Background

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.  

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.

In 2016, the International Organisation for Standardization (ISO) published an international anti-bribery management systems standard,  ISO 37001, which has superseded BS 10500.  ISO 37001 was developed by an ISO Project Committee led by BSI, which comprised 59 countries.  The purpose, scope and content of ISO 37001 are materially similar to those of BS 10500.  See GIACC summary on ISO 37001.

Although ISO 37001 superseded BS 10500 with effect from October 2016, organisations which were compliant with or certified to BS 10500 were able to continue to use BS 10500 for a transitional period to the end of 2019.  After that, they will be unable to be certified to BS 10500, and will need to switch to ISO 37001.

BS 10500 will continue to be relevant even after discontinuance in relation to any investigations which relate to a period during which the organisation claims to be compliant with or certified to BS 10500

Purpose and scope of BS 10500

BS 10500 was intended to help an organisation to implement an effective anti-bribery management system.  It could be used both in the UK and internationally. The requirements of UK law and internationally recognised good practice were taken into account.  It was applicable to small, medium and large organisations in the public, private and voluntary sectors.  BS 10500 specified the implementation by the organisation of policies, procedures and controls which were reasonable and proportionate to the bribery risks faced by the organisation.

Compliance with BS10500 could not provide assurance that no bribery had occurred in relation to an organisation.  However, the standard could help establish that the organisation had implemented reasonable and proportionate measures designed to prevent bribery.

BS 10500 is likely to have been useful to organisations in the following way.

• To help provide assurance to the board and shareholders of an organisation that their organisation had implemented good practice anti-bribery controls.
• A project developer or project funder may have required the contractors, suppliers and consultants which were constructing a project to provide certification to BS 10500 as evidence that they had implemented anti-bribery controls in their organisations.
• Organisations may have required 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 was applicable only to bribery.  It was not applicable to other criminal offences such as fraud, anti-trust/competition offences, and money laundering, although the organisation may have chosen to extend the scope of its anti-bribery management system to include these other offences.

Requirements of BS 10500

In order to have complied with BS 10500, an organisation must have implemented specified minimum requirements in a manner which was reasonable and proportionate to the bribery risks faced by the organisation.  These requirements included 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 had an Annex which contained guidance to help an organisation implement the anti-bribery management system. 

Certification to BS 10500

An organisation could get its compliance with BS 10500 independently certified.

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.