There are several requirements related to top management regarding the anti-bribery management system in terms of leadership, commitment, and necessary actions for the proper and effective operation of the anti-bribery management system. Some of these include:
Ensuring the implementation and maintenance of the management system
It is the responsibility of top management to ensure that the anti-bribery management system is established, implemented, maintained, and critically reviewed to address the organization’s bribery risks. This means that top management is responsible for the full operation of the management system in pursuit of continuous improvement.
Providing adequate and appropriate resources
For an anti-bribery management system to be effectively maintained, resources are required—whether financial resources, personnel, or infrastructure. Depending on the level of detail in the anti-bribery management system, the required resources may vary, but it is the responsibility of top management to provide these resources.
Communicating the anti-bribery policy
The anti-bribery policy establishes the general guidelines for the anti-bribery management system. It is the responsibility of top management to communicate these guidelines, both internally and externally, to all interested parties.
Requesting resources for the operation of the anti-bribery management system
One of the responsibilities of the governing body is to require the organization to provide adequate resources for the effective operation of anti-bribery compliance and to ensure that these resources are allocated and assigned to meet the needs in this area.
Promoting an anti-bribery culture
This is one of the most important responsibilities of top management in ISO 37001, as it encompasses nearly all the others. An organizational culture is promoted through structured actions, such as practice and awareness. The role of leadership in this process is fundamental and crucial to the effectiveness of the anti-bribery management system.
Promoting continuous improvement
After the implementation of a compliance program according to ISO 37001, it is the responsibility of top management to motivate and establish actions to promote continuous improvement. This can be achieved through the standard’s own requirements, such as internal audits, investigation of potential bribery allegations, review of internal controls, etc.
Encouraging the reporting of suspected and actual bribery
Top management in ISO 37001 plays a key role in encouraging whistleblowing channels and other procedures for reporting suspected and actual bribery. In organizations where this process is well-managed by top management, employees and other interested parties feel obligated to report any suspicions, ensuring that these are investigated. This is another tool for strengthening the process.
Reporting to the governing body
Where applicable, top management in ISO 37001 is responsible for reporting at planned intervals on the content and operation of the anti-bribery management system, including any systematic or serious bribery allegations or other processes defined by the organization. However, when a governing body does not exist, top management must assume its respective responsibilities and establish other reporting mechanisms. Ultimately, as per requirement 5.1.2, there are numerous responsibilities for top management in ISO 37001, and the leadership role they play in the organization will determine the course of the anti-bribery management system.
