Building an employment compliance program in Peru for a multinational group

Multinationals rarely arrive in Peru without a compliance framework. They bring a code of conduct, a speak-up policy, a group anti-harassment standard, a health and safety charter and an internal audit calendar. The temptation is either to assume those documents cover Peru, or to commission a full set of Peruvian policies that duplicate them. Both approaches fail in predictable ways. The first leaves statutory gaps that an inspector will find in minutes. The second produces two rulebooks that drift apart, confuse employees and generate contradictory evidence.

The better design treats the Peruvian program as a localization layer: it inherits everything the group already does well and adds only what Peruvian law specifically requires. This article sets out how to build that layer. For the system-level view, see our guide to employment compliance in Peru.

Start from obligations, not from policies

Group programs are usually organized by policy: one document per topic. A local program should be organized by obligation. The difference is practical. A policy says what the group expects; an obligation says what a specific law requires, when it is triggered and what proof of compliance looks like.

The core tool is an obligation matrix. Each row is a statutory duty. The columns record the legal source, the trigger (headcount, activity, event), the frequency, the owner, the control that ensures it happens and the evidence retained. Below is a simplified extract.

The matrix is the program’s single source of truth. Policies, procedures and trainings exist to operate the rows; the evidence column is what the entity would hand to SUNAFIL, Peru’s national labor inspection authority.

The localization layer: what stays global, what becomes local

The architecture that works for most groups has three tiers.

Tier one: group policy, unchanged. Code of conduct, conflicts of interest, anti-bribery, data use, general respect-at-work principles. These apply in Peru as written.

Tier two: a short Peruvian addendum. A single document, owned locally, that states where Peruvian law adds requirements or departs from the group standard and cross-refers to the local instruments. It avoids rewriting group policy while making the local differences explicit.

Tier three: statutory local instruments. Documents Peruvian law requires in a specific form: the internal work rules (Reglamento Interno de Trabajo) for employers with more than 100 workers, the internal harassment policy for employers with 20 or more workers, the internal health and safety regulations for employers with 20 or more workers, the annual hazard identification and risk assessment, and the statutory registers. These cannot be replaced by group documents because their content, approval or delivery is prescribed locally.

The internal work rules are a good illustration. They must contain specific topics, including disciplinary rules and harassment-prevention measures, are filed with the labor authority and must be delivered to workers. Our article on internal work rules in Peru explains how to draft them so that they reference group policy rather than restate it.

Ownership: assign by obligation, not by department

A common failure is assigning “employment compliance” to HR as a whole. In practice, obligations cut across functions. Payroll owns benefit calculations; facilities or operations often run the safety system; legal owns filings; HR owns the harassment procedure and discipline. The matrix should name a role for each row and a backup.

For multinationals, it also helps to separate three responsibilities that group structures sometimes blur:

• The operator, who performs the obligation locally (e.g., the HR business partner who delivers onboarding harassment training).
• The control owner, who checks that it happened and retains evidence (e.g., the local compliance coordinator).
• The oversight function, which tests the control periodically (regional compliance or internal audit).

This is the same three-lines logic most groups already apply to financial controls. Applying it to employment makes the local program legible to regional leadership.

Monitoring: controls an inspector would recognize

A SOX-style mindset transfers well: define each control, its frequency, its owner and the evidence it produces, then test it. The difference is that the test criterion is the Peruvian rule, not the group’s own design.

Examples of monitoring controls that add real value:

• Headcount threshold alert. Several duties switch on at 20 workers and at more than 100 workers. A monthly headcount check against those thresholds, by entity and by workplace where relevant, prevents the entity from drifting into non-compliance through growth.
• Training completion reconciliation. Reconciling safety and harassment training attendance against the active employee list each quarter, not just counting sessions.
• Deadline tracking for harassment cases. A case log that records each statutory step and date, reviewed by the control owner. The full procedure is explained in our article on sexual harassment prevention duties in Peru.
• Safety register review. Periodic review that mandatory registers are complete and retained for the required periods; see occupational health and safety obligations in Peru.
• Independent review. A periodic employment audit, run against local law, validates that the controls are operating. Our note on how an employment audit works describes the method.

Checklist: minimum components of the local program

• An obligation matrix covering labor, benefits, working time, harassment prevention and health and safety, with owners and evidence.
• A Peruvian addendum to group policy, reviewed at least annually.
• The statutory instruments required by current headcount, filed or approved where the law requires it.
• Functioning committees or delegates/supervisors, with records of their constitution and activity.
• A compliance calendar for recurring obligations.
• A case log for harassment complaints and disciplinary procedures.
• A reporting line from the local coordinator to regional compliance, with periodic control testing.

Common mistakes

Translating the group policy and calling it local. A translated policy that omits statutory committees, deadlines and filings adds language coverage, not compliance.

Writing a local policy for everything. Duplicating group policies creates conflicting versions. When they diverge, employees and inspectors will rely on whichever text favors them.

Ignoring workplace-level thresholds. Some obligations depend on the number of workers at the workplace or employer level. Growth at one site can trigger duties the entity has never had to meet.

Treating the program as an HR project. Without payroll, operations and legal in the matrix, large areas of exposure remain unowned.

Consequences of a weak program

The administrative exposure is the most visible: inspection fines are graduated by severity, company size and number of workers affected, and, under Law 28806, may reach up to 200 UIT for a very serious infringement, within an overall cap of 300 UIT for all infringements detected. The UIT, a tax reference unit, is S/ 5,500 in 2026. For a multinational, the less visible costs are often greater: inconsistent documents undermining a disciplinary dismissal, harassment cases mishandled because the global process ignored local deadlines, and audit findings repeating year after year.

Key takeaways

A Peruvian employment compliance program should be small where the group already covers the ground and precise where local law is specific. The obligation matrix, clear ownership and controls that produce inspection-grade evidence do most of the work. Our employment compliance program service helps regional teams design that layer so that it integrates with the group framework rather than competing with it.