From ancient Greece to the present day, there has been a quest to understand, judge, critique, and improve moral behavior and human conduct in society. This human perseverance has always had a common goal: to establish a better way of life for all of us—society. This is what we call “ethics.”
As we define what is ethical or not, we establish standards of conduct that become habits, traditions, and even codes and laws. To ensure these behaviors are followed by all, many organizations have established so-called ethics and compliance programs. In Brazil, some public institutions have given it a more comprehensive name—integrity programs.
This progress was largely driven by the corruption scandals that plagued mainly the United States starting in 2000 with the Enron case, later affecting major European companies, and eventually reaching Brazil with the Mensalão scandal and Operation Car Wash.
The outcomes of these investigations were quite similar: companies paid extremely heavy fines; executives, partners, and even board members were dismissed, prosecuted, and imprisoned—not to mention the immeasurable damage to their image and reputations, forever recorded in books, articles, newspapers, films, and other media. Even if the involved companies changed their names or addresses, they will always be remembered for these events. Digital memory does not forgive; it is eternal.
On the positive side, these large corporations had to establish so-called ethics and compliance (or integrity) programs. These programs involved applying various elements such as implementing internal controls and continuous education on ethics, laws, codes, and behavioral standards expected by society as a whole. Beyond ensuring the effectiveness of contractual and legal commitments among all related parties, additional elements—such as ongoing anti-corruption risk management, conflict-of-interest prevention processes, audits, independent whistleblowing channels, and continuous investigations—were implemented to uphold the highest standard of integrity.
On the other hand, not everything is rosy! Those affected by these processes fought back, and just as in Italy with the “Clean Hands” operation, those involved in Operation Car Wash faced setbacks. Despite progress toward more ethical conduct standards, recent years have seen a relaxation in punishment processes and new investigative initiatives. Executives and political figures received reduced or canceled sentences, while prosecutors were persecuted and/or left their positions.
Adding to this narrative, recent decisions by the new U.S. government have also contributed to weakening anti-corruption efforts. By order of the U.S. President, one of the most important laws driving investigations into governmental corruption worldwide—the Foreign Corrupt Practices Act (FCPA)—faced a suspension request alongside guidance for the Department of Justice to halt investigations against companies and individuals.
Furthermore, due to the above, we have observed a growing scenario where many companies no longer take integrity programs seriously. Many now have ineffective programs—merely for appearances or to qualify for bids—but in reality, they offer nothing. Worse, integrity functions are again being merged with legal departments, and leadership roles are being handed to junior employees to serve only commercial interests. Companies don’t want integrity leaders at the decision-making table; they want them to simply “follow orders.”
The effects of this setback on corporate integrity programs and their degree of impact remain uncertain. The guardians of these programs—known as compliance officers or compliance executives—are bewildered, and many refer to the current times as difficult or even “strange.” Additionally, top management support has truly weakened. As if this weren’t enough, we also see attacks on other ethics-related initiatives, such as the cancellation of diversity and inclusion programs or sustainability efforts like ESG.
Faced with this scenario, doubt, uncertainty, and fear of regression take hold. Initially, some companies may quickly adopt the new trend by restructuring, downsizing, or even dismantling ethics and compliance programs—clearly demonstrating they acted out of obligation, not principle or values.
However, others will maintain certain standards, recognizing that an integrity program goes far beyond legal compliance. A company with the highest standard of conduct has much to gain—beyond reputation and image. Its entire ecosystem of suppliers, partners, customers, and especially employees desires a better, more ethical way of life. In this environment of integrity, relationships are stronger and more transparent, results are more solid, and there is no doubt that everyone wants to see this company succeed.
And for those who don’t believe in ethics, compliance, or integrity—who believe only in making money and the survival of the shrewdest—a reminder is needed:
First, all movements are pendulum-like—what goes up must come down. Today, we face an attack on ethical principles—concepts already understood, judged, refined, and tested. There’s no need to prove corruption is harmful to social well-being. So beware—this pendulum will swing back, especially when new and larger public and private corruption scandals emerge again. Society is tired of being deceived.
Second, Newton’s third law doesn’t need further proof—every action has an equal and opposite reaction. This attempt to dismantle societal progress has generated resistance that will soon become a counter-force. Prosecutors, judges, compliance executives, ethics advocates, sustainability champions, board members, and others aren’t passive—they’re reflecting, even frustrated, seeking a solution that will come. As the saying goes: “Think compliance is bad? Try non-compliance.” Sadly, many companies are taking this risk—tossing a coin and hoping it won’t land on the ground.
Third, for those who have seen and lived through scandals involving countless public and private companies engaged in corruption—people imprisoned and convicted, businesses and families destroyed, and reputations eternally tarnished—weakening these programs means taking a huge risk. For companies that value good governance and for board members who had to pick up the pieces post-disaster, either a lesson was learned—or another one will be needed in a few years.
In the end, for those who uphold ethics as a principle—not an obligation—this is a time for resilience. The wheat will soon be separated from the chaff. Until then, rowing without wind, patience, steadfastness, and refusal to retreat are necessary—for in the end, integrity prevails.
