Conduct a bribery risk assessment across procurement categories, geographies and supplier types.
Warehousing & Procurement
Applying ISO 37001 Anti-Bribery Controls to Procurement and Supplier Onboarding
Learn to apply ISO 37001 anti-bribery management system requirements to procurement processes, from supplier due diligence and gift controls to red-flag investigation and audit readiness.
🗓️Duration5 training days
📚Content4 modules · 8 sessions
🎓On completionAccredited attendance certificate
About the programme
Course Overview
Procurement sits at one of the highest bribery-risk points in an organisation because it controls who gets contracts, and ISO 37001 gives buyers a structured, auditable way to manage that risk rather than relying on a generic code of conduct. This course focuses on applying the standard's anti-bribery management system requirements to procurement and supplier onboarding, translating clauses on risk assessment, due diligence and control activities into practical procedures. Participants learn to conduct bribery risk assessments by category and country, design proportionate due diligence for new suppliers and intermediaries, and set enforceable limits on gifts, hospitality and facilitation payments within tender and negotiation activity. The course covers red-flag indicators specific to procurement, such as unusual bid patterns, related-party ownership or pressure to bypass approval processes, and how to escalate and investigate them without compromising a live tender. It also addresses the documentation ISO 37001 certification or internal audit expects, including approval trails for gifts, evidence of due diligence and training records for staff. A case-based workshop applying the standard to a sample procurement function has participants build the risk assessment, due diligence checklist and gift-approval workflow their organisation would need.
Expected Learning Outcomes
Design proportionate due diligence procedures for onboarding new suppliers, agents and intermediaries.
Set enforceable limits and approval workflows for gifts, hospitality and facilitation payments in procurement.
Recognise red-flag indicators of bribery risk specific to tendering, negotiation and contract award.
Escalate and investigate suspected bribery concerns without compromising an active procurement process.
Maintain the documentation and records ISO 37001 certification or internal audit requires from procurement.
Train procurement staff on anti-bribery obligations and embed controls into standard procurement procedures.
Who Should Attend
Procurement and category managers responsible for supplier selection and contract award.
Compliance officers implementing or maintaining ISO 37001 across procurement functions.
Internal audit staff reviewing anti-bribery controls in procurement processes.
Legal counsel advising on bribery risk in supplier contracts and intermediary relationships.
Procurement policy and governance leads designing gift, hospitality and due diligence procedures.
Supplier relationship managers who must apply due diligence during onboarding and renewal.
Course Modules
Select any module to see its sessions and points.
01Understanding ISO 37001 in a Procurement Context
2 sessions · 8 points
Session 1Mapping the Standard to Procurement Processes
- Identify which ISO 37001 clauses apply directly to procurement, sourcing and supplier onboarding activity.
- Distinguish bribery risk in procurement from broader organisational corruption risk covered elsewhere.
- Review common gaps between existing procurement policy and ISO 37001 control expectations.
- Assign roles and responsibilities for anti-bribery controls within the procurement function.
Session 2Assessing Bribery Risk by Category and Geography
- Score procurement categories by bribery risk using factors such as discretion, value and contact frequency.
- Assess elevated risk in specific geographies using recognised corruption perception indicators.
- Identify higher-risk supplier types such as agents, distributors and joint venture partners.
- Prioritise risk mitigation effort towards the categories and relationships carrying the highest exposure.
02Building Due Diligence into Supplier Onboarding
2 sessions · 8 points
Session 1Designing Proportionate Due Diligence
- Set due diligence depth proportionate to the bribery risk score of the supplier or intermediary.
- Screen suppliers against sanctions, politically exposed person and adverse media databases.
- Verify beneficial ownership to identify related-party or conflict-of-interest risk before contract award.
- Document due diligence findings and the rationale for onboarding decisions in an auditable record.
Session 2Managing Intermediaries and Agents
- Apply enhanced due diligence to agents, consultants and intermediaries who interact with third parties on the buyer's behalf.
- Include anti-bribery warranties and audit rights in intermediary contracts.
- Review commission structures for features that could disguise improper payments.
- Monitor intermediary relationships periodically rather than relying solely on onboarding checks.
03Controlling Gifts, Hospitality and Tender Conduct
2 sessions · 8 points
Session 1Setting Gift and Hospitality Limits
- Define monetary limits and approval requirements for gifts and hospitality offered or received in procurement.
- Require disclosure and pre-approval of hospitality during active tender or negotiation periods.
- Prohibit facilitation payments and set an escalation route for situations where one is demanded.
- Maintain a gift and hospitality register reviewed periodically for patterns of concern.
Session 2Recognising and Handling Red Flags
- Identify red-flag indicators such as unusual bid clustering, late withdrawal or repeated single-bid awards.
- Recognise pressure tactics, such as urgency or bypassing approval steps, as bribery risk indicators.
- Escalate suspected bribery concerns through a defined confidential reporting channel.
- Investigate red flags without disclosing sensitive detail that could compromise an active tender.
04Documentation, Audit and Continuous Improvement
2 sessions · 8 points
Session 1Preparing Records for Audit or Certification
- Maintain risk assessment, due diligence and approval records in the format an ISO 37001 audit expects.
- Retain training records demonstrating procurement staff understand their anti-bribery obligations.
- Prepare a control self-assessment ahead of internal or external ISO 37001 audit activity.
- Respond to audit findings with corrective action plans and evidence of implementation.
Session 2Sustaining and Improving Controls
- Review anti-bribery controls periodically against changes in supplier base, geography or category mix.
- Update training content based on emerging red-flag patterns identified through investigations.
- Benchmark procurement anti-bribery controls against ISO 37001 requirements as the standard is revised.
- Report anti-bribery control performance and incidents to senior management and audit committees.
What the participant receives
4 course modules
A structured syllabus
8 training sessions
across 5 days
32 detailed points
Applied, detailed content
Accredited attendance certificate
On completing the programme
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