A challenge for any company with an embedded anti-corruption compliance programme is implementing an anti-bribery management system as required by the ISO 37001 standard. Part of this challenge is ‘retrofitting’ some of your programme into the structure of a management system. While there are very significant similarities between an anti-corruption compliance programme and an anti-bribery management system, there are some areas that make a management system capable of being certified.
The main thing to remember is that a management system relies on documented evidence. You may ‘do something’, but you need to be able to prove it – especially if your management system is the subject of a certification audit.
The board of directors – or the governing body, as it is known in the ISO world – has a key role to play in the development and review of management standards, such as an anti-bribery management system under ISO 37001.
When we interview board members or members of the governing body as part of a certification audit, we are looking for some key indicators to be proved to us. One of the focus areas in our interviews is resourcing. How has the board assigned resources? How can we know that they have assigned the right resources? How did they ascertain what the right level of resources was? Who did they check with to decide that what they assigned is adequate? Did they refer to published research or benchmarking, and can they share a copy of the published material they used?
> Click here to download a visual summary of the role of the board in ABMS <
The board is more than just a mouthpiece telling us that the company has ‘zero tolerance’. It needs to be actively involved in oversight and resourcing and must be able to prove that level of engagement.
