ISO 37001:2016 · clauses 8.2 to 8.5
Bribery rarely happens in your own building. It happens through intermediaries.
ISO 37001 puts due diligence on business associates at the centre – agents, intermediaries, consultants, distributors and suppliers in high-risk countries.
The anti-bribery management standard starts from an uncomfortable observation: payments almost never travel directly, but through third parties. It therefore requires risk-based due diligence before a relationship begins and controls while it lasts.
For Swiss exporters this is more than a certification question. Working through representatives in high-risk markets carries real liability – and in a crisis you need evidence that you looked.
Where the risk sits
- Sales agents and intermediaries on success-based commission.
- Consultants without a clearly described deliverable.
- Joint venture and consortium partners.
- Suppliers and customs agents in high corruption risk countries.
- Donations and sponsoring near a customer’s orbit.
What the standard requires
- 8.2
- Risk-based due diligence on business associates, projects and transactions.
- 8.3
- Financial controls that make concealed payments harder.
- 8.4
- Non-financial controls, particularly in procurement and awarding.
- 8.5
- Obtain anti-bribery commitments from business associates where appropriate.
- 8.9
- Reporting channels through which suspicions can be raised from outside too.
How SCRM covers it
Business associates, not just suppliers
Intermediaries and consultants in the same register as goods suppliers, classified differently.
Due diligence with a result
An assessment with a date, a source and a decision – not a gut feeling.
Commitments
Codes and confirmations with validity and recall dates.
Re-assessment
Relationships age; changes of ownership and new projects trigger a fresh check.
Frequently asked
Do we need certification?
Rarely. The structure is a useful framework without one – and in a crisis the documented process counts, not the certificate on the wall.
How deeply do we assess an intermediary?
Depending on country, sector, remuneration model and customer. Success-based commission in high-risk markets justifies the highest level.
How does this relate to Know Your Supplier?
It is the same exercise with a different focus: establish identity and beneficial owners, then assess corruption risk.