FCPAméricas Blog

New Tool for Compliance Practitioners Published in Brazil

Author: Carlos Ayres

WagnerA new book published recently in Brazil is a good tool for compliance practitioners. The book, entitled Compliance: A excelência na prática (Compliance: Excellence in practice), was written by Wagner Giovanini, Siemens’s Compliance Officer for Brazil. Having served in this position for several years, Wagner was one of the first compliance officers in Brazil, with deep experience in the area.

With 506 pages divided in 14 chapters, the book covers numerous areas of anti-corruption compliance and related areas. Chapters of the book address topics such as how to design a compliance program, where to place the compliance area within the company, how to interact with other departments of the company (e.g., HR, internal audit, legal, marketing), best practices for implementation of hotlines, how to develop communication and training plans to promote the compliance program within the organization and third parties, how to create controls and processes to access the effectiveness of the compliance program, among others.

The approach taken is highly practical and goes beyond listing specific requirements or best practices. It deals with real challenges faced by compliance professionals and presents ways to address them. Also, the book helps in-house compliance professionals navigate what Wagner calls the “the four hats of compliance”, meaning that the compliance person may have to act as a counselor (when providing an opinion about a specific matter), facilitator (when helping the company to achieve its objectives within the limits of the law), defender (when acting to defend the program and taking appropriate measures, regardless of the person who commits a wrongdoing), and convincer (when explaining to employees that doing the right thing is more than just meeting legal requirements and internal policies).

Wagner explained the purpose of the book:

The idea was to write a useful book, not only from an academic perspective, but also to serve as practical guidance for compliance professionals, regardless of the size or industry of their companies. The idea is not to describe applicable legislation. Rather, it is to focus on daily challenges of compliance practitioners. Readers will come across examples and practical scenarios, which they can adapt, and use in accordance with their reality and needs.

The book was written in Portuguese and, hopefully, it will be translated to other languages in the future so that more people can benefit from it. The book cost R$ 100 (approximately US$ 46) plus shipping and copies can be obtained here or by emailing katia@compliancetotal.com.br.

The opinions expressed in this post are those of the author in his or her individual capacity, and do not necessarily represent the views of anyone else, including the entities with which the author is affiliated, the author`s employers, other contributors, FCPAméricas, or its advertisers. The information in the FCPAméricas blog is intended for public discussion and educational purposes only. It is not intended to provide legal advice to its readers and does not create an attorney-client relationship. It does not seek to describe or convey the quality of legal services. FCPAméricas encourages readers to seek qualified legal counsel regarding anti-corruption laws or any other legal issue. FCPAméricas gives permission to link, post, distribute, or reference this article for any lawful purpose, provided attribution is made to the author and to FCPAméricas LLC.

© 2014 FCPAméricas, LLC

Carlos Henrique da Silva Ayres

Post authored by Carlos Henrique da Silva Ayres, FCPAméricas Contributor

Categories: Anti-Corruption Compliance, Brazil, English, FCPA

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