Module 10:  The benefits and requirements of ISO 37001

Requirements: (7) Controls over personnel

7.1  Vetting of personnel

Potential personnel who could pose a more than low bribery risk to the organisation should be vetted before they are employed to ascertain as far as is reasonable they are the type of person who is likely to comply with the ABMS. This vetting could include actions such as:

  • discuss the organisation’s anti-bribery policy with prospective personnel at interview, and assess whether they appear to understand it, and accept the importance of compliance with it
  • verify the identity of personnel, and their right to work in the relevant country
  • take reasonable steps to verify that personnel qualifications are accurate
  • take reasonable steps to obtain satisfactory references from the previous employers of prospective personnel
  • for personnel who could be handling cash or have financial or payment responsibilities, criminal record and credit checks should be carried out as far as possible to ensure that they have not got any previous convictions for dishonesty, and are not in unsustainable debt.

7.2  Conditions of appointment

The employment contract should contain a provision allowing the organisation to take appropriate disciplinary action against personnel, including dismissal, in the event that they breach the ABMS.

7.3  Induction

As soon as new personnel join the organisation, steps should be taken to ensure that the personnel are aware of the anti-bribery policy, and understand how to comply with it.  The personnel should be given a copy of the policy, either in hard copy or electronically, and sign a commitment to comply with it. 

They should also as soon as possible be instructed or trained in how to comply with the relevant parts of the ABMS applicable to their role (see requirement 10)

7.4  Disciplinary procedures

The organisation should have disciplinary procedures which entitle it to take appropriate disciplinary action against personnel who breach the ABMS.

7.5  No wrongful penalisation 

Personnel must not be penalised (e.g. by demotion, disciplinary action, transfer or dismissal) for refusing to participate in, or for turning down, a business opportunity in respect of which they have reasonably and in good faith judged there to be an unacceptable risk of bribery.  Nor should any personnel be penalised for reporting in good faith, or on the basis of reasonable belief, any actual or suspected bribery.

7.6  Bonuses and targets

Performance bonuses, performance targets and other incentivising elements of remuneration should be reviewed regularly by an appropriate manager to ensure that there are reasonable safeguards to prevent these from encouraging bribery.

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January 2025
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