As a step towards implementing Fiduciary duty in the 21st century’s recommendations, the Brazil roadmap makes recommendations in five categories: regulatory action, investor education, corporate reporting, stewardship and engagement and industry guidance. 

Regulatory action

  • The Superintendence of Private Pension Funds (PREVIC) should recommend a revision to Resolution 3.792 which governs investment practices and disclosures by closed pension schemes.
  • Oversight and monitoring by the Central Bank of Brazil (the Central Bank) of the impact of Resolution 4.327 on the investment activities of relevant regulated entities.

Investor education

  • Industry associations and accreditation agencies to collaborate on raising ESG awareness and practical training provision.

Corporate reporting

  • The securities regulator (CVM) should review the effectiveness of reporting of material ESG factors by Brazilian corporations.

Stewardship and engagement:

  • CVM should adopt the Brazilian Association of Capital Market Investors’ (AMEC) stewardship code.


  • Regulatory and industry associations to provide guidance for asset managers and private pension providers on the scope and content of their fiduciary duties.

This work also sets the Brazilian capital market in a broader international context, as regulators and investors respond to a rapidly-changing investing environment. Following assessment of seven further markets (Australia, Canada, Germany, Japan, South Africa, UK and US), the PRI, UNEP FI and The Generation Foundation will prioritise the areas to which we will contribute.

Produced in collaboration with UNEP FI and Generation Foundation

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