Compliance / Anti-corruption

The latest events in Brazil related to fraud and corruption always had the involvement of top management. Many of the implicated companies already had a compliance policy, code of conduct or a similar document, which does not seem to suffice however.


Taking this into consideration, our partner Marcelo Marchetti, legal adviser with broad experience in the infrastructure and the construction sector, Amanda Paradela, specialist in Corporate Communication, Social Responsibility and Press Office, and Roberta Marques, consultant in Culture and Integrity, Human and Organizational Development, joined forces to develop the Systemic Integrity Program, aiming to promote differentiated solutions based on the individual’s conscience in the essence of their systemic actions to create a collective impulse that allows the perpetuation of the raison d’être of the company guided by ethics, integrity and veracity.


After a thorough diagnosis of the culture and the objectives of each company, a risk management plan is conducted, which will review governance, raise leadership and the individual awareness and culminate with the formation of a new organizational culture. Therefore, the Systemic Integrity Program aims not only to create a system that controls the occurrence of risks (including possibilities for fraud and corruption), with policies, procedures and tools, but also aims to make each manager aware of their acts, strong sense of ethics and systemic vision. It is thus expected that the compliance program surpasses the company’s bureaucratic level and be translated from theory into practice, permeating the company’s culture and becoming a natural addition to every employee’s day-to-day life.


The performance of the practice of Compliance and Anticorruption of Toledo Marchetti Advogados includes the following services:


  • Diagnosing Organizational Culture;
  • Structuring a customized Systemic Integrity Program focused on Individual, Collective and Systemic Responsibility;
  • Reviewing the organization’s values ​​and benefits;
  • Conducting a “Risk Assessment” and a Monitoring and Control Plan based on COSO methodology (Committee of Sponsoring Organizations of the Treadway Commission);
  • Implementing an effective internal and external Communication Plan to disseminate and facilitate the understanding of the public involved;
  • Organizing periodic training;
  • Internal Auditing;
  • Implementing tools to measure the topics absorption by the organization internally;
  • Establishing performance indicators for each phase of the Systemic Integrity Program;
  • Defining continuous monitoring and the Systemic Integrity Program’s refinement.


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