ISO 37001:2025 is an international standard that specifies requirements and provides guidance for establishing, implementing, maintaining and continually improving an Anti-Bribery Management System (ABMS). It supports organizations in preventing, detecting and responding to bribery, as well as in complying with applicable anti-bribery laws, anti-corruption legislation and voluntarily adopted commitments.
The 2025 edition (Edition 2) supersedes and replaces ISO 37001:2016 and its subsequent amendments. Key changes include a stronger emphasis on compliance culture, a more in-depth treatment of conflicts of interest, and clearer definition of the role, responsibilities and positioning of the anti-bribery function within the organization.
The standard also introduces requirements to consider climate change as a factor when analysing the context of the organization and aligns terminology with other management system standards through the application of the latest ISO Harmonized Structure (HS), thereby facilitating the integration of multiple management systems.
 
Scope and applicability
ISO 37001 is applicable to any organization, regardless of its size, legal form or sector of activity. It can be applied in the public, private and not-for-profit sectors by organizations seeking to proactively manage bribery risks and promote ethical and responsible business practices.
The anti-bribery management system may be implemented as a standalone system or integrated into the organization’s overall management system. Owing to the ISO Harmonized Structure, the standard integrates effectively with other management systems such as ISO 9001, ISO 14001, ISO/IEC 27001 and ISO 37301, as well as with compliance and ethics frameworks, thereby contributing to the overall strengthening of corporate governance.
ISO 37001 applies to all forms of bribery related to the organization’s activities, including:

• bribery in the public, private and not-for-profit sectors;
• bribery by the organization or on its behalf, including by personnel and business partners;
• bribery directed at the organization, including its personnel and business partners;
• direct and indirect bribery, including through third parties.

The standard focuses exclusively on bribery and supports organizations in the systematic management of the associated risks.
 
Key elements of ISO 37001
ISO 37001 requires the implementation of a systematic and integrated approach to managing bribery risks, encompassing governance, organizational and operational processes. In this context, the standard emphasizes:

• defining the context of the organization, relevant interested parties and bribery risks related to activities, locations and business relationships;
• clear allocation of roles, responsibilities and authorities, including the establishment of an anti-bribery function with appropriate independence and direct access to top management;
• establishing an anti-bribery policy and measurable objectives aligned with the organization’s risk profile;
• implementing financial and non-financial controls relating to personnel, business partners and third parties;
• ensuring training, awareness and internal communication to support a culture of integrity and compliance;
• establishing mechanisms for reporting, investigation and corrective actions;
• monitoring, internal audit, management review and continual improvement of the anti-bribery management system.

 
Benefits of implementing ISO 37001
Implementing ISO 37001 helps organizations effectively manage bribery risks and build a sustainable culture of integrity and compliance. Key benefits include:

• reducing the risk of bribery and its associated financial, legal and reputational consequences;
• improving compliance with national and international anti-bribery and anti-corruption requirements;
• enhancing trust among customers, partners, investors and public authorities;
• strengthening reputation and corporate integrity through clearly defined policies, responsibilities and control mechanisms;
• improving opportunities for participation in public procurement procedures and international projects;
• fostering and embedding an ethical and responsible organizational culture.

 
How CONSEJO can support you
CONSEJO provides comprehensive support for the implementation and maintenance of ISO 37001, including:

• analysis of the organizational context and bribery risk assessment;
• development and customization of policies, procedures and control measures;
• establishment or optimization of the anti-bribery function;
• integration of ISO 37001 with other management systems (ISO 9001, ISO 14001, ISO/IEC 27001, ISO 37301);
• preparation for certification audits and ongoing support.

Contact us to build an effective anti-bribery management system in accordance with ISO 37001.

ISO 37001 Anti-bribery management systems – Requirements with guidance for use