One of the first entities to comply with the Anti-Corruption rules in Brazil, ABES finalized its Integrity Program, whose main document is, in addition to the Code of Ethics, a Guide to Policies for Interaction with Public Agents
In order to bring more transparency in its relations with other entities, with companies and public agents, ABES (Brazilian Association of Software and Services) has developed its own Integrity Program, reformulating its Code of Ethics, which already brought good practices and is now fully in line with the rules of the Anti-Corruption Law 12.846 / 2013.
According to the entity's president, Francisco Camargo, ABES is a pioneer among industry associations to develop its own Integrity Program, which also brings a Guide to Policies for Interaction with Public Agents.
The program not only prepares ABES for new times in Brazil and in the world, but also aims to educate and inform its members about the need to develop compliance programs and ethical rules against corruption and unfair competition.
Comprehensive, the Anti-Corruption Law allows companies to be severely punished for acts of corruption involving Brazilian or foreign public officials, as well as punished their managers, individuals.
It also transfers to the private individual the duty to inspect, imposing the adoption of a set of internal measures to prevent or minimize the risks of violating the law. “In addition to bringing more transparency in the entity's relations with its employees, suppliers, associates and public entities, these documents will serve as Integrity. All documents can be accessed on the ABES Portal”, Says Francisco Camargo, president of ABES.
Compliance Officer
The entity relied on the consultancy of the specialized firm Mattos Filho, Veiga Filho, Marrey Jr. and Quiroga Advogados, which mapped processes, analysis and interviews with all the people and companies that act on behalf of the entity, checking possible sensitive points and risk of exposure to laws, and set up the Entity's Risk Matrix, which is necessary to adapt internal rules.
One of the recommendations was to hire an internal or outsourced Compliance Officer.
"Companies, associations and foundations of any size and with any legal organization can be framed by acts or omissions of employees or even third parties", explains lawyer Carolina Marzano, ABES Compliance Officer and specialist in Intellectual Property and Anti-Corruption.
“The Compliance Officer lives not only in anti-corruption. With the new European standard, GDPR (General Data Protection Regulation) that deals with the Privacy and Security of Personal Data, companies will need to establish rules regarding the use of their customers' data, if they are in accordance with the GDPR and with Brazilian standards. It is up to the Compliance Officer to verify that they are being complied with ”, explains Dr. Carolina.
For the coming months, with the help of Mattos Filho, the entity must apply for the Seal
“ Pro-Ethical Company ” issued by the Ministry of Transparency and the Comptroller General of the Union, which publicly recognizes organizations that are committed to implementing measures aimed at preventing, detecting and remedying acts of corruption and fraud.
According to the entity's president, Francisco Camargo, ABES is a pioneer among industry associations to develop its own Integrity Program, which also brings a Guide to Policies for Interaction with Public Agents.
The program not only prepares ABES for new times in Brazil and in the world, but also aims to educate and inform its members about the need to develop compliance programs and ethical rules against corruption and unfair competition.
Comprehensive, the Anti-Corruption Law allows companies to be severely punished for acts of corruption involving Brazilian or foreign public officials, as well as punished their managers, individuals.
It also transfers to the private individual the duty to inspect, imposing the adoption of a set of internal measures to prevent or minimize the risks of violating the law. “In addition to bringing more transparency in the entity's relations with its employees, suppliers, associates and public entities, these documents will serve as Integrity. All documents can be accessed on the ABES Portal”, Says Francisco Camargo, president of ABES.
Compliance Officer
The entity relied on the consultancy of the specialized firm Mattos Filho, Veiga Filho, Marrey Jr. and Quiroga Advogados, which mapped processes, analysis and interviews with all the people and companies that act on behalf of the entity, checking possible sensitive points and risk of exposure to laws, and set up the Entity's Risk Matrix, which is necessary to adapt internal rules.
One of the recommendations was to hire an internal or outsourced Compliance Officer.
"Companies, associations and foundations of any size and with any legal organization can be framed by acts or omissions of employees or even third parties", explains lawyer Carolina Marzano, ABES Compliance Officer and specialist in Intellectual Property and Anti-Corruption.
“The Compliance Officer lives not only in anti-corruption. With the new European standard, GDPR (General Data Protection Regulation) that deals with the Privacy and Security of Personal Data, companies will need to establish rules regarding the use of their customers' data, if they are in accordance with the GDPR and with Brazilian standards. It is up to the Compliance Officer to verify that they are being complied with ”, explains Dr. Carolina.
For the coming months, with the help of Mattos Filho, the entity must apply for the Seal
“ Pro-Ethical Company ” issued by the Ministry of Transparency and the Comptroller General of the Union, which publicly recognizes organizations that are committed to implementing measures aimed at preventing, detecting and remedying acts of corruption and fraud.
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