This chapter looks at current institutional arrangements for public integrity established in Brazil at the federal level, including existing co-ordination mechanisms and the outreach to states and municipalities. It provides recommendations for strengthening the institutional and strategic integrity framework in Brazil in view of consolidating a coherent and consistent integrity system. It also shares as good practices for setting incentives to implement integrity policies at the state and municipal levels. Brazil’s National Strategy against Corruption and Money Laundering (ENCCLA) could be better leveraged to provide a vision for the country’s integrity approach and to monitor, evaluate and communicate integrity and anti-corruption policies.
OECD Integrity Review of Brazil 2025
Abstract
The lack of integrity in public decision-making, in the form of corruption or other unethical practices, is affecting countries worldwide, with generally corrosive effects: it impedes the quality and effective delivery of public services, impedes inclusive growth, perpetuates inequality and poverty and enables organised crime. This can exacerbate political polarisation and undermine democracy and public trust in public institutions.
Corruption continues to be perceived by both experts and citizens as an issue in Brazil despite efforts to strengthen the country’s integrity and anti-corruption system. In Transparency International’s 2024 Corruption Perception Index (CPI), which measures the perception of experts and businesspeople based on different international corruption surveys and assessments, Brazil scored 34 on a scale of 0 (highly corrupt) to 100 (very clean). Brazil’s score is equal to the average of Latin America (34) and, with a confidence interval of 30-38, Brazil’s score is not significantly different from Colombia (39), Argentina (37), Dominican Republic (36) or Panama (33), Peru (32) and Ecuador (31). However, Brazil scored significantly lower than other Latin American countries like Chile (63), Costa Rica (58) and Uruguay (76) and significantly lower to its own score in 2012 (where the score was 43). Figure 1.1 displays the results of the CPI 2024 with the confidence intervals. In the Capacity to Combat Corruption Index 2023, published by Americas Society, the Council of the Americas and Control Risks, Brazil experienced for the first time a slight (1.5%) increase after a three-year decline between 2019 and 2022.
Source: Transparency International (2025[1]), Corruption Perceptions Index 2024, https://www.transparency.org/en/cpi/2024 (accessed on 14 February 2025).
Trust in public institutions is essential for democracy and is key to helping Brazil effectively address many of its current challenges. However, Brazil has historically been a country with low-to-moderate levels of public trust, which, in line with trends across Latin American countries, has been consistently declining during the last decades (OECD, 2023[2]). According to the Gallup World Poll, in 2022, only 39% of Brazilians reported having confidence in their national government (OECD, 2023[2]). This share was equal to the Latin American and the Caribbean average, but below the levels of trust reported prior to the 2008 global financial crisis, when Brazil experienced a peak in levels of trust with 51% of the population reporting having confidence in the federal government (OECD, 2023[2]).
Furthermore, the OECD Trust Survey carried out online in Brazil in April 2022 found that, while only one quarter of Brazilians (25.9%) reported “high” or “moderately high” levels of trust in their federal government, this was a larger share than those who reported “high” or “moderately high” levels of trust in local government (19.6%) and the civil service (23.6%) (OECD, 2023[2]).
Additionally, more than half of Brazilians believe that public institutions are not working in the public interest. According to the 2023 Latinobarómetro survey, 54.2% of respondents in Brazil think that their country is governed in the interest of a few powerful groups, while 40.9% believe Brazil is governed for the good of all people (Figure 1.2). Although this is considerably better than the average of all Latin American countries covered by the survey (71.6% of people in the region think that their countries are governed for a few powerful groups in their own interest), the score indicates that Brazilians perceive that powerful groups exert too much influence on the outcomes of public decision-making processes. When compared to previous years, there seems to be a positive trend since 2017 that needs to be maintained to strengthen trust in public institutions and in democracy (Figure 1.3).
Note: Respondents were asked the following question: “Generally speaking, would you say that your country is governed for a few powerful groups in their own interest? Or is it governed for the good of all?”
This survey was conducted in 17 countries in the region (i.e., Argentina, Bolivia, Brazil, Colombia, Costa Rica, Chile, Ecuador, El Salvador, Guatemala, Honduras, Mexico, Panama, Paraguay, Peru, Dominican Republic, Uruguay and Venezuela).
Source: Corporación Latinobarómetro (2023[3]), Homepage, https://www.latinobarometro.org/latOnline.jsp (accessed on 14 February 2025).
Moreover, satisfaction with the functioning of democracy in Brazil is also experiencing a positive trend since 2018. Indeed, in 2023, 31.3% of Brazilians indicated that they are either “very satisfied” or “rather satisfied” with the functioning of democracy in their country, compared to 21.3% in 2020 and 8.7% in 2018 (Corporación Latinobarómetro, 2021[4]). This positive trend takes place after a significant increase in the number of those who declared themselves to be “not satisfied at all” or “not very satisfied” with the functioning of democracy from 2010 (44.7%) to 2018 (89%) (Figure 1.4). Despite this positive trend since 2018, those who declare themselves to be “very/rather satisfied” with democracy remain low, and challenges persist. For instance, in its 2021 Global State of Democracy Report, the International Institute for Democracy and Electoral Assistance (IDEA) listed Brazil as one of the ten democracies with the greatest decline in sub-attributes of democracy in the past decade (IDEA, 2021[5]).
Note: Respondents were asked the following question: “Generally speaking, would you say that your country is governed for a few powerful groups in their own interest? Or is it governed for the good of all?”
This survey was conducted in 17 countries in the region (i.e., Argentina, Bolivia, Brazil, Colombia, Costa Rica, Chile, Ecuador, El Salvador, Guatemala, Honduras, Mexico, Panama, Paraguay, Peru, Dominican Republic, Uruguay and Venezuela).
Source: Corporación Latinobarómetro (2023[3]), Homepage, https://www.latinobarometro.org/latOnline.jsp (accessed on 14 February 2025).
Note: Respondents were asked the following question: “In general, would you say that you are very satisfied, rather satisfied, not very satisfied or not at all satisfied with the functioning of democracy in Brazil?”
This survey was conducted in 17 countries in the region (i.e., Argentina, Bolivia, Brazil, Colombia, Costa Rica, Chile, Ecuador, El Salvador, Guatemala, Honduras, Mexico, Panama, Paraguay, Peru, Dominican Republic, Uruguay and Venezuela).
Source: Corporación Latinobarómetro (2023[3]), Homepage, https://www.latinobarometro.org/latOnline.jsp (accessed on 14 February 2025).
To help governments respond to high levels of perception of corruption and low levels of public trust and satisfaction with the functioning of democracy, the 2017 OECD Recommendation of the Council on Public Integrity provides policymakers with a vision for a public integrity system based on international experiences and good practices (Figure 1.5). It shifts the focus from ad hoc integrity policies to a context dependent, behavioural, risk-based approach with an emphasis on nurturing a culture of integrity across the whole of society (OECD, 2017[6]).
Source: OECD (2017[6]), Recommendation of the Council on Public Integrity, https://legalinstruments.oecd.org/en/instruments/OECD-LEGAL-0435.
The goal of a public integrity system is to ensure the consistent alignment of, and adherence to, shared ethical values, principles and norms for upholding and prioritising the public interest over private interests in the public sector (OECD, 2017[6]). Promoting public integrity therefore includes, but goes beyond, tackling corruption. The integrity lens is a positive and broad approach that emphasises the goal a country wants to achieve rather than focusing on the problem it faces, while taking a risk-based approach. Indeed, while corruption and other unethical practices need to be detected, investigated and sanctioned, more in-depth preventive actions are necessary to address systemic and institutional weaknesses that enable such behaviours in the first place. Put differently, countries face the challenge to move from a reactive “culture of cases” to a proactive “culture of integrity”. As such, public integrity is a cornerstone of good governance and a condition for ensuring that public policies unfold their intended benefits and that public institutions are trusted by the citizens.
This Integrity Review is a comprehensive analysis of the situation in Brazil today and provides concrete recommendations on how to continue improving in several dimensions of its public integrity system. The resulting road map is meant to inform the national dialogue and enrich it with proposals for action and good practices from other countries.
This first chapter examines the first pillar of the OECD Recommendation of the Council on Public Integrity: the System. It analyses the institutional and strategic arrangements in Brazil, which should ensure that public-sector organisations take responsibility for effectively managing the integrity of their activities as well as that of the public officials who carry out those activities. Country practices and experiences show that an effective public integrity system requires demonstrating commitment at the highest political and management levels of the public sector (Principle 1) (OECD, 2020[7]). Integrity reforms should be integrated into senior political and managerial governance agendas and based on in-depth analysis that recognises the complexity of integrity problems, rather than highly visible but short-term fixes (Brinkerhoff, 2000[8]). This translates into developing the necessary legal, institutional and strategic frameworks, clarifying institutional responsibilities and objectives as well as ensuring that these can be effectively implemented to achieve impact.
In this sense, this chapter looks at the different actors participating in the Brazilian integrity system and the formal and/or informal mechanisms for co-operation and co-ordination between them (Principle 2). Clear mechanisms for horizontal and vertical co-operation and co-ordination between integrity actors within and across branches of power, sectors and subnational levels help to avoid fragmentation, overlap and gaps and ultimately to ensure the coherence and impact of integrity policies (OECD, 2020[7]). This chapter also emphasises the relevance of a national public integrity strategy for supporting a coherent and comprehensive integrity system in Brazil (Principle 3). In addition to setting strategic objectives and priorities for the public integrity system based on a risk-based approach, a national strategy demonstrates commitment and can be used to establish and further clarify institutional responsibilities (OECD, 2020[7]). This includes identifying and involving all relevant public sector and whole-of-society stakeholders in the development process and specifying monitoring and evaluation arrangements to properly gauge the effectiveness of the integrity strategy.
The other chapters of this Integrity Review analyse in further detail specific areas of the public integrity system: promoting an open culture of integrity in the public sector (Chapter 2), recognising the role of private companies, civil society organisations and citizens in promoting public integrity and adhering to integrity standards in their interactions with public officials and with one another (Chapter 3), strengthening the control and audit framework and improving its implementation to safeguard public integrity (Chapter 4), consolidating the systematic implementation of enforcement mechanisms to effectively detect and sanction misconduct (Chapter 5), and strengthening transparency and integrity in public decision-making processes to protect them from risks of capture and undue influence by special interest groups (Chapter 6).
Assigning clear responsibilities to the actors in the integrity system is necessary to ensure co-operation, avoid overlaps and prevent fragmentation. Responsibilities for public integrity include developing, implementing, monitoring and evaluating integrity standards and tools, and are carried out by actors across the whole-of-government (legislative, executive and judicial) as well as across levels of government (national and sub-national). Responsibilities for public integrity are also found within each public sector organisation. All public officials at all levels of government are expected to carry out their duties in the public interest. To prevent fragmentation and overlap in the public integrity system, the OECD Recommendation of the Council on Public Integrity recommends that adherents “clarify institutional responsibilities across the public sector to strengthen the effectiveness of the public integrity system” (OECD, 2017[6]).
In Brazil, as in most countries, there are several public institutions that cover different functions of an integrity system. Table 1.1 outlines the main actors and their responsibilities across branches at the federal level. The challenge of reaching the autonomous states and municipalities in a federal State of continental dimensions like Brazil and ensuring some degree of coherence is addressed in a separate section below.
Source: OECD authors based on OECD (2021[9]), Strengthening Public Integrity in Brazil: Mainstreaming Integrity Policies in the Federal Executive Branch, https://doi.org/10.1787/a8cbb8fa-en.
The System of Integrity, Transparency and Access to Information of the Federal Public Administration (SITAI) is a significant step towards a unified and coherent integrity system but Brazil should consider transforming the Ethics Commissions into dedicated ethics units or advisors and transfer all sanctioning powers to the disciplinary regime
Mainstreaming integrity policies across ministries, agencies and functional units (horizontally) as well as across levels of government (vertically) to ensure their effective implementation throughout the public administration is a challenge in all countries. Gaps are often observed between what legislation or policies on integrity stipulate and what is being implemented in public institutions, preventing change in organisational cultures and in the behaviour of public officials.
Over the past years and recognising the existing challenges, Brazil has implemented several reforms aimed at improving its integrity system in the federal executive branch. The Office of the Comptroller General of the Union (Controladoria-Geral da União, CGU) is the internal control body of the federal government. Since its creation in 2001, it has been a core element of the federal government’s strategy to enhance integrity and prevent corruption in Brazil, leading integrity policies in the federal executive branch (OECD, 2012[10]). The CGU has several responsibilities related to public integrity, such as contributing to the framework for managing conflict of interest, preventing and fighting corruption, promoting integrity in the federal public administration and in the whole of society, supporting integrity risk management, internal control and audit, and disciplinary enforcement. The CGU also has ombudsman functions and promotes open government, social control and transparency (OECD, 2022[11]).
Nonetheless, when it comes to promoting integrity in the federal public administration with its 202 bodies and institutions, mainstreaming integrity policies to ensure their effective implementation remains an arduous task.
To overcome this challenge, Brazil undertook four major initiatives over the past two decades to reach out to the organisational level:
First, in 2007, Brazil established the Ethics Management System of the Federal Executive Branch (Sistema de Gestão da Ética do Poder Executivo Federal, SGEP) through Decree 6.029/2007, which is led by the Public Ethics Commission (Comissão de Ética Pública, CEP) and incorporates the Ethics Commissions (Comissões de Ética) at the institution level to support the mainstreaming and implementation of the Code of Professional Ethics of the Public Servant of the Federal Executive Branch.
Second, in 2017, Brazil introduced integrity programmes through Decree 9.203/2017. These programmes aim to promote the adoption of institutional measures and actions for preventing, detecting, punishing and remediating fraud and acts of corruption. The first mandatory step of an integrity programme is establishing units responsible for implementing an integrity programme within a public institution. These units were later called Integrity Management Units (Unidades de Gestão da Integridade, UGI) by Portaria CGU 1.089/2018.
Third, in 2021, Brazil established the Public Integrity System of the Federal Executive Branch (Sistema de Integridade Pública do Poder Executivo Federal, SIPEF), with the aim of further formalising and strengthening the normative basis for the integrity programmes and promoting integrity throughout the Brazilian federal executive (OECD, 2021[9]). The SIPEF was led by the CGU and incorporated the UGI in public institutions.
Finally, in 2023, Brazil replaced the SIPEF by creating the System of Integrity, Transparency and Access to Information of the Federal Public Administration (Sistema de Integridade, Transparência e Acesso à Informação da Administração Pública Federal, SITAI) by Decree 11.529/2023. The SITAI coexists with the SGEP. The SITAI expands the concept of integrity (Box 1.1) and the scope of institutional integrity programmes. The SITAI aims to co-ordinate activities related to integrity, transparency and access to information, as well as to establish standards, practices and measures related to these topics. The SITAI is led by the CGU and includes SITAI's Sectoral Units (Unidades Setoriais do SITAI) (herein “Sectoral Units”), in all public institutions of the direct, autarchic and foundational federal public administration (administração pública federal direta, autárquica e fundacional). The Sectoral Units replaced the UGI.
In addition to establishing the System of Integrity, Transparency and Access to Information of the Federal Public Administration (Sistema de Integridade, Transparência e Acesso à Informação da Administração Pública Federal, SITAI) by Decree 11.529/2023, Brazil incorporated additional changes via this reform.
Amongst others, Brazil expanded the concept and scope of institutional integrity programmes by including measures aimed at preventing and detecting breaches or disregards of rights, values and principles, such as discrimination of any kind, sexual harassment and moral harassment, that harm institutional trust, credibility and reputation. This broad approach to public integrity beyond anti-corruption is stated clearly in the objective of integrity programmes, which is to “promote compliance of conducts, transparency, prioritisation of public interest and an organisational culture aimed at delivering public value to society”.
Source: OECD based on information provided by Brazil.
To further strengthen the SITAI, Brazil launched in 2023 the Public Integrity Maturity Model (Modelo de Maturidade em Integridade Pública, MMIP). The MMIP provides a set of standards for SITAI’s public institutions to guide them through the key processes and elements needed to achieve a robust and effective integrity management, connected to the institution’s mission. The model is organised in a matrix that consists of five maturity levels (1 - Initial, 2 - Standardised, 3 - Integrated, 4 - Managed and 5 - Optimised) over three dimensions (Governance and organisational structure for integrity; Organisational capacity for integrity; Integrity management and performance). The Sectoral Units are expected to perform a self-assessment of their maturity level in public integrity and define steps for improvements. Institutions are not required to reach the highest maturity level, but to assess what is their adequate level of maturity based on their nature, size, complexity and the risk to which they are exposed. The CGU, through the Public Integrity Secretariat (Secretaria de Integridade Pública, SIP), is providing support by reviewing the answers and improvement actions to achieve the desired level of maturity. The objective is that 100% of SITAI institutions carry out the self-assessment and receive the SIP support in the next 3 years (until 2027).
With the latest reforms implemented in 2023, Brazil addressed some of the areas for improvement identified in the 2021 OECD report Strengthening Public Integrity in Brazil: Mainstreaming Integrity Policies in the Federal Executive Branch as barriers for mainstreaming integrity policies in the federal executive branch (OECD, 2021[9]). For instance, the CGU strengthened its internal capacities on public integrity by revising the responsibilities of the former Secretariat of Transparency and Corruption Prevention (STPC). By Decree 11.330/2023 (modified by Decree 11.389/2023), Brazil approved a new structure for the CGU, and the STPC was replaced by the Public Integrity Secretariat (SIP). The SIP is responsible for, among others, formulating, co-ordinating, promoting and supporting the implementation of plans, programmes and projects aimed at promoting transparency, open government, public integrity, ethical conduct and conflict-of-interest management.
The SIP consists of three directorates with clearly defined and complementary functions:
The Directorate of Public Integrity Promotion (Diretoria de Promoção de Integridade Pública, DIPIN), which is responsible for policies related to public integrity, including the implementation of public integrity programmes and management of conflict of interest.
The Directorate of Open Government and Transparency (Diretoria de Governo Aberto e Transparência, DGAT), which is responsible for policies related to open government and transparency, including managing the Open Data Policy of the federal executive branch and the National Open Government Policy.
The Directorate of Studies and Development of Public Integrity (Diretoria de Estudos e Desenvolvimento da Integridade Pública, DEIP), which is responsible for developing, supporting, co-ordinating and implementing projects, studies, research and actions for further developing public integrity, open government and transparency.
Moreover, Brazil has also developed initiatives to strengthen co-ordination between the SITAI and other integrity functions, including the ethics management function under the SGEP and its corresponding units (CEP and Ethics Commissions). For example, a co-operation agreement between the CGU and the CEP aims at promoting integrated actions, mutual support and exchange of experiences, information, technologies and methodologies. In addition, by Decree 11.529/2023, Brazil gave Sectoral Units the responsibility of co-ordinating with other institutional units responsible for integrity functions, such as the units within the systems of correction (de corregedoria), the ombudsman, or units responsible for internal control, ethics management, among others. Through the co-ordination with the other relevant units, the Sectoral Units obtain information required to understand the institution's specificities in view of structuring and monitoring integrity programmes, co-ordinating integrity risk's management and promoting guidance and training on matters related to the integrity programme.
This reform focusing on improving co-ordination across integrity functions contributes to overcome some challenges previously identified in the 2021 OECD report. For example, the fact that the new Sectoral Units are not providing advice on integrity issues to public officials could address the overlap of responsibilities between the SIPEF and the SGEP and reduce the misunderstanding and confusion among public officials with respect to where to turn to internally when seeking guidance on integrity. Nonetheless, it is advisable that the CGU and the CEP co-ordinate closely to raise awareness amongst public servants so that these know where to seek advice and make sure that the respective units are aware of the division of labour (see Chapter 2).
A finding from the 2021 OECD report that remains unaddressed concerns the organisation and the power of the Ethics Commissions to issue reprimands (censura) (OECD, 2021[9]). Indeed, the Ethics Commissions in Brazil suffer similar weaknesses as identified in other countries with comparable arrangements (OECD, 2017[12]; 2021[13]; 2019[14]):
First, the members of the Ethics Commissions in Brazil are selected on a temporary basis and often do not have time to develop specialised knowledge on integrity or establish trust-based relationships within their public entity. Furthermore, given that being a member of the Commission is an additional task without additional remuneration, the work on promoting ethics will often be only the second priority or depend strongly on the motivation of the selected individuals (OECD, 2021[9]).
Second, the Ethics Commissions in Brazil can issue reprimands (censura) in case of breaches to the Code of Professional Ethics of the Public Servant of the Federal Executive Branch. However, this can backfire as public officials may not feel comfortable seeking advice in case of doubts. The unit or person in charge of providing advice should not be involved in the investigation or sanctioning of integrity breaches, but rather be able to provide a safe haven where employees can speak up and ask questions without fearing direct repercussions (OECD, 2018[15]). In addition, there is some overlap between the Code of Professional Ethics and the legal framework regulating the civil service regime for all public officials in Brazil (Law 8.112/1990), which includes a list of duties and prohibitions, whose breach leads to disciplinary liability on top of the civil, criminal and administrative liability that may cumulatively apply (OECD, 2021[9]).
As such, Brazil should consider, on the one hand, transforming the ethics commissions into dedicated and professional ethics units or advisors that can build knowledge over time and become the visible and trusted safe haven in their public institutions. On the other hand, Brazil should consider aligning or adding the breaches of the Code of Professional Ethics to the list of duties and prohibitions included in Law 8.112/1190 and transfer the power to sanction those breaches to the CGU’s General Inspectorate for Administrative Discipline (Corregedoria-Geral da União) and, at entity level, the Federal Inspectorates (Corregedorias Federais) that are the institutions competent to deal with internal disciplinary cases (see Chapter 5).
The coherence and impact of national integrity policies could be improved by a more strategic co-ordination between the existing co-ordination platforms and the main integrity actors across and within branches
The OECD Recommendation of the Council on Public Integrity, in Principle 2, invites countries to promote mechanisms for horizontal and vertical co-operation between the different relevant public integrity actors, including, where possible, with and between subnational levels of government. Such co-operation mechanisms can be formal or informal and aim at supporting coherence, avoiding overlaps and gaps as well as sharing information and building on lessons learned from good practices.
To enable co-operation between the different integrity actors, co-ordination mechanisms are key. Such co-ordination mechanisms are usually established to lead the integrity reforms efforts in a country, in particular the development, implementation and monitoring of a national integrity strategy and policy. The co‑ordination mechanisms, such as councils, commissions or committees typically consist of several responsible government agencies and ministries. Beyond the executive, they sometimes involve representatives of the legislative and the judiciary branches and may involve civil society and the private sector. They are usually assisted by a technical unit supporting the work of the co-ordination mechanism. Table 1.2 provides an overview of some co-ordination arrangements in selected Latin American countries.
Sources: Based on OECD (2019[16]), La Integridad Pública en América Latina y el Caribe 2018-2019: De Gobiernos Reactivos a Estados Proactivos, https://doi.org/10.1787/ebd84d6d-es, updated with OECD (2021[17]), Public Integrity in Ecuador: Towards a National Integrity System, https://dx.doi.org/10.1787/9623672c-en; OECD (2021[18]), Follow up Report on the OECD Integrity Review of Argentina: Adopting a Strategic Approach to Integrity, https://web-archive.oecd.org/2021-07-02/593958-follow-up-report-on-the-oecd-integrity-review-of-argentina.pdf; OECD (2021[9]), Strengthening Public Integrity in Brazil: Mainstreaming Integrity Policies in the Federal Executive Branch, https://doi.org/10.1787/a8cbb8fa-en; Administrative Decision 592/2021 (Argentina) and Executive Decree 249 of 2024 (Ecuador).
In Brazil, there exist several co-ordination mechanisms between the different integrity actors. Some of these mechanisms include representatives of the three branches, different levels of government and civil society organisations, while others include integrity actors of the federal executive branch only.
The main co-ordination mechanisms are the following:
Brazil’s National Strategy against Corruption and Money Laundering (Estratégia Nacional de Combate à Corrupção e à Lavagem de Dinheiro, ENCCLA) is the main national policy co-ordination mechanism on integrity, anti-corruption and anti-money-laundering. It brings together almost 90 actors from the three branches and the Federal Office of the Public Prosecutor, the different levels of government (from the federal, state and sometimes even municipal level) to facilitate the exchange of good practices and the development and implementation of joint activities. Every year, representatives from civil society organisations, companies and academic institutions are invited to participate in the call for proposals for action that is undertaken to define the activities of the ENCCLA. In the 2024 edition, citizens were invited to submit their proposals for the first time. The ENCCLA Governance Council (Conselho de Governança) is a high-level, political and strategic group, including representatives from the following bodies: Vice-Presidency of the Republic, Ministry of Justice and Public Security, Office of the Attorney General of the Union (AGU), Central Bank of Brazil (BCB), CGU, Financial Intelligence Unit (COAF), National Council of Justice (CNJ), National Council of the Public Ministry (CNMP), Federal Police of Brazil (PF), Special Secretariat of Brazilian Federal Revenue Service (RFB) and the Federal Court of Accounts (Tribunal de Contas da União, TCU). Through the Council, Brazil defines its priority themes in the fight against corruption and money laundering.
The Anticorruption Inter-ministerial Committee (Comitê Interministerial de Combate à Corrupção, CICC), established by Decree 9.755/2019 and modified by Decree 12.294/2024, advises the Presidency on formulating, implementing, and evaluating integrity and anti-corruption policies. The CICC is co-ordinated by the CGU and is composed of the heads of the Ministry of Justice and Public Security, the Attorney General of the Union (AGU), the Central Bank of Brazil, the Ministry of Finance, the Ministry for Management and Innovation in Public Services, and the Ministry for Planning and Budget. A technical body assists the CICC and working groups to analyse specific issues can be formed.
The Transparency, Integrity and Anti-Corruption Council (Conselho de Transparência, Integridade e Combate à Corrupção, CTICC) was created by Decree 11.528/2023 replacing the former Council for Public Transparency and Fight against Corruption (Conselho de Transparência Pública e Combate à Corrupção, CTPCC). Led by the CGU, the CTICC debates and proposes measures to improve and promote policies and strategies on anti-corruption, social control, open government, transparency, integrity, amongst others. It also monitors and evaluates anti-corruption, transparency and integrity policies of the federal executive branch and encourages the exchange of experiences in these areas. The CTICC is composed of eleven institutional actors from the federal executive branch as well as 30 representatives of civil society organisations, substantially expanding the representation of civil society compared to the CTPCC. Within the scope of the CTICC, four working groups were created to discuss specific topics at more technical levels (i.e., open government, monitoring and evaluation of public policies, promotion of private integrity, and access to information and transparency).
In addition to these formal co-ordination platforms, Brazil recently implemented an informal mechanism to enable horizontal exchange and support on public integrity across public federal institutions. Indeed, the CGU created the Public Integrity Community (Comunidade de Integridade Pública, CIP) an online platform for integrity managers and integrity teams from the bodies and institutions of the federal executive branch, including staff working in the SITAI’s Sectoral Units or other units with integrity functions. The aim of this community is to promote greater interaction and exchange of lessons learnt, common challenges and good practices between those responsible for integrity policies at the institution level. Additionally, the community provides a repository for documents such as guides and manuals on integrity, where the CGU and other members can upload and share relevant information.
These mechanisms available in Brazil allow both core or non-core integrity actors to come together to define common objectives to ensure impact of integrity policies and enable communication and the sharing of information. Nonetheless, there are some opportunities to fine-tune and to further strengthen the existing co-ordination mechanisms and how they related to each other.
The ENCCLA brings together all relevant integrity actors, ensures legitimacy of the process as well as ownership and commitment from all institutions. However, it appears that it is not well known, neither by the general public nor by public officials. Therefore, the ENCCLA could improve its communication as the main co-ordination platform on anti-corruption and integrity in Brazil.
Moreover, discussions with stakeholders indicated that the ENCCLA is currently being perceived by the participating actors as mainly an informal discussion group for bringing up new ideas. It is not a strategic mechanism responsible for defining a vision for Brazil on public policies and solutions to combat corruption. This is also reflected in ENCCLA’s annual action plans, which provide a short-term vision rather than a strategic longer-term perspective for promoting integrity and fighting corruption. While such informal discussions have value, they are not leveraging the full strategic potential of the ENCCLA (see the section below).
Finally, it is key to ensure coherence between the ENCCLA, the CICC and the CTICC. Currently, such coherence seems to be mainly ensured by the participating actors themselves. While it may be difficult moving to a single co-ordination mechanism that includes all relevant actors and acknowledging the value added by the CICC and the CTICC, Brazil may want to analyse the possibility of creating institutionalised co-ordination spaces between the three platforms to avoid creating complexity, opacity and overlapping responsibilities. In particular for the recently created CTICC, it is important to ensure its coherence with the ENCCLA and the CICC. For instance, measures, policies and strategies proposed by the CTICC should be aligned with the priorities defined by the ENCCLA, translating such objectives into concrete actions to be developed within the federal executive branch.
The CGU could strengthen internal co-ordination among its units with responsibilities related to integrity and implementing an internal and external communication campaign to clarify the differences between CGU’s role in support and oversight
Co-ordination and co-operation are relevant not only among different institutional actors, but also at the institutional level among units that have different responsibilities in the integrity system. In Brazil, the CGU is a strong and important actor in several integrity-related areas such as conflict of interest, integrity risk management, internal control and audit, disciplinary enforcement, social control and transparency, amongst others. Responsibilities in these different areas are led and undertaken by different units within the CGU (Figure 1.6). For instance, the Federal Secretariat for Internal Control (Secretaria Federal de Controle Interno, SFC) leads the internal control system and is responsible for providing regulatory guidance and technical supervision for the bodies of such system. The General Inspectorate for Administrative Discipline (Corregedoria-Geral da União, CRG) is responsible for overseeing the implementation of the centralized federal executive branch disciplinary system. Because of its multiple responsibilities, internal co-ordination within CGU is as relevant as ensuring co-ordination across different institutions.
Source: OECD authors based on Government of Brazil (2023[19]), Decreto No. 11.330 de 1 de Janeiro de 2023, http://www.planalto.gov.br/ccivil_03/_ato2023-2026/2023/decreto/D11330.htm.
Moreover, as functions of prevention, control and disciplinary/administrative enforcement are within the same institution, it is key to prevent undermining the credibility and effectiveness of the preventive advisory role of the CGU carried out by different units, including the Public Integrity Secretariat (SIP). For instance, public officials could think that measures aimed at gathering information for preventive purposes, such as surveys and studies conducted by the Directorate of Studies and Development of Public Integrity, are in fact a way to obtain information for audits or administrative disciplinary process purposes (see Chapter 4), which could prevent them from sharing relevant information or open up. Additionally, discussions with key stakeholders undertaken during the fact-finding mission underscored that public officials struggle to differentiate between the advisory role and the control and audit role of the CGU.
To mitigate potential adverse effects on its preventive and policy advice function, the CGU could consider developing a strong communication strategy, not only internally, but also and especially targeting external stakeholders (i.e., federal public institutions), aimed at clarifying the separation that exists between CGU’s units and their different roles, as well as emphasising the preventive and advisory role undertaken by the SIP and other relevant units. Moreover, whenever different units within the CGU get together to implement specific initiatives, such as the Integrated Report on Climate Change, which combines auditing, social oversight and integrity assessments to inform public policy, it is vital to clearly communicate the scope and boundaries of such collaborations. While CGU units co-ordinate, collaborate and share information internally, it remains essential to reassure public institutions that their information is handled securely, used appropriately and that such collaboration does not compromise the confidentiality or trust necessary for effective preventive engagement.
A strategy for public integrity is essential for supporting a coherent and comprehensive integrity system. However, a strategy is not an end, but rather a means to an end. For instance, the process of strategy development is perhaps as important as the resulting strategy. An inclusive and rigorous process can help select relevant strategic objectives that are meaningful to citizens and businesses; prioritise and sequence actions in an open manner to address the most crucial integrity risks; and provide the necessary evidence for the interventions that are most cost-effective and likely to have the greatest impact. Strategies are also a way of demonstrating commitment and can be used to establish institutional responsibilities. If, however, strategies do not lead to visible gains – for example, due to inadequate implementation – they can at best become irrelevant and at worst erode public confidence in national authorities (OECD, 2020[7]).
The OECD Recommendation of the Council on Public Integrity states that adherents should “develop a strategic approach for the public sector that is based on evidence and aimed at mitigating public integrity risks” (OECD, 2017[6]) by:
“Setting strategic objectives and priorities for the public integrity system based on a risk-based approach to violations of public integrity standards, and that considers factors that contribute to effective public integrity policies.
Developing benchmarks and indicators and gathering credible and relevant data on the level of implementation, performance and overall effectiveness of the public integrity system” (OECD, 2017[6]).
In Brazil, there are currently two planning documents that are related to public integrity. First, the annual actions adopted every year by the Plenary of the National Strategy against Corruption and Money Laundering (Estratégia Nacional de Combate à Corrupção e à Lavagem de Dinheiro, ENCCLA). These annual actions are defined by the ENCCLA after a call for proposals to which representatives from public institutions, civil society organisations, private companies and academic institutions are invited to participate in. Table 1.3 shows the ten actions prioritised by the ENCCLA for 2025.
Note: Each of the actions includes a series of public institutions that should support the co-ordinator in the implementation of the actions (colaboradores) and that could be invited to participate in the implementation of the actions (convidados).
Source: ENCCLA (2024[20]), Ações de 2025, https://www.gov.br/mj/pt-br/assuntos/sua-protecao/lavagem-de-dinheiro/enccla/acoes-enccla.
Second, Brazil adopted the Integrity and Anti-corruption Plan 2025-2027 (Plano de Integridade e Combate à Corrupção) in December 2024. It was developed in a participative way, steered by the CGU and involving the CTICC, specialists from universities and research institutions, 100 private sector organisations and civil society. This new Integrity and Anti-corruption Plan 2025-2027 follows the Anti-Corruption Plan 2020-2025, which was adopted by the Anticorruption Inter-ministerial Committee (Comitê Interministerial de Combate à Corrupção, CICC) via Decree 9.755/2019. The Integrity and Anti-corruption Plan 2025-2027 defines 260 actions designed to tackle specific challenges faced by the federal public administration and to help strengthen integrity, prevent and combat corruption. The actions are organised in five thematic pillars: i) Quality control in the use of public resources, ii) Integrity in state–private sector relations, iii) Transparency and open government, iv) Combating corruption, and v) Institutional strengthening for integrity.
Brazil should ensure adequate monitoring and evaluation of the current Integrity and Anti-corruption Plan 2025-2027, while strengthening the evidence-based development and ensuring financial sustainability of future strategic frameworks
The OECD Public Integrity Indicator for Principle 3 (strategic framework) of the OECD Recommendation of the Council on Public Integrity provides insights into the strengths and areas of improvement of the Integrity and Anti-corruption Plan 2025-2027 (Figure 1.7).
Note: The OECD Public Integrity Indicators measure, amongst others, the quality of the strategic frameworks (Principle 3 of the OECD Recommendation of the Council on Public Integrity). The criteria for each indicator were established by the OECD Working Party of Senior Public Integrity Officials (SPIO), currently Working Party on Public Integrity and Anti-Corruption (PIAC). Brazil 2023 corresponds to the assessment conducted in 2023 of the Anti-Corruption Plan 2020-2025. Brazil 2025 corresponds to the assessment conducted in 2025 of the Anti-corruption Plan 2025-2027.
Source: OECD (n.d.[21]), OECD Public Integrity Indicators (database), https://oecd-public-integrity-indicators.org/ (accessed on 14 February 2025).
The Integrity and Anti-corruption Plan 2025-2027 performs well particularly on the sub-indicators “Coverage” and “Inclusiveness and consultation in practice”, showing improvements compared to the previous Anti-Corruption Plan 2020–2025. In terms of its coverage, the new Plan was adopted by the Office of the President and the Inter-Ministerial Anti-Corruption Committee, underscoring its political relevance and commitment at the highest level of government. It sets out strategic objectives aimed at mitigating integrity risks in five thematic axes: i) Quality control in the use of public resources, ii) Integrity in state-private sector relations, iii) Transparency and open government, iv) Combating corruption and v) Institutional strengthening for integrity. For instance, the Integrity and Anti-corruption Plan 2025-2027 sets the following strategic objectives (Objetivos Estratégicos, OE) to mitigate public integrity risks in the private sector:
OE2.1: Improve processes for obtaining registrations, authorisations, licenses and grants, aimed at increasing legal security, equality and predictability, reducing regulatory costs and spaces for arbitrariness in interactions between the State and the Private Sector.
OE2.2. Strengthen the integrity of regulatory bodies and partnerships, projects and agreements with companies and civil society organisations.
OE2.3. Strengthen incentives and collective action to promote private integrity and prevent corruption, aligning the scope of integrity programmes with the socio-environmental agenda and the promotion of human rights, and standardising evaluations.
OE2.4. Improve the regulatory framework and develop programmes and tools to prevent and monitor the risks of conflict of interest, strengthening social control (CGU, 2024[22]).
Regarding inclusiveness, the Plan was developed through a broad participatory process. It involved consultations with 53 federal institutions, 30 representatives from civil society, 50 academic experts, and around 100 private sector entities. Led by the CGU, the process featured inter-institutional dialogue as well as public roundtables and debates, engaging stakeholders from diverse regions and backgrounds. These exchanges helped refine the scope of the Plan’s strategic objectives and shaped the development of additional anti-corruption measures, contributing to a more grounded and inclusive approach.
Despite improvement in these areas, the Integrity and Anti-corruption Plan 2025-2027 falls short in the sub-indicators “Minimum content” when compared to the previous Anti-Corruption Plan 2020–2025. Indeed, although the new Plan refers to international legal instrument related to public integrity such as the United Nations and the Organisation of American States Anti-Corruption Conventions, it lacks a comprehensive situation analysis that includes clear identification of existing public integrity risks as well as outcome-level indicators to track progress against the fulfilment of its strategic objectives.
Moreover, both strategic documents assessed present weaknesses when it comes to the “evidence-based development”, “financial sustainability” and “evaluation practices” sub-indicators. In terms of an evidence-based development, the Integrity and Anti-Corruption Plan 2025–2027 was informed by an internal assessment that drew on multiple sources: international guidelines for anti-corruption strategy development (from UNDP, UNODC, and the G20), benchmarking with strategies from countries such as Mexico and Chile, academic research, international indices, and internal diagnostics conducted by CGU departments using audit reports and data dashboards. However, the Plan could benefit from greater use of additional empirical data, particularly from employee, household and business surveys. Furthermore, integrating analytical reports that not only assess public integrity risks but also provide concrete recommendations and set system-wide priorities would significantly strengthen the evidence base.
In terms of financial sustainability, both plans lack a centralised financial framework. Neither plan includes estimates of capital and operational expenditures, required to ensure consistent, long-term implementation. While specific activities are incorporated into the budgets of individual implementing bodies, the lack of a dedicated budget for the overall strategic framework raises concerns about the long-term viability of fulfilling planned commitments over.
As for evaluation practices, at the time of writing, no evaluation report for the Anti-Corruption Plan 2020‑2025 had been made publicly available. Moreover, the Integrity and Anti-Corruption Plan 2025–2027 does not include an end-of-term evaluation in its Action Plan, limiting accountability and opportunities for institutional learning.
Finally, regarding the sub-indicators “Adequacy of implementation plan” and “implementation rates”, these sub-indicators were measured based on the information available at the time of assessment, when no monitoring report was available, and no evaluation exercise had been conducted. The first monitoring report is due July 2025, after which the values of the sub-indictors will be updated on the OECD Public Integrity Indicators.
To address these weaknesses and strengthen future efforts, Brazil could consider the following actions:
Ensure sufficient resources and time are allocated for the first monitoring cycle of the Integrity and Anti-Corruption Plan 2025–2027. This process should actively involve relevant stakeholders and civil society and be supported by a communications strategy aimed at informing and engaging citizens and businesses on the outcomes of the monitoring exercise (see also next section).
Conduct a final evaluation of the Integrity and Anti-Corruption Plan 2025–2027 to promote learning, enhance accountability, and inform the design of the next strategic framework. Evaluation at the end of the cycle is key to understanding what worked, what did not work, and why.
Strengthen the next strategic framework through a risk-informed, evidence-based approach. This includes drawing on the analysis and recommendations of this Integrity Review, incorporating results from institutional self-assessments using the Public Integrity Maturity Model, and leveraging empirical data—particularly from employee, household, and business surveys—to shape priorities and interventions.
Develop and implement an effective monitoring mechanism for the next strategic framework, based on meaningful indicators and well-defined processes. Monitoring should support decision-making, foster honest dialogue around implementation challenges and be clearly distinguished from compliance enforcement.
Create and deliver a robust communication plan to support the implementation of the next strategic framework. Ongoing engagement with internal and external stakeholders, as well as transparent communication with the public, can foster trust, strengthen credibility, and build momentum for future integrity and anti-corruption efforts (see also next section).
Include detailed financial estimates for each proposed project and action in the next strategic framework. This will enhance planning, ensure financial feasibility, and support long-term implementation.
Establish evaluation mechanisms from the outset of the next strategic framework. These can be conducted internally or outsourced, depending on the purpose and available resources. Internal evaluations may promote organisational learning and offer cost-effective, timely insights, though they may face challenges around objectivity and staff capacity. External evaluations, while potentially more impartial, may require more time and budget. Table 1.4 outlines the advantages and disadvantages of each approach.
Brazil could leverage the strategic potential of the ENCCLA to drive and sustain national co-ordination involving the whole-of-society and to promote a long-term vision for promoting integrity across branches
As emphasised before, Brazil could consider leveraging the full strategic potential of the ENCCLA. The annual actions currently defined by the new ENCCLA Governance Council (Conselho de Governança) bring together proposals from public institutions, civil society organisations, private companies, academic institutions and, more recently, from citizens. This whole of society approach aligns with the OECD Recommendation of the Council on Public Integrity which recognises the relevance of conducting inclusive and transparent strategy development processes to demonstrate commitment, gather relevant evidence and help setting meaningful objectives.
However, the timeframe for implementing such actions, which is currently one year, is likely to be too short to allow a strategic perspective and ensure continuity of efforts. While there is a possibility to extend some actions beyond a year, the current focus on one-year activities could bias the selection of these activities towards those that allow short-term results without reflecting on the medium and long-term challenges related to anti-corruption and integrity. Indeed, reforms and actions aimed at producing cultural and behavioural changes such as integrity policies need time for implementation and even more for showing impact. Therefore, integrity and anti-corruption strategies usually cover a time span between 4-5 years, allowing to foresee short-term (1 year), mid-term (2-5 years), and long-term (5-10 years) measures (CoE, 2013[23]).
Moreover, considering the many responsible institutional actors and stakeholders under the Brazilian integrity system, having a medium- or long-term vision (2-5 years or more) could help effectively co-ordinate existing regulatory and institutional arrangements and foster synergies and co-ordinating efforts from relevant integrity actors. This would contribute to improve the coherence of anti-corruption and integrity efforts in Brazil.
As such, to further improve its strategic relevance, Brazil could mandate the ENCCLA Governance Council with developing a multi-year vision and strategic approach to public integrity in the country. As ENCCLA truly involves all relevant actors across powers and the whole of society, the vision could help aligning other current and future anti-corruption policies and plans from the executive (like the new Integrity and Anti-corruption Plan 2025-2027) and other initiatives. For example, such a strategic vision could also include, as a shared goal, that the Legislative and Judiciary branches, or even States and Municipalities (see section below) develop their own Anti-corruption Plans, similar to the plans developed by and for the federal executive. Together, this could ensure a coherent, co-ordinated and strategic approach to promoting public integrity under the umbrella of the ENCCLA but respecting the autonomies and specificities of the other branches and levels of government (Figure 1.8). Examples from other jurisdictions could inspire Brazil to further develop its own longer-term vision that goes beyond the executive branch (Box 1.2).
Costa Rica
Costa Rica’s National Strategy for Integrity and Prevention of Corruption (Estrategia Nacional de Integridad y Prevención de la Corrupción, ENIPC) aims at establishing a strategic framework for action by the State and all actors in society, with a clear horizon, emphasising prevention, the promotion of integrity and the creation of a culture of legality that minimises acts of corruption. The ENIPC defined five priority areas: 1. Governance in the fight against corruption, 2. Management of human talent to fight corruption, 3. Promotion of citizen participation and control, 4. Management of corruption risks in public-private interaction, and 5. Access to Information of public interest and accountability. The ENIPC has a ten-year implementation period (2021-2030) that includes short, medium and long-term actions.
Chile
Chile's National Public Integrity Strategy (Estrategia Nacional de Integridad Pública, ENIP) is a participatory, evidence-based log-term policy with a proactive approach aimed at improving standards of transparency, integrity and anti-corruption in the country. The ENIP has objectives in five thematic areas: 1. civil service, 2. public resources, 3. transparency, 4. politics and 5. private sector, with a ten‑year horizon (2023-2033). Additionally, each of these thematic areas is accompanied by an action plan, consisting of more than 200 measures to be implemented in the short, medium and long term.
Sources: Government of Chile (2023[24]), Resolución 1096 Exenta Aprueba Estrategia Nacional de Integridad Pública 2023-2033, https://www.bcn.cl/leychile/navegar?idNorma=1199509; Government of Costa Rica (2021[25]), Estrategia Nacional de Integridad y Prevención de la Corrupción, https://www.enipc.co.cr/wp-content/uploads/2021/08/CR-INFORME-ENIPC-FINAL-julio-06.pdf.
An empowered ENCCLA could play a role in monitoring, evaluating and communicating future integrity and anti-corruption strategies and plans in Brazil
To properly gauge the effectiveness of an integrity strategy, monitoring and evaluation arrangements should be specified. A monitoring and evaluation system, based on the planning, ensures that integrity policies follow an evidence-based strategic approach enabling continuous learning (OECD, 2017[26]). Evidence from monitoring and evaluation can also enhance targeting and steering of current and future policies and help to detect challenges and problems in a policy’s implementation process (OECD, 2017[26]).
Monitoring and evaluation are different but complementary practices. Monitoring is a continuous function that consists in collecting and analysing information on a policy’s direct and intermediary outputs. Monitoring allows assessing the progress and achievement of policy objectives against set targets to identify and lift implementation bottlenecks. Monitoring informs operational decision-making. Evaluation, in turn, focuses on a policy’s mid- and longer-term outcomes. Evaluation refers to the structured and objective assessment of the design, implementation and/or results of a future, ongoing or completed public intervention. In this sense, while monitoring is often a continuous function, evaluation is a measurement endeavour specifically set-up to investigate a certain policy’s effect with a causal attribution (OECD, 2017[26]). Evaluations therefore inform strategic decision-making and could follow the six OECD-DAC evaluation criteria, adapted to integrity and anti-corruption strategies (Box 1.3).
As a policy evaluation, the goal is not to assess whether every single activity of a given strategy has been implemented and to what degree, but rather to look at whether the strategy has been able to contribute to the stated goals and objectives.
As such, while the level of implementation is a relevant dimension to look at, an evaluation goes beyond the implementation and achievement of outputs to investigate the change to which the strategy has contributed and to what extend the desired results have been achieved and how (OECD, 2017[26]).
Therefore, the methodology to evaluate the achievement of the envisaged results and the objectives of an integrity and anti-corruption strategy could consider the following dimensions:
Relevance: Was the strategy designed to respond to country needs and priorities? To what extend are the objectives still valid? Do the stakeholders feel that they “own” the strategy, that they are an active part of it (sense of ownership)?
Coherence: Was the strategy coherent with other governance reforms and policies in relevant key areas (external coherence)? Were the different objectives and activities of the strategy designed in a way to reinforce one another and create synergies and were the activities relevant to contribute to the achievement of the results and the objectives (internal coherence)?
Effectiveness: To what degree has the strategy achieved the envisaged goals and implemented the activities (level of implementation)? What were the major factors influencing the achievement or non-achievement of the objectives?
Efficiency: How well were the available resources used to achieve the objectives of the strategy? Were the objectives achieved on time?
Impact: What differences did strategy make? What were the positive changes and could some unintended consequences be observed?
Sustainability: How did the strategy build on earlier efforts to prevent and combat corruption and how likely are the implemented changes to last over time?
Note: The criteria follow the OECD-DAC evaluation criteria.
Source: Adapted from OECD (2021[27]), Lobbying in the 21st Century: Transparency, Integrity and Access, https://doi.org/10.1787/c6d8eff8-en.
The composition of the ENCCLA and its potential role in providing a strategic umbrella to which the federal executive, the legislative and the judiciary could align their own plans, would make it the ideal centralised platform for monitoring, evaluating and communicating integrity and anti-corruption measures as promoted by the different plans. In fact, the participation of civil society organisations, private companies, academia and citizens could add credibility, contribute to ensure continuity independent from the government elected and further improve social accountability of anti-corruption efforts in the country.
The benefit of monitoring and evaluation for management, policy design, and learning depends significantly on how process and results are communicated (OECD, 2017[26]). Communication with internal and external stakeholders enables accountability, increases the credibility of integrity efforts and stimulates future action (OECD, 2017[26]). Additionally, considering the sensitivity of integrity-related information, many risks can be countered in continuous dialogue with stakeholders and by avoiding communication of abstract information without context.
Currently, in Brazil, the communication of the results of integrity planning documents is limited to specific measures. When it comes to the annual actions of the ENCCLA, every year in the Plenary Session of the ENCCLA, responsible institutions present the results of the implementation of last year’s actions to the members of the ENCCLA. These sessions are livestreamed in official channels of the Brazilian government on YouTube. Moreover, a summary of the results is published on the website of the ENCLAA, together with videos of the opening and closing plenary sessions of the corresponding year.
Despite these and other one-off communication measures, Brazil does not have communication strategies for the results of the implementation of existing integrity planning documents to a wider group of internal and external stakeholders that would maximise the effectiveness of the communication. Brazil could design and implement communication strategies that focus on the achievements of ENCCLA’s actions, the past Anti-Corruption Plan 2020-2025, the new Integrity and Anti-corruption Plan 2025-2027 and future plans. The communication of achievements needs to be based on the data from monitoring activities and evaluations’ results, to avoid promoting cynicism, weakening trust in government and disconnecting citizens from constructive political engagement. Brazil could consider international good practices for designing such communication planning documents (Box 1.4).
When designing a communication strategy, there are several elements that countries should considered to maximise its effectiveness. Below, some general good practices for designing a communication strategy:
Carry out a context analysis: To be able to communicate successfully, it is indispensable to have a clear understanding of the issues that are being addressed, based on evidence rather than impressions.
Define the main objectives of the communication strategy: Based on the context, define the objectives of the communication strategy. This could be done by responding to the following questions: “What is the change or impact you are trying to make? What does success look like?”
Identify the target audiences: Who are you targeting? Whose life do you want to change?
Carefully design the messages to avoid negative impact: Messages should be designed carefully in order to avoid negative or unexpected consequences. For instance, raising the issue of corruption and the costs related to it may lead to undesired consequences. In a context where corruption is already very present in the public debate and media, awareness raising campaigns on corruption may increase the already high awareness for an existing problem and thereby confirming the impression that corruption is widespread, leading to inaction or increasing corruption.
Identify relevant channels that can be used to distribute the messages: When identifying the relevant channels, it may be relevant to use the following guiding questions: How do you engage with our audience? Where are they most receptive? Which format will be more engaging for them? Channels may include television, print media, the website, blogs, social media, and specific networks and partnerships.
Identify the resources and skills needed for the implementation of the strategy.
Assess the results of the communication campaigns and the impact of the strategy: Assess the impact of communications strategy to fine-tune and improve, within a continuous circle of implementation, evaluation and adaptation.
Source: OECD (2023[28]), A Strategic Approach to Public Integrity in Hungary: The 2023-25 National Anti-Corruption Strategy and Action Plan, https://doi.org/10.1787/a5461405-en.
Subnational governments have important responsibilities and provide a wide range of public services involving high exposure to the public, which comes along with risks and opportunities. As such, subnational governments should have in place adequate integrity systems and policies to respond to integrity risks in their local contexts. Indeed, to effectively build a culture of integrity in the public sector, it is key to reach all levels of government (i.e., states and municipalities).
However, when some laws apply to the federal level only, especially in federal countries like Brazil, there may be a certain risk of loopholes if subnational levels of government fail to address a cross-cutting issue such as corruption through an adequate legal and institutional framework. In turn, looking only at the federal level may hide the complexity and diversity of contexts often encountered at the subnational levels, which may require specific laws. Indeed, ensuring a high-quality institutional framework at all levels of government can only be achieved if countries take into consideration the diversity of local needs and the particularities of lower levels of government (Rodrigo, Allio and Andres-Amo, 2009[29]). This may apply even more so in a country of the dimensions of Brazil.
Brazil is divided into 26 states, a Federal District (Brasilia) and 5.570 municipalities. Both states and municipalities have elected legislative bodies and count with elected governors and mayors heading, respectively, the local administrations. The 26 states have their own constitution while the Federal District is governed by an Organic Law (Lei Orgânica do Distrito Federal). The municipalities are federal institutions on their own, at the same level as the states. They are governed by an organic law, which must comply with federal and state constitutions. Despite the significant differences in size as well as social and economic indicators, all municipalities enjoy the same legal status. According to data from the 2022 Demographic Census carried out by the Brazilian Institute of Geography and Statistics (Instituto Brasileiro de Geografia e Estatística, IBGE), 15 municipalities (0.27% of municipalities) have more than 1 million inhabitants and are home to 20% of Brazil’s population and 2.494 municipalities (44.78% of municipalities) have less than 10.000 inhabitants and are home to 6.3% of the country’s population (IBGE, 2023[30]).
Moreover, as in all OECD countries, responsibilities for decentralised policies in Brazil –healthcare, education, social security, welfare, agriculture and food distribution, housing and sanitation, among others– are shared among all levels of government (OECD, 2020[31]). Each level is autonomous in legislating and providing services, as long as these do not conflict with the powers exclusively provided or legislated by the Federal Union and there are different multi-level arrangements available to ensure an effective co‑ordination in the case of decentralised policies (Box 1.5).
Brazil’s Federal Constitution explicitly reserves certain powers for the federal government while providing broad and general mandates to states and municipal governments. States are granted “all powers not otherwise prohibited to them” by the Constitution, whereas municipalities are assigned "the power to legislate over subjects of local interest" and to provide "services of local public interest" (Constitution of the Federative Republic of Brazil, Art. 21-24). However, the Constitution also delineates a number of public policy areas where responsibilities are concurrently held by the federal government and the states, leading to overlaps among levels of governments. These areas include health, social protection, culture and sport, environment protection, and the protection of historic and cultural heritage (Constitution of the Federative Republic of Brazil, Article 24). Moreover, federal law usually sets general conditions that can be further detailed and regulated by the states and municipalities.
Multi-level arrangements are particularly crucial for ensuring effective co-ordination in the case of decentralised policies, which are highly fragmented in Brazil both from a vertical and horizontal perspective. On the horizontal level, Brazilian institutions tend to work mostly in-silo, meaning that each sectoral ministry has its own territorial vision and does not necessarily co-ordinate with other ministries. The result is that each ministry, state, agency or publicly owned enterprise pursues its own strategy and policy objectives, creating potential policy coverage and objective gaps.
Regarding the vertical dimension, two forms of multi-level arrangements are particularly common in Brazil –contract agreements and federative pacts:
Agreements (convenios) and contracts are regularly used for co-operation among public institutions in Brazil. These standard contracts make it possible to clarify the responsibilities of each level of government: on the one hand, the co-ordination, regulation and financing roles of central government, and on the other the tasks to be assumed by the municipality.
Federative pacts (pactos federativos) are sets of constitutional provisions established by sectoral ministries with leadership from the president’s office, generally after consultation and negotiation with subnational governments. These bodies draw up a set of objectives, roles, responsibilities and financing arrangements in a specific policy area, for each level of government. When a sector is entitled to discretionary transfers, the federal ministry can make those transfers conditional on adhesion to the pact. These pacts may be wide-ranging in scope; one example is the Health Pact passed in 2006. Currently, discussions are mainly oriented towards a federative pact to set up new rules overseeing federal, state and municipal budgets.
Some ministries have developed legal mechanisms on their own to ensure vertical co-ordination. This is the case of the health sector, which is highly decentralised to state and municipalities. The Ministry of Health co-ordinates policy design and implementation through tripartite and bipartite commissions, including health representatives from the three levels of government that meet once a month.
Source: OECD (2020[31]), Auditing Decentralised Policies in Brazil: Collaborative and Evidence-Based Approaches for Better Outcomes, https://doi.org/10.1787/30023307-en.
Brazil could include in the overarching legal framework for public integrity of the federal executive branch an obligation for states, the Federal District and municipalities to develop specific integrity rules
Considering the federal structure of Brazil and given the autonomy of subnational governments, integrity policies and standards enacted at the federal level do not apply to the states, the Federal District and municipalities. For instance, neither Law 12.813/2013, also known as the Conflict-of-Interest Law, which sets the framework for identifying and managing conflict of interest, nor the Code of Professional Ethics for the Civilian Public Servants, which provides integrity principles and standards that should be followed by public servants while conducting public duties, cover public officials working in public institutions at subnational levels. Moreover, subnational public institutions are not expected to establish Sectoral Unit nor to develop or implement integrity programmes (programas de integridade) and integrity plans (planos de Integridade) as the SITAI only covers public institutions at the federal level. Finally, subnational governments are not required to draft their own laws on public integrity or similar frameworks as a basis for subnational integrity systems.
As such, Brazil could consider including an obligation requiring all states, the Federal District and municipalities to develop their own specific rules on public integrity, as a solid step towards strengthening public integrity throughout the country. This could be included in the revised overarching legal framework for public integrity of the Executive Branch recommended in Chapter 2. While allowing to tailor these specific laws and regulations to their own needs, they should be developed along similar lines to the Public Integrity System of the SITAI and the legal framework for public integrity of the federal executive branch (Chapter 2), ensuring thereby co-ordination and coherence across the different levels of government. This would guarantee some minimum shared standards while respecting the independence of the subnational authorities and responding to the specificities of the subnational level. Examples from other jurisdictions could be used as an inspiration (Box 1.6).
Moreover, states, the Federal District and municipalities could develop their own Anti-corruption Plans considering the country’s long term strategic vision recommended to be developed by the ENCCLA in the previous section. In practice, this means that states, the Federal District and municipalities could propose concrete actions at the subnational level aligned to the country’s long term strategic vision by the ENCCLA, in which the sub-national level is also represented. Such a responsibility could be included within the overarching legal framework for public integrity, ensuring that all subnational governments contribute to achieving Brazil’s long-term strategic vision in the integrity and anti-corruption field.
In Mexico, the General Law of the National Anticorruption System (Sistema Nacional Anticorrupción, NACS), which came into force on 18 July 2016, is the cornerstone piece of legislation that establishes the institutional and governance arrangements for the country’s Anticorruption System and outlines objectives and required activities. Having the character of a general law, it applies to subnational levels. In this sense, the creation of local anti-corruption systems is embodied in the NACS General Law as local systems are considered to be members of the national system (article 7 of the General Law of the NACS). Moreover, the NACS General Law requires states to establish their own systems along similar lines and to pass the relevant legislation in line with the general laws within one year (article 36).
Mexico’s NACS- and package of complementary reforms- marked a turning point in the country’s approach to anti-corruption policies as it (i) addresses fragmentation in policies and develops a more comprehensive and coherent approach to integrity, and (ii) prevents “implementation gaps” by improving co-ordination both vertically and horizontally between levels of government, and particularly by bringing states under the remit of the System.
Source: OECD (2017[12]), OECD Integrity Review of Mexico: Taking a Stronger Stance Against Corruption, https://dx.doi.org/10.1787/9789264273207-en.
Considering the federal structure of government, Brazil could build on national and international good practices to set incentives for coherent integrity policies at the state and municipal levels
The Brazilian federal public administration has implemented initiatives to encourage subnational governments to adopt some of the regulations on public integrity implemented at the federal level. For instance, the programme Transparency and Integrity in Municipalities and States (Transparência e Integridade em Municípios e Estados, TIME Brasil) and the National Programme for the Prevention of Corruption (Programa Nacional de Prevenção à Corrupção, PNPC), a joint initiative by the CGU and the TCU (Box 1.7). Moreover, some subnational governments have voluntarily adapted and implemented integrity initiatives developed at the federal level within their own administrations with the aim of establishing coherent integrity systems and promoting a culture of public integrity (Box 1.7).
States and municipalities -to a lesser extent- have started implementing integrity initiatives following some of the developments of the federal administration. Examples include the following:
The state of Rio Grande do Norte launched the Integrity and Compliance Programme (Programa de Integridade e Compliance), a structured set of guidelines, policies, procedures and practices adopted to promote a culture of ethics, compliance, transparency and responsibility that applies to bodies and entities of the State Public Administration, except for public companies (empresas públicas) and mixed-capital companies.
The state of Minas Gerais established the Minas Gerais Integrity Promotion Plan (Plano Mineiro de Promoção da Integridade, PMPI), providing that each body or institution of the Public Administration of the State Executive Branch would be responsible for the creation and dissemination of specific integrity plans (planos de integridade).
Through Decree 67.683/2023, the state of São Paulo established the State Integrity Promotion Plan (Plano Estadual de Promoção de Integridade) and requested all bodies and institutions of the São Paulo Public Administration to create and implement integrity programmes (programas de integridade) and integrity management units (unidades de gestão de integridade).
National Corruption Prevention Programme (PNPC)
The PNPC is an initiative created in 2020 by the TCU and supported by the CGU. The purpose of the PNPC is to encourage the implementation of a set of good national and international integrity practices at all levels of the public administration. To support the implementation of the programme, the TCU created a self-service platform – e-Prevention System, which is available to public organisations for a self- assessment, via questionnaire. Based on the diagnosis resulting from the self-assessment, public organisations are encouraged to implement the practices recommended by the PNPC as a way of improving the management and governance of corruption and fraud prevention mechanisms. Currently, around 16.000 public organisations are registered in the e-Prevention System, and approximately 9.500 of them have already completed the questionnaire and, therefore, have diagnoses.
Transparency and Integrity in Municipalities and States (TIME Brasil)
TIME Brasil is an initiative of the CGU to support and guide states, municipalities and the Federal District in adopting policies to prevent corruption, promote integrity and open government, and foster transparency, access to information and social participation. Participation in TIME Brasil is voluntary and is carried out through the preparation of a self-diagnosis and a subsequent action plan by the state or municipality. The CGU, through its regional comptrollers of the union in the states, reviews the proposed action plan, monitors the development of the actions, offers training (both to public officials and representatives from civil society), and evaluates the progress achieved. Currently, 130 states and municipalities have adhered to TIME Brasil.
Sources: Interviews with stakeholders and Government of Canada (2015[32]), Apparent Conflict of Interest, https://www.canada.ca/en/treasury-board-secretariat/services/values-ethics/conflict-interest-post-employment/apparent-conflict-interest.html; Legislative Assembly of the State of São Paulo (2023[33]), Decreto Nº 67.683, de 03 de maio de 2023, https://www.al.sp.gov.br/repositorio/legislacao/decreto/2023/decreto-67683-03.05.2023.html.
Although the interest of subnational governments to adhere to existing initiatives and adapt integrity policies developed at the federal level to their own administrations continues to increase, additional efforts are needed to reach out to all states and municipalities and support them in their efforts to establish coherent integrity systems.
To that end, Brazil could consider building on national (and international) good practices to set additional incentives for the design and implementation of coherent integrity policies at the state and municipal levels. The CGU, as the leading institution of the executive branch at the federal level for integrity policies, and the TCU, as the leading institution of the PNPC, could consider prioritising the following activities in both direct and indirect support to Brazilian states and municipalities:
Further promoting the adherence to existing initiatives such as the PNPC and TIME Brasil by means of raising awareness about the benefits of adhering to the available initiatives, providing new incentives, and further engaging states and municipalities in the fight against corruption. First, the CGU and the TCU could consider developing a partnership with the ENCCLA to scale up the PNPC and the TIME Brasil initiatives. As the ENCCLA includes representatives from states and municipalities, this could help further promote these initiatives at subnational levels and ensure co‑ordination among relevant actors. Second, the CGU and the TCU could consider further exploiting the state public management control networks (redes estaduais de controle da gestão pública) of the PNPC and the regional comptrollers of the union in the states to mobilise political commitment of governors and mayors as well as to facilitate dialogue and co-ordination in those contexts. Third, the CGU and the TCU could consider providing additional incentives - such as public recognition and more in-depth analysis of integrity policies in place - for those states and municipalities that effectively champion the promotion of integrity. For instance, inspired by national good practices such as Pro-Ethics (Pro Ética) and the Transparent Brazil Map (Mapa Brasil Transparente) (Figure 1.9), the CGU and the TCU could consider developing a Pro-Ethical Municipality seal and Pro-Ethical State seal as well as a graphical representation of the states and municipalities that have adhered to the TIME Brasil and the PNPC. Those states and municipalities willing to participate in the Pro-Ethics seal would benefit from a more in-depth analysis of current practices in the area of integrity that could further support their improvement, while the CGU and the TCU could identify good practices across the country to be shared among subnational governments and even internationally.
Note: This figure is a graphic representation of the results of the 360° Evaluation second edition conducted by the CGU to verify the degree of compliance in subnational entities with the provisions of the Law on Access to Information (elements of passive and active transparency). At the left: results of the evaluation of all Brazilian states; in the middle: results of the evaluation of the participating municipalities of the State of Minas Geris; at the right: scale of results.
Source: CGU (2020[34]), Mapa Brasil Transparente, https://mbt.cgu.gov.br/publico/avaliacao/escala_brasil_transparente/66.
Supporting and building capacities of integrity staff working in states and municipalities: While capacity building programmes for general staff working at the subnational level should be organised and managed at the state and municipal levels, with the support of other federal institutions such as the TCU, the National School of Public Administration (Escola Nacional de Administração Pública, ENAP) and the Ministry of Management and Innovation in Public Services (Ministério da Gestão e Inovação em Serviços Públicos), the CGU could consider setting up a train-the-trainer programme for public integrity officials working in states and municipalities. Such programme could target integrity actors in states and municipalities and then be autonomously replicated internally to ensure a minimum coherent set of skills and tasks while adapting to local particularities. These could be carried out in training events by state, led by the regional comptrollers in the states, but also through supporting guidelines, e-learning material and activities. Moreover, the CGU could consider developing differentiated criteria for integrity at municipal level responding to the different needs, sizes and capacities. Similar initiatives have been implemented in the past by the CGU and could be considered as new efforts to further build capacity of integrity staff working in states and municipalities are designed and implemented. For instance, from 2017 to 2019, the CGU published a series of guidelines known as "Coleção Município Transparente" for municipalities, to enhance transparency and prevention of corruption. More recently, in 2023, the CGU launched the LAi for All Programme (Lai para todos), aimed at strengthening knowledge about the law in states, municipalities and society. As part of this programme, the CGU developed a series of materials to support states and municipalities.
Further promoting dialogue and exchange between states and municipalities: Although contexts, needs and capacities for developing integrity systems may differ from state to state and municipality to municipality, a mechanism, e.g., an online platform or periodical meetings, could help to ensure coherence, exchange of experiences and lessons learnt, mutual learning of failed attempts and support in the design and implementation of integrity systems. Moreover, these mechanisms could also help identify and ensure the public recognition of those individuals or institutions that championed the promotion of integrity through innovative ideas. To that end, the CGU could consider creating spaces for interaction among members within the online platforms of the PNPC and the TIME Brasil initiatives, as well as creating a National Network on Public Integrity to promote collaboration and exchange on issues related to public integrity among states and municipalities. The CGU could draw inspiration from the National Network on Digital Government (Rede Nacional de Governo Digital, rede.gov.br), which currently includes 27 states and 1250 municipalities and aims at promoting collaboration, dialogue, co-ordination and the creation of innovative initiatives related to digital government in the public sector, or the recently created National Network for Transparency and Access to Information (RedeLAI), whose aim is to promote national access to information through a collaborative environment between bodies and institutions from the federal government, the states, the Federal District and the municipalities.
Improving co-ordination and coherence at the federal level
The System of Integrity, Transparency and Access to Information of the Federal Public Administration (SITAI) is a significant step towards a unified and coherent integrity system but Brazil should consider transforming the Ethics Commissions into dedicated ethics units or advisors and transfer all sanctioning powers to the disciplinary regime.
The coherence and impact of national integrity policies could be improved by a more strategic co-ordination between the existing co-ordination platforms and the main integrity actors across and within branches.
The CGU could strengthen internal co-ordination among its units with responsibilities related to integrity and implementing an internal and external communication campaign to clarify the differences between CGU’s role in support and oversight.
Strengthening the long-term strategic approach to public integrity
Brazil should ensure adequate monitoring and evaluation of the current Integrity and Anti‑corruption Plan 2025-2027, while strengthening the evidence-based development and ensuring financial sustainability of future strategic frameworks.
Brazil could leverage the strategic potential of the ENCCLA to drive and sustain national co‑ordination involving the whole-of-society and to promote a long-term vision for promoting integrity across branches.
An empowered ENCCLA could play a role in monitoring, evaluating and communicating future integrity and anti-corruption strategies and plans in Brazil.
Enabling public integrity at the subnational levels
Brazil could include in the overarching legal framework for public integrity of the federal executive branch an obligation for states, the Federal District and municipalities to develop specific integrity rules.
Considering the federal structure of government, Brazil could build on national and international good practices to set incentives for coherent integrity policies at the state and municipal levels.
References
[8] Brinkerhoff, D. (2000), “Assessing political will for anti‐corruption efforts: An analytic framework”, Public Administration and Development, Vol. 20, pp. 239-252, http://onlinelibrary.wiley.com/doi/10.1002/1099-162X(200008)20:3%3C239::AID-PAD138%3E3.0.CO;2-3/abstract (accessed on 5 January 2015).
[22] CGU (2024), Plano de Integridade e Combate à Corrupção 2025-2027, Comptroller General of Brazil, https://www.gov.br/cgu/pt-br/plano-de-integridade-e-combate-a-corrupcao-2025-2027/documentos#documentos (accessed on 16 June 2025).
[34] CGU (2020), Mapa Brasil Transparente, Comptroller General of Brazil, https://mbt.cgu.gov.br/publico/avaliacao/escala_brasil_transparente/66 (accessed on 22 February 2024).
[23] CoE (2013), Designing and Implementing Anti-Corruption Policies - Handbook, Council of Europe, https://rm.coe.int/16806d8ad7 (accessed on 22 February 2024).
[3] Corporación Latinobarómetro (2023), Homepage, https://www.latinobarometro.org/latOnline.jsp (accessed on 14 February 2025).
[4] Corporación Latinobarómetro (2021), Latinobarómetro 2020, https://www.latinobarometro.org/latinobarometro-2020.
[20] ENCCLA (2024), Ações de 2025, National Strategy to Combat Corruption and Money Laundering, https://www.gov.br/mj/pt-br/assuntos/sua-protecao/lavagem-de-dinheiro/enccla/acoes-enccla (accessed on 7 June 2025).
[19] Government of Brazil (2023), Decreto No. 11.330 de 1 de Janeiro de 2023, http://www.planalto.gov.br/ccivil_03/_ato2023-2026/2023/decreto/D11330.htm (accessed on 22 February 2024).
[32] Government of Canada (2015), Apparent Conflict of Interest, https://www.canada.ca/en/treasury-board-secretariat/services/values-ethics/conflict-interest-post-employment/apparent-conflict-interest.html (accessed on 16 February 2025).
[24] Government of Chile (2023), Resolución 1096 Exenta Aprueba Estrategia Nacional de Integridad Pública 2023-2033, https://www.bcn.cl/leychile/navegar?idNorma=1199509 (accessed on 22 February 2024).
[25] Government of Costa Rica (2021), Estrategia Nacional de Integridad y Prevención de la Corrupción, https://www.enipc.co.cr/wp-content/uploads/2021/08/CR-INFORME-ENIPC-FINAL-julio-06.pdf (accessed on 22 February 2024).
[30] IBGE (2023), Censo Demográfico 2022, Brazilian Institute of Geography and Statistics, https://sidra.ibge.gov.br/tabela/4709 (accessed on 22 January 2024).
[5] IDEA (2021), Global State of Democracy Report 2021 Building Resilience in a Pandemic Era, International Institute for Democracy and Electoral Assistance, https://www.idea.int/gsod-2021/global-report (accessed on 18 Janaury 2024).
[33] Legislative Assembly of the State of São Paulo (2023), Decreto Nº 67.683, de 03 de maio de 2023, https://www.al.sp.gov.br/repositorio/legislacao/decreto/2023/decreto-67683-03.05.2023.html (accessed on 22 February 2024).
[28] OECD (2023), A Strategic Approach to Public Integrity in Hungary: The 2023-25 National Anti-Corruption Strategy and Action Plan, OECD Publishing, Paris, https://doi.org/10.1787/a5461405-en.
[2] OECD (2023), Drivers of Trust in Public Institutions in Brazil, Building Trust in Public Institutions, OECD Publishing, Paris, https://doi.org/10.1787/fb0e1896-en.
[11] OECD (2022), Open Government Review of Brazil : Towards an Integrated Open Government Agenda, OECD Public Governance Reviews, OECD Publishing, Paris, https://doi.org/10.1787/3f9009d4-en.
[18] OECD (2021), Follow up Report on the OECD Integrity Review of Argentina: Adopting a Strategic Approach to Integrity, OECD, Paris, https://web-archive.oecd.org/2021-07-02/593958-follow-up-report-on-the-oecd-integrity-review-of-argentina.pdf (accessed on 15 March 2022).
[27] OECD (2021), Lobbying in the 21st Century: Transparency, Integrity and Access, OECD Publishing, Paris, https://doi.org/10.1787/c6d8eff8-en.
[13] OECD (2021), OECD Integrity Review of the State of Mexico: Enabling a Culture of Integrity, OECD Public Governance Reviews, OECD Publishing, Paris, https://dx.doi.org/10.1787/daee206e-en.
[17] OECD (2021), Public Integrity in Ecuador: Towards a National Integrity System, OECD Public Governance Reviews, OECD Publishing, Paris, https://dx.doi.org/10.1787/9623672c-en.
[9] OECD (2021), Strengthening Public Integrity in Brazil: Mainstreaming Integrity Policies in the Federal Executive Branch, OECD Public Governance Reviews, OECD Publishing, Paris, https://doi.org/10.1787/a8cbb8fa-en.
[31] OECD (2020), Auditing Decentralised Policies in Brazil: Collaborative and Evidence-Based Approaches for Better Outcomes, OECD Public Governance Reviews, OECD Publishing, Paris, https://doi.org/10.1787/30023307-en.
[7] OECD (2020), OECD Public Integrity Handbook, OECD Publishing, Paris, https://doi.org/10.1787/ac8ed8e8-en.
[14] OECD (2019), Follow up Report on the OECD Integrity Review of Mexico: Responding to Citizens’ Expectations, OECD, Paris, https://web-archive.oecd.org/2020-11-17/503424-follow-up-integrity-review-mexico.pdf (accessed on 19 August 2021).
[16] OECD (2019), La Integridad Pública en América Latina y el Caribe 2018-2019: De Gobiernos Reactivos a Estados Proactivos, Estudios de la OCDE sobre Gobernanza Pública, OECD Publishing, Paris, https://doi.org/10.1787/ebd84d6d-es.
[15] OECD (2018), Behavioural Insights for Public Integrity: Harnessing the Human Factor to Counter Corruption, OECD Public Governance Reviews, OECD Publishing, Paris, https://doi.org/10.1787/9789264297067-en.
[26] OECD (2017), “Monitoring and evaluating integrity policies”, Working Party of Senior Public Integrity Officials, GOV/PGC/INT(2017)4, OECD, Paris.
[12] OECD (2017), OECD Integrity Review of Mexico: Taking a Stronger Stance Against Corruption, OECD Public Governance Reviews, OECD Publishing, Paris, https://dx.doi.org/10.1787/9789264273207-en.
[6] OECD (2017), Recommendation of the Council on Public Integrity, OECD Paris, https://legalinstruments.oecd.org/en/instruments/OECD-LEGAL-0435.
[10] OECD (2012), OECD Integrity Review of Brazil: Managing Risks for a Cleaner Public Service, OECD Public Governance Reviews, OECD Publishing, Paris, https://doi.org/10.1787/9789264119321-en.
[21] OECD (n.d.), OECD Public Integrity Indicators (database), OECD, Paris, https://oecd-public-integrity-indicators.org/ (accessed on 14 February 2025).
[29] Rodrigo, D., L. Allio and P. Andres-Amo (2009), “Multi-Level Regulatory Governance: Policies, Institutions and Tools for Regulatory Quality and Policy Coherence”, OECD Working Papers on Public Governance, No. 13, OECD Publishing, Paris, https://doi.org/10.1787/224074617147.
[1] Transparency International (2025), Corruption Perceptions Index 2024, https://www.transparency.org/en/cpi/2024 (accessed on 14 February 2025).