ISO 37001: Standardization and its Discontents

We are reposting an article as part of the debate about the value of the ISO anti-bribery compliance standard. This was first published when the ISO standard was released, but we believe it remains a relevant part of the debate today.

The issue of universal standards has recently come to the forefront of the compliance world. We have just seen the release of a new and highly-anticipated document from the International Organization for Standardization: ISO 37001 - "Anti-bribery management systems." The document (available for purchase online) aims to define a standard for corporate anti-bribery compliance programs, both as an aid to implementation and as a reference point for certifying auditors.

Standards, of course, serve various purposes. On the one hand, they can help assure baseline quality in the interest of public welfare. On the other hand, they can establish compatibility and interoperability among separate systems. Both of these functions can be seen in the Great Baltimore Fire of 1904. When firefighting crews from New York and Philadelphia came to the city’s assistance, they discovered their hoses didn't fit the local hydrants. That experience led to the national standardization of firehose couplings—a classic example of the “compatibility” type of standard. It also led the city to adopt a building code requiring the use of fireproof materials—a good illustration of standards as “baselines.”

ISO 37001 is essentially a baseline-type standard. As such, it can serve a helpful purpose: articulating familiar principles from a formally neutral standpoint, not bound to the authority of any particular jurisdiction. What it doesn't do is respond to the need for consistency. Because there is no perfect anti-bribery system, it is important for companies to know that their programs are in line with industry and regional best practices, reflecting the actual risks each company faces. (A supermajor operating in Angola and a pharma company operating in China face very different challenges.) This can’t be captured in a single document. It requires ongoing development, communication, refinement, and response among companies and their compliance professionals.

By sharing and improving their anti-bribery strategies, practices, and techniques, companies can help elevate the standards of corporate ethics and integrity and send an increasingly consistent message that corruption will not be tolerated. At TRACE, we aim to support companies in their efforts to meet international standards that are based on a shared understanding of best practices and reasonableness.

Alexandra Wrage

President and Founder, TRACE