Attorney advertising & terms of use

OBJECTIVE

SCOPE

OBLIGATION TO KNOW AND COMPLY WITH THE CODE OF ETHICS

GENERAL ETHICAL PRINCIPLES

• RESPECT FOR PEOPLE

  Moral and/or sexual harassment, abuse, intimidation, disrespect and lack of consideration or any other type of physical or verbal aggression are unacceptable, neither allowed nor tolerated at work.

• DIVERSITY

  Promoting diversity means recognizing and valuing differences to enrich personal relationships and boost performance. This involves creating an environment of acceptance and respect, without prejudice, in which each individual is encouraged to contribute with their talents to the OFFICE’s development.

  Diversity encompasses a range of individual characteristics that may include, but are not limited to, sex/gender, race/color/ethnicity, nationality, age, physical condition, disability, sexual orientation, marital status, social class, ideas, religious beliefs or their absence, political affiliation or union membership.

• EQUAL OPPORTUNITIES AND NON-DISCRIMINATION

  It is the OFFICE’s basic principle to provide the same opportunities in terms of access to work and professional promotion for all Collaborators. Discrimination based on sex/gender, race/color/ethnicity, nationality, age, physical condition, disability, sexual orientation, marital status, social class, ideas, religious beliefs or their absence, political affiliation or union membership are not tolerated, being such act characterized as a breach of this Code of Ethics and also a violation of the law.

• COLLECTIVE RIGHTS

  Collaborators shall respect the rights of unionization and association provided by law, as well as the activities performed by workers' representative organizations, in accordance with their legally assigned duties and competencies, with which a relationship based on mutual respect will be maintained, in order to promote an open, transparent and constructive dialogue.

• CONCILIATION OF WORK AND PERSONAL LIFE

  Collaborators should promote a work environment that is compatible with personal development, helping their team members to match in the best possible way their professional demands with the needs of their personal and family life.

• HEALTH AND SAFETY AT WORK

  The OFFICE considers the health and safety at work of the Collaborators fundamental for a comfortable and safe working environment. To this end, it strives to maintain a high standard of working conditions.

• ENVIRONMENTAL PROTECTION, SOCIAL AND ENVIRONMENTAL RESPONSIBILITY

  The OFFICE seeks to generate results for the business, with management practices and financial solutions that preserve the environment and promote the development of society. Thus, the Office considers the environment and the society in the development and adequacy of products, services and in the risk analysis process.

• PROTECTION OF PHYSICAL ASSETS

  Collaborators must ensure that the OFFICE’s physical assets (such as computer, machines, electronic devices, television, telephone, desks, chairs, general office supplies, etc.) are not reduced in value other than natural depreciation with the course of time.

• INTELLECTUAL PROPERTY AND INDUSTRIAL PROPERTY RIGHTS

  Collaborators will respect the OFFICE’s intellectual property and right of use. Courses, projects, programs and information systems; equipment, manuals and videos; knowledge, processes, technology, know-how and, in general, other works developed or created as a result and during the exercise of their professional activity or of third parties in the Office will be the OFFICE’s property and, therefore, their use will be made exclusively as part of their activities in the OFFICE.

  Collaborators will respect the OFFICE’s brand and, therefore, will only use the Office's image, name or trademarks for the proper development of their professional activity and, when necessary, will follow the guidelines of the use of the brand.

  Likewise, Collaborators shall respect the intellectual and industrial property rights of outside persons of the OFFICE. Specifically, Collaborators will not include or use any type of physical or electronic information or documentation that belongs to another company and was obtained as a result of past performance in a position without the consent of the property owner.

• CONFLICTS OF INTEREST

  The OFFICE and its Collaborators must always act in such a way that the best interests of their clients prevail.

  The OFFICE and its Collaborators must always take all reasonable steps to identify and, where possible, avoid actual and potential conflicts of interest.

  The OFFICE should always take all reasonable steps to identify, avoid, manage and mitigate conflicts and potential conflicts of interest.

• EXTERNAL ACTIVITY

  Professional activities outside the Office may cause actual or potential conflicts of interest, so these duties should be exceptions and may be permitted provided they meet certain conditions. Collaborators should always prioritize the exercise of their duties in the Office.

• CLIENT RELATIONSHIP

  The OFFICE and its Collaborators will not exploit the relationship with their clients, under any circumstances, to obtain any benefit.

• RELATIONSHIP WITH SUPPLIERS AND COMPETITORS

  Collaborators will not exploit the relationship with their suppliers and competitors under any circumstances to achieve any benefit. Collaborators, and specifically those who intervene in decisions regarding the procurement of inputs or services, or the definition of their economic conditions, should avoid any interference that may affect their impartiality or objectivity in this regard.

  The contracting of the supply of inputs and external services shall be performed according to the procedures established in specific policy.

  All Collaborators shall:

  - Perform or support, directly or indirectly, the practice of fair competition;

  - Respect the reputation of competitors by refraining from making statements that may affect their image;

  - Respect the intellectual property of competitors.

• GIFTS AND ENTERTAINMENT

  The giving and receiving of gifts and entertainment must always be in line with the principles of this Code of Ethics. In business relationships it is common for gifts, hospitalities or entertainment to be received and offered from/to business partners. In certain circumstances, giving or receiving gifts may influence decision making and thus lead to a conflict of interest. In order to avoid such situations, all Collaborators are prohibited from soliciting gifts, entertainment or hospitality and may only accept or offer them in accordance with the criteria below and under the following circumstances:

  - Report to Senior Partner for registration and approval, where applicable;

  - Items or invitations are appropriate for the business environment;

  - Cash or equivalents, such as traveler checks or gift cards, are prohibited;

  - If the recipient is an agent, government official, and/or candidate for the Government or political party, any kind of gift or entertainment, such as business meals, must be previously approved by the Senior Partner.

  Small gifts (pens, glasses, umbrellas, cell phone cases, notebooks) don’t need to be communicated.

INFORMATION FLOW AND CONFIDENTIALITY CONTROL

• GENERAL OBLIGATION OF CONFIDENTIALITY

  The OFFICE and its Collaborators must ensure that all confidential information is protected and preserved.

• NEED TO KNOW BASIS

  Any and all confidential information to which Collaborators have access should be used only in the performance of their activities and should only be made available to the persons who should receive them in order to perform their activities in the Office.

  Accordingly, it is not allowed to make such data or information available to third parties.

• DISCLOSURE OF INFORMATION AND SOCIAL NETWORKS

  Collaborators are prohibited from posting comments, rumors or images related to the Office, Collaborators, competitors and any third parties related to the Office's business on any media and social network, even on their personal profiles, blogs and internet forums.

• RELATIONSHIP WITH THE PRESS AND PUBLIC STATEMENTS

  Collaborators will refrain from transmitting, on their own initiative or at the request of third parties, any information or news about the Office, its Collaborators, competitors or third parties, to the media.

• TELEPHONE RECORDING AND CHAT

  In compliance with existing rules and controls, the Office has a telephone recording system.

• FILE RETENTION

  The OFFICE shall always maintain electronic or physical records, as applicable, for an appropriate period of time in a safe, legible and accessible manner.

  Collaborators are individually responsible for ensuring that relevant records and documentation are maintained and for ensuring that they comply with applicable file retention rules, regulations, policies and procedures.

PREVENTION TO WHITE-COLLAR CRIMES: MONEY LAUNDERING AND FINANCING TO TERRORISM, FRAUD, BRIBERY AND CORRUPTION

• PREVENTION TO WHITE-COLLAR CRIMES

  Collaborators must have the knowledge and comply with all policies and procedures established by the Office to prevent and combat financial crime.

  The OFFICE acts with zero tolerance on any practice related to white-collar crimes, and is therefore seeking to adhere to local and international anti-money laundering and anti-terrorist financing standards.

  Collaborators who notices any suspicious activity, whether from customers, suppliers or other collaborators, must report immediately to the Senior Partner.

• ANTI-CORRUPTION

  It is the responsibility of all Collaborators to know, understand and seek ways to protect the Office against corruption and bribery procedures, and no omissive behavior in this regard is permitted.

  All Collaborators are prohibited from receiving, offering, promising, making, authorizing or providing (directly or indirectly) any improper advantage, payments, gifts or the transfer of anything of value to anyone, whether Public Agent or not, to obtain improper advantage, influence or reward any action or decision for the benefit of the Office.

  This prohibition extends to authorities, officials or civil servants in Brazil as well as any other country.

  Collaborators shall refuse and report to the Senior Partner any request made by a third party for payments, commissions, gifts or compensation, as mentioned above.

• CODE OF ETHICS AND APPLICABLE SANCTIONS

  The determinations of this Code of Ethics are fundamental to promote and guarantee the behavior that is expected of the Collaborators.

  Collaborators should be aware that any violation may result in disciplinary action by the Office, including termination of employment contract, without prejudice to administrative or criminal penalties that may also result from non-compliance.

  For unforeseen situations in this instrument, or in case of doubt, the Senior Partner should be consulted.