ISO 37001: Anti - Bribery Management System
ISO 37001:Anti-Bribery Management SystemA New Era in Anti-Bribery/Anti-Corruption ("ABAC")ComplianceNOVEMBER 7, 2017
FCPA ENFORCEMENTSIndicators show continued aggressive approach to FCPA andglobal enforcements with rewards for a strong ABACcompliance program- 2016 was a banner year for FCPA penalties; blockbuster 2 billion in fines and 2016contributed 4 of the historical FCPA Top 10 list- self-disclosure pilot program will continue- new administration confirmed anti-corruption campaign will stay the course- recent release of DOJ's "Evaluation of Corporate Compliance Program" re-affirmsimportance of taking proactive measures 2017 Grant Thornton LLP All rights reserved U.S. member firm of Grant Thornton International Ltd*Gibson Dunn Charts2
ISO BACKGROUNDISO 37001: Anti-Bribery Management SystemISO is a globally recognized authority that establishes standards across a widerange of industries.ISO 37001 has been a closely monitored standard throughout it's development and it'spublication opens up a new perspective on ABAC compliance: Published on October 2016 after several years of development by 59 countriesincluding China, India, Mexico, UK, and the US; included representatives fromvarying industries and backgrounds standard lays out a framework for establishing a strong anti-bribery program that isreasonable and proportionate according to the company's bribery risks Designed to be used by small, medium, and large organization in the public, private,and non-profit sectors 37001 moves beyond the US and UK-centric anti-corruption guidelines that areindustry standardsABAC Game Changer: first time ever, companies can certifytheir anti-bribery program under a global standard (37001) 2017 Grant Thornton LLP All rights reserved U.S. member firm of Grant Thornton International Ltd3
ISO 37001 FRAMEWORKOrganizationOverall structure andscope, controlenvironment and ABAC riskassessmentImprovementsLeadershipNoncompliance andcorrective actions,continuously improvingPerformanceMonitoring, InternalAudits, top managementreview, compliancefunction reviewTone at the top, compliancefunction, delegation of power37001:Anti-BriberyManagement SystemSeven ComplianceAreasPlanningActivities, link and mapcorruption risks tocontrol activities, plan ofaction to fill gaps andimplement controlsOperationSupportRisk assessment thoroughness,financial/non-financial/3rd partycontrols, gifts and entertainmentpolicies, whistleblower, instigationsCompetent compliancepersonnel, training,communication,documentation 2017 Grant Thornton LLP All rights reserved U.S. member firm of Grant Thornton International Ltd4
CertificationProcess for a Company to be 37001 Certified-Outside firm performs a 37001 certification audit-On-site audit will include a review of the company's ABACpolicies and controls. Auditor will test the existence andeffectiveness of the policies and controls mainly throughinterviews and observations.-Audit varies in length of time and cost depending on complexityof company and ABAC program-If company passes the audit, the certification is valid for threeyears and includes "surveillance audit" to be performed on anannual basis then full re-certification in year four in order tomaintain the 37001 certificate. 2017 Grant Thornton LLP All rights reserved U.S. member firm of Grant Thornton International Ltd5
BENEFITSBenefits for Companies Pursuing ISO 37001 CertificationBased on our experience, companies have realized the inherent compliance risks associated withconducting business overseas, especially within the BRIC countries (Brazil, Russia, India, and China)as well as other countries deemed high risk. From an anti-bribery perspective, a significantamount of resources and efforts have been spent by companies to mitigate these risks. Below area few of the benefits companies may reap by adopting and certifying the ISO 37001 system.Good GovernanceCompetitive AdvantageGovernmentEnforcement AgenciesMitigate Risks 2017 Grant Thornton LLP All rights reserved U.S. member firm of Grant Thornton International Ltd6
ISO 37001: Anti - Bribery Management System ISO BACKGROUND ISO is a globally recognized authority that establishes standards across a wide range of industries. ISO 37001 has been a closely monitored standard throughout it's development and it's publication opens up a new perspective on ABAC compliance:
ISO 37001 is an anti-bribery management system (ABMS) standard for organizations. It specifies various anti-bribery policies and procedures which an organization should implement to assist it prevent bribery, and identify and deal with any bribery which does occur. It is published by the International Organization for Standardization (ISO .
n ISO 37001 cannot provide absolute assurance that no bribery will occur. But can help establish that organization has implemented reasonable and proportionate anti-bribery measures. n The risk of bribery is reduced and the playing field is levelled for organizations if certification to ISO 37001 is a project pre-qualification requirement.
What is the ISO 37001 Anti-bribery Management Systems standard? –Why was it created? –How is the standard different from the FCPA? –What are its benefits? How does ISO 37001 work? –What is/are its structure, contents, principles and key concepts? How does an organization prepare for an ISO 37001 certification audit?
ISO 45001 : 2018 Health & Safety (OH&S) Management Systems ISO 37001 : 2016 Anti-Bribery Management Systems ISO 28000 : 2007 Supply Chain Security Management Systems ISO 21001 : 2018 Education Management Systems ISO 22000 : 2018 Food Safety Management Systems ISO 50001 : 2018 Energy Management Systems ISO 20000-1 : 2018 IT Service Management Part 1
Anti Bribery Management System (ISO 37001) . An anti-bribery management system (ABMS) designed to introduce an anti bribery culture within an organization and implement appropriate controls, which will in turn increase the chance of detecting bribery and reduce its
ISO 37001: THE NEW STANDARD FOR ANTI-BRIBERY MANAGEMENT What is the focus of the standard? The ISO 37001 standard, published in October 2016, is designed to help an organization implement and maintain a proactive anti-bribery system. The standard, which replaced the British Standar
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, vetting and training employees, undertaking risk
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