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Organization Context in ISO 37001:2016

The ISO 37001 Standard is a management tool for companies that want to implement and maintain an anti-bribery management system, it is not by chance that the requirements clauses start with the organization context in ISO 37001.

The term organization context was introduced in ISO Standards with Annex SL, an ISO document to align all management system standards in the same structure, so you will find the same term in other ISO standards such as ISO 9001, ISO 14001 , ISO 45001, among others. The kickoff of the requirements is requirement 4.1 Organization context, this helps the company understand the scenario on the topic of anti-bribery with a detailed assessment and address possible actions arising from this process.

Usually, when companies implement the anti-bribery management system, they carry out the context assessment using the SWOT tool, a tool that is already well-known and easy to implement. In assessing the context of the organization of the anti-bribery management system, the Standard defines as a requirement the determination of internal and external issues, hence the common use of SWOT.

For this detailed assessment, whether or not using the SWOT tool, ISO 37001 already informs that the organization must take into account the following factors:

  • Size, structure, delegation of decision-making authority of the organization;
  • Locations and sectors in which the organization operates or anticipates operation;
  • Nature, scale and complexity of the organization’s operations and activities;
  • The organization’s business model; Entities over which the organization has control and entities that exercise control over the organization;
  • Organization’s business partners;
  • Nature and extent of interactions with public agents;
  • Applicable statutory, regulatory, contractual and professional obligations and duties.

This assessment can also be done in a Brainstorming meeting with the organization’s leadership and the company in general, so it will be possible to assess the organization’s context in ISO 37001 by a multidisciplinary team covering all the factors and inputs of the organization.

After evaluating the scenario of the organization’s context in ISO 37001, action plans necessary for the anti-bribery management system may arise, thus being important to support the implementation of other requirements of the ISO 37001 Standard and especially the improvement of anti-bribery compliance.


QMS Certification Services is a fully accredited third-party International Certification Body. Operating since 1994, QMS is one of the oldest and most experienced certification bodies auditing and certifying thousands of organizations globally. We have built a great reputation for first-class service, market-leading pricing, and a hassle-free process for our clients. International Recognition: QMS Certification Services is accredited by IAS (INTERNATIONAL ACCREDITATION SERVICE) – a member of the IAF (International Accreditation Forum). All Certificates of Approval are issued under the IAS accredited system in the USA. QMS has auditors and clients all over the world, allowing for multi-country certification for clients.

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