The Brazilian CGU launches batch of significant new initiatives for Compliance Programs
The Office of the General Comptrollership of the Union (known as its local acronym “CGU”) has been playing a crucial role in fostering integrity in both the public and private sectors through the launch of innovative initiatives. Throughout December, CGU announced a series of actions aimed at solidifying its efforts to create a more transparent and ethical environment in both public and private domains, underscoring the importance of transparency and ethics in institutional practices.
Among these efforts, we highlight the launch of the Pro-Ethics Panel on December 7, 2023, a tool of the Pro-Ethics Project to incentivize raising awareness among companies regarding their role in combating corruption and reducing the risks of fraud in interactions between the public and private sectors.¹ The Panel provides a simplified and intuitive visualization of key information related to the project, including analytical data on the past editions, company profiles, and evaluations of the Compliance Form in the 2022-2023 edition. Lastly, an Analytical Compliance Report is generated as a result of Comprehensive Assessments of each company’s Compliance Program. The information is presented in a de-identified manner to preserve confidentiality, providing insightful data for companies committed to integrity. The interactive tool can be filtered to obtain various information, making it a valuable contribution for compliance professionals and scholars in the field.
On December 13, the Minister of the CGU, Vinicius de Carvalho, announced the Brazil Pact for Corporate Integrity, a project developed with the support of the Council for Sustainable Economic and Social Development (CDESS).² This initiative encourages companies operating in Brazil to publicly commit to corporate integrity throughout the business cycle. In this context, the implementation of integrity measures deemed necessary would provide protection to participating companies by preventing fraud, irregularities, and potentially reducing penalties under the Anti-Corruption Law. Any company with a presence in Brazilian territory, regardless of size or sector, can voluntarily join the Brazil Pact via:
- submitting the Adhesion Term, which will be available in January 2024; and
- conducting self-assessment within 180 (one hundred and eighty) days counted from the adhesion, as per the regulations.
The self-assessment results, made available through a CGU designated system, offer a diagnosis of basic integrity measures and encourage continuous improvement.
Lastly, on December 15, the Conference of the States Parties to the United Nations Convention against Corruption (CoSP-UNCAC) – a biennial meeting dedicated to the global fight against corruption – approved a resolution led by the Brazilian delegation coordinated by the CGU.³ The resolution, yet to be released through official channels, underscores the need to encourage the private sector to adopt integrity measures to prevent and combat corruption. In alignment with the CGU practices, the measure aims to establish a set of governmental incentives to encourage companies to adopt robust governance and risk management practices. Furthermore, the resolution acknowledges the significance of gender empowerment in the private sector and advocates for the public acknowledgment of entities dedicated to integrity. Backed by extensive international support, the resolution highlights Brazil's commitment to promoting ethical business practices and contributing to a more inclusive and sustainable business environment.
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