Article

Luara Antunes Stollmeier; Carlos Alberto Dos Santos Silva

DOI: 10.22167/2675-6528-202602293

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 Revista E&S with the support of the ResumeAI tool, an artificial intelligence solution developed by the Pecege Institute for textual synthesis and organization.

Abstract

Sustainability reports are widely used as instruments for managing corporate legitimacy, but their function as a mechanism for cognitive reorganization in contexts of reputational crisis has remained underexplored in the literature. The study analyzed the transformations in ESG action categories reported by the JBS Company in its annual sustainability reports from 2015 to 2018, a period that encompassed two years before and two years after Operation Carne Fraca and its developments. The objective was to investigate how the organization altered its cognitive structure after the reputational crisis, through one of its reporting systems. A systematic cataloging process of 1,088 reported practices was employed, classified by ESG pillar, material theme, and action category. The theoretical framework mobilized Mary Douglas (1986), Michael Power (1997), Meyer and Rowan (1977), and Edelman (2016) to interpret the observed phenomena. The results showed a required growth in governance, which coexisted with the collapse of the social pillar, the disappearance of substantive categories, and the replacement of award-oriented actions with actions that reframed the organization’s relationships and its market positioning. Furthermore, leadership training shifted from the theme of culture to compliance, communication campaigns gave way to permanent structural channels, and investors became the audience with the largest proportional growth. It was concluded that the sophistication of the legitimization effort resided not in what the company necessarily did, but in the consistency with which it reorganized who it claims to be and for whom, based on the action categories it reported.

Keywords: Reputational crisis; ESG; Institutional thinking; Sustainability reports; Organizational strategy.

1. Introduction

Sustainability reports are widely recognized as essential instruments for managing corporate legitimacy. However, the role of these reports as mechanisms for cognitive reorganization in contexts of reputational crisis remains underexplored in academic literature. JBS Company, one of the largest animal protein processors in the world, with operations in more than 150 countries and revenue exceeding 180 billion reais in 2018 (JBS, 2019), is listed on B3’s Novo Mercado, a segment with high corporate governance requirements. The company has published annual and sustainability reports since 2012, following the Global Reporting Initiative (GRI) guidelines and mapping the Sustainable Development Goals, presenting itself as a sector benchmark in transparency and best practices.

On March 17, 2017, the Federal Police launched Operation “Carne Fraca” (Weak Meat), which exposed a scheme of adulteration of expired meats and systematic bribery of Ministry of Agriculture inspectors. JBS was among the targets of the operation, with three of its units investigated. On the same day, the company’s shares fell 10.59% on the B3 (Agência Brasil, 2017), and major importers such as China, the European Union, Chile, and South Korea announced the partial or total suspension of purchases of Brazilian meat.

The scandal was not an isolated event. Between 2016 and 2017, JBS and its holding company, J&F Investimentos S.A., were the target of five simultaneous police operations, in the context of ongoing anti-corruption investigations in the country. Besides Carne Fraca, operations such as Greenfield, Sépsis, Cui Bono, Bullish, Patmos, Tendão de Aquiles, and Capitu investigated fraud in state pension funds, fraudulent loans from Caixa, and irregularities in BNDES contributions. In May 2017, the controllers signed a plea bargain agreement, confessing to bribes to more than 1,800 politicians (O Estado de São Paulo, 2017a). In June 2017, the holding company signed the largest leniency agreement in Brazilian history, worth 10.3 billion reais (O Globo, 2017), and the controllers were arrested in September 2017 and again in November 2018.

Despite this scenario of intense reputational crisis, JBS’s sustainability report for the fiscal year 2018, published in May 2019, cited the company as first in the food sector and ninth in the overall transparency ranking of Transparency International Brazil. However, Transparency International Brazil itself (2018) issued a public clarification note, pointing out JBS’s selective use of data for credibility recovery, omitting a low score in financial transparency. This episode condenses the central empirical problem of this work: how could a company subjected to simultaneous police operations, the largest leniency agreement in the country, and two arrests of its controller simultaneously produce sustainability reports that reconfigured it as a benchmark for transparency?

The proposed answer does not lie in the intentional behavior of the manager or specific actors, but in the institution’s cognitive structure: in the way it reorganized who it claims to be and which characteristics of its identity would justify the possibility of legitimizing itself as such. It is proposed that this movement be analyzed from the ESG reporting system itself, which functions as a mechanism for producing legitimacy. The theoretical framework mobilizes Mary Douglas (1986) to analyze processes of institutional forgetting, Michael Power (1997) to interpret rituals of verification and formal auditability, and Meyer and Rowan (1977) and Edelman (2016) to understand the possibility of symbolic decoupling.

The objective of the work is to analyze how the ESG action categories reported by JBS transformed between 2015 and 2018, and to interpret these transformations as an expression of institutional thought and verification rituals described by Douglas (1986) and Power (1997).

2. Material and Methods

The study consisted of a single-case longitudinal analysis of the JBS Company, focusing on the reorganization of its cognitive structure after a reputational crisis, through its reporting systems. The analytical relevance of the group’s corporate structure was considered, given that JBS is a publicly traded company subject to disclosure obligations, while its controlling company, J&F holding S.A., which is privately held, signed a leniency agreement of R$ 10.3 billion on June 5, 2017. This contractual architecture allowed JBS to maintain, in its public reports, an institutional identity discursively separated from the irregularities confessed by the controlling company, functioning as a decoupling mechanism.

The cycle of crises to which JBS and its holding company were exposed between 2016 and 2018 is systematized in Table 1.

Table 1. JBS cycle of crises and its holding company (2016-2018)

Federal Police Operation	Year	Focus of the investigation	Primary outcome / endpoint
Greenfield	2016	Frauds in state-owned pension funds (Funcef, Petros, Postalis, Previ) via FIPs. the holding company pointed out as the beneficiary of FIP Florestal/Eldorado.	Judicial block of R$ 8 billion in assets; task force recovered more than R$ 11 billion.
Sepsis	2016	Bribe for the release of FI-FGTS funds by Caixa; JBS among the target companies.	Searches at JBS headquarters and controller’s residence; arrest of money launderer Lúcio Funaro.
Cui Bono	2016	Fraudulent loans from Caixa; the holding company between legal entities beneficiaries.	MPF’s complaints involving five companies and eighteen people, in operations of over R$ 3 billion.
Weak Meat	2017	Adulteration of meats and bribery of MAPA inspectors; three JBS units affected.	Largest PF operation to date; R$ 1 billion blocked; JBS shares fall 10.59% on the day.
Bullish	2017	Frauds in R$ 8.1 billion of BNDES contributions to JBS (2007-2011).	Loss estimated by the TCU at around R$ 711.3 million to public coffers, former BNDES presidents and former minister Guido Mantega judicially acquitted in 2023.
Patmos / ‘Day of Denunciation’	2017	Whistleblower testimony from controllers to the PGR; R$ 600 million distributed to 1,829 candidates from 28 parties.	Audio leak on 05/17/2017 causes intraday drop of over 10% in Ibovespa (closing: -8.8%) on the following trading day, 05/18/2017 – the worst since 2008; holding leniency of R$ 10.3 billion
Achilles tendon	2017	Insider trading: JBS stock trades on the eve of the plea deal’s disclosure.	CVM absolved the controllers in 2023; fine of R$ 500 thousand to the holding company.
Capitu	2018	Bribes to MAPA agents for regulations favorable to JBS; political campaign financing.	Second arrest of the controller; operation launched after the end of the 2018 fiscal year, but before the publication of the report.

Source: own elaboration based on Agência Brasil (2017a; 2017b; 2018a; 2018b), Correio Braziliense (2017), Diário do Nordeste (2016), Gazeta do Povo (2020), O Estado de S. Paulo (2017), O Globo (2017), InfoMoney (2022), Poder360 (2023), Terra (2019); Fleck & Rodrigues (2023).

The documentary corpus was composed of four JBS annual sustainability reports, referring to the fiscal years 2015 to 2018. The time window was defined to cover two years prior (2015–2016) and two years subsequent (2017–2018) to Operation Carne Fraca, which was launched in 2017. The 2017 report was prepared during the scandal, and the 2018 report, with full knowledge of all operations and Operation Capitu. The reports used are detailed in Table 2.

Table 2. Research documentary corpus

Report	Exercise	Publication date	Period covered	Pages
Annual and Sustainability Report 2015	2015	May 2016 (approx.)	01/01/2015 to 12/31/2015	96
Annual and Sustainability Report 2016	2016	May 2017 (approx.)	01/01/2016 to 12/31/2016	148
Annual and Sustainability Report 2017	2017	May 2018 (approx.)	01/01/2017 to 12/31/2017	216
2018 Annual and Sustainability Report	2018	May 06, 2019	01/01/2018 to 12/31/2018	180

Source: JBS (2016; 2017; 2018; 2019).

The central analytical procedure involved the systematic cataloging of reported actions in the four reports. The primary unit of analysis was the reported action, defined as any sentence or set of sentences describing a concrete action of the organization, distinguishing it from value statements, abstract goals, or principle assertions. The cataloging instrument was developed and tested by the researcher in a previous study and adapted for this longitudinal single-case analysis, replacing the variable “company” with “report year”.

For each identified action, the following were recorded: year of the report, period (pre/post-scandal in Operation “Weak Meat”), ESG pillar (Environmental, Social, or Governance), material theme, action category, and description of the reported practice, with indication of the source page or section. Data extraction was performed manually, following the publication sequence of the report sections. Artificial intelligence Claude (Anthropic, Opus 4.7 model) was used for database review, detection of duplicates and inconsistencies, and subsequently to test hypotheses and generate visualizations from correlations identified by human intelligence.

At the end of the cataloging, 44 distinct action categories were standardized, distributed across 19 material themes, totaling 1,088 registered actions (447 pre-scandal and 641 post-scandal).

This cataloging approach, which articulates broad categories of action with minimal categories of practice, allowed for the identification of patterns and the tracking of shifts that would be invisible in conventional content analyses. The granularity achieved was compatible with the theoretical frameworks mobilized to analyze mechanisms of reclassification, forgetting, and legitimation by analogy.

3. Results and Discussion

The corpus indicates an expressive growth in the volume of reported practices between 2015 and 2018, with the total almost doubling in the period. This growth was not uniform across the ESG pillars, concentrating, above all, on Governance, which went from approximately 100 to over 200 records, increasing its relative weight in the total, especially from 2017 onwards. The data indicate that the organization, in light of the 2017 scandal, intensified its declaratory activity. The growing volume, in itself, does not reveal the nature of this change, whether it reflects a substantive alteration of conduct or a reorganization of what is categorized and made visible as practice. The following analyses organize the identified patterns into four interpretive dimensions: cognitive reclassification, colonization of verification rituals, conformity ceremony, and symbolic decoupling.

Figure 1 – Volume of reported practices per year and ESG pillar (2015-2018)

Source: author’s own elaboration.

Reclassification as a survival strategy

For Douglas (1986), institutions survive through their capacity to make the world legible and to make themselves legible within it. Institutional cognition operates through classification, where each practice, actor, and problem needs to fit into a category. When scandal breaks previous legibility, the institution does not necessarily change what it does, but reclassifies its actions to propose a new order of expectations.

The corpus evidences this mechanism in practices related to leadership, which total 135 records and jump from 53 occurrences in the pre-scandal period to 82 in the post-scandal period – a 55% increase, with a peak of 47 records already in 2017. This jump coincides with a change in framing: leadership training became more focused on scopes of the material theme “Ethics, compliance, and governance,” replacing “Organizational culture management.” Leadership ceases to be a theme of culture and becomes a theme of governance. Facing the crisis, the problem is culture; governance, the solution; and leadership, the vector of the necessary change. The company not only expanded the volume of leadership-oriented practices but reclassified these practices to make them legible in the new field of expectations.

Figure 2 – Transformations in leadership-related action categories.

Source: author’s own elaboration.

The same mechanism operates in the case of “Animal health and welfare”, the material topic with the largest proportional growth in the corpus (from 10 practices in 2015 to 59 in 2018). The JBS scandal involved corruption, anti-competitive practices, and food adulteration, not directly animal treatment. The escalation of animal welfare as a dominant theme constitutes legitimation by analogy: by occupying the technical-productive field with the narrative of care, the company shifts institutional attention from the ethical-political sphere, where the problem lay, to a terrain where it can demonstrate competence and commitment. This is what Douglas would describe as symbolic purification by category displacement.

Figure 3 – Number of actions by most frequent material themes considering the 3 ESG pillars (2015-2018)

Source: author’s own elaboration.

Simultaneously, the social pillar – which, in theory, would concentrate the responses to the ethical and political dimension of the crisis – registers a retraction between 2017 and 2018, falling from 64 to 43 practices. This may be a negative reclassification movement: the company removes from its public discourse precisely the area where exposure was greatest.

Graphs 4, 5, and 6 detail the reconfiguration by material theme within each pillar. In Governance (Figure 4), growth sharply concentrates on “Ethics, compliance, and governance”, the theme with the largest absolute expansion across the entire corpus. In the Social pillar (Figure 6), “Food Quality and Safety”, a theme directly linked to the scandal, even grows between 2016 and 2017, but recedes sharply in 2018, while other themes remain with marginal volumes throughout the entire period. The internal distribution of each pillar supports the already outlined framework: the company’s reorganization occurs preferably around themes that allow for the demonstration of technical and procedural control, not around the ethical-political core of the crisis, which remains in the background.

Figure 4 – Frequency of actions by material themes in the Governance pillar (2015-2018)

Source: author’s own elaboration.

Figure 5 – Frequency of actions by material themes in the Environmental Pillar (2015–2018)

Source: author’s own elaboration.

Figure 6 – Frequency of actions by material themes in the Social Pillar (2015-2018)

Source: author’s own elaboration.

The colonization of the verification ritual

Power (1997) described a process in which auditing ceases to be a technical instrument and becomes a ritual of legitimation. When this occurs, what matters is not what the verification finds, but the fact that the verification exists and can be demonstrated. The audit society is one in which the demonstrability of control replaces the effectiveness of control.

Audit actions (internal and external) are among the most mobile in the corpus, migrating through up to six distinct action categories over the four years. Before the crisis, they mainly resided in “Certifications” and “Production Monitoring”, acting as instruments of technical quality applied directly to the organization’s establishments. After the scandal, they became more numerous in “Supplier Compliance and Engagement Actions” and “Supplier Monitoring”: the verification ritual already operated in the supply chain, but it is repositioned as a response to the crisis, characterizing the relationship with suppliers as a new field of legitimation.

In communication practices, the substitution of campaigns by structured communication channels is observed. In 2015, 50% of communication practices were campaigns – discursive actions, with specific content, with a beginning and an end. In 2018, this proportion fell to 8.3%. What grew were channels: ombudsman offices, newsletters, platforms, service areas, periodic teleconferences. The campaign announces something about a pre-established topic; the channel demonstrates that there is a system through which anything could be announced. For Power (1997), this is the essence of auditability logic: the proof is not the content, but the existence of the structure. The company began to demonstrate that it has a perennial communication structure.

Figure 7 – Comparative evolution between communication campaigns and channels (2015-2018)

Source: author’s own elaboration.

Figure 8 – Volume of communication practices by audience, pre- and post-scandal comparison

Source: author’s own elaboration.

Internal communication deserves attention. Internal channels grow from 4 to 10 practices between 2015 and 2018, but the theme anchoring them shifts from “Organizational culture management”, predominant in 2015, to “Ethics, compliance, and governance”, which comes to concentrate the majority of records in 2018. The company begins to internally transmit the same message it transmits externally: there are rules, there are channels, the system works. Data or metrics on the implementation, receptivity, and use of these channels are not available in the reports. Meyer and Rowan (1977) would designate this as a ceremony of reaffirmation of formal values: the performative reaffirmation that reinforces institutional coherence regardless of any practical effect.

Table 3 – Dominant material theme by communication channel category (2015–2018)

Source: author’s own elaboration.

The stakeholder emerging with the greatest proportional growth is not the one closest to operations, but the one with the greatest capacity to demand accountability: the investor.

From the 2015 report to that of 2018, it is possible to map changes regarding each of the main stakeholder groups. For suppliers, the relationship changed from partner to audited. In the pre-scandal period, engagement was mainly with “Responsible Purchasing Policy” and “Legal Supplier Program”. In the post-scandal period, the dominant instrument became auditing, with “Internal Audits” and “External Audits” as the most frequent actions, establishing new control objectives.

Regarding workers, the shift was from culture to compliance. Before the crisis, the most frequent action was “Animal welfare training”, indicating instrumentalization for productive purposes. After the crisis, the dominant actions are Newsletter, “Compliance training for employees” and “Talent identification for leadership”, emphasizing the worker as a recipient of compliance messages and a reservoir of future leaders, with the relationship becoming denser and focused on internal compliance.

For the sector, the transition was from recognition to belonging. The category “External Recognition” (45 pre-scandal practices) was replaced by “Bonding/Affiliation” (82 post-scandal). The company stopped flaunting awards and started flaunting relationships, seeking to be dissolved into the sector and maintain its identity linked to tradition, with the same legitimizing effect.

Investors have become increasingly central. They were the most invisible stakeholder in the ESG corpus, but in the post-scandal era, they became the group with the largest proportional growth, with a jump of +450% in the number of practices, including periodic conference calls, company visits, dedicated website development, and events. The crisis transformed financial capital into a privileged interlocutor for the ESG agenda, with the sustainability report functioning as a piece of investor relations.

The Market/Expansion group was the only one with a real drop in participation, from 12.7% in 2015 to 5.9% in 2018. The expansion narrative (new companies, new markets, new products) decreased significantly in the post-crisis report. The company interrupted its discourse on growth and replaced it with a discourse on stability, compliance, and improvement. Taking Douglas (1986) as inspiration, this phenomenon can be considered a form of reorientation of institutional memory: JBS stopped narrating itself as an expanding organization and began narrating itself as an organization that leverages existing resources.

The local community was the least considered stakeholder. It fell to practically zero in 2016–2017 (0.4% and 0.3% of the corpus) and returned slightly in 2018 (1.8%). It is the most neglected group in the corpus, which is noteworthy considering it is a company with intensive local impact – factories in small towns, massive employment, land use. The limited expressiveness of the local community in ESG reports, especially during and after the scandal, is an interpretive fact: the company presents itself as a global actor, but imagines itself – or narrates itself – little as a community actor.

The ceremony of compliance

Meyer and Rowan (1977) argued that organizations embedded in highly regulated institutional environments tend to adopt formal structures that mirror environmental expectations, regardless of their operational effectiveness. Symbolic compliance precedes and often replaces substantive compliance. Structures assume a ceremonial role: they assert that the organization is the type that does certain things, not necessarily that it does them.

The corpus offers its most singular finding: the emphasis of a proper name on the action of “Appointment of José Batista Sobrinho to the presidency and new Compliance Directorate” (2017). The change of president and the creation of the compliance directorate are reported as a unique institutional act, in which the person and the system are presented as inseparable. The leadership ceremony and the compliance ceremony merge into a single act of legitimation.

Committees are the most fertile ground for this process. The corpus contains dozens of practices related to committees and councils, distributed almost equally between pre- and post-scandal. The volume does not change much; the nature does. In the pre-scandal period, committees were operational: Finance Committee, Risk Management Committee, People Management Committee, Retention Committee, Solid Waste Committee. In the post-scandal period, committees of an ethical and ceremonial nature are mentioned more frequently: Related Parties and Governance Committee, Institutional Ethics Committee. The company did not create more committees, but it created committees of another type, appointed to mirror the failures that needed to be publicly addressed and resolved.

The Related Parties and Governance Committee, created in 2017 and nonexistent before the scandal, is the most accurate example. The JBS scandal directly involved related party operations and corporate conflicts of interest, and the company responded by creating a committee named exactly with the terms of the problem. Edelman (2016) would call this a symbol of compliance: a structure whose name directly maps the public failure to demonstrate that it has been institutionally resolved.

Figure 9 – Evolution of action categories in the Governance pillar (2015-2018)

Source: author’s own elaboration.

Figure 10 – Active action categories in the Governance pillar by year, pre and post-scandal

Source: author’s own elaboration.

The decoupling and the solution by symbol

The clearest decoupling in the corpus is in the relationship between the nature of the scandal and the response of the Social pillar. The scandal involved practices of systemic corruption, co-optation of public agents, and product adulteration – issues of an eminently social dimension.

The documented ESG response is the +69.5% growth in the Governance pillar between the pre- and post-scandal periods, while the Social pillar – which grew in the immediate heat of the crisis in 2017 – sharply declined already in 2018. The company responded to the social problem by building governance symbols. Edelman (2016) showed that organizations under legal and regulatory pressure tend to solve the compliance problem by creating symbolic structures (compliance departments, written policies, ethics committees), which signal adherence to norms without necessarily transforming behaviors. The symbol of compliance has social value regardless of its practical effect.

Figure 11 – Main categories of action reported in 2017

Source: author’s own elaboration.

Figure 12 – Main categories of action reported in 2018

Source: author’s own elaboration.

The dynamic between sector recognition and belonging is equally revealing. The category “Obtaining awards and recognitions” recedes, while “Affiliation in sector associations and unions” jumps, becoming one of the categories with the highest absolute growth in the corpus. Previously, the company distinguished itself from the sector to gain recognition; afterwards, it dissolves into it to gain protection. By massively reporting affiliation with sector bodies and institutions, JBS imports external legitimacy and dilutes its uniqueness as a target of scrutiny – a mechanism that Power (1997) would describe as social auditability.

The methodology employed makes visible, with unprecedented granularity, how the organization’s narrative strategy reorganizes itself under pressure, revealing patterns of behavior, reclassification, forgetting, and legitimation that conventional content analyses would not capture. Silva et al. (2021) identified the systematic absence of crisis cause diagnosis in JBS documents, and this is precisely the shaded gap that this work empirically mapped through action categories over the years.

The central theoretical contribution lies in the articulation between Douglas (1986) and Power (1997), explored in the dimensions above, to explain at the organizational level processes that previous studies described at the level of managers’ communicational behavior. Institutional forgetting is not just omission, but active reorganization of memory; the verification ritual is not just an image strategy, but the mechanism by which the institution becomes auditable without becoming transparent or completely different.

From a practical point of view, the findings suggest that compliance analysts, ESG risk managers, and investors should adopt a critical stance towards sustainability reports in contexts of reputational crisis, paying attention not only to what is present (new programs, certifications, and indicators), but also to what is absent (the shaded holes where structural questions about the crisis do not appear). The proliferation of formal verification rituals can itself be an indicator of decoupling, rather than transparency.

The sophistication of the filter lies not in what the company does, but in the speed and consistency with which it reorganizes what it says it does and who it claims to be.

4. Conclusion

This study investigated the transformations in ESG action categories reported by JBS Company in its annual sustainability reports, covering the period from 2015 to 2018, with the objective of analyzing how the organization altered its cognitive structure after the intense reputational crisis triggered by Operation “Carne Fraca” (Weak Meat) and its developments. An expressive growth in the volume of reported practices was verified, concentrated mainly in the Governance pillar, which coexisted with a retraction of the Social pillar and the disappearance of substantive categories. It was observed that leadership trainings migrated from the theme of organizational culture to ethics, compliance, and governance, and communication campaigns were replaced by permanent structural channels. Furthermore, it was identified that investors became the audience with the largest proportional growth, and actions focused on awards gave way to sectoral affiliations, reconfiguring the organization’s relationships and its market positioning. These findings evidenced a process of cognitive reclassification and colonization of verification rituals, where the company reorganized its narrative and institutional identity to become legible and auditable in a new scenario of expectations.

The main theoretical contribution of this work lies in the articulation of the perspectives of Mary Douglas (1986) and Michael Power (1997), which allowed us to interpret the observed transformations not only as managerial communication strategies, but as mechanisms of institutional forgetting and the construction of a formal auditability that does not necessarily imply substantive transparency. From a practical point of view, the results suggest that compliance analysts, ESG risk managers, and investors should adopt a critical stance when examining sustainability reports in crisis contexts, paying attention to absences and the proliferation of verification rituals as potential indicators of symbolic decoupling. A limitation of the study lies in the analysis focused on reported actions, without delving into the operational effectiveness of these changes. For future studies, it is recommended to apply the methodology in a comparative approach, analyzing multiple companies from the same sector or in different crisis contexts, in order to identify broader patterns of cognitive reorganization and institutional legitimation. It was concluded that the sophistication of JBS’s legitimation effort resided in the consistency with which it reorganized who it claims to be and for whom, based on the categories of action it reported.

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

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