This chapter presents findings that are key to understand the current context and main challenges and opportunities to strengthening integrity leadership and building an open organisational culture in the Brazilian federal administration. Currently, integrity is neither systematically considered in the selection, appointment and promotion of senior management position, nor part of leadership trainings. In addition, Brazil is facing challenges in terms of promoting an open organisational culture.
Strengthening Integrity Leadership in Brazil’s Federal Public Administration
Applying Behavioural Insights for Public Integrity
OECD Public Governance Reviews
2. Integrity leadership and open organisational culture in the Brazilian federal administration
Abstract
2.1. Understanding the context
The BASIC methodology requires a deep understanding of the context in which a target behaviour occurs (OECD, 2019[13]). As emphasised in Chapter 1, looking at integrity leadership from a behavioural perspective is interesting at two levels: first, the behaviour of leaders themselves: Are leaders behaving as a role model? Do they provide guidance on integrity and are contributing to creating a safe space where employees can discuss about problems, errors and clarify doubts? Second, the behaviour of the leaders’ employees: Do employees follow their leader, as has been shown in experimental research (D’adda et al., 2017[45]), and could thus become a key leverage for influencing organisational cultures of integrity and openness?
Considering the potential role that leaders could have in promoting a culture of integrity within the public sector, in June 2022 the CGU and the OECD implemented the CGU/OECD Survey on integrity and leadership in the Brazilian Executive Branch. This survey aimed at providing information on leaders’ behaviours and other key factors that could be considered to further strengthen public integrity within the Brazilian Public Administration. The survey targeted high-level officials of the executive branch – this is, people who at the time of the survey were occupying DAS-4, DAS-5, or equivalent positions – across the country, and who additionally directly supervised a work team within a public institution. The survey included questions on sociodemographic characteristics, participation on integrity-related training, exposure to unethical behaviours within the public institution and direct work team, perceptions about openness to dialogue and organisational environment, level of knowledge and approval of UGIs’ management, leadership style preferences, and a vignette experiment aimed at identifying relative determinants of unethical behaviour’s perception (for more information see Annex A).
Additional information used as part of the analysis of this report comes from previous and ongoing work of the OECD on integrity and leadership in Brazil (OECD, 2023[50]; OECD, 2019[51]; OECD, 2021[15]) and from interviews and focus groups carried out by the OECD in the context of this project and the forthcoming OECD Integrity Review of Brazil. In the following sections, this chapter thus presents some findings that are key to understand integrity leadership in Brazil.
2.2. Current challenges to integrity leadership in the Brazilian federal administration
2.2.1. Merit-based selection, appointment and promotion of senior management positions are not systematically implemented in Brazil threatening integrity leadership
In Brazil, leadership (liderança) has been identified as one of the mechanisms for the exercise of public governance, together with strategy (estratégia) and control (controle). According to Decree 9.203/2017, leadership comprises a set of human or behavioural practices exercised in the main positions of organisations to ensure the existence of the minimum requirements for the exercise of good governance (Art 5(I)).
These minimum requirements are:
integrity
competence
responsibility
motivation
Considering the role that leadership plays in achieving good governance, Brazil has recently implemented reforms with the aim of clarifying and consolidating a regime to support and manage senior leaders, which include the design and implementation of a new classification system for senior management positions and a set of common competences for leaders.
Until 2021, the senior managers regime included Senior Direction and Counselling Group (Grupo Direção e Assessoramento Superiores, DAS), commissioned functions (funções comissionadas do poder executivo, FCPE) and various other contract types (OECD, 2019[51]). DAS was Brazil’s dominant system of senior managers, which was structured into six levels of management (operational, tactical and strategic management), DAS-6 being the highest ranking (OECD, 2019[51]). Additionally, several senior positions were handled outside the DAS system, including through the FCPE, which ranged from 1 to 6. The main difference between DAS and FCPE positions was that FCPE positions were reserved for civil servants, while anybody could be appointed to DAS positions. Moreover, appointments into DAS and FCPE positions were, by definition, made at the will of the government and relevant hiring authorities. Appointment criteria were neither systematic nor comprehensive and the vast number of managerial positions were independent from passing a competitive examination (OECD, 2019[51]). In this sense, across the federal administration, there was great heterogeneity in procedures, application forms and criteria for selecting and appointing senior managers, depending on the hiring and selection authority (OECD, 2019[51]).
As of 2021, by means of Law 14.204/2021 and Decree 10.829/2021, a new classification for senior management positions, including minimum criteria for selection/appointment of senior public officials that were previously established by a 2019 Executive Order, came into force. DAS positions have been converted to Executive Commissioned Positions (Cargo Comissionado Executivo, CCE), ranging from levels 1-18, and FCPE positions have been converted to Executive Commissioned Functions (Função Comissionada Executiva, FCE), ranging from levels 1-17. As before, certain positions are reserved for civil servants: 60% of the total number of commissioned positions need to be occupied by career civil servants. Moreover, both CCE and FCE may hold positions of “Advising”, “Management” and “Project Management”; but only FCEs may also hold positions of “Specialised/Technical Management”. Decree 10.829/2021 establishes criteria for appointed senior management positions (cargos em comissão e de funções de confiança), requiring, amongst others, “moral suitability” and an “undoubted reputation”, without defining these further, however.
Additionally, by Normative Instruction SPG-ENAP/SEDGG/ME 21/2021, the National School of Public Administration (Escola Nacional de Administração Pública, ENAP) and the former Ministry for Economy (Ministério da Economia – today Ministry of Management and Innovation in Public Services (Ministério da Gestão e Inovação em Serviços Públicos)) published a set of transversal competences for a high-performance public sector (competências transversais de um setor público de alto desempenho), which apply to all public officials of the federal administration, as well as a set of competences for leaders (competências de liderança), which apply to public officials in leadership positions. Although these competences are not mandatory but are meant to provide public institutions a support framework for setting their People Development Plan (Plano de Desenvolvimento de Pessoas), this is a step towards mapping the skills, attitudes and competences that public sector leaders require.
There are seven transversal competences – i.e. evidence-based problem solving (resolução de problemas com base em dados), focus on results for citizens (foco nos resultados para os cidadãos), digital mindset (mentalidade digital), communication (comunicação), teamwork (trabalho em equipe), ethical values orientation (orientação por valores éticos), and systemic view (visão sistêmica) – and nine competences for leaders. Competences for leaders are organised into three groups – people (pessoas), results (resultados) and strategy (estratégia) – and include the following:
People: i) self-knowledge and personal development (autoconhecimento e desenvolvimento pessoal); ii) people and team engagement (engajamento de pessoas e equipes); and iii) networking and collaboration (coordenação e colaboração em rede).
Results: i) users value creation (geração de valor para o usuário); ii) results management (gestão para resultados); and iii) crisis management (gestão de crises).
Strategy: i) future thinking (visão de futuro); ii) innovation and change (inovação e mudança); and iii) strategic communication (comunicação estratégica).
Despite these reforms, the approach to the senior civil service is still fragmented and it is not accompanied by a broader strategy to further consolidate and strengthen the senior level in the federal civil service (OECD, 2023[50]). This also implies challenges to developing integrity leadership in a more systematic manner. For instance, under the new regime, there are still two distinct groups of senior civil servants (CCE and FCE), where all FCE positions are required to be career civil servants, meaning the CCE can be filled with people who were not required to pass through a competitive examination to enter the civil service. Moreover, it is not required – but voluntary – to undertake competitive selection processes to fill these positions, meaning that most senior civil servants are appointed directly to their position without any formal skills assessment. Additionally, candidates are expected to meet limited criteria to be eligible or hired, which ministries can circumvent under justification addressed to the Presidency (OECD, 2023[50]).
Finally, weaknesses remain in terms of performance assessment, learning and development and open transparent promotion opportunities for senior civil servants (OECD, 2023[50]). Indeed, beyond the selection and hiring process, most OECD countries have a separate and specific performance assessment system that applies to senior civil servants to ensure well-defined goals, aligned incentives, relevant learning and development opportunities and appropriate accountability (Gerson, 2020[21]). More specifically, in over 60% of OECD countries, performance assessments for senior public servants are essential as there is a clear relationship between contract renewal and the results of formal performance assessments. However, in Brazil, although performance evaluation is mandatory during civil servants’ probationary period and for the majority of civil servants every 6, 12 or 18 months, there are some groups that are not evaluated, including public servants who occupy high-level positions. The lack of performance assessment for senior public servants raises specific integrity risks and concerns, especially when considering that many senior public servants are freely appointed – this is, appointed directly to their position without any formal skills assessment.
2.2.2. Currently, integrity is not explicitly part of leadership trainings in Brazil
In Brazil, the ENAP is the main institutional actor responsible for supporting and promoting training programmes for people in leadership positions (Decree 10.369/2020 and Decree 11.094/2022). As part of this mission, in 2020, the ENAP established the LideraGov Programme, a development programme for potential leaders of the Brazilian federal administration (Box 2.1). Additionally, the ENAP has conducted other activities aimed at supporting and promoting training for leaders. These activities include providing postgraduate training in specific policy areas and strengthening partnerships with international leadership training institutions to develop and deliver short-term courses in areas related to leadership in public organisations (Programa de Capacitação para Altos Executivos).
Box 2.1. The Brazilian LideraGov Programme for the federal public administration
The LideraGov Programme (herein “LideraGov”) was established by Joint Ordinance (Portaria Conjunta) 254/2020 as the result of an unprecedented partnership between the former Ministry of Economy and the ENAP. LideraGov makes part of the National People Development Policy (Política Nacional de Desenvolvimento de Pessoas - PNDP) of the federal government (Decree 9.991/2019).
LideraGov targets civil servants (occupying DAS 1, 2 or 3) with the potential and motivation to become leaders. The aim of the programme is to build a network of qualified professionals committed to the generation of public value, with the potential of enacting as innovative leaders, and occupying strategic leadership positions (i.e., DAS and FCPE positions from levels 4 to 6, or equivalent) at the Brazilian federal administration.
LideraGov encompasses four phases, deemed essential for participants to develop the desired skills and abilities:
First phase: selection process. During this phase, candidates who demonstrate having leadership potential are identified. The selection process is merit based and consists of three stages: i) analysis of the profile and professional trajectory; ii) analysis of the leadership potential; and iii) analysis of the professional competencies.
Second phase: qualification course (Curso de Qualificação). Theoretical and practical executive trainings aimed at developing essential skills for public leaders. This phase consists of 120 hours of synchronous activities organised in 8-hour classes given over 9 months every 15 days. In addition, participants have 20 extra hours of activities (synchronous and asynchronous) to support their learning process by enabling the application of the skills learned.
Third phase: Assistance and realisation (Acompanhamento e Efetivação). It takes place in parallel with the second phase and consists in guiding participants through individual and collective mentoring, supporting each participant in preparing a personal development plan, offering feedback sessions, and conducting networking events.
Fourth phase: evaluation of the Programme.
The training path carried out by LideraGov is designed based on three axes, enabling participants to experience a learning process focused on the development of a set of skills related to self-leadership (axis 1), engagement of people and teams (axis 2) and the organisation's strategy (axis 3).
LideraGOV is currently in the second phase of its second edition, which was launched in October 2021.
Source: Interviews conducted by the OECD during the fact-finding missions in Brazil.
However, when it comes to specific training on integrity, evidence suggests that additional efforts are needed to ensure leaders are provided with the skills and abilities to uphold integrity standards, provide timely advice on relevant ethical issues and promote ethical decision making among those they lead. Indeed, the CGU/OECD Survey on integrity and leadership in the Brazilian Executive Branch shows that almost half of high-ranked officials surveyed (45%) have not participated in any ethics related training over the previous two years prior to when the survey was conducted (Figure 2.1), and only 19.7% of high-ranked officials surveyed reported to have participated in three or more ethics related courses. These indicators suggest that even when leaders do participate in ethics-related training, the training intensity is relatively low.
Figure 2.1. Training intensity among high-ranked officials surveyed over the previous two years
Note: High-ranked officials survey were asked “On how many training sessions have you participated in over the last 2 years?”. Maximum value is equal to 15 trainings.
Source: CGU/OECD Survey on integrity and leadership in the Brazilian Executive Branch.
Throughout their career path, public officials are offered to improve their knowledge and acquire skills on integrity. Therefore, it could be expected that the training intensity (understood as the number of courses attended by an official in the last 2 years) should be significantly and positively correlated with age. However, testing this assumption through a simple linear regression, the results did not find a positive, statistically significant relationship between age and training intensity. On the contrary, data suggest that the younger the respondents, the higher their training participation for those who responded to have received more than five courses. This may reflect a need to focus active efforts to reach out to older leaders, while younger generations seem to be more intrinsically motivated to participate in integrity trainings. Finally, when differentiating by gender, female high-ranked officials surveyed seem to be more interested in integrity related training that their male peers. On average, female officials have participated in 1.6 trainings over the previous two years prior to when the survey was conducted, compared to 1.3 trainings in the case of men. This difference is significant at the 10% level.
The limited number of high-level officials that have participated in training on public integrity over the previous two years prior to the survey contrasts with the high number of respondents interested in participating in such a training. Indeed, the CGU/OECD Survey on integrity and leadership in the Brazilian Executive Branch reveals that 68% of officials surveyed indicated being interested in participating in a leadership training/intervention. This suggests that there may be gaps between the type, intensity and/or schedule of trainings provided by the CGU, the Integrity Management Units (Unidades de Gestão da Integridade, UGIs) and/or others, including the Public Ethics Commission (Comissão de Ética Pública, CEP) and the Ethics Commissions (Comissões de Ética), and the type, intensity and/or schedule of trainings expected by senior civil servants – for instance, trainings are scheduled during particularly busy periods, so even if senior civil servants wish to attend they cannot do it. The results thus highlight the relevance of collecting participants’ feedback and developing innovative ways of delivering training on public integrity and integrity leadership.
Moreover, evidence suggest that leaders do not sufficiently engage in raising awareness about integrity and communicating integrity standards within their teams and organisations. Indeed, the 2021 Survey on Ethics and Corruption in the Federal Public Service reveals that civil servants’ training on integrity programmes is limited (only 31.3% of respondents reported having received training on their organisation’s integrity programme), and that integrity programmes are generally little publicised by leaders (only 36% of civil servants said their leaders regularly promoted their organisation’s integrity programmes) (World Bank, 2021[52]). This survey, designed and implemented by the World Bank in partnership with the CGU, the former Ministry of Economy and the ENAP, was implemented in June 2021 and targeted civil servants of the federal administration. The survey includes questions related to human resources, social norms and regulations, behaviour assessment (collective and individual) and corruption reporting mechanisms.
Additionally, evidence from the CGU Perception Survey of Federal Civil Servants on Public Integrity (Pesquisa de Percepção com Servidores Públicos Federais sobre Integridade Pública) complements these findings by showing that 65% of respondents have never participated in a meeting or discussion in their institution related to “integrity”, and that 26% of respondents have not participated in an integrity related training – on conflicts of interests, ethics, information or risk management, nepotism, disciplinary regime, and transparency – in the previous two years prior to when the survey was conducted. This survey was designed and implemented by the CGU in 2022 and targeted civil servants of the federal administration.
2.2.3. Brazil faces several challenges for effectively promoting an open organisational culture in the public sector
The culture of integrity in an organisation is greatly determined by the development and promotion of an open organisational culture (OECD, 2020[18]). Within the context of public integrity, an open organisational culture means employees, managers and leaders feel safe to voice their opinions and actively identify and discuss questions, concerns and ideas on potential violation of public integrity. Building an open organisational culture has several benefits. For instance, it can help cultivate pride of ownership and motivation amongst employees who feel their voice is heard and valued and encourage people to raise and solve integrity questions before they become damaging to the organisation.
An open organisational culture has the following supportive elements: leaders that are responsive and committed to providing timely advice and resolving relevant integrity concerns, and employees that feel comfortable raising integrity concerns and reporting misconduct (OECD, 2017[49]). In Brazil, evidence from recent surveys suggests that the supportive elements of an open organisational culture are still weak, and challenges remain to effectively promote openness within the public sector.
First, leaders have difficulties to communicate about integrity and engage in conversations about integrity concerns. Indeed, according to the CGU/OECD Survey on integrity and leadership in the Brazilian Executive Branch, most high-ranked officials surveyed (54.7%) reported to find it “hard” or “very hard” to discuss unethical practices in their institutions (Figure 2.2). However, this proportion decreases to 33.7% when it comes to discussing unethical practices within the officials’ direct work team, which suggests leaders feel less uncomfortable discussing integrity concerns with their direct peers (Figure 2.2). “Psychological safety” or a safe environment is a baseline condition for openness within an organisation (OECD, 2020[18]; Liang, Farh and Farh, 2012[53]). How to enable an open and safe environment therefore should be a key part of the integrity training for leaders (see Chapter 3).
Figure 2.2. Difficulty to discuss unethical practices within respondents’ institutions and teams
Note: High-ranked officials survey were asked “In your opinion, how difficult is it to talk about unethical behaviours that have occurred within your federal agency?” and “In your opinion, how difficult is it to talk about unethical behaviours that have occurred within your team?”.
Source: CGU/OECD Survey on integrity and leadership in the Brazilian Executive Branch.
Moreover, when differentiating by gender, female high-ranked officials surveyed are more likely to find it “hard” or “very hard” to discuss misbehaviour compared to their male peers, both at the institutional level and within the officials’ direct work team. Indeed, 65% of female surveyed consider it “hard” or “very hard” to discuss misbehaviour at the institutional level compared to 49% of their male peers, and 38% of female surveyed consider it “hard” or “very hard” to discuss misbehaviour at the team level compared to 28.2% of their male peers. Potentially, in addition to reflect a higher discomfort of speaking up, this finding could reflect issues related to sexual harassment in the federal public administration. This hypothesis could be further investigated and addressed by the CGU.
Second, the majority of civil servants do not feel safe enough reporting misconduct, mainly because of the lack of protection mechanisms for complainants and the fear of conflict with other civil servants. Indeed, according to the 2021 Survey on Ethics and Corruption in the Federal Public Service, although a third of all civil servants have witnessed unethical practices in the past three years to when the survey was conducted, only 12% reported corruption in the same period (World Bank, 2021[52]). It is important to point out, however, that not all unethical practices necessarily correspond to corruption. Additionally, a greater number of women reported feeling insecure when reporting (59.6%) compared to men (44.3%), which confirms the finding above from a different perspective and provides a strong case to include a gender lens in CGU’s integrity policies.
Knowledge on integrity programmes seems to reduce these feelings of insecurity when it comes to reporting misconduct: 68% of respondents who fully agreed with having received training on integrity programmes indicated feeling safe to report misconduct, while only 36.3% of respondents who fully disagreed with having received training on integrity programmes indicated feeling safe to report misconduct (World Bank, 2021[52]). These indicators suggest the relevance of strengthening training on integrity as a mechanism to encourage reporting.
Third, as emphasised in Chapter 1, there can be a dark side of leadership. Sometimes, leaders are promoting unethical practices. Indeed, according to the 2021 Survey on Ethics and Corruption in the Federal Public Service, leaders and managers are considered to be the main agents of pressure to civil servants to engage and commit unethical practices. The survey indicates that amongst civil servants who reported having been pressured to engage in unethical practices, 65% indicated that the pressure came from their (direct or indirect) superior (World Bank, 2021[52]). The main unethical practices hierarchical superiors exerted pressure to civil servants to commit were bending the organisation's rules and procedures and overlooking inappropriate behaviours. A deeper analysis on this issue revealed that DAS officials reported having suffered less pressure from their hierarchical superiors but greater pressure from politicians (World Bank, 2021[52]). These findings go against the idea of encouraging a safe environment where employees voice their opinions and feel comfortable discussing ethical dilemmas and unveil challenges to promote openness at different levels of the federal public administration.
Finally, another challenge for effectively promoting an open organisational culture consists in the low levels of perception of the presence of certain key values within senior civil servants’ work teams. Indeed, the CGU/OECD Survey on integrity and leadership in the Brazilian Executive Branch (Figure 2.3) shows that, at the team level, only 17% of respondents “totally agree” that people within their team prioritise the public interest over their individual interests when conducting their public duties, only 19% of respondents “totally agree” that people within their team show respect towards others’ opinions, and only 21% of respondents “totally agree” that people within their team are supportive (solidários). These indicators show clearly the relevance of strengthening an open organisational culture were people feel safe to discuss their ethical concerns and share their opinions, as well as strengthening solidarity and respect within work teams.
Figure 2.3. Senior public servants’ perception towards people within their work teams
Note: This figure shows the percentage of respondents that totally agree “people within their work teams…”.
Source: CGU/OECD Survey on integrity and leadership in the Brazilian Executive Branch.
Despite the several challenges to promote an open organisational culture in the Brazilian federal administration, the CGU/OECD Survey on integrity and leadership in the Brazilian Executive Branch reveals that openness to dialogue is highly appreciated by high-level officials when it comes to handling unethical situations with subordinates. Indeed, when asked for an ideal day-to-day leadership style, the senior civil servants rated “openness to dialogue and tolerance” and “high values and integrity” as more important than leading with an “iron fist and setting clear boundaries”.
This finding was also backed by the results of a vignettes experiment conducted within the CGU/OECD Survey on integrity and leadership in the Brazilian Executive Branch. Indeed, the survey included two vignette sections aimed at revealing senior public officials’ personal preferences based on fictive systematically varied scenarios (see Annex A for more details on this methodology). Amongst others, Vignette 2 (the second set of scenarios) explored the importance of openness to dialogue from the leaders’ perspective when it comes to reacting to unethical behaviours within their team. The results clearly show that the senior civil servants who participated in the survey support the scenario where the leader opened a safe space to discuss misconduct with their employee allowing him/her to share their version of the situation instead of just calling him/her to communicate a sanction. This suggests that despite the challenges previously described, Brazilian leaders value and are aware of the benefits of an open organisational culture within their teams and support an open dialogue between supervisors and employees for handling unethical issues.
Key findings
Recent reforms have been implemented in Brazil to clarify and consolidate the senior civil service regime. Despite relevant improvements, there is still scope to strengthen integrity leadership, including with respect to the lack of systematic merit-based criteria and procedures to select and appoint senior civil servants, the lack of explicit references to integrity in the competences for leaders’ framework and the fact that senior public servants’ performance is not periodically and systematically assessed.
Demand and offer of specific public integrity training targeting high-ranked officials is limited across the Brazilian federal administration. As a result, few high-ranked officials have participated in training on public integrity and even fewer have promoted their employees’ engagement in public integrity training.
Key elements of an open organisational culture in the Brazilian federal administration are weak, and challenges remain to effectively promote openness within the public sector: leaders have difficulties to communicate about integrity within their teams and engage in conversations regarding integrity concerns in their institutions, while civil servants do not feel safe enough to report misconduct.
Differences observed between female high-ranked officials and male high-ranked officials regarding the level of comfort and security to discuss misbehaviour and report cases of corruption suggest the relevance of designing and implementing gender specific integrity policies to effectively encourage an open organisational culture.
Despite the several challenges to promote an open organisational culture in the Brazilian federal administration, leaders value and are aware of the benefits of an open dialogue with their employees for handling unethical issues and concerns.