Cade Advances Investigation Into Possible “HR Cartel”

The General Superintendence of Brazil’s Administrative Council for Economic Defense (“CADE“) is reported to have gathered more than 2,000 documents and other evidentiary items within an investigation involving more than 50 large Brazilian and multinational companies, across two administrative proceedings examining the alleged practice of anticompetitive conduct consisting of the systematic exchange of sensitive information regarding compensation, salary adjustments and benefits among companies operating in Brazil.

The case originated from a leniency agreement executed in 2020 and subsequently gave rise to an administrative proceeding as of 2024, encompassing conduct allegedly carried out between 1994 and 2021.