Adherence to the compliance program of Brazil’s anti-corruption law and internal controls implementation

ABSTRACT The aim of this study is to investigate the adherence of Brazilian publicly listed companies to the parameters of the anti-corruption law compliance program as well as its association with internal controls implementation. In light of the accounting scandals and corporate frauds reported in several countries, including Brazil, Law n. 12,846, known as the anti-corruption law, was approved on August 1st, 2013, and Decree n. 8,420, approved on March 18, 2013, regulated this law and defined criteria for the functioning of compliance programs. Considering that compliance programs can affect internal controls, it is important to understand the adherence of companies to their parameters as well as identifying the internal controls derived from them. The findings show a substantial degree of adherence among listed companies to the parameters of the compliance program. Additionally, the results revealed the existence of new internal controls, such as the emergence of the “compliance officer” function. A survey in the form of a questionnaire was adopted. The questionnaire was sent to companies associated with ABRASCA (Brazilian Association of Publicly Listed Companies). The final sample included 32 publicly listed companies. Paraconsistent logic was applied to analyze the data. This paper contributes by empirically showing that, in Brazil, publicly listed companies are adherent to the anti-corruption law. Furthermore, this paper reveals that higher levels of adherence to compliance programs are associated with greater implementation of internal controls.