On October 15, 2024, the Brazilian Office of the Comptroller General (Controladoria-Geral da União or “CGU”) published Volume II of its Integrity Program Guideline for Private Companies (“Manual Programa de Integridade: Diretrizes para Empresas Privadas” or “Guideline”), which sets new recommendations for implementing, improving and monitoring integrity programs based on recent legislative updates and new market practices regarding integrity and environmental, social and corporate governance (“ESG”) matters.
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