Implementing ISO 37001:2025 is not only about fulfilling documentation and procedural requirements. Organizations also need to build an anti-bribery culture that is consistently embedded at every level of the organization.

This is an important aspect of Clause 5.1.3 of ISO 37001:2025, which emphasizes the development, maintenance, and promotion of an anti-bribery culture throughout the organization.

This culture should be supported by leadership commitment, clear policies, reporting mechanisms, awareness, and risk management in business relationships.

What Is an Anti-Bribery Culture?

An anti-bribery culture refers to the values, ethics, beliefs, and behaviors embedded throughout an organization to support its policies and Anti-Bribery Management System (ABMS).

In practice, this culture cannot be established through written policies alone. Organizations need to demonstrate that leaders and employees consistently demonstrate behaviors that promote integrity and prevent bribery.

How Can Organizations Build an Anti-Bribery Culture?

1. Strengthening Tone at the Top

A culture of integrity will not work if it does not start from top management. The Board of Directors and leadership must show real commitment, not just signatures on paper.

Implementation in Organizations:

• Top management routinely delivers anti-bribery messages at every large meeting or townhall.
• Establish an independent compliance function and be given adequate authority and resources.
• Leaders provide direct examples, for example by openly rejecting gratuities from vendors and reporting them to the compliance unit.

2. Implementing a Zero-Tolerance Policy

There are no exceptions or “notices” to the practice of bribery, no matter how small the value or how large the business profit target is sought to be achieved.

Implementation in Organizations:

• Establish and socialize the Anti-Bribery Policy which includes clear rules related to gifts, entertainment, donations, and facilitation payments).
• Apply strict sanctions (up to termination of employment or reporting to the legal realm) for anyone proven to be in violation, regardless of position.

3. Building a Speak-Up Culture

Employees and external parties should feel safe and supported to report suspicions or indications of violations without fear of retaliation.

Implementation in Organizations:

• Provide  an easily accessible, confidential Whistleblowing System (WBS) channel that allows for anonymous reporting (e.g. via a dedicated website, email, or independent hotline).
• Issue a Non-Retaliation policy  that guarantees that well-meaning whistleblowers will not be demolished, fired, or intimidated.

4. Strengthening Risk Awareness and Training

Culture is formed from the right understanding. Every individual must know the forms of covert bribery and how to avoid them.

Implementation in Organizations:

• Conduct regular anti-bribery training that is adjusted to the level of risk of the position (procurement or sales employees  must receive more in-depth training).
• Regularly update the Bribery Risk Assessment to adjust to the latest business dynamics.
• Require employees to sign an Integrity Pact every year.

5. Strengthening Integrity in Business Relationships

The organization does not operate alone. The anti-bribery culture must be extended to third parties (vendors, agents, consultants) acting on behalf of the organization.

Implementation in Organizations:

• Conduct due diligence before establishing business partnerships or recruiting personnel in high-risk positions.              
• Incorporating an anti-bribery compliance clause (ISO 37001 clause) into any cooperation contract with a third party.

Why Is an Anti-Bribery Culture Important in ISO 37001:2025?

ISO 37001:2025 provides a management system framework to help organizations prevent, detect, and respond to bribery. The standard also recognizes integrity culture as an important part of an anti-bribery management system.

Therefore, the effectiveness of ISO 37001:2025 implementation should not be assessed solely based on the existence of policies and procedures.

Organizations should also be able to provide evidence that anti-bribery commitments are reflected in behavior, decision-making, training, reporting, and business relationships.

From Policy to Anti-Bribery Culture

The implementation of ISO 37001:2025 can be summarized through the following approach:

Leadership → Policy → Awareness → Reporting → Risk Management → Evidence

This means organizations need to establish leadership commitment, implement clear policies, strengthen awareness, provide reporting mechanisms, manage bribery risks, and ensure that implementation can be demonstrated through appropriate evidence.

An anti-bribery culture is not only about having rules. It is about making those rules part of organizational behavior.

Build an Anti-Bribery Culture with CBQA Global

CBQA Global supports organizations in strengthening their Anti-Bribery Management System (ABMS) through Certification, Audit, and Training services.

Organizations can also strengthen their knowledge and competencies through ISO 37001:2025 and Anti-Bribery Training programs at CBQA Academy.

For ISO 37001:2025 Certification, Anti-Bribery Management System, or Anti-Bribery Training, contact CBQA Global to discuss your organization’s requirements.

Contact CBQA Global for more information:
Email: info@cbqaglobal.com
WhatsApp: 08118468777
Phone: +62 21 2781 4200

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