ISO 37001 Lead Implementer Training — Lesson 2: Bribery Risk Assessment, Objectives, Due Diligence, and Treatment

Learning Objectives

• Interpret the principles, requirements, roles, and dependencies shaping bribery risk assessment, objectives, due diligence, and treatment.
• Apply the workflow and produce bribery risk and due-diligence register that another practitioner can review.
• Analyze “a third party is approved despite unresolved beneficial-ownership concerns” and recommend a proportionate, supported response.

Detailed Topics

• bribery risk assessment
• risk criteria
• risk analysis
• risk evaluation
• anti-bribery objectives
• due diligence
• risk treatment
• approval thresholds
• Competence, communication, governance, documented information, risk, validation, and follow-up considerations

Instructor Demonstration

The instructor demonstrates the bribery risk assessment, objectives, due diligence, and treatment workflow, identifies the applicable inputs and responsibilities, records checkpoints in bribery risk and due-diligence register, and contrasts the accepted state with a condition where a third party is approved despite unresolved beneficial-ownership concerns.

Hands-On Exercise

Complete a controlled implementation, audit, assessment, or foundation exercise for Bribery Risk Assessment, Objectives, Due Diligence, and Treatment. Establish scope and criteria, collect or create evidence, examine “a third party is approved despite unresolved beneficial-ownership concerns,” reach a supported conclusion, and preserve the result in bribery risk and due-diligence register.

1. Confirm objectives, scope, roles, criteria, stakeholders, and expected outputs.
2. Perform the planned activities while recording assumptions, evidence, and decisions.
3. Test a normal case, an exception, and a follow-up or improvement condition.
4. Document conclusions, owners, due dates, escalation, and verification requirements.

Scenario Analysis

• Identify the requirement or principle with the strongest influence on bribery risk assessment, objectives, due diligence, and treatment.
• Compare two defensible responses and explain their governance, risk, and evidence trade-offs.
• Determine how bribery risk and due-diligence register should be approved, retained, reviewed, and updated.

Troubleshooting Guidance

Separate missing evidence from ineffective practice, and distinguish a documentation issue from a control, process, governance, or competence failure. Use bribery risk and due-diligence register to trace the earliest divergence. Treat “a third party is approved despite unresolved beneficial-ownership concerns” as a hypothesis until the response is validated against the applicable requirement and intended outcome.

Validation Checklist

• The scope, criteria, stakeholders, and intended outcome for bribery risk assessment, objectives, due diligence, and treatment are explicit.
• The bribery risk and due-diligence register links statements and decisions to objective, reviewable support.
• Responsibilities, competence, communication, risk, legal duties, and change impact were considered where relevant.
• Findings, corrective actions, monitoring, review triggers, and improvement ownership are clear.

Lesson Outcome

Learners can apply Bribery Risk Assessment, Objectives, Due Diligence, and Treatment, explain the reasoning used, and defend the result through bribery risk and due-diligence register.