May 20, 2025
Strengthening Anti-Bribery Management Systems: Operation, Evaluation, and Improvement
A strong is essential for protecting an organization’s integrity and reputation.
Clause 8 of ISO 37001 is where an Anti-Bribery Management System becomes truly operational. It covers the implementation of controls, due diligence, and procedures to prevent bribery in day-to-day activities, especially in high-risk areas like gifts, donations, and third-party relationships. This clause also ensures that the system is continually monitored and improved through audits, incident reports, and performance reviews. In essence, Clause 8 turns policy into practice,making anti-bribery efforts measurable, enforceable, and adaptable over time.
Operation: Planning and Controlling Activities
Operation is the foundation for minimizing bribery risks. Organizations must plan, implement, and control key processes, including:
- Operational Planning and Control: Managing planned and unintended changes, including outsourced activities.
- Due Diligence: Assessing business associates and partners for bribery risks.
- Financial and Non-Financial Controls: Implementing systems to prevent and detect improper practices.
- Third-Party Management: Ensuring business partners meet anti-bribery standards.
- Gifts, Hospitality, and Donations: Regulating practices to avoid conflicts of interest.
- Handling Concerns: Establishing secure reporting channels and investigation procedures.
If bribery risks are assessed as higher than “low,” organizations must apply appropriate operational controls proportionate to the nature and extent of the risk.
Evaluation: Monitoring and Corrective Actions
To maintain an effective ABMS, organizations should regularly apply key evaluation practices, including:
- Internal audits and management reviews:
Regular audits assess how well the ABMS is functioning, identify gaps, and ensure top-level oversight through management reviews. - Corrective actions for nonconformities:
Any issues found should be addressed promptly by identifying root causes and implementing measures to prevent recurrence. - Performance data analysis:
Ongoing review of key metrics—such as incidents, audit results, and training completion—helps identify trends and shape future improvements.
Evaluation not only ensures compliance but also strengthens overall system resilience.
Improvement: Continuous Anti-Bribery Progress
Continuous improvement is critical for adapting to evolving risks. Organizations should:
- Enhance anti-bribery processes and practices:
Regularly update policies, controls, and training to reflect new risks, regulations, and best practices. - Correct weaknesses promptly:
Address nonconformities quickly by identifying root causes and implementing corrective actions to prevent recurrence. - Promote a culture of learning and integrity:
Foster open communication, recognize ethical behavior, and share lessons learned to strengthen a culture of integrity across all levels.
At PECB Skills, we champion continuous learning to empower professionals in strengthening and sustaining effective compliance programs.
The pillars of a robust Anti-Bribery Management System—Operation, Evaluation, and Improvement require a proactive and systematic approach. By effectively managing bribery risks, organizations foster trust, enhance resilience, and create long-term value. With the right training and tools from PECB Skills, leaders can navigate today’s compliance landscape with confidence.
Our mission is to equip professionals and organizations with the knowledge and strategies needed to build resilient and compliant systems that stand the test of time.
