ISO 37001 provides standards for anti-bribery management systems to help companies implement adequate procedures against corruption. It aims to provide assurance to companies and international certification for anti-corruption systems. Implementing the standard involves establishing top-level commitment, designating responsible roles, assessing risks, and creating procedures for issues like gifts, donations, whistleblowing and investigations. Training, communication, monitoring and reviews are also required to evaluate and improve the anti-bribery system over time.

1. ISO 37001
Anti-Bribery Management System
Dr Mark Lovatt
mark.lovatt@trident-integrity.com
www.trident-integrity.com

2. How does corruption arise?
Corruption arises from:
– Weak systems
– Poor enforcement
– Acceptance culture
You have to change the first two to impact the
third

3. Purpose of ISO 37001
• To provide assurance for
companies that their anti-
bribery system comprises
‘adequate procedures’
regarding bribery &
corruption
• To provide an international
certification for
anticorruption systems
• Published 15 Oct 2016

4. Who can use ISO 37001?

5. ISO: Full Structure

6. Implementation infrastructure

7. Risk Matrix (5 x 5)
7
Almost certain Significant Significant High High High
Likely Moderate Significant Significant High High
Moderate Low Moderate Significant High High
Unlikely Low Low Moderate Significant High
Rare Low Low Moderate Significant Significant
Insignificant Minor Moderate Major Catastrophic

8. Implementation infrastructure

9. Step 1: Top-Level Commitment
• The programme must start at the right level:
from the top
– Board agrees to the programme
– Designated senior manager made responsible
– Company roles & responsibilities determined

10. Implementation infrastructure

11. Having established the
necessary implementation
infrastructure, the core
infrastructure can now be set up

12. ISO: Full Structure

13. ISO 37001 Core Infrastructure

14. Nestle

15. ISO 37001 Core Infrastructure

16. CoI management: Rio Tinto

17. ISO 37001 Core Infrastructure

18. Your money is like water going through the system
You have to stop the leakages!

19. Example: Procurement profiling

20. ISO 37001 Core Infrastructure

21. High Risk areas
• Gifts & Hospitality
– Hampers
– Gifts
– Dinners
– Entertainment
• Political donations
• Charitable donations &
sponsorships
• Support letters
• Facilitation payments

22. ISO 37001 Core Infrastructure

23. Whistleblowing procedure

24. ISO 37001 Core Infrastructure

25. Investigations procedure
• Documented procedures for investigations
• Qualified and trained staff in position to
conduct investigations
• Procedures linked to Domestic Inquiry process
and Police / ACC reporting protocol etc.

26. Implementation infrastructure

27. Communication & Training
• General communications
– Newsletter
– Team meetings
– Intranet / portal
• Training, esp. for specialist functions
– Sales
– Tendering & Procurement
– Contract management
• Customer & Supplier
– Letter or leaflet
– Briefing event

28. Implementation infrastructure

29. Performance evaluation & Improvement
• Monitoring & Enforcement
– Audits on compliance
– Investigations on incidents
– Prosecutions and terminations
• Periodic reviews of the system
– Audit (internal & external)
– Top management review
• Improvements to the system
– Analysis of incidents
– External expert review

31. Dr Mark Lovatt
mark.lovatt@trident-integrity.com
www.trident-integrity.com
+6 013 297 4450
THANK YOU