BRAZIL Trends and Developments Contributed by: Patricia Barboza, Alinne Gordilho and Amanda Costa, CGM Advogados
and emotional health of workers, such as bullying, burnout, and psychological violence. In this context, internal investigations are no longer just a corrective mechanism but have become part of a preventive strategy aimed at promoting safer and healthier work environments. The second trend is related to the impacts of the LGPD on the conduct of internal investigations. With the growing use of technologies such as inter - view recording and transcription, AI tools, and auto - mated analysis systems, new challenges arise: how to ensure compliance with principles such as purpose, necessity, data minimisation and non-discrimination without compromising investigative efficiency? In addition, issues such as valid consent, information security, and algorithmic transparency become central to avoiding regulatory risks and preserving employee trust. Although these two themes may seem disconnected at first glance, they both converge on the same axis: the need to balance investigative efficiency with com - prehensive protection, whether of workers’ mental health or of the privacy and personal data involved in the process. This intersection reveals a contemporary challenge for companies: structuring internal investigations that are robust, ethical, and compliant with labour and data protection regulations, without compromising agility and credibility. In the following sections, the authors will explore how these trends are shaping internal investigation prac - tices, the challenges they pose, and the best practices that can guide organisations towards a more integrat -
This transformation accompanies a global movement that values risk prevention, transparency, and social responsibility as pillars of business management. Traditionally, internal investigations were conducted to ascertain facts after illegal conduct or ethical vio - lations had occurred. Today, organisations recog - nise that anticipating risks is more efficient and less costly than remedying damage. This paradigm shift is directly linked to the expansion of regulatory and social expectations of companies. In the global context, internal investigations play an essential role in integrity programmes, ensuring com - pliance with national and international legislation. They reflect companies’ commitment to ethical prac - tices and respect for human rights, as well as reducing reputational and financial impacts in crisis situations. The way a company conducts its investigations reflects its commitment to ethical practices and respect for human rights, which is of paramount importance from an ESG, organisational culture and crisis management perspective. It should not be forgotten that well-structured inves - tigations reduce reputational and financial impacts. In Brazil, this movement will gain momentum in 2026 in the face of stricter labour rules, such as changes to NR-1, which require active management of psychoso - cial risks, and ongoing enforcement of data protection requirements under the LGPD, which imposes param - eters for the collection and processing of personal information. Added to this is the pressure for transparency, driven by stakeholders and regulatory bodies. This landscape sets the stage for the two trends that will be explored in the following sections: the use of internal investigations as a tool for preventing psycho - social risks, and the impacts of the LGPD and technol - ogy on the conduct of these investigations.
ed, preventive, and secure model. Overview of Internal Investigations
Internal investigations have evolved from a reactive mechanism, triggered only in response to reports or suspicions of irregularities, to a strategic corporate governance tool.
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