Leadership for ISO 37001 Anti-Bribery
ISO 37001 Clause 5
- Top management leads and commits to the anti-bribery system
- An anti-bribery policy is established and communicated
- An anti-bribery compliance function is appointed with authority and independence
ISO 37001 Clause 5 - Leadership
Clause 5 of ISO 37001:2025 places anti-bribery commitment squarely with the governing body, top management and the anti-bribery function. The clause has three parts. 5.1 covers what leadership must do and includes the new sub-clause on anti-bribery culture. 5.2 sets out the requirements for the anti-bribery policy itself. 5.3 defines the roles, the anti-bribery function and the controls around delegated decision-making.
Sub-clauses Covered by Clause 5
Clause 5.1 - Leadership and Commitment requires demonstrable commitment from the governing body (where one exists) and from top management. The 2025 revision added Clause 5.1.3 Anti-bribery Culture as a new sub-clause requiring leaders to develop, maintain and promote an anti-bribery culture across all levels of the organisation.
Clause 5.2 - Anti-bribery Policy sets out exactly what the policy has to contain - including a prohibition on bribery, a commitment to legal compliance, a commitment to encouraging concerns to be raised in good faith and the consequences of non-compliance.
Clause 5.3 - Organisational Roles, Responsibilities and Authorities covers three things. 5.3.1 assigns overall responsibility to top management. 5.3.2 requires an anti-bribery function with adequate resources, competence and independence (renamed from "anti-bribery compliance function" in 2025). 5.3.3 requires controls around delegated decision-making where bribery risk is greater than low.
Leadership is where ISO 37001 starts to differ from the other ISO standards. The standard does not just want a signed-off policy - it wants visible behaviour from the top that lines up with what the policy says. Leaders who only talk about anti-bribery when an audit is due will fail this clause.
I look for three things at leadership level. The anti-bribery policy signed by top management. Evidence the anti-bribery function exists and reports to the right people. Some indication the anti-bribery culture is more than words - usually that means seeing training records, communications and example cases where leaders have acted in line with the policy.
