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?