New update of the international standard for the Anti-Bribery Management System ISO 37001

Below are the key changes explained:

1. New Harmonized and Integrated Structure.

This new structure not only makes it easier to understand the requirements but also allows for efficient integration between various management systems, providing a coherent foundation that minimizes redundancies, optimizes efficiency, and ensures that all requirements are aligned in the same direction. 

2. Greater Focus on Anti-Bribery Culture.

A greater emphasis has been placed on the anti-bribery culture in section 5.1.3, which establishes that bribery prevention is not limited to documented procedures but also includes the promotion of behaviors, values, and daily practices within the organization.

3. Clarity of the Anti-Bribery Function.

Covered in section 5.3.2, this function, which was previously linked to the compliance area, is now redefined more precisely to avoid overlap with other management systems, such as Compliance (ISO 37301).

4. New Definition of Conflicts of Interest.

The conflict of interest was already part of the 2016 version, but now it is redefined in section 3.28 and expanded in Annex A. This update provides clearer guidance on how to manage conflicts in key processes such as recruitment, especially in roles sensitive to bribery risks (ISO 37009:2025).

5. Differentiation Between Training and Awareness.

In section 7.3, the new standard clearly separates awareness from training to avoid confusion between the two concepts.

6. Climate Change.

Sub-clauses on climate change have been added, and the importance of a compliance culture among stakeholders has been emphasized.

7. Update of Annex A.

It offers more detailed guidelines on topics such as anti-bribery culture and conflict of interest management. Its structure has also been adjusted to better align with the main body of the standard, making its consultation and implementation much easier.

What Impact Do These Changes Have on Companies That Need to Make This Update?

Although the modifications do not represent a drastic transformation of the standard, they do strengthen its robustness, clarity, and practical feasibility, reinforcing the ethical culture, avoiding ambiguous interpretations in the assignment of responsibilities, integrating the anti-bribery system with other systems, increasing stakeholder trust, and demonstrating a real and measurable commitment to integrity.

Companies that already have an anti-bribery management system will be able to easily adjust it to align with international best practices.

How can we assist you?

At Forvis Mazars, we have professionals with expertise in the implementation of the international standard ISO 37001 related to the Anti-Bribery Management System. If you need support in implementing or complying with the obligations outlined in this newsletter, please contact us via the email addresses provided, and we will be happy to discuss the best way to assist you.