INTEGRITY PROGRAMS IN PUBLIC PROCUREMENT: ANALYSIS OF COMPLIANCE EFFECTIVENESS AS AN ANTI-CORRUPTION REGULATORY INSTRUMENT IN LAW 14.133/2021

Abstract

This study analyzes the effectiveness of integrity programs as an anti-corruption regulatory instrument in public procurement governed by Law 14.133/21. The New Public Procurement Law innovated by making mandatory the implementation of compliance programs by companies contracted for large-scale works and services, using state purchasing power to induce ethical behaviors in the private sector. Through narrative and qualitative bibliographic review of legislation, specialized doctrine, and academic production published between 2015 and 2025, legal foundations, legislative trajectory, preventive potentialities, and practical inconsistencies of this requirement were identified. Results reveal that the measure has solid constitutional basis, aligns with international governance standards, and presents potential to qualify bidding processes through selection of companies with better organizational culture. However, significant risks of facade compliance, monitoring difficulties due to institutional capacity limitations, and disproportionate impacts on micro and small enterprises are evidenced. Analysis demonstrates that regulatory policy effectiveness does not automatically derive from normative provision, depending crucially on rigorous monitoring, objective evaluation criteria, and consistent enforcement. It is concluded that Law 14.133/21 represents significant legislative advancement, but materialization of its anti-corruption potential remains an implementation challenge that will require investments in manager training, integration among control agencies, and lasting cultural change.