NALCO ABMS Consultant Bid Proposal | ISO 37001:2025

4-Stage Turnkey Consulting Methodology

Structured 24-week institutional transformation for ISO 37001:2025 certification readiness

STAGE 1 : WEEKS 1 - 6 Clause 4 & 6

Bribery Risk Assessment & Baseline Gap Diagnosis

Comprehensive audit of NALCO's operational touchpoints across Corporate, Mines (Damanjodi), Smelter (Angul), and Port (Vizag).
Quantified Bribery Risk Matrix: Inherent vs. Residual risk across high-value procurement, scrap auctions, logistics, and CSR disbursements.
Review of existing vigilance frameworks, integrity pacts, and Central Vigilance Commission (CVC) statutory alignments.
Stakeholder expectations and Anti-Bribery Governance boundary definition for NALCO Corporate.

STAGE 2 : WEEKS 7 - 12 Clause 5, 7 & 8

ABMS Governance Architecture & Policy Formulation

Drafting the NALCO Apex ABMS Manual, Anti-Bribery Policy Statement, and Board-level Charter.
Formulation of Standard Operating Procedures (SOPs): Gifts, Hospitality, Donations, Sponsorships, and Conflict of Interest.
Third-Party Due Diligence protocols for high-risk vendors, contractors, bauxite hauliers, and joint venture associates.
Establishment of Independent Anti-Bribery Compliance Function (ABCF) with direct reporting line to Board Audit Committee / CVO.

STAGE 3 : WEEKS 13 - 18 Clause 8 & 9

Operational Controls & Digital Whistleblowing OS

Integration of financial and non-financial anti-bribery controls within SAP ERP procurement and approval matrices.
Turnkey architecture for an anonymous, end-to-end encrypted Whistleblower Reporting & Incident Case Management System.
Contractual clauses enhancement: Anti-Bribery and Anti-Corruption (ABAC) warranties in tender schedules and purchase orders.
Vendor Due Diligence Scorecards and automated sanction/debarment screening checklists.

STAGE 4 : WEEKS 19 - 24 Clause 9 & 10

Capacity Building, Internal Audits & Certification Body Audit Support

Leadership workshops for CMD, CVO, Functional Directors, EDs, and General Managers.
Certified Lead Internal Auditor Training (ISO 37001:2025) for NALCO Vigilance and Quality teams.
Complete pre-assessment mock audit across all operating units to identify and close NCs (Non-Conformities).
100% on-site facilitation during Stage 1 and Stage 2 certification audits by accredited Certification Bodies (NABCB / IAF).

NALCO Core Operational Units - Risk Mitigation Scope

Tailored risk containment protocols across NALCO's industrial lifecycle

Central Procurement & Contracts

Risk screening on tender drafting, sole-source proprietary purchases, variation orders, rate contracts, and bill clearing milestones.

Mines & Refinery (Damanjodi)

Bauxite extraction oversight, haulage contracts, diesel supply management, weighbridge integrity, and local land displacement compliance.

Smelter & Power Plant (Angul)

Coal linkage oversight, ash dyke management, plant maintenance contracting, scrap aluminium auction disposal, and power transmission.

Port Facilities (Visakhapatnam)

Caustic soda import handling, alumina export vessel chartering, customs clearance touchpoints, and port demurrage charge mitigation.

Marketing, Export & CSR Desks

Domestic distributor quota allocations, export pricing discounts, CSR project implementing agency vetting, and grant disbursements.

Vigilance & Statutory Interface

Continuous alignment with Central Vigilance Commission (CVC) Circulars, Lokpal directives, CAG audit observations, and statutory filings.

Key Consulting Team & Resource Allocation

Dedicated domain experts deployed for NALCO Corporate Office engagement

Er. S. K. Rajhans

Lead Engagement Director

B.Eng (1995), 30+ Years Engineering & Industrial Management Leadership. Project governance, C-suite alignment, and PSU liaison.

Senior ABMS Consultant

ISO 37001 Lead Auditor

Certified ISO 37001:2025 & ISO 9001 Lead Auditor with 15+ years experience in corporate compliance manuals, gap analysis, and audits.

Legal & CVC Specialist

Statutory Compliance Lead

Expert in Prevention of Corruption Act (POCA 1988/2018), CVC Vigilance Manual, Whistleblower Protection Act, and contract risk clauses.

IT & ERP Systems Analyst

Whistleblower OS Architect

Specialist in SAP ERP segregation of duties (SoD), automated delegation of financial powers (DoFP) verification, and encrypted intake portals.

Interactive NALCO ABMS Clause-by-Clause Checklist

Evaluate departmental readiness for ISO 37001:2025 standard requirements

Readiness Score: 100%

Clause 4.5: Bribery Risk Assessment

Regular quantified assessment across high-value contracts and external touchpoints.

Clause 5.1 / 5.2: Governing Body Oversight & Policy

Board-approved Anti-Bribery Policy and designated Compliance Officer.

Clause 7.2 / 7.3: Training, Awareness & Competency

Role-specific training for procurement, logistics, finance, and marketing executives.

Clause 8.2: Third-Party & Vendor Due Diligence

Risk-based vetting before onboarding suppliers, contractors, and intermediaries.

Clause 8.7: Gifts, Hospitality, Donations & Benefits

Strict value thresholds, gift declarations, and transparent CSR grant protocols.

Clause 8.9: Whistleblower Reporting & Non-Retaliation

Confidential and anonymous intake mechanism with strict whistleblower protection.

Clause 9.2: Internal ABMS Audits & Inspections

Scheduled audit programs by trained and independent internal auditors.

Clause 10.1: Nonconformity & Corrective Actions

Root cause investigation protocols, CAPA registers, and continual improvement.

Milestone Billing & Deliverables Schedule

Standard PSU milestone distribution aligned with GeM contracting norms

Milestone	Key Deliverable	Timeline	Payment %	Verification Authority
M1 : Inception & Gap Report	As-Is Gap Analysis Report, Enterprise Bribery Risk Matrix, Stakeholder Map	T + 6 Weeks	20%	GM (Vigilance) / NALCO Nodal Officer
M2 : ABMS Manual & SOPs	Apex ABMS Manual, 12 Core SOPs, Gift & Hospitality Code, Due Diligence Toolkit	T + 12 Weeks	25%	CVO / Audit Committee Approval
M3 : Controls & Whistleblower OS	ERP Control Matrix, Anonymous Whistleblower Portal Blueprint, Vendor ABAC Toolkit	T + 18 Weeks	25%	ED (P&A) / GM (IT & Systems)
M4 : Audits & Certification	Internal Audit Reports, Executive Training Records, CB Stage 1 & 2 Audit Clearance	T + 24 Weeks	30%	Director (HR) / CMD / NALCO Board