GG-1-19 Anti-bribery Supplier Selection
File Reference : GG-1-19 Anti-bribery Supplier Selection
Date File Updated 07-10-26
Category General Guidance
Tags: ISO 37001

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This guidance explains how to judge the bribery risk a supplier poses, the purchasing controls that reduce it, and how the supplier bribery risk rating works.

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These files are included in the alphaZ subscription. The training talk is also included in the ISO 37001 Toolkit and the integrated toolkits that include it.

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Anti-Bribery Supplier Selection Guidance

A general guidance document on anti-bribery supplier selection for anyone involved in choosing suppliers or making purchases. It explains the factors used to judge the bribery risk a supplier poses, the purchasing controls that reduce that risk, and how the supplier bribery risk register sets a risk rating for each supplier.

Topics Covered

  • Location and scope of work - bribery risk linked to where a supplier is based, checked with the Corruption Perceptions Index, and to high-value work
  • The supplier's own controls - favouring suppliers with an anti-bribery policy, reporting procedures or a management system over those with few controls
  • Bargaining power and certification - greater risk where few suppliers are available, and certification such as ISO 37001 counted as a sign of commitment
  • Purchasing controls - buying from checked suppliers, authorised buyers working within spending limits, and complete purchase orders, requisitions and receipts
  • Supplier bribery risk rating - a score for each supplier based on how often business takes place, the value of the work and a general risk rating
  • Due diligence for high ratings - further checks where a supplier has a high bribery risk rating, recorded on a bribery due diligence review

Who Is It For?

Buyers, managers who approve spending and anyone else involved in choosing suppliers or making purchases for the company.

Included in the ISO 37001 Toolkit

This guidance is supplied with the TT-1-19 Anti-Bribery Supplier Selection training talk, which is part of the ISO 37001 Toolkit and the integrated toolkits that include it.

Using the Guidance

Issue it to anyone authorised to make purchases or choose suppliers, and keep it as a reference alongside the purchasing procedure and the supplier bribery risk register. Record who has received it, for example on the training matrix.

How the Bribery Risk Rating Works

The supplier bribery risk register gives each supplier a bribery risk rating built from how often business takes place, the value of the work and a general bribery risk rating. That general rating looks at the sector, the product or service bought, the authority of the people involved, the supplier location, known intelligence and the type of payment. A high rating can lead to due diligence.

Adapting the Guidance

Edit the guidance to match your own arrangements - your purchasing procedure, spending limits and approvals, purchase card rules, and the names of your supplier list, supplier bribery risk register and due diligence form.

Related Documents

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