Strategy & Policy Workshop: ISO 37001 Anti-Bribery and Corruption Management (5-Days)

Day 1

Introduction to today's business legal context driving the need for a formal anti-bribery and corruption system

• How are bribery and corruption fully defined?
  • Official bribery versus commercial bribery
  • Typical examples
• High-level comparative overview of laws and regulation requiring a formal Anti-Bribery and Corruption Management System
  • OECD Convention Anti-Bribery Convention
  • United Nations Convention against Corruption
  • United States - Foreign Corrupt Practices Act (FCPA)
  • United Kingdom - Bribery Act
  • Canada - Corruption of Foreign Public Officials Act (CFPOA)
  • Mexico's General Law of Administrative Accountability and Model Program for Corporation Integrity
  • France - Sapin II
  • Germany - German Administrative Act
  • Russia - Federal Anti-Corruption Law No. 273, Article 13.3
• Overview of how the ISO 37001 standard provides a common framework for a program that fulfills differing international requirements for bribery and corruption control

Establishing, managing, and performing anti-bribery and corruption controls

• Introduction to ISO 37001, "Anti-bribery management systems - requirements with guidance for use"
  • The Plan-Do-Check-Act (PDCA) process approach
  • Overview of integrating an ISO 37001-certified anti-bribery management system into the organization's comprehensive enterprise risk management system
• Establishing the Anti-Bribery and Corruption (ABC) Management System (ISO 37001 Clauses 4 - 5)
  • Determining internal and external business context drivers that form ABC strategic requirements, goals, and objectives
  • Determining the scope of the ABC management system
  • Defining the ABC management system
  • Performing bribery and corruption risk assessment (Inherent risk assessment + operational risk assessments + ongoing risk monitoring)
    1. risk identification
    2. risk analysis
    3. risk evaluation (impact assessment)
  • Establishing top-down ABC system leadership
    1. Leadership requirements for top management
    2. Establishing a formal ABC system policy defining the ABC system goals (what it will accomplish) based upon internal and external context requirements (Soft-copy policy template available)
    3. Establishing appropriate roles and responsibility throughout the organization to detect, investigate, and correct potential bribery and corruption
       • Establishing a formal ABC compliance function in accordance with local, national, and international requirements

Day 2

Establishing, managing, and performing anti-bribery and corruption controls, continued

• Establishing top-down ABC system leadership
  • Leadership requirements for top management
  • Establishing a formal ABC system policy defining the ABC system goals (what it will accomplish) based upon internal and external context requirements requirements (Soft-copy policy template available)
  • Establishing appropriate roles and responsibility throughout the organization to detect, investigate, and correct potential bribery and corruption
    1. Establishing a formal ABC compliance function in accordance with local, national, and international requirements
• Planning the ABC Management System (ISO 37001 Clause 6)
  • Planning the ABC goals to align with defined business context requirements and system (ABC risks and opportunities)
  • Planning ABC objectives to fulfill ABC system goals and requirements
• Supporting the ABC Management System (ISO Clause 7)
  • Properly budgeting and supporting the ABC management system
  • Establishing and validating appropriate ABC Management System competence and skills (ISO Clause 7)
    1. General competence and skills development, validation, and maintenance for top and senior management for ABC System Management
    2. Employment process requirements
  • General Awareness and training requirements for all staff
  • Communication requirements
  • Documentation requirements

Day 3

Establishing, managing, and performing anti-bribery and corruption controls, continued

• Integrating ABC into Operations (ISO 37001 Clause 8)
  • Developing and implementing operational planning and control processes to fulfill planned ABC objectives, goals, and requirements
  • Performing ABC due diligence 
  • Implementing financial ABC controls
  • Implementing non-financial ABC controls throughout the organization, including (but not limited to) procurement, operations, sales, commercial, human resources, and regulatory activities
  • Establishing upstream ABC requirements for vendors and suppliers
  • Establishing formal ABC incident response measures
  • Establish operational policies and procedures preventing bribery
  • Continuously monitoring ABC control effectiveness
  • Establishing a ABC tip program to facilitate ABC risk identification
  • Investigating suspected ABC incidents, or even ABC vulnerabilities

Day 4

Measuring the performance and effectiveness of the ABC Management System and ABC Controls (ISO 37001 Clause 9)

• Internal audit requirements
• Management review requirements
• Governing body / Board of Directors review requirements
• ABC Compliance function review requirements

Continuous improvement and corrective action (ISO 37001 Clause 10)

Break-out Class Lab: ABC Management System Gap Assessment

Day 5

Understanding typical high-risk areas for bribery and corruption

• Procurement Corruption / Facilitation and Extortion Payments
  • Bribery
  • Kickbacks
  • Improper gratuities
  • Bid rigging
• Sales corruption
  • Selling product discounts
  • Fraudulent sales and/or debt write-off/release
• Conflict of Interest Schemes
  • Shell companies
  • Business diversions

Training Certificate of attendance (32 CPE) awarded

Optional Online Certification Exam (Student laptop required)

• Online practice exams provided throughout the week for live instructor-led classes
• Participants successfully completing the training and the corresponding certification exam will be awarded a professional certificate for "Certified ISO 37001 Anti-Bribery & Corruption Manager"

* ISO Standards are NOT included in this management system and compliance training, nor are provided in class. Students are encouraged to bring their own hard-copies of the standards to the class. ISO standards are available for purchase at www.iso.org.