Pró-Ética is an initiative developed by the Office of the Comptroller General (CGU) that seeks to encourage the voluntary adoption of compliance mechanisms and procedures by Brazilian and multinational companies, through public recognition of companies that are committed to implementing measures aimed at preventing, detecting and remediating corruption and fraud misconducts, as well as promoting an organizational culture of integrity. At the end of each edition of Pró-Ética, the companies approved in the evaluation are included in the list of Pró-Ética Companies and are publicly recognized by CGU, and the winners are entitled to use the Pró-Ética seal. In addition, CGU also publicly discloses examples of best compliance practices adopted by companies included in the list of Pró-Ética Companies.

CGU has recently published the report for the 2018-2019 edition of Pró-Ética, in which it presented data on the evaluation of compliance programs of the companies participating in that edition. Considering the evaluation results and the data presented in the report, CGU identified certain aspects of compliance programs that need improvement and special attention by companies, including: (i) conducting periodic risk analyzes that address integrity risks; (ii) development of periodic communication and training plans; (iii) compliance program should be focused on fostering an organizational culture based on ethics and integrity, and not only on mere legal compliance; (iv) existence of a continuous process of supervision and management of compliance risks presented by third parties, among others.

CGU’s recommendations offer a valuable parameter for Brazilian and multinational companies operating in Brazil to improve their compliance programs, and show Brazilian authorities’ expectations regarding the implementation and improvement of compliance programs in light of the challenges presented by the new business reality.

Applications for the program Empresa Pró-Ética 2020-2021 edition are open until January 29, 2021.

For additional information, please contact Saud Advogados.

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