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Sustainability Command Center 17 items

ISO 37001 Anti-Bribery Management System Checklist

Assess the design and operation of an anti-bribery management system against ISO 37001, covering risk assessment, due diligence, controls, and monitoring.

ISO 37001:2016

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Context & Leadership

  • Has a bribery risk assessment been conducted to identify and evaluate bribery risks? *
  • Has top management demonstrated leadership and commitment to the ABMS? *
  • Is there an anti-bribery policy prohibiting bribery and requiring compliance with anti-bribery laws? *
  • Has an anti-bribery compliance function been assigned appropriate authority and independence? *

Due Diligence & Controls

  • Is due diligence performed on transactions, projects, business associates, and personnel in higher-risk categories? *
  • Are financial controls in place to manage bribery risk? *
  • Are non-financial controls (procurement, commercial, operational) implemented? *
  • Are anti-bribery commitments obtained from controlled organizations and business associates? *

Gifts, Hospitality & Third Parties

  • Are controls implemented for gifts, hospitality, donations, and similar benefits? *
  • Is there a process to manage inadequacy of anti-bribery controls in business associates? *
  • Are facilitation payments prohibited or controlled consistent with applicable law? *

Raising Concerns & Investigation

  • Is a confidential reporting (whistleblowing) mechanism available and protected from retaliation? *
  • Are procedures in place to investigate and deal with reported or suspected bribery? *
  • Are personnel encouraged to report suspicions in good faith without fear of reprisal? *

Competence, Monitoring & Review

  • Are personnel provided with anti-bribery awareness and training appropriate to their roles? *
  • Are internal audits of the ABMS conducted at planned intervals? *
  • Does the anti-bribery compliance function and top management review the ABMS? *

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