Anti-Bribery Certification for G7 Contractors (MS ISO 37001)
CIDB has made MS ISO 37001:2016 Anti-Bribery Management System certification mandatory for Grade G7 contractors through Pekeliling CIDB Bil. 1/2026. For the contractors that bid for the largest public and private projects in Malaysia, anti-bribery certification is becoming a condition of doing business, not a badge. It sits on top of an obligation that already applies: under Section 17A of the MACC Act 2009, in force since 1 June 2020, a company commits an offence when a person associated with it, including a subcontractor or agent, gives a bribe to obtain or retain business, whether or not management knew. The penalty is a fine of at least ten times the gratification or RM1 million, whichever is higher, imprisonment of up to twenty years, or both. The only defence is proof of adequate procedures.
This two-day course is for the integrity officers, quality and ISO managers, contracts, procurement and project leaders who have to build and certify the system in a construction business. It is construction-specific: tender and pre-qualification, site approvals and inspections, variation orders, subcontractor and supplier chains, and joint ventures. Check the effective date and any transition arrangements that apply to your next CIDB application with CIDB directly; the session walks through the circular and the certification timeline. For general awareness of the standard across a wider workforce, see ISO 37001 Anti-Bribery Awareness.
HRD Corp SBL-Khas Claimable
Programme Agenda
Day 1, 9:00 AM - 9:15 AM
Welcome and Programme Overview
Introduction to the session, objectives, and housekeeping.
Day 1, 9:15 AM - 10:15 AM
The CIDB Requirement and What It Means for G7 Contractors
Pekeliling CIDB Bil. 1/2026, how the requirement connects to CIDB registration and the contractor's standing on major tenders, and planning certification against your own registration timeline. Where the requirement meets the National Anti-Corruption Strategy and client-side integrity demands.
Day 1, 10:15 AM - 10:30 AM
Break
Day 1, 10:30 AM - 11:30 AM
Section 17A in a Construction Business
Corporate liability for bribery by associated persons, who counts as associated in construction, including subcontractors, agents, consultants and JV partners, and the adequate procedures defence built on the T.R.U.S.T. principles: top-level commitment, risk assessment, undertaking control measures, systematic review, and training and communication.
Day 1, 11:30 AM - 12:30 PM
Bribery Risk Assessment for a Contractor
Mapping bribery risk across the project lifecycle: tender and pre-qualification, approvals and permits, inspections and certificates, variation orders and claims, payment certification, procurement, foreign worker processes and dealings with public officials. Building a risk register the certification auditor will accept.
Day 1, 12:30 PM - 1:30 PM
Lunch
Day 1, 1:30 PM - 3:15 PM
Leadership, Policy and the Compliance Function
What MS ISO 37001 requires of the board and top management, the anti-bribery policy, and setting up an anti-bribery compliance function with the authority and independence the standard expects.
Day 1, 3:15 PM - 3:30 PM
Break
Day 1, 3:30 PM - 4:45 PM
Due Diligence on Subcontractors, Suppliers and Partners
Proportionate due diligence on subcontractors, suppliers, agents and JV partners, anti-bribery clauses and commitments, and managing the associated persons who create most of a contractor's Section 17A exposure.
Day 1, 4:45 PM - 5:00 PM
Day 1 Close
Recap and what to review before day two.
Day 2, 9:00 AM - 9:15 AM
Day 1 Review
Recap of day one and the questions it left open.
Day 2, 9:15 AM - 10:15 AM
Controls That Work on Site and in the Office
Gifts, hospitality, donations and sponsorships, facilitation payments, financial controls on payments and petty cash, controls over tender processes and variation approvals, and decision records that show why.
Day 2, 10:15 AM - 10:30 AM
Break
Day 2, 10:30 AM - 11:30 AM
Raising Concerns, Investigations and Training
Speak-up channels, protecting people who report, investigating allegations, disciplinary consequences, and role-based anti-bribery training for site, commercial and management staff.
Day 2, 11:30 AM - 12:30 PM
Documented Information and the Evidence Pack
The documents the standard requires and the evidence that shows the system operates, mapped to T.R.U.S.T. so the same pack supports certification and a Section 17A defence.
Day 2, 12:30 PM - 1:30 PM
Lunch
Day 2, 1:30 PM - 3:15 PM
Internal Audit, Management Review and Certification
Internal audit and management review, choosing a certification body accredited by the Department of Standards Malaysia, stage one and stage two audits, typical nonconformities in construction, and surveillance after certification.
Day 2, 3:15 PM - 3:30 PM
Break
Day 2, 3:30 PM - 4:45 PM
Workshop: Readiness Gap Assessment
Participants score their own organisation against the standard and the CIDB requirement, and leave with a prioritised gap list, a bribery risk register outline and a certification timeline.
Day 2, 4:45 PM - 5:00 PM
Wrap-Up and Q&A
Key takeaways, next steps, and close.
Key Outcomes
- Explain the CIDB MS ISO 37001 requirement for G7 contractors and plan certification against it
- Apply Section 17A corporate liability and the T.R.U.S.T. principles to a construction business
- Build a bribery risk register covering tender, approvals, variations, payments and subcontractors
- Design proportionate due diligence and controls for subcontractors, suppliers and JV partners
- Assemble the documented information and evidence pack a certification audit expects
- Prepare for internal audit, management review and stage one and two certification audits
Training Mode Physical / Online / Hybrid / e-learning
HRD Corp SBL-Khas Claimable
Level Intermediate. For integrity and compliance officers, ISO and quality managers, contracts, procurement and project managers, and directors of G7 contractors and those preparing to become G7. Awareness of MS ISO 37001 helpful but not required.
Duration 2 Days (16 Hours) | 9:00 AM to 5:00 PM daily
Venue In-house at the client's premises, or delivered via the client's preferred platform (Microsoft Teams, Zoom, or equivalent)
Assessment A readiness gap assessment and bribery risk register outline for the participant's organisation, plus a written knowledge check
Certificate Certificate of Completion issued to all participants upon full attendance