This chapter explores Brazil's efforts to cultivate a culture of integrity in the whole-of-society. It examines the country’s main integrity issues, drawing on perception surveys that illustrate the impact of corruption in society. This chapter encourages Brazil to provide further guidance and support to the private sector in embedding cultures of integrity within companies. In addition, it invites civil society organisations to reinforce their co-responsibility in promoting public integrity. Finally, it highlights the need to raise awareness in society on the shared responsibility for upholding public integrity and to mainstream public integrity into the curriculum at lower and upper secondary levels.
OECD Integrity Review of Brazil 2025
Consolidating Progress on Public Integrity
Abstract
Public integrity is not just an issue for the public sector: individuals, civil society organisations and companies also active members of society and have a shared responsibility as their actions can harm or foster public integrity (OECD, 2020[1]). They interact with public officials, play a critical role in setting the public agenda and influence public decision-making- all of which must align with public integrity values.
There are many ways in which actions by individuals, civil society organisations and companies can harm public integrity. When citizens pay bribes, evade taxes, seek or receive fraudulent social benefits or exploit public services without paying, they unfairly take government resources and erode interpersonal trust. Companies that evade their taxes, offer bribes for procurement contracts or provide illegal funds to political parties threaten the legitimacy of the government, exacerbate inequality and weaken citizens’ trust in institutions. When civil society organisations engage in corrupt practices or are used to implement strategies to spread misinformation and manipulate public opinion, they distort decision-making in favour of a select few and undermine trust in democratic institutions.
In this sense, a “whole-of- society” approach to public integrity requires companies, civil society organisations and individuals to ensure that their engagement with the public sector respects the shared ethical norms, principles, and values of society (OECD, 2020[1]). The 2017 OECD Recommendation of the Council on Public Integrity stipulates that “governments can promote a whole-of-society culture of public integrity, partnering with the private sector, civil society and individuals”, in particular through (OECD, 2017[2]):
Recognising in the public integrity system the role of the private sector, civil society, and individuals in respecting public integrity values in their interactions with the public sector, in particular by encouraging the private sector, civil society and individuals to uphold those values as a shared responsibility.
Engaging relevant stakeholders in the development, regular update, and implementation of the public integrity system.
Raising awareness in society of the benefits of public integrity and reducing tolerance of violations of public integrity standards and carrying out, where appropriate, campaigns to promote civic education on public integrity, among individuals and particularly in schools.
Engaging the private sector and civil society on the complementary benefits to public integrity that arise from upholding integrity in business and in non-profit activities, sharing and building on, lessons learned from good practices.
In Brazil, corruption is a major concern for citizens. According to the 2019 Global Corruption Barometer for Latin America and the Caribbean, 90% of Brazilians consider corruption in government to be a problem in their country, compared to a regional average of 85% (Transparency International, 2019[3]). Moreover, Brazilians have a high perception of corruption among public officials and private sector representatives, a sentiment that worsened from 2017 to 2019 (Figure 3.1). In 2019, more than half of respondents mentioned that “most or all” officials in the presidential office (57%), senators and members of the House of Representatives (63%), local government councillors (62%), and business executives (50%) are corrupt (Figure 3.1).
In addition, according to the Gallup World Poll, in 2024, 72% of Brazilians surveyed responded that corruption is widespread throughout the government, compared to 68% in 2023, 69% in 2022 and 71% in 2021 (Gallup, 2025[4]). The perception of widespread corruption is pervasive and extends into a lack of trust in politicians and the wider governmental system: only 32.3%, 29.6% and 18.3% of Brazilians expressed having “high” or “some confidence” in the government, in the Congress and in the political parties, respectively (Corporación Latinobarómetro, 2023[5]).
Note: Figure corresponds to the percentage of respondents who think that most or all people in these institutions are corrupt.
Sources: Transparency International (n.d.[6]), Global Corruption Barometer, https://www.transparency.org/en/gcb.
Corruption is also a concern for companies doing business in Brazil. Although the most recent data on private sector’s perception of corruption is captured in the 2009 World Bank Enterprise Survey, more recent discussions with key stakeholders underscored that there is a general distrust among companies towards the government and a general fear of being associated with the public sector, especially after the Car Wash Operation.
Beyond perceptions, Brazilians experience corruption in their daily life. For instance, the 2019 Global Corruption Barometer for Latin America and the Caribbean revealed that 11% of public service users in Brazil had paid a bribe in the 12 months prior to the survey, and 40% had been offered bribes in exchange for their vote during the same period (Transparency International, 2019[3]).
In light of these challenges, actively engaging citizens, civil society organisations and business in promoting public integrity is key to mitigating corruption risks and cultivating a culture of integrity in the whole-of-society. Brazil recognises the importance of engaging the whole-of-society in fostering integrity. This is reflected in its Anti-Corruption Plan 2020–2025 (Plano Anticorrupção), which stated that “promoting integrity, both in the public and private sectors, is essential to effectively fight corruption” (CGU, 2020, p. 26[7]). It is also embedded in the recently launched Integrity and Anti-Corruption Plan 2025-2027, which highlights integrity in State-private sector relations as one of its five thematic pillars, while “societal involvement” is identified as one of the four key principles guiding the plan’s development. Additionally, Brazil has been developing and implementing several initiatives in this area led by the Office of the Comptroller General of the Union (Controladoria-Geral da União, CGU) and the National Strategy to Combat Corruption and Money Laundering (Estratégia Nacional de Combate à Corrupção e à Lavagem de Dinheiro, ENCCLA).
As a means of informing further actions by Brazil aimed at strengthening a whole-of-society approach to public integrity, this chapter assesses current integrity initiatives – mainly implemented by the CGU – targeting business, civil society organisations and citizens. Based on this analysis, the chapter provides tailored recommendations to promote greater ownership and recognition amongst Brazilian non-state stakeholder groups of their shared responsibility in cultivating public integrity as well as to raise awareness of the benefits of public integrity for society as a whole.
Addressing corruption and integrity challenges in the private sector is beneficial, not only for the business sector itself, but for governments and society as a whole. Indeed, when firms evade taxes, offer bribes, or engage in procurement fraud, they distort markets, reduce competitiveness and discourage investments and trade, affecting negatively the business environment and more broadly, society’s wellbeing. However, the private sector can also be a force for good, by advancing corporate integrity reforms and reshaping the global integrity landscape. In this regard, a whole-of-society approach to public integrity requires governments partnering with the private sector to ensure their actions respect and follow the shared ethical norms, principles and values of society (OECD, 2020[1]).
There are different mechanisms for government to encourage integrity within the private sector. First, governments can support integrity in companies by ensuring the relevant legislation is in place. This not only covers anticorruption measures, but also provisions regarding responsible business conduct and integrity in companies. Integrity in companies is concerned with ensuring that common values and integrity standards are upheld when companies interact with government, in particular through their lobbying and political financing practices (i.e., “responsible influence”), as well as in the movement of people between the public and private sectors (i.e., “revolving doors”) (for more information on this issue see Chapter 6).
Second, governments can also encourage a cultural change and promote integrity in the private sector through a combination of sanctions and incentive regimes (OECD, 2020[1]). On one hand, while effective, proportionate and dissuasive sanctions can discourage private companies from acting against the public administration On the other hand, incentives can be used to recognise companies’ commitment to corruption prevention efforts and corporate integrity policies. Incentives can range from preferential access to government benefits and business opportunities, penalty mitigation, and public acknowledgement of a company’s commitment to combating corruption (OECD/UN, 2024[8]).
Brazil is aware of the importance of engaging the private sector in promoting public integrity and has planned and undertaken several initiatives to do so (OECD, 2023[9]). Brazil’s commitment to encouraging integrity in the private sector was recently renewed in 2023, when the Government created the Secretariat of Private Integrity (Secretária de Integridade Privada) within the Office of the Comptroller General of the Union (Controladoria-Geral da União, CGU). The Secretariat of Private Integrity is responsible for leading several activities related to leniency agreements, accountability of legal entities and integrity of private institutions (Government of Brazil, 2023[10]).
Additionally, Brazil has been advancing efforts to support integrity practices in private companies, applying a broad range of tools including voluntary integrity programmes, penalty mitigation, and public acknowledgement of companies’ commitment to good integrity practices. For instance:
The CGU created the Pro-Ethics (Pró-Ética) programme, an initiative that promotes the adoption of integrity policies by private companies. Through this programme, companies may voluntarily seek validation from the CGU in recognition of their anti-corruption and integrity efforts by means of a “Pro-Ethics Business” seal. This programme has been implemented since 2010, and in 2022-2023 alone (the most recent edition), nearly 300 private companies participated by filling out the assessment questionnaire, and more than 250 companies were admitted and evaluated by the CGU. Subsequently 84 companies were approved by the Pro-Ethics Committee (Comité Pró-Ética) and received the “Pro-Etichs Business” seal (CGU, 2024[11]).
Recently, the CGU established the Brazilian Pact for Corporate Integrity (Pacto Brasil pela Integridade Empresarial), which encourages companies operating in the country to voluntarily make a public commitment to corporate integrity by signing an adherence agreement and conducting a self-assessment. This initiative is supported by the Sustainable Social and Economic Development Council) of the Presidency of the Republic, among other institutional supporters (such as ministries, unions, and industry federations). The objectives of the Brazilian Pact are: 1) to enhance the promotion of corporate integrity; 2) to disseminate knowledge on the subject; and 3) to raise awareness among companies about the importance of the topic. Approximately 150 companies have already joined the Brazilian Pact and completed their self-assessments. This initiative, in addition to addressing topics related to anti-corruption compliance, also encompasses environmental, labour, and human rights aspects.
In 2023, the CGU created the National Network for the Promotion of Private Integrity (Rede Nacional de Promoção da Integridade Privada), an initiative aimed at enhancing institutional co‑operation among federal, state, and municipal bodies. Its primary objectives are to foster and standardise the application of the Anti-Corruption Law (Law 12.846 of 2013, which provides for the administrative and civil liability of legal entities for acts committed against the public administration, whether domestic or foreign), as well as to promote transparency, ethics, and corporate integrity.
However, additional efforts could be implemented to ensure existing initiatives are effectively developed and implemented by the private sector to address the organisational culture issues that lead to integrity violations instead of becoming simple tick-the-box exercises to avoid stronger sanctions. Moreover, the lack of information on business integrity practices and challenges limits the impact of CGU’s initiatives on business integrity. The following recommendations aim at supporting the Government of Brazil in promoting a culture of integrity in the private sector.
The CGU, together with business organisations, could provide further guidance and support to companies on establishing their integrity programmes to effectively create a culture of integrity in the private sector
Establishing a coherent legislative framework for public integrity is an essential step to support integrity in private companies. In Brazil, the Anti-Corruption Law (Lei Anticorrupção widely known as the ‘Clean Company Law, Federal Law 12.846 of 2013) establishes a system of civil and administrative liabilities for legal entities bribing public officials, and prohibits other conducts such as fraud in public tenders, manipulation of contracts, obstruction of investigations and other illicit acts practiced against both national and foreign public administrations (OECD, 2022[12]). Under this Law, legal entities responsible for harmful acts provided for in the Anti-Corruption Law may be imposed administrative fines of up to 20% of their gross sales (article 6), depending on a series of criteria that include having in place corporate compliance programmes as a mitigating factor for companies facing sanctions in case of violations of the Anti‑Corruption Law (article 7) (OECD, 2022[12]). The Anti-Corruption Law also empowers the CGU to initiate administrative processes to hold legal entities involved in cases of corruption and mismanagement of federal public resources accountable (article 8), and to conclude leniency agreements (acordos de leniência) with companies involved in corruption that effectively collaborate with investigations and the administrative process (article 16).
Moreover, the Government issued an implementing decree (Decree 11.129/2022) providing additional information for the effective implementation of the Anti-Corruption Law, including on what can be considered as an effective corporate compliance programme under article 7 of the Anti-Corruption Law. Article 56 provides a clear definition of an integrity programme for a legal entity and defines its objectives, which include fostering and maintaining a culture of integrity in the organisational environment (Government of Brazil, 2022[13]). Decree 11.129/2022 takes a risk-based approach, with article 56 further requiring companies to develop integrity programmes based on the characteristics and specific risks of their activities and provides further guidance regarding the parameters that would be considered when evaluating legal entities’ integrity programmes for the definition and application of sanctions.
Additionally, the CGU has provided further guidance on the adoption of integrity programmes by elaborating and publishing the Private Integrity Programme Collection1 consisting of a series of manuals, guides, and other publications, including the Practical Manual for Evaluating Integrity Programmes in PAR. Such publications cover several topics including the implementation of integrity programmes by entities in the private sector, the evaluation of integrity programmes in leniency agreements and in administrative procedures on violations of the Anti-Corruption Law, integrity best practices for Small and Medium Enterprises (SMEs) and Brazilian companies abroad, among others. This approach, given the level of details and transparency it provides for companies as been identified as a good practice in the Phase 4 report by the OECD Working Group on Bribery (OECD, 2023[9]).
The CGU has made considerable efforts to provide general guidance to support companies in developing integrity programmes. As a complement to the efforts and mechanisms already in place, the CGU could take further action, together with business organisations, to encourage Brazilian companies, particularly SMEs, to adopt adequate ethics and compliance measures. This could be done by organising awareness-raising and training activities on the importance of having integrity programmes in place and to support companies in their efforts to establish such programmes, including organising forums and roundtables (see the example of France in Box 3.1). Both the recently created Brazilian Pact for Corporate Integrity and the National Network for the Promotion of Private Integrity could serve as appropriate platforms to raise awareness and build capacities on developing and implementing integrity programmes.
Moreover, the CGU could consider developing an online platform to facilitate the exchange of good practices and examples on integrity among businesses of different sizes, fostering peer-to-peer learning (see the example of Argentina in Box 3.1). This platform could be integrated into the website of the Brazilian Pact for Corporate Integrity aligning with the initiative’s second objective: disseminating knowledge on integrity. Such an approach would enable the sharing of good practices and examples beyond the companies that have joined the Brazilian Pact, potentially inspiring additional companies to join this initiative, Finally, the CGU could continue current efforts aimed at providing greater support for SMEs to adopt clear and effective integrity programmes and policies. For instance, the joint efforts between the CGU and the Brazilian Service for Support to Micro and Small Enterprises (Serviço Brasileiro de Apoio às Micro e Pequenas Empresas) to provide greater support to SMEs via updating relevant guidelines and providing tailored-made capacity-building activities could continue.
Business integrity guidance in Argentina
The Anticorruption Office plays a central role in Argentina’s integrity system. The Anticorruption Office is responsible for strengthening ethics and integrity in the national public administration and the private sector, through preventive and transparency policies and investigation of corruption.
Recently, the Anticorruption Office developed the collaborative platform Registry of Integrity and Transparency (Registro de Integridad y Transparencia) for companies and public institutions. The purpose of this platform is to promote integrity across private companies and public institutions by means of sharing good practices and guidance for upholding public integrity. The platform consists of a registry – where companies make their commitment to the integrity agenda visible – and a training platform –where tools, materials and training resources are provided by the Anticorruption Office to support private companies and public institutions in learning about and promoting integrity. Materials published by the Anticorruption Office include guidance for the development of different components of the integrity programmes, including on encouraging high-level commitment to public integrity, risk management, training and capacity building, amongst others.
AFA’s guidance to support business integrity in France
The French Anti-Corruption Agency (AFA) provides assistance and advisory services to businesses to support them in implementing anticorruption and compliance measures, particularly as established in the anti-corruption law called the “Loi Sapin II pour la transparence de la vie économique” (“Sapin II”). In particular, AFA activities on the matter include:
Development of recommendations and practical guides for companies. This includes the French Anti-corruption Agency guidelines, the Practical guide on anti-corruption due diligence for mergers and acquisitions, the Gifts and hospitality policy in private and public sector corporations and non-profits, and the Practical guide on preventing conflict of interest in the private sector. All publications aimed at private sector actors have been subject to a public consultation process.
Awareness-raising and training activities for various types of private actors. This includes general presentations of anti-corruption issues and the French anti-corruption legal framework, technical workshops organised for professionals (e.g. on internal control systems), workshops organised together with professional organisations and associations, specialised training courses aimed at both beginner and advanced audiences, helpdesk-style legal and technical support in response to questions from private sector actors regarding corruption prevention and compliance programmes. These actions are aimed at strengthening the private sector’s ownership in the fight against corruption and the challenges it faces when navigating the French anti-corruption framework.
Tailored, on-demand support to private sector actors in the implementation of anti-corruption compliance programmes on a voluntarily basis. These individual support actions for companies are provided depending on the private sector actor’s technical needs and the required scope of the support.
Note: To access Argentina’s business integrity guidelines: https://www.rite.gob.ar/herramientas, the 2020 French anti-corruption agency guidelines: https://www.agence-francaise-anticorruption.gouv.fr/files/files/French%20AC%20Agency%20Guidelines%20.pdf, other AFA’s guidelines: https://www.agence-francaise-anticorruption.gouv.fr/fr/guides-et-chartes.
Sources: AFA (n.d.[14]), Guides et Fiches pratiques, https://www.agence-francaise-anticorruption.gouv.fr/fr/guides-et-fiches-pratiques; OECD (2022[15]), OECD Integrity Review of the Slovak Republic: Delivering Effective Public Integrity Policies, https://doi.org/10.1787/45bd4657-en.
The CGU could encourage companies to include responsible engagement standards in their integrity programmes, including through specific guidelines for business
In the private sector, there is a growing call for companies to become more transparent with society and go beyond strictly legal requirements on lobbying activities. For example, companies concentrated in the fossil fuel and energy-intensive sectors have been facing criticism for using climate commitments or sustainability policies as a smoke screen to display a public image of climate responsibility while lobbying to delay or block binding climate policies, or providing donations to candidates who are against strengthening climate-related regulations (OECD, 2022[16]).
As a result, large institutional investors are becoming increasingly aware of the financial and non-financial risks of lobbying malpractice and are demanding increased transparency on corporate political engagement practices. For example, the number of shareholder proposals concerning corporate political engagement disclosures has increased significantly over the last decade, to become one of the most popular types of shareholder resolutions that are put to a vote, in particular in the area of climate change lobbying (OECD, 2022[16]).
Considering that lobbyists and companies are under increasing scrutiny, they need a clearer integrity framework for engaging with the policy-making process in a way that does not raise concerns over integrity and inclusiveness. As such, the Government of Brazil could promote responsible engagement and self-regulation from the private sector in this area. To do so, the CGU could encourage companies and organisations to include responsible engagement standards in their integrity programmes, and to formalise internal processes that address the full scope of corporate and trade association conduct in the policy-making process to reassure the public and institutional investors that lobbying is done professionally and with high standards. Similarly, the CGU and the Pro-Ethics Committee could consider taking into account the adoption of responsible engagement standards in companies’ integrity programmes as part of the criteria for public recognition of integrity programmes considered innovative and effective via the Pro-Ethics programme.
In particular, the CGU could include responsible engagement standards in its guidance on business integrity programmes that makes part of the Private Integrity Programme Collection. In particular, responsible engagement standards could cover issues such as ensuring accuracy and plurality of views, promoting transparency in the funding of research organisations and think tanks, managing and preventing conflict of interest in the research process and ensuring that staff assigned to conduct lobbying activities have a good understanding of transparent, responsible, and thus professional interaction. These standards could also specify disclosures that may involve social responsibility considerations regarding a company's involvement in public policymaking and lobbying (Box 3.2).
Creation of a responsible engagement / lobbying policy and explaining how lobbying and influence activities align with public commitments to support goals on climate change and other shared sustainability challenges.
Specifying the role of board members, top management and senior executives in regularly monitoring the implementation of the standards. The board should be in charge of monitoring and overseeing the company’s lobbying/influence activities and how they align with broader corporate sustainability pledges. Board members and management can also be held personally liable for violations of the rules.
Establishing adequate due diligence measures to ensure that the positions and practices of those who lobby on a company’s behalf (industry and lobby associations) do not run afoul of the organisation’s values and commitments. This may include:
processes to regularly review membership of trade associations and third-party organisations and identify misalignment
transparency on memberships of trade associations or other third-party organisations that may engage in political activities (charities, foundations, PACs, fundraising organisations)
the level of funding and engagement in these organisations (e.g., representation on the board, funding beyond membership, participation in specific committees or working groups)
actions taken when the positions and lobbying practices of these organisations do not align with the company’s own lobbying practices and commitments.
Mainstreaming these standards across all business lines – including government affairs and sustainability functions to create a coherent position across the company’s government affairs activities and CSR/ESG branches. These policies should ensure that CSR/ESG teams have sufficient access to information on a company’s lobbying activities.
Include lobbying/influence related risks in risk management strategies and disclose information about them.
Adopting transparency and integrity measures on the hiring of former public officials.
Integrity training on conducting lobbying activities. Provision of integrity related training to company board members, management and lobbyists on lobbying responsibly is an effective way to spread knowledge about the key principles that should guide responsible engagement.
Incentivising responsible engagement within companies. For example, linking the promotion and implementation of the company’s integrity policy / lobbying policies to performance-related bonuses and remuneration.
Whistle-blower protection. Developing internal reporting mechanisms and providing protection to whistle-blowers who report violations of lobbying related rules or the companies’ own lobbying policies play an essential role in enhancing companies’ integrity framework.
Reporting initiatives. Some companies can adhere to reporting initiatives to disclose information on their lobbying activities.
Sources: Based on OECD (2022[16]), “Regulating corporate political engagement: Trends, challenges and the role for investors”, https://doi.org/10.1787/8c5615fe-en; OECD (2011[17]), OECD Guidelines for Multinational Enterprises, https://web-archive.oecd.org/2023-06-27/95735-48004323.pdf; OECD (2017[18]), “Responsible business conduct in Kazakhstan and the OECD Guidelines for Multinational Enterprises”, https://doi.org/10.1787/9789264269606-12-en.
The CGU could encourage high-risk sectors to develop sector-oriented initiatives to acknowledge and further encourage companies’ commitment to public integrity
The role of ensuring clear guidance also encompasses taking into consideration the specific risks associated with the sectors that are most exposed to corruption. Indeed, integrity risks vary by sector, and therefore it is critical that public sector institutions calibrate their guidance, tools and approaches to their specific objectives, environment and contexts (OECD, 2020[1]). In this sense, tailoring existing initiatives to the specific risks and challenges of high-risk sectors – e.g., health, infrastructure, education, etc. – could help further strengthening Brazil’s whole-of-society approach to public integrity.
To that end, the CGU could consider encouraging high-risk sectors to develop sector-oriented initiatives to acknowledge and further encourage companies’ commitment to public integrity. This could be done based on broader initiatives designed, implemented and tested at a national level by the CGU, and that can be considered as good practices because of their good results. This would ensure the development of sector-oriented initiatives based on an overarching framework that has been proven to work while allowing to respond to the specificities of high-risk sectors. For instance, the Ministry of Agriculture and Livestock (Ministério da Agricultura e Pecuária, MAPA) has already started to develop specific initiatives to acknowledge and further encourage agribusiness companies’ commitment to public integrity, based on the logic of existing CGU’s initiatives (Box 3.3).
In Brazil, the Ministry of Agriculture and Livestock (Ministério da Agricultura e Pecuária, MAPA) has developed a series of initiatives to strengthen public integrity within the Ministry (internal axis) and more broadly within the agricultural sector (external axis). These initiatives are included in the Integrity Plan (Plano de Integridade) of the MAPA.
As part of the initiatives developed to encourage public integrity within the agricultural sector (external axis), the MAPA created the MAPA Seal of Integrity, “More Integrity” (Selo de Integridade do MAPA, “Mais Integridade”). The aim of this initiative is to promote, recognize and reward integrity practices by agribusiness companies from the perspective of social responsibility, sustainability, ethics and integrity (commitment to mitigating practices of fraud, bribery and corruption). Through this initiative, agribusiness companies and cooperatives may voluntarily seek certification from the MAPA throughout different progressive stages, ending up with the “Pro-Ethics Business” seal of the CGU, if the company manages to obtain the previous two seals.
Note: Green seal: First award. Yellow seal: Renewal. “Pro-Ethics Business” seal: Awarded by the CGU when a company has obtained the previous two seals.
Source: Brazilian Ministry of Agriculture and Livestock (n.d.[19]), Selo Mais Integridade, https://www.gov.br/agricultura/pt-br/assuntos/integridade/selo-mais-integridade.
A Management Committee (Comitê Gestor) is responsible for approving the final result of the technical assessments carried out by the MAPA Integrity Area on the documentation sent by companies and cooperatives interested in obtaining the MAPA Seal of Integrity. The Management Committee consists of private institutions nationwide linked to agribusiness and the following public bodies: the MAPA, the Brazilian Trade and Investment Promotion Agency (Agência Brasileira de Promoção de Exportações e Investimentos), the Brazilian Agricultural Research Corporation (Empresa Brasileira de Pesquisa Agropecuária), the National Supply Company (Companhia Nacional de Abastecimento), and the CGU.
Source: Meetings during the fact-finding mission conducted in June 2022; Brazilian Ministry of Agriculture and Livestock (n.d.[19]), Selo Mais Integridade, https://www.gov.br/agricultura/pt-br/assuntos/integridade/selo-mais-integridade.
The CGU could further strengthen the evidence base on business integrity practices and challenges
To develop effective legislation and policy measures for business integrity, governments need reliable and up-to-date information and data that allows them to understand companies’ integrity risks, motivations for corrupt behaviour, difficulties in implementing integrity programmes, amongst others. Information and data on the specific business integrity practices, needs and challenges for various categories of companies, i.e., depending on their size and sector, as well as on the quality of anti-corruption and compliance programmes is also insightful to develop prospective policies and further guidelines. Lastly, information and data also allow to measure progress over time and to identify where additional attention and resources should be spent.
In Brazil, there is currently limited information about business integrity practices, needs and challenges. Since 2020, the CGU has been collecting relevant data based on the editions of Pro-Ethics programme. This data has been used to improve future editions of the initiative and define the areas to be analysed. However, this information is limited to the companies participating in the Pro-Ethics programme, excluding those that may have less interest and initiatives in integrity. Moreover, in 2022, the CGU launched the System for Assessing and Monitoring Integrity Programmes (Sistema de Avaliacão e Monitoramento de Programas de Integridade). This system was used to manage the 2022-2023 edition of the Pro-Ethics programme and is expected to be used to manage the evaluations of companies’ integrity programmes under Laws 12.846 of 2013 and 14.133 of 2021 (on general bidding and contracting rules for the direct, autarchic and foundational public organisations of the Union, states, the Federal District and municipalities).
Similarly, the motivations for corrupt behaviour could be better understood, especially considering that comprehensive studies on business integrity have not been conducted in recent years – for instance, the only World Bank Enterprise Survey conducted in Brazil was published in 2009. Furthermore, it is not yet well-documented what companies of different sizes and sectors expect in terms of government support for business integrity and their specific difficulties in designing and implementing integrity programmes.
Given its prominent role in cultivating public integrity in Brazil, the CGU could take the lead in strengthening the evidence base on business integrity practices and challenges. The CGU has already taken some steps in this direction by collecting and systematising information on companies participating in recent editions of the Pro-Ethics programme. However, further efforts could be undertaken in alignment with the responsibilities of the Secretariat of Private Integrity, which include promoting, co-ordinating and encouraging studies and research aimed at generating and disseminating knowledge in the areas of leniency agreements, responsibility of private entities and private integrity (Government of Brazil, 2023[10]). For instance, the experience of the French Anti-Corruption Agency in implementing a national survey on business integrity may serve as an example of a government-led survey implemented to better understand the challenges related to business integrity practices (Box 3.4).
Additionally, other alternatives could also be explored, in particular given the scepticism from the private sector towards the government. In this sense, the CGU could also consider strengthening co-operation with the academic community and private sector organisations by partnering with universities and sector federations to measure the business integrity practices and challenges. The academic partner may serve as a safeguard of the independence and methodological soundness of the research, whereas sector federations can help disseminate both the surveys and the results.
The French Anti-Corruption Agency (AFA) carried out a national survey in 2020. The survey analysed the understanding of corruption risks and the legal framework, as well as the maturity of the corruption prevention and detection systems among businesses in France. Open to companies regardless of their size, the survey consisted of an anonymous questionnaire that was accessible online. Professional organisations were key partners in the dissemination of the survey and actively engaged in communication activities mobilising their membership. As a result, more than 2 000 companies were reached, and around 400 companies, including SMEs, provided actionable responses.
The survey resulted in key insights on the business integrity landscape in France, including:
While companies reported that they have a clear understanding of corruption offences and that 70% of them have an anti-corruption compliance programme in place, these compliance programmes present too many shortcomings in terms of risk mapping and third-party risk management.
The position of the head of the compliance function is crucial in the implementation of effective compliance systems and needs to be strengthened.
SMEs (who are not subject to the compliance obligations set out in Article 17 of the Sapin II law) seemed to be lagging behind in the implementation of the anti-corruption compliance programmes.
The results of the 2020 survey will serve as a benchmark for measuring progress and gaps in business integrity in the future and have already informed the 2021 priorities and recommendations of the AFA on business integrity.
Sources: AFA (2020[20]), National Diagnostic Survey of Anti-Corruption Systems in Business - 2020 Survey Results, https://www.agence-francaise-anticorruption.gouv.fr/files/2021-03/National%20Diagnostic.pdf; OECD (2022[15]), OECD Integrity Review of the Slovak Republic: Delivering Effective Public Integrity Policies, https://doi.org/10.1787/45bd4657-en.
The OECD Recommendation of the Council on Public Integrity highlights the key responsibility civil society organisations (CSOs) have in promoting public integrity (OECD, 2020[1]). On the one hand, CSOs have a key role in educating the public, providing basic services, protecting the environment, defending the interests of vulnerable groups, conducting social research and analysis, and acting as a public watchdog, including in the public integrity field (OECD, 2022[21]). On the other hand, CSOs are expected to display exemplary behaviour by adhering to public integrity standards, acting in alignment with their mission, being trustworthy and encouraging transparency. This, considering that they often receive special status – such as tax exemption, have access to public contracts, and receive funds from companies or private individuals (OECD, 2020[1]). In this sense, the lack of transparency in CSOs’ mission and sources of funding can lead to perceptions that CSOs are a vehicle for the pursuit of private interests, jeopardising their legitimacy in the eyes of government and the public.
Civil society organisations in Brazil could further promote, establish and implement self-regulation initiatives that take into account proportionality
Governments can use legal and regulatory frameworks to promote integrity within CSOs. In Brazil, there are currently some requirements aimed at promoting accountability, transparency and integrity by CSOs. For instance, the Regulatory Framework for Civil Society Organisations (Marco Regulatório das Organizações da Sociedade Civil, MROSC) was established by Law 13.019 of 31 July 2014 and put into practice by means of Decree 8.726/2016 to regulate partnerships between the public administration and CSOs. Moreover, following the development of the MROSC, the Secretariat of Government and the Institute of Applied Economic Research (Instituto de Pesquisa Econômica Aplicada, Ipea) undertook an online mapping of CSOs to increase transparency. The online platform is called CSOs Map (Mapa das OSC), is continuously updated and integrates official databases and information provided directly by CSOs on areas of operation, regional distribution, projects and funding as part of a notable effort to increase the transparency of information related to CSOs in Brazil (OECD, 2022[21]). Additionally, to encourage organisations to fill out their data in the CSOs Map, the government created a fulfilment seal (selo de preenchimento), which varies according to the percentage of data completed by a CSO: A bronze seal is given to CSOs that have 50-70% of the information filled out, a silver seal for 71-90%, a gold seal for 91‑99% and a diamond seal for CSOs that fill out 100% of the fields available on the platform (Ipea, 2021[22]).
However, despite improvements in recent years, there is still room for the CSO sector to continue strengthening its transparency, integrity and accountability practices with a view to further encouraging public trust. Indeed, the Edelman Trust Barometer shows that trust in non-governmental organisations increased slightly in Brazil in recent years, from 56 in 2021 to 60 in 2022 and 2023, which places them as “trusted” institutions together with business (Edelman, 2023[23]). As part of the same research, 55% of Brazilians responded that non-governmental organisations are a reliable source of trustworthy information, but as many as 29% of citizens said that they are a source of false or misleading information (Edelman, 2023[23]). A failure to improve accountability, transparency and integrity could negatively impact CSOs’ credibility as anti-corruption advocates and limit their capacity to represent the interests of citizens.
To that end, CSOs in Brazil could consider further promoting, establishing and implementing self-regulation initiatives to increase their accountability, transparency and integrity. This also represents a good opportunity to open a dialogue amongst CSOs across the country and from different sizes, and with the government as an enabler. Self-regulation initiatives should take into account proportionality (i.e., the size of CSOs), so that smaller CSOs are not left behind due to their lack of expertise, human and financial resources. One concrete tool to support accountability, transparency and integrity of CSOs that CSOs in Brazil could be inspired by is the “Global Standard for CSO Accountability” (Box 3.5), which was developed by a group of CSOs specialised in accountability. Moreover, CSOs in Brazil could also use examples from other jurisdictions as an inspiration for undertaking their own exercise, including the Transparent Civil Society Initiative in Germany (Box 3.5).
Moreover, parallel to this, citizens’ perception of CSOs could be improved via positive public communications from the government recognising CSO’s positive contribution to society and their efforts to increase transparency, integrity and accountability. In this sense, the Government of Brazil could consider further communicating on the CSOs Map and the fulfilment seal initiative, as well as simplifying access to information on CSOs, for instance by expanding the ready-made visualisations of selected indicators in the CSO Map platform to facilitate citizens’ consultation and understanding of relevant information (OECD, 2022[21]).
The Global Standard for CSO Accountability
The Global Standard for CSO Accountability has been developed in a participatory process by a partnership of nine established Accountability Initiatives from across the world. Built on their practical experience and together with a wide range of consultative partners, they have created a common accountability framework for CSOs that consists of the following 12 commitments:
1. Justice and Equality: We will address injustice, exclusion, inequality, poverty and violence to create healthy societies for all.
2. Women’s rights and gender equality: we will promote women’s and girls’ rights and enhance gender equality.
3. Healthy planet: we will protect the natural environment and enhance its ability to support life for future generations.
4. Lasting positive change: we will deliver long-term positive results.
5. People-driven work: we will ensure that the people we work with have a key role in driving our work.
6. Strong partnerships: we will work in fair and respectful partnerships to achieve shared goals.
7. Advocating for fundamental change: we will address root causes by advocating for fundamental change.
8. Open organisations: we will be transparent about who we are, what we do and our successes and failures.
9. Empowered and effective staff and volunteers: We will invest in staff and volunteers to develop their full potential and achieve our goals.
10. Well-handled resources: we will handle our resources responsibly to reach our goals and serve the public good.
11. Responsive decision-making: we will ensure our decisions are responsive to feedback from people affected by our work, partners, volunteers and staff.
12. Responsible leadership: we will ensure our management and governing body are accountable.
Such framework is further defined in guidance material. This document suggests steps to work towards a global CSO practice in which CSOs are truly accountable to all of their stakeholders for their impact, approach and organisational processes.
Transparent Civil Society Initiative in Germany
In Germany, on the initiative of Transparency International Deutschland e.V., numerous actors from civil society and academia defined ten basic points that every civil society organisation should make accessible to the public. This includes:
1. name, registered office, address and year of foundation
2. complete articles of association as well as information on the organisational objectives
3. information on tax relief
4. name and function of key decision-makers
5. annual report
6. personnel structure
7. information on the source of funds
8. information on the use of funds
9. affiliation with third parties under company law
10. names of people whose annual payments account for more than 10% of the total annual budget.
As of December 2023, 1 861 organisations have joined the initiative. The complete list of organisations can be found at https://www.transparente-zivilgesellschaft.de/ueber-uns/unterzeichnerorganisationen.
Sources: Global Standard for CSO Accountability (n.d.[24]), 12 Commitments for Dynamic Accounability Guidance Materials, https://www.csostandard.org/wp-content/uploads/2019/09/2017_The-Global-Standard-Guidance-Materials.pdf; ITZ (n.d.[25]), Homepage, https://www.transparente-zivilgesellschaft.de/.
In addition to companies and civil society organisations, individuals also play a key role in upholding a culture of integrity in society (OECD, 2020[1]). Individuals have a shared responsibility to ensure that their engagement with the public sector respects the ethical norms, principles and values of society. This responsibility materialises in different ways, including by respecting the rules governing interactions with public officials and access to public resources, not engaging in fraudulent social benefit schemes, not avoiding taxes, and reporting corruption and fraud when they encounter it. Governments can cultivate commitment among society and reduce tolerance for public integrity violations by raising awareness on the benefits of public integrity.
Building on existing initiatives, the CGU could be more active in communicating to citizens their roles and responsibilities for upholding integrity using a comprehensive communication strategy, being aware of potential unintended consequences
Awareness-raising campaigns are one of the methods by which governments can increase individuals’ understanding of public integrity issues (OECD, 2020[1]). However, raising awareness is not a question of educating about the existence of corruption, something that citizens are typically well aware of, but rather about how to break the vicious cycles that undermine integrity in society. Also, it is key to have a good understanding of what citizens perceive, experience and expect with respect to dimensions related to public integrity.
As a first approximation, evidence suggests that most Brazilians do not tolerate integrity breaches such as claiming social benefits to which one is not entitled, avoiding the fare on public transport, cheating on ones’ taxes, and accepting a bribe in the course of ones’ duties (Figure 3.3). In all cases (except for cheating on taxes), the percentage of Brazilians stating that these behaviours are “never justifiable” is higher than the OECD average.
Despite these low levels of tolerance to integrity breaches, citizens’ willingness to report potential cases of misconduct is low. According to the Latinobarometer Survey 2018, although 82% of Brazilians think that not reporting an act of corruption of which one is aware of transforms a person into an accomplice of corruption -the highest figure in the LAC region, 48% of respondents think that it is better to remain silent when they know about corrupt activities (Corporación Latinobarómetro, 2018[26]).
Figure corresponds to the percentage of Brazilians stating that the following actions are “never justifiable”
Note: OECD average includes Australia, Canada, Chile, Colombia, Germany, Greece, Japan, Korea, Mexico, the Netherlands, New Zealand, Türkiye and the United States.
Source: WVS (n.d.[27]), World Values Survey, Wave 7 (2017-2022), https://www.worldvaluessurvey.org/WVSDocumentationWV7.jsp.
Moreover, although levels of public trust vary across institutions, they are generally low in Brazil. On a scale of 0-10, with zero meaning no trust at all and 10 complete trust, average trust levels in Brazil are below three for all the institutions considered, except the police and trust in other people (Figure 3.4) (OECD, 2023[28]). Low trust levels are a risk factor for clientelism across the country, especially if coupled with poor –perceived or real– service delivery.
Note: Share of respondents who indicate levels of trust in public institutions in Brazil, 2022. This figure presents responses to the question “On a scale of 0 to 10, where 0 is not at all and 10 is completely, how much do you trust the institutions?” “High or moderately high trust” corresponds to responses of 6-10, “neutral” to a response of 5 and “low or no trust” to responses of 0-4; “don't know” was a separate answer choice. OECD (22) refers to the unweighted average across 22 OECD countries.
Source: OECD (2023[28]), Drivers of Trust in Public Institutions in Brazil, https://doi.org/10.1787/fb0e1896-en.
Additionally, public opinion about the effectiveness of anticorruption reforms in Brazil is low. The 2021 Latinobarometer Survey found that only 23% of Brazilians believed that there have been significant or some improvements in reducing corruption within public institutions over the previous two years (Corporación Latinobarómetro, 2021[29]). Citizens’ approval of government’s efforts to combat corruption is also low, with 46% of Brazilians rating the government’s performance as poor in this regard (Transparency International, 2019[30]). Moreover, the 2021 Latinobarometer Survey also revealed that 52% of Brazilians felt that corruption had increased over the previous 12 months prior to the survey (Corporación Latinobarómetro, 2021[29]).
However, while the evidence presented above serves as a valuable starting point for understanding and analysing the perceptions, attitudes and experiences of Brazilians, additional and up-to-date data would be needed to enable a more thorough and comprehensive assessment of the situation.
Indeed, currently, the evidence suggests that integrity actors in Brazil could consider designing and implementing a communication strategy to address the widespread beliefs that discourage citizens from reporting corruption and misbehaviour, increase the low levels of trust in public institutions and improve perceptions of government’s effectiveness in combating corruption. But, to be impactful, the messages should be informed by an in-depth understanding of the perceptions, attitudes and experiences faced by citizens. Ideally, the Office of the Comptroller General of the Union (Controladoria-Geral da União, CGU) could consider conducting periodic surveys to generate knowledge and data over time that would help fortify evidence-based efforts in this area and track changes and impact.
Such a communication strategy could incorporate activities already in place and others foreseen in existing plans (e.g., the Anticorruption Plan 2025-2027). For each of the specific activities included in the communication strategy, the CGU should identify:
the expected outcomes (e.g., behaviours to change or skills to develop)
the target audiences (e.g., adults, young people, or vulnerable communities)
the key messages to be transmitted (recalling the possible unintended effects, see below)
the communication channels to do so (e.g., television, website, social media or print media)
the evaluation mechanisms (e.g., opinion surveys, web analytics, participation in events, number of complaints submitted, etc.). Evaluating awareness raising campaigns allows to better understand the results and impact of such campaigns, introduce changes and improvements and better prioritise the use of scarce public resources.
When it comes to the messages to be transmitted, Brazil should consider several factors. First, awareness campaigns should avoid over-emphasising corruption, as focusing on its prevalence and associated costs can have unintended consequences. Evidence suggests that in contexts where corruption is very present in public debates and the media, as in Brazil, campaigns cantered on corruption can have a counter-productive effect by increasing the already high perception of corruption and reinforcing the belief that it is widespread. Second, research shows that unethical behaviour can be contagious, and corruption-focused communication may trigger a “self-fulfilling prophecy” effect, where the perception that corruption is a common practice in society can lead to the rationalisation and justification of one’s own unethical behaviour (Ajzenman, 2021[31]; Bicchieri and Xiao, 2009[32]; Corbacho et al., 2016[33]; Gino, Ayal and Ariely, 2009[34]; Robert and Arnab, 2013[35]). Third, studies indicate that the right messaging can effectively encourage citizens to report corruption (Peiffer and Walton, 2022[36]). Messages that highlight the direct and broader impacts of unethical behaviour on communities can increase the willingness of individuals to report corruption and foster a more positive view of reporting. Such efforts should be complemented by initiatives that strengthen reporting channels and institutional responses, thereby building trust in the whistle-blowing system (see also Chapter 5).
Finally, lessons learned from social campaigns that seek to promote value and behaviour change across society (e.g., public health, drink driving, domestic violence, etc), indicate that there are four success factors (Table 3.1) that could be relevant to integrity campaigns.
Source: Adapted from Mann, C. (2011[37]), “Behaviour changing campaigns: Success and failure factors”, https://www.u4.no/publications/behaviour-changing-campaigns-success-and-failure-factors.
As such, Brazil could build on three complementary pillars when designing the messages to be transmitted in a communication strategy:
First, on promoting citizens' co-responsibility for upholding public integrity (success factor “generating community responsibility” in Table 3.1). In this sense, the campaigns could challenge any justification of unethical behaviour and create a link between one’s own integrity and the wider public benefit.
Second, on increasing citizens’ sense of agency towards public integrity, by proposing alternative behaviours to specific situations citizens may encounter in their interactions with public officials and developing individual motivation to act, including by reporting corrupt behaviours.
Third, campaigns could aim at building citizens’ trust (e.g. along OECD’s five drivers of trust (OECD, 2024[38])) and strengthening their engagement in ongoing public integrity initiatives. This could be achieved by going beyond communicating about the government’s efforts to mitigate corruption, and instead focusing on presenting success stories that show effective behavioural changes throughout the public administration and in society.
Considering the importance of the message to be transmitted, the CGU could consider developing and implementing pilots by first selecting a subset of individuals where the messages of the campaigns could be tested before they are deployed more widely. Without piloting and testing the impact of different messages, campaigns could do more harm than good. Getting the messages right through carefully testing their impact through controlled pilots could help, for example, to effectively target the challenges that impede citizens from reporting corruption to authorities (Peiffer and Walton, 2022[36])
Lastly, the CGU could partner with the Integrity Sectoral Units of high-risk public institutions that deal with areas more susceptible to corruption and fraud and/or that due to their functions have a greater proximity to citizens, to develop and implement tailored integrity awareness-raising campaigns for citizens in their respective sectors. Examples of high risks-public institutions could include the Ministry of Health (Ministério de Saúde), and the Ministry of Education (Ministério da Educação). Such campaigns could be tailored to the specific risks of the corresponding sector (e.g., social benefit fraud, health insurance fraud, etc.), and could identify the roles and responsibilities of citizens in these highly risky areas. By partnering with Integrity Sectoral Units, the CGU could ensure that awareness-raising campaigns are informed by relevant evidence specific to the sector while developing the ownership of integrity policies at sector-level and supporting the development of new capacities for public integrity within public institutions.
The CGU could collaborate with the Ministry of Education and secondary school teachers to develop an education programme on public integrity aligned to the Common National Curriculum Base for lower and upper secondary students
Building a culture of integrity in society necessarily begins with the education of young people (OECD, 2018[39]). Education on public integrity equip young people with the knowledge and skills needed to resist corruption and help challenge entrenched social norms that enable corruption to flourish by generating new common knowledge about the expected norms and behaviours needed to prevent corruption. Indeed, evidence has shown that civic education programmes can increase the likelihood of young people rejecting authoritarian governments, corrupt practices and excuses for breaking the law (Ainley et al., 2011[40]). To this end, educating on public integrity is a key tool for encouraging citizens to embrace their roles and responsibilities in enhancing public integrity.
In Brazil, the CGU has developed a range of innovative and voluntary initiatives to foster public integrity and ethics literacy of primary, lower-secondary and upper-secondary students (estudantes de Ensino Fundamental I, Ensino Fundamental II e Ensino Médio). Existing good practices in Brazil target students between 6 and 17 years old, and include the following initiatives:
The programme “One for all and all for one! For ethics and citizenship” (Um por todos e todos por um! Pela ética e cidadania) is an initiative for primary school students (students between 6 and 10 years old) that was developed in 2008 by the CGU in partnership with the Instituto Maurício de Sousa and more recently with the Ministry of Education as well. Structured around comic characters, the programme uses magazines, stories, animation videos, comic books, etc. to educate future generations of citizens on topics related to ethics, citizenship, and social participation, amongst others. Teaching materials are available in printed and digital formats.
The Citizenship Team (Turma da Cidadania) is an initiative aimed at encouraging the development of an ethical and civic culture among students in the first two years of lower secondary school. This initiative includes didactic-pedagogical material (comics and animated videos) presenting several situations that portray the daily reality of many children and highlighting the relevance of topics such as citizenship, democracy, ethics, combating bullying, social participation and combating corruption (Government of Brazil, n.d.[41]).
The Citizenship’s Game (Game da Cidadania) is a virtual game that exposes youth between 11 and 17 years old to situations in which their ethics and citizenship skills are put to test, in order to develop critical awareness of small acts of corruption that often go unnoticed (Government of Brazil, 2022[42]).
The National Essays and Drawings contest (Concurso de Desenho e Redação) is a competition that engage students between 6 and 17 years old in discussions around ethics, citizenship and social control (the topic changes each year). It allows participants to compete in different categories (design and drafting, for students and their teachers depending on the student’s education level, and mobilisation plans, for schools) and compete for prizes (Government of Brazil, 2022[43]). The contest, now in its 13th year, focuses annually on a specific theme related to citizenship. In 2024, the chosen theme was ‘Digital Citizenship: Access and education for democracy’.
Although public integrity educational initiatives offered by CGU cover both primary and secondary students, initiatives remain voluntary and do not cover all students between 6 and 17 years old throughout the country. Indeed, although coverage of the programme has increased thanks to efforts by the CGU and the Ministry of Education, including to produce digital material and raising awareness about the programme in schools, the coverage remains limited especially considering Brazil’s size. Moreover, only the programme “One for all and all for one! For ethics and citizenship” has been designed and is being implemented following a methodical progression in the internalisation of key concepts on integrity in alignment with the official curriculum, providing age-appropriate modules and a solid approach to education for public integrity (Box 3.6). In this sense, education on public integrity of students between 10 and 17 years old is not done through this age-appropriate and incremental approach.
The programme “One for all and all for one! For ethics and citizenship” is a free and voluntary citizen education initiative in Brazil to educate future generations of citizens on topics related to ethics, citizenship, and social participation, amongst others. It considers education on public integrity as a long-term policy tool that builds on the knowledge and skills developed previously.
The programme is structured around comic characters. The programme provides students with age-appropriate magazines developed based on the Common National Curriculum Base (Base Nacional Comum Curricular) as well as additional materials that students can use to reinforce the learning process outside the classroom - stories, animation videos and comic books – including in digital format. Moreover, the programme provides specific teaching materials and online courses for educators, aimed at building capacities on those responsible for supporting students in the achievement of the learning outcomes, recognising that education about public integrity requires teachers who are capable of delivering the material, as well as modelling integrity.
The didactic material has been designed to ensure a methodical progression in the internalisation of key concepts of ethics, citizenship, social responsibilities and participation, in alignment with the official curriculum, providing a solid approach to education for public integrity.
The didactic material offers students the opportunity to get to learn and practice, in a playful way, concepts such as self-esteem, respect, tolerance, inclusion, combating bullying, democracy, ethics, citizenship, social participation, public property, environment, solidarity and volunteering.
The programme provides for the participation of educators, families and the community as a whole, with the school as the centre for the development of awareness raising and education actions, allowing to reach out both students and their families.
The programme has been implemented in Brazilian schools from more than 15 years and it is part of a broader set of training and knowledge management actions developed by the CGU for children and young people, known as “Citizen Education”.
Source: Meetings during the fact-finding mission conduced in June 2022; CGU (n.d.[44]), Um por Todos e Todos por Um, https://www.gov.br/cgu/pt-br/educacao-cidada/programas/upt.
Considering this, the CGU and the Ministry of Education could continue their efforts to expand the coverage of the programme “One for all and all for one! For ethics and citizenship” to reach out to more schools and primary school students. Additionally, with the aim of strengthening education on public integrity, especially for secondary students, the CGU, in collaboration with the Ministry of Education, could consider developing an education programme for lower and upper secondary students that incorporates public integrity learning outcomes into age-appropriate modules that are aligned to the Common National Curriculum Base. Such actions do not aim to replace the existing initiatives, which could remain as extracurricular activities once reviewed under the new education programme, but to complement them while ensuring a comprehensive coverage for all secondary students.
To that end, the CGU could convene a multi-stakeholder working group consisting of representatives from the CGU, the Ministry of Education, secondary school teachers and non-government organisations (NGOs) working on the field, which has proven to be an effective approach in the development of the programme “One for all and all for one! For ethics and citizenship” and other international experiences (Box 3.7) and tasked them with developing an education programme with learning outcomes on integrity for secondary schools. The learning outcomes could build on what has worked already (e.g., lessons learnt from the programme “One for all and all for one! For ethics and citizenship”, other education initiatives by CGU and international good practices) and could also take inspiration from the OECD education for integrity learning outcomes (Table 3.2).
As part of the “Innovative Approaches towards teaching Anti-Corruption in Formal education” project, three Chapters of Transparency International (TI), the Hungarian, the Slovenian and the Italian, supported by the European Commission, published a joint handbook for anti-corruption education in high school. Such manual is designed as a guide for high school teachers to address the issue of corruption in the classroom. The project also included exchange experiences among teachers of the three countries involved, a conference with the institutions of the education sector, and a short film competition about anticorruption (with national and international winners).
Note: For more information on the Handbook for anti-corruption education in high school, see: https://transparency.hu/wp-content/uploads/2018/05/Booklet_ENG.pdf.
Source: G20 Anti-Corruption Working Group (2022[45]), Compendium of Good Practices on Public Participation and Anti-Corruption Education, https://g7g20-documents.org/database/document/2022-g20-indonesia-leaders-leaders-annex-compendium-of-good-practices-on-public-participation-and-anti-corruption-education.
Source: OECD (2018[39]), Education for Integrity Teaching on Anti‑Corruption, Values and the Rule of Law, https://www.oecd.org/governance/ethics/education-for-integrity-web.pdf.
In developing the proposed education programme, the working group could also be tasked with developing age-appropriate guidance material utilising practical activities such as in-class participatory games, role-play scenarios and debates to engage students in a practical way. Indeed, experiential evidence has shown that students who engage in practical integrity-related activities not only build the knowledge and skills to hold public officials accountable, but also indicate a stronger willingness to contribute to integrity efforts in their communities (OECD, 2018[39]). Good practice also includes the adaption of materials to the local situation and the pursuit of community-based projects, examples of which include a visit to a local government office to oversee reporting registers, or the preparation of an access to information request (OECD, 2018[39]).
Additionally, considering that to effectively facilitate learning on public integrity in the classroom educators require the appropriate skills, knowledge and confidence to teach about integrity and anti-corruption, the working group could also be tasked with developing specific training for educators as well as specific teaching material. Training can take many forms ranging from courses taken during teacher trainee programmes or in-service training, to seminars and resource kits prepared by government institutions or civil society actors (OECD, 2018[39]). Independently of the delivery method, training should also help educators to ensure an open classroom environment that enables students to open up about their values and insights, as well as to handle difficult and sensitive conversations on ethical and moral questions that could arise in the classroom. Moreover, training can be supported by the development of guidance on how to deliver the material in a relevant and engaging manner and promote respectful and open discussions. To develop these guidelines, the working group could leverage on good practices from a range of countries summarised by the OECD in its report on Education for Integrity (OECD, 2018[39]).
Higher education institutions in Brazil could consider developing and mainstreaming integrity and anti-corruption courses throughout their regular degree programmes
Students, researchers and higher-education institutions (Instituições de Ensino Superior) play a key role in generating and disseminating knowledge on public integrity. As future employees, higher-education students need the knowledge and skills to comply with ethical requirements, as well as be able to confront integrity challenges that they may encounter in their future workplace. Indeed, higher education provides a good opportunity to consolidate integrity and ethics education because it is the final stage prior to entry into the workforce (Munro and Kirya, 2020[46]). Moreover, ensuring that institutions that train future leaders promote the necessary values as part of their education programmes is foundational to building a pool of ethical public servants and private employees (Munro and Kirya, 2020[46]).
In Brazil, the CGU and the National School of Public Administration (Escola Nacional de Administração Pública, ENAP) offer courses open to the general public, including high-education students, on ethics and public integrity. The courses offered by the CGU and the ENAP include the following: Public Integrity Foundations – Preventing Corruption, Ethics and Public Service, Introduction to Public Ethics Management and Assessment, Prevention of money laundering and terrorist financing, and Ethics in public administration. However, these courses are voluntary and do not necessarily reach the majority of higher education students, as participation depends on their interest in the subjects offered. Moreover, while there are courses tailored to specific professions and disciplines, such as the course “Training and Management of Community Civil Protection and Defence Centres” aimed at municipal civil protection and defence agents, civil society and those interested in risk and disaster management, they do not necessarily address the ethics and integrity risk associated with these professions.
To that end, to complement the current practices, higher-education institutions in Brazil could consider developing integrity and anti-corruption courses and mainstreaming these into their regular study programmes such as public administration, law, economics, business, and engineering. Moreover, although the content of integrity and anti-corruption courses should be adapted to the specific needs and risks of the different professions/careers, as a first step towards public integrity education for higher-education students, universities could also consider developing modules ethics and public integrity as part of general induction courses for all newcomers. Given the autonomous nature of higher-education institutions in Brazil, the Ministry of Education does not have jurisdiction over degree programmes. Therefore, including content on public integrity and anticorruption into degree programmes is the responsibility of each university.
Evidence has shown that integrating ethics education into university curricula exposes students to a range of ethical issues and thereby improve their ethical sensitivity, a critical component which initiates the ethical decision-making process (Martinov-Bennie and Mladenovic, 2015[47]). Additionally, to be effective, training on integrity for higher-education students could be supplemented by experiential learning and immersion techniques – to give students the opportunity to experience and practice ethical considerations (Christensen et al., 2007[48]), and should cover all professions – as integrity breaches can be found across all sectors. Initiatives of the UNDOC to promote teaching of anti-corruption and integrity, including the Global Resource for Anti-Corruption Education and Youth Empowerment (GRACE), contain extensive resource material that Brazilian higher-education institutions can draw upon to design the integrity and anti-corruption courses (Box 3.8). Additionally, where appropriate, the CGU and the Ministry of Education could support higher-education institutions by sharing lessons learned, good practices and expertise on the initiatives developed to foster public integrity and ethics literacy of higher-education students.
Building on the success of the Education for Justice (E4J) and Anti-Corruption Academic (ACAD) initiatives, in 2021 UNODC launched the Global Resource for Anti-Corruption Education and Youth Empowerment (GRACE) initiative to promote further the role of education and youth empowerment in preventing and countering corruption. The GRACE initiative is developed around three pillars: primary and secondary education, academia and research, and youth empowerment.
Primary and secondary education pillar: within this pillar, the GRACE initiative aims to strengthen the capacity of primary and secondary school teachers to teach anti-corruption, integrity and ethics through training, dialogues, forums, and campaigns.
Academia and research pillar: within this pillar, the GRACE initiative seeks to facilitate the exchange of knowledge and good practices in the areas of education and research on anti-corruption, ethics and integrity among higher education institutions. To achieve this, UNODC aims to continue expanding its network of academics and researchers and providing them with opportunities to enhance their capacity to teach and conduct research on corruption-related issues. As part of this pillar, UNDOC provides the GRACE Knowledge Hub, which offers various knowledge tools and products that university lecturers and trainers can use in their academic courses and professional trainings to transmit knowledge and create a deeper understanding of corruption- related issues, with a focus on integrity and ethics.
Youth empowerment pillar: within this pillar, the GRACE imitative aims to promote the role of youth as agents of change and enhance their capacity to respond to corruption through innovation, technology and social entrepreneurship, in particular through regional and international forums, dialogues and other activities between youth, policymakers, and anti‑corruption authorities.
Note: For more information on the GRACE Knowledge Hub see: https://grace.unodc.org/grace/en/academia/knowledge-hub.html. Other UNODC resources and teaching tools can be accessed freely on the web https://track.unodc.org/.
Source: UNODC (n.d.[49]), Global Resource for Anti-Corruption Education and Youth Empowerment (GRACE), https://grace.unodc.org/ (accessed on 26 September 2022).
Governments can also engage stakeholders in developing, updating and implementing the public integrity system as part of the promotion of a whole-of-society approach to public integrity (OECD, 2020[1]). Moreover, the OECD Recommendation of the Council on Public Integrity states that adherents should “encourage transparency and stakeholders’ engagement at all stages of the political process and policy cycle to promote accountability and the public interest through different actions” (OECD, 2020[1]), including by granting all stakeholders – including the private sector, civil society and individuals – access in the development and implementation of public policies.
Engaging stakeholders in the development, update and implementation of public integrity systems and public integrity policies provides for several benefits. First, it helps ensuring that policy makers have a clear, concise and grounded understanding of the integrity challenges facing society in a rapidly evolving context. Second, it helps developing up-to-date and tailored solutions based on current evidence and information rather than impressions. Third, it helps averting unintended impacts and avoid practical implementation problems associated with integrity policies. Lastly, it can lead to higher compliance with and acceptance of the regulations, in particular when stakeholders feel that their views and comments were considered.
The CGU could institutionalise stakeholder engagement by establishing formal requirements to consult civil society, business and individuals on different elements of the public integrity system and issuing guidelines
In Brazil, at the Federal level, almost all public institutions involve citizens and stakeholders at some point in their decision-making process, whether in the design and delivery of public services or in drafting or implementation of a policy (OECD, 2022[21]). For instance, public consultations are widely used to gather opinions and inputs from citizens in other areas beyond regulation, such as their strategic documents, in design and delivery of public services and in the drafting of policies (OECD, 2022[21]).However, when it comes to the different elements of the public integrity system (e.g., integrity policies, integrity programmes and integrity plans), citizens’ engagement could be strengthened.
To that end, public institutions of the Federal Executive branch could consider further engaging civil society, business and individuals in developing, updating and implementing new integrity policies, as well as their institutional integrity programmes and plans. This, in line with the Public Maturity Model (Modelo de Maturidade Pública, MMIP) published in 2023 by the Office of the Comptroller General of the Union (Controladoria-Geral da União, CGU), which aims at promoting the adoption of actions, within the scope of the Integrity Programme, that engage organised civil society and the beneficiaries of the institutional mission (KPA 5.1.1.). In particular, the CGU could consider institutionalising stakeholders’ engagement by establishing formal requirements to consult civil society, business and individuals on different elements of the public integrity system and issuing guidelines for all public institutions with practical support to organise consultations on institutions’ integrity programmes and plans. When doing so, the CGU should consider the three levels of citizen and stakeholder engagement provided by the OECD Recommendation of the Council on Open Government (2017) -information, consultation and engagement, which differ according to the level of involvement of citizens in the policy-making process (OECD, 2022[50]). When defining these guidelines, the CGU should also consider that there are different participation mechanisms of civil society, business and individuals in public integrity systems (OECD, 2019[51]), while encouraging public institutions to experiment with more innovative and impactful mechanisms for stakeholders to influence public integrity policies, programmes and plans beyond public consultations (Box 3.9).
Participation is a fundamental tool to promote inclusion as it guarantees that stakeholders have equal opportunities and multiple channels to access information and have an impact in public decision-making. Involving and consulting civil society, business and individuals helps decision makers to have diverse inputs and evidence on multidimensional policy objectives, and to identify costs and benefits for different actors, to make more informed and equitable decisions.
There are different participation mechanisms of stakeholders in public integrity systems. There are also common challenges, particularly related to ensuring the sustainable financing of these mechanisms to guarantee their effectiveness without compromising their role within the public integrity systems. International experiences suggest some key elements to effectively engage civil society, business and individuals on different elements of the public integrity system:
It is better to have imperfect co-ordination and stakeholder inclusion mechanisms than not having mechanisms at all.
For formal mechanisms to work, the following key elements are necessary: Leadership, particularly from the highest authority within the mechanism; Management, to effectively set tasks, commitments and visible goals; Capacity, to guide and follow up.
It may be difficult to have a single mechanism or to include all relevant stakeholders in it. This could be solved by establishing alternative but integrated co-ordination spaces that feed into a core group (e.g., inter-institutional working groups or commissions with rotating leadership). Also, to allow for dialogue with other actors, maintaining or opening informal spaces without weakening the formal ones, may be a solution in certain contexts.
For instance, in the Republic of Korea, the Anti-Corruption and Civil Right Commission created the ‘People’s Monitoring Group on Integrity Policy’, consisting of people who are interested in corruption eradication and integrity and who have great understanding in it, including university school students, workers, and homemakers. The aim of this group is to conduct citizens’ discussions and surveys to collect feedback about the effectiveness of anti-corruption and integrity policies and ideas about the direction and change in such policies.
Source: ACRC (n.d.[52]), Promoting Public-Private Partnership, https://www.clean.go.kr/menu.es?mid=a20106060000; OECD (2019[51]), La Integridad Pública en América Latina y el Caribe 2018-2019: De Gobiernos Reactivos a Estados Proactivos, https://doi.org/10.1787/ebd84d6d-es.
Further engaging the private sector to strengthen public integrity
The CGU, together with business organisations, could provide further guidance and support to companies on establishing their integrity programmes to effectively create a culture of integrity in the private sector.
The CGU could provide an online platform for businesses to exchange good practices and examples on public integrity in companies.
The CGU could continue current efforts aimed at providing further specific guidance and capacity-building opportunities to SMEs, to respond to their particular needs and capacities.
The CGU could encourage companies to include responsible engagement standards in their integrity programmes, including through specific guidelines for business.
The CGU could encourage high-risk sectors to develop sector-oriented initiatives to acknowledge and further encourage companies’ commitment to public integrity.
The CGU could further strengthen the evidence base on business integrity practices and challenges.
Fostering public integrity, accountability and transparency in civil society organisations
Civil society organisations in Brazil could further promote, establish and implement self-regulation initiatives that take into account proportionality.
The Government of Brazil could consider further communicating on the CSOs Map and the fulfilment seal and simplifying access to information on CSOs.
Cultivating a shared sense of responsibility for public integrity throughout society
The CGU could consider conducting surveys to generate knowledge and data on citizens’ perceptions, attitudes and experiences related to corruption and integrity. Ideally such surveys would be conducted regularly to generate evidence over time and enable to track changes and impact of policy interventions.
The CGU could build on existing initiatives and develop a comprehensive communication strategy that identifies a series of complementary awareness raising campaigns about public integrity and the appropriate timeline and resources for each.
The CGU could partner with Integrity Sectoral Unit of certain high-risk public institutions to develop and implement tailored integrity awareness-raising campaigns for citizens in their respective sectors.
The CGU and the Ministry of Education could continue their efforts to expand the coverage of the programme “One for all and all for one! For ethics and citizenship” to reach out to more schools and primary school students.
The CGU could convene a multi-stakeholder working group consisting of representatives from the CGU, the Ministry of Education, secondary school teachers and non-governmental organisations working in the field and tasked them with developing learning outcomes and guidance material on integrity for lower and upper secondary students, aligned to the Common National Curriculum Base.
Such a multi-stakeholder working group could also be tasked with developing age-appropriate guidance material, specific training for educators as well as specific teaching material.
Higher education institutions in Brazil could consider developing and mainstreaming integrity and anti-corruption courses throughout their regular degree programmes.
Engaging relevant stakeholders in the development, update and implementation of the public integrity system
The CGU could institutionalise stakeholder engagement by establishing formal requirements to consult civil society, business and individuals on different elements of the public integrity system.
The CGU could issue guidelines with practical support to public institutions to organise consultations and further encourage citizens’ participation on different elements of the public integrity system.
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← 1. CGU’s Private Integrity Programme Collection can be found in CGU’s website: https://www.gov.br/cgu/pt-br/centrais-de-conteudo/publicacoes/integridade/colecao-programa-de-integridade-privada.