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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:
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:
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.…
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:
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.
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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