ISO 37001:
Anti-Corruption Standard for Organisations in Kazakhstan, Uzbekistan, Georgia, and Kyrgyzstan

Corruption remains one of the most serious threats to economic growth, social progress and effective governance in the CIS countries, including Kazakhstan, Uzbekistan, Georgia and Kyrgyzstan. This phenomenon undermines trust in institutions, creates unfair competition and hinders the attraction of investment. To provide a systematic and effective response to these challenges, the international standard ISO 37001 Anti-Bribery Management Systems was developed. This standard offers organisations of any size and sector a proven methodology and practical tools for identifying, preventing, detecting and addressing corruption risks, as well as for responding to incidents of bribery.

What is ISO 37001 and why is it important

ISO 37001 is the world’s first international standard that sets out the requirements for an Anti-Bribery Management System (ABMS). Published by the International Organization for Standardization (ISO) in 2016, it is designed to help organisations implement and maintain effective anti-corruption measures. The standard is based on leading global experience and best practices in compliance and anti-bribery management.

Key elements of an Anti-Bribery Management System under ISO 37001 include:

• Development of anti-bribery policies and procedures: Formalising top management’s commitment and setting clear rules of conduct for all employees and associated parties.
• Appointment of responsible persons: Establishing a compliance function or designating an employee with the authority and resources to oversee the ABMS.
• Comprehensive bribery risk assessment: Identifying, analysing and evaluating bribery risks specific to the organisation’s activities, geographical presence and interactions with counterparties.
• Training and raising staff awareness: Regular training for employees at all levels on anti-bribery policies, procedures and the consequences of non-compliance.
• Implementation of financial and non-financial controls: Introducing mechanisms to monitor financial flows, procurement, gifts, hospitality expenses and other areas vulnerable to bribery risk.
• Due diligence: Screening business partners, suppliers, contractors and other third parties for bribery risks before establishing or continuing business relationships.
• Whistleblowing mechanisms: Creating safe and confidential channels for reporting suspected bribery without fear of retaliation.
• Internal audits and corrective actions: Regularly reviewing the effectiveness of the ABMS, identifying non-conformities and promptly taking corrective measures.
• Continual improvement: Analysing system performance and adapting it to changing conditions and emerging risks.

ISO 37001 is applicable to organisations of any size, type and sector – from small and medium-sized enterprises to large corporations, as well as public authorities, quasi-state institutions and non-profit organisations. Its flexibility allows requirements to be tailored to the specific context of each organisation.

Key benefits of ISO 37001 certification for your business:

Certification of a management system in compliance with ISO 37001 provides organisations with a range of strategic and operational advantages:

• Significant reduction of corruption and bribery risks: Implementing a structured system enables organisations to proactively identify, assess and minimise corruption risks, preventing financial and reputational losses.
• Enhanced trust and strengthened reputation: Holding an ISO 37001 certificate sends a strong signal to clients, partners, investors, employees and regulators about the organisation’s commitment to high ethical standards and transparency.
• Competitive advantage: Certified organisations often gain preferences when participating in public and private tenders, particularly where anti-bribery requirements are mandatory or highly valued.
• Access to international markets and foreign investment: ISO 37001 certification is recognised globally and can support compliance with the requirements of international partners and investors, as well as anti-bribery legislation in other countries (such as the FCPA and the UK Bribery Act).
• Improved corporate culture: Encourages a culture of zero tolerance towards corruption, raising ethical awareness and accountability among employees.
• Optimised business processes: The implementation of controls and procedures required by the standard often leads to overall management efficiency and cost reduction.
• Compliance with legal and regulatory requirements: The system helps organisations meet national anti-corruption laws and industry regulations.
• Easy integration with other management systems: ISO 37001 is built on the High-Level Structure (HLS), making it simple to integrate with other widely adopted standards, such as ISO 9001 (Quality), ISO 14001 (Environment), ISO 45001 (Occupational Health & Safety) and ISO 27001 (Information Security).

The process of implementing and certifying ISO 37001:

The process of implementation and subsequent certification to ISO 37001 is multi-staged and requires the involvement of both management and employees:

1. Preparatory stage: Management decision, formation of a working group, and defining the scope of the Anti-Bribery Management System (ABMS).
2. Diagnostic audit (Gap analysis): Assessment of the current management system and existing anti-bribery measures against the requirements of ISO 37001, identifying any “gaps”.
3. Development and implementation of the ABMS: Creation or refinement of anti-bribery policies, procedures and guidelines; appointment of responsible persons; conducting risk assessments; and developing control measures.
4. Staff training: Delivery of training sessions and workshops for employees at all levels on anti-bribery policies, procedures, risk identification and whistleblowing mechanisms.
5. Internal audit: Self-assessment of the effectiveness of the implemented ABMS, identification of non-conformities and development of corrective actions.
6. Management review: Evaluation by top management of the ABMS performance and decision-making on further improvements.
7. Certification audit: Independent audit carried out by an accredited certification body, usually conducted in two stages:
   • Stage 1: Review of documentation and readiness for the main audit.
   • Stage 2: Assessment of the actual implementation and effectiveness of the ABMS.
8. Certification: Upon successful completion of the audit, the organisation is awarded an ISO 37001 certificate, typically valid for three years, subject to annual surveillance audits.

Relevance of ISO 37001 in Kazakhstan, Uzbekistan, Georgia and Kyrgyzstan

The countries of Central Asia and the Caucasus are actively striving to improve their investment climate and strengthen the rule of law. In this context, the adoption of ISO 37001 takes on particular importance:

• Kazakhstan: The country pays considerable attention to anti-corruption measures at the state level. The adoption of ISO 37001 by government bodies (such as the Academy of Public Administration under the President of the Republic of Kazakhstan), as well as by quasi-state and private sector companies, demonstrates a commitment to transparency. This is particularly important for companies participating in public procurement and seeking international cooperation. The standard also supports compliance with the requirements of the Anti-Corruption Agency of Kazakhstan and national legislation.
• Uzbekistan: In recent years, Uzbekistan has taken significant steps to liberalise its economy and combat corruption. The adoption of the Law “On Combating Corruption” and the establishment of the Anti-Corruption Agency underline the seriousness of these efforts. For Uzbek companies, particularly those engaged in export activities and attracting foreign investment, ISO 37001 has become an important tool for demonstrating reliability and compliance with international business standards.
• Georgia: Georgia has made notable progress in tackling petty corruption and continues to refine its anti-corruption legislation. For Georgian companies aiming to integrate into European and global markets, ISO 37001 certification can serve as a valuable competitive advantage, confirming their commitment to ethical practices and transparency.
• Kyrgyzstan: In Kyrgyzstan, the fight against corruption is also a central focus for both government and society. The implementation of ISO 37001 can help organisations—especially those working with international donors or aiming to expand into foreign markets—strengthen their position, minimise risks and enhance trust among partners.

Across all these countries, there is a growing interest in the ISO 37001 anti-bribery standard from both state and quasi-state institutions, as well as the private sector, recognising that an effective anti-bribery management system is not merely a formality but a foundation for long-term and sustainable development.

How LLP System Management supports ISO 37001 certification

System Management has many years of experience and a team of qualified experts ready to provide a full range of services for the preparation, implementation and support of anti-bribery management system certification in line with ISO 37001:

• Professional consultancy: Clarifying the requirements of the standard and assisting in adapting the ABMS to the specific context of your organisation.
• Development and implementation of documentation: Support in creating an anti-bribery policy, procedures, risk maps and other essential documents.
• Staff training: Delivery of interactive training sessions and workshops for employees at all levels, including top management, on the fundamentals of ISO 37001 and its practical application.
• Diagnostic and internal audits: Assessing your system’s readiness for certification, identifying areas for improvement and preparing for the external audit.
• Support during the certification audit: Assisting your organisation throughout the certification process with the accredited body and helping to resolve any potential non-conformities.
• Post-certification support: Ongoing consultancy on maintaining and improving the ABMS after certification has been achieved.

Partnering with System Management is your route to an effective anti-bribery system, risk minimisation and enhanced business reputation. We guarantee a tailored approach, high-quality services and a results-driven focus at every stage of ISO 37001 implementation and certification.

Contact us today to receive detailed advice and discover how we can help your organisation reach new heights in anti-bribery management and business ethics!