Previ: Collective engagement on integrity and anti-corruption

Give a brief overview of your initiative, its objectives, and why you decided to undertake it.

Integrity has been important to investors in Brazil, but the theme gained even more prominence in the past few years, amid cases of corruption involving big companies. In response, investors increasingly demand best practice and greater transparency, and are focusing more on stewardship and engagement.

In a fast-evolving environment, the PRI Collaboration Platform is extremely helpful. Indeed, 35 Brazilian and international investors, supported by the PRI, have formed a working group to develop responsible investment through the engagement of major Brazilian companies, focusing on best practice in integrity and strengthening the fight against corruption.

For this work, publicly traded companies from different sectors were selected from the Brazilian Stock Exchange. Of the 19 companies initially pre-selected, 12 were interviewed.

Before the interviews, the first step was to develop a questionnaire. The questionnaire covered: relations with public entities; engagement of senior management; integrity programme management; integrity documents; training; whistleblowing channels; disciplinary measures; monitoring/indicators; collective actions; and communication/dissemination. The questionnaire was submitted to the selected companies, and responses informed the interview process.

The interviews were exclusively with representatives of each company, but were open to members of the engagement group. Companies provided detailed insights and we discussed how they could implement integrity and anti-corruption best practice.

After finishing the interviews, a final report was sent to all investors and companies that took part. The document was also annexed to the PRI Collaboration Platform.

Describe how your initiative is aligned to Active Ownership 2.0.

Our collective engagement initiative on integrity and anti-corruption measures is aligned with Principle 5: “We will work together to enhance our effectiveness in implementing the Principles.”

The purpose of this work was to promote best practice to help develop integrity and anti-corruption measures in Brazilian companies. While effective integrity programmes have been identified in recent years, a key concern for this work was whether we would be able to catalyse effective action that would reflect investor priorities and goals. This type of initiative is consistent with Active Ownership 2.0, which builds on existing practices and experiences, but explicitly prioritises collective efforts aimed at achieving concrete outcomes.

Despite the inherent difficulties of collective work, as pointed out in Active Ownership 2.0, several stakeholders said that the initiative was positive and worthwhile. Many investors said the initiative was rewarding from their point of view.

Informing the initiative was our collective experience in other engagement programmes and the integration of the Brazilian signatories network. The structure of the PRI and the ability to bring together investors with the same purpose was also paramount.

PRI representative in Brazil, Marcelo Seraphim, played an important role in the interaction with the PRI and in teaming up the signatories. The group also used PRI tools such as the Collaboration Platform, which facilitated invitations to other signatories, especially outside Brazil, and helped us organise and disseminate documents. The work was also presented to PRI employees, as a reference for initiatives on integrity and the fight against corruption.

The COVID-19 pandemic presented some obstacles, including the need to postpone several interviews. Indeed, we decided to put the project on hold for a while, before restarting. Still, at the end of the work, the group concluded that there is a clear movement in the market towards the adoption of good practice in integrity and anti-corruption measures. In addition, investors are thinking more carefully about the theme and asking more questions in their investment processes and decisions.

Another matter that became clear from the engagement work was that companies need to increase disclosure of information about integrity and anti-corruption measures, as well as the key indicators of effectiveness of integrity programmes. This would allow investors to more deeply incorporate the theme into investment analysis. It will also be important to monitor progress across the Brazilian market.

The results achieved in the initiative to date, including: evaluation of its success against the objectives; any adjustments to plans going forward; and any insights learned from this project that can be applied more broadly?

Stakeholders gave very positive feedback to the initiative and its results. The first sign of positive impact was the fact that interviewed companies agreed for their names and logos to be included in the final report. This went beyond their initial commitment. Many felt the report should be used as a reference in the market, and that they would like their brands to be linked to the work.

Several interviewed companies said the work would be used as a guide for good practice, mainly through use of the questionnaire. With the feedback provided by investors and the report, companies reported that they were able to analyse and identify action points and compare themselves to peers. Focus areas included preserving anonymity in reporting channels, disclosure of indicators, and the company’s impartiality when the person involved is a member of top management.

The initiative generated invitations to the signatories to participate in debates and webinars about integrity and anti-corruption measures. It was also used as a study case to show a practical example of engagement. A leading newspaper published an article on the work and its results.

Building from the success of this initiative, we intend to use the model to widen engagement work with companies on the Brazilian Stock Exchange on integrity and anti-corruption measures. We also intend, with the PRI, to develop a new engagement initiative focusing on social issues and diversity and inclusion.