ISO 37001 is the international standard for anti-bribery management systems, helping organisations prevent, detect and respond to bribery. In ESG, business integrity is the foundation of the Governance pillar: a company with impressive environmental figures but caught up in a bribery scandal is still seen as high risk.
Key takeaways
- The Law on Anti-Corruption 2018 has extended its scope to the non-state sector.
- The main components of a compliance programme: leadership commitment, risk assessment, partner due diligence, financial controls and a whistleblowing channel.
- Metrics disclosed under GRI 205: corruption risk assessments, training and confirmed incidents.
The components of an anti-bribery programme
- Leadership commitment: a published zero-tolerance policy.
- An independent compliance function with access to the Board.
- Process-based risk assessment: procurement, licensing, sales to the public sector.
- Partner due diligence: suppliers, agents, intermediaries.
- Controls: gifts, hospitality, sponsorship, unusual payments.
- Regular training, especially for high-risk positions.
- A confidential whistleblowing channel with protection against retaliation.
- Monitoring, internal audit and improvement.
Gifts policy: the easiest place to start
| Item | Good practice |
|---|---|
| Value threshold | Set a maximum, with approval required above the threshold |
| Register | A register of gifts and hospitality given and received |
| Sensitive periods | No giving or receiving gifts during tenders or contract negotiations |
Integrity is not measured by slogans, but by the number of incidents detected and dealt with.
Links to the other pillars
The compliance programme is part of the oversight responsibility of the Board of Directors and commonly features in the supplier codes of conduct of international customers.
Frequently asked questions
Is ISO 37001 mandatory?
It is not mandatory; however, many corporations, financial institutions and international projects prefer partners that are certified or have an equivalent anti-bribery programme.
Does the Law on Anti-Corruption apply to private companies?
Yes. The Law on Anti-Corruption 2018 contains provisions on preventing and combating corruption in enterprises and organisations in the non-state sector.
What conditions should a whistleblowing channel meet?
It should protect identities, allow anonymity, have an independent handling process and commit to no retaliation against whistleblowers acting in good faith.
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