The Department of Standards Malaysia (DSM) has released an updated Malaysian Standard for Anti-Bribery Management Systems (ABMS). To ensure effective understanding and practical adoption across industries, ABMS-MY has formed a Working Group (WG) comprising practitioners and experts to review the changes, evaluate practicality, and share some guidance for practitioners and members.

This detailed write-up outlines the key findings and recommendations from the review of Clause 4 of ISO 37001:2025.

This article’s primary goal is to provide a clear and comprehensive overview of the new requirements within ISO 37001:2025. We aim to help you understand the core concepts and show you how they can be practically integrated into your organization’s anti-bribery management system.

For a more detailed look into the “how-to” aspects of implementation, we will be hosting a series of webinars. We’ll be inviting subject matter experts to share their insights and practical guidance.

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The latest update to ISO 37001:2025 marks a significant evolution in how organizations approach anti-bribery management. Instead of merely focusing on “objectives,” the new standard hones in on “intended results,” signaling a fundamental shift from simple process compliance to demonstrating genuine effectiveness and tangible outcomes. This change means that it’s no longer enough to have policies written down; organizations must actively show that these policies are working and producing real-world results.

A key concept introduced to support this is “Management Influence.” This expands an organization’s accountability beyond its direct control. It holds a company responsible for entities it can significantly sway, even without full ownership. This broader perspective ensures that an organization’s anti-corruption efforts extend beyond its own walls and into its wider ecosystem, like its supply chain or partnerships, preventing corruption in areas it might indirectly influence.

This new mindset requires a visible, physical commitment from leadership. For example, a board of directors cannot simply approve an anti-bribery policy and consider their job done. They must demonstrate their dedication through concrete actions, such as discussing anti-corruption efforts in meetings, implementing clear action plans, and fostering a culture of compliance that permeates the entire organization. This focus on “intended results” requires organizations to prove that their systems are truly effective at mitigating corruption, not just that they exist on paper. This is a move from simply “ticking boxes” to showing a verifiable, proactive stance against bribery.

MS ISO 37001:2025 introduces the concept of “Management Influence,” holding organisations accountable for entities they can significantly sway, even without direct control. This extends an organisation’s influence beyond direct ownership to its broader ecosystem.

For example, a parent company might not have a controlling share in a joint venture (JV), but its senior executives may hold key leadership positions on the JV’s board. In this scenario, the parent company’s influence over the JV’s governance, policies, and anti-bribery measures would be considered “management influence.” Similarly, a company that provides the sole essential technology for a critical government-run project, like a major infrastructure development, would likely have significant influence over the project’s operational and ethical standards, even if it’s not a formal partner.

This expanded accountability requires a wider definition of “interested parties.” The standard clarifies that “interested parties” is a more encompassing term than “stakeholders,” including anyone who can be affected by an organisation’s decisions, and is crucial for a robust ABMS system.

In practice, this means establishing the ABMS with a broader scope, forcing in-depth due diligence on all relevant parties. It also enhances how we monitor performance; instead of just internal metrics, we must now incorporate feedback from a more diverse group, turning monitoring into a proactive tool for risk mitigation.