Adequate Procedures Principles, Section 17A, MACC Act Amendment 2018 Overview

ISO 37001: 2016 ABMS Introduction and Understanding the Requirements:

Scope

Normative references

Terms and definitions

Context of the organization (clause 4)

• Understanding the organization and its context
• Understanding the needs and expectations of stakeholders
• Determining the scope of the anti-bribery management system
• Anti-bribery management system
• Bribery risk assessment.

Leadership (clause 5)

• Leadership and commitment
• Anti-bribery policy
• Organizational roles, responsibilities and authorities

Planning (clause 6)

• Actions to address risks and opportunities
• Anti-bribery objectives and planning to achieve them

Support (clause 7)

• Resources
• Competence
• Awareness and training
• Communication
• Documented information

Operation (clause 8)

• Operational planning and control
• Due diligence
• Financial controls
• Non-financial controls
• Implementation of anti-bribery controls by controlled organizations and by business associates
• Anti-bribery commitments
• Gifts, hospitality, donations and similar benefits
• Managing inadequacy of anti-bribery controls
• Raising concerns
• Investigating and dealing with bribery

Performance evaluation (clause 9)

• Monitoring, measurement, analysis and evaluation
• Internal audit
• Management review
• Review by anti-bribery compliance function

Improvement (clause 10)

• Nonconformity and corrective action
• Continual improvement