BRAZIL Trends and Developments Contributed by: Valeska Teixeira Zanin Martins, Carla Costa Carneiro da Silveira, Carlos Henrique Sousa Dias, João Victor Orlandi Zanetti Della Penna and Renato Bastos Abreu, Zanin Martins Advogados
requiring tangible evidence of senior management’s engagement. These regulatory developments have encouraged the integration of compliance culture into corporate governance and risk management. Companies have come to understand integrity as a strategic value, real - ising that prevention is both more effective and less costly than remediation. Consequently, compliance is no longer viewed as a mere bureaucratic or financial burden but as an inte - gral part of performance and sustainable innovation. Aligning compliance with strategic business objec - tives creates a virtuous cycle that combines integrity, reputation and competitiveness. Public policy and international co-operation According to Transparency International, Brazil scored only 34 points in the 2024 Corruption Perceptions Index, ranking 107th out of 180 countries. This repre - sents the lowest performance since the index’s incep - tion and reveals a worrying stagnation in the advance - ment of both public and private integrity. Despite legislative progress, such as the enactment of the Anti-Corruption Law and the Public Procurement and Contracts Law (Law No. 14.133/2021), significant challenges remain regarding the effective enforcement of these norms. In this regard, the Office of the Comptroller General (CGU) has played a central role in promoting a culture of integrity, focusing on inter-institutional co-operation and constructive dialogue with the private sector. Among its recent initiatives, the 2025–2027 Integ - rity and Anti-Corruption Plan stands out, aiming to transform regulatory guidelines into concrete initia - tives. Organised around strategic pillars – prevention, detection, transparency and accountability – the plan comprises hundreds of measures to strengthen integ - rity across both the public and private sectors. These include educational campaigns, guidance materials, and institutional partnerships with companies and trade associations, thereby reinforcing social co- responsibility in the fight against corruption.
The plan also provides for joint operations with enti - ties such as the Administrative Council for Economic Defence (CADE) and the Federal Police, balancing reactive anti-corruption actions with proactive meas - ures to promote voluntary compliance. Moreover, the plan encourages good practices within the private sector, including awareness campaigns, advisory materials, and co-operation agreements with companies and business associations. This collabora - tive approach seeks to break away from a purely puni - tive model, fostering a shared environment of integrity. Parallel to domestic initiatives, Brazil has been expanding its international engagement in matters of integrity. During the 2025 BRICS Anti-Corruption Working Group meeting, co-ordinated by the CGU, participating nations reaffirmed their commitment to technical exchange and policy alignment. This mul - tilateral engagement strengthens Brazil’s reputation as a trustworthy partner in global governance and transparency. Such active participation in multilateral forums helps improve national strategies and harmonise anti-cor - ruption criteria across global value chains – position - ing Brazil as a credible partner in sustainable develop - ment and trade relations. Organisational culture and ethical leadership Embedding compliance into organisational culture remains one of the greatest challenges faced by com - panies. This requires more than documents and for - mal controls – it demands leadership, communication, and coherence between discourse and practice. An ethical culture is consolidated when declared val - ues translate into concrete decisions at every level of the organisation. A culture of integrity depends directly on an environment founded upon mutual trust. When employees perceive consistency between insti - tutional values and daily practices, they feel encour - aged to contribute to continuous improvement and to report irregularities, thereby strengthening integrity in a genuine and sustainable manner. The active engagement of senior management is vital to legitimising compliance actions and fostering
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