A eficácia do compliance: uma análise documental em matéria de integridade da Cia Vale S.A.

Abstract

This article aims to analyse Compliance as an institute, generally, as a set of initiatives adopted by companies in order to promote the culture of diligence, legality and ethics in the corporate environment and how it impacts on self-regulatory mechanisms. To this end, it turns to the investigation of the various parameters on legislation and legal doctrine, which must be reflected in these documents that illustrate such commitments. In this regard, it is adopted as reference the “Vale S.A.” program, a large Brazilian company, listed by ​Bolsa Brasil Brasil Balcão (“B3”)​1 in the highest level in terms of corporate governance.The choice is justified by the fact that recently, the Company was the subject of the media and social attention due to the environmental disaster in Brumadinho (2019), which motivates the examination of its public documents in terms of integrity in the period from 2018 to 2020, in order to verify if they embrace the dimension of Vale's responsibility, especially regarding prevention and mitigation of risks that are inherent to its activity.