Modelo de avaliação da maturidade de um programa de compliance: uma aplicação no SENAC/Bahia

Abstract

The present study proposed to develop a model for assessing compliance program maturity, based on the analysis of factors that make it possible to identify the level at which an organization is found, based on the verification of evidence in the dimensions evaluated. These factors were identified in the analysis matrix elaborated from the Manual Prático de Avaliação do Programa de Integridade, prepared by Controladoria Geral da União (CGU), in KPMG's compliance maturity survey, in the questionnaire to assess companies that are part of the Cadastro Nacional de Empresas Comprometidas com a Ética e a Integridade (Empresa Pró-Ética) and in the document called Evaluation of Corporate Compliance Program – DOJ (Department of Justice). This work was based on the premise that it is important to analyze the level of maturity of a compliance program based on the analysis of factors that make it possible to guide its implementation. To validate the model, it was applied at SENAC Bahia, an institution that is part of the Autonomous Social Service and that provides a service to society with relevant participation. The basis of the study was based on the Agency Theory, corporate governance, and the literature on compliance from the perspective of CGU, ISO 19.600:2014, the Committee of Sponsoring Organizations of the Treadway Commission (COSO), Foreign Corrupt Practices Act (FCPA), and Brazilian Anti-Corruption Law. Methodologically, for data collection, some instruments were used, namely: bibliographical research, documental research, interviews with strategic managers and application of a questionnaire for employees of SENAC Bahia, distributed by five groups of function for analyzing the perception of the existing compliance program. For data treatment, the analysis was performed using descriptive statistics, the correlation between the variables of each index, and the boxplot analysis, which indicated the dispersion of the data obtained in the research. The result of the survey showed that SENAC Regional Bahia is making efforts to improve the maturity indexes achieved, identified in the survey with an index of 2.68, classified as a sustainable level, thus indicating the existence of compliance practices implemented in the Regional. However, it was noted that there is a way to go to reach more advanced levels in improving existing practices and maintaining compliance with regulatory agencies. The model and factors suggested in the evaluation matrix and validated are sufficient to define the maturity of a program, which can be, in other researches, improved and used other parameters from updated sources. It can also be applied to other institutions or organizations, including adjusting its nature and size, in order to identify the level of maturity to support action plans and guide the implementation of compliance programs.