities that the organisation determines
to be high risk, but that it cannot manage, should not be undertaken.

67. 5. Leadership
• 5.1 Leadership and commitment
• 5.1.1 Governing body
• 5.1.2 Top management
• 5.2 Anti-bribery policy
• 5.3 Organizational roles, responsibilities and authorities
• 5.3.1 Roles and responsibilities
• 5.3.2 Anti-bribery compliance function
• 5.3.3 Delegated decision-making

68. • The intent of this subclause is to ensure that top management
demonstrate leadership and commitment by taking an active role in
engaging, promoting, and ensuring, communicating and monitoring
the performance and effectiveness of the Anti bribery management
system. The ways it can be applied are based on various factors, such
as the size and complexity of an organization, management style and
organizational culture

69. 6.Planning
• 6.1 Actions to address risks and opportunities
• 6.2 Anti-bribery objectives and planning to achieve them
• The intent of this subclause is to ensure that when planning the Anti
Bribery management system processes, the organization determines
its risks and opportunities and plans actions to address them. Its
purpose is to prevent nonconformities, including nonconforming
outputs, and to determine opportunities that might enhance Anti
bribery performance or achieve an organization’s Anti bribery
objectives

70. 7.Support
• 7.1 Resources
• 7.2 Competence
• 7.2.1 General
• 7.2.2 Employment process
• 7.3 Awareness and training
• 7.4 Communication
• 7.5 Documented information
• 7.5.1 General
• 7.5.2 Creating and updating
• 7.5.3 Control of documented information

71. • The intent of this subclause is to ensure that the organization
provides the resources necessary for the establishment,
implementation, maintenance and continual improvement of the Anti
Bribery management system, and for its effective operation.
• In determining the resources that need to be provided, the
organization should consider the current capabilities of its internal
resources (e.g. people, capability of equipment, organizational
knowledge) and any constraints (e.g. budget, number of resources,
schedule).

72. • There must be adequate and appropriate training and communication
of the anti-bribery management system and documentation of the
information provided.

73. Specific in employment process
• The second is the requirement for due diligence on all personnel in
positions which are exposed to more than a low bribery risk, and to
all personnel employed in the anti-bribery compliance function.
Specifically:
• due diligence is conducted on persons before they are employed, and
on personnel before they are transferred or promoted by the
organization, to ascertain as far as is reasonable that it is appropriate
to employ or redeploy them and that it is reasonable to believe that
they will comply with the anti-bribery policy and anti-bribery
management system requirements;

74. 8. Operation
• 8.1 Operational planning and control
• 8.2 Due diligence
• 8.3 Financial controls
• 8.4 Non-financial controls
• 8.5 Implementation of anti-bribery controls by controlled organizations and by
• business associates
• 8.6 Anti-bribery commitments
• 8.7 Gifts, hospitality, donations and similar benefits
• 8.8 Managing inadequacy of anti-bribery controls
• 8.9 Raising concerns
• 8.10 Investigating and dealing with bribery

75. • The operational planning and control of ISO 37001 includes due
diligence, financial controls and non-financial controls. It covers the
reporting of suspected and actual bribery, as well as investigating on
and dealing with such findings.

76. • Due Diligence: Conducting checks of on certain transactions, projects,
activities, business associates, or an organisation’s personnel is a key
component of the standard, as it informs the decision on whether to
postpone, discontinue, or revise those transactions, projects, or
relationships with business associates or personnel. As expected, and
in line with all its requirements, the standard does not adopt the
‘one-size-fits-all’ approach, and due diligence must be weighted
according to risk.

77. • In relation to non-controlled business associates, for which the
bribery risk assessment or due diligence has not identified as low, the
organiation should obtain anti-bribery commitments, and require the
business associate to implement anti-bribery controls in relation to
the relevant transaction, project or activity.
• This might be limited to training, and controls over key payments and
gifts/hospitality. In the case of a major high bribery risk business
associate with a large and complex scope of work, the organization
might require the business associate to have implemented controls
equivalent to those required by ISO 37001. The organization will
normally impose these requirements on the business associate as a
pre-condition to working it, and/or as part of the contract document.

78. 9. Performance evaluation
• 9.1 Monitoring, measurement, analysis and evaluation
• 9.2 Internal audit
• 9.3 Management review
• 9.3.1 Top management review
• 9.3.2 Governing body review
• 9.4 Review by anti-bribery compliance function

79. • Organizations are required to review periodically the organization
compliance system, either via an independent internal audit or a
competent and independent third party. Such audits consist of internal
audit processes or other procedures which review procedures, controls and
systems for:
a. bribery or suspected bribery;
b. non-compliance with the anti-bribery policy or anti-bribery management
system requirements;
c. failure of business associates to conform to the applicable requirements of
the organization; and
d. weaknesses in or opportunities for improvement to the anti-bribery
management system.

80. 10. Improvement
• 10.1 Nonconformity and corrective action
• 10.2 Continual improvement

81. Mandatory procedures
• reporting procedures for suspected and actual bribery (5.1.2)
• procedures which enable it to take appropriate disciplinary action
against personnel who violate the anti-bribery policy or anti-bribery
management system (7.2.2.1)
• Employment process (7.2.2)
• Procedures in positions which are exposed to more than a low bribery
risk such as due diligence (7.2.2.2)
• The anti-bribery compliance declaration
• procedures addressing anti-bribery awareness and training for
business associates (7.3)

82. Mandatory procedures cont.
• Procedures controlling Implementation of anti-bribery controls by
controlled organizations and by business associates (8.5.2)
• Procedures addressing Anti-bribery commitments for business
associates which pose more than a low bribery risk (8.6)
• Procedures Raising concerns (8.9)
• Procedures Investigating and dealing with bribery (8.10)
• procedures which review procedures, controls and systems ABMS

83. • may also implement audit procedures to identify ways personnel may
exploit existing control weaknesses for personal gain A.8.4.4
• audit procedures for business associate (A13.3.6)
• Procedures to control the extent and frequency of gifts and
hospitality A.15.3

84. Mandatory documented
• Scope of the anti-bribery management system i.e. the certification scope (clause 4.3);
• identification, review and assessment of the bribery risks (clause 4.5);
• the anti-bribery policy, available in appropriate languages (clause 5.2);
• the measurable and achievable anti-bribery objectives (clause 6.2);
• competence of personnel (clause 7.2.1);
• awareness and training provided to employees and business associates (clause 7.3);
• evidence that processes have been carried out as planned (clause 8.1.);
• methods and result for monitoring, measurement, analysis and evaluation (clause 9.1.);
• the internal audit (clause 9.2);
• results of the top management reviews (clause 9.3.1);
• results of the governing body reviews (clause 9.3.2);
• control of nonconformities and corrective actions (clause 10.1).

85. A.17 Documented information
• The documented information under 7.5.1 may include:
• a) receipt of anti-bribery policy by personnel;
• b) provision of anti-bribery policy to business associates who pose more than a
low risk of bribery;
• c) the policies, procedures and controls of the anti-bribery management system;
• d) bribery risk assessment results (see 4.5);
• e) anti-bribery training provided (see 7.3);
• f) due diligence carried out (see 8.2);
• g) the measures taken to implement the anti-bribery management system;
• h) approvals and records of gifts, hospitality, donations and similar benefits given
and received(see 8.7) ;

86. • I)the actions and outcomes of concerns raised in relation to:
• 1) any weakness of the anti-bribery management system;
• 2) incidents of attempted, suspected or actual bribery;
• j) the results of monitoring, investigating or auditing carried out by
the organization or third parties.

87. Periodic review
❑periodic management review of significant financial transactions A 11
❑periodic and independent financial audits and changing, on a regular
basis, the person or the organization that carries out the audit.A 11
❑periodic summary report of any minor compliance function failure
indication

88. Peraturan terkait
• permenkeu 83 2015 pengendalian gratifikasi di lingkungan kementerian keuangan
• perpres 54 2018 tentang strategi nasional pencegahan korupsi
• permenpan rb 03 2013 tentang pedoman umum sistem penanganan pengaduan
(whistleblower system) tindak pidana korupsi di lingkungan kementerian
pendayagunaan aparatur negara dan reformasi birokrasi
• permenpan rb 10 tahun 2019 pedoman pembangunan zona integrase, perubahan
permenpan rb no 54 tahun 2012
• permenpan rb no 54 tahun 2012 pedoman pembangunan zona integritas menuju
wilayah bebas dari korupsi dan wilayah birokrasi bersih dan melayani di
lingkungan instansi pemerintah
• uu 20 2001
• per ma 13 2016

91. GRI 205:
Anti-corruption
• GRI 205 addresses the topic of anti-corruption. In this Standard,
corruption is understood to include practices such as bribery,
facilitation payments, fraud, extortion, collusion, and money
laundering; the offer or receipt of gifts, loans, fees, rewards, or other
advantages as an inducement to do something that is dishonest,
illegal, or represents a breach of trust. It can also include practices
such as embezzlement, trading in influence, abuse of function, illicit
enrichment, concealment, and obstructing justice.

92. GRI 205:
Anti-corruption
• The reporting organization should disclose the following information:
• 1.2.1 The organization’s risk assessment procedures for corruption, including the
criteria used in the risk assessment, such as location, activity, and sector;
• 1.2.2 How the organization identifies and manages conflicts of interest that
employees or persons linked to the organization’s activities, products, or services
may have. Conflicts of interest for the highest governance body are covered in
Disclosure 102-25 of GRI 102: General Disclosures;
• 1.2.3 How the organization ensures that charitable donations and sponsorships
(financial and in-kind) that are made to other organizations are not used as a
disguised form of bribery. Recipients of charitable donations and sponsorships
(financial and in-kind) can include not-for-profit organizations, religious
organizations, private organizations, and events;.

93. • 1.2.4 The extent to which communication and training on anti-
corruption is tailored to those governance body members,
employees, business partners, and other persons that have been
identified as having a high risk of incidents of corruption;
• 1.2.5 At which stage the training on anti-corruption for governance
body members, employees, business partners and other persons that
have been identified as having a high risk of incidents of corruption is
provided (e.g. when new employees join the organization or when
relationships with new business partners are established); and the
frequency of the training (e.g. annually or biannually);

94. • 1.2.6 Whether the organization participates in collective action to
combat corruption, including:
• 1.2.6.1 the strategy for the collective action activities;
• 1.2.6.2 a list of the collective action initiatives in which the
organization participates;
• 1.2.6.3 a description of the main commitments of these initiatives

95. Disclosure Operations assessed for risks
related to corruption
• The reporting organization shall report the following information:
• a. Total number and percentage of operations assessed for risks
related to corruption.
• b. Significant risks related to corruption identified through the risk
assessment.

96. Disclosure Communication and training about
anti-corruption policies and procedures
• a. Total number and percentage of governance body members that the
organization’s anti-corruption policies and procedures have been
communicated to, broken down by region.
• b. Total number and percentage of employees that the organization’s
anti-corruption policies and procedures have been communicated to,
broken down by employee category and region.
• c. Total number and percentage of business partners that the
organization’s anti-corruption policies and procedures have been
communicated to, broken down by type of business partner and region.
Describe if the organization’s anti-corruption policies and procedures
have been communicated to any other persons or organizations.

97. • d. Total number and percentage of governance body members that
have received training on anti-corruption, broken down by region.
• e. Total number and percentage of employees that have received
training on anti-corruption, broken down by employee category and
region.

98. Disclosure Confirmed incidents of corruption
and actions taken
• a. Total number and nature of confirmed incidents of corruption.
• b. Total number of confirmed incidents in which employees were
dismissed or disciplined for corruption.
• c. Total number of confirmed incidents when contracts with
business partners were terminated or not renewed due to violations
related to corruption.
• d. Public legal cases regarding corruption brought against the
organization or its employees during the reporting period and the
outcomes of such cases.

99. • collective action to combat corruption voluntary engagement with
initiatives and stakeholders to improve the broader operating
environment and culture, in order to combat corruption
• Note: Collective action to combat corruption can include proactive
collaboration with peers, governments and the wider public sector,
trade unions and civil society organizations.
• confirmed incident of corruption incident of corruption that has
been found to be substantiated
• Note: Confirmed incidents of corruption do not include incidents of
corruption that are still under investigation in the reporting period.

100. • conflict of interest situation where an individual is confronted with
choosing between the requirements of his or her function and his or her
own private interests
• corruption ‘abuse of entrusted power for private gain’,1 which can be
instigated by individuals or organizations
• Note: In the GRI Standards, corruption includes practices such as bribery,
facilitation payments, fraud, extortion, collusion, and money laundering. It
also includes an offer or receipt of any gift, loan, fee, reward, or other
advantage to or from any person as an inducement to do something that is
dishonest, illegal, or a breach of trust in the conduct of the enterprise’s
business.2 This can include cash or in-kind benefits, such as free goods,
gifts, and holidays, or special personal services provided for the purpose of
an improper advantage, or that can result in moral pressure to receive such
an advantage.