Course Overview for ISO 37001:2025 Understanding & Implementing
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 and implementing of auditing against MS ISO 37001:2025, the Malaysian adoption of ISO 37001:2025. It covers Clauses 4–10 and applies translates requirements into practical actions across 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 complete practical exercises to identify implementation gaps, map bribery risks to controls, assign responsibilities and develop implementation priorities. 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:
Effective ABMS implementation goes beyond checking policies and procedures. It establishes accountability, puts proportionate controls into practice and strengthens governance, corruption-risk management and a sustainable culture of integrity.
Course Objectives
By the end of the programme, participants will:
- Explain the key requirements of ISO 37001:2025 and the principles of ABMS implementation.
- Analyse organisational context and bribery risks to identify implementation priorities and gaps.
- Identify and analyse bribery risks and relevant controls.
- Evaluate whether proposed controls are proportionate to identified bribery risks
- Develop an implementation roadmap with actions, responsible owners, milestones and monitoring measures.
Learning Outcomes
Participants will leave with the ability to:
- Explain ABMS requirements and implementation sequence.
- Analyse bribery risks and prioritise implementation needs.
- Apply requirements by mapping risks to controls and owners.
- Evaluate whether controls address identified risks.
- Develop an implementation roadmap with responsibilities, milestones and progress measures.
Key Outcome
Build interdepartmental understanding of ABMS requirements and produce practical implementation priorities, assigned responsibilities and an organisation-specific roadmap.
Key Takeaways
Participants will leave the programme with the ability to:
- Understand the Requirements
- Assess the Risk
- Examine the Evidence
- Improve Implementation Readiness
- Strengthen inter-departmental work for companies benefit
Course Content
Day 1 – Understanding the Standard and Building the ABMS Foundation
Opening: The Implementation Challenge
Programme orientation; expectations; implementation mindset and distinction between documented policies and operational controls.
Module 1: Understanding the Standard
MS ISO 37001:2025 as the ABMS requirements; how to use the standard as a stand-alone system or within wider governance arrangements, without treating certification as proof of legal immunity.
Module 2: Context, Scope and Gap Assessment
Clause 4; organisational context, interested parties, scope, bribery risk assessment and process mapping
Module 3: Leadership and Planning
Clauses 5–6; leadership, anti-bribery policy, roles, objectives, resources and risk-based planning.
Module 4: Supporting the ABMS
Clause 7; competence, awareness, communication, documented information and resources needed to operate the ABMS.
Day 1 Checkpoint
Short knowledge check; review context, scope, risk assessment and implementation priorities.
Module 5: Bribery Risk Assessment and Control Design
Clause 8; due diligence, financial and non-financial controls, business associates, gifts and hospitality, concerns and investigations.
Module 6: Turning Risks into an Implementation Plan
Translate priority bribery risks into controls, accountable owners, evidence of operation and practical implementation actions.
Day 1 Exercise: Risk-to-Control Mapping
Teams map selected risks to controls, identify control owners and record gaps requiring action.
Day 2 – Implementing Controls, Monitoring and the Implementation Roadmap
Day 2 Opening: From Design to Operation
Recap; move from requirements and risk assessment to implementation, monitoring and continual improvement.
Module 7: Operating and Monitoring Controls
Clause 9; monitoring, measurement, indicators, internal audit, management review and evaluation of control effectiveness.
Module 8: Reporting, Concerns and Investigations
Establish reporting channels, protect good-faith reporting, define responsibilities and understand the interface between concerns and investigations.
Module 9: Monitoring, Internal Audit and Management Review
Clause 9; monitoring, measurement, internal audit programme, management review and follow-up of actions.
Module 10: Nonconformity and Corrective Action
Clause 10; address nonconformity, determine causes, implement corrective action and verify effectiveness.
Module 11: Malaysian Corruption Risk Management
MS 2764:2022 corruption risk management context and Section 17A MACC Act 2009; distinguish management-system implementation from legal conclusions or guarantees.
Module 12: ABMS Implementation Workshop
Team workshop: translate a bribery-risk scenario into controls, assigned owners, implementation actions and evidence of operation.
Module 13: Implementation Roadmap and Readiness Review
Produce and present an implementation roadmap with priorities, owners, milestones, measures and readiness gaps.
Assessment and closing.
Knowledge check, learning review, participant feedback and individual action commitments.
