Planning for ISO 37001 Anti-Bribery
ISO 37001 Clause 6
Bribery risks are identified, assessed and rated, with anti-bribery objectives set to address them and plans drawn up to deliver those objectives.
ISO 37001 Clause 6 - Planning
Clause 6 takes the issues, parties and risks identified in Clause 4 and turns them into planned actions, objectives and changes. The clause has three sub-clauses. 6.1 covers actions to address risks and opportunities. 6.2 covers the anti-bribery objectives and how they are planned and tracked. 6.3 requires changes to the ABMS to be carried out in a planned manner - this is a new sub-clause added in ISO 37001:2025 to align the standard with other Annex SL management systems.
Sub-clauses Covered by Clause 6
Clause 6.1 - Actions to Address Risks and Opportunities requires the organisation to plan actions arising from the issues, interested parties and bribery risk assessment, integrate them into the ABMS processes and evaluate their effectiveness.
Clause 6.2 - Anti-bribery Objectives and Planning to Achieve Them requires anti-bribery objectives at relevant functions and levels - measurable, monitored, communicated, updated and consistent with the policy.
Clause 6.3 - Planning of Changes is the 2025 addition - changes to the ABMS need to be carried out in a planned manner. This brings 37001 into line with the rest of the Annex SL family.
Planning links the bribery risk assessment to what the organisation actually does next. If the assessment surfaces risks but no action follows, the planning step is missing. Most of the work happens through an issues and actions register and the ABMS objectives.
The objectives in Clause 6.2 and the actions in Clause 6.1 are different things. Objectives are the targets the organisation sets for itself - reduce time to investigate concerns, increase staff completing anti-bribery training, complete due diligence on all higher-risk suppliers. Actions are the specific tasks that arise from risks and opportunities. Both come together in management review.
