Anti-Bribery and Corruption Compliance Course
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Bribery Risk Rarely Arrives Labelled “Bribe.”
It can look like a success fee paid through an intermediary.
A gift offered just before a tender decision.
A consultant whose scope is vague but whose government relationships are valuable.
A charitable donation requested by a customer contact.
A facilitation payment described as the only way to move a shipment.
An employee's undisclosed conflict of interest.
A third party with unusual commissions and no evidence of real work.
ISO 37001:2025 is now the current second edition of the international anti-bribery management-system standard. It covers systems to prevent, detect and respond to bribery through policy, risk assessment, due diligence, financial and non-financial controls, training, reporting and improvement. The UK Ministry of Justice's Bribery Act guidance, updated in January 2025, continues to frame preventive procedures around six principles: proportionality, top-level commitment, risk assessment, due diligence, communication/training, and monitoring/review.
This course translates those principles into operational controls for organisations exposed to customers, suppliers, public officials, agents, consultants, joint ventures and high-risk transactions.
ISO 37001:2025 · UK Bribery Act Guidance. Evidence is contextual; jurisdiction-specific or specialist advice remains separate where relevant.
Anti-bribery programmes become weak when:
- generic codes of conduct replace a specific bribery risk assessment
- country risk is used as the only risk factor
- intermediaries are approved because a senior executive knows them
- commissions and success fees are not challenged commercially
- gifts and hospitality thresholds are treated as the whole control
- conflicts of interest are declared but not managed
- procurement and sales incentives create unmanaged bribery pressure
- third-party due diligence is completed once and never refreshed
- finance reviews whether a payment is documented but not whether it makes commercial sense
- whistleblowing channels exist but retaliation risk discourages use
- investigations are improvised
- training is identical for everyone regardless of exposure
- leaders receive completion rates but no evidence of programme effectiveness.
How This Applies Across the Markets MATSH Serves
GCC
Relevant to government-linked business, infrastructure, energy, healthcare, procurement, licensing, agents/intermediaries and multinational operations. Participants focus on proportionate control of public/private bribery exposure without assuming one legal framework applies across all states.
Africa
Applications include public procurement, permits, customs, agents, distributors, infrastructure and third-party relationships across different legal and institutional environments.
Asia
Participants consider complex distribution and intermediary networks, public-sector interaction, high-volume procurement/sales and cross-border operations.
Europe
Applications include global anti-bribery programmes, third-party governance, public procurement and multinational compliance obligations. Specific legal prohibitions and enforcement exposure depend on jurisdiction and require qualified legal advice where necessary.
Who Should Attend
Compliance and Ethics Professionals
Designing or operating anti-bribery programmes.
Legal and Regulatory Teams
Translating anti-bribery obligations into controls.
Procurement and Supply Chain Professionals
Managing suppliers, agents and tender risk.
Sales and Business Development Leaders
Working with customers, public officials, distributors and intermediaries.
Finance and Internal Control Teams
Reviewing payments, approvals and transaction evidence.
Internal Audit and Risk Professionals
Assessing bribery-risk controls and programme effectiveness.
What You Will Leave With
- A bribery-risk assessment method, looking beyond country risk. - A third-party risk model, distinguishing low, medium and high-risk relationships. - A due-diligence workflow, with escalation and approval criteria. - Gifts, hospitality and conflict controls, designed around context and influence. - Financial/non-financial controls, targeting unusual payments and commercial arrangements. - A high-risk transaction checklist, covering agents, donations, sponsorship and public officials. - Role-based training plans, focusing on actual exposure. - A speak-up and investigation protocol, protecting evidence and escalation. - An anti-bribery monitoring plan, measuring control effectiveness rather than training completion alone. - An ISO 37001-aligned management-system map, without claiming certification.
Programme Curriculum
Why this module matters: Anti-bribery controls should reflect how bribery could occur in the organisation, not only what the law says in abstract terms. Participants learn to:
- distinguish bribery, corruption, fraud and conflicts of interest
- understand direct and indirect bribery conceptually
- distinguish public/private bribery exposure
- identify business, transaction, geography and relationship risk factors
- map high-risk processes
- understand ISO 37001:2025 structure conceptually
- define anti-bribery roles
- establish top-level commitment
- integrate bribery risk with wider compliance
- identify when specialist legal advice is required.
Workshop: Build a bribery-risk universe for a regional organisation.
Why this module matters: Organisations can face bribery exposure through parties acting for or benefiting them, especially where the commercial rationale is weak or influence is opaque. Participants learn to:
- classify third-party relationships
- identify intermediary/agent red flags
- evaluate beneficial ownership and capability evidence
- assess compensation structure
- review scope and business rationale
- conduct proportionate due diligence
- manage enhanced review
- document approvals
- include appropriate contractual controls
- refresh monitoring when risk changes.
Simulation: Review three potential intermediaries and decide whether/how to proceed.
Why this module matters: Bribery risk often appears through transactions that are legitimate in many circumstances. Participants learn to:
- assess gifts/hospitality by value, timing, recipient and purpose
- manage public-official risk
- control facilitation-payment exposure
- identify and manage conflicts of interest
- review charitable donations
- review sponsorships
- manage political-contribution restrictions where applicable
- assess travel/expense arrangements
- identify tender/procurement risk
- document exceptions and escalation.
Workshop: Apply a risk-based decision framework to borderline transactions.
Why this module matters: Policies do not stop bribery when payment, procurement and approval processes allow transactions to bypass meaningful challenge. Participants learn to:
- design approval controls
- challenge unusual commissions and fees
- use segregation of duties
- connect procurement/sales controls with bribery risk
- review supporting evidence
- design speak-up channels
- manage non-retaliation
- triage allegations
- preserve evidence
- coordinate independent investigations and specialist support.
Workshop: Trace a bribery-risk scenario through payment, approval, report and investigation.
Why this module matters: An anti-bribery programme should evolve as markets, third parties, people and business models change. Participants learn to:
- design role-based training
- evaluate training beyond attendance
- monitor gifts, third parties and exceptions
- use data analytics cautiously to identify anomalies
- review programme incidents and near misses
- test key controls
- report meaningful information to leadership
- refresh the bribery risk assessment
- conduct management review
- build an ISO 37001-aligned improvement roadmap.
Capstone: Present an anti-bribery management programme for a realistic multinational organisation.
Design Controls Around the Transaction, Not the Policy Document
Anti-bribery controls become credible when they operate at the points where value, influence and discretion actually move. Participants map a transaction from request through approval, payment and review, then identify where bribery risk could enter and what evidence the organisation should retain.
- Third parties: define proportionate due diligence before appointment, including ownership, capability, reputation, commercial rationale and the reason for unusual commission or payment terms.
- Gifts and hospitality: set approval thresholds, prohibited circumstances, recording requirements and escalation for interactions involving public officials or sensitive decisions.
- Conflicts of interest: create a process for declaration, review, mitigation and periodic refresh rather than relying on a one-time form.
- Payments: connect invoice description, contract, deliverable, bank details and approval authority so a payment can be traced back to legitimate work.
- Speak-up and investigations: define how concerns are received, protected, triaged, investigated and escalated without prejudging the allegation.
- Monitoring: use transaction patterns, exceptions, override activity and third-party changes to identify where controls may be failing in practice.
Participants apply this method to a realistic transaction and document the control owner, evidence produced and escalation condition at each stage. The aim is to move beyond a policy that says bribery is prohibited toward a system that can show how higher-risk decisions are reviewed, how exceptions are visible and how management can detect whether the controls are actually operating.
Common Questions
The Absence of a Bribery Incident Is Not Proof That the Anti-Bribery Programme Works.
Build the risk, due-diligence and control evidence required to prevent, detect and respond with confidence.
📅 Upcoming Schedules — View dates and locations ▾
We run this course as a private programme for organisations. Bespoke dates, tailored content, group pricing.
Every course starts with a needs assessment and includes structured follow-up at three points after it ends.
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