Anti-Bribery Management
Shows that you take reasonable steps to prevent, detect and respond to bribery.
A complete documentation kit written to ISO 37001:2025: manual, policies, procedures, SOPs, forms, registers, process maps, indicator and risk frameworks, audit and management review packs, an implementation roadmap, sector guides and commercial templates, with every clause mapped to the document that meets it, and bribery risk assessment, due diligence, financial and non-financial controls, gifts, conflicts of interest, concerns and investigations built into the system.
- Edition 2025
- 144 Word + 29 Excel files
- One organization
- Downloads open 7 days after payment
You need this if
- You work with public officials, agents or intermediaries.
- A contract or partner asks for anti-bribery controls or ISO 37001.
- You need due diligence, gifts and hospitality control and a speak-up route.
What you get, in numbers
Counted from the files in the pack. Every file title is listed further down.
What this toolkit is not
Worth knowing before you buy.
Not the certificate
Certification is decided by an independent certification body after it audits a system you have run for some months, with records. No toolkit can guarantee it.
Not the ISO text
The standard is copyrighted and sold by ISO and national standards bodies. Buy your own copy. The toolkit describes requirements in its own words.
Not a consultant
We do not assess your organization. You review, adapt and approve every document before you use it.
What’s inside
15 numbered folders. Open any folder to see the title of every file in it. Titles only: the files themselves are delivered after payment.
00Start Here
Six guides: read-me, how to implement with an initial review checklist, documentation structure, quick start, an ISO 37001:2025 clause mapping guide including the 2025 changes, and a certification preparation guide.
6 files
- WordSH-001 Read Me Guide
- WordSH-002 How to Implement Guide
- WordSH-003 Documentation Structure Guide
- WordSH-004 Quick Start Guide
- WordSH-005 ISO 37001-2025 Clause Mapping Guide
- WordSH-006 Certification Preparation Guide
01Master Index
One Excel register of every controlled document: number, title, type, owner, department, retention and clause, with review dates and overdue flags.
1 file
- ExcelREG-01 Master Document Register
02Manual
The Anti-Bribery Management System Manual, section-numbered to match clauses 4 to 10: context including the climate decision, scope, bribery risk assessment, leadership and the compliance function, planning, support, operation (due diligence, controls, gifts and conflicts, concerns and investigations), performance evaluation including Board review, and improvement.
1 file
- WordABMS-001 Anti-Bribery Management System Manual
03Procedures (P-001 to P-022)
Document and record control, context and scope, bribery risk assessment, leadership and Board oversight, roles and the compliance function, objectives and change, competence and the employment process, awareness and training, operational control, due diligence, financial controls, non-financial controls, controlled organizations and associates, gifts, hospitality and donations, conflicts of interest, inadequate controls, raising concerns, investigations, monitoring and function review, audit and review, corrective action and improvement. Each has a flowchart, responsibility table, controls, risk and indicator matrices.
22 files
- WordP-001 Document Control Procedure
- WordP-002 Record Control Procedure
- WordP-003 Context, Interested Parties, Requirements and Scope Procedure
- WordP-004 Bribery Risk Assessment Procedure
- WordP-005 Leadership, Policy and Governing Body Oversight Procedure
- WordP-006 Roles, Anti-Bribery Function and Delegated Decision-Making Procedure
- WordP-007 Objectives and Planning of Changes Procedure
- WordP-008 Resources, Competence and Employment Process Procedure
- WordP-009 Awareness, Training and Communication Procedure
- WordP-010 Operational Planning and Control Procedure
- WordP-011 Due Diligence Procedure
- WordP-012 Financial Controls Procedure
- WordP-013 Non-Financial Controls Procedure
- WordP-014 Controlled Organizations and Business Associates Procedure
- WordP-015 Gifts, Hospitality, Donations and Similar Benefits Procedure
- WordP-016 Conflicts of Interest Procedure
- WordP-017 Managing Inadequate Anti-Bribery Controls Procedure
- WordP-018 Raising Concerns Procedure
- WordP-019 Investigating and Dealing with Bribery Procedure
- WordP-020 Monitoring, Measurement and Compliance Function Review Procedure
- WordP-021 Internal Audit and Management Review Procedure
- WordP-022 Nonconformity, Corrective Action and Continual Improvement Procedure
04Policies (POL-001 to POL-012)
Anti-bribery policy, document control, record retention, bribery risk management, governance and the compliance function, competence, training and culture, due diligence and associates, financial and non-financial controls, gifts, hospitality and donations, conflicts of interest, raising concerns and investigations, and audit, review and improvement.
12 files
- WordPOL-001 Anti-Bribery Policy
- WordPOL-002 Document Control Policy
- WordPOL-003 Record Retention Policy
- WordPOL-004 Bribery Risk Management Policy
- WordPOL-005 Governance and Anti-Bribery Function Policy
- WordPOL-006 Competence, Training and Culture Policy
- WordPOL-007 Due Diligence and Business Associates Policy
- WordPOL-008 Financial and Non-Financial Controls Policy
- WordPOL-009 Gifts, Hospitality, Donations and Benefits Policy
- WordPOL-010 Conflicts of Interest Policy
- WordPOL-011 Raising Concerns and Investigations Policy
- WordPOL-012 Audit, Review and Improvement Policy
05SOP Library (SOP-001 to SOP-020)
Step-by-step task instructions with flowcharts and acceptance criteria: risk workshop, Board briefing, due diligence, associate onboarding, payment control check, tender control, gift approval, conflict management, receiving a concern, investigation conduct, control failure handling, function review, internal audit and corrective action.
20 files
- WordSOP-001 Document Issue and Withdrawal
- WordSOP-002 Records Filing and Archiving
- WordSOP-003 Context Review Workshop
- WordSOP-004 Bribery Risk Workshop
- WordSOP-005 Governing Body Briefing
- WordSOP-006 Delegated Authority Review
- WordSOP-007 Competence and Integrity Check
- WordSOP-008 Training Delivery
- WordSOP-009 Due Diligence Process
- WordSOP-010 Business Associate Onboarding
- WordSOP-011 Payment Control Check
- WordSOP-012 Procurement and Tender Control
- WordSOP-013 Gift and Hospitality Approval
- WordSOP-014 Conflict of Interest Management
- WordSOP-015 Receiving a Concern
- WordSOP-016 Investigation Conduct
- WordSOP-017 Control Failure Handling
- WordSOP-018 Anti-Bribery Function Review
- WordSOP-019 Internal Audit Conduct
- WordSOP-020 Corrective Action Tracking
06Forms (FR-001 to FR-052)
Fifty-two forms. Each comes with field descriptions, a blank form that prints on its own, and a completed example record.
52 files
- WordFR-001 Document Change Request
- WordFR-002 Document Review Record
- WordFR-003 Record Disposal Authorization
- WordFR-004 Context and Climate Review
- WordFR-005 Interested Party and Requirements Review
- WordFR-006 ABMS Scope Statement
- WordFR-007 Bribery Risk Assessment Worksheet
- WordFR-008 Risk Treatment Plan
- WordFR-009 Governing Body Briefing Record
- WordFR-010 Policy Communication Record
- WordFR-011 Roles, Responsibilities and Authorities Record
- WordFR-012 Delegated Authority Record
- WordFR-013 Anti-Bribery Objectives Plan
- WordFR-014 ABMS Change Record
- WordFR-015 Competence Assessment
- WordFR-016 Employment Integrity Check
- WordFR-017 Training and Awareness Record
- WordFR-018 Communication Plan
- WordFR-019 Operational Control Plan
- WordFR-020 Due Diligence Request
- WordFR-021 Due Diligence Report
- WordFR-022 Business Associate Approval Record
- WordFR-023 Financial Control Review
- WordFR-024 Payment Approval Check
- WordFR-025 Non-Financial Control Review
- WordFR-026 Procurement and Tender Control Record
- WordFR-027 Business Associate Anti-Bribery Commitment
- WordFR-028 Controlled Organization Controls Review
- WordFR-029 Gift and Hospitality Declaration
- WordFR-030 Gift and Hospitality Approval
- WordFR-031 Donation and Sponsorship Request
- WordFR-032 Conflict of Interest Declaration
- WordFR-033 Conflict of Interest Management Plan
- WordFR-034 Control Inadequacy Record
- WordFR-035 Concern Report
- WordFR-036 Concern Handling Record
- WordFR-037 Investigation Plan
- WordFR-038 Investigation Report
- WordFR-039 Anti-Bribery Function Review Report
- WordFR-040 Indicator Definition Sheet
- WordFR-041 Annual Audit Programme
- WordFR-042 Audit Plan
- WordFR-043 Internal Audit Checklist
- WordFR-044 Audit Report
- WordFR-045 Auditor Competence Record
- WordFR-046 Management Review Agenda
- WordFR-047 Management Review Minutes
- WordFR-048 Governing Body Review Record
- WordFR-049 NCR Form
- WordFR-050 Corrective Action Request
- WordFR-051 Corrective Action Effectiveness Review
- WordFR-052 Improvement Suggestion Form
07Registers (REG-01 to REG-15)
Fifteen Excel registers with examples, drop-down lists, automatic calculations, due dates and overdue flags: bribery risks (with a risk score rule), associates (with a payment-before-approval check), gifts and hospitality (with declaration timing and approval checks), donations, conflicts of interest, concerns and investigations (with acknowledgement timing), training, control reviews, corrective actions, audits, objectives and delegated authority limits.
15 files
- ExcelREG-01 Document Register
- ExcelREG-02 Record Register
- ExcelREG-03 Legal, Regulatory and Contractual Requirements Register
- ExcelREG-04 Bribery Risk Register
- ExcelREG-05 Business Associate and Due Diligence Register
- ExcelREG-06 Gifts and Hospitality Register
- ExcelREG-07 Donations and Sponsorships Register
- ExcelREG-08 Conflict of Interest Register
- ExcelREG-09 Concerns and Investigations Register
- ExcelREG-10 Training and Competence Register
- ExcelREG-11 Control Review Register
- ExcelREG-12 Nonconformity and Corrective Action Register
- ExcelREG-13 Audit Register
- ExcelREG-14 Objectives and Programme Register
- ExcelREG-15 Delegated Authority and Approval Limits Register
08Process Maps
Eight swimlane maps with inputs, outputs, owners and indicator links: context and governance, risk assessment, people, due diligence, controls, gifts and conflicts, concerns and investigations, and review and improvement.
8 files
- WordPM-01 Context, Leadership and Planning Process Map
- WordPM-02 Bribery Risk Assessment and Operational Control Process Map
- WordPM-03 Competence, Employment and Training Process Map
- WordPM-04 Due Diligence and Business Associates Process Map
- WordPM-05 Financial and Non-Financial Controls Process Map
- WordPM-06 Gifts, Hospitality, Donations and Conflicts of Interest Process Map
- WordPM-07 Concerns and Investigations Process Map
- WordPM-08 Monitoring, Audit, Review and Improvement Process Map
09Indicators & Risk
81 indicators with formulas and targets in a filterable matrix, corporate and department frameworks, a balanced scorecard, a 5 x 5 risk matrix with 38 example risks, and an improvement opportunity matrix with 25 examples.
6 files
- WordKPI-01 Corporate Anti-Bribery Indicator Framework
- WordKPI-02 Department Indicator Framework
- ExcelKPI-03 Balanced Scorecard
- ExcelKPI-04 Process Indicator Matrix
- ExcelRSK-01 Risk Management Matrix
- ExcelRSK-02 Opportunity Matrix
10Audit
Annual audit programme covering every clause and high-risk area, audit plan, notification, auditor competence matrix, a 39-question checklist by clause, a complete audit report and a findings tracker.
7 files
- WordAUD-01 Annual Audit Programme
- WordAUD-02 Audit Plan
- WordAUD-03 Audit Notification
- ExcelAUD-04 Auditor Competence Matrix
- ExcelAUD-05 Audit Checklist by Clause
- WordAUD-06 Audit Report
- ExcelAUD-07 Follow-up Tracker
11Management Review
Agenda, inputs checklist covering every input of clause 9.3 and the Board review, completed sample minutes with the required outputs, action plan and a dashboard.
5 files
- WordMRV-01 Management Review Agenda
- WordMRV-02 Management Review Inputs Checklist
- WordMRV-03 Management Review Minutes Template
- ExcelMRV-04 Management Review Action Plan
- ExcelMRV-05 Management Review Dashboard
12Implementation
An eight-month roadmap with activities, milestones, deliverables and responsibilities, and a task tracker.
2 files
- WordIMP-01 Implementation Roadmap
- ExcelIMP-02 Implementation Tracker
13Customization
Guides with risks, controls and indicators for engineering and contracting, oil, gas and energy, logistics and customs, healthcare and medical supply, technology sold to government, financial services, real estate, manufacturing and trading, professional services, and education and non-profit organizations.
10 files
- WordCUS-01 Engineering, Construction and Contracting Customization Guide
- WordCUS-02 Oil, Gas and Energy Customization Guide
- WordCUS-03 Logistics, Freight and Customs Services Customization Guide
- WordCUS-04 Healthcare, Pharma and Medical Supply Customization Guide
- WordCUS-05 Technology and Software Providers selling to Government Customization Guide
- WordCUS-06 Financial Services Customization Guide
- WordCUS-07 Real Estate and Property Development Customization Guide
- WordCUS-08 Manufacturing and Trading Customization Guide
- WordCUS-09 Professional Services and Consultancies Customization Guide
- WordCUS-10 Education, Non-Profit and Charitable Organizations Customization Guide
14Commercial
Gap assessment checklist, certification readiness checklist, implementation and training proposal templates, consultancy agreement template and audit preparation checklist.
6 files
- ExcelCOM-01 Gap Assessment Checklist
- ExcelCOM-02 Certification Readiness Checklist
- WordCOM-03 Implementation Proposal Template
- WordCOM-04 Training Proposal Template
- WordCOM-05 Consultancy Agreement
- ExcelCOM-06 Audit Preparation Checklist
Sample pages
Pages from the delivered files, before your company details are applied.
After you download
The order most organizations follow.
Before you buy
Is the text of ISO 37001:2025 included?
No. The standard is copyrighted by ISO and sold by ISO and national standards bodies. Buy your own copy. The toolkit describes requirements in its own words and maps every clause to the document that meets it, so you can check each against the standard.
Which edition does the kit follow?
ISO 37001:2025, the second edition published in February 2025, which replaces the 2016 edition and its Amendment 1:2024. The 2025 edition adds the term anti-bribery culture, clarifies the compliance function, addresses conflicts of interest and reorders the improvement clauses. Check with your certification body which edition applies to your audit date; one certifier states that initial and recertification audits after 30 June 2026 are against the 2025 edition.
Does the kit replace legal advice or prevent bribery?
No. A management system reduces the risk of bribery but cannot eliminate it, and it is not a defence in itself. Anti-bribery laws differ by country and apply to the organization and to individuals. Take advice from a lawyer in each country where you operate, especially on investigations and reporting to authorities.
Are the examples, limits and figures real data?
No. Names, associates, thresholds, approval limits, risk ratings and cases in example records are fictional and marked as examples. Your own must come from your risk assessment and local law.
Can we edit the documents after purchase?
Yes. Files are delivered as standard, unlocked .docx and .xlsx files. Nothing is watermarked or restricted. Items such as prepared-by names and company profile facts are left for you to complete.
Will this get us certified on its own?
The toolkit gives you a complete, clause-mapped documentation baseline and tools for operating the system. Certification is decided by independent bodies after they audit a working system, including sampling of records and interviews with top management, so you must run the system for some months first. Neither a toolkit nor a management system guarantees certification or the absence of bribery.
How long can we download the files?
For 7 days from payment. In that time you can enter your company details, correct them and regenerate, and download as often as you need. After 7 days the purchase stays in your account history, but the download closes. Save the ZIP somewhere safe.
What if we need the files again later?
Buying the same toolkit again is a new order with its own 7-day download window. Each purchase is listed separately in your account.
Licence
One purchase licenses one organization to use, edit and adapt the documents for its own management system. You may not resell, share or publish the toolkit or its templates. Each file carries a footer line with the buyer’s email and order number. Full wording is in the Terms & licence.