The fight against corruption in Brazil has significantly evolved in recent years, largely due to the increasing awareness among companies regarding the importance of implementing more robust integrity policies.

The Brazil Office of the Comptroller General (“CGU”) plays a strategic and essential role in this evolution, acting not only as one of the main enforcement agencies against violations of corporate integrity but also in a preventive capacity by leading various initiatives to promote a more ethical and transparent corporate environment. An example of this is the management of the well-established “Pro-Ethics Company” program, which recognizes companies that adopt state-of-the-art compliance programs.

In this context, with the aim of attracting even more companies that wish to commit to corporate integrity, on August 29, 2024, the CGU published Normative Ordinance No. 160, which established the Pact Brazil for Corporate Integrity (“Pacto Brasil”). The purpose of Pacto Brasil is to invite companies and private entities to voluntarily commit to the corporate integrity and adopt concrete compliance measures. With Pacto Brasil, the CGU intends to reward small, medium, or large companies that, although may not yet have excellent integrity programs, are on the right path and intend to continue improving their integrity programs.

The management of Pacto Brasil will be carried out by the Secretariat of Private Integrity, which shall adhere to the rules established by Normative Instruction No. 39, which regulates Pacto Brasil. Among the various topics addressed in the regulation, we highlight the following:

(i) Adherence to Pacto Brasil will be formalized through the signing of an Adhesion Term by the company's principal executive leadership;

(ii) The adhering company must complete a self-assessment form, a mechanism through which companies can analyze the integrity measures they have in place and the existing possibilities for improving them; and

(iii) A company that adheres to Pacto Brasil may use the program's brand on its website and institutional materials, which could provide an opportunity for positive publicity.

It is also important to highlight that, according to statements from the CGU itself, adherence to Pacto Brasil will likely become a requirement for companies to register in the evaluation process of the Pro-Ethics Company program.

VPBG has a specialized team and is available to assist with this and any other matters related to compliance and corporate integrity.