The Office of the Federal Controller General (CGU in Portuguese) launched, on April 15, 2025, the 2025-2026 edition of the Pro-Ethics Company Program (Programa Empresa Pró-Ética - “Pro-Ethics” or “Program”), featuring innovations compared to the previous edition of 2022-2023. The Pro-Ethics Program is an initiative from CGU to encourage companies to voluntarily adopt integrity measures.
The 2025-2026 edition of the Pro-Ethics Program increases the number of topics under analysis compared to previous editions, including socioenvironmental responsibility and the defense of human rights among the requirements. This wider concept of corporate integrity, which goes beyond the fight against corruption, reflects global trends such as those from the G20, the UN, the OECD, and the European Union.
We highlighted below the main updates of the Program, including a comparison between the editions of 2022-2023 and 2025-2026.
Eligibility:
2025-2026: Non-profit organizations, entities of “System S”[1] (Sistema S), political parties, and law firms, among others, are no longer eligible[2].
Inclusion of Socioenvironmental Topics and Human Rights
2022-2023: Socioenvironmental responsibility was linked to transparency actions, such as publishing sustainability reports/integrated reports, when conducted by the company, on the company's website, and information on the integrity program.
2025-2026: Inclusion of specific criteria related to the socioenvironmental and human rights agenda, such as:
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Presentation of a contingency plan, based on a risk matrix and approved by top management, to deal with events and emergencies related to climate change that may affect the continuity of the company's operations;
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Evidence of preventive and mitigating measures implemented or planned to deal with future events related to climate change that have occurred in the last 5 years;
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Presentation of policies and procedures for the treatment and sustainable disposal of solid waste, effluents and gases generated in administrative and/or production activities, considering the environmental impacts of the company’s activities – approved by top management and widely disseminated; and
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Participation in initiatives or dissemination, to the external public, of actions that promote the protection of human rights and preservation of the environment, and mitigation or adaptation to climate change – proved by publishing, to the external public, articles in newspapers, interviews, press releases, messages on the company's website and social media. Also, the company must adhere, by adding its signature, to collective actions related to the promotion of human rights and environmental preservation.
Diversity and Inclusion
2022-2023: The topic Diversity and Inclusion was only one of the points to be addressed in the company’s Code of Ethics and Conduct.
2025-2026: Inclusion of objective criteria for evaluating diversity, equity, and inclusion policies. Examples from the Application Form:
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Diversity and Inclusion Policy or Norm implemented by top management;
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Qualification or training conducted by top management to work appropriately on issues related to fighting prejudice, discrimination, and harassment of any kind (including curriculum, attendance lists, training support materials, pictures, videos, and certificates);
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Clear messages from top management to employees, society, market, and stakeholders, reinforcing the company’s commitment to fighting prejudice, discrimination, and harassment of any kind;
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Conduction of general training for employees to fight prejudice, discrimination, and harassment of any kind.
In addition to the changes above, as a way of integrating the Pro-Ethics Program into a broader agenda for promoting integrity, the new cycle requires prior adherence to Brazil Pact for Business Integrity (Pacto Brasil pela Integridade Empresarial). For further details on Brazil Pact, please click here to access our Newsletter on the subject.
Those interested in participating in the Program must meet the deadline to register for the 2025-2026 cycle, which began on May 5, 2025, and ends on June 5, 2025. Companies should also be aware of the program's admissibility requirements.
TozziniFreire's Compliance and Investigation team is available to assist clients in this process.
[1] Reference in Portuguese to group of private entities that provide public interest services but are not part of the government.
[2] “Art. 1 (...) § 5. Non-profit Organizations, Class Entities or Trade Unions, Religious Organizations, Foundations, Specific Purpose Entities (SPE) with no economic activity, Consortia, Recreational Clubs, Notary and Registry Offices, Social Assistance Entities, Political Parties, Class Representative Entities, Non-Profit Recreational Clubs and Associations, Law firms, State, District and Municipal Owned Companies and “System S” Entities cannot join the program”.
