Developing Key Performance Indicators and Tracking Metrics Using ISO 37001 (Part One of Two) 

The International Organisation for Standardisation, a worldwide federation of national standards bodies, recently released a standard for anti-bribery management systems – ISO 37001. The new standard sets forth requirements for such a program, as well as guidance for establishing, implementing, maintaining, reviewing and improving it. It is a fairly detailed document spanning a range of topics such as employment procedures, third-party due diligence, risk assessments, financial and non-financial controls, and internal audits. In a guest article, Matthew Herrington, a partner at Steptoe & Johnson, Jonathan Drimmer, vice president and deputy general counsel at Barrick Gold Corp., and Leslie Benton, vice president of advocacy and stakeholder engagement of, discuss how companies can use the ISO to develop management tools such as key performance indicators (KPIs) and tracking metrics to address anti-corruption compliance. See “Developing Key Performance Indicators and Tracking Metrics for an Anti-Corruption Program” Part One (Feb. 24, 2016); Part Two (Mar. 9, 2016).

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