INTEGRITY AND GOOD PRACTICES

PUBLIC ADMINISTRATION

By using our experience in Compliance Programs for private companies, we have created INTEGRITY PROGRAMS for public administration entities, whether state or local, direct, autarchic, or foundational, in accordance with the Union’s General Controller (CGU Resolution 57/2019), and with State and Federal Laws that lay down the rules of conduct for service providers and for the promotion of transparency and access to information, and handling of conflicts of interest, and nepotism, the collection, and handling of complaints, the operation of the internal controls and procedures for functional accountability, it’s always up-to-date with the best practices in the world, including training of officers, government officials, and other professionals involved with the important and essential Government activity.

DEVELOPMENT AND IMPLEMENTATION OF THE INTEGRITY PROGRAM

Diagnosis, Implementation, Training, and Maintenance of the Integrity Program, in compliance with national and foreign legal provisions (CGU provisions, Bidding Law, Brazilian Anti-Corruption Law, FCPA, Sarbanes-Oxley, UK-BA, Antitrust), Receipt of Complaints (Ethics Channel), and Work/Adaptation to the standards of collegiate bodies (TCU, TCE, Comptroller, Ethics Committee). Background analysis of suppliers and other public or private organizations.

Complete Integrity Program cycle:

Prevention, detection, punishment, and remediation of corruption practices, fraud, irregularities, ethical and conduct deviations

Prevention and detection of vulnerabilities that may favor or facilitate the occurrence of facts that may compromise the Public Institution objectives

Document approved by senior management to organize integrity measures (Public Sector's Code of Conduct)

Proactive verification and analysis of implemented public acts and policies, as well as actions of suppliers, and other public or private organizations

Promotion, Strengthening, and Following of the Integrity Plan on behalf of public servants

Detection of irregular conduct, fraud, and ethical and conduct deviations

Receipt of reports by an independent, and auditable system, across multiple platforms

Proactive or reactive activity that is continuously carried out, supported by law, and within the scope of the Integrity Plan, directed to the integrity management unit

Prior survey on the business concept, and on suppliers', and others' work activities