ISO 37001 Anti-Bribery Compliance for Public Agencies Training Course

Course overview

Public agencies administering procurement, grants, humanitarian assistance, infrastructure programmes, licences, or donor-funded projects face bribery risks at points where discretion, third parties, and public funds meet. A facilitation payment at a border crossing, an undeclared conflict in a tender evaluation, an agent paid through a vague consultancy invoice, or pressure to favour a local partner can expose the agency to financial loss, donor sanctions, investigations, and loss of public trust. Staff need a defensible operating system, not simply an anti-corruption policy.

This five-day course applies ISO 37001 anti-bribery management system requirements to public-sector and development settings. Participants learn to define the organisation's anti-bribery scope, conduct bribery risk assessments, establish proportionate controls, perform due diligence on suppliers and implementing partners, manage gifts and conflicts of interest, operate reporting and investigation processes, and monitor control performance. They also practise translating ISO 37001 clauses into procurement, grant-management, finance, and programme-delivery procedures.

Instructor-led briefings are combined with public-agency case studies, control-design workshops, document reviews, and facilitated peer challenge. Participants work through a simulated donor-funded procurement and partner-management scenario, using risk registers, due-diligence forms, approval matrices, and monitoring plans. Each participant leaves with an ISO 37001 implementation action plan and a tailored anti-bribery control pack for a selected agency process, plus a certificate on completion.

The course is designed for intermediate public-sector, humanitarian, and development professionals who already work with governance, procurement, finance, programme delivery, compliance, or assurance and need to help build, improve, or assess an anti-bribery management system.

Course objectives

By the end of this course, participants will be able to:

• Interpret ISO 37001:2025 clauses and translate them into public-agency anti-bribery controls
• Conduct a documented bribery risk assessment using risk scenarios, inherent-risk scoring, and control evaluation
• Define an anti-bribery management system scope, governance structure, and accountable control owners
• Design proportionate due-diligence workflows for suppliers, consultants, implementing partners, and beneficial owners
• Build procurement and grant-control matrices covering conflicts of interest, approvals, segregation of duties, and red flags
• Develop reporting, investigation, and non-retaliation procedures for suspected bribery concerns
• Plan ISO 37001 internal audits, management reviews, corrective actions, and performance indicators
• Produce an agency-specific ISO 37001 implementation roadmap and prioritised control improvement plan

Benefits of attending

Target competencies

Who should attend

• Anti-Corruption and Compliance Managers — who must design or strengthen agency-wide bribery controls
• Procurement Officers — who evaluate supplier bids and must defend award decisions
• Grant and Partnership Managers — who oversee implementing partners, sub-grantees, and donor-funded delivery
• Internal Auditors — who test anti-bribery controls and report assurance findings to leadership
• Finance and Programme Managers — who approve expenditure, manage delivery risks, and detect irregular payments
• Legal, Ethics, and Investigation Officers — who handle disclosures, conflicts, misconduct cases, and corrective action

Requirements and prerequisites

Participants should have working experience in a public agency, development organisation, humanitarian programme, or donor-funded project, ideally involving procurement, grants, finance, governance, audit, or programme oversight. Familiarity with basic concepts such as conflicts of interest, delegated authority, supplier due diligence, risk registers, and internal controls is assumed. Participants should be able to read organisational policies and work with simple spreadsheets or document templates. Prior ISO management-system training, anti-bribery certification, legal qualification, audit qualification, or experience conducting investigations is not required.

Training methodology

The course uses instructor-led clause interpretation, short demonstrations of control templates, and public-sector case analysis rather than abstract compliance lectures. Participants assess bribery scenarios involving tender evaluation, customs clearance, implementing partners, and consultancy payments; then work in groups to score risks, draft controls, and test evidence requirements. Facilitated workshops use an ISO 37001 gap-assessment checklist, risk register, due-diligence file, and corrective-action log. On the final day, each participant converts findings into a practical 90-day implementation plan for their own agency or business unit.

Course outline

Day 1: ISO 37001 foundations and public-sector bribery exposure

• ISO 37001:2025 structure, terminology, and anti-bribery management system intent
• Bribery definitions, public-official risks, and facilitation payment scenarios
• Public-agency and donor-funded programme bribery exposure points
• Leadership commitments, anti-bribery policy, and tone-from-the-top evidence
• Management system scope boundaries for agencies, projects, and controlled entities
• Roles of governing bodies, anti-bribery compliance function, and process owners
• Context analysis using stakeholder, legal, donor, and operational requirements

Workshop: Participants map a selected agency process and produce a scope statement, stakeholder map, and preliminary bribery exposure profile.

Day 2: Bribery risk assessment and control design

• ISO 37001 risk assessment requirements and documented-information expectations
• Risk scenario identification across procurement, grants, border operations, and licensing
• Inherent-risk scoring using likelihood, impact, discretion, and third-party exposure
• Existing-control evaluation for design adequacy and operating effectiveness
• Residual-risk ratings, risk appetite, and escalation thresholds
• Control selection using preventive, detective, and corrective control types
• Risk register design, ownership assignment, and review-cycle planning

Workshop: Using a donor-funded infrastructure procurement case, participants produce a scored bribery risk register and prioritised treatment actions.

Day 3: Third parties, procurement, and financial controls

• Risk-based due diligence for suppliers, agents, consultants, and implementing partners
• Beneficial ownership checks, sanctions screening, adverse-media review, and conflict declarations
• Procurement integrity controls for specifications, tender evaluation, and award approvals
• Contractual anti-bribery clauses, audit rights, training obligations, and termination triggers
• Gifts, hospitality, donations, sponsorships, and political contribution controls
• Financial controls for invoices, cash, advances, split payments, and unusual payment routes
• Approval matrices, segregation of duties, and exception-management records

Workshop: Participants build a due-diligence decision file and procurement control matrix for a high-risk implementing partner appointment.

Day 4: Reporting, investigations, and assurance

• Speak-up channels, confidentiality, accessibility, and non-retaliation safeguards
• Triage criteria for allegations, red flags, and urgent preservation actions
• Investigation planning, evidence logs, interview protocols, and case documentation
• Fairness, legal escalation, data protection, and referral to competent authorities
• Corrective actions, root-cause analysis, and disciplinary-control linkages
• ISO 37001 internal audit programme design and auditor independence
• Management review inputs, anti-bribery performance indicators, and reporting dashboards

Workshop: Participants run an allegation-triage workshop and produce an investigation plan, evidence log, and corrective-action record.

Day 5: Implementation planning and continual improvement

• ISO 37001 gap assessment against existing policies, procedures, and evidence
• Documented-information architecture for policies, registers, approvals, and records
• Training and communications plans for employees, officials, contractors, and partners
• Control testing schedules and evidence sampling for priority risk areas
• Nonconformity classification, corrective-action plans, and effectiveness verification
• Integration with ISO 37301 compliance management and existing agency governance systems
• Ninety-day implementation roadmap, milestones, resources, and executive reporting

Workshop: Participants complete an ISO 37001 gap assessment and present a 90-day implementation roadmap with accountable owners and milestones.

Tools & standards covered

ISO 37001:2025 Anti-bribery management systems, ISO 37301:2021 Compliance management systems, ISO 31000:2018 Risk management guidelines, Microsoft Excel

A typical training day

Live online deliveries follow the same structure in the East Africa Time zone, with shorter screen blocks and longer breaks.

What the fee includes

How you can take this course

Certification

Participants who complete the full five days receive the Skillset Development Certificate of Completion, stating the course title, course code, dates and delivery format — suitable for professional-development records and employer reimbursement.

Frequently asked questions