On November 30, 2018, the Administrative Council for Economic Defense (“CADE”) published the agency's Compliance and Integrity Program1, which sets out measures to prevent, detect and remedy institutional risks. The risk management effort aims to reduce or eliminate the occurrence of illegal or unethical acts that could jeopardize the achievement of objectives defined by CADE.
The Program has been segmented into the following topics: information on the institution, including the entity's main competencies and compliance management structures; general provisions about the compliance management unit; risks and remedy measures; and considerations on the periodic monitoring and updating process regarding the actions and results of the Program.
CADE's compliance management actions provided for in the Program focus on issues such as conflicts of interest, codes of conduct for employees, active transparency, nepotism, and the implementation of accountability procedures.
The document also outlines the principles, guidelines and minimum responsibilities that must be observed for compliance, risk and internal control management of the strategic plans, programs, projects and processes conducted by CADE.
It should be noted that the agency's compliance and integrity agenda is part of the Governance, Compliance Management, Risks and Controls Policy, established by CADE Ordinance No. 283, published in May 2018. The project is also aligned with the Strategic Planning of the antitrust agency for the 2017-2020 period.