Compliance And Esg
September 15, 2026
Quality of Integrity Programs of Sanitation Sector Companies Listed on B3
Gustavo Angeoletto Scramim; Tatiane Dutra Romana
DOI: 10.22167/2675-6528-202602224
Article derived from a Term Paper (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.
Summary
The sanitation sector plays a strategic role in national socioeconomic development, and the high regulation of its operations justified the verification of the consistency of integrity and compliance mechanisms. Given this scenario, the objective was to develop a methodology to assess the quality of integrity programs and apply it to verify the level of adequacy of sanitation sector companies listed on the B3 to the components of Brazilian anti-corruption legislation. The research was characterized as descriptive and documentary, based on the analysis of reference forms, internal policies, and official public documents disclosed by the organizations in the year 2024. The methodology used fifteen components with specific evaluation criteria to determine the Total Adherence Index, an indicator adapted to measure the compliance of each company. The results showed a marked heterogeneity in the maturity of the companies, finding that size and regulatory registration category did not act as determining factors for the performance of the programs. A compliance logic focused on the documentary aspect was observed, with significant adherence in structural requirements, such as independence, codes of conduct, and whistleblowing channels, in contrast to operational gaps in accounting records, due diligence, and continuous training. It was concluded that strengthening integrity in the sector depends on the evolution of the strictly formal model, demanding the effective implementation of operational mechanisms and the continuous dissemination of a culture of integrity.
Keywords: Compliance; Disclosure; Corporate governance; Anti-corruption Law.
1. Introduction
The term compliance, derived from the English “to comply”, refers to conformity with rules and standards of conduct. This concept, as explained by Nakamura et al. (2019), transcends the mere fulfillment of legal norms, also encompassing internal policies that guide organizational conduct. Coimbra and Manzi (2010) reinforce that compliance is not limited to formal observance, but includes a structure to prevent and correct deviations. Historically, the first compliance initiatives emerged in North American financial institutions, such as the “Federal Reserve”, in response to the demand for greater transparency and trust in the market (Manzi, 2008). The theme gained greater dissemination in business practices from the 1990s onwards, driven by corporate fraud scandals and the economic crisis of 2008 (Coimbra and Manzi, 2010).
In Brazil, the theme of compliance and integrity programs gained prominence with the enactment of Federal Law No. 12.846/2013, known as the Anti-Corruption Law, and its regulation by Decree No. 11.129/2022 (Carvalho et al., 2021). This normative framework established the objective liability of legal entities for acts against public administration and provided guidelines for the implementation of integrity programs. Such programs, according to Ribeiro and Diniz (2015), comprise a set of internal mechanisms and procedures designed to detect, prevent, and inhibit illegal practices, including audits, whistleblowing channels, codes of ethics and conduct, and internal controls.
Despite the normative evolution, Mello (2024) points out that Brazilian legislation does not offer a standardized model for evaluating the effectiveness of these programs. This results in heterogeneous structures among organizations and hinders self-assessment of the adequacy and effectiveness of their initiatives. From a consolidated perspective, the analysis suggests that, even with legislation and guidance from regulatory agencies and the Comptroller General of the Union, there is no standardization in the structuring and disclosure of integrity programs in the sector (OECD, 2025). This heterogeneity and the identified structural and disclosure gaps indicate that the maturity of compliance and integrity practices still requires evolution to contribute to transparency and corporate reputation (Nakamura et al., 2019).
The choice of the sanitation sector for this study is justified by its strategic importance for the socioeconomic development of Brazil. Siqueira (2025) highlights that the sector will move significant values in the national economy, driven by investments and the effects of the approval of the New Regulatory Framework for Sanitation (Federal Law nº 14.026/2020), which establishes goals for the universalization of water and sewage services by 2033 and intensifies regulatory supervision (Leite et al., 2022). Furthermore, the sector is characterized by strong interaction with public authorities, bidding processes, and concession contracts, making it an area of high compliance risk, with vulnerabilities related to bidding fraud, resource diversion, and corruption cases (Jenkins, 2017).
Given this scenario, the need arises for a practical and comparable method to assess the quality of integrity programs, which allows for the identification of gaps, strengths, and opportunities for improvement aligned with legal requirements and best practices in corporate governance. Thus, the present work is justified by establishing a comparable analysis model, offering a reference base for sectoral benchmarking and a practical self-assessment tool, in order to support the strengthening of corporate integrity and encourage the continuous improvement of compliance mechanisms. Therefore, the objective was to develop a methodology for assessing the quality of integrity programs and apply it to verify the level of adequacy of companies in the sanitation sector listed on the B3 to the components of Brazilian anti-corruption legislation.
2. Material and Methods
The present work was characterized as a multiple case study, of a descriptive and documentary nature, as categorized by Yin (2018) and Marconi and Lakatos (2017). The objective was to analyze the quality of the integrity programs of companies in the sanitation sector listed on the B3.
The data were collected from reference forms (FRE) from the year 2024 and from information disclosed on the companies’ investor relations websites. The analysis was qualitative, focused on evaluating adherence to Brazilian anti-corruption legislation.
The selection criteria for the companies were: i) operation in the sanitation sector and inclusion in the Water and Sanitation segment on the B3 website for the analyzed period; ii) exclusion of companies operating in other business models, such as waste management, construction, infrastructure, and holdings. The final sample comprised seven companies, anonymized as G1, M1, M2, P1, P2, P3, and P4, to preserve the impartiality of the analysis and protect sensitive data.
For a comparative and sectorally homogeneous analysis, the companies were stratified by business size, based on the number of active economies in 2024, and by registration category before the Securities Commission [CVM]), according to Resolution No. 80 (2022).
Table 1. Population stratification
| Company | Total of active savings (2024) | Business size | CVM Category |
|---|---|---|---|
| G1 | 24.834.000 | Large | A |
| M1 | 9.842.000 | Average | A |
| M2 | 7.806.359 | Average | A |
| P1 | 1.706.272 | Small | A |
| P2 | 1.358.400 | Small | A |
| P3 | 549.000 | Small | B |
| P4 | 196.694 | Small | B |
Source: Original survey data
The assessment of integrity program quality involved analyzing companies’ disclosures, comparing them with the minimum components of Brazilian anti-corruption legislation and recommendations from the Comptroller General of the Union (CGU). The existence of each integrity program component was classified as total, partial, or null, adapting the method from Dal Magro et al. (2023). Components with total or partial existence were subjected to a qualitative evaluation of three attributes, structured based on the requirements of Decree No. 11.129/2022, whose criteria are synthesized in Table 2.
Table 2. Evaluation criteria
| Integrity program component | Evaluated attributes |
|---|---|
| Top management commitment | 1. Formalization and periodicity |
| 2. Allocation of human and financial resources | |
| 3. Formal accountability | |
| Conduct standards for internal audience | 1. Thematic scope and update |
| 2. Differentiation by hierarchical level | |
| 3. Disclosure and accessibility | |
| Conduct Standards for Third Parties | 1. Scope and Update |
| 2. Content of obligations | |
| 3. Enforcement Mechanisms | |
| Trainings and communications | 1. Audience scope and periodicity |
| 2. Thematic scope and depth | |
| 3. Adherence and effectiveness indicators | |
| Risk Analysis and Management | 1. Methodology and scope of the analysis |
| 2. Reassessment periodicity | |
| 3. Integration with strategy and governance | |
| Complete and accurate accounting records | 1. Formal accountability |
| 2. Compliance with recognized standards | |
| 3. Procedures for validation and audit | |
| Internal controls | 1. Methodology and formal structure |
| 2. Reassessment periodicity | |
| 3. Deficiency reporting | |
| Prevention of fraud and illicit activities in interactions with the public sector | 1. Mapping of risk transactions |
| 2. Conduct restrictions | |
| 3. Third-party checks | |
| Independence, structure, and authority of the integrity instance | 1. Organogram and hierarchical reporting |
| 2. Dedication and exclusivity to the role | |
| 3. Unrestricted access and participation in decisions | |
| Whistleblowing channels and whistleblower protection | 1. Accessibility and availability |
| 2. Handling and responses to complaints | |
| 3. Anonymity and whistleblower protection | |
| Disciplinary measures in case of violation of the integrity program | 1. Variety and proportionality |
| 2. Universal applicability | |
| 3. Formal application procedures | |
| Irregularity interruption and remediation procedures | 1. Comprehensive risk mapping |
| 2. Detective mechanisms | |
| 3. Remediation readiness | |
| Risk-based due diligence | 1. Third-party verifications |
| 2. Politically exposed persons checks | |
| 3. Supervision of sponsorships and donations | |
| M&A and restructuring checks | 1. Comprehensive risk mapping |
| 2. Readiness of mechanisms | |
| 3. Extensibility of policies and culture | |
| Continuous monitoring of the integrity program | 1. Indicators and metrics |
| 2. Reassessment periodicity | |
| 3. Communication of updates |
Source: Original research data.
To summarize the level of adherence and allow comparability, the Adherence Index (IA) was calculated for each individual component and the Total Adherence Index (IAT) for all components, using methodologies adapted from Dias et al. (2006) and Carvalho and Siqueira (2008), according to the following formulas:
AI = (Total points obtained in the attributes / Total possible points (6 per component)) × Multiplier (1)
IAT = (Σ IA of all components / Total of components (15)) (2)
Points for each attribute were allocated as two points for full adherence, one point for partial adherence, and zero for null adherence, totaling up to six points per component. The multiplier was 1.0 for full existence, 0.5 for partial existence, and zero for absence of minimum evidence, adapted from Dal Magro et al. (2023). The data were tabulated and the calculations of the IA and IAT indicators performed in Microsoft Excel software.
3. Results and Discussion
The analysis of the results, presented in Table 3, revealed the percentages of the Total Adherence Index (IAT) for each company. Company P2 obtained the highest index, with 84%, indicating a high level of compliance with Brazilian anti-corruption legislation requirements for integrity programs. In contrast, company P3 presented the lowest percentage, with 63%, suggesting significant gaps in its program structure.
Table 3. Total Adherence Index based on classification criteria
| Company | P1 | P2 | P3 | P4 | M1 | M2 | G1 |
|---|---|---|---|---|---|---|---|
| Ordinance | Small | Small | Small | Small | Average | Average | Large |
| CVM Category | A | A | B | B | A | A | A |
| IAT% | 66 | 84 | 63 | 77 | 76 | 81 | 67 |
Source: Original research results
This heterogeneity in company maturity, even within the same sector and with similar operations, aligns with the observations of Dal Magro et al. (2023) regarding the variation in compliance practices and controls in Brazilian publicly traded companies. Comparing the results of Table 3 with the business size stratification (Table 1 of the methodology), it was found that there is no direct correlation between company size and the level of adherence or the quality of the integrity program. Similarly, the registration category with the Securities and Exchange Commission (CVM) also did not prove to be a determining factor, despite Category A companies having more robust governance and transparency obligations, according to CVM Resolution No. 80 (2022). The data from Table 3 indicated that regulatory rigor did not guarantee superior rates for Category A companies, corroborating the thesis of Alves and Pinheiro (2017) that the practical effectiveness of regulation requires integration with other legal and regulatory spheres.
For a more detailed understanding, Table 4 presents the adherence level by component in each company, as well as the overall average. An asymmetry in adherence was observed, depending on the nature of the evaluated requirement. Components associated with formal and regulatory structures showed high adherence, such as “Independence, structure, and authority of the integrity unit,” with an average adherence of 100%, and “Reporting channels and whistleblower protection,” with an average of 86%. The high adherence to independence is justified by it being a structural starting point for integrity programs, according to guidelines from the Comptroller General of the Union (CGU).
Table 4. Individual and average adherence index of integrity programs in %
| Integrity program component | P1 | P2 | P3 | P4 | M1 | M2 | G1 | Mean |
|---|---|---|---|---|---|---|---|---|
| Top management commitment | 83 | 67 | 67 | 50 | 83 | 83 | 67 | 71 |
| Conduct standards for internal audience | 67 | 83 | 83 | 67 | 83 | 83 | 67 | 76 |
| Conduct Standards for Third Parties | 67 | 100 | 83 | 83 | 100 | 100 | 67 | 86 |
| Trainings and communications | 67 | 33 | 25 | 25 | 83 | 100 | 83 | 60 |
| Risk Analysis and Management | 83 | 100 | 25 | 83 | 83 | 83 | 83 | 77 |
| Complete and accurate accounting records | 25 | 25 | 25 | 67 | 25 | 25 | 33 | 32 |
| Internal controls | 67 | 100 | 25 | 67 | 83 | 100 | 100 | 77 |
| Prevention of fraud and illicit activities in interactions with the public sector | 67 | 100 | 100 | 100 | 83 | 83 | 50 | 83 |
| Independence, structure, and authority of the integrity instance | 100 | 100 | 100 | 100 | 100 | 100 | 100 | 100 |
| Whistleblowing channels and whistleblower protection | 83 | 100 | 83 | 83 | 83 | 83 | 83 | 86 |
| Disciplinary measures in case of violation of the integrity program | 67 | 83 | 83 | 83 | 83 | 100 | 67 | 81 |
| Irregularity interruption and remediation procedures | 83 | 100 | 25 | 100 | 83 | 83 | 83 | 80 |
| Risk-based due diligence | 8 | 83 | 67 | 67 | 33 | 25 | 0 | 40 |
| M&A and restructuring checks | 83 | 100 | 83 | 100 | 83 | 83 | 42 | 82 |
| Continuous monitoring of the integrity program | 33 | 83 | 67 | 83 | 42 | 83 | 83 | 68 |
| IAT | 66 | 84 | 63 | 77 | 76 | 81 | 67 | 73 |
Source: Original research results.
In contrast, the lowest adherence rates were recorded in preventive mechanisms focused on operational and financial monitoring. “Complete and accurate accounting records” obtained the lowest average, 32%, and “Appropriate risk-based due diligence” presented an average of 40%, with high dispersion among companies (ranging from 0% to 83%). These results suggest that prior investigation processes in third parties and the detailing of accounting practices are sensitive points in the sector’s compliance, possibly due to the difficulty of operationalization or the need for specific investments. This difficulty is in line with Castro et al. (2019), who highlight the need for structural improvements in internal controls, and with Rorie and Rooij (2022), who point out the challenges of due diligence in integration with organizational culture.
The “Training and communications” component also deserves attention, with an average of 60% and severe discrepancies between companies (from 25% to 100%). This fragility in continuous training, in an environment where the average adherence to formal components such as “Conduct standards for internal staff and third parties” and “Disciplinary measures” was over 76%, suggests an operational mismatch. This scenario, characterized by Copello (2023) as “shelfware programs,” indicates structures created to meet governance requirements but that fail to integrate with the corporate culture. The results in Table 4 suggest that, without continuous training to translate theory into real dilemmas, the system may be limited to a set of good intentions, as explained by Martín (2014).
The other components evaluated in Table 4 showed intermediate performance, with adherence rates mostly between 68% and 83%. “Continuous monitoring of the integrity program” and “Prevention of fraud and illicit acts in interactions with the public sector” represent this maturity range, indicating that companies have satisfactory guidelines, but with room for improvement in execution or documentary transparency.
From a consolidated perspective, the analysis of the results suggests that, despite Brazilian anti-corruption legislation and CGU guidelines, there is no standardization in the structuring and disclosure of integrity programs in the sanitation sector. The heterogeneity, with IAT variation from 63% to 84%, aligns with the OECD (2025) finding that companies adopt distinct approaches in evaluating and disclosing their compliance programs. The structural and disclosure gaps identified indicate that the maturity of compliance and integrity practices still requires evolution to contribute to transparency and corporate reputation, especially in highly regulated sectors, according to Nakamura et al. (2019).
It is important to note that adherence indices reflected the combination between the existence of integrity mechanisms and their degree of disclosure in public documents. The methodology employed may not absolutely distinguish whether low adherence stems from a structural gap (absence of the instrument) or a transparency gap (inadequate disclosure of the existing instrument). This limitation is recognized by international analyses, such as those by the OECD (2025), which characterize documentary compliance assessments as predominantly formal and focused on the analysis of policies and procedures.
The results indicated that the sanitation sector presents a heterogeneous maturity in its integrity programs, operating under a predominantly documental logic that prioritizes meeting formal and structural requirements over operational execution. The company’s size and its registration category at the CVM did not prove to be determining factors for the program’s quality, evidencing that regulatory rigor or the extent of operations do not guarantee the effectiveness of internal compliance practices.
4. Conclusion
This study sought to develop a methodology to assess the quality of integrity programs and apply it to verify the adequacy level of companies in the sanitation sector listed on the B3 to the components of Brazilian anti-corruption legislation. A marked heterogeneity was found in the maturity of integrity programs among the analyzed companies, with full adherence rates varying significantly. It was observed that the size of the companies and their regulatory registration category did not act as determining factors for the quality or performance of the programs. The findings evidenced a predominantly documentary compliance logic, with high adherence to structural requirements, such as the independence of the integrity unit and the existence of whistleblowing channels. In contrast, significant operational gaps were identified in components such as complete and accurate accounting records, appropriate risk-based due diligence, and continuous training, suggesting that programs often function as “off-the-shelf programs,” without full cultural and operational integration. The developed methodology offers a practical contribution to the sector, establishing a comparable analysis model that can serve as a basis for benchmarking and self-assessment, supporting the strengthening of corporate integrity and continuous improvement of compliance mechanisms.
For the strengthening of integrity in the sanitation sector, it is essential that companies evolve from a strictly formal model, demanding the effective implementation of operational mechanisms and the continuous dissemination of an ethical culture. However, it is recognized that the methodology employed, based on documentary analysis, may not absolutely distinguish whether low adherence to a requirement stems from its structural absence or from a lack of transparency in the disclosure of an existing instrument. Additionally, as the analyzed period exclusively covered the 2024 fiscal year, the data should not be extrapolated as a historical trend. It is suggested that future studies may analyze other disclosure periods, explore related sectors, or employ methods complementary to documentary analysis, in order to provide a more in-depth understanding of individual strategies for building and disclosing integrity programs.
Bibliographic References
Carvalho, A.C.; Bertoccelli, R.P.; Alvim, T.C.; Venturini, O. 2021. Manual de Compliance. 3ed. Forense, Rio de Janeiro, RJ, Brasil.
Coimbra, M.A.; Manzi, V.A. 2010. Manual de Compliance. 1ed. Atlas, São Paulo, SP, Brasil.
Manzi, V.A. 2008. Compliance no Brasil. 1ed. Saint Paul, São Paulo, SP, Brasil.
Mello, F.A. 2024. Eficácia de programas de integridade: riscos, armadilhas e perspectivas. In: XLVIII Encontro da ANPAD, 2024, Florianópolis, SC, Brasil. Anais do XLVIII Encontro da ANPAD p. 2177-2576.
Nakamura, E.V.; Nakamura, W.T.; Jones, G.C. 2019. Necessidade de estrutura de compliance nas instituições financeiras. Revista Gestão & Tecnologia 19(5): 257-275.
Organização para a Cooperação e Desenvolvimento Econômico [OCDE].
Ribeiro, M.P.; Diniz, P.F. 2015. Compliance e a lei anticorrupção nas empresas. Revista de informação legislativa 52(205): 87-105.
Article originating from the Course Conclusion Work of the Specialization in Compliance and ESG of the MBA USP/Esalq
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