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Readiness for ISO 37001 — Anti-Bribery Management

Assess how close your business is to the requirements of ISO 37001:2025.

26 questions · ~6 min

Anonymous: we don't ask for a name, email or company details. Only the answers are kept, with nothing that identifies you, for statistics.

How to answer

Choose “Yes” only when the requirement is applied in practice and there is documentation or records. “Partly” means it is done informally or not everywhere.

4 Context of the organization

4.1 Have you recorded the internal and external issues (e.g. market, competition, technology, legislation) that affect your anti-bribery management system?

4.2 Have you identified the interested parties (customers, employees, authorities, suppliers, etc.) and their requirements?

4.5 Has a bribery risk assessment been carried out (by activity, market, type of transaction and business associate), and is it reviewed periodically?

4.3–4.4 Has the scope of your anti-bribery management system been defined in writing (activities, sites, any exclusions), and have the main processes been mapped?

5 Leadership

5.1 Is top management actively involved in the anti-bribery management system, providing resources and building it into business decisions?

5.2 Is there an approved anti-bribery policy that suits the business, has been communicated to staff and is available to those who need it?

5.3 Have roles, responsibilities and authorities for the system been defined and communicated?

5.3.2 Has an anti-bribery compliance function been appointed with enough authority, independence and direct access to top management?

6 Planning

6.1 Have you assessed the risks and opportunities related to your anti-bribery management system and planned actions to address them?

6.2 Are there measurable anti-bribery objectives with owners, resources, a timeline and a way of monitoring them?

7 Support

7.1–7.2 Have you defined the competence required for each relevant role, and do you keep records of training, experience or qualifications?

7.3–7.4 Are staff aware of the anti-bribery policy and of their contribution to the system, and is there a defined way of communicating internally and externally?

7.2.2 Do hiring procedures include screening for higher-risk roles and a commitment to comply with the policy?

7.5 Are the system's documents and records controlled (approval, versions, distribution, storage, retention)?

8 Operation

8.2 Is due diligence carried out on transactions, projects, business associates and personnel with a higher bribery risk?

8.3–8.4 Are financial and non-financial controls applied (dual approvals, segregation of duties, checks on payments and purchases)?

8.5–8.6 Do controlled companies and high-risk business associates apply equivalent controls, and have they given written commitments?

8.7 Are there rules for gifts, hospitality, donations and sponsorships, with limits and a register?

8.9 Is there a secure and confidential way to report concerns (whistleblowing), with protection from retaliation?

8.10 Is there a procedure for investigating and dealing with bribery incidents?

9 Performance evaluation

9.1 Do you monitor, measure and analyse indicators of the anti-bribery system's performance and evaluate the results?

9.4 Does the compliance function periodically assess the adequacy of the system and report on it to top management?

9.2 Is there an internal audit programme, and has at least one full internal audit of the system been completed by a competent person?

9.3 Has a management review of the system been held and recorded, with decisions and actions?

10 Improvement

10 Are nonconformities recorded, their causes analysed, and corrective actions taken and checked for effectiveness?

10 Are there documented examples of continual improvement of the system?

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