Restruturação da governança corporativa e de compliance em uma situação de crise: O caso da Odebrecht S.A.

Abstract

The overall purpose of this research was to assess the restructuring process of Odebrecht S.A. corporate governance and compliance in the context of the development of its Compliance System, in response to contemporary challenges faced by the company. In order to do so, we analyzed company's documents and records and made individual interviews with key people in the development of the compliance system. The study concludes that: (a) corporate governance and compliance restructuring and senior management actions to sponsor / reinforce the program have boosted Odebrecht SA 's compliance system improvement, without, however, reaching the targets contained in the commitments made with competent authorities; (b) by establishing a responsible body, staffed by adequate people and resources, a permanent structure was established for the evaluation and improvement of processes of compliance and dissemination of experiences and best practices; and (c) in spite of having published a policy on the subject, Odebrecht S.A.'s risk management process is still incipient, as there is no formal risk mapping as well as a definition of maximum acceptable exposure for them.