Awareness-raising and education: The keys to a successful implementation of the ISO 37001:2016 Anti-Bribery in organizations
No organization is immune to bribery. Therefore, implementing the ISO 37001:2016 Anti Bribery Management System (ABMS) in company activities is one of the best first steps to address this risk.
Tone from the top adds to the legitimacy of this policy. However, that alone is not enough.
In order for standards to be implemented effectively, companies need to consistently promote these standards to relevant parties — employees, third parties such as vendors/suppliers and its supply chain, and consumers/clients.
This is also stipulated in the ISO 37001:2016 standard requirements, namely the clause on Support. The clause basically encourages the organization to provide the necessary resources to support and improve the implementation of the anti-bribery system. This support includes an Awareness and Training clause and a Communication clause.
Awareness and Training
This clause encourages the organization to provide adequate Anti-Bribery Awareness and Training programs for employees and business partners. This program is conducted periodically as a reminder and for the provision of the latest relevant information.
Organizations can focus this program on employees whose scope of work demands a great deal of exposure and contact with external parties, or those who have a high risk of exposure to bribery. For example, personnel from the sales and procurement departments, as well as other operational employees who deal directly with external parties.
The contents of the training are designed according to their roles, the bribery risks they face, and the results of the risk assessment.
In addition to applying it to personnel, organizations are also encouraged to implement this program within the supply chain, namely to third parties they work with. The hope is that third parties will at least implement adequate internal controls.
Outreach to the masses
Consistent communication is an important part of implementing an anti-bribery policy. Even though an organization already has an anti-bribery policy in place, if management does not communicate it to related parties, they will not know about it. This will only result in the system being nothing more than an ornament.
Therefore, the Communication clause encourages organizations to communicate their policies to internal and external parties, including clients and partners.
Communication with employees can be done in several ways:
- Share policy-related content through regular email blasts, including those related to the whistleblowing system policy.
- Set up content with related themes that can be seen by computer screen savers at any time.
- For new employees, policies can be conveyed during the introduction of company culture during onboarding.
- Include an anti-bribery component in employee performance appraisal or selection of the best employee.
To external parties, organizations can submit anti-bribery policies in proposals or cooperation agreement documents in the form of clear clauses. In addition, project tenders involving partners or third parties must be carried out in an open and proportional manner.
In essence, organizations need to actively and periodically disseminate information and ensure that this policy is accessible and available to relevant parties.
