What makes a good Integrity Program?
The 16 parameters used to evaluate Integrity Programs in Brazil are established in the article 42nd of the Brazilian Decree-Law 8420/2015. Do you think you can answer a couple questions about them?
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1
Standards of conduct, code of ethics and integrity policies and procedures must be applied:
To third parties, always, and to employees and the administrative personnel, if necessary.
To all employees and the administrative personnel, always, and to third parties, if necessary.
2
What is the responsibility of the company's top management regarding the Integrity Program?
To merely respect the program guidelines, just like any other collaborator.
To show explicit support to the program.
3
Which of the following is NOT a pillar of the Integrity Programs?
Performance of periodic analysis of risks.
Continuous monitoring of the program aiming at its enhancement.
Implementation of periodic trainings regarding the program.
Provision of financial incentives to those who follow the policies of the program.
4
When it comes to the company's financial controls, which of those is NOT an obligation of Integrity Programs?
To keep accounting books with complete and precise records of the company's transactions.
To establish specific procedures in order to prevent fraud and illicit acts during bidding processes and in the execution of administrative contracts, or in any interaction with the public sector.
To stimulate advance payments.
To create internal controls that secure the elaboration and reliability of the company's reports and financial statements.
5
The Compliance Department must:
Be located in a physical establishment separated from the other departments.
Have independency, structure and authority in order to apply the Integrity Program and supervise its compliance.
6
When it comes to preventing possible irregularities, which measure should NOT be taken by the Compliance team?
Open and wide dissemination of the reporting channels to employees and third parties.
Establishment of punishments for those who report without having evidences to corroborate their statements, even if they are reporting in good faith.
Creation of procedures that guarantee the immediate interruption of the irregularities or infractions detected, and that quickly remediate any possible damages caused by it.
Establishment of disciplinary measures in case of violations of the Integrity Program.
7
The due diligence process should be performed when hiring and, if necessary, supervising third parties who are:
Suppliers, service providers, intermediary agents, and associates in general.
Exclusively public companies, government agencies and foundations.
8
During the processes of fusion, acquisition and corporate restructuring, the Compliance Department must:
Execute the payments of any values involved in the transaction.
Verify the existence of irregularities, illicit acts or vulnerabilities regarding the legal entities involved.
9
All the factors bellow affect the strictness of the Integrity Programs assessments, except:
The level of interaction with the public sector and the importance of governmental approvals, licenses and permits in its operations.
The CEO's nationality.
The company's size.
The internal hierarchy complexity.
The amount and location of legal entities included in its economic group.
The countries in which it operates.
The usage of intermediary agents as consultants or commercial representatives.
The market sector it is in.
