Os 3 pilares da ISO 37001:2017 – Sistemas de Gestão Antissuborno

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Entenda os 3 pilares da ISO 37001:2016 e saiba como ela pode ajudar a combater práticas de suborno e corrupção nas empresas!

A ISO 37001 foi lançada em 2016 e gerou certo alvoroço no mercado. Afinal, sabemos que corrupção e suborno, infelizmente, são um problema crônico em nosso país. Porém, aqui na QMS, nós acreditamos que as certificações e sistemas de gestão têm o poder de mudar a realidade do país. Por isso acreditamos que essa norma é importante!

A 37001 pode ser uma poderosa arma para as organizações melhorarem sua performance e contribuírem para manutenção da integridade de sua gestão. Por isso, no artigo de hoje, vou falar sobre os 3 pilares da ISO 37001:2016. Também quero falar sobre o escopo da norma e sobre uma questão um pouco polêmica.

Antes de mais nada, vejamos os 3 pilares:

Prevenção

A 37001 é uma norma propositiva, dessa forma, contém requisitos que se destinam a atacar e combater o suborno. Assim, parece lógico que um dos pilares da norma seja prevenir, ou seja, tentar evitar que o suborno ocorra.

Detecção

Vamos falar disso mais a frente, mas obviamente uma norma (por melhor e mais robusta que seja) não é garantia incontestável de que o suborno não vá ocorrer. Além disso, podem ocorrer casos em que a implantação da norma ocorra após a incidência de casos de corrupção e suborno.

Portanto, a norma precisa conter requisitos que auxiliem na detecção, ou seja, na descoberta de possíveis ocorrências de suborno.

Resposta

De nada adianta detectar casos de suborno se a organização não executar ações certeiras contra esse mal. Por isso, um dos pilares da ISO 37001:2016 é ajudar as empresas a criar respostas e planos de ação para possíveis casos de suborno. Aliados aos pilares anteriores, a Resposta ajuda a criar um Sistema Antissuborno completo.

A ISO 37001:2016 atua apenas contra Suborno?

Uma questão comum de profissionais que estão começando a se aprofundar na ISO 37001 é se ela atua apenas contra o suborno. Para responder a essa questão, quero recorrer a um trecho do Escopo da norma. Vejamos o texto na íntegra:

“Este Documento é aplicável apenas a suborno. Ele estabelece requisitos e fornece orientações para um sistema de gestão concebido para ajudar uma organização a prevenir, detectar e responder ao suborno e cumprir com as leis antissuborno e comprometimentos voluntários aplicáveis às suas atividades.

Este Documento não aborda especificamente fraude, cartéis e outros delitos antitruste/anticoncorrencial, lavagem de dinheiro ou outras atividades relacionadas a práticas corruptas, embora uma organização possa escolher ampliar o escopo do sistema de gestão para incluir estas atividades.” (inserir como citação)

Assim, respondendo à pergunta: a norma foi criada para atuar contra práticas de suborno. Entretanto, cabe à organização definir qual é a maior ameaça que cerca seu entorno, ou seja, quais riscos ela quer gerenciar. Podendo, então, abordar temas como:

  • Fraude;
  • cartéis e outros delitos antitruste/anticoncorrencial;
  • lavagem de dinheiro;
  • outras atividades relacionadas a práticas corruptas.

Portanto, a definição do escopo é extremamente importante na concepção e implantação de um Sistema de Gestão ISO 37001:2016. É o escopo que define os limites e aplicabilidade do sistema de gestão. O que, por sua vez, vai impactar na definição do contexto da organização, das partes interessadas e, obviamente, na avaliação de riscos.

Organizações que implantarem corretamente os pilares da 37001:2016 vão extinguir o suborno?

Essa é outra questão que ronda a cabeça de muitos profissionais. Da mesma forma, também é algo que gera polêmica e até mesmo descrença sobre a norma. Afinal, implantar a 37001:2016 é garantia de que o suborno e corrupção vão deixar de existir? Vejamos o que a própria norma tem a dizer:

“A conformidade com este Documento não pode fornecer garantia de que nenhum suborno tenha ocorrido ou ocorrerá em relação à organização, uma vez que não é possível eliminar completamente o risco de suborno. Entretanto, este Documento pode ajudar a organização a implementar medidas razoáveis e proporcionais concebidas para prevenir, detectar e responder ao suborno.” .(inserir como citação)

Seria no mínimo imaturo acreditar que um sistema possa garantir 100% de inviolabilidade. Principalmente quando o assunto são problemas tão graves em nossa cultura. Entretanto, como a própria norma diz, um Sistema de Gestão Antissuborno fornece ferramentas e ações sistêmicas que ajudam a tratar riscos desse tipo.

Compliance, Caso ou Acaso?

Pensando nisso, deixo então uma provocação: mesmo que não possamos fornecer garantias de que “nenhum suborno tenha ocorrido ou ocorrerá”, quais empresas estarão mais vulneráveis a perecer diante do suborno? Quais empresas sofrerão mais e terão mais prejuízos com essa prática? Vejamos as opções:

  • Opção A: as que tem um Sistema de Gestão Antissuborno implementado e consolidado, com ações estabelecidas para Prever, Detectar e Responder a ocorrências desse tipo?
  • Opção B: empresas que não tem nenhuma iniciativa nessa área?

Não precisa ser nenhum Guru ou especialista em sistemas de gestão para entender que a alternativa A é a melhor das escolhas. Nela, contaremos com algo concreto e palpável, com um sistema que roda, atua e melhora constantemente.

Na opção B, mantemos a Anticorrupção à cargo do acaso. Muitas vezes, contamos com a boa fé de nossas organizações, pois sabemos como funcionam os processos que gerenciamos. Entretanto, quanto maiores forem nossas empresas, consequentemente mais relações com outras empresas teremos. Nesses casos, será que vale a pena deixar os riscos de Suborno e Corrupção ao acaso?

 

 

80 comentários em “Os 3 pilares da ISO 37001:2017 – Sistemas de Gestão Antissuborno”

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