Anti-Bribery Management – Policy & Due Diligence
ABMS policy + third-party due diligence
Cách dùng: Third parties are where risk concentrates: unusual payment terms and government connections are red flags auditors expect documented. No-retaliation wording is required for the reporting channel.
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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? |
|---|---|---|---|---|---|