HR Internal Investigations 2026

BRAZIL Trends and Developments Contributed by: Patricia Barboza, Alinne Gordilho and Amanda Costa, CGM Advogados

• behavioural audits, conducted through periodic interviews with teams to assess the organisational climate; and • proactive interviews with leaders and employees, promoting a preventive approach with leaders and employees to detect signs of harassment and work overload, for example. These actions allow the organisation to act quickly, avoiding damage to workers’ mental health, psycho - social risks and reputational risks. The implementation of this preventive approach poses significant challenges, such as: • guaranteeing impartiality and confidentiality, and ensuring that internal investigations are not per - ceived by employees as persecution or excessive control and that they are not used as a tool for retaliation; • integrating strategic areas such as human resourc - es, compliance and legal; and • training teams to deal with emotional aspects and manage sensitive communications effectively. Good practices include creating clear protocols for investigating complaints, formalised in robust inter - nal policies, establishing organisational climate indi - cators, and offering psychological support to those involved. In general, when trained internal or external consult - ants participate in a compliance investigation, at the end of the process, recommendations for improve - ments are presented that aim to promote a healthier and safer work environment, in addition to preventing new irregularities. Among the most common recommendations are: • reviewing internal policies and codes of conduct; • conducting training on ethics, respect, and harass - ment prevention; • adopting more accessible and secure reporting channels; • strengthening internal communication and trans - parency in processes; and

• making adjustments to the organisational structure or work processes to reduce psychosocial risk factors, such as overload, lack of clarity of roles, or toxic environments. These actions can and should be integrated into the GRO provided for in NR-1, especially regarding the identification, assessment, and control of work-relat - ed psychosocial risk factors. By aligning compliance recommendations with the requirements of NR-1, the company strengthens its organisational culture, reduces legal and reputation - al risks, and contributes to a more ethical, safe and healthy work environment. It is also worth noting that these investigations often result in disciplinary measures being taken against employees who have acted contrary to the company’s ethical values and principles. The management of psychosocial risk factors provid - ed for in NR-1 and internal compliance investigations are therefore complementary processes. While the GRO acts in prevention and continuous monitoring, compliance investigations respond to specific situations, promoting correction and improve - ment. Integrating these practices strengthens organisational culture, reduces legal and reputational risks, and con - tributes to a safer, healthier and more ethical work environment. In the coming years, technological and cultural devel - opments are expected in this field, with the use of analytics and AI to identify behaviour patterns and risk signals in large volumes of data (such as feedback, internal surveys, etc), integration of investigations with ESG programmes, reinforcing corporate social responsibility, and greater regulatory requirements for transparent reporting on preventive and correc - tive measures. This trend positions internal investigations as pillars of mental health management at work, aligning compli - ance, well-being, and corporate reputation.

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