CGU adopts ESG focus and publishes “Integrity Programme: Sustainable Practices for Private Companies”

In brief

The Office of the Comptroller General (CGU) announced yesterday, November 25, 2024, the publication of the document “Integrity Program: Sustainable Practices for Private Companies”, which was chosen as the “Outstanding Action of ENCCLA 2024″. This guide, developed by the Private Integrity Secretariat, reflects the CGU’s new, broader position on ESG issues and provides new integrity guidelines to prevent and combat corruption and fraud in connection with projects with environmental impacts.

The guide contains 53 integrity guidelines organised into ten strategic areas, providing a valuable resource for companies seeking to implement effective compliance programmes. These guidelines complement Volumes I and II of the Integrity Programme: Guidelines for Private Companies” and are designed to help companies adopt ethical business practices and protect the environment from crimes that affect not only the sector but society as a whole.

Main Requirements and New Practices for Private Companies

Private companies should review and, if necessary, update their compliance programmes to align them with the new ESG integrity guidelines.

Below are practical examples of what the CGU expects companies to adopt to comply with the guidelines in the Integrity Programme: Sustainable Practices for Private Companies” guide:

• Involve senior management in the discussion and approval of standards, policies and procedures related to social and environmental strategies and commitments, social and environmental impact materiality studies, environmental protection and anti-corruption, including the code of conduct, anti-corruption policy and sustainability reports;
• Allocate a specific budget for environmental integrity and sustainability activities;
• Establish environmental integrity criteria for the selection of senior management, including background checks for environmental crimes;
• Demonstrate to internal and external audiences the ongoing and unequivocal support of senior management for ethical practices, integrity and social and environmental responsibility in activities and processes involving the use of natural resources;
• Develop and implement clear policies, guidelines and internal controls that prevent, control and remedy acts or schemes of asset laundering related to violations, crimes and environmental damage, in accordance with applicable regulations and best national and international practices;
• Provide sustainability, integrity and environmental risk management training to senior management;
• Apply a due diligence process, based on integrity risks, to verify the history of suppliers and conduct an ongoing assessment of the legality of the origin of natural resource inputs (the CGU even identifies specific sources for research);
• Establish and implement mechanisms to analyse, audit and verify the origin and possible traceability of natural resources used by the company as raw materials or inputs in its operations, products and activities; and
• Establish a dedicated process for investigating and addressing complaints and remediating illegal activities in which the company is involved, as well as the associated environmental impacts.

These measures are essential for private companies to adapt to the new guidelines and ensure that their operations are in line with best integrity and sustainability practices.

The Ethics, Compliance & Investigations team is available to discuss the guide and offer all the necessary support to our clients.