The International Organisation for Standardisation’s new standard for anti-bribery management systems – ISO 37001 – provides a useful frame of reference for companies developing management tools such as key performance indicators (KPIs) and tracking metrics to address anti-corruption compliance. In the first part of this guest article series, 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 CREATE.org, explained how to use ISO 37001 to develop management tools such as KPIs and tracking metrics to address anti-corruption compliance, and provided an example of a KPI strategy mapped to the training requirement. In this second part, they examine additional areas of ISO 37001 that naturally lend themselves to KPI and/or metrics. See “Developing Key Performance Indicators and Tracking Metrics for an Anti-Corruption Program” Part One of Two)” (Feb. 24, 2016); Part Two (Mar. 9, 2016).