British Standard BS 10500
Specification for an Anti-bribery Management System
The British Standards Institution (BSI) is the UK's national standards body. It is also the UK representative at the International Organisation for Standardization (ISO).
BSI has published over 30,000 current standards. Some of the top global standards, including ISO 9001 and ISO 14001, began as BSI Standards. The most popular global standard is ISO 9001 Quality Management System, which is used by over 1,000,000 organisations in 178 countries. The second most popular global standard is ISO 14001 Environmental Management System which is used by over 220,000 organisations in 159 countries. BSI Standards also publishes the widely used BS OHSAS 18001 Health and Safety Management System.
In 2011, BSI Standards published BS 10500 Anti-bribery Management System, which was developed by a working group of 30 experts from the public and private sector and representing several different industry sectors.
Purpose and scope of BS 10500
BS 10500 is intended to help an organisation to implement an effective anti-bribery management system. It can be used both in the UK and internationally. The requirements of UK law and internationally recognised good practice are taken into account. It is applicable to small, medium and large organisations in the public, private and voluntary sectors. BS 10500 specifies the implementation by the organisation of policies, procedures and controls which are reasonable and proportionate to the bribery risk faced by the organisation.
Compliance with BS10500 cannot provide assurance that no bribery has occurred or will take place in relation to an organisation. However, the standard can help establish that the organisation has implemented reasonable and proportionate measures designed to prevent bribery.
Well-managed ethical organisations are likely to implement effective anti-bribery management systems in their organisations in the same way that they would implement effective quality, environmental and safety management systems. They would therefore be likely to obtain certification to BS 10500 in a similar way to obtaining certification to 9001, 14001 and 18001.
BS 10500 is likely to be useful to organisations in the following way.
- It will help provide assurance to the board and shareholders of an organisation that their organisation has implemented good practice anti-bribery controls.
- A project developer or project funder may require the contractors, suppliers and consultants which are constructing a project to provide certification to BS 10500 as evidence that they have implemented anti-bribery controls in their organisations.
- Organisations may require their major sub-contractors, suppliers and consultants to provide evidence of certification to BS 10500 as part of their supply chain approval process (on a similar basis to their requiring evidence of certification to ISO 9001 etc.).
BS 10500 is applicable only to bribery. It is not applicable to other criminal offences such as fraud, anti-trust/competition offences, and money laundering, although the organisation may choose to extend the scope of its anti-bribery management system to include these other offences.
Requirements of BS 10500
In order to comply with BS 10500, an organisation must implement specified minimum requirements in a manner which is reasonable and proportionate to the bribery risk faced by the organisation. These requirements include the following:
Implement an anti-bribery policy and programme.
Communicate the policy and programme to all relevant personnel and business associates (joint venture partners, sub-contractors, suppliers, consultants etc.).
Appoint a compliance manager (full time or part time) to oversee the programme.
Provide appropriate anti-bribery training to personnel.
Assess bribery risks, including undertaking appropriate due diligence.
Take reasonable steps to ensure that controlled organisations and business associates have implemented appropriate anti-bribery controls.
Verify as far as reasonable that personnel will comply with the anti-bribery policy.
Control gifts, hospitality, donations and similar benefits to ensure that they do not have a corrupt purpose.
Implement appropriate financial, procurement, contractual and other commercial controls so as to help prevent the risk of bribery.
Implement reporting (whistle-blowing) procedures.
Investigate and deal appropriately with any actual or suspected bribery.
Monitor and review the effectiveness of the programme, and make improvements where necessary.
BS 10500 has an Annex which contains guidance to help an organisation implement the anti-bribery management system.
Certification to BS 10500
BS 10500 will be most effective if its implementation by an organisation is independently certified. Certification bodies could be the existing organisations which provide certification to e.g. ISO 9001. They could also be accounting practices which can provide certification as part of their annual financial audit. Alternatively, other organisations could provide this service.
The cost of certification is likely to vary materially according to the size of the organisation obtaining the certification (as is the case with the cost of obtaining certification, for example, to ISO 9001). Certification of an organisation of e.g. 20 people working in one country will be materially more simple, and is likely therefore to cost materially less, than certification of an organisation with e.g. 10,000 employees working in 20 countries.
The cost of implementing the anti-bribery management system and obtaining certification is unlikely to be a competitive disadvantage. If, for example, a procuring entity requires all its bidders to be certified to BS 10500, then all bidders will be required to bear the cost and so will be on an equivalent footing. Where certification to BS 10500 is not a tender requirement, organisations may find it a competitive advantage to be certified, as they will be able to show the procuring entity that they have an anti-bribery management system in place which may gain them an advantage in the procurement evaluation.
The cost of implementing the anti-bribery management system and obtaining certification is also likely to be minimal when compared to the loss and damage which could be suffered by an organisation which gets involved in corruption. Having such a system can help prevent this loss and damage.
Copy of BS 10500
BS 10500 is copyright protected by BSI. A full copy of BS 10500 can be purchased from BSI’s web-site.
Implementing BS 10500
GIACC’s free on-line anti-corruption programme for organisations provides detailed requirements, guidance and supporting tools to assist an organisation implement an anti-corruption programme. GIACC’s programme is consistent with the requirements of BS 10500. An organisation can implement a BS 10500 compliant programme using GIACC’s programme, guidance and tools.
Publication of ISO 37001
In 2013, the International Organisation for Standardization (ISO) decided to develop and publish an international anti-bribery management systems standard. The standard, which is numbered ISO 37001, was developed by an ISO Project Committee led by BSI, and was published on 15th October 2016. The purpose, scope and content of ISO 37001 are materially similar to those of BS 10500. ISO 37001 has replaced BS 10500 with effect from 15th October 2016, but organizations which are currently compliant with or certified to BS 10500 will continue to be able to use BS 10500 for a transitional period of approximately one year before they will need to switch to ISO 37001.
Most recent update on 26th October 2016
Page first published on 21st February 2016
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