The document discusses ISO 37001, an anti-bribery management system standard published by the International Organization for Standardization (ISO). ISO 37001 provides guidance for organizations to establish, implement, maintain and improve anti-bribery compliance programs. It includes a series of measures and controls representing global anti-corruption good practice. Organizations of any size or sector can implement an anti-bribery management system consistent with ISO 37001 to help prevent, detect and address bribery risks. Certification to ISO 37001 is also possible through independent third parties.

1. ISO 37001: 2016
Anti-Bribery Management
System Standard
Prepared By
Mrs. Mayada EL Moaaz

2. What is ISO?
1. The International Organization for Standardization
(ISO) develops and publishes International standards
ISO 37000.
2. It is compromised of the national standards bodies
from 163 member countries.
3. It has developed nearly twenty thousand voluntary
international standards

3. What is ISO?
‫الخا‬ ‫المواصفه‬ ‫اصدرت‬ ‫لأليزو‬ ‫العالميه‬ ‫المواصفه‬‫صه‬
‫اإلدارى‬ ‫بالفساد‬
‫من‬ ‫إصدارها‬ ‫تم‬163‫دولهم‬ ‫يمثلون‬ ‫عضو‬.
‫من‬ ‫أكثر‬ ‫أصدرت‬ ‫المنظمه‬20000‫عالميه‬ ‫مواصفه‬

4. What is ISO 37001?
 An anti-bribery management system standard, had
published successfully.
 It is designed to help an organization establish,
implement, maintain, and improve an anti-bribery
compliance program or “management system.”
 It includes a series of measures and controls that
represent global anti-corruption good practice.

5. What is ISO 37001?
‫بنجاح‬ ‫الفساد‬ ‫مواصفه‬ ‫إصدار‬ ‫تم‬.
‫نظم‬ ‫تنفيذ‬ ‫و‬ ‫إنشاء‬ ‫على‬ ‫المنظمات‬ ‫لتساعد‬ ‫أنشأت‬ ‫قد‬‫قويه‬
‫اإلدارى‬ ‫الفساد‬ ‫لمحاربه‬ ‫إداريه‬
‫ال‬ ‫لمحاربه‬ ‫عالميه‬ ‫للرقابه‬ ‫أساليب‬ ‫على‬ ‫تحتوى‬ ‫هى‬ ‫و‬‫و‬ ‫فساد‬
‫ذلك‬ ‫لتنفيذ‬ ‫تفصيليه‬ ‫طرق‬

6. Who can use this
Standard?
The standard is flexible and can be adapted to a
wide range of organizations, including:
• Large organizations
• Small & medium sized enterprises (SMEs)
• Public and private sector organizations
• Non-governmental organizations (NGOs)
The standard can be used by organizations in any
country.

7. Who can use this
Standard?
‫فى‬ ‫لتنفذ‬ ‫تعديلها‬ ‫يمكن‬ ‫و‬ ‫مرنه‬ ‫المواصفه‬:-
•‫الحجم‬ ‫كبيره‬ ‫المنظمات‬
•‫متوسطه‬ ‫و‬ ‫صغيره‬ ‫المنظمات‬
•‫خاصه‬ ‫و‬ ‫عامه‬ ‫منظمات‬
•‫حكوميه‬ ‫غير‬ ‫منظمات‬

8. Does the Standard require a stand-
alone Management System?
 The measures required by ISO 37001
are designed to be integrated with
existing management processes and
controls.
 Follows the common high-level
structure for management system
standards, for easy integration with,
for example, ISO 9001
 New or enhanced measures can be
integrated into existing systems.

9. Does the Standard require a stand-
alone Management System?
‫األيزو‬ ‫مواصفه‬ ‫صممت‬37000‫مع‬ ‫تدمج‬ ‫لكى‬
‫المنظمه‬ ‫فى‬ ‫تطبيقها‬ ‫تم‬ ‫أخرى‬ ‫مواصفات‬.
‫األيزو‬ ‫مواصفه‬ ‫ع‬ ‫فى‬ ‫بسهوله‬ ‫دمجها‬ ‫يتم‬9001‫و‬
‫بالفعل‬ ‫الموضوعه‬ ‫اإلدارهنظم‬ ‫بجوده‬ ‫الخاصه‬.

10. What does ISO 37001
address?
 Bribery by the organization, or by its
personnel or business associates acting on
the organization’s behalf or for its benefit
 Bribery of the organization, or of its
personnel or business associates in relation
to the organization’s activities

11. What does ISO 37001
address?
‫العاملين‬ ‫األفراد‬ ‫أو‬ ‫ككل‬ ‫المنظمه‬ ‫بواسطه‬ ‫يكون‬ ‫قد‬ ‫الفساد‬
‫بالن‬ ‫يتعاملوا‬ ‫الذين‬ ‫و‬ ‫المنظمه‬ ‫مع‬ ‫المتعاملين‬ ‫أو‬ ‫بالمنظمه‬‫عن‬ ‫يابه‬
‫المنظمه‬.
‫ض‬ ‫نظام‬ ‫تنشئ‬ ‫التى‬ ‫بالمنظمه‬ ‫الصله‬ ‫ذات‬ ‫الهيئات‬ ‫فساد‬ ‫أو‬‫د‬
‫الفساد‬

12. Does the Standard define
bribery?
 Bribery is defined by law which varies
between countries.
 Therefore the Standard does not provide an
independent definition of bribery.
 The Standard provides guidance on what is
meant by bribery to help users understand
the intention and scope of the Standard.

13. Does the Standard define
bribery?
‫ألخرى‬ ‫دوله‬ ‫من‬ ‫يختلف‬ ‫الذى‬ ‫بالقانون‬ ‫يعرف‬ ‫الفساد‬
‫المواصف‬ ‫فى‬ ‫كامل‬ ‫بشكل‬ ‫يوجد‬ ‫ال‬ ‫الفساد‬ ‫تعريف‬ ‫لذلك‬ ‫و‬‫يعتمد‬ ‫و‬ ‫ه‬
‫بلد‬ ‫كل‬ ‫قوانين‬ ‫على‬.
‫المست‬ ‫لمساعده‬ ‫بالفساد‬ ‫تعريفى‬ ‫دليل‬ ‫توفر‬ ‫المواصفه‬‫خدمين‬
‫تط‬ ‫من‬ ‫الهدف‬ ‫و‬ ‫المواصفه‬ ‫تطبيق‬ ‫مجال‬ ‫لتحديد‬ ‫للمواصفه‬‫بيقها‬.

14. What does the standard
require?
A series of measures and controls to help prevent,
detect, and address bribery, among them:
 An anti-bribery policy, procedures, and controls
 Top management leadership, commitment and
responsibility
 Senior level oversight
 Anti-bribery training
 Risk assessments
 Due diligence on projects and business associates
 Reporting, monitoring, investigation and review
 Corrective action and continual improvement

15. What does the standard
require?
‫مجمةعه‬‫من‬‫اساليب‬‫الرقابه‬‫لمساعده‬‫المنظمه‬‫لمنع‬‫و‬‫إكتشاف‬‫و‬‫تحديد‬‫ال‬‫فساد‬
‫و‬‫هى‬‫كالتالى‬:-
‫السياسه‬‫و‬‫اإلجراءات‬‫و‬‫أساليب‬‫الرقابه‬.
‫القياده‬‫و‬‫اإللتزام‬‫و‬‫المسئوليه‬‫من‬‫اإلداره‬‫العليا‬.
‫النظره‬‫الشموليه‬‫لإلداره‬‫العليا‬.
‫التدريب‬
‫تقييم‬‫المخاطر‬
‫العمل‬‫بالنيابه‬‫فى‬‫المشاريع‬‫و‬‫النظم‬
‫كيفيه‬‫متابعه‬‫و‬‫مراقبه‬‫و‬‫التحقيق‬‫و‬‫المراجعه‬
‫اإلجراءؤات‬‫التصحيحيه‬‫و‬‫التطوير‬‫المستمر‬

16. What if a Standard provision is illegal
in a country?
 ISO specifies measures and controls
globally regarded as anti-corruption good
practice.
 If a requirement is prohibited by applicable
law, an organization will be required to
comply with that requirement, in accordance
with the standard.

17. What if a Standard provision is illegal
in a country?
‫كأس‬ ‫شمولى‬ ‫بشكل‬ ‫القياس‬ ‫و‬ ‫الرقابه‬ ‫تحدد‬ ‫األيزو‬ ‫مواصفه‬‫لوب‬
‫الفساد‬ ‫لمواجهه‬ ‫عام‬.
‫داخ‬ ‫المنظمه‬ ‫فى‬ ‫بالفساد‬ ‫يتعلق‬ ‫قانونى‬ ‫مطلب‬ ‫هناك‬ ‫كان‬ ‫إذا‬‫ل‬
‫ويت‬ ‫القانون‬ ‫مع‬ ‫بالتطابق‬ ‫المنظمه‬ ‫إلزام‬ ‫يتم‬ ‫سوف‬ ‫الدوله‬‫تطبيقه‬ ‫م‬
‫الفساد‬ ‫محاربه‬ ‫نظام‬ ‫داخل‬.

18. How will the Standard benefit
an organization?
By providing:
 Minimum requirements and supporting
guidance for implementing or benchmarking
an anti-bribery management system
 Assurance to management, investors,
employees, customers, and other stakeholders
that an organization is taking steps to prevent
bribery risk
 Evidence that an organization has taken
reasonable steps to prevent bribery

19. How will the Standard benefit
an organization?
‫و‬‫ذلك‬‫من‬‫خالل‬‫تنفيذ‬:-
‫تنفيذ‬‫الحد‬‫االدنى‬‫من‬‫متطلبات‬‫المواصفه‬‫داخل‬‫نظام‬‫محاربه‬‫الف‬‫ساد‬
‫اإلدارى‬.
‫تأكيد‬‫للمساهمين‬‫فى‬‫المنظمه‬‫و‬‫العاملين‬‫و‬‫العمالء‬‫و‬‫الجهات‬‫األخ‬‫رى‬
‫بأن‬‫المنظمه‬‫قادره‬‫على‬‫إتخاذ‬‫خطوات‬‫لمحاربه‬‫خطر‬‫الفساد‬.
‫دليل‬‫على‬‫أن‬‫المنظمه‬‫تأخذ‬‫خطوات‬‫مسئوله‬‫تجاه‬‫محاربه‬‫الفساد‬‫ب‬‫ها‬.

20. Can my organization be ISO 37001
certified?
 ISO 37001 is being developed as a
requirements standard, making it capable of
independent certification.
 If approved as such, third parties will be able to
certify an organization’s compliance with the
Standard.

21. Can my organization be ISO 37001
certified?
‫االيزو‬37000‫تم‬‫تطويره‬‫كمواصفه‬‫عالميه‬‫و‬‫يتم‬‫أخذ‬‫شهاده‬
‫معتمده‬‫لها‬.
‫فى‬‫حاله‬‫الموافقه‬‫على‬‫نظام‬‫محاربه‬‫الفساد‬‫الموضوع‬‫يتم‬‫تأه‬‫يل‬
‫المنظمه‬‫للحصول‬‫على‬‫الشهاده‬.

22. What is anti Bribery
Management system
 Bribery is one of the most destructive and
complex problems of our times, and despite
national and international efforts to combat it, it
remains widespread.
 An anti-bribery management system is
designed to enhance an anti-bribery culture
within an organization and implement
appropriate controls, which will in turn increase
the chance of detecting bribery and reduce its
incidence in the first place.

23. What is anti Bribery
Management system
‫ع‬ ‫مجهود‬ ‫يوجد‬ ‫و‬ ‫الحالى‬ ‫وقتنا‬ ‫فى‬ ‫المعقده‬ ‫المشكالت‬ ‫من‬ ‫الفساد‬‫المى‬
‫اإلنتشار‬ ‫واسع‬ ‫أنه‬ ‫حيث‬ ‫عليه‬ ‫للسيطره‬ ‫محلى‬ ‫و‬.
‫المنظ‬ ‫داخل‬ ‫العامه‬ ‫الثقافه‬ ‫لتحسين‬ ‫مصمم‬ ‫الفساد‬ ‫محاربه‬ ‫نظام‬‫و‬ ‫مه‬
‫ف‬ ‫تزيد‬ ‫بالتبيعيه‬ ‫التى‬ ‫و‬ ‫مناسبه‬ ‫رقابيه‬ ‫أساليب‬ ‫تنفيذ‬‫إكتشاف‬ ‫رص‬
‫االول‬ ‫بالمفام‬ ‫حدوثه‬ ‫إحتماالت‬ ‫تقليل‬ ‫و‬ ‫الفساد‬

24. What is anti Bribery
Management system
 ISO 37001, Anti-bribery management systems
– Requirements with guidance for use, gives
the requirements and guidance for
establishing, implementing, maintaining and
improving an anti-bribery management system.
 The system can be independent of, or
integrated into, an overall management
system.
 It covers bribery in the public, private and not-
for-profit sectors, including bribery by and
against an organization or its staff, and bribes
paid or received through or by a third party.

25. What is anti Bribery
Management system
‫األيزو‬ ‫مواصفه‬37000‫توفر‬ ‫الفساد‬ ‫لمحاربه‬ ‫اإلدارى‬ ‫للنظام‬
‫نظا‬ ‫تحسين‬ ‫و‬ ‫تصميم‬ ‫و‬ ‫إلنشاء‬ ‫للتنفيذ‬ ‫بدليل‬ ‫متطلبات‬‫لمحاربه‬ ‫م‬
‫المنظمه‬ ‫داخل‬ ‫الفساد‬.
‫داخل‬ ‫أخرى‬ ‫منفذه‬ ‫نظم‬ ‫مع‬ ‫دمجه‬ ‫يتم‬ ‫أو‬ ‫مستقل‬ ‫يكون‬ ‫قد‬ ‫النظام‬
‫المنظمه‬.
‫للر‬ ‫هادفه‬ ‫الغير‬ ‫و‬ ‫الخاصه‬ ‫و‬ ‫العامه‬ ‫للمنظمات‬ ‫تصلح‬ ‫نظم‬ ‫هى‬ ‫و‬‫بح‬
‫الم‬ ‫أو‬ ‫بالمنظمه‬ ‫العاملين‬ ‫األشخاص‬ ‫من‬ ‫فردى‬ ‫الفساد‬ ‫كان‬ ‫سواء‬‫نظمه‬
‫المنظمه‬ ‫مع‬ ‫متعامله‬ ‫جهات‬ ‫أو‬ ‫ككل‬.

26. What is benefits
 ISO 37001 is designed to help your
organization implement an anti-bribery
management system or enhance the controls
you currently have.
 It requires implementing a series of measures
such as adopting an anti-bribery policy,
appointing someone to oversee compliance
with that policy, getting and training employees,
undertaking risk assessments on projects and
business associates, implementing financial
and commercial controls, and instituting
reporting and investigation procedures.

27. What is benefits
‫مواصفه‬‫األيزو‬37000‫مصممه‬‫لتطوير‬‫النظم‬‫الموضوعه‬‫بالفعل‬
‫داخل‬‫المنظمه‬‫أو‬‫تحسين‬‫أساليب‬‫الرقابه‬.
‫المواصفه‬‫تتطلب‬‫مجموعه‬‫من‬‫األساليب‬‫كتعديل‬‫للسياسات‬‫و‬‫تعيين‬
‫أفراد‬‫مسئولين‬‫عن‬‫متابعه‬‫التطابق‬‫داخل‬‫المنظمه‬‫م‬‫ع‬‫السياس‬‫ات‬
‫الموضوعه‬.
‫المواصفه‬‫تتطلب‬‫تدريب‬‫العاملين‬‫بالمنظمه‬‫و‬‫تقييم‬‫المخ‬‫اطر‬‫التى‬‫قد‬
‫تتعرض‬‫لها‬‫المنظمه‬‫فى‬‫المشاريع‬.
‫تنفيذ‬‫نظم‬‫ماليه‬‫و‬‫بيعيه‬‫قويه‬‫تشمل‬‫نظم‬‫للتحقيق‬‫و‬‫الم‬‫تابعه‬.

28. What is benefits
 Implementing an anti-bribery management
system requires leadership and input from top
management, and the policy and programme
must be communicated to all staff and external
parties such as contractors, suppliers and
jointventure partners.

29. What is benefits
‫تنفيذ‬‫نظم‬‫إداريه‬‫لمحاربه‬‫الفساد‬‫تشمل‬‫القياده‬‫و‬‫مدخالت‬‫من‬‫اإلداره‬
‫العليا‬‫و‬‫توزيع‬‫و‬‫توصيل‬‫السياسات‬‫و‬‫البرامج‬‫للعاملين‬‫ب‬‫المنظمه‬‫و‬
‫الجهات‬‫المتعامله‬‫مع‬‫المنظمه‬‫كالمتعاقدين‬‫و‬‫الموردين‬‫و‬‫الشرك‬‫اء‬.

30. What is benefits
 In this way, it helps to reduce the risk of
bribery occurring and can demonstrate to
your management, employees, owners,
funders, customers and other business
associates that you have put in place
internationally recognized good-practice
anti-bribery controls.
 It can also provide evidence in the event of
a criminal investigation that you have taken
reasonable steps to prevent bribery.

31. What is benefits
‫فى‬‫هذا‬‫النظاق‬‫تقلل‬‫تطبيق‬‫المواصفه‬‫من‬‫خطر‬‫الفساد‬‫و‬‫يوفر‬
‫دليل‬‫مادى‬‫للمتعاملين‬‫مع‬‫المنظمه‬‫داخليا‬‫و‬‫خارجيا‬‫أن‬‫المن‬‫ظمه‬
‫لديها‬‫دليل‬‫عالمى‬‫لتطبيق‬‫أساليب‬‫رقابيه‬‫قويه‬‫على‬‫ن‬‫شاطها‬‫تمنع‬
‫الفساد‬
‫ف‬ ‫قويه‬ ‫للتحقيق‬ ‫أساليب‬ ‫وجود‬ ‫على‬ ‫قوى‬ ‫دليل‬ ‫توفر‬ ‫و‬‫حاله‬ ‫ى‬
‫الفساد‬ ‫جريمه‬ ‫وقوع‬.

32. Context of the organization
Understanding the organization and its
context
 The organization will determine external
and internal factors that are relevant to its
purpose and that affect its ability to achieve
the objectives of its anti-bribery
management system. These factors will
include, without limitation, the following:
 a) size and structure of the organization;
 b) locations and sectors in which the
organization operates or anticipates
operating;
How to Implement ISO 37001 in your organization

33.  c) nature, scale and complexity of the
organization's activities and operations;
 d) entities over which the organization has
control;
 e) organization's business associates;
 f) the nature and extent of interactions with
public officials; and
 g) applicable statutory, regulatory,
contractual and professional obligations
and duties.

34. ‫ا‬‫المؤسسه‬ ‫فهم‬
‫سياق‬ ‫وفهم‬ ‫تحديد‬‫المؤسسه‬.
‫المؤسسه‬ ‫سياق‬ ‫فهم‬ ‫تحديد‬‫قبل‬‫الجودة‬ ‫إدارة‬ ‫نظام‬ ‫إنشاء‬
‫المؤسسه‬ ‫اقتراحات‬ ‫ووضع‬ ‫الخارجية‬ ‫التغييرات‬ ‫فهم‬‫ووض‬‫ع‬
‫الذي‬ ‫األثر‬ ‫لدراسه‬ ‫عمل‬ ‫خطط‬ ‫على‬ ‫العمل‬ ‫لمواجهتها‬ ‫نظم‬
‫بلو‬ ‫المراد‬ ‫والنتائج‬ ‫الجودة‬ ‫إدارة‬ ‫نظام‬ ‫على‬ ‫يحدث‬ ‫أن‬ ‫يمكن‬‫غها‬.
‫سياق‬ ‫عن‬ ‫المعلومات‬ ‫رصد‬‫المؤسسه‬.
‫ع‬ ‫يحدث‬ ‫أن‬ ‫يمكن‬ ‫الذي‬ ‫البيئة‬ ‫في‬ ‫التغيرات‬ ‫أثر‬ ‫دراسه‬‫نظام‬ ‫لى‬
‫المؤسسه‬ ‫إدارة‬.
‫علي‬ ‫بالرقابه‬ ‫المؤسسه‬ ‫تقوم‬ ‫التى‬ ‫المنشأت‬ ‫طبيعه‬ ‫فهم‬‫ها‬
‫كذل‬ ‫و‬ ‫معها‬ ‫التعامل‬ ‫يتم‬ ‫التى‬ ‫الحكوميه‬ ‫الجهات‬ ‫مع‬ ‫التداخل‬‫ك‬
‫المنظمه‬ ‫على‬ ‫تطبق‬ ‫التى‬ ‫القرارات‬ ‫و‬ ‫القوانين‬.
How to Implement ISO 37001 in your organization

35. Understanding the needs and
expectations of stakeholders
 The organization will determine:
 a) the stakeholders that are relevant to the
anti-bribery management system;
 b) the relevant requirements of these
stakeholders

36. ‫المنظمه‬ ‫مع‬ ‫للمتعاملين‬ ‫التوقعات‬ ‫و‬ ‫اإلحتياجات‬ ‫دراسه‬
‫تحدد‬ ‫أن‬ ‫المنشأه‬ ‫على‬ ‫يجب‬:-
‫المطلو‬ ‫اإلدارى‬ ‫بالنظام‬ ‫عالقه‬ ‫لهم‬ ‫و‬ ‫المنظمه‬ ‫مع‬ ‫المتعاملين‬‫ب‬
‫به‬ ‫المحتمل‬ ‫الفساد‬ ‫لمكافحها‬ ‫رقابيه‬ ‫أساليب‬ ‫إنشاء‬.
‫النظام‬ ‫فى‬ ‫إلدراجها‬ ‫المتعالمين‬ ‫هؤالء‬ ‫متطلبات‬.

37. Determining the scope of the anti-bribery
management system
 The organization shall determine the
boundaries and applicability of the anti-
bribery management system to establish its
scope.
 When determining this scope, the
organization shall consider:
 a) the external and internal factors
 b) the requirements
 c) the results of the bribery risk assessment

38. ‫اإلدارى‬ ‫الفساد‬ ‫مجال‬ ‫تحديد‬
‫وي‬ ‫اإلدارى‬ ‫الفساد‬ ‫نظام‬ ‫تنفيذ‬ ‫مجال‬ ‫تحدد‬ ‫أن‬ ‫المؤسسه‬ ‫على‬‫جب‬
‫األتى‬ ‫اإلعتبار‬ ‫فى‬ ‫األخذ‬:-
‫الخارجيه‬ ‫و‬ ‫الداخليه‬ ‫المعامالت‬
‫المواصف‬ ‫فى‬ ‫الموجوده‬ ‫المتطلبات‬ ‫و‬ ‫القانونيه‬ ‫المتطلبات‬‫ه‬
‫اإلدارى‬ ‫الفساد‬ ‫مخاطر‬ ‫تقييم‬ ‫نظام‬ ‫نتائج‬

39. Anti-bribery management system
 The organization shall establish, document,
implement, maintain and continually review
and, where necessary, improve an anti-
bribery management system, including the
processes needed and their interactions, in
accordance with the country regulation
 The anti-bribery management system shall
contain measures designed to identify and
evaluate the risk of, and to prevent, detect
and address, bribery

40. ‫اإلدارى‬ ‫الفساد‬ ‫ضد‬ ‫نظام‬
‫ترا‬ ‫و‬ ‫تحافظ‬ ‫و‬ ‫تنفذ‬ ‫و‬ ‫توثق‬ ‫و‬ ‫تؤسس‬ ‫أن‬ ‫يجب‬ ‫المنظمه‬‫جع‬
‫الف‬ ‫لمكافحه‬ ‫نظم‬ ‫تطور‬ ‫حاجه‬ ‫هناك‬ ‫كان‬ ‫إذا‬ ‫و‬ ‫مستمره‬ ‫بصفه‬‫ساد‬
‫م‬ ‫مع‬ ‫بالتوافق‬ ‫العمليات‬ ‫بين‬ ‫التداخل‬ ‫و‬ ‫إجراءات‬ ‫إنشاء‬ ‫و‬‫تطلبات‬
‫المنظمه‬ ‫بها‬ ‫الكموجود‬ ‫الدوله‬.
‫و‬ ‫تحديد‬ ‫على‬ ‫يحتوى‬ ‫المنشأ‬ ‫اإلدارى‬ ‫النظام‬ ‫يكون‬ ‫أن‬ ‫يجب‬
‫ت‬ ‫و‬ ‫منع‬ ‫أساليب‬ ‫كذلك‬ ‫و‬ ‫الفساد‬ ‫إحتماليه‬ ‫لمخاطر‬ ‫تقييم‬‫و‬ ‫حديد‬
‫الفساد‬ ‫دراسه‬

41. Bribery risk assessment
 The organization shall undertake bribery
risk assessment(s) which shall:
 a) identify the bribery risks the organization
might reasonably anticipate given the
factors
 b) assess and prioritize the identified
bribery risks;
 c) evaluate the suitability and effectiveness
of the organization's existing controls to
mitigate the assessed bribery risks.
 The organization shall establish criteria for
evaluating its level of bribery risk, which
shall take into account the organization's

42. Bribery risk assessment
 The bribery risk assessment shall be
reviewed on a regular basis so that
changes and new information can be
properly assessed based on timing and
frequency defined by the organization;
 b) in the event of a significant change to the
structure or activities of the organization.
 The organization shall maintain
documented information that demonstrates
that the bribery risk assessment has been
conducted, and used to design the anti-
bribery management system

43. Leadership
Leadership and commitment
Governing body
 When the organization has a governing
body, that body shall demonstrate
leadership and commitment with respect to
the anti-bribery management system by:
 a) approving the organization’s anti-bribery
policy;
 b) at planned intervals receiving and
reviewing information about the content and
operation of the organization’s anti-bribery
management system;

44. Leadership
Leadership and commitment
Governing body
 c) ensuring that adequate and appropriate
resources needed for effective operation of
the anti-bribery management system are
allocated and assigned;
 d) exercising reasonable oversight over the
implementation of the organization’s anti-
bribery management system by top
management and its effectiveness.

45. Top management
Top management shall demonstrate
leadership and commitment with respect to
the anti-bribery management
 system by:
 a) ensuring that the anti-bribery
management system, including policy and
objectives, is established, implemented,
maintained and reviewed to adequately
address the organization's bribery risks;
 b) ensuring the integration of the anti-
bribery management system requirements
into the organization’s processes;

46. Top management
 C) deploying adequate and appropriate
resources for the effective operation of the
anti-bribery management system;
 d) communicating internally and externally
regarding the anti-bribery policy;
 e) communicating internally the importance
of effective anti-bribery management and of
conforming to the anti-bribery management
system requirements;

47. Top management
 f) ensuring that the anti-bribery
management system is appropriately
designed to achieve its objectives;
 g) directing and supporting personnel to
contribute to the effectiveness of the anti-
bribery management system; promoting an
appropriate anti-bribery culture within the
organization;
 i) promoting continual improvement

48. Top management
 j) supporting other relevant management
roles to demonstrate their leadership in
preventing and detecting bribery as it
applies to their areas of responsibility;
 k) encouraging the use of reporting
procedures for suspected and actual
bribery

49. Top management
 l) ensuring that no personnel will suffer retaliation
or discriminatory or disciplinary action for reports
made in good faith or on the basis of a reasonable
belief of violations or suspected violations of the
organization’s anti-bribery policy, or for refusing to
engage in bribery, even if such refusal may result
in the organization losing business (except where
the individual participated in the breach);
 m) at planned intervals, reporting to the governing
body (if one exists) on the content and operation of
the anti-bribery management system and of
allegations of serious and/or systematic bribery.

50. Anti-bribery policy
 Top management shall establish, review and
maintain an anti-bribery policy that:
 a) prohibits bribery;
 b) requires compliance with anti-bribery laws that
are applicable to the organization;
 c) is appropriate to the purpose of the organization;
 d) provides a framework for setting, reviewing and
achieving anti-bribery objectives;
 e) includes a commitment to satisfy anti-bribery
management system requirements;
 f) encourages raising concerns in confidence
without fear of reprisal

51. Anti-bribery policy
 includes a commitment to continual improvement
of the anti-bribery management system;
 h) explains the authority and independence of the
anti-bribery compliance function; and
 i) explains the consequences of not complying with
the anti-bribery policy.
 The anti-bribery policy shall:
 a) be available as documented information;
 b) be communicated in appropriate languages
within the organization and to business associates
who pose more than a low risk of bribery;
c) be available to relevant stakeholders, as
appropriate

52. Organizational roles, responsibilities and
authorities
Roles and responsibilities
 Top management shall have overall
responsibility for the implementation of and
compliance with the anti bribery
management system
 Top management shall ensure that the
responsibilities and authorities for relevant
roles are assigned and communicated
within and throughout every level of the
organization.
 Managers at every level shall be
responsible for ensuring that the anti-

53. Anti-bribery compliance function
 Top management shall assign to an anti-
bribery compliance function the
responsibility and authority for:
 a) overseeing the design and
implementation by the organization of the
anti-bribery management system;
 b) providing advice and guidance to
personnel on the anti-bribery management
system and issues relating to bribery;
 c) ensuring that the anti-bribery
management system conforms to the
requirements of country regulation


54. Anti-bribery compliance function
 d) reporting on the performance of the anti-
bribery management system to the
governing body (if any) and top
management and other compliance
functions, as appropriate.
 The anti-bribery compliance function shall
be adequately resourced and assigned to
person(s) who have the appropriate
competence, status, and independence.

55. Anti-bribery compliance function
 The anti-bribery compliance function shall have
direct and prompt access to the governing body (if
any) and top management in the event that any
issue or concern needs to be raised in relation to
bribery or the anti-bribery management system.
 Top management may assign some or all of the
anti-bribery compliance function to persons
external to the organization. If it does, top
management shall ensure that specific personnel
have responsibility for and authority over those
assigned parts of the function.

56. Anti-bribery compliance function
 Where top management delegates to personnel
the responsibility or authority for the making of
decisions in relation to which there is more than a
low risk of bribery, the organization shall establish
and maintain a decision-making process or set of
controls that requires that the decision process and
the level of authority of the decision-maker(s) are
appropriate and free of actual or potential conflicts
of interest.
 Top management shall ensure that these
processes are reviewed periodically as part of its
roles and responsibilities for implementation of and
compliance with the anti-bribery management
system.

57. Planning
Actions to address bribery risks and
opportunities
 When planning for the anti-bribery management
system, the organization shall risks and
opportunities that need to be addressed to:
 a) give reasonable assurance that the anti-bribery
management system can achieve its objectives;
 b) prevent, or reduce, undesired effects relevant to
the anti-bribery policy and objectives;
 C)monitor the effectiveness of the anti-bribery
management system

58. Planning
Actions to address bribery risks and
opportunities
The organization shall plan:
a) actions to address these bribery risks and
opportunities;
b) how to:
1) integrate and implement these actions into its anti-
bribery management system processes;
2) evaluate the effectiveness of these actions.

59. Anti-bribery objectives and planning to achieve
them
The organization shall establish anti-bribery
objectives at relevant functions and levels.
The anti-bribery objectives shall:
a) be consistent with the anti-bribery policy;
b) be measurable (if practicable);
c) be achievable;
d) be monitored;
e) be communicated;
f) be updated as appropriate

60. Anti-bribery objectives and planning to achieve
them
The organization shall establish anti-bribery
objectives at relevant functions and levels.
The anti-bribery objectives shall:
a) be consistent with the anti-bribery policy;
b) be measurable (if practicable);
c) be achievable;
d) be monitored;
e) be communicated;
f) be updated as appropriate

61. Anti-bribery objectives and planning to achieve
them
 The organization shall retain documented
information on the anti-bribery objectives.
 When planning how to achieve its anti-bribery
objectives, the organization shall determine:
 what will be done;
 what resources will be required;
 who will be responsible;
 when the objectives will be achieved;
 how the results will be evaluated and reported.

62. Support
Resources
The organization shall determine and provide the
resources needed for the establishment,
implementation, maintenance and continual
improvement of the anti-bribery management
system.
Competence
General
The organization shall:
a) determine the necessary competence of person(s)
doing work under its control that affects its anti-
bribery performance;
b) ensure that these persons are competent on the
basis of appropriate education, training, or
experience;

63. Competence
 c) where applicable, take actions to acquire and
maintain the necessary competence, and evaluate
the effectiveness of the actions taken;
 d) retain appropriate documented information as
evidence of competence.
 Employment procedures
 In relation to all of its personnel, the organization
shall implement procedures such that:
 a) conditions of employment require personnel to
comply with the anti-bribery policy and anti-bribery
management system, and give the organization the
right to discipline personnel in the event of non
compliance;

64.  b) within a reasonable period of their employment
commencing, personnel receive a copy of, or are
provided with access to, the anti-bribery policy and
training in relation to that policy;
 c) the organization has procedures which enable it
to take appropriate disciplinary action against
personnel who breach the anti-bribery policy and
anti-bribery management system; and
 d) personnel are not penalized (e.g. by demotion,
preventing advancement, disciplinary action,
transfer, dismissal, bullying or victimization):
 1) for refusing to participate in, or for turning down,
any activity in respect of which they have
reasonably judged there to be a more than low risk
of bribery which has not been mitigated by the
organization; or

65.  2) for concerns raised or reports made in good
faith or on the basis of a reasonable belief, of
attempted, actual or suspected bribery or breaches
of the anti-bribery policy or the anti-bribery
management system (except where the individual
participated in the breach).
 In relation to all personnel in positions which are
exposed to more than a low bribery risk as
determined in the bribery risk assessment, and to
all personnel employed in the anti-bribery
compliance function the organization shall
implement procedures which provide that:

66.  a) 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;
 b) performance bonuses, performance targets and
other incentivizing elements of remuneration are
reviewed periodically to verify that there are
reasonable safeguards in place to prevent them
from encouraging bribery;
 c) such personnel, top management, as well as
and the governing body (if any), file a declaration
at reasonable intervals proportionate with the

67.  c) such personnel, top management, as well as
and the governing body (if any), file a declaration
at reasonable intervals proportionate with the
identified bribery risk, confirming their compliance
with the anti bribery policy.
Awareness and training
 The organization shall provide adequate and
appropriate anti-bribery awareness and training to
personnel.
 Such training shall address the following issues as
appropriate, taking into account the results of the
bribery risk assessment:
 a) the organization’s anti-bribery policy and
procedures and anti-bribery management system

68. Awareness and training
 b) the bribery risk and the damage to them and the
organization which can result from bribery;
 c) the circumstances in which bribery can occur in
relation to their duties, and how to recognize these
circumstances;
 d) how they can help prevent and avoid bribery
and recognize key bribery risk indicators;
 e) their contribution to the effectiveness of the anti-
bribery management system, including the benefits
of improved anti-bribery performance and of
reporting suspected bribery;
 f) the implications and potential consequences of
not conforming with the anti-bribery management
system requirements;

69. Awareness and training
 g) how and to whom they should report any
concerns
 h) information on available training and resources.
 Personnel shall be provided with anti-bribery
awareness and training on a regular basis (at
planned intervals determined by the organization)
as appropriate to their roles, the risks of bribery to
which they are exposed, and any changing
circumstances. The awareness and training
programmes shall be periodically updated as
necessary to reflect relevant new information.

70. Awareness and training
 Taking into account the bribery risks identified, the
organization shall also implement procedures
addressing anti-bribery awareness and training for
business associates acting on its behalf or for its
benefit and which could pose more than a low
bribery risk to the organization. These procedures
shall identify the business associates for which
such awareness and training is necessary, its
content, and the means by which the training shall
be provided.
 The organization shall retain documented
information on the training procedures, the content
of the training, and to whom it was provided.

71. Communication
The organization shall determine the internal and
external communications relevant to the anti-bribery
management system including:
a) on what it will communicate;
b) when to communicate;
c) with whom to communicate;
d) how to communicate;
e) who will communicate;
f) the languages in which to communicate.

72. Due diligence
 Where the organization's bribery risk assessment
conducted has assessed a more than low bribery
risk
 in relation to:
 a) specific categories of transactions, projects or
activities;
 b) planned or on-going relationships with specific
categories of business associates; or c) specific
categories of personnel in certain positions the
organization shall assess the nature and extent of
the bribery risk in relation to specific transactions,
projects, activities, business associates and
personnel falling within those categories.

73. Financial controls
 The organization shall implement financial controls
that manage bribery risk.
Non-financial controls
 The organization shall implement procurement,
operational, sales, commercial and other non-
financial controls that manage bribery risk.

74. Implementation of anti-bribery controls by
controlled organizations and by business
associates
 The organization shall implement procedures
which require that all other organizations over
which it has control either:
 a) implement the organization’s anti-bribery
management system; or b) implement their own
anti-bribery controls, in each case only to the
extent that is reasonable and proportionate having
regard to the bribery risks which the controlled
organizations face, taking into account the bribery
risk assessment conducted pursuant.

75. Implementation of anti-bribery controls by
controlled organizations and by business
associates
 In relation to business associates not controlled by
the organization for which the bribery risk
assessment or due diligence has identified a more
than low bribery risk, and where anti bribery
controls implemented by the business associates
would help mitigate the relevant bribery risk, the
organization shall implement procedures as
follows:
 a) the organization shall determine whether the
business associate has in place anti-bribery
controls which manage the relevant bribery risk.
 b) where a business associate does not have in
place anti-bribery controls, or it is not possible to
verify whether it has them in place:

76. Implementation of anti-bribery controls by
controlled organizations and by business
associates
 1) the organization shall where practicable require
the business associate to implement anti-bribery
controls in relation to the relevant transaction,
project or activity, or
 2) where it is not practicable to require the
business associate to implement anti-bribery
controls, the organization shall take this factor into
account when assessing the bribery risks that the
business associates pose, and the way in which
the organization manages such risks

77.  Anti-bribery commitments
 For business associates which pose more than a
low bribery risk, the organization shall implement
procedures which require that, as far as is
practicable:
 a) business associates commit to prevent bribery
by or on behalf of or for the benefit of the business
associate in connection with the relevant
transaction, project, activity, or relationship;
 b) the organization is able to terminate the
relationship with the business associate in the
event of bribery by or on behalf of or for the benefit
of the business associate in connection with the
relevant transaction, project, activity, or
relationship.
 Where it is not practicable to meet the
requirements of a) or b) above, then this shall be a

78. Gifts, hospitality, donations and similar benefits
 The organization shall implement procedures
which are designed to prevent the offer, provision
or acceptance of gifts, hospitality, donations and
similar benefits where the offer, provision or
acceptance is or could reasonably be perceived as
bribery.
Managing inadequacy of anti-bribery controls
Where the due diligence conducted on a specific
transaction, project, activity or relationship with a
business associate establishes that the bribery risks
cannot be managed by existing anti-bribery controls,
and the organization cannot or does not wish to
implement additional or enhanced anti-bribery
controls or take other appropriate steps,

79. Managing inadequacy of anti-bribery controls
to enable the organization to manage the relevant
bribery risks, the organization shall :-
 a) in the case of an existing transaction, project,
activity or relationship, take steps appropriate to
the bribery risks and the nature of the transaction,
project, activity or relationship to terminate,
discontinue, suspend or withdraw from it as soon
as is practicable;
 b) in the case of a proposed new transaction,
project, activity or relationship, postpone or decline
to continue with it.

80. Raising concerns
 The organization shall implement procedures
which:
 a) enable persons to report attempted, suspected
and actual bribery, or any breach of or weakness in
the anti-bribery management system, to the anti-
bribery compliance function or to appropriate
personnel (either directly or through an appropriate
third party);
 b) except to the extent required to progress an
investigation or by law, require that the
organization treats reports confidentially so as to
protect the identity of the reporter and of others
involved or referenced in the report

81. Raising concerns
 d) prohibit retaliation, and protect personnel from
retaliation, after such personnel have in good faith
or on the basis of a reasonable belief raised or
reported a concern about attempted, actual or
suspected bribery or breaches of the anti-bribery
policy or the anti-bribery management system;
 e) enable personnel to receive advice from an
appropriate person on what to do if faced with a
concern or situation which could involve bribery;
 f) encourage the use by personnel of the reporting
procedures.
 The organization shall ensure that all personnel
are aware of the reporting procedures, and are
able to use them, and are aware of their rights and
protections under the procedures;

82. Investigating and dealing with bribery
 The organization shall implement procedures
which:
 a) require assessment and, where appropriate,
investigation of bribery, or breach of the anti-
bribery policy or the anti-bribery management
system , which is reported, detected or reasonably
suspected;
 b) require appropriate action in the event that the
investigation reveals bribery, or breach of the anti-
bribery policy or the anti-bribery management
system; empower and enable investigators and
require co-operation in the investigation by relevant
personnel;
 d) require that the status and results of the
investigation are reported to the anti-bribery

83. Investigating and dealing with bribery
 The organization shall implement procedures
which:
 a) require assessment and, where appropriate,
investigation of bribery, or breach of the anti-
bribery policy or the anti-bribery management
system , which is reported, detected or reasonably
suspected;
 b) require appropriate action in the event that the
investigation reveals bribery, or breach of the anti-
bribery policy or the anti-bribery management
system; empower and enable investigators and
require co-operation in the investigation by relevant
personnel;
 d) require that the status and results of the
investigation are reported to the anti-bribery