# Anti-Bribery Management – Policy & Due Diligence

> ISO 37001:2016 (ABMS). Two artifacts: the anti-bribery policy all
> staff sign, and the due diligence record for third parties –
> intermediaries are where bribery risk concentrates.

| Field | Value |
|-------|-------|
| Document ID | DOC-ABMS-NNN |
| Owner | Compliance function |
| Approved by | Governing body |

## Part A – Anti-bribery policy (cl.5.2)

- Zero tolerance for bribery in any form, direct or through third
  parties – giving AND receiving.
- Covers: facilitation payments (prohibited), gifts & hospitality
  (threshold + register), donations, sponsorships, political
  contributions.
- Non-compliance = disciplinary action up to termination.
- Reporting channel: confidential, no retaliation – whistleblower
  protection stated explicitly.
- Signed acknowledgment by all personnel + relevant third parties.

## Part B – Third-party due diligence (cl.8.2)

| Field | Value |
|-------|-------|
| Third party | name |
| Relationship | agent/distributor/consultant/JV |
| Risk rating | high/medium/low |
| Assessed by | @name |
| Date | YYYY-MM-DD |

### Risk indicators

| Indicator | Present? | Notes |
|-----------|----------|-------|
| Operates in high-corruption jurisdiction | | index ref |
| Government interaction on our behalf | | |
| Unusual payment terms (cash, offshore) | | red flag |
| Recommended by official/government | | red flag |
| Compensation disproportionate to service | | |
| Prior integrity issues / PEP ownership | | |

### Due diligence performed

- [ ] Background check / adverse media
- [ ] Beneficial ownership verified
- [ ] References checked
- [ ] Contract includes anti-bribery clauses + audit rights + termination right
- [ ] Training/certification obtained from third party

### Decision

- [ ] Approved – low risk
- [ ] Approved with controls: (monitoring, payment caps, contract terms)
- [ ] Declined – risk exceeds tolerance

## Part C – Gifts & hospitality register

| Date | Giver/receiver | Item | Value | Approved? | Declined? |
|------|----------------|------|-------|-----------|-----------|
| | | | | | |