ISO 37001 anti-bribery management in Georgia

What ISO 37001 is

ISO 37001 sets requirements for an anti-bribery management system. It covers bribery by and of the organisation, its staff and its business associates, in the public and private sectors. Core elements are an anti-bribery policy, a compliance function with real authority, bribery risk assessment, due diligence on staff and business associates, financial and non-financial controls, gifts and hospitality rules, whistleblowing and investigation.

The second edition, ISO 37001:2025, was published in 2025. It keeps the same structure and core requirements as the 2016 edition, adds climate change considerations, clarifies the role of the anti-bribery compliance function and revises the requirements on conflicts of interest. Under the transition arrangements, initial certification audits against the 2016 edition were possible only until 30 August 2026, and certificates to ISO 37001:2016 must be transitioned by 28 February 2027.

Why it matters in Georgia

Bribery is a criminal offence under Georgian law, and Georgian companies working with foreign partners can also be affected by foreign laws such as the UK Bribery Act or the US Foreign Corrupt Practices Act through their contracts. The institutional setting also changed in 2026: the Anti-Corruption Bureau was abolished and its functions moved to the State Audit Office. For businesses, the practical drivers for ISO 37001 are:

• Public procurement. Georgian public tenders run through the State Procurement Agency's electronic procurement system. A documented anti-bribery system helps a bidder show integrity controls to contracting authorities and reduces the risk of disputes and exclusions.
• Donor and lender-funded projects. Infrastructure, energy and municipal projects financed by international lenders such as the World Bank, EBRD and ADB come with anti-corruption clauses and sanction regimes for contractors and subcontractors.
• Foreign shareholders and partners. International groups require their Georgian subsidiaries, distributors and agents to show anti-bribery controls.
• State-owned enterprises and regulated sectors that want to show transparent governance to lenders and partners.

How BALTUM prepares you

1. Context and scope. We review your business model, markets, public sector exposure and business associates.
2. Bribery risk assessment. We identify where bribery risk sits: tenders, permits, customs, sales agents, donations, sponsorships and hiring.
3. Policy and compliance function. We draft the anti-bribery policy and define the compliance function, its independence and reporting lines.
4. Controls and due diligence. Gifts and hospitality rules, conflict of interest declarations, due diligence for business associates and high-risk positions, and anti-bribery clauses in contracts.
5. Reporting and investigation. A confidential reporting channel and an investigation procedure that protects reporters.
6. Training, internal audit and management review. Training for staff and managers by risk level, an internal audit and the governing body review the standard requires.
7. Certification support. Help in choosing an accredited certification body and support during the audits.

Duration depends on the size of the organisation, the number of business associates and existing compliance practices. We set it after the first assessment.

How certification works

Certification follows a two-stage audit and a three-year cycle with surveillance audits. The auditor interviews management and staff in high-risk roles and samples due diligence and financial control records. Choose a certification body accredited for ISO 37001 by an IAF MLA signatory and check its certificates in IAF CertSearch.

Related standards and reading

ISO 37001 can be integrated with ISO 9001, which many tender participants already hold. For the procurement angle, read ISO 37001 anti-bribery management and public procurement in Georgia.

To discuss your situation, send a short description through the request form or to info@baltum.org. Requests are handled confidentially.

Frequently asked questions

Does ISO 37001 certification guarantee that no bribery will happen?

No. The standard itself says it cannot guarantee that. It requires reasonable and proportionate measures to prevent, detect and respond to bribery, which is what auditors and partners look for.

We are certified to ISO 37001:2016. What should we do?

Plan the transition audit with your certification body so that it is completed before 28 February 2027. We can run a gap assessment against the 2025 edition and update your documents.

Is ISO 37001 suitable for a medium-sized company?

Yes. The controls are proportionate to risk. A medium-sized supplier can meet the standard with a short policy, a part-time compliance function and focused due diligence.