Navigating the Changes: ISO 37001:2016/Amd 1:2024 Explained
In today’s business landscape, where integrity, sustainability, and compliance are paramount, ISO 37001:2016 stands out as a crucial standard for promoting anti-bribery management systems. Positioned at the heart of ethics and due diligence, this standard transcends compliance; it embodies a commitment to fostering transparency and accountability in the fight against corruption. With environmental responsibility becoming increasingly vital, the upcoming Amendment 1:2024 is particularly relevant. This amendment aims to align the standard with the urgent need for climate action, risk management, and carbon footprint reduction, emphasising the role of businesses in fostering a more ethical and sustainable world.
This article explores the specifics of ISO 37001:2016 and its forthcoming amendment, explaining why this standard and its update are essential for modern business strategies that prioritise sustainability and integrity. We’ll break down Amendment 1 to show how it addresses climate action changes and highlights the growing importance of environmental considerations in corporate governance. Additionally, we’ll offer strategic implementation tips for organisations looking to adopt the updated standards, emphasising the role of due diligence, ethics, and compliance in mitigating risks and promoting a sustainable business model. By reading this, you’ll gain a roadmap for navigating the updated ISO 37001:2016/Amd 1:2024 landscape, marking a significant step toward integrating climate considerations into business ethics and integrity.
Understanding ISO 37001 and Its Importance
What is ISO 37001?
ISO 37001, introduced by the International Organisation for Standardisation in October 2016, is a comprehensive anti-bribery management system (ABMS) standard. It outlines a series of policies and procedures to help organisations prevent, identify, and address bribery. This includes implementing an anti-bribery policy, appointing a compliance officer, conducting training, performing risk assessments, due diligence on projects and business associates, and instituting financial and commercial controls.
The Role of Anti-Bribery Management Systems
The significance of ISO 37001 extends beyond mere compliance. It represents a global effort to eliminate bribery and corruption, some of the most destructive challenges worldwide. By providing a universally recognised framework, ISO 37001 helps organisations cultivate a culture of integrity, transparency, and trust. This framework combats the turnover of over a trillion dollars of illicit funds annually and reinforces the credibility of institutions and businesses by ensuring fair operations free from bribery.
Global Adoption and Impact
The impact of ISO 37001 is evident in its adoption by various governments and leading corporations worldwide. For instance, the governments of Singapore and Peru have adopted this standard for their anti-bribery systems. Additionally, it has influenced the “Shenzhen Standard,” an official anti-bribery standard in Shenzhen, China. Companies like Microsoft and Walmart aim to obtain ISO 37001 certification, showcasing its broad influence and recognition as a crucial tool in fighting corruption. This widespread adoption highlights the standard’s versatility and applicability across different sectors and organisational sizes, making it a key instrument in promoting ethical business practices globally.
Unpacking Amendment 1: Climate Action Changes
Overview of Amendment 1: 2024
The ISO and the International Accreditation Forum (IAF) have introduced amendments to 31 Annex SL management system standards, including ISO 37001:2016, to incorporate climate change considerations. Effective from February 2024, this initiative aims to align business operations with international climate agreements and emphasise the importance of climate change in organisational management systems.
Key Changes and Additions
Two significant changes are included in the ISO 37001:2016 amendment. First, organisations must assess whether climate change is relevant to their operations (Clause 4.1). Second, they must consider climate change-related requirements of interested parties (Clause 4.2). These additions underscore the need for sustainability clauses in contracts with cloud service providers and a broader commitment to reducing carbon footprints and addressing climate impacts.
Implications for Existing ISO 37001 Certifications
Organisations with ISO 37001 certifications must now integrate climate change considerations into their anti-bribery management systems. This involves reviewing internal and external issues, including climate change, and adjusting policies, procedures, and processes accordingly. The amendments require immediate implementation and will be assessed by auditors without a transition period. Failure to incorporate these changes could result in non-conformities during audits, stressing the importance of systematically considering climate change in organisational analyses and risk assessments.
Strategic Implementation of ISO 37001 Amendment 1
Preparing for the Transition
To navigate the transition to ISO 37001:2016/Amd 1:2024, organisations should review their current management systems to identify necessary adjustments in light of the new climate action changes. This includes assessing the relevance of climate change to their operations and integrating sustainability clauses into contracts with cloud service providers. The transition requires demonstrating conformance to the updated standards, ensuring climate change considerations are embedded in anti-bribery management systems.
Best Practices for Integrating Climate Action
Integrating climate action into anti-bribery management involves assessing internal and external issues related to climate change and adapting policies, procedures, and processes. Organisations should determine whether climate change is a relevant issue and integrate climate-related requirements into their management systems. This includes evaluating the impact of climate change on business context and considering the climate change-related requirements of interested parties. By doing so, organisations can enhance resilience and adaptability to climate-related risks.
Conclusion
The enhancements introduced by ISO 37001:2016/Amd 1:2024 not only reinforce the global commitment to anti-bribery management systems but also integrate climate action into corporate governance. Including climate considerations represents a progressive step toward aligning business operations with environmental goals, ensuring resilience and competitiveness in a changing global landscape. By prioritising sustainability and integrity, organisations can mitigate risks and contribute to a more ethical and sustainable world.
Navigating the complexities of these standards requires expert guidance. Engaging with seasoned professionals like CRI Group is essential for a smooth transition and certification process. Their expertise ensures that your organisation meets the updated ISO 37001:2016/Amd 1:2024 requirements and enhances overall performance and credibility. By fostering transparency, accountability, and environmental stewardship, businesses can comply with international standards and drive meaningful change.
CRI Group’s Services:
- Comprehensive risk assessments
- Anti-bribery policy formulation
- Compliance officer training and appointment
- Detailed due diligence on projects and business associates
- Implementation of financial and commercial controls
- Guidance on integrating climate change considerations into management systems
- Audit support to ensure adherence to updated ISO 37001 standards
ABAC Group’s Services:
- Training and certification for ISO 37001 compliance
- Tailored risk management solutions
- Anti-bribery and anti-corruption consulting
- Investigative research services
- Compliance and ethics program development
- Third-party risk management
- Whistleblowing hotline services
- Due diligence and background checks
By leveraging these services, your organisation can achieve compliance and strengthen its commitment to ethical and sustainable business practices.
CRI celebrates the 2022 International Anti-Corruption Day
The world today is plagued with some of the biggest issues of all time. The plague of corruption is intertwined in most of them, threatening the prosperity and stability of many countries. Corruption negatively impacts several aspects of society and is intertwined with conflict and instability jeopardising social and economic development and undermining democratic institutions and the rule of law.
Corruption fuels conflict and hampers peace by undermining the rule of law, and facilitating the illegal use of resources for armed conflict or illicit substances like drugs.
The United Nations designated 9 December as International Anti-Corruption Day, to raise awareness of corruption and of the role of the United Nations Convention against Corruption in combating and preventing it. The Convention entered into force in December 2005.
The 2022 International Anti-Corruption Day (IACD) looks at driving home the crucial link between anti-corruption and peace, security, and development. Tackling this crime is the right and responsibility of everyone, and this is possible only through cooperation and the involvement of all people and institutions in play, says the United Nations.
The Corruption Perceptions Index (CPI), published annually by the non-governmental organisation Transparency International ranked 180 countries “on a scale from 100 (very clean) to 0 (highly corrupt)” based on the situation between 1 May 2020 and 30 April 2021. As per the CPI, Denmark, New Zealand, Finland, Singapore, and Sweden are perceived as the least corrupt nations in the world, ranking consistently high among international financial transparency, while the most apparently corrupt are Syria, Somalia, and South Sudan.
Some staggering stats on corruption
- Here are some interesting statistics from transparency.org to blow your socks off:
- £100 billion of dirty money passes through UK systems and services every year.
- 87,000 land titles in England and Wales are owned by opaque corporate structures that hide the true owners.
- 76% think wealthy individuals often use their influence on Government for their own interests.
- Just 52 people made a sixth of all declared UK political donations between 2001 and 2016.
- £1.27 billion is lost annually to fraud, bribery and corruption in the NHS.
And some more stats for you on the Anti-Corruption Day:
- The annual costs of international corruption is estimated to amount to a staggering $3.6 trillion in the form of bribes and stolen money.
- Corruption often impacts the poorest in societies the most. In Paraguay, the poorest households are forced to pay nearly 13% of their income in bribes – twice as much as the richest households.
- Airbus was fined £3.6 billion in February 2020 by courts in the UK, US and France for slush funds, “success payments” and lavish hospitality.
- £820 million of this fine was paid in the UK. This is more than double the total of fines paid in respect of all criminal conduct in England and Wales in 2018.
And even more statistics on corruption:
- Corruption in the health sector kills an estimated 140,000 children a year.
- Up to 25% of public procurement funds are lost to corruption each year.
- Governments are spending $7.5 trillion a year on providing healthcare globally. But corruption means that $500billion (7%) of that money is lost.
- The World Health Organisation estimates $370billion would be enough to give everyone on the planet access to healthcare.
- Every year, pharmaceutical companies, universities and other research groups conduct around 20,000 clinical trials involving over two million patients worldwide, at an estimated cost of over US$60 billion.
- An estimated US$85 billion in medical research funding is being wasted every year as trials that cost millions to run fail to contribute to medical progress because their results are not reported.
As you can see from these statistics, corruption is a problem worldwide, costing both huge amounts of money and precious lives. Corruption and bribery can impact any organisation and cause severe harm to businesses, including causing financial loss, dire legal consequences, brand damage, damage to an organisation’s reputation and impeding sustainable development. The only way to get beyond this menace is through international collaboration.
Please make use of this opportunity to educate yourself better and your personnel to work towards a more transparent corporate model while seamlessly integrating it into your day-to-day lives. Ethical business always begins from within, and CRI Group™ is more than happy to help you through this.
Matters surrounding risk management and compliance can be daunting, so why not contact CRI Group™? Our experts have years of experience and have been trained to provide your business with bespoke advice that fits your organisations’ needs. Implement preventative measures in your workplace today and guide your team to an ethical and correct way of working on this Anti-Corruption Day.
Who is CRI Group™?
Based in London, CRI Group™ works with companies across the Americas, Europe, Africa, Middle East and Asia-Pacific as a one-stop international Risk Management, Employee Background Screening, Business Intelligence, TPRM, Due Diligence, Compliance Solutions and other professional Investigative Research solutions provider. We have the largest proprietary network of background-screening analysts and investigators across the Middle East and Asia. Our global presence ensures that no matter how international your operations are, we have the network needed to provide you with all you need, wherever you happen to be. CRI Group™ also holds BS 102000:2013 and BS 7858:2012 Certifications, is an HRO certified provider and partner with Oracle.
In 2016, CRI Group™ launched the Anti-Bribery Anti-Corruption (ABAC™) Center of Excellence – an independent certification body that provides education and certification services for individuals and organisations on a wide range of disciplines and ISO standards, including ISO 31000:2018 Risk Management- Guidelines; ISO 37000:2021 Governance of Organisations; ISO 37002:2021 Whistleblowing Management System; ISO 37301:2021 (formerly ISO 19600) Compliance Management system (CMS); Anti-Money Laundering (AML); and ISO 37001:2016 Anti-Bribery Management Systems ABMS. ABAC® offers a complete suite of solutions designed to help organisations mitigate the internal and external risks associated with operating in multi-jurisdiction and multi-cultural environments while assisting in developing frameworks for strategic compliance programs. Contact ABAC™ for more on ISO Certification and training.
CRI® Group’s DueDiligence360™ involves a review of all relevant information pertaining to virtually any business on the planet to ascertain past business dealings, criminal records, executive stability and suspect associations to ensure your organisation is protected from internal threats and outside risks.
CRI® Group’s exclusive 3PRM-Certified™ solution provides Third-Party Risk Management while ensuring compliance with FCPA, UK Bribery Act, Anti-Bribery and Anti-Corruption, and other global, regional and local regulations.
CRI® Group’s EmploySmart™ — a pre-employment background screening process, can boost your fraud prevention efforts and provide a “boots on the ground” approach to extensive background checking.
LEARN MORE ABOUT OUR SOLUTIONS
Contact CRI Group™ today to learn more about preventing and detecting corruption.
Supply Chain Due Diligence Act: New Risk Management & Reporting Duties for German Businesses
This article looks at the Supply Chain Due Diligence Act (LkSG) that applies to companies operating or trading in Germany and will enter into force on 1 January 2023.
The new German law, known as the Supply Chain Due Diligence Act (LkSG, short for Lieferkettensorgfaltspflichtengesetz in German) imposes due diligence obligations on environmental protection and on human rights, with all businesses having to introduce iterative and ongoing, or in certain circumstances ad hoc, due diligence processes specified by the Act.
Identification and management of an organisation’s supply chain and the risks that come with it require the implementation of due diligence processes.
The term “supply chain” refers to all products/services of a business, including all manufacturing and services, in Germany and/or abroad, from the extraction of raw materials to their delivery to the end customer.
Furthermore, due diligence processes should implement the following criteria:
- type and scope of the business activities of the company subject to the due diligence obligations,
- the ability of the company subject to the due diligence obligations to exert influence (so-called leverage),
- typically expected severity of the violation, and
- type of contribution by the company subject to the due diligence obligations to cause a violation.
More details can be had in our FREE Supply Chain Due Diligence Act (LkSG) eBook.
Who is Affected by the Supply Chain Due Diligence Act?
- As of 1 January 2023: Companies with at least 3,000 employees that have their head office, administrative seat or statutory seat in Germany OR companies that have a branch in Germany and usually employ at least 3,000 employees in this branch;
- As of 1 January 2024: Companies with at least 1,000 employees that have their head office, administrative seat or statutory seat in Germany OR companies that have a branch in Germany and usually employ at least 1,000 employees in this branch.
From 2024, the law will apply to businesses with more than 1,000 employees.
Even if companies with fewer employees are not addressees of the Supply Chain Act, they may still be indirectly affected. This is because the companies directly affected would be obliged to enforce compliance to the best of their ability with human rights in their supply chain. The measures necessary for this can have a direct impact on their suppliers, for example, through the implementation of a code of conduct. In addition, the directly affected companies will often be dependent on the active support of their suppliers and thus have this support be contractually assured, e.g. in the form of reporting obligations as part of their risk analysis.
DOWNLOAD THE SUPPLY CHAIN DUE DILIGENCE ACT (LkSG) EBOOK.
Due Diligence Investigations: Mitigate Critical Risks
At CRI®, we provide corporate reporting and due diligence services wherever you are. Use our DueDiligence360™ reports to help you comply with anti-money laundering, anti-bribery, and anti-corruption regulations ahead of a merger, acquisition, or joint venture. You can also use them for third-party risk assessment, onboarding decision-making, and identifying beneficial ownership structures.
Due Diligence helps you Identify key risk issues clearly and concisely using accurate information in a well-structured and transparent report format. Our comprehensive range of reports includes specialised reports that support specific compliance requirements. Protect your reputation and the risk of financial damage and regulator action using our detailed reports. They enhance your knowledge and understanding of the customer, supplier, and third-party risk, helping you avoid those involved with financial crime.
The CRI® Group invites you to schedule a quick appointment with them to discuss in more detail how conducting due diligence and compliance can help you and your organisation.
Based in London, CRI Group™ works with companies across the Americas, Europe, Africa, Middle East and Asia-Pacific as a one-stop international Risk Management, Employee Background Screening, Business Intelligence, TPRM, Due Diligence, Compliance Solutions and other professional Investigative Research solutions provider.
We have the largest proprietary network of background-screening analysts and investigators across the Middle East and Asia. Our global presence ensures that no matter how international your operations are we have the network needed to provide you with all you need, wherever you happen to be. CRI Group™ also holds BS 102000:2013 and BS 7858:2012 Certifications, is an HRO certified provider and partner with Oracle.
How to Protect Your IP with Brand Protection Investigations?
Intellectual Property (IP) is an exclusive right of the brand owner. This property includes intangible creations of the brand owners’ human intellect; therefore, the brand owners are lawful copyright or trademark owners. However, when unscrupulous individuals indulge in manufacturing and distributing counterfeit products of well-known brands, the result is the loss of sales, a tarnished brand image and erosion of brand loyalty, not to mention the ill effects of consumption by the consumer and the loss of revenue to the government. This is when Brand protection services are crucial to business integrity.
Counterfeiting threatens the fabric of national economies, endangers safety and frequently kills. It devalues corporate reputations, hinders investment, funds terrorism, and costs hundreds of thousands of people their livelihood annually. Companies and organizations face IP-related risks from a multitude of sources, namely:
- From within the organization itself;
- From entities in the ecosystem of the organization;
- From competitors;
- From independent 3rd parties; and/or
- From illegal entities.
It is important to consider the risks to your intellectual property and take the steps necessary to protect your brand. Because of the potential complexity of IP investigations you should consider consulting experts. Investigators who are specially trained to protect the brand equity and customer loyalty you’ve built by providing professional assistance in the areas of:
- Trade Secret Breaches
- Data Breaches & IP Leaks
- Theft of Proprietary Customer Data
- Copyright Abuse
- Unauthorized Use of Trademarks
- Counterfeit & Pirated Products
- Threats to Brand Integrity & Reputation
- Brand Imitation & Product Copying
- Global Counterfeiting Investigations
Getting help
Brand protection services can:
- Research and investigate the legal aspects of copyright, trademark and patent claims
- Identify the company and/or individuals that have breached your IP rights
- Perform background and financial investigations on subjects involved in IP infringement
- Pinpoint the source and location of the manufacturer in counterfeit product claims
- Establish new delivery channels for the trade of your products
As an integral member of the ICC Counterfeiting Intelligence Bureau, CRI Group™ is certified to advise and assist organizations with intellectual property investigations involving grey market and product counterfeiting crimes.
CRI Group™ utilizes various techniques, analytics, and global technology to investigate intellectual property infringements, including the use of international Counterfeiting Seizure Maps and International Anti-Counterfeiting Directories. Our strategic partnerships with IP firms worldwide ensure that leads are identified and investigated and claims are settled expeditiously.
CRI Group™ Intellectual Property (IP) Investigations:
- Trademark Investigations
- Intellectual Property Acquisition Services
- Patent Investigations
- Brand, Media and Internet Monitoring Services
- Anti-Counterfeiting Programs
- Brand Integrity Programs
- Copyright Abuse Investigations
- Cyber Surveillance
- Litigation Support
CRI™ is an ideal partner to be the eyes and ears of brands across markets, offline and online. Our multidisciplinary experts regularly review and scan the online marketplaces to keep a close eye on fake products. From online surveillance to supply chain audits and real-time market surveys, brands will find CRI™ the ideal long-term partner to keep a close eye on all markets. You, meanwhile, can focus on running the business and building your brand.
CRI Group™ invites you to schedule a quick appointment with us to discuss in more detail how our Brand Protection Solutions can help you and your organization.
About CRI Group™
For short, Corporate Research and Investigations Limited, or CRI Group™, has protected businesses from fraud, bribery, and corruption since 1990. Globally, we are a leading Compliance and Risk Management company licensed and incorporated entity of the Dubai International Financial Center (DIFC) and Qatar Financial Center (QFC). CRI™ protects businesses by establishing the legal compliance, financial viability, and integrity levels of outside partners, suppliers and customers seeking to affiliate with your business. Based in London, United Kingdom, CRI™ is a global company with experts and resources in key regional marketplaces across the Asia Pacific, South Asia, the Middle East, North Africa, Europe, and North and South America. Our global team can support your organization anywhere in the world.
Fraud Prevention Strategy: Build One in Five Simple Steps
Fraud Prevention Strategy: The 5 Simple Steps
A fraud prevention strategy is one of the key policies that can aid an organization in safeguarding itself against reprimands of the matter. One of the greatest encounters a fraud auditor can confront is the mission of persuading management that the peril of fraud exists across all aspects of corporate culture – regardless of whether it is from internal factors or external factors. Fraud cannot ever be eradicated from the corporation as collusion is adept in continually conquering routine organizational regulations.
What is the strategy?
The objective of a Fraud Prevention Strategy is to identify a high-level proposal on how an organization should implement its fraud prevention policy in the presence of its internal and external influences. The strategy forms the most important part of the fraud deterrence strategy; thus, the policy an organization chooses to implement must be straightforward and pragmatic.
Combating fraud requires a distinct and refreshing methodology that entails including all three facets of the fraud cycle:
- Fraud deterrence and prevention
- Fraud detection
- Fraud investigation
Preferably, with the fraud cycle in mind, every enterprise ought to put together a distinctly specified fraud prevention strategy that integrates the following:
- Determine the proper culture with the proposed policy: having protocols and policies in place for dealing with fraud will help you establish a good grounding for identifying it.
- Counteract and detect: To detect fraud, you need to have effective systems and processes in place covering all aspects of your business.
- Investigation of any occurrences in which fraud occurs.
- Review and monitor policies and occasions in which fraud has transpired regularly to ensure that fraud levels stay below the goal amount.
- Learn from previous occurrences and update training procedures.
- Risk management covers all types of risk, from corporate and social responsibility compliance to performance measurement.
To learn more about third-party risk management, why not check out our 3PRM brochure.
What should be established in a fraud prevention strategy:
1. Whistleblowing policy
Whistleblowing is the act of exposing information about misconduct in the workplace and is a crucial element in any prevention strategy. When whistle-blower hotlines are implemented and sustained correctly, they can substantially decrease an organization’s exposure to fraud by permitting for prior detection and thus savings in the form of reduced fraud losses from the prior detection.
2. Identify the risks:
The risk of fraud is not solely based on an employee’s background but also a myriad of other factors. Most notably, it is important to be able to identify risks by nature of items (some examples include size and value, ease of resale and cash), nature of the control environment (including separation of duties, safeguards, complexity, turnover and related party transactions) and pressures ( i.e., level of dissatisfaction – if the workforce is unhappy with the company, they will be more inclined to engage in fraud, expectations and guarantees). Identifying these risks is the first step in figuring out how to counteract them, thus preventing fraud.
3. Implement effective controls:
When it comes to implementation, organizations need to ensure that they complete the action plan and then refer it to an appropriate person – in most instances. This is from HR and other figures in leadership to management of employees. It is then up to the subordinates to assist them with implementing the strategy, reviewing the strategy, or delegating it to the employees.
Most policies implement:
- Making employees aware of emergency procedures
- Making employees aware of the location of first aid stations
- Educating employees on the location and obvious danger and workplace hazards
- Examine health and safety workplace responsibilities; wear the necessary protective clothing or equipment, participate and have input to management report incidents or mishaps as considered essential by management.
4. Increase awareness of the risks:
It must not be presumed that staff members have an innate perception of the risks of fraud or that they have any understanding of the scope of risks that encircle them. This means that it is incredibly important to stimulate a risk-conscious culture within an organization.
Some examples of methods to increase such awareness include:
- Performing risk audits and engaging as many individuals as possible in the organization in the risk auditing procedure
- Benchmarking – studying “best practices” from other organizations that have executed risk management.
- Sending organization personnel to attend industry seminars on fraud prevention as well as risk management
5. Plan for the worst:
It might sound pessimistic, but it is always best to prepare yourself and your employees for the worst-case scenario. Unfortunately, as hard as we try to minimize fraud, it cannot, be fully eradicated. If it appears too good to be true, it most likely is. It is good practice to meticulously probe all agreements, prospects, transactions, data and documents.
Want to know more about recruiting the right people for your organization? Visit our page on Background Screening services or view our EmploySmart brochure.
Crucial components that a proper fraud prevention strategy accomplishes:
It is easy to infer that fraud can leak into all aspects of corporate culture and can destroy an organization from within. Despite this issue, several organizations opt not to implement a fraud prevention strategy – it is primarily implied that this is ascribed to the absence of knowledge circulating on the benefits of such a strategy. However, the rewards reaped from this type of policy is beneficial to corporations eventually and can reap the rewards such as:
- Lower consequential loss pertaining to fraud
- Lesser/no legal and investigative costs relating to fraud
- Lesser/no regulatory fines paid in the occurrence of fraud
- Better time management can be used to enrich employees’ knowledge and experience at the organization.
- Reduced insurance premiums
- Lower turnover of key staff and customers
- The lessened cost of/capability to increase new finance
Overall, the process of preventing fraud can be an extensive one, but one whose benefits outweigh the onerous course. Protect your organization from liability, business interruption and brand damage by partnering with the CRI® Group. Our 3PRM solution address various specific areas, including:
- Third-Party Integrity Due Diligence & Screening: ensures global compliance, provides adequate monitoring & protection against potential litigation;
- 3PRM Enhanced Background Checks: uncovers derogatory information within the public & private record resources through risk-based background checks, including investigative research into suppliers & individuals, ultimate-beneficial owners;
- ISO 37001 Anti-Bribery Management System: CRI® Group’s independent and accredited Certification Body can examine your Anti-Bribery & Anti-Corruption procedures & issue an accredited Certification; and
- ISO 37301 Compliance Management System: CRI® Group’s independent certification body helps companies worldwide to increase & measure their efforts against regulatory compliance risks.
If you still have any questions surrounding fraud prevention, why not contact CRI®? Our experts have years of experience and have been trained to provide your business with bespoke advice that fits your organizations’ needs.
Don’t hesitate to prevent fraud in your workplace today.
About us…
Based in London, CRI Group™ works with companies across the Americas, Europe, Africa, Middle East and Asia-Pacific as a one-stop international Risk Management, Employee Background Screening, Business Intelligence, Due Diligence, Compliance Solutions and other professional Investigative Research solutions provider. We have the largest proprietary network of background screening analysts and investigators across the Middle East and Asia. Our global presence ensures that no matter how international your operations are, we have the network needed to provide you with all you need, wherever you happen to be. CRI Group™ also holds BS102000:2013 and BS7858:2019 Certifications is an HRO certified provider and partner with Oracle.
In 2016, CRI Group™ launched the Anti-Bribery Anti-Corruption (ABAC™) Center of Excellence – an independent certification body established for ISO 37001:2016 Anti-Bribery Management Systems, ISO 37301 Compliance Management Systems and ISO 31000:2018 Risk Management, providing training and certification. ABAC™ operates through its global network of certified ethics and compliance professionals, qualified auditors and other certified professionals. As a result, CRI Group’s global team of certified fraud examiners work as a discreet white-labelled supplier to some of the world’s largest organizations. Contact ABAC™ for more on ISO Certification and training.
Time to get ISO 37001:2016 Certified – The Process, Part 2
Shifting a light on anti-Bribery and anti-corruption methods, our sister brand ABAC™ Centre of Excellence tells us how key is ISO 37001:2016 Anti-Bribery Management System Certification is for public, private, and non-profit organisations across the globe and explains the process behind certification. At CRI™, we believe it is important as it provides a key layer against threats of bribery, corruption, fraud and other security concerns. It also sets an organisation apart from its peers as a model for ethical behaviour and compliance.
In a recent guest blog, ABAC™ Centre of Excellence discussed the first part of getting ISO 37001:2016 certified. ABAC™ covered the initial engagement and the first four steps, including the audit confirmation, pre-assessment, and stage one and two audit processes. Today our sister brand ABAC™ will discuss the rest of the certification process and the path to getting your organisation better protected and fully compliant in addition to CRI Group’s corporate due diligence services.
Step 5: Follow up Audit (optional)
If a major non-conformity is raised or remains outstanding from Stage 1, an additional visit will need to be booked. For major non-conformity raised during Stage 2, a revisit will be required within 30 days of submitting the CAP to confirm the implementation of an effective CAP.
Step 6: Awarding of Certificate
If the organisation is compliant with the standard conditions, a recommendation for certification will be made.
- For minor non-conformities: This will not delay the certificate if an organisation has a CAP. The certificate is granted within 04 weeks from the time of CAP submission.
- For major non-conformities, the organisation must submit and implement CAP within 180 days maximum. Once the auditor has verified the CAP, the certificate is granted within six weeks (from the time of CAP submission by the Client). However, all major non-conformities will need to be addressed before a certificate can be published.
Step 7: Continual improvement and surveillance audits
Surveillance is planned over three years and will ensure that the organisation complies with the standard.
Step 8: Re-certification Audit
The registration period is three years from the date on the certificate. After the initial registration period, renewing your Anti-Bribery Management System Certification is relatively seamless. Once the second surveillance visit has been completed, you will be sent a registration renewal/re-certification proposal detailing the process and associated costs and assessment days for the next three years. A re-certification audit will require Stage 1 and Stage 2 audit. The depth of the audit and time required would be determined as per your performance (during the certification period) and any planned changes to your system. It’s that easy. Now is the time to move forward with ISO 37001:2016 certification.
What comes next?
For assistance in developing and implementing an Anti-Bribery Management System, go to www.abacgroup.com, contact ABAC™. today or get a FREE QUOTE!
In 2016, CRI Group™ launched Anti-Bribery Anti-Corruption (ABAC™) Center of Excellence – an independent certification body that provides education and certification services for individuals and organisations on a wide range of disciplines and ISO standards, including ISO 31000:2018 Risk Management- Guidelines, ISO 37000:2021 Governance of Organisations, ISO 37002:2021 Whistleblowing Management System, ISO 37301:2021 (formerly ISO 19600) Compliance Management system, Anti-Money Laundering (AML) and ISO 37001:2016 Anti-Bribery Management Systems.
Who is CRI Group™?
Based in London, CRI Group™ works with companies across the Americas, Europe, Africa, Middle East and Asia-Pacific as a one-stop international Risk Management, Employee Background Screening, Business Intelligence, Due Diligence, Compliance Solutions and other professional Investigative Research solutions provider. We have the largest proprietary network of background-screening analysts and investigators across the Middle East and Asia. Our global presence ensures that no matter how international your operations are, we have the network needed to provide you with all you need, wherever you happen to be. CRI Group™ also holds BS 102000:2013 and BS 7858:2012 Certifications, is an HRO certified provider and partner with Oracle.
Time to get ISO 37001 Certified – The Process, Part 1
Shifting a light on anti-Bribery and anti-corruption methods, our sister brand ABAC™ Centre of Excellence tells us how key is ISO 37001:2016 Anti-Bribery Management System Certification is for public, private, and non-profit organisations across the globe and explains the process behind certification. At CRI®, we believe it is important as it provides a key layer against threats of bribery, corruption, fraud and other security concerns. It also sets an organisation apart from its peers as a model for ethical behaviour and compliance. After all, consider the benefits: Certification adds a distinct level of credibility to the organisation’s management systems and ensures that the organisation implements a viable anti-bribery management program utilising widely accepted controls and systems.
It assures management, investors, business associates, personnel and other stakeholders that the organisation is actively pursuing internationally recognised and accepted processes to prevent bribery and corruption. ISO 37001:2016 certification also protects the organisation, its assets, shareholders and directors from the effects of bribery. But what, exactly, is the process for getting ISO 37001:2016 certified by ABAC Group™? Once your organisation has submitted questionnaire information and completed the approval and contract stage, the certification cycle is ready to begin.
Step 1: Audit confirmation
An audit plan will be developed with your organisation and confirmed to the Certification’s Body Assessment Team at least three months before the organisation’s first audit.
Step 2: Pre-assessment audit (optional)
The organisation can opt to perform a pre-assessment audit to identify any possible gaps between its current management system and the standard requirements. This audit is optional and helps the organisation check its preparedness for the stage 1 and 2 assessments by identifying any major non-conformities that have not been addressed.
Step 3: Stage 1 audit
Review the results of the audit, including:
- General observations
- Non-conformities (major or minor, see below)
Minor non-conformities: These are not seen as serious. The organisation must complete an internal Corrective Action Plan (CAP) before Stage 2. CAP is not required to be sent to the Assessment Team at Stage 1.
Major non-conformities: These are more serious. The organisation will need to submit a CAP within ten days of receiving the audit report, with all actions scheduled to be completed before Stage 2. The CAP should be sent to the Assessment Team. The major non-conformities raised during Stage 1 will be re-assessed during Stage 2 Audit.
Step 4: Stage 2 audit
This is an on-site audit and takes place after the organisation has successfully completed Stage 1 and corrected any major non-conformities identified during the Stage 1 audit. Stage 2 confirms that the organisation’s management system is fully aligned to the standard. The evaluation is of management system implementation and its effectiveness.
Outcome: The audit report will detail the following:
- Any positive observations
- Opportunities for improvement – suggestions for improvement and any findings that could lead to potential non-conformities.
- Non-conformities (Major or Minor)
- Recommendation for Certification
Minor non-conformities: The organisation must complete an internal Corrective Action Plan (CAP) and submit this to the Assessment Team within 45 working days of receiving the audit report. The Assessment Team will review the CAP; it must detail the non-conformity, the cause, the proposed corrective action, who is responsible and the date the action will be implemented. Based on the evaluation of CAP, the recommendation for certification will be made.
For minor non-conformities, if an organisation has a corrective action procedure, this will not delay the certificate.
Major non-conformities: The organisation must complete an internal Corrective Action Plan (CAP) and submit it within 90 days (or 180 days depending on the number and risk of major non-conformities) of receiving the audit report be sent to the auditor.
What Comes Next?
Stay tuned for the second instalment in our two-part series about the ISO 37001:2016 certification process: sign up for our newsletter HERE!
In 2016, CRI Group™ launched Anti-Bribery Anti-Corruption (ABAC™) Center of Excellence – an independent certification body that provides education and certification services for individuals and organisations on a wide range of disciplines and ISO standards, including ISO 31000:2018 Risk Management- Guidelines, ISO 37000:2021 Governance of Organisations, ISO 37002:2021 Whistleblowing Management System, ISO 37301:2021 (formerly ISO 19600) Compliance Management system, Anti-Money Laundering (AML) and ISO 37001:2016 Anti-Bribery Management Systems.
Who is CRI Group™?
Based in London, CRI Group™ works with companies across the Americas, Europe, Africa, Middle East and Asia-Pacific as a one-stop international Risk Management, Employee Background Screening, Business Intelligence, Due Diligence, Compliance Solutions and other professional Investigative Research solutions provider. We have the largest proprietary network of background-screening analysts and investigators across the Middle East and Asia. Our global presence ensures that no matter how international your operations are, we have the network needed to provide you with all you need, wherever you happen to be. CRI Group™ also holds BS 102000:2013 and BS 7858:2012 Certifications, is an HRO certified provider and partner with Oracle.
Risk Assessment Breakdown: Identification, Analysis, and Evaluation
Risk management is a full-time, ongoing endeavour for organisations in today’s business world, and it poses constant challenges. Unfortunately, fraud, bribery and corruption are major factors affecting businesses and agencies of all sizes and industries. Being proactive against these risks can mean the difference between success and ruin. Whatever your reasons or motivations might be, if your organisation’s objective is to have an effective risk assessment management strategy in place. This article discusses the importance of Risk Assessment. There are two important building blocks that form the core of risk management:
- Risk assessment
- Risk treatment
Each of these stages can stand on their own – in this article we will go into detail about best practices for identifying risks, how to analyse them in terms of probability and severity, and how they can be evaluated in terms of the company’s risk appetite.
What is Risk Assessment?
Risk assessment is the overall process of identification, analysis and evaluation of any given risk. It can be a systematic examination of a task, job or process that a risk professional carries out at work for the purpose of identifying significant hazards. For example, the risk of someone being harmed and deciding what further control measures to take to reduce the risk to an acceptable level. The process will vary between organisations, but it should start with identification of hazards, analysis of who and what might be harmed, evaluation of the risk, documentation of the risks, taking action and review. Your organisation should conduct a risk assessment systematically, interactively and collaboratively, drawing on the knowledge and views of stakeholders. It should use the best available information, supplemented by a further inquiry as necessary.
Risk assessment breaks down into:
- Step 1: Identification
- Step 2: Analysis
- Step 3: Evaluation
Business Intelligence (BI) Solutions can help during this stage. BI take many shapes and forms in today’s complex business environment. Budgets are stretched and the challenges facing a business and its employees can sometimes lead to issues that start off small, but then lead to wider spread problems which can affect the very fabric of your organisation and damage both your credibility, reputation and bottom line profits. CRI Group™ takes two approaches to BI solutions:
- Intelligence operations (via market research and analysis): we focus on researching the future and potential growth of your business – i.e. determine the commercial viability and potential for success in the market, analyse consumer behaviour and business trends in that market, etc.
- Investigative operations (via commercial investigations): we focus on the current status of your business – i.e. location of assets, financial information, identification of unmet needs of any market, gauge brand awareness and identity in the market, etc.)
CHECK OUT OUR BI SOLUTIONS or DOWNLOAD BROCHURE
Risk Identification
The purpose of risk identification is to find, recognise and describe risks that might help or prevent an organisation achieving its objectives. Relevant, appropriate and up-to-date information is important in identifying risks. The organisation can use a range of techniques for identifying uncertainties that may affect one or more objectives. The following factors, and the relationship between these factors, should be considered:
- Tangible and intangible sources of risk;
- Causes and events;
- Threats and opportunities;
- Vulnerabilities and capabilities;
- Changes in the external and internal context;
- Indicators of emerging risks;
- The nature and value of assets and resources;
- Consequences and their impact on objectives;
- Limitations of knowledge and reliability of information;
- Time-related factors;
- Biases, assumptions and beliefs of those involved.
Your organisation should identify risks, whether or not your sources are under your control. Consideration should be given that there may be more than one type of outcome, which may result in a variety of tangible or intangible consequences.
Risk Analysis
Risk analysis allows you to understand the nature of risk, its characteristics and level. Because an event can have multiple causes and consequences and can affect multiple objectives a risk analysis should involve a detailed consideration of uncertainties such as risk sources, consequences, likelihood, events, scenarios, controls and their effectiveness.
Risk analysis can be undertaken with varying degrees of detail and complexity, depending on the purpose of the analysis, the availability and reliability of the information, and the resources available. Analysis techniques can be qualitative, quantitative or a combination of both, depending on the circumstances and intended use. Risk analysis should consider factors such as:
- The likelihood of events and consequences;
- The nature and magnitude of consequences;
- Complexity and connectivity;
- Time-related factors and volatility;
- The effectiveness of existing controls;
- Sensitivity and confidence levels.
A risk analysis is likely to be influenced by a wide range of variables, from any divergence of opinions, biases to perceptions of risk, from judgements, quality of the information used to the assumptions and exclusions made and any limitations of the techniques and how they are executed. These influences should be considered any risk analysis, documented and communicated to any decision-makers involved in the process.
It is important to remember that any highly uncertain event can be difficult to quantify, and this is an issue. If you find yourself in such a situation, using a combination of techniques generally provides greater insight. Risk analysis provides input to risk evaluation, to decisions on whether risk needs to be treated and how, and on the most appropriate risk treatment strategy and methods. The results provide insight for decisions, where choices are being made, and the options involve different types and levels of risk.
Risk Evaluation
Risk evaluation can support your decisions. Risk evaluation involves comparing the results of the risk analysis with the established risk criteria to determine where additional action is required. This can lead to a decision to:
- Do nothing further;
- Consider risk treatment options;
- Undertake further analysis to better understand the risk;
- Maintain existing controls;
- Reconsider objectives.
Any decisions should take into account the wider context and the actual and perceived consequences to external and internal stakeholders. The outcome of risk evaluation should be recorded, communicated and then validated at appropriate levels of the organisation.
Who should do Risk Assessments?
Well, by law, every employer must conduct risk assessments. Risk assessments should always be carried out by a professional who is familiar to risk, a person who is experienced and competent to do so. Competence can be expressed as a combination of knowledge, awareness, training, and experience. Remember competence does not mean you have to know everything about everything, competence also means knowing when you know enough or when you should call in further expert help.
But we all like to think that all of our employees will be trustworthy, but this is not always the case. There have been many instances in which an employee has been dishonest about their job history, qualifications or even criminal history. A dishonest employee could be unqualified for the position, possibly endangering others on the job. Or they might be a fraud risk, willing to bend the truth in other ways in order to enrich or advance themselves on your dime. No organisation can afford to have employees or staff who aren’t what they claim to be. Even a seemingly innocent embellishment can indicate more background problems under the surface, and the potential for future problems down the road so remember, trust your employees but, verify them too.
CHECK OUT OUR EMPLOYEE BACKGROUND SCREENING SOLUTIONS or DOWNLOAD BROCHURE
Risk Assessment and ISO 31000 Certification with ABAC™
While the team at CRI® do not deliver any training or certification on ISO 31000, our partner ABAC™ Center of Excellence do. ISO 31000 can provide the principles, framework and a process for managing risk. ISO 31000 is not a certifiable standard; the standard is a set of guidelines which provide guidance for internal or external audit programmes. However we recommend taking ISO 31000 Awareness training, this will enable you to fully understand Risk Management activities and mitigate risk.
ISO 31000 was developed by hundreds of experts in risk mitigation, from thirty countries. This international effort produced a standard that is worldwide and represents best practices and leading operations for risk management. Organisations can trust that they are following a tested, robust standard to increase success. The standard converts risk management into a set of “friendly” and actionable – and straightforward to implement – guidelines, regardless of the size, nature, or location of a business.
The training helps establish an ethical culture by educating your personnel on the following:
- What constitutes fraud, corruption, and bribery, and why these are so damaging to business
- How to identify red flags of fraud, corruption, and bribery
- The process for reporting fraudulent and unethical acts
- The organization’s zero-tolerance attitude toward unethical behaviour and willingness to terminate employees for breaches, and prosecute unethical acts
- The serious ramifications for committing fraud or bribery, the legal consequences, and the negative impact on one’s career
The ISO certifications helps us at ABAC™ to provide appropriate anti-bribery training to personnel across various industries. This standard helps to assess bribery risks, perform the appropriate due diligence required for your business and to take reasonable and proportionate steps to ensure that controlled organizations and business associates have implemented appropriate anti-bribery controls.
> Find out more about ISO 31000 Risk Management and other standards now!
Other Solutions
While CRI™ may not offer the ISO certification, we do offer other services. We specialise in solutions regarding compliance, working as trusted partners to businesses and institutions across the globe. Our experts work with energy, insight and care to ensure we provide a positive experience to everyone involved – clients, reference providers and candidates. CRI’s unique identity and vision evolved from our fundamental desire to support our clients and their candidates, thus creating the DueDiligence360™.
The DueDiligence360TM reports to help organisations comply with anti-money laundering, anti-bribery, and anti-corruption regulations. This service also proves beneficial ahead of a merger, acquisition, or joint venture as it can be used for a third-party risk assessment, onboarding decision-making, and identifying beneficial ownership structures. Identifying key risk issues clearly and concisely helps enhance your knowledge and understanding of the customer, supplier, and third-party risk, helping you avoid those involved with financial crime.
Why not consider our background investigative solutions? Employee Background Checks can aid in reducing the risk of hiring an employee who does not live up to their supposed skill set and could cause irrevocable damage. Firms spend years, thousands, even millions to brand their products and services – it only takes one bad hire to cause loss of capital and reputation. It can go as far as bringing a business to fail – especially if the employee holds malice towards the organisation. EmploySmart™ is CRI’s own solution aiming to expose vulnerabilities and threats within your organisation. Much like the ISO certification, our EmploySmart™ is a risk management measure which can be used to significantly reduce business and financial crime, fraud and malpractice within your workplace.
Our solutions are also certified by the British Standard Institute BSI for the scope of BS 7858:2019 Screening of individuals working in a secure environment, Code of practice (the only BS 7858 certified background screening services provider in the UAE and across the Middle East); and BS 102000:2018 Code of practice for the provision of investigative services.
Another risk management solution to consider from CRI® is our Third-Party Risk Management solution (TPRM), also known as 3PRM™. In wake of the global pandemic, the 3PRM™ was developed in a bid to aid organisations to accurately determine the legal compliance, financial viability, and integrity levels of external parties, vendors, and customers who seek to be affiliated with and represent the business.
The 3PRM-Certified™ program consists of gap analysis and investigative due diligence on the targeted above parties. This highly thorough program reveals anti-corruption, compliance and risk management discrepancies associated with the international regulatory framework helping your business to flourish at any scale. Find out more about CRI Group’s Solutions here.
If you’re unsure of what solution may be best for you and your business, how about connecting with one of our experts for a free consultation? Receive tailored advice from the top analysts and investigators across the globe.
About CRI Group™
Based in London, CRI™ works with companies across the Americas, Europe, Africa, Middle East and Asia-Pacific as a one-stop international Risk Management, Employee Background Screening, Business Intelligence, Due Diligence, Compliance Solutions and other professional Investigative Research solutions provider. We have the largest proprietary network of background-screening analysts and investigators across the Middle East and Asia. Our global presence ensures that no matter how international your operations are we have the network needed to provide you with all you need, wherever you happen to be. CRI™ also holds BS 102000:2013 and BS 7858:2012 Certifications, is an HRO certified provider and partner with Oracle.
In 2016, CRI™ launched Anti-Bribery Anti-Corruption (ABAC™) Center of Excellence – an independent certification body established for ISO 37001:2016 Anti-Bribery Management Systems, ISO 37301 Compliance Management Systems and ISO 31000:2018 Risk Management, providing training and certification. ABAC™ operates through its global network of certified ethics and compliance professionals, qualified auditors and other certified professionals. As a result, CRI® Group’s global team of certified fraud examiners work as a discreet white-labelled supplier to some of the world’s largest organisations. Contact ABAC™ for more on ISO Certification and training.
WEBINAR | Breaking Down The ISO 37001 Audit Process
There is no “one-size-fits-all” method to the ISO 37001 Audit Process to achieve the anti-bribery management systems certification
There’s been much discussion surrounding ISO 37001:2016 Anti-Bribery Management Systems and the ways that attaining certification to the standard can enhance an organisation’s existing anti-corruption compliance program.
The ISO 37001:2016 standard specifies a series of measures and controls to help organisations prevent, detect and address bribery. These measures include adopting an anti-bribery policy, appointing an individual to oversee anti-bribery compliance, training, risk assessments and due diligence on projects and business associates, implementing financial and commercial controls, and instituting reporting, investigation and monitoring procedures.
CRI Group’s ABAC™ will be hosting a paid webinar on the 30th of September exploring the Pitfalls Most Organisations Often Commit – the importance of implementing Anti-Bribery Management System (ABMS). Being a part of the solution means being able to share our expert knowledge on what would be best for your organisation.
Our webinar will have a rundown of the following:
- What are the core Bribery and Corruption Risks for Financial Institution?
- How to protect financial institutions and corporations from bribery and corruption risk
- Reparations from bribery that could affect the businesses, clients, and employees
- Successful regulations to mitigate risk for bribery and corruption.
- What can be done if bribery is detected?
- Internationally recognised solutions laid forth by ISO 37001: Anti-Bribery Management System that gives businesses effective controls to mitigate risk
- Components of risk management at a financial institution
Certification of compliance with the standard is based on an impartial, independent third-party review, assessment and audit of the organisation’s anti-bribery management system and the versatility, effectiveness and proactive nature of said system.
The compliance audit itself has too often been referred to as a “one-size-fits-all” or “check-the-box” subjective process, which couldn’t be further from the truth. Proper certification to the standard requires a substantial amount of preparation and self-assessment beforehand; a highly involved review, interview and audit process (often involving a sampling of affiliated or regional offices); and an evaluation and monitoring phase which is annually conducted over the three-year certification cycle.
Let’s take a brief look at the audit process and examine why large multi-national companies such as Walmart, Microsoft, Alstom and a host of others have weighed the costs and benefits, and subsequently committed to attaining ISO 37001:2016 certification.
An Evidence-Based Review; A Risk-Based Approach
The ABMS audit is a diligent approach that links auditing activity to an organisation’s overall risk management framework, providing assurance to top management that risk management processes are effectively addressing all bribery risks throughout the organisation and its operations.
It should be noted that the certification audit isn’t solely structured on a review of paper-based controls. As you’ll read below, the process assesses the organisation’s overarching stance on anti-bribery and how that stance is conveyed — tangibly and intangibly — from the board of directors right down to lower-level staff members.
Employing interviews, policy reviews, sampling, due diligence and testing of methods and techniques, the audit will produce sufficient evidence of a sound anti-bribery management system, while spotlighting specific areas of risk that demand attention and subsequent improvement to adhere to the standard.
Certified Auditors; ISO 37001 Anti-Bribery Experts
First and foremost, ISO 37001:2016 auditors must be specifically certified and credentialed in order to lead and conduct such audits. Auditors are guided by the requirements of ISO 17021-9 to conduct an ABMS assessment. To attain this status, auditors must undergo intensive training to fully comprehend the concepts and principles behind the various ISO management systems compliance, and the corresponding specifications and auditing techniques associated with those ISO guidelines. From that training, auditors will gain the necessary knowledge and skills to effectively plan and perform related audits.
Further — and just as vital — auditing professionals must possess considerable experience in the areas of anti-bribery and anti-corruption, and have deep-seated knowledge of the industry sectors and the respective geographic regions (with a familiarity of the legal jurisdictions) served by the organisation being certified.
And finally, the ISO 37001:2016 auditor must be qualified to serve as a helpful, non-confrontational advocate during the entire audit process, expertly guiding the organisation through the process with the shared goal of achieving outcomes that will ultimately fortify the organisation’s commitment to battling instances of bribery in the global marketplace.
The ISO 37001 Audit Process
The process, which adheres closely to ISO 19011 requirements, begins well in advance of the on-site visit, with the auditor conducting a thorough analysis of news, social media and other public domain information pertaining to the organisation. This outside review oftentimes helps the auditor determine the organisation’s perceived “culture of compliance” prior to initiating the audit.
The audit process itself is a critical assessment of a number of crucial elements that are required by the ISO 37001:2016 standard, and a determination of how the overall policy is represented by the various roles and responsibilities throughout the organisation. The process entails:
- A review of the organisation’s anti-bribery policies, procedures and controls;
- An assessment of the organisation’s plan for communicating its polices to all employees worldwide;
- In-depth interviews with compliance personnel, leadership, management, and legal, finance, procurement, human resource and communications staff members to assess familiarity with the policies and comprehension levels for identifying and responding to red flag events;
- A review of all procedures and instructors involved with the organisation’s anti-bribery training;
- Performing risk assessments specific to particular projects, industries, regions, jurisdictions and third-parties associated with the organisation;
- Conducting due diligence on third-party partners (by region);
- Assessment of monitoring, reporting and investigation procedures as related to anti-bribery events;
- Bench-marking the organisation’s overall commitment to its anti-bribery policy and management systems;
- Assessment of the organisation’s financial controls to detect and prevent incidences of bribery;
- Review of all corrective actions to the policy following a bribery investigation;
- Confirmation of the organisation’s attempt at continuous improvement of the anti-bribery management system.
And throughout the various processes of observation, document review, sampling, interviews, technical verification and evaluation, the audit team is constantly meeting and communicating through the proper channels to assist the organisation in identifying risks and improving its processes and procedures.
The audit process can take weeks or months to complete, and needless to say, this process varies widely between organisations, industry sectors and geographic regions.
Reporting & Documentation
Post-audit, the team convenes an oversight board comprised of anti-bribery experts to review the audit reports and findings, and makes recommendations to both the organisation and the certification committee.
The ensuing documentation covers a host of topics, including risk areas (by project, personnel group, and geographic region), training recommendations, investigative techniques, reporting processes, and other areas of improvement.
Follow-Up Surveillance Audits to Ensure Continuous Improvement
The certification process doesn’t end after the initial audit phase. Certification to the standard requires verification of continuous improvement and confirmation of how outcomes are implemented, documented, monitored and assessed over time. To achieve this, the audit team will conduct annual surveillance audits of the organisation’s anti-bribery system over the three-year certification cycle. Surveillance audits verify the organisation’s continued adherence to the standard, evaluate any prescribed corrective action plans, and review what the organisation is doing to improve its anti-bribery management systems.
Certification in ISO 37001:2016 symbolises an organisation’s unrelenting commitment to fight corruption and pursue best practices in an ongoing quest for compliance to the widely-accepted anti-bribery standards. And the in-depth process involved in achieving certification to the standard — together with the counsel, risk assessment, and improvement recommendations that result from the audit — can make the certification process well worth the investment.
This paid webinar will be running from the following times on Thursday the 30th of September;
- 08:00 to 10:00 GMT
- 15:00 to 17:00 MYT
- 12:00 to 14:00 GST
Your turnout with come with a certificate of Attendance (COA) as well as a complimentary webinar ABMS Awareness for 2 Pax per company. While you’re there, why not attain a Continuing Professional Development (CPD) certificate and stay on top of your industry?
Register your place for this webinar here and find out how to tackle the issue of bribery and corruption in your workplace before it has time to manifest itself into a greater issue. Finance is the greatest asset to the economy after all.
Why Financial Services Firms Need ISO 37001 ABMS?
When Société Générale, a global financial services institution based in France, agreed to pay a combined total penalty of more than $860 million for an alleged bribery and corruption scheme, it served as a warning shot to financial firms worldwide that a culture of enforcement has arrived. Société Générale was accused of paying bribes to officials in Libya and committing violations in manipulating the London InterBank Offered Rate (LIBOR), one of the world’s leading benchmark interest rates. Together with other regulatory penalties faced by the financial services giant, the total amount to be paid exceeds $1 billion. (The United States Department of Justice, 2018)
Bribery and corruption often go together with money laundering – and, as such, the financial sector faces new Anti-Money Laundering (AML) rules and legislation that is strict and increasingly enforced. Remaining in compliance through implementing proper prevention controls is a must. Failing to do so can mean a loss of business, trust and reputation: Banking giant Citibank was fined $70 million in the US for failing to address shortcomings in its anti-money laundering policies. We at CRI intend on being apart of the solution. Therefore, CRI Group’s ABAC™ will be hosting a webinar on the 30th of September exploring the Pitfalls Most Organisations Often Commit – the importance of implementing Anti-Bribery Management System (ABMS). Being a part of the solution means sharing our knowledge so society is one step closer to an ethical reality.
In the US alone, more than 100 bribery investigations were in progress at the end of last year, with the financial services industry facing the most investigations. (Wall Street Journal, 2019)
Having layers of safeguards in place is required both from a legal and compliance standpoint. One of the most critical layers is an effective anti-bribery management system (ABMS).
Prevent Corruption and Promote Compliance
There is a solution that financial services organisations can implement to take a proactive stance against bribery and corruption: The ISO 37001:2016 Anti-Bribery Management System standard. ISO 37001 ABMS is designed to help global organisations implement an anti-bribery management system (ABMS), as the standard specifies a series of measures required by the organisation to prevent, detect and address bribery, and provides guidance relative to that implementation.
For financial services firms, this is a critical layer of protection that provides both anti-bribery controls and a system for compliance with various anti-corruption legislation, such as the FCPA and UK Bribery Act. The UK Bribery Act’s adequate procedures requirement dictates that all companies need to have ongoing monitoring, training, surveillance and risk assessments – ISO 37001 ABMS is designed to fulfil these criteria and more.
CRI Group’s ABAC™ Certification Services is accredited to offer independent ISO 37001 certification to ensure that an organisation is in compliance with the standard, which is recognised and practised in more than 160 countries worldwide. CRI Group’s auditors and analysts work with financial services organisations to develop measures that integrate with existing management processes and controls, and include:
- Adopting an anti-bribery policy
- Establishing buy-in and leadership from management
- Training personnel in charge of overseeing compliance
- Communicating the policy and program to all personnel and business associates
- Providing bribery and corruption risk assessments
- Conducting due diligence on projects, business associates and other third-party affiliations
- Implementing financial and commercial controls
- Developing reporting and investigation procedures
Our paid webinar will have a rundown of the following:
- What are the core Bribery and Corruption Risks for Financial Institution?
- How to protect financial institutions and corporations from bribery and corruption risk
- Reparations from bribery that could affect the businesses, clients, and employees
- Successful regulations to mitigate risk for bribery and corruption.
- What can be done if bribery is detected?
- Internationally recognised solutions laid forth by ISO 37001: Anti-Bribery Management System that gives businesses effective controls to mitigate risk
- Components of risk management at a financial institution
We will also be exploring how the implementation of such a standard aids in examining and dealing fittingly with any actual or suspected bribery within the corporation and also how to implement appropriate financial, procurement and other commercial controls so as to help prevent the risk of bribery in financial services as these organisations face unique challenges.
Among them are maintaining proper internal procedures as they relate to bribery and AML regulations. These measures can be logistically challenging, especially in the auditing process – but keeping accurate books and records is a key provision of the UK Bribery Act. ISO 37001 ABMS standard makes this a key provision in cultivating proper due diligence and reporting procedures.
Another major challenge involves monitoring third-party risk. The due diligence practices and risk assessments implemented through ISO 37001 ABMS are critical in this area. Financial services firms, more than any other sector, must conduct effective vetting and ongoing monitoring of third-parties. This goes beyond “on-boarding” and relates to how companies continually assess risk from outside partners – including brokerage firms, introducers, agents, joint-venture relationships, even clients – as borrowers, for example, represent a major risk on the balance sheet.
Some financial services companies do not properly score or assign risk profiles to third-party partners, and this can represent a major weak point in efforts to prevent bribery, corruption and money laundering. Regulators understand this, too. That’s why ISO 37001 ABMS dictates thorough and comprehensive due diligence in regards to all third-parties and especially in the case of mergers and acquisitions.
Once certified, an organisation must continue surveillance and undergo a recertification audit over three years to ensure that the organisation still complies with the ISO 37001:2016 ABMS standard. During this time, any changes to processes, the addition of new partners and expansion/acquisition of new assets or energy contracts, etc. are carefully reviewed.
Long-lasting Benefits of Certification
ISO 37001 ABMS provides a strong framework for addressing and isolating risk factors, and the benefits of certification are far-reaching, impacting not just the primary organisation but also influencing contractors, clients, and raising the profile of the company as an ethical entity that is a good trading partner. By achieving ISO 37001:2016 ABMS certification, a financial services firm will:
- Ensure that the organisation is implementing a viable anti-bribery management system utilising widely accepted controls and systems.
- Assure management, investors, business associates, personnel and other stakeholders that the organisation is actively pursuing internationally recognised and accepted processes to prevent bribery and corruption.
- If needed, provide acceptable evidence to prosecutors or courts that the organisation has taken reasonable steps to prevent bribery and corruption.
Cases like Société Générale are not isolated, but more and more, we are seeing companies punished for not taking proper preventative action with a robust anti-bribery management system (ABMS). Financial services firms need to be aware and stay in front of increased anti-bribery and corruption legislation given that such regulations have, in most cases, achieved a global reach. For ownership and management, the stakes are especially high – accountability now includes criminal liability for organisation personnel as individuals, beyond (and in addition to) liabilities faced by the organisation. This trend will only continue as governments, and their publics become increasingly intolerant of fraud, bribery and corruption. Significant media coverage and the real and perceived threat to governments’ economies contribute to this changing landscape of public opinion.
As the ISO 37001 International standard document states, “Conformity with (ISO 37001) cannot provide assurance that no bribery has occurred or will occur in relation to the organisation, as it is not possible to eliminate the risk of bribery. However, (the standard) can help the organisation implement reasonable and proportionate measures designed to prevent, detect and respond to bribery”. With this in mind, It’s important to note that ISO 37001 certification, on its own, is not a “safe harbour” from prosecution should bribery or corruption be discovered. Significantly, ISO certification is, as the above explains, a potential mitigating piece of evidence to regulators or even prosecutors and the courts that the entity has taken meaningful steps in its efforts to prevent bribery and corruption.
Financial Services Firms Need ISO 37001 ABMS
It is critical that any financial services organisation have a proper, comprehensive strategy to prevent and detect bribery and corruption, and remain in compliance with all regulations – on the local, regional, and international levels. The ISO 37001 ABMS standard is an established, tried and tested program to address those issues head-on through a comprehensive program of training and certification. The training process is tailored to the organisation while still following the developed curriculum and documented best practices. Due diligence procedures and risk assessments are applied in a thorough, comprehensive manner. Certification requires the demonstration that processes have been implemented effectively, with follow-up evaluations.
Worldwide developments in laws and regulations have demonstrated that there isn’t time to wait to implement controls and compliance procedures – the next investigation and/or prosecution may be too late. The harm caused by bribery and corruption to an entity’s reputation, investments and business can be far-reaching and long-lasting.
This paid webinar will be running from the following times on Thursday the 30th of September;
- 08:00 to 10:00 GMT
- 15:00 to 17:00 MYT
- 12:00 to 14:00 GST
Your turnout with come with a certificate of Attendance (COA) as well as a complimentary webinar ABMS Awareness for 2 Pax per company. While you’re there, why not attain a Continuing Professional Development (CPD) certificate and stay on top of your industry?
Register your place for this webinar here and find out how to tackle the issue of bribery and corruption in your workplace before it has time to manifest itself into a greater issue. Finance is the greatest asset to the economy after all.
CONTACT US
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Local: +971 800 274552
Email: info@crigroup.com
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Email: info@crigroup.com
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