The requirements for the implementation of ISO 37001 ABMS are mentioned in the ten clauses of the Annex SL of the High-level Structure of the standard. The first three clauses are introductory in nature, whereas the remaining clauses give the specifications for the implementation of IS 37001. These are explained below:
Clause 4 – Context of the organization: This section has 5 sub-clauses that describe what is important for the implementation of an Anti-bribery Management System in your organization. It helps you in determining your anti-bribery objectives and practices. It takes into consideration the needs and requirements of your shareholders and interested parties.
Clause 5- Leadership: This section deals with the role of top management in ensuring the best practices in anti-bribery management. It includes approving anti-bribery policies of the organization, ensuring the alignment of the organization’s strategy in anti-bribery policy, receiving and reviewing information about the operation of the anti-bribery management system, ensuring that no personnel suffers retaliation on reporting any incident of bribery in the organization, etc.
Clause 6- Planning: It deals with the planning of an anti-bribery management system by referring to the external and internal factors in the context of the organization. It also involves assessing the bribery risk and their effective control.
Clause 7- Support: This includes all the necessary resources for the implementation, maintenance, and improvement of the anti-bribery management system. It requires the organization to implement controls related to the employment terms and conditions.
Clause 8- Operation: This deals with the need of planning, implementing, monitor, and control the processes to meet the requirements of the anti-bribery management system. The organizations are required to assess their risks and impart appropriate controls to check them.
Clause 9- Performance evaluation: The organizations are required to evaluate the performance of their management system to verify if the processes and controls are delivering the desired outcomes. The organization should review and report at regular and planned intervals to the top management about the effectiveness and shortcomings of the ABMS.
Clause 10- Improvement: The organization is required to analyze its gap so that it can plan and execute the corrective measures. This leads to the continual improvement of the anti-bribery management system so that it can face any challenges with respect to bribery.