ISO 37001:2016 4.1: 4.1 Understanding the organization and its context
Identify the internal and external factors, tied to what the organization exists to do, that bear on whether its anti-bribery system can deliver its aims. At a minimum look at: how big it is, how it is structured and who holds delegated authority to decide; the places and industries it works in now or plans to enter; what its activities involve and how large and complex they are; how it makes its money; which entities it controls and which control it; who its business associates are; how often and in what way it deals with public officials; and the legal, regulatory, contractual and professional duties that bind it. Under Amendment 1 (2024) it must also decide whether climate change counts as one of these factors. Controlling another organization means directing its management, directly or indirectly.
This control maps to 28 controls across 21 other frameworks. If you already hold one of them, the evidence you collected for it is the starting point here rather than new work.