Improvement of the Pro-Ethics Company Registry (BR0078)

to improve the Pro-Ethics Company Registry with the aim of increasing the number of companies listed in the registry, which implement effective and impactful compliance programs. To this end, the disclosure policy of the registry shall be improved, as well as the strategy to give visibility to the companies listed in the registry. Furthermore, the registry rules and the integrity verification tools shall also be improved and new partnerships with other bodies and agencies of the public sector, the private sector and the civil society shall be established with the aim of strengthening the scope of the initiative.

Commitment 4.1. Improvement of the Pro-Ethics Company Registry

Commitment Text: To improve the Pro-Ethics Company Registry with the aim of increasing the number of companies listed in the registry, which implement effective and impactful compliance programs. To this end, the disclosure policy of the registry shall be improved, as well as the strategy to give visibility to the companies listed in the registry. Furthermore, the registry rules and the integrity verification tools shall also be improved and new partnerships with other bodies and agencies of the public sector, the private sector and the civil society shall be established with the aim of strengthening the scope of the initiative.

Responsible institution: Office of the Comptroller General

Supporting institution: None

Start date: Not specified                          End date: 15 March 2015

Commitment aim

The Pro-Ethics Company Registry is an initiative to improve corporate ethics, integrity, and transparency by publicly recognizing companies that commit to fighting corruption and other types of fraud. Companies submit information on their anti-corruption practices, and the best scoring companies receive an “ethics accreditation.” The commitment attempted to improve the registry’s tools and policies to encourage more companies to join the initiative.

Status

Midterm: Limited

The commitment had to be revised, as the Anticorruption Law (Law 12.846/2013) forced it to redesign the company registry’s principles and practices. The registry’s website was renovated, a new regulatory norm regarding the system’s restructuring was proposed, and a new evaluation survey was designed. However, company evaluations were suspended until the program was restructured.

End of term: Completed

Since the midterm report, the following improvements were made to the program in fulfillment of the commitment:

•The questionnaire used to obtain information from companies about their practices was revised to include the latest requirements enacted by the Anticorruption Law.^{[Note 112: Ministerio da Transparencia Fiscalizacao e Controladoria-Geral da Uniao, Empresa Pró-Ética, Histórico, http://bit.ly/2nc6ekJ. ]}

•The program website was updated to disclose the most recent regulations and requirements for companies desiring certification.^{[Note 113: Ministerio da Transparencia Fiscalizacao e Controladoria-Geral da Uniao, Empresa Pró-Ética, Regulamento, http://bit.ly/2oD0YH6. ]}

•A new communications strategy was employed. This included hosting two Clean Business (Empresa Limpa) conferences to share the results of the accreditation process.^{[Note 114: Ethos Institute, “CGU promove a 2a Conferência Lei da Empresa Limpa,” 9 November 2015, http://bit.ly/2nLv8Ed ]}

•The Brazilian Institute of Ethical Competition (ETCO) joined the committee that reviews applications.

•The registration and accreditation of new companies was reopened in 2015, and continued in 2016.^{[Note 115: Office of the Comptroller General, “Pró-Ética 2016: Empresas têm até 13 de maio para solicitor adesão,” 1 March 2016, http://bit.ly/1WUOfXg. ]}

Did it open government?

Access to information: Marginal

Civic participation: Marginal

Public accountability: Did not change

The Pro-Ethics Company Registry program evaluates and highlights firms engaged in best practices in integrity and anti-corruption. The commitment’s objective was to expand the scope of the initiative by remodeling the submission of candidacies and investing in awareness-raising for registered companies and the program’s results. In this sense, the results of the commitment were quite positive, as changes to the program significantly expanded the number of companies listed in the registry. In 2016, 195 companies applied for the system, as opposed to 170 between 2011 and 2013, and 97 in 2015. The number of businesses evaluated also rose from 33 in 2015 to 74 in 2016.^{[Note 116: Office of the Comptroller General, “Pró-Ética em Números,” 23 January 2017, http://bit.ly/2o4zite. ]}

These results mark an improvement in access to information because they provide citizens with more information on which businesses are following best practices, and how they scored on publicly available transparency and integrity criteria. In terms of civic participation, ETCO’s integration into the selection committee represents a growing partnership between the government and civil society in managing the program and applying the accreditation criteria (the program is co-led by the Office of the Comptroller General and the Ethos Institute).

It should be noted that the Pro-Ethics Company Registry was launched in 2010, before the start of the action plan. Hence, even though the program has raised awareness of the certified businesses and expanded the number of applicants, the improvements made during the action plan represent incremental improvements to an existing program. In addition, although the commitment is an important corporate accountability initiative, it does not contribute to greater government accountability, which is why there was no change in public accountability.

Carried forward?

The commitment is not included in the next action plan. If carried forward in the future, the IRM researcher suggests publishing the scores and results of business applicants, as well as creating accountability mechanisms for civil society to monitor the registered companies.