ETHIC Intelligence hosts its third annual international conference
on corruption prevention Standards and Guidelines

OECD Conference Centre, Paris - Monday, September 10, 2018

ETHIC Intelligence is very pleased to host its third annual international conference on Standards and Guidelines in corruption prevention on September 10, 2018 at the OECD Conference Centre in Paris. Click below to view photos and videos from last year’s event where experts from business, civil society and government exchanged and debated issues related to the fight against corruption.

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ISO 37001 for small and medium sized enterprises: why and how 

For small to medium-sized enterprises who need to implement an anti-corruption compliance policy the ISO 37001 is a useful, easy-to-use and affordable reference.

In addition to its function as a certifiable standard, ISO 37001 can be used as a handbook to develop an anti-bribery management system.

Small and medium-sized companies often lack adequate resources for support functions including compliance. The implementation of an anti-bribery management system is often viewed as an onerous expense particularly if the risk it is designed to meet is misunderstood by the relevant actors.

The standard offers a simple methodology for the design, implementation and continual improvement of an anti-bribery management system appropriate to the needs of the company. The company simply needs to follow the different sections of the standard step-by-step and pay particular attention to section 4 which focuses on the context of the organization. 

The central tenet of the standard is that anti-bribery management systems be adapted to:

  • the specific organization and activity of the organization (section 4)
  • the expectations of the stakeholders including clients and national authorities (Italy, USA, UK, Russia, Brazil, Spain and France) which recommend or impose certain obligations in corruption prevention (section 4.2)
  • the risks specific to the organization given its activity, the way it operates, its countries of operation, etc… (section 4.5)


Having participated in the drafting of the standard, I can affirm that it was the intention of participating delegations to ensure that the standard be useful to small and medium-sized enterprises. 

For small to medium-sized companies it is relatively easy to respond to the questions in section 4 and then identify the measures necessary for implementation in order to limit identified corruption risk. These include:

  • the involvement of top management (section 5) which is self-evident for a small to medium-sized company on such an undertaking;
  • planning of the implementation over a certain period, over 3 years, for example (section 6);
  • definition of the resources required particularly human resources, and budgetary if necessary (section 7)
  • implementation of prevention tools (due diligence, gifts and invitations policy, etc. (section 8) adapted to the specific needs of the company
  • regular evaluation – ie. annual – of the implementation of the program (section 9) which is standard for any management system
  • continual improvement to the Anti-Bribery Management System based on the aforementioned evaluations (Section 10)


The advantages of an ISO 37001 certification form a real return on investment vis-à-vis the cost of an ISO 37001 audit.
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Having participated in the drafting of the standard, I can affirm that it was the intention of participating delegations to ensure that the standard be useful to small and medium-sized enterprises. This is evident in the frequent use of the terms ‘reasonable’ and ‘appropriate’ to reassure small to medium-sized companies that an anti-bribery management system is an affordable tool for all companies, not just the wealthier multi-nationals.

And, finally, drafters of the 37001 made sure to include an annex of detailed guidelines so that the standard is as informative as possible. For example, details on the development of prevention tools required in section 8 will be found in the annex: due diligence (section A.10), gifts and invitations policy (section A.15) etc.…

Why an ISO 37001 certification could be useful for SMEs

Although I believe that the ISO 37001 is first and foremost a useful reference for the development of an anti-bribery management system, there are still situations where certification would bring even more advantages to SMEs.

I envisage two primary situations where SMEs should consider certification:

  1. Certain multinationals, dedicated to corruption prevention, send questionnaires to their potential suppliers and service providers on their commitment to doing business with integrity before any contract is signed. Completing these questionnaires is time-consuming for the SMEs. In addition, multinationals do not send the same questionnaire so an SME will often find itself obliged to repeat the exercise time and again. And the fact that an SME has successfully completed an integrity questionnaire for one multi-national does not mean that it has qualified itself to work with other multi-nationals without completing their own versions of an integrity questionnaire. In this context, an ISO 37001 certification allows the SME to demonstrate to the multi-nationals that a qualified third party has verified that the SME implements an anti-bribery management system which meets international best practices standards. ISO 37001 certification then could reasonably reduce the amount of time SMEs spend on completing integrity questionnaires.

  2. The second instance I see where an SME could benefit from an ISO 37001 certification involves situations where an SME is bidding on a public or private call for tender. In a response to a call for tender where price and offers of service are very similar amongst companies a policy dedicated to social responsibility or a commitment to sustainable development has made the difference. Today, proof of an appropriate, effective anti-bribery management system, can make a similar difference between two competing bidders. ISO 37001 certification gives a comparative advantage.

In both cases, the advantages of an ISO 37001 certification form a real return on investment vis-à-vis the cost of an ISO 37001 audit.  




03 JUL, 2017 Category : Blog no comment 750 Views

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Philippe Montigny President, ETHIC Intelligence Certification Committee

Philippe Montigny is CEO of ETHIC Intelligence and Chairman of its Certification Committee. Philippe has over 20 years of experience in advising companies on strategies to prevent corruption and leverage business integrity.

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The compliance community must navigate amidst an ever-changing landscape of laws, recommendations, emerging corruption risks, trends in investigations and the threat of prosecution. The ambition of this blog is to bring this landscape into focus while raising compliance effectiveness from both a business and legal perspective.

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