Overview
ISO 37001:2016/Amd 1:2024 is an official amendment to ISO 37001 - the International Organization for Standardization’s standard for anti‑bribery management systems. Published in February 2024, Amendment 1 introduces climate action changes that integrate climate‑related considerations into the contextual and stakeholder‑related requirements of the anti‑bribery management system. Specifically, it adds to clauses 4.1 and 4.2 the expectation that organizations determine whether climate change is a relevant issue and that relevant stakeholders can have climate‑related requirements.
Key Topics and Requirements
- Anti‑bribery management system scope: ISO 37001 remains focused on requirements and guidance for implementing, maintaining and improving anti‑bribery controls and governance.
- Climate relevance assessment (new): Organizations shall determine whether climate change is a relevant issue to their anti‑bribery system (addition to clause 4.1).
- Stakeholder requirements (new note): Acknowledges that relevant stakeholders can have requirements related to climate change and these should be considered in the organization’s context (addition to clause 4.2).
- Integration with existing controls: Climate considerations should be reflected where appropriate in risk assessments, due diligence, policies, monitoring and reporting, and third‑party management.
- Governance and accountability: The amendment reinforces the need for leadership to consider external environmental risks and stakeholder expectations when designing anti‑bribery measures.
Applications
Who uses this standard and how:
- Compliance and legal teams: Update risk registers and compliance programs to include climate‑linked bribery risks (e.g., in procurement, carbon projects, public tenders).
- Board and senior management: Incorporate climate relevance findings into organizational context and governance decisions.
- Risk, ESG and sustainability functions: Coordinate with anti‑bribery controls to address intersectional risks where climate action programs create new corruption or bribery exposures.
- Third‑party and supply‑chain managers: Adjust due diligence to capture climate‑related stakeholder requirements and potential bribery risks in climate finance, offsets, or infrastructure projects.
- Internal auditors and certification bodies: Evaluate whether organizations have properly determined climate relevance and integrated stakeholder requirements into their anti‑bribery management system.
Related Standards
- ISO 37001 (core standard, 2016)
- ISO 14001 (environmental management systems) - relevant for climate risk integration
- ISO 37301 (compliance management systems) and ISO 37002 (whistleblowing) - related governance and reporting frameworks
By explicitly linking anti‑bribery controls with climate action considerations, ISO 37001:2016/Amd 1:2024 helps organizations address emerging corruption risks tied to the transition to a low‑carbon economy while aligning compliance and sustainability efforts.