Governance and Sustainability in Mining: Restructuring Integrity After Socio-Environmental Disaster

Beatriz de Souza Lima Miranda; Thais Helena Zero de Oliveira Pereira

DOI: 10.22167/2675-6528-202602707

Article derived from a Final Course Work (TCC), with content based on the student’s original work and adapted to the editorial format of the E&S Magazine with the support of the ResumeAI tool, an artificial intelligence solution developed by the Pecege Institute for textual synthesis and organization.

Abstract

The growing relevance of Environmental, Social and Governance (ESG) criteria has been redefining corporate governance models, especially in sectors with high socio-environmental impact, such as mining. In this context, the study aimed to analyze the corporate governance restructuring process and ESG strategies in an organization in the mineral sector, focusing on the transition from a symbolic compliance model to integrated risk management. Methodologically, the research was characterized as qualitative and exploratory, using a single case study and documentary research as technical procedures, with data analysis based on the Content Analysis technique. The results showed that the organization operated under a paper compliance model, in which documentary compliance was not accompanied by practical effectiveness, contributing to the occurrence of systemic failures in risk management. After the critical event analyzed, the implementation of restructuring measures was observed, including the strengthening of control mechanisms, the creation of independent governance structures, and the incorporation of ESG indicators into strategic management. It was concluded that the effectiveness of ESG practices depends on the internalization of a culture of organizational integrity, the adoption of formal mechanisms disconnected from institutional practice being insufficient, reinforcing the need for integration between governance, ethics, and sustainability for risk prevention and the promotion of corporate resilience.

Keywords: Compliance; ESG; Risk Management; Corporate Governance; Business Sustainability.

1. Introduction

The consolidation of Environmental, Social and Governance (ESG) criteria has stood out, throughout this decade, as one of the main milestones in the transformation of corporate governance on a global scale. In this context, these guidelines cease to be understood merely as instruments of regulatory compliance and begin to assume a strategic function in organizational management, especially with regard to the mitigation of financial, operational, and reputational risks. Thus, the incorporation of ESG principles is configured as an essential requirement for long-term business sustainability, particularly in sectors characterized by high socio-environmental impact (Pereira & Cunha, 2025).

Within the extractive sector, this discussion becomes more complex, considering the externalities associated with mining activities. Thus, the need for implementing integrity systems capable of aligning economic performance and socio-environmental responsibility is evident. However, the recurrence of practices such as greenwashing and social washing is observed, characterized by the dissemination of information that does not faithfully reflect organizational practices. In this sense, such conduct approaches the concept of symbolic compliance or paper compliance, in which there is formalization of norms without effective practical application (Reis et al., 2025).

In this scenario, it becomes relevant to distinguish between institutional communication strategies and the effective construction of an organizational integrity culture. While certain practices rely on sustainability reports with a predominantly declaratory function, corporate integrity presupposes the incorporation of ethical values into decision-making and operational processes. Thus, compliance systems based exclusively on normative instruments tend to present limitations, especially due to the absence of mechanisms that promote behavioral changes in the organizational environment (Giovanini, 2014). In the mining sector, the relationship with stakeholders, especially local communities and ecosystems, is a central element in the analysis of corporate governance. The prioritization of short-term results, associated with the limited integration of socio-environmental aspects in decision-making, can result in significant impacts, both economically and reputationally (Moffat & Zhang, 2014).

Additionally, the incorporation of ESG criteria has been progressively associated with the assessment of financial risks by investors and regulatory agents. In this context, the ability of organizations to manage socio-environmental risks directly influences aspects such as market value, access to credit, and competitiveness. Thus, the absence of effective governance and sustainability practices no longer represents merely reputational fragility but constitutes a material risk to the continuity of operations (Pereira; Cunha, 2025; Trindade; Botelho, 2023). In the period prior to the critical event analyzed, it is observed that the relationship with stakeholders was predominantly instrumental, with social participation restricted to formal consultation mechanisms. This configuration limits the construction of institutional trust, as the effectiveness of engagement depends on the inclusion of different actors in the decision-making process.

Overcoming merely formal integrity demands a reconfiguration of corporate governance, with an emphasis on the commitment of top leadership. In this sense, compliance programs are more effective when associated with the concept of Tone at the Top, in which organizational leaders demonstrate, through their decisions, the priority given to ethics, safety, and sustainability. Thus, coherence between institutional discourse and organizational practices constitutes a central element for consolidating a culture of integrity (Bertoccelli, 2022; Gomes, 2025). The quality of organizational decision-making is directly related to the availability and validation of critical information. In contexts characterized by high production pressure, such as the mining sector, there is a tendency to prioritize operational goals over structural safety, highlighting governance weaknesses (Coimbra; Manzi, 2010; Gomes, 2025).

Thus, the transition from a reactive to a proactive governance model implies recognizing compliance as a strategic element of the organization. In this sense, the effectiveness of ESG practices depends on the integration between organizational culture, risk management, and decision-making, ensuring that institutional mechanisms are capable of preventing systemic failures and reducing the probability of critical events. Considering this context, the research problem is delimited in the following terms: in what way can the restructuring of compliance strategies and the effective adoption of ESG criteria contribute to the mitigation of merely formal compliance (paper compliance) in companies with high socio-environmental impact?

The relevance of the study is based on the need to improve governance mechanisms in the mining sector, especially in the face of critical events that highlight limitations in corporate control systems. In this sense, the analysis of symbolic compliance and its implications contributes to the understanding of existing fragilities and to the proposal of more effective responsible management strategies. Finally, the research offers a theoretical contribution by articulating the concepts of ESG, compliance, and organizational culture, in addition to offering practical implications for managers, regulators, and investors. Thus, the study seeks to support the construction of more efficient governance models aligned with contemporary demands for transparency, responsibility, and sustainability in the corporate environment. The general objective of this work is to analyze the restructuring process of corporate governance and ESG strategies in an organization in the mining sector, focusing on the transition from a model of symbolic compliance to integrated risk management.

2. Material and Methods

The present investigation was characterized as a qualitative research, with an interpretive and exploratory approach. This methodological choice aimed to deepen the understanding of the reconfiguration processes of corporate governance and integrity culture in complex organizational contexts. The qualitative approach was considered adequate for analyzing multifaceted phenomena, especially those related to institutional dynamics and the internalization of ethical values, which cannot be reduced to quantitative metrics (Gil, 2019).

The exploratory nature of the research was justified by the need to broaden the understanding of the transition between different integrity models, allowing for a closer approach to the research problem. As a methodological strategy, a single case study was adopted, a procedure considered appropriate by Yin (2015) for examining contemporary phenomena embedded in real and specific contexts, such as the critical event analyzed in this work.

The unit of analysis corresponded to Company Alpha, a large Brazilian multinational organization. This company operates in the mining and metallurgy sector, with operations concentrated in the states of Minas Gerais and Pará. The selection of Company Alpha was based on criteria of empirical relevance, socio-environmental impact, and availability of public information, as it is a publicly traded company subject to transparency standards required by national and international financial markets.

The study focused on the restructuring of Empresa Alpha’s corporate governance after the rupture of a tailings dam that occurred in two thousand and nineteen, in the region of Brumadinho (MG). This critical event highlighted fragilities in the organization’s risk management system and drove a restructuring process guided by sustainability and compliance criteria.

Data collection was carried out through documentary research, considered by Gil (2019) a relevant source for obtaining historical and institutional evidence. The survey took place systematically during the first semester of two thousand and twenty-four, with access to public databases and the Investor Relations portals of Company Alpha.

The documents were selected based on four specific criteria: (i) thematic relevance to governance, sustainability, and risk management; (ii) temporal scope, covering the period before and after the critical event; (iii) institutional credibility of the sources; and (iv) full availability of the documents. These criteria ensured the relevance and reliability of the analyzed material.

Based on the established criteria, the documentary corpus was composed of Sustainability Reports and Annual Reports published between two thousand and eighteen and two thousand and twenty-four. Additionally, the Final Report of the Parliamentary Commission of Inquiry (2019) and the Accountability Report of the General Comptroller’s Office of the Union (2021) were included. The diversity of these sources enabled data triangulation, contributing to the analytical robustness of the study.

The treatment and analysis of the data were based on the Content Analysis technique, as proposed by Bardin (2016). This technique was structured in three main stages, aiming to systematically and rigorously organize, explore, and interpret the collected material.

The first stage, called pre-analysis, involved the organization of the material and the floating reading of the documents. At this time, the units of record and context were defined, as well as the final delimitation of the analysis corpus. This initial phase was crucial for familiarization with the data and for establishing the foundations for subsequent stages.

Next, in the material exploration phase, the data was coded. A categorical system previously guided by the theoretical framework was used, combining open and axial coding. This stage included the identification of discursive patterns, semantic recurrences, and elements of contradiction present in the analyzed documents, allowing the grouping of content into categories and subcategories.

The analytical categories were defined from a hybrid process, which combined a deductive approach, based on existing literature, with an inductive approach, emerging from the data itself. Initially, preliminary categories were established such as the socio-environmental impact of the critical event, fragility in the materiality of the Triple Bottom Line, occurrence of paper compliance, and post-crisis restructuring strategies.

Subsequently, these categories were refined from the empirical analysis, allowing the inclusion of subcategories related to organizational culture, risk management, and the performance of senior leadership. Finally, the treatment and interpretation stage consisted of the inferential analysis of the coded data, articulating the empirical findings with the theoretical concepts of governance, ESG, and compliance. The validation of the results occurred through the triangulation of evidence, confronting the institutional discourse of Alpha Company with the technical information and the inconsistencies pointed out in the official reports of the CPI and CGU, ensuring greater consistency and reliability to the interpretations produced.

3. Results and Discussion

The data analysis revealed that the organization’s operational unit, located in Brumadinho (MG), presented a complex coexistence between intense mining activity and the presence of rural communities and administrative structures. Before the critical event, the mine’s infrastructure was vast, employing hundreds of workers in various productive sectors. It was observed that the administrative area, including cafeterias, offices, and workshops, was positioned directly below the tailings dam, which constituted a structural condition of high vulnerability, as pointed out by Souza and Souza (2020).

The investigation demonstrated that the failure that occurred cannot be attributed to an isolated technical error, but rather to a systemic fragility in the organizational architecture. The internal control systems did not operate in an integrated manner, and corporate governance exhibited a limited capacity for articulation between crucial areas, such as risk management, auditing, and operations. This institutional fragmentation prevented the early detection of signs of instability, hindering evidence-based decision-making and increasing the organization’s exposure to complex risks, as discussed by Kadel Junior (2023) and Silva and Freitas (2025).

Contemporary literature reinforces the need for mining ventures to integrate technical, social, and environmental criteria into territorial planning. Kneipp et al. (2012) emphasize that sustainable management in the mineral sector requires anticipating risks and prioritizing collective safety to avoid exposing workers and communities to critical situations. The absence of a systemic risk management approach, therefore, contributed to the maintenance of vulnerable operational structures, where latent failures could evolve into a catastrophic event of great proportions.

The dam rupture in 2019 triggered an abrupt and irreversible transformation in the region, with millions of cubic meters of iron ore tailings burying the mine’s infrastructure, devastating native vegetation, and contaminating watercourses. In a matter of seconds, the event resulted in the deaths of 270 people, including workers and residents, becoming the largest workplace accident in Brazil’s history. The mud reached the Paraopeba River, compromising the water supply of several municipalities and generating environmental impacts that extended for hundreds of kilometers (Brasil, 2019; Souza; Souza, 2020).

The disaster’s impacts transcended the immediate physical dimension, extending to psychosocial and public health aspects, durably affecting the local population. The contamination of the region’s main watercourse by heavy metals created a scenario of large-scale environmental pollution, with effects that spread throughout the entire river basin. This situation highlighted a systemic governance collapse, where the absence of effective prevention and control mechanisms directly contributed to the materialization of previously identified critical risks.

The post-rupture context revealed a systemic failure in risk management, characterized by the normalization of structural hazards and the maintenance of human coexistence areas in zones without self-rescue conditions, according to Andrade da Silva et al. (2020). This finding aligns with Elkington’s (2012) approach to the Triple Bottom Line, demonstrating that the imbalance between the economic, social, and environmental pillars compromised organizational sustainability. The prioritization of economic goals over safety and environmental preservation made the sustainable continuity of operations unfeasible.

The permanence of administrative structures in areas of fatal risk demonstrated that the logic of logistical efficiency prevailed over the preservation of human life, materializing the critical imbalance pointed out by Elkington (2012). In this scenario, the absence of a consolidated social pillar compromised the sustainability of the productive system, and the neglected operational risk materialized as a human and environmental collapse of great proportions, revealing the fragility of the corporate governance adopted by the organization.

The organizational trajectory analyzed indicated that the concept of corporate sustainability has undergone transformations, ceasing to be a peripheral practice to become integrated into the strategic core. This change was driven by the understanding that environmental and social risks directly impact long-term economic viability, requiring a more integrated approach to corporate management. Elkington’s (2012) Triple Bottom Line model emphasizes the need for balance between economic, social, and environmental results, where corporate performance is not restricted to financial profit, but also to the ability to generate positive impacts on society and the environment.

However, the neglect of the social and environmental pillars in favor of financial performance, observed in the organization’s history, can be understood by the theory of risk materiality. The corporate strategy dissociated economic success from socio-environmental issues, treating them as secondary. Financial performance prior to 2019 concealed uninternalized social and environmental costs, increasing operational vulnerability and preventing the fulfillment of the company’s social function, according to Souza and Mezzaroba (2022).

From the perspective of Stakeholder Theory, the disregard for the interests of local communities solely for the benefit of shareholders constituted a systemic risk that compromised organizational legitimacy. The superficial adoption of ESG principles contributed to the formation of an ecological liability that converted into an immediate economic liability. The organization faced significant losses in market value, financial sanctions, and severe legal restrictions, demonstrating that sustainability cannot be dissociated from effective corporate governance (Brasil, 2019).

From an economic point of view, the disaster resulted in significant losses, including stock devaluation in the financial market and billion-dollar fines, in addition to socio-environmental reparation agreements. It is estimated that the total costs related to the event exceed tens of billions of reais, considering indemnities and environmental recovery. These data demonstrate that negligence regarding socio-environmental risks not only compromises safety but also directly impacts the organization’s long-term financial sustainability.

The commitment to sustainability is no longer an optional strategic choice, becoming an essential requirement for economic survival in regulated global markets. The management of non-financial risks, especially those related to environmental and social dimensions, has come to occupy a central position in corporate governance. Elkington (2012) argues that sustainability is an indispensable condition for organizational resilience, and the imbalance between the economic, social, and environmental pillars compromises the continuity of operations. The organization, by neglecting the Triple Bottom Line, triggered a socio-environmental disaster and highlighted the fragility of a governance model based on greenwashing practices, with a dissociation between institutional discourse and operational reality.

Contemporary literature reinforces that ESG represents a conceptual evolution of traditional sustainability, by emphasizing the materiality of risks for investors and stakeholders. Moffat and Zhang (2014) highlight that the social license to operate depends directly on the perception of affected communities regarding the company’s ethical and responsible performance. The absence of alignment between corporate practices and social expectations can generate severe institutional disruptions, as observed in the analyzed case, and the effective adoption of ESG criteria allows for the anticipation of reputational and operational risks (Souza and Mezzaroba, 2022).

Despite the growing adoption of ESG discourse in the mining sector, the analyzed case demonstrated that the superficial incorporation of these criteria can create a false perception of sustainability. ESG was instrumentalized as a reputational strategy, detached from organizational practice, reinforcing the phenomenon of greenwashing. The absence of effective monitoring and accountability mechanisms turned ESG into a symbolic element, incapable of preventing systemic failures and large-scale events.

In the post-2019 restructuring process, the organization sought to incorporate these principles into its strategy, especially in recomposing relations with impacted communities and strengthening transparency practices. However, Claro and Claro (2014) emphasize that the generation of sustainable value depends on the company’s ability to integrate such dimensions into its decision-making logic, not just to incorporate them into institutional reports. Governance began to be conceived as a structuring axis of the organization, responsible for aligning economic, social, and environmental interests in a systemic manner.

The restructuring observed in the post-crisis period was characterized as a predominantly reactive response, motivated by regulatory sanctions and external pressures, rather than an internal process of organizational maturation. This dynamic suggests that the transformation of governance occurred within a context of institutional imposition, where the need for reputational recomposition took precedence over the gradual construction of a culture of integrity. Although such changes represent advances, their sustainability depends on the organization’s ability to continuously internalize these principles, avoiding a new cycle of symbolic compliance (Morais, 2023; Reis et al., 2025).

The analysis of the period preceding the disaster revealed a profound discrepancy between institutional discourse and operational reality. In the years 2017 and 2018, the company was internationally recognized as a benchmark in sustainability, using corporate reports for legitimation. Institutional documents indicated that 100% of the tailings disposal structures had valid Declarations of Stability Condition (DCE), reinforcing a perception of technical safety. Furthermore, ISO 14001 certification was presented as evidence of excellence in environmental management, based on the continuous improvement cycle.

Although international certifications, such as ISO 14001, are often used as indicators of maturity in environmental management, their effectiveness depends on how they are internalized in organizational processes. In the analyzed case, the certifications were incorporated as formal elements of external validation, without effective correspondence in operational practice. This mismatch highlights a structural limitation of models based exclusively on normative standardization, as technical compliance does not guarantee the anticipation of critical risks (Claro; Claro, 2014; Kneipp et al., 2012).

The critical analysis of this data revealed that the apparent robustness of the governance mechanisms was anchored in predominantly formal indicators, without effective correspondence with the operational reality. The maintenance of 100% of the Stability Condition Declarations, even in the face of subsequent technical evidence of liquefaction risk, indicated a governance oriented towards documentary compliance, rather than structural safety. This scenario reinforces the hypothesis that the control instruments were used more as mechanisms of institutional legitimation than as effective risk management tools (Brasil, 2019; Bertoccelli, 2022; Reis et al., 2025).

The literature shows that certifications and reports do not, by themselves, guarantee the effectiveness of governance systems. Kneipp et al. (2012) state that sustainability maturity in the mining sector depends on the internalization of preventive practices and the integration between environmental management and strategic decision-making. The absence of effective control and monitoring mechanisms contributes to the maintenance of latent risks, even in formally certified organizations, as observed in this case study.

The effectiveness of these systems is directly conditioned by the commitment of senior leadership, a central element in the concept of Tone at the Top. Giovanini (2014) highlights that organizational culture reflects the values practiced by senior management, this being the main determinant of the success or failure of compliance programs. The Final Report of the CPI (Brazil, 2019) showed that strategic decisions prioritized productive goals over safety, transforming governance instruments into merely formal mechanisms.

This configuration characterizes the phenomenon of paper compliance, where there is documentary conformity without practical effectiveness. Bertoccelli (2022) describes this model as the superficial fulfillment of regulatory requirements, prioritizing the appearance of conformity over the prevention of real risks. Thus, governance began to operate under the logic of check-the-box, compromising its ability to identify and mitigate systemic failures, which was a determining factor for the disaster.

Recent studies indicate that the fragility of governance in the mineral sector is associated with low integration between risk management and corporate strategy. Silva and Freitas (2025) indicate that organizations with a low level of sustainability maturity tend to present greater exposure to critical events, precisely due to the absence of mechanisms for anticipating and responding to complex risks. The case analysis shows that the absence of an effective integrity culture contributed directly to the worsening of the disaster.

The post-2019 organizational transformation occurred predominantly reactively, driven by regulatory and market pressures. Although there have been advances in risk monitoring and institutional transparency, these changes did not stem from a previously consolidated organizational culture, but from the need to recompose legitimacy before the market and society. The evolution of governance mechanisms indicates a forced transition from a model of symbolic compliance to a more robust structure, still in the process of consolidation.

Governance failures were not restricted to isolated technical aspects, but reflected a structural deficiency in the integration of the environmental, social, and governance (ESG) pillars. The effectiveness of sustainability in the mining sector depends on the articulation between governance, fundamental rights, and socio-environmental responsibility, with the adoption of merely declarative practices being insufficient, according to Fonteles (2024). The analysis reinforces that the consolidation of sustainable governance requires not only the formalization of policies and certifications, but the internalization of an organizational culture oriented towards risk prevention and the generation of shared value.

The discrepancy between institutional discourse and the technical evidence identified by control bodies was striking. Governance mechanisms were structured to meet formal requirements, without ensuring effective operational risk management. This configuration characterized an organizational environment where compliance was used as an instrument of reputational protection, while critical risks remained underestimated or deliberately omitted. Governance ceased to exercise its preventive function and began to operate as a legitimizing element of potentially unsafe practices.

To sustain the apparent robustness of its governance, the organization relied on external audits of high international repute, such as the certification issued by TÜV SÜD, which conferred legitimacy on the Stability Condition Statements (DCEs). This reinforced the perception of reliability before the market and regulatory bodies. However, the CPI’s Final Report (Brazil, 2019) highlighted significant weaknesses in this validation structure, with the omission of critical data related to liquefaction risk, influenced by commercial pressures from the company itself.

This scenario revealed that the adopted governance was not able to ensure the necessary technical independence, compromising the effectiveness of control mechanisms. Investigations by the Comptroller General of the Union demonstrated that the organization provided incomplete and, in some cases, misleading information to oversight bodies, omitting the evolution of risks identified by sensors in the dams. This practice constitutes a direct violation of the principles of transparency and accountability, fundamental to contemporary corporate governance (Moura Fonteles, 2024).

The dissociation between institutional discourse and operational practice evidenced an instrumentalization of ESG as a reputational tool, rather than as an effective risk management mechanism. The discrepancy between excellence certifications and the technical evidence gathered by control bodies reinforces the characterization of a paper compliance system. Reis et al. (2025) explain that this phenomenon occurs when organizations prioritize building an institutional image aligned with good practices, without promoting structural changes in their internal processes, resulting in neglected operational risks.

The fragility of governance systems in the mineral sector is directly related to the level of maturity in sustainability of organizations. Mining projects with low maturity in ESG tend to present a higher incidence of critical failures, precisely due to the absence of integrated monitoring and control mechanisms, according to Silva and Freitas (2025). The case analysis demonstrates that the lack of an organizational culture oriented towards prevention contributed significantly to the worsening of the disaster.

The analysis of the sustainability maturity level showed that organizations in the initial stages tend to adopt fragmented practices, focusing predominantly on documentary compliance. This approach limits the integration between risk management, corporate strategy, and socio-environmental responsibility, compromising the effectiveness of prevention mechanisms. Higher maturity levels, on the other hand, are associated with the systemic incorporation of ESG criteria, where sustainability guides decision-making at all organizational levels, reducing exposure to critical risks (Silva; Freitas, 2025; Kneipp et al., 2012).

The institutional crisis imposed on the organization the need for a profound restructuring of its governance and internal control mechanisms, driven by severe regulatory sanctions and the loss of credibility in the financial market, evidenced by the company’s exclusion from sustainability indices such as the ISE B3. Morais (2023) highlights that institutional credibility in the mining sector is directly associated with consistency between discourse and practice, being quickly compromised in crisis situations.

In this context, the organizational response included the creation of independent monitoring structures, such as the Executive Directorate of Operational Safety and Surveillance, with the autonomy to interrupt activities in case of imminent risk. This measure represented an attempt to correct failures in the Tone at the Top, reinforcing the importance of leadership in consolidating a culture of integrity. Kadel Junior (2023) argues that sustainable governance depends on the ability of organizations to establish independent decision-making mechanisms, capable of prioritizing safety and ethics even in the face of economic pressures.

Additionally, the incorporation of ESG indicators into the variable remuneration of senior management represented a relevant strategy for aligning economic and socio-environmental interests. Trindade and Botelho (2023) affirm that the effectiveness of regulatory practices in the mining sector depends on the creation of incentives that promote sustainability as a central element of corporate strategy. Thus, linking financial results to integrity metrics contributes to the internalization of ethical values in the organizational culture, with the aim of reducing accidents, improving reputation, and ensuring regulatory compliance.

Despite these initiatives, the literature highlights that the consolidation of a culture of integrity is a gradual process, which depends on the continuity and consistency of the practices adopted. Kneipp et al. (2012) emphasize that sustainability in the mining sector requires a structural transformation, in which risk management and socio-environmental responsibility are permanently incorporated into the organizational strategy. The integrated analysis of the results allows us to infer that the main critical factor lies not in the absence of governance instruments, but in the inability to convert them into effective organizational practices.

The existence of reports, certifications, and formal structures was not enough to guarantee operational safety, demonstrating that governance, when dissociated from organizational culture, loses its strategic function (Elkington, 2012; Giovanini, 2014). The central challenge for organizations in the mining sector is not just to implement control mechanisms, but to ensure that such mechanisms are capable of influencing behaviors, decisions, and institutional priorities, promoting a truly integrated risk management. The restructuring of governance should not be understood as a one-time response to a crisis, but as a continuous process of institutional improvement, whose effectiveness will depend on the organization’s ability to maintain the autonomy of its control mechanisms, even in the face of future economic pressures, ensuring that the new culture of integrity is, in fact, structuring and lasting.

In summary, the results demonstrate that the failure in corporate governance did not stem from the absence of formal instruments, but from the inability to internalize a culture of integrity oriented towards risk prevention. The predominance of paper compliance, associated with the prioritization of productive goals and the fragility of control mechanisms, contributed directly to the occurrence of the disaster. Although the post-crisis restructuring process has promoted relevant advances, its effectiveness will depend on the consolidation of organizational practices that transcend documentary compliance, ensuring the real integration of ESG principles into corporate strategy and responding to the objective of transition to integrated risk management.

4. Conclusion

The study aimed to analyze the process of restructuring corporate governance and ESG strategies in an organization in the mining sector, focusing on the transition from a model of symbolic compliance to integrated risk management. It was observed that, before a critical event, the organization operated under a paper compliance model, in which formal adherence to norms and certifications, such as ISO 14001 and current Stability Condition Declarations, did not translate into practical effectiveness. This discrepancy, coupled with fragmented internal controls and the prioritization of production goals over safety, contributed to systemic failures in risk management and the materialization of a socio-environmental disaster. In the post-crisis period, a reactive restructuring was implemented, driven by regulatory sanctions and external pressures. Measures such as strengthening control mechanisms, creating independent governance structures, and incorporating ESG indicators into strategic management and executive compensation were adopted. This restructuring sought to align economic and socio-environmental interests, demonstrating that the effectiveness of ESG practices depends on the internalization of a culture of organizational integrity, not just the adoption of formal mechanisms detached from institutional practice. The study’s main practical contribution lies in demonstrating the need for governance models that transcend documentary compliance, promoting transparency and autonomy of control mechanisms for risk prevention.

Despite the advances observed in restructuring, the consolidation of a culture of integrity is a gradual and continuous process. The study, however, presents limitations inherent to its methodological approach, especially because it is a single case study, which restricts the generalization of results to other organizations in the mineral sector. Furthermore, the reliance on documentary sources limited the understanding of more subjective aspects of organizational culture. For future studies, it is recommended to expand the analysis to multiple cases, as well as to integrate qualitative and quantitative approaches, in order to deepen the understanding of the maturity of governance and sustainability systems in the sector.

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Article originating from the Final Course Work of the Specialization in Compliance and ESG of the MBA USP/Esalq

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