CADE adopts new Code of Ethics for public officials

The Administrative Council for Economic Defense (CADE) has updated its Code of Ethics, setting out the principles, values, and standards of conduct for its public officials. Introduced by Resolution 39, of 29 October 2026, the Code aims to strengthen institutional integrity, guide professional conduct and bring CADE's internal rules into line with federal ethics regulations.

The update is part of the CADE Ethics Commission's (CECADE) broader efforts to promote ethical conduct and institutional integrity, including its 2026 educational campaign, ‘Ethics, Dialogue, and Responsibility in Competition Defence’.

The review began in 2022 and was led by CECADE and its Executive Secretariat, with input from other units, staff, and external stakeholders through a public consultation. The proposal was also reviewed by the Office of the Attorney General at CADE (PFE/CADE).

The new Code consolidates guidance on integrity, conflicts of interest, harassment, discrimination, nepotism, and information protection. Clearer, more consistent guidance is intended to give officials greater legal certainty in their work and help maintain public confidence in CADE.

The Code draws on four key federal measures: Decree 10571/2020, on asset declarations and potential conflicts of interest; Decree 10889/2021, on public agendas, meetings, and events; Law 14540/2023, on preventing and addressing sexual harassment, related offences, and sexual violence; and Decree 12122/2024, on preventing and addressing harassment, and discrimination across the federal administration.

It also reflects MGI Ordinance 6719/2024, Public Ethics Commission (CEP) Resolution 21/2025, and Joint CGU/CEP Ordinance 3/2025, among other updates to federal public-service ethics, and integrity standards.

The Code brings previously scattered guidance into one document and clarifies CECADE's preventive, advisory and educational role in promoting integrity.

Guidelines for ethical conduct

Resolution 39/2026 sets out principles for CADE officials, including legality, impersonality, impartiality, morality, transparency, efficiency, human dignity, gender equity, respect for diversity, and action against harassment and

discrimination. They also promote transparency and integrity in CADE's dealings with other public officials, market participants, and the wider public.

The Code also clarifies officials' rights and duties, including a healthy workplace, ongoing training, personal-data protection, and safeguards against retaliation for reporting misconduct. Officials must uphold ethical principles, safeguard confidential information, prevent conflicts of interest, and disclose circumstances that could affect their impartiality.

The rules also cover technology and AI tools, interactions with external parties, participation in meetings and events, and other risks to institutional integrity.

Preventing conflicts of interest

The Code sets clear guidance for identifying, reporting, and preventing conflicts of interest, reinforcing impartial decision-making in the public interest. It also addresses nepotism, privileged information, and dealings with individuals or organisations with matters before CADE.

Aligned with federal rules, the provisions help officials identify and report situations that could compromise their independence.

Ethics guidance and oversight

CECADE will continue to provide guidance, promote ethical conduct and monitor application of the Code, in line with its mandate and federal ethics-management rules.

Breaches may result in measures under the applicable rules, including ethical censure, a Personal and Professional Conduct Agreement (ACPP – Acordo de Conduta Pessoal e Profissional) or recommendations, depending on the circumstances.

The update brings CADE's ethics and conduct standards into a clearer framework, following a review involving staff, departments, and external stakeholders. It reaffirms CADE's commitment to ethical, transparent and respectful public service, preventing misconduct and building public trust.

Resolution 39 repeals Resolution 19/2017 and takes effect 60 days after its publication.