The initial assessment considers the company’s activities, size, governance structure and exposure to legal and regulatory risks. Mapping these risks informs integrity programs, action plans, codes of conduct and risk management policies. We work with the teams involved to define priorities, responsibilities and deadlines, so that measures can be implemented and reviewed as the business changes.
For financial and capital markets and public procurement in Brazil, advice takes account of each organization’s regulatory status and the rules governing its activities. The work covers policies on anti-corruption, conflicts of interest, dealings with public officials, third-party due diligence, disclosure and securities trading. It also includes measures to prevent money laundering, terrorist financing and the financing of proliferation of weapons of mass destruction, according to each participant’s obligations.
Board members, directors and managers receive guidance on applying policies, documenting decisions and addressing matters that require legal assessment. We support plan implementation, control reviews and responses to regulatory changes, working with internal teams and other specialists. Training, indicators and reports help identify gaps, assign corrective actions and bring relevant matters to management’s attention.
We help establish reporting channels and procedures for receiving, screening and investigating reports. Internal investigations and incident response take account of professional confidentiality, data protection, lawful preservation of evidence and proportionality. The process addresses restricted access to information, impartiality, protection against retaliation and the rights of those involved. Legal assessment informs corrective measures and any appropriate or required reports to authorities.
Scope of Work
- Design, implementation and review of compliance programs and integrity plans.
- Risk management policies, responsibility matrices, controls and action plans.
- Codes of conduct and policies on anti-corruption, conflicts of interest, gifts and hospitality.
- Disclosure and securities trading policies under the applicable regulatory framework.
- Compliance and anti-money laundering, counter-terrorist financing and counter-proliferation financing policies, according to the activity.
- Integrity in public tenders and contracts, dealings with public officials and third-party due diligence.
- Advice to board members, directors and managers, and training for teams.
- Reporting channel design, initial assessment of reports and procedures to protect against retaliation.
- Internal investigations, incident response, corrective measures and assessment of reporting to authorities.
- Program monitoring, legal review of controls, policy updates and management reporting.
In Practice
Is a compliance program limited to drafting policies?
No. The work can cover assessment, priorities, implementation, training and ongoing support. Policies need to assign responsibilities and work in daily operations, including receiving reports, reviewing facts and implementing corrective measures.
For an Initial Discussion
Describe the sector, organization size, regulated activities and existing controls. Indicate whether the need is to establish a program, review policies, address a requirement or handle a specific matter.
Contact the firm.