INTEGRITY
CORPORATE

In this context, we highlight the Law 12.846/2013, of 1st of August, 2013, known as Anticorruption Law or Clean Company Law, that creates in Brazil the administrative and civil objective responsibility of companies when performing harmful acts for its own interest or benefit, against national or foreign public administrations. Besides its punitive aspect, the cited law also attaches special importance to anticorruption measures adopted by a company which might be taken into account as a mitigating factor in eventual accountability implications. Later, in 2015, the 8.420/2015 Decree, of 18th of March 2015, was enacted, which regulated the 12.846/2013 Law. The aforementioned Decree defined in its Article # 41, what a Integraty Program is, which has as focus anticorruption measures adopted by the company, specially the ones which aim at the prevention, detection and remediation of harmful acts against national and foreign public adminsitrations.

Companies that already have a compliance program, meaning a structure for the proper compliance with laws in general, should work towards integrating anti-corruption measures into the existing program or actions. Even companies that have or implement measures of this nature, especially to comply with foreign anti-bribery laws, must pay attention to the need to adapt them to the new Brazilian law, particularly to reflect concerns about the occurrence of fraud in public bids and contract execution with the public sector.

The Comptroller General of the Union (CGU) established, in the same year, Portaria nº 909 - Integrity Program, containing guidelines for private companies to develop, implement, or enhance their Integrity Program.

The Integrity Program is a specific compliance program for the prevention, detection, and remediation of harmful acts provided for in Law 12.846/2013, which focuses not only on bribery but also on fraud in public bidding processes and contract execution with the public sector.

In addition to its punitive nature, the mentioned Law also attaches special importance to the anti-corruption measures adopted by a company, which may be recognized as a mitigating factor in a potential liability process.

The Integrity Program, defined by CGU, is structured on five pillars:

1) Commitment and support from top management;
2) Responsible body for the Integrity Program;
3) Profile and risk analysis;
4) Structuring of rules and instruments;
5) Strategies for continuous monitoring.

Each Integrity Program must be tailored to meet the company's needs, taking into account its characteristics and business area risks.

Aware of the aforementioned guidelines and all government efforts to combat corruption, CRA Infra is committed to enhancing and improving its integrity actions, which will be consolidated into a program as envisioned and recommended by CGU.

Our internal area responsible for these activities is currently handling CRA Infra's Quality Management System.

Corruption is an evil that affects everyone. Governments, citizens, and companies suffer daily from its effects. Combating it, therefore, relies on the joint and continuous efforts of all, including companies, which play an extremely important role in this context.

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