1. The Public Integrity System in the Brazilian Federal Executive Branch

The OECD defines public integrity as the consistent alignment of, and adherence to, shared ethical values, principles and norms for upholding and prioritising the public interest over private interests in the public sector (OECD, 2017[1]). An integrity system, whether at the government (national and sub-national) or organisational level, includes different actors with responsibilities for defining, supporting, controlling and enforcing public integrity. These include the “core” integrity actors, such as the institutions, units or individuals responsible for implementing integrity policies, but also “complementary” integrity actors with key support functions such as finance, human resource management and public procurement (OECD, 2020[2]; OECD, 2017[1]).

For both the core and complementary integrity actors, there are a number of integrity functions, as laid out in Table 1.1. The assignment of responsibilities related to public integrity depend on the institutional and jurisdictional setup of a country. For example, some countries give core responsibilities for integrity with a central government body or other key ministry, whereas others will make this the responsibility of an independent or autonomous body. Typically, complementary integrity functions are assigned to the institutions responsible for education, industry, civil society and human resource management, as well as supreme audit institutions, regulatory agencies, and electoral bodies.

In Brazil, there are several integrity actors, co-ordination mechanisms and a variety of relevant legislation and policies that cover the different functions of an integrity system as outlined in Table 1.1. Box 1.1 provides a concise overview, focusing only on the most relevant elements. Additional complexity arises, as Brazil is a federal republic as well as a large and heterogeneous country. The federal system includes 26 states, a Federal District and over 5 000 different municipalities. Each level is autonomous in legislating and providing services, as long as these do not conflict with the powers exclusively provided or legislated by the Federal Union. Brazil is also one of the world’s most populous countries with over 200 million inhabitants, the fifth largest country in the world with a territory almost as big as Europe, as well as one of the largest global economies.

As outlined in the OECD Recommendation on Public Integrity, the variety of actors require establishing clear responsibilities and mechanisms for co-operation. The responsibilities at the relevant levels (organisational, subnational and national) for designing, leading and implementing the elements of an integrity system need to be clear. In addition, mechanisms to promote horizontal and vertical co-operation between the integrity actors and where possible, with and between subnational levels of government, support coherence and avoid overlap and gaps within the system (OECD, 2017[1]). For Brazil, these arrangements and challenges will be analysed in a forthcoming OECD Integrity Review (OECD, forthcoming[5]), which will build upon previous OECD work with Brazil (OECD, 2012[4]; OECD, 2017[6]; OECD, 2013[7]; OECD, 2020[8]).

This report contributes to this analysis by focusing on the specific challenge of mainstreaming integrity policies throughout the federal executive in Brazil. In line with the OECD Recommendation on Public Integrity, this mainstreaming should go beyond a formal compliance with the existing regulations but achieve real change in behaviours (Rangone, 2021[9]). In many countries, gaps often exist between what the legislation or policies stipulate and what is put into practice in the day-to-day work of a public entity. In particular, the challenge involves translating and anchoring standards into organisational realities to achieve effective changes in organisational cultures and the behaviour of public servants. This report reviews the ongoing efforts of the Office of the Comptroller General of the Union (Controladoria Geral da União, CGU) to mainstream public integrity policies across the Federal public administration and provides concrete recommendations for managing integrity risks and promoting cultures of organisational public integrity (OECD, forthcoming[10]).

Integrity is the responsibility of all public servants. In particular, integrity leadership at all levels is essential to demonstrate a public sector organisation’s commitment to integrity; with their function of being ethical leaders and providing an example, they play a crucial part in the effective promotion of an integrity culture (OECD, 2017[1]; OECD, 2009[11]; OECD, 2020[2]; OECD, forthcoming[12]). For example, in Colombia, the Integrated Planning and Management Model (Modelo Integrado de Planeación y Gestión, MIPG) requires managers to periodically report on their actions related to integrity, transparency and other cross-cutting issues (Función Pública, 2017[13]). In France, senior management are personally responsible and ultimately accountable for the effective implementation and promotion of an organisation’s integrity programme (Agence Française Anticorruption, 2020[14]).

Nonetheless, dedicated “integrity actors” in public entities can contribute to overcome the challenge of mainstreaming integrity policies to ensure implementation in public entities and to promote organisational cultures of integrity. International experience shows the value of having a specialised and dedicated person or unit that is responsible and held accountable for the internal implementation and promotion of integrity laws and policies (OECD, 2009[11]; G20, 2017[15]; OECD, 2019[16]).

Recognising this challenge, Brazil undertook two major initiatives over the past decades:

  • In 2007, the Ethics Management System of the Federal Executive Branch (Sistema de Gestão da Ética do Poder Executivo federal, SGEP) has been established through Decree 6029/2007.

  • In 2021, the Public Integrity System of the Federal Executive Branch (Sistema de Integridade Pública do Poder Executivo Federal, SIPEF) has been established through Decree 10756/2021.

While the Ethics Management System applies to the whole of the Federal executive branch, including the entities of the indirect administration, the SIPEF currently covers bodies and entities of the direct, autarchic and foundational administration (administração direta, autárquica e fundacional) (Box 1.2).

In 1994, Brazil introduced the Code of Professional Ethics of the Public Servant of the Federal Executive Branch (Código de Ética Profissional do Servidor Público Civil do Poder Executivo federal, Decree 1171/1994). The Code requires establishing Ethics Commission (Comissões de Ética) in every entity of the Federal executive to support its mainstreaming and implementation. Each Ethics Commission has three sitting members and three alternates, chosen from among public servants of its permanent staff and appointed by the highest officer of the respective entity or body for non-coinciding terms of three years. The Ethics Commissions are required to have an Executive Secretariat headed by a civil servant or employee of the permanent staff of the entity, occupying a management position compatible with its structure, the technical and material support necessary to comply with its attributions (Decree 6029/2007).

The Ethics Commissions are responsible to guide and advise public officials on professional ethics, to build awareness of consequences of ethical breaches and to receive notice of possible breaches. They provide information to the human resources department about the ethical record of public officials through their career development and can issue a reprimand (censura) in case of breaches to the Code.

In 2007, the Ethics Commissions were incorporated into the Ethics Management System of the Federal Executive Branch (Decree 6029/2007), which has the following objectives:

  • linking the agencies, programmes and actions related to public ethics

  • contributing to the implementation of public policies using transparency and access to information as fundamental instruments for the exercise of public ethics management (see also the Open Government Review of Brazil (OECD, forthcoming[3]))

  • promoting compatibility and coherence of standards, technical and management procedures related to public ethics

  • developing actions to establish and implement procedures to encourage and enhance institutional performance in the management of public ethics in the Brazilian government.

A recent evaluation of the SGEP, carried out amongst other through the application of the Ethics Management Evaluation Questionnaire in June-July 2020 to which 117 Commissions responded, evidenced that 88% of the Commissions have an Executive Secretary in place. Of these, 29% have exclusive dedication, 31% hold a managerial position, 62% are having their own space and 58% have established a work plan (Comissão de Ética Pública, 2021[17]). These results show that while the SGEP advanced in its implementation, it still faces challenges, especially outside of the state owned enterprises. Interviews carried out for this OECD report underscored that often a main weakness is a lack of support by the highest authorities.

In turn, the Public Ethics Commission (Comissão de Ética Pública, CEP, Box 1.3), established in 1999, coordinates, evaluates and supervises the Ethics Management System. Since 2000, the CEP has been responsible for implementing and enforcing the Code of Conduct of the High Federal Administration and providing advice on conflict of interest. In addition, the CEP monitors and conducts an annual evaluation of the implementation of ethics management system in the Federal Executive Branch. The CEP can conduct technical visits, which are on-site initiatives to disseminate and assess the progress in adopting actions to establish a more effective ethics infrastructure. Furthermore, the CEP has been promoting and providing various training courses, including the Course on Management and Investigation of Public Ethics and the International Seminar on Ethics in Management, for example.

A second key element of the normative framework on public integrity is Law 12813/2013 on managing conflict of interest in the federal executive branch. The Law applies to all public officials within the federal executive. However, its scope is currently limited to the divulgation or use of privileged information and to pursuing private external activities that are incompatible with the current public position and functions. Nonetheless, the use of privileged information has not been regulated yet for public servants that do not belong to the higher administration as defined in the Law. A preliminary analysis indicates that the conflict-of-interest framework could be improved taking into account the standards of the OECD (2004[18]). The forthcoming OECD Integrity Review will review this aspect in depth (OECD, forthcoming[5]).

Furthermore, under the current framework, the competence to provide guidance and opinions in case of doubts concerning (potential) exercise of private activity that is not expressly prohibited, as well as to supervise and formally assess conflict of interest situations, has been divided between the CEP and the CGU. Currently, the CEP is responsible for public officials belonging to the high administration and the CGU for all other public servants.

The CGU is the internal control body of the Federal Government and, since its creation in 2001, has been a core element of the federal government’s strategy to enhance integrity and prevent corruption in Brazil (OECD, 2012[4]). The CGU has responsibilities in a number of core and complementary integrity functions, as outlined in Table 1.1, such as promoting public integrity, contributing to the framework for managing conflict of interest, preventing and fighting corruption, supporting integrity risk management, internal control and audit, disciplinary enforcement as well as ombudsman functions, promoting social control and transparency.

In particular, the CGU is responsible for leading the mandatory Integrity Programmes to prevent, detect, punish and remediate corruption, fraud, illicit acts and violations of the standards of ethics and conduct in all public entities of the Federal Executive. Decree 9203/2017 introduced the Integrity Programmes that were subsequently regulated through Ordinance 1089/2018 and Ordinance 57/2019. Integrity Programmes have to be developed along the following axes:

  • Commitment and support from senior management.

  • Existence of a unit responsible for implementation in the organ or entity.

  • Analysis, evaluation and management of risks associated with integrity.

  • Monitoring of the elements of the Integrity Programme. 

Integrity Programmes aim to ensure that internal units responsible for integrity-related activities and areas such as corruption prevention, internal audit, disciplinary enforcement and transparency work together in co-ordination to ensure integrity and minimise integrity risks. As such, the Integrity Programmes focus on prevention and aim at reducing integrity risks in public entities. Developing an Integrity Programme implies going beyond ensuring formal compliance with Laws and regulations and should aim at promoting cultures of integrity within the public entities.

The CGU established procedures for developing, implementing and monitoring these Integrity Programmes, such as the 2017 Manual for the Implementation of Integrity Programmes or the 2018 Practical Guide for Implementing a Programme of Integrity. Currently, the CGU is carrying out an evaluation of the Integrity Programmes. Some preliminary results have informed the findings of the report through the discussions with CGU staff.

The first mandatory step of an Integrity Programme is establishing an Integrity Management Unit (Unidade de Gestão da Integridade, UGI) within the public entity. The UGI coordinates the development of the internal Integrity Plan of the public entity, as well as its subsequent implementation, monitoring and evaluation. These Integrity Plans need to be approved by senior management and set out the integrity measures and an action plan for their implementation.

Key elements required in the integrity plans include (Ordinance 57/2019):

  • a description of the body or entity

  • establishment of the integrity units

  • assessment of the integrity risks and measures to address them

  • provisions for monitoring and the periodic updating integrity plans.

Since 2017, the CGU has supported the establishment of UGIs and the elaboration of integrity plans in all 186 entities of the Federal Executive government. The recent Public Integrity System of the Federal Executive Branch (SIPEF), established in July 2021, further formalises and strengthens the normative basis for the Integrity Programmes and the UGI and therefore for promoting integrity throughout the Brazilian Federal Executive. The SIPEF establishes the UGI as the systems’ responsible sectorial units, expanding their functions and responsibilities (Box 1.4). These responsibilities could be summarised as articulating different integrity efforts within the entity, but also include providing guidance, training and support on matters related to public integrity and integrity risk management.

As mentioned above, the CGU has a shared responsibility in the management of conflict of interest. Indeed, to facilitate the management of conflict of interests, public servants can send to the human resources unit of their entities a request for consultation on possible conflict of interest situations. In case the public entity concludes that there is a potential conflict of interest situation, the consultation is automatically forwarded to the CGU. These consultations are submitted through the Electronic System for Conflict of Interest Prevention (Sistema Eletrônico de Prevenção de Conflito de Interesses, SeCI, Box 1.5).

Both the Ethics Management and more recently the Public Integrity System are responses to the mainstreaming challenge. Nonetheless, the fact-finding of the OECD, that involved a survey, interviews and focus group discussions as well as an in-depth review of the relevant Brazilian legislation and policy documents, evidenced some challenges related to the design and implementation as well as overlaps or unclear responsibilities in particular in relation to the promotion of public integrity cultures and managing integrity risks. As mentioned above, while public integrity has many elements and typically involve different actors and units, there also needs to be coherence and clarity with respect to the promotion of integrity at entity level to avoid potential mixed messages or confusion amongst public servants.

While the conceptual debate is complex, both “ethics’ and “integrity” are aiming at promoting high standards of behaviour of public servants. In fact, the OECD uses “ethics management” and “integrity management” as synonyms. While earlier OECD publications refer to “ethics”, recent publications prefer the term “integrity”, indicating a shift to modern styles of integrity management that combine rules-based with values-based approaches (OECD, 2009[11]). In fact, the 2017 OECD Recommendation on Public Integrity has been the result of a process reviewing the 1998 Recommendation of the OECD Council on Improving Ethical Conduct in the Public Service, which by then provided for the first time guidance to policy makers on the management of ethics in the public sector. The Recommendation on Public Integrity incorporates this perspective by calling adherents to set high standards of conduct for public officials, while opening the scope to provide policy makers with a vision for a context dependent, behavioural, risk-based approach to public integrity that emphasises the relevance of cultivating culture of integrity across the whole of society (OECD, 2017[1]).

In the end, what matters more than the term is the definition of the concept, its operationalisation and ability to achieve impact in terms of behavioural change. Integrity – or ethics – management aim to promote integrity and prevent integrity violations (OECD, 2009[11]). Public integrity ensures a consistent alignment of, and adherence to, shared ethical values, principles and norms for upholding and prioritising the public interest over private interests in the public sector (OECD, 2017[1]). However, the co-existence of two systems in Brazil with essentially the same goal implies complexity and opacity, comes with a serious risk of overlaps, sending mixed messages and a lack of clarity with respect to responsibilities, especially regarding trainings and guidance on values, ethical dilemmas and conflict of interest situations. Indeed, the fact-finding evidenced that that the co-existence of an ethics system and the integrity programmes (and now the SIPEF) comes along with some misunderstandings and confusion amongst public servants.

Brazil could therefore clarify and streamline the responsibility and the concepts aimed at promoting cultures of organisational integrity in the Federal Executive by moving the responsibilities for supporting the management of public ethics and the managing conflict of interest from the ethics management system to the SIPEF and its institutions. This reform could provide the opportunity to broaden the scope of application of the SIPEF to the whole federal executive administration (Box 1.2). In turn, in close co-ordination with the SIPEF, the CEP could be maintained as an advisory body to the President of the Republic and to the Ministers of State and to oversee and promote the application of the current Code of Conduct of the High Federal Administration. By the time of the drafting of this report, an inter-institutional working group has been working on revising both the Code of Professional Ethics and the Code of Conduct of the High Federal Administration. This ongoing revision provides an opportunity to further clarify and streamline the guidance provided to public servants (see Chapter 2).

The OECD Recommendation on Regulatory Policy and Governance emphasises that governments should ensure that regulations are comprehensible and clear and should identify and reform overlapping regulations (OECD, 2012[21]). In addition, as emphasised in the OECD report on Applying Behavioural Insights to Public Integrity, the clarification of responsibilities across the public sector not only increases the effectiveness of an integrity system, but can also strengthen the integrity of individual decision makers (OECD, 2018[22]). Indeed, behavioural insights associated with simplification, convenience and salience, would suggest that many existing regulations may themselves be too complex and cumbersome to be effective (Lunn, 2014[23]). By streamlining the integrity and ethics systems as recommended, Brazil could simplify the presentation of what matters to promote a culture of integrity and limit the number or complexity of concepts associated with it. This streamlining will also help to promote the salience of the concept of public integrity. Evidence suggests that as human beings, public servants can pay attention to a limited number of attributes associated with any given option in front of them (Lunn, 2014[23]). Making the concept of integrity salient will facilitate communication on integrity-related matters and provide clarity with respect to key elements of integrity policies such as managing conflicts of interest, promoting open cultures of organisational integrity, integrity risk management or dealing with ethical dilemmas, i.e. dilemmas arising due to legal grey areas and/or conflicting values (Chapter 2).

Finally, Brazil should consider reviewing the coherence and alignment of the new SIPEF in terms of connections and concepts with the following federal systems that are related to public integrity (see also forthcoming Integrity Review of Brazil (OECD, forthcoming[5])):

  • the Internal Control System of the Federal Executive Branch (Sistema de Controle Interno do Poder Executivo Federal, SCI) to align concepts related to risk management, internal control and audit

  • the Administrative Disciplinary System of the Federal Executive Branch (Sistema de Correição do Poder Executivo Federal, SISCOR) to ensure the enforcement of integrity breaches

  • the Ombdusman System of the Federal Executive Branch (Sistema de Ouvidoria do Poder Executivo Federal) for aspects related to consulting and receiving reports and feed-back from citizens and users of public services in relation to public integrity (for an in-depth analysis on the shortcomings of the current system, see the OECD Open Government Review (OECD, forthcoming[3])).

As described above, the Ethics Commissions are currently responsible at the level of public entities for guiding and raising awareness on public ethics as well as for receiving notice of possible breaches of the Code of Professional Ethics.

However, the Ethics Commissions in Brazil suffer from similar weaknesses as identified in other countries with comparable arrangements (OECD, 2017[24]; OECD, 2021[25]; OECD, 2019[26]):

  • First, the organisation as a commission comes along with inherent challenges. The members of the Ethics Commissions are selected among the staff from the federal entity on a temporary basis, often do not have any previous experience in the subject matter and require specialised training to fulfil effectively their tasks. In Brazil, the CEP provides such trainings. However, given that members are selected for three, maximum six years, it is difficult to establish experience, which affects learning, continuity and effectiveness of the Ethics Commissions. The rotation makes it also difficult to establish a “visible” face for integrity in the public entity and could undermine the establishment of trust that is required to fulfil credibly the function of advising on often sensitive issues. Furthermore, given that being a member of the Commission is an additional task without additional remuneration, the work on promoting ethics will often be only the second priority or depend strongly on the motivation of the selected individuals.

  • Second, the fact that the Ethics Commissions in Brazil can receive reports about potential breaches and issue reprimands (censura) is mixing prevention with enforcement related tasks. This does not make them the best place to provide public officials a safe place where they can seek guidance about ethical dilemmas or situations where they may have committed an error (OECD, 2018[22]). The unit or person in charge of providing advice should not be involved in any tasks related to investigation or sanctioning of integrity breaches, but rather be a safe haven where employees can speak up and ask questions without fearing direct repercussions. Moreover, confidentiality of the questions as well as the advice provided should be ensured to promote a trustworthy environment.

In turn, within the SIPEF, the UGI are responsible for promoting guidance and training on matters relating to the Integrity Programme and for supporting integrity risk management. With support from CGU, the UGI already played a key role in the process of identifying the new Values of the Federal Public Service and in promoting the campaign #IntegridadeSomosTodosNós. As such, the UGI are well placed to use the Values as an entry point to mainstream integrity into processes and day-to-day practice relevant in the context of their public entity and promote an open organisational culture of integrity (see Chapter 2).

As mentioned, the co-existence of the Ethics Commissions and the UGI, however, creates confusion amongst public servants. In line with the previous recommendation, Brazil could therefore consider transferring the preventive functions related to ethics and conflict-of-interest management from the Ethics Commissions to the UGI. From another perspective, this could be equivalent to transforming the Executive Secretariats of the Ethics Commissions into UGI with permanent and professionalised staff under the SIPEF, as has been recommended for the similar case of the federal level in Mexico (OECD, 2017[24]; OECD, 2019[26]).

However, while the UGI have the potential to become dedicated units with permanent and professionalised staff under the SIPEF, the current normative framework does not require this.1 The fact finding in the context of this project found that this comes along with challenges and weaknesses in delivering the mandate and functions of the UGI (Chapter 2). Box 1.6 provides some general arguments in favour of such a dedicated space for integrity in an organisation. Brazil could thus focus on strengthening the UGI by requiring them to be a dedicated unit and by aligning their organisational design with their mandate. Then, the role of the UGI within the SIPEF could be communicated clearly and it would be easier to invest into the required capacities and skills to co-ordinate, plan and monitor the Integrity Plans and provide support and guidance on ethical dilemmas, potential conflict of interests, integrity risk management and other questions related to public integrity. This would address the identified weaknesses, give public integrity a visible and dedicated place within the organisation, and contribute to improve both clarity and conceptual coherence of the institutional framework and entity level. Chapter 2 provides further recommendations on how to strengthen the UGI along these lines.

As already mentioned, the Ethics Commissions currently also receive complaints and reports concerning potential infractions against the Code of Professional Ethics, carry out preliminary fact-checking of complaints concerning and have the power to issue reprimands (censura) in case of breaches to the Code. These functions should not be transferred to the UGI to avoid mixing preventive functions with punitive elements; nonetheless, the UGI could articulate and assure the implementation of such elements related to detection and enforcement.

In fact, the legal framework regulating the civil service regime for all public officials in Brazil (Law 8112/1990) includes a list of duties and prohibitions, whose breach leads to disciplinary liability on top of the civil, criminal and administrative liability that may cumulatively apply. The CGU’s General Inspectorate for Administrative Discipline (Corregedoria-Geral da União) and, at entity level, the Federal Inspectorates (Corregedorias Federais) are the institutions competent to deal with such internal disciplinary cases; although they do not exist yet in all federal entities. Established in 2001, the inspectorates conducts investigations, either ex officio or upon receipt of a credible report, of possible misconduct by federal public officials. As the central unit of the Administrative Disciplinary System of the Federal Executive Branch (SISCOR), it co-ordinates, evaluates and supervises the activities of inspectorates and disciplinary committees within federal public organisations. Recently, the CGU updated the Disciplinary Procedures Management System (e-PAD), which is an online system aimed at storing and making available information on the disciplinary procedures of the Federal Executive Branch.

While an in-depth review of Brazil’s disciplinary regime is out of the scope of this report and will be carried out in the forthcoming OECD Integrity Review of Brazil, a preliminary analysis seems to indicate an overlap of the investigative and punitive function of the Ethics Commissions with Law 8112/1990 and the Federal Inspectorates. Depending on the degree of this potential overlap, and if the preventive functions are transferred to the UGI as recommended above, the Ethics Commissions would either cease to have any function or could maintained focusing only on their role to enforce the current Code of Professional Ethics. Nonetheless, this role need to ensure a close co-ordination with the Federal Inspectorates, articulated through the Integrity Programmes and the UGI.


[14] Agence Française Anticorruption (2020), The French Anti-Corruption Agency Guidelines, Agence française Anticorruption (AFA), Paris, https://www.agence-francaise-anticorruption.gouv.fr/files/2021-03/French%20AC%20Agency%20Guidelines%20.pdf (accessed on 20 September 2021).

[20] CGU (n.d.), Electronic System for Prevention of Conflict of Interest, https://seci.cgu.gov.br/SeCI/Login/Externo.aspx?ReturnUrl=%2fSeCI (accessed on 5 March 2021).

[17] Comissão de Ética Pública (2021), “BOLETIM INFORMATIVO do Sistema de Gestão da Ética do Poder Executivo Federal” 39, https://www.gov.br/planalto/pt-br/assuntos/etica-publica/sistema-de-gestao-da-etica/boletim-informativo/boletins-informativos-2021/BoletimInformativo39Outubro2021.pdf (accessed on 15 November 2021).

[13] Función Pública (2017), Modelo Integrado de Planeación y Gestión, https://www.funcionpublica.gov.co/web/mipg (accessed on 20 September 2021).

[15] G20 (2017), G20 High Level Principles on Organizing Against Corruption, http://www.g20.utoronto.ca/2017/2017-g20-acwg-anti-corruption.html.

[23] Lunn, P. (2014), Regulatory Policy and Behavioural Economics, OECD Publishing, Paris, https://dx.doi.org/10.1787/9789264207851-en.

[25] OECD (2021), OECD Integrity Review of the State of Mexico: Enabling a Culture of Integrity, OECD Public Governance Reviews, OECD Publishing, Paris, https://dx.doi.org/10.1787/daee206e-en.

[8] OECD (2020), Auditing Decentralised Policies in Brazil: Collaborative and Evidence-Based Approaches for Better Outcomes, OECD Public Governance Reviews, OECD Publishing, Paris, https://dx.doi.org/10.1787/30023307-en.

[2] OECD (2020), OECD Public Integrity Handbook, OECD Publishing, Paris, https://dx.doi.org/10.1787/ac8ed8e8-en.

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[16] OECD (2019), La Integridad Pública en América Latina y el Caribe 2018-2019: De Gobiernos reactivos a Estados proactivos, OECD, Paris, https://www.oecd.org/gov/ethics/integridad-publica-en-america-latina-caribe-2018-2019.htm.

[22] OECD (2018), Behavioural Insights for Public Integrity: Harnessing the Human Factor to Counter Corruption, OECD Public Governance Reviews, OECD Publishing, Paris, https://dx.doi.org/10.1787/9789264297067-en.

[6] OECD (2017), Brazil’s Federal Court of Accounts: Insight and Foresight for Better Governance, OECD Public Governance Reviews, OECD Publishing, Paris, https://dx.doi.org/10.1787/9789264279247-en.

[24] OECD (2017), OECD Integrity Review of Mexico: Taking a Stronger Stance Against Corruption, OECD Public Governance Reviews, OECD Publishing, Paris, https://dx.doi.org/10.1787/9789264273207-en.

[1] OECD (2017), OECD Recommendation of the Council on Public Integrity, OECD, Paris, http://www.oecd.org/gov/ethics/Recommendation-Public-Integrity.pdf.

[7] OECD (2013), Brazil’s Supreme Audit Institution: The Audit of the Consolidated Year-end Government Report, OECD Public Governance Reviews, OECD Publishing, Paris, https://dx.doi.org/10.1787/9789264188112-en.

[4] OECD (2012), OECD Integrity Review of Brazil: Managing Risks for a Cleaner Public Service, OECD Public Governance Reviews, OECD Publishing, Paris, https://dx.doi.org/10.1787/9789264119321-en.

[21] OECD (2012), Recommendation of the Council on Regulatory Policy and Governance, OECD/LEGAL/0390, https://legalinstruments.oecd.org/en/instruments/OECD-LEGAL-0390.

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[12] OECD (forthcoming), Behavioural Insights for Public Integrity: Strengthening integrity leadership in Brazil’s federal executive branch, OECD Publishing, Paris.

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[3] OECD (forthcoming), Open Government Review of Brazil, OECD Publishing, Paris.

[9] Rangone, N. (2021), “Making Law Effective: Behavioural Insights into Compliance”, European Journal of Risk Regulation, Vol. 9, pp. 483-501, http://dx.doi.org/10.1017/err.2018.51.

[19] UNDOC (2018), Provision of Technical Assistance by G20 Anti-corruption Working Group Countries. Information Provided by Brazil., https://www.unodc.org/documents/corruption/G20TechnicalAssistance/PROVISION_OF_TECHNICAL_ASSISTANCE_BY_BRAZIL_on_G20_ACWG.pdf (accessed on 5 March 2021).


← 1. Even though, in fact, the Ordinance 57/2019 talks about “constituting” UGI, which is ambiguous and could mean to “set up”, to “establish” or to “create”.

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