Course Overview for ISO 37001:2025 Anti-Bribery Management System Internal Auditor Training
Organisations across sectors face bribery exposure through procurement, third-party relationships, gifts and hospitality, sponsorships, recruitment, contract awards, licensing, inspections and other business decisions. An effective anti-bribery management system (ABMS) must therefore be assessed against the organisation’s context and actual risk exposure – not simply the presence of policies.
This two-day programme develops participants’ practical understanding of auditing against MS ISO 37001:2025, the Malaysian adoption of ISO 37001:2025. It covers Clauses 4–10 and applies audit guidance and evidence-based methods to common organisational processes, including procurement, third-party due diligence, financial and non-financial controls, gifts and hospitality, reporting channels, investigations and contract management.
Official special value-add references for companies to self-appreciate:
- Department of Standards Malaysia (JSM), “Langkah memperkukuh integriti syarikat kini lebih berbaloi!” (4 August 2026). JSM’s public notice summarises the ABMS tax incentive and stated conditions. Companies should confirm any claim directly with LHDN or their tax adviser.
- Mandatory ABMS Certification for CIDB G7 Contractors. CIDB’s official announcements listing includes a notice titled Pekeliling CIDB Bil. 1/2025, dated 1 January 2026, with implementation from 1 January 2027. Clients should verify the full circular and its applicability directly with CIDB: https://www.cidb.gov.my/wp-content/uploads/2025/12/Pekeliling-CIDB-Bil-1.2026_organized.pdf
Participants will practise identifying audit criteria, examining records and interview evidence, recognising potential nonconformities and recommending improvements through cross-industry scenarios and a simulated audit. The emphasis is on determining whether controls are appropriately designed, implemented and operating effectively – not merely whether policies and procedures exist.
For organisations, the challenge is therefore not simply knowing the rules, but ensuring that governance, risk management, controls and ethical judgement hold when people face pressure, competing interests and difficult choices.
This programme brings together Section 17A, ABAC governance, MS 2764:2022 Corruption Risk Management and ISO 37001:2025 ABMS, alongside ethical blindness, behavioural influences and ethical decision making.
Through practical cases, dilemmas and workplace scenarios, participants will analyse corruption risks, evaluate organisational responses and identify practical improvements.
The Message:
An effective ABMS audit awareness goes beyond checking policies and procedures. It evaluates whether controls work in practice, strengthens governance and corruption-risk management, and supports a sustainable culture of integrity across the organisation in order to avoid potential revenue leakage.
Course Objectives
By the end of the programme, participants will:
- Explain the key requirements of ISO 37001:2025 and the principles of ABMS auditing.
- Describe the application of ISO 19011:2026 guidance to audit planning and execution.
- Identify and analyse bribery risks and relevant controls.
- Examine audit evidence and recognise potential nonconformities.
- Recommend practical improvements to support ABMS implementation and effectiveness.
Learning Outcomes
Participants will leave with the ability to:
- Understand ABMS requirements.
- Identify bribery risks.
- Plan and conduct audits.
- Evaluate audit evidence.
- Report findings and recommend improvements.
Key Outcome
Build interdepartmental understanding of ABMS requirements and strengthen organisation-wide audit readiness.
Key Takeaways
Participants will leave the programme with the ability to:
- Understand the Requirements
- Assess the Risk
- Examine the Evidence
- Improve Audit Readiness
- Strengthen inter-departmental work for companies benefit
Methodology
- Interactive presentations and discussions
- Case studies and practical exercises
- Group activities and experience sharing
- Audit simulation and assessment
Who Should Attend
- ABMS / Compliance Personnel
- Integrity and Risk Management Officers
- Internal Auditors
- Procurement and Supply Chain Personnel
- Engineering and Quality Assurance Personnel
- Technical Inspection and Acceptance Teams
- Contract Management Personnel
- Department Heads and Process Owners
Course Content
Day 1 — Understanding ABMS and Operational Controls
Opening: The Audit Challenge
Programme orientation; expectations; audit mindset and distinction between risk indicators and evidence.
Module 1: Understanding the Audit Framework
ISO 37001:2025 as audit criteria; ISO 19011:2026 as auditing guidance; internal versus certification audits; contextual role of ISO/IEC 17021-1.
Module 2: Understanding the Organisation
Clause 4; context, interested parties, scope, bribery risk assessment and industry process mapping.
Module 3: Leadership and Planning
Clauses 5–6; leadership, anti-bribery policy, roles, objectives and risk-based planning.
Module 4: Supporting the ABMS
Clause 7; competence, awareness, communication, documented information and audit evidence.
Day 1 Checkpoint
Short knowledge check; review audit criteria, questions and evidence.
Module 5: Auditing Operational Controls
Clause 8; due diligence, financial and non-financial controls, business associates, gifts and hospitality, concerns and investigations.
Module 6: Following the Evidence
Trace a transaction across procurement, supplier selection, component inspection, technical approvals and contract variations; sampling and corroboration.
Day 1 Exercise: Follow the Transaction
Teams identify risk indicators, define evidence needed, record observations and distinguish suspicion from a substantiated audit finding.
Day 2 — Conducting Audits, Evaluating Findings and Improving Controls
Day 2 Opening: From Risk to Evidence
Recap; audit chain: criterion → audit question → evidence → evaluation → finding.
Module 7: Evaluating ABMS Performance
Clause 9; monitoring, measurement, internal audit, management review and control effectiveness.
Module 8: Improvement and Corrective Action
Clause 10; nonconformity, correction, root-cause analysis, corrective action and effectiveness verification.
Module 9: Planning and Conducting an Audit
ISO 19011:2026 guidance; objectives, scope, criteria, questions, sampling, team roles, opening meeting, interviews and impartiality.
Module 10: Audit Findings and Reporting
Draft findings using criterion, objective evidence and demonstrated gap; classification under the organisation’s procedure; reporting and follow-up.
Module 11: Malaysian Corruption Risk Management
MS 2764:2022 context and Section 17A MACC Act 2009; distinguish management-system findings from criminal conclusions.
Module 12: Industry Audit Simulation
Team simulation involving supplier selection, component inspection, technical acceptance or contract variation; assign auditor and auditee roles.
Module 13: From Evidence to Improvement
Present findings, evidence, business implications, root causes and corrective actions; explain effectiveness verification.
Assessment and closing.
Knowledge check, learning review, participant feedback and action commitments.
