Third-party lifecycle management for Brazil operations
Last updated: August 19, 2026
Verdana is a third-party lifecycle management platform that helps companies operating in Brazil manage supplier and contractor due diligence, documentation, and labor-liability exposure in one system, built around Brazil's specific mix of anti-corruption and labor law.
The Lei Anticorrupção (Lei 12.846/2013) imposes strict corporate liability for acts against public administration, and explicitly reaches acts done through an interposed third party or advantages given indirectly. Decreto 11.129/2022, Article 57, names risk-based due diligence on the hiring and supervision of third parties — suppliers, service providers, intermediaries, consultants, and commercial representatives — as one of the evaluation criteria for an effective integrity program. Verdana runs that side of the program: risk-based third-party classification, documented due diligence at onboarding, and continuous monitoring with a dated record of every check.
Outsourcing labor in Brazil (Lei 6.019/1974, as amended) can make the contracting company subsidiarily liable for a service provider's unpaid labor obligations, and jointly liable for its Social Security contributions, when the provider defaults — a liability regime Súmula 331 of the TST has applied consistently. Verdana tracks each contractor's registration and standing so a lapse shows up as an expiring document, not as a labor claim discovered after the fact.
Brazil sits alongside the rest of Latin America, the United States, and Europe in the same platform: document requirements are configured per jurisdiction, and headquarters gets one consolidated view of every supplier and contractor regardless of where they operate.
Frequently asked questions
Does the Lei Anticorrupção require due diligence on third parties specifically?
Decreto 11.129/2022, which regulates the law, names risk-based due diligence in the hiring and supervision of third parties — suppliers, service providers, intermediaries, consultants, and commercial representatives — as one of the criteria evaluated for an effective integrity program, alongside the company's own internal controls.
Are we liable for a contractor's unpaid wages in Brazil?
Outsourcing law can make the contracting company subsidiarily liable for a service provider's labor debts if the provider fails to pay, and jointly liable for Social Security contributions during the engagement — a pattern Brazilian labor courts have applied consistently under Súmula 331 of the TST.
What counts as an "interposed person" under the Lei Anticorrupção?
Using a third party — an intermediary, a shell entity, an agent — to conceal the real party in interest behind an improper advantage to a public official is itself a violation under Article 5, independent of who ultimately delivered the payment.