ISO 37001 Lead Auditor Training — Lesson 2: Examining Bribery Risk, Due Diligence, Objectives, Approvals, and Evidence

Learning Objectives

• Interpret the purpose, responsibilities, inputs, and decision points shaping examining bribery risk, due diligence, objectives, approvals, and evidence.
• Apply the workflow and produce anti-bribery audit working papers that another practitioner can review.
• Analyze “a third party is approved despite unresolved ownership concerns” and recommend a proportionate, evidence-based response.

Detailed Topics

• bribery risk
• risk criteria
• due diligence
• beneficial ownership
• approval thresholds
• anti-bribery objectives
• sampling strategy
• objective evidence
• Governance, competence, communication, documentation, validation, risk, and follow-up considerations

Instructor Demonstration

The instructor demonstrates the examining bribery risk, due diligence, objectives, approvals, and evidence workflow, identifies applicable responsibilities, records checkpoints in anti-bribery audit working papers, and contrasts the accepted state with a condition where a third party is approved despite unresolved ownership concerns.

Hands-On Exercise

Complete a controlled implementation, management, audit, assessment, foundation, introduction, awareness, or transition exercise for Examining Bribery Risk, Due Diligence, Objectives, Approvals, and Evidence. Establish scope and criteria, collect or create evidence, examine “a third party is approved despite unresolved ownership concerns,” reach a supported conclusion, and preserve the result in anti-bribery audit working papers.

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 examining bribery risk, due diligence, objectives, approvals, and evidence.
• Compare two defensible responses and explain their governance, risk, and evidence trade-offs.
• Determine how the anti-bribery audit working papers 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 anti-bribery audit working papers to trace the earliest divergence. Treat “a third party is approved despite unresolved 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 examining bribery risk, due diligence, objectives, approvals, and evidence are explicit.
• The anti-bribery audit working papers 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 Examining Bribery Risk, Due Diligence, Objectives, Approvals, and Evidence, explain the reasoning used, and defend the result through anti-bribery audit working papers.