Programa de integridade e compliance: um modelo aplicável a municípios

Abstract

The enactment of Federal Law No. 12.846/2013 and the recommendations of the Organization for Economic Cooperation and Development (OECD) served as driving forces for public institutions to implement integrity programs aimed at better serving the public interest. In this context, the general objective of this study is to analyze the activities, tasks, and processes required for the implementation of an integrity and compliance program in municipalities. The research is qualitative, documentary, and descriptive in nature, employing a case study of the Office of the Comptroller General and Ombudsman (CGM) of the Municipality of Fortaleza. Data collection was conducted through document analysis and interviews with 21 public servants involved in the program, and the information gathered was examined using content analysis. The interviews sought to capture perceptions regarding the implementation, effectiveness, and impact of the program, as well as to gather suggestions and recommendations for improvement. Additionally, based on a survey carried out among municipalities in the Metropolitan Region of Fortaleza, a model of Integrity and Compliance Program applicable to municipalities was proposed, grounded in the case study. The case study in Fortaleza’s CGM highlighted that, when properly structured, implemented in stages, and supported by senior management, an integrity and compliance program can transform organizational culture, promote transparency, and strengthen public trust. It also revealed that there will always be opportunities for improvements and adjustments to new policies and innovations within the cultural process of public integrity. The study concludes that implementing an Integrity and Compliance Program is not only a necessary measure for legal compliance, but also a strategic tool for improving public governance.