Module 10:  The benefits and requirements of ISO 37001

Requirements: (14) Financial, commercial and other corporate controls

Implement appropriate financial, commercial and other corporate controls within the organisation which are designed to reduce bribery risk.  For example:

  • require at least two signatures on any transaction which could result in more than low bribery risk (as ascertained by the risk assessment). For example:
    • payments made by the organisation
    • contracts entered into by the organisation
    • approval of work undertaken for the organisation
  • ensure that suitably senior decision makers are required to approve any transaction falling within the medium to high risk category in the organisation’s risk assessment
  • ensure that where more than one signature is required, that the signatories come from separate functions (e.g. one from operations and one from finance)
  • as far as possible, make and receive payments through the banking system, so that the payments are traceable
  • restrict the use of cash payment to an absolute minimum, and only when there is no other reasonable alternative payment method available.

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January 2025
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