Do you know what an integrity program is and what it is for?

Gone are the days when companies simply had to worry about selling their products (or providing their services) and making a profit. These days, even small companies need to comply with a series of industry standards and demonstrate they have an ecosystem of ethical work — there are even discussions about a corporation's role in social and environmental factors, such as the famous assessment known as Environmental, Social and Corporate Governance or ESG.

In this series of obligations and competitive differentiators, there are integrity programs — but, after all, do you know what they are and what they are for? They are often mistaken with compliance programs, which, in turn, are more focused on complying with specific regulatory measures of the sector in which the company operates. In turn, integrity programs were created through Federal Decree No. 8.420/2015, which regulates the Anti-Corruption Law (No. 12.846/2013).

According to this decree, an integrity program "consists, within a legal entity, of a set of internal mechanisms and procedures for integrity, audits, and incentives to report irregularities and the effective application of codes of ethics and conduct, policies and guidelines aimed at detecting and correcting deviations, frauds, irregularities and unlawful acts committed against the public administration, either national or foreign". In practice, what does this mean?

Pillars of a program

In simple terms, an integrity program is a series of internal rules and actions that seeks to prevent and combat illegal activities within a company, including embezzlement, corruption, fraud, impediments to auditing processes, and so on. The ultimate objective is to prevent private companies from conflicting with public interests, being especially important in bidding processes and various types of inspection. However, the corporate culture also benefits from integrity programs.

After all, it can avoid financial and reputational damage, strengthen the company as a whole, bolster its credibility on the market, enhance its brand, and contribute to sustainable development (which directly reflects the aforementioned ESG concept). However, for a program to be successful, it needs to abide by some crucial pillars that need to work in the most integrated and harmonious way possible. These pillars are:

• The commitment and support of the top management;

• Responsible instances;

• Profile and risk analyses;

• The structuring of rules and instruments;

• Continuous monitoring strategies.

In other words, the company's board of directors needs to be directly involved in the preparation of the program; a group focused on this activity must be created; a study must be conducted of the risks according to the company's organizational structure; and a code of ethics and conduct must be drawn up consistent with the reality of the corporate culture to ensure that the program is applied continuously.

Actions under development

It is important to point out that an integrity program is cyclical — its role is to prevent illegal practices, mitigate them if they are identified, and to react by adapting actions to prevent such incidents from happening again. Furthermore, considering that current legislation is always changing and evolving, the program also needs to adapt to the needs of the current scenario.