1. ETHICAL PRINCIPLES
1.1 Integrity
1.2 Trust
1.3 Commitment
1.4 Respect and Meritocracy
2. SCOPE
3. LEGAL AND REGULATORY COMPLIANCE
4. CONFIDENTIALITY AND INFORMATION SECURITY
4.1 Strategic and/or Confidential Information
4.2 Protecting information provided by clients
4.3 Protecting Assets
4.4 Electronic Media and Communication Systems
4.5 Representation by Third Parties
5. PROFESSIONAL CONDUCT GUIDELINES
5.1 Gifts, Presents and Hospitality
5.2 Entertainment.
5.3 Travel and accommodation.
5.4 Donations and contributions.
5.5 Payments
5.6 Financial Records and Reports.
5.7 Competition
6. CONFLICT OF INTEREST
7. SUPPLIERS AND THIRD PARTIES
8. INAPPROPRIATE CONDUCT
8.1 Disciplinary measures
9. SNA COMMUNICATION CHANNEL
1.1 Integrity
SNA believes that integrity is the basis of everything we do, i.e. our actions and attitudes must reflect our values and ethical principles, with the aim of fulfilling our commitments and achieving our objectives.
1.2 Trust
We have built and consolidated our reputation based on the trust we have acquired with our clients, business partners, competitors and society, established by the tripod of honesty, truthfulness and loyalty.
1.3 Commitment
SNA is committed to treating its clients with respect and transparency, so that any conflicts do not jeopardize the performance and effectiveness of the legal services provided to them, always seeking to provide the best possible results.
1.4 Respect and Meritocracy
SNA employees must be treated with respect and dignity, in accordance with the guidelines contained in the firm’s Internal Policies.
To this end, in order to promote and maintain a healthy, harmonious and productive working environment, SNA does not accept or tolerate (i) discriminatory practices, (ii) prejudice, (iii) abuse of power, (iv) sexual, physical or moral harassment, (v) situations of disrespect, threats or intimidation and (vi) punitive administrative practices in the relationship between managers, employees and third parties, regardless of hierarchical level.
The CODE OF ETHICS AND PROFESSIONAL CONDUCT OF STÜSSI-NEVES ADVOGADOS is part of the firm’s Internal Policies, which guide the professional activities of all employees, without distinction.
The guidelines contained in this document cover all workplaces and field activities in which the firm is involved, in whole or in part, and include both relations with the Government and its representatives, and private relations with other companies and/or competitors.
Its application is mandatory and normative, in order to guide all those who work for SNA, inside and/or outside its premises.
SNA acts in compliance with national legislation in general, in particular Law No. 8.906/94 – Statute of the Bar Association, Law No. 12.846/13 – Corporate Anti-Corruption Law and Law No. 9.613/98 – Prevention of Money Laundering Crime, as well as observing the Internal Policies that govern its activities, which are based on the highest ethical principles and the values of respect, equality and morality.
All SNA employees must adhere to the laws and regulations applicable to their activities, regardless of where they work. In this context, if the ethical and professional conduct standards set out in the laws are not sufficient, the standards in this Code may be reviewed and the higher regulatory level will prevail.
INFORMATION: Any and all assets, data or intellectual or material content developed by SNA, which must be valued and protected in an appropriate manner compatible with the firm’s commitment.
INFORMATION SECURITY: Procedures for protecting information against threats to its availability, integrity and confidentiality, in order to avoid risks and vulnerabilities, with a view to preserving the technological structure and ensuring business continuity.
Considering the above definitions, all information used within the office is considered strategic and confidential and is the property of SNA, except for information in the public domain (e.g. information published in newspapers, magazines and specialized websites).
Employees must not use or disclose information that is not publicly available. Otherwise, it could be characterized as improper use of internal and confidential information.
Information is extremely valuable and essential to our competitiveness in the market. It must be used exclusively for professional activities and protected against theft, damage, violation, leakage, unauthorized exposure or improper use.
4.1 Strategic and/or Confidential Information: Information whose disclosure could affect the services provided by the firm, as well as clients and other counterparties. Examples of such information are: financial results, investments, contracts, new products and services, personal data of employees and clients, etc.
4.2 Protection of Information Provided by Clients: It is essential to treat the information entrusted by our clients with confidentiality. SNA guarantees the secrecy and preservation of disclosures made by clients, acting with discretion with regard to this information
Information disclosed by SNA clients can only be made public with their express authorization, except if necessary for the regular development of SNA’s activities.
In addition, SNA undertakes to take due care to avoid breaching the confidentiality of the data provided by our clients.
4.3 Protection of Assets: The firm’s assets are intended exclusively for its activities and must not be used for private purposes, while also avoiding misuse and waste. They include tangible assets such as property, equipment, systems, etc., as well as intangible assets such as the firm’s proprietary information and relationships with clients and partners.
4.4 Electronic Media and Communication Systems: Any and all electronic media and communication systems, including electronic mail (e-mail) and Internet access, are SNA property and subject to monitoring. Use of these resources must be restricted to office activities.
4.5 Third-party representation: Third-party representation can be carried out by parties who have a relationship with SNA, such as consultants, service providers, business partners, subcontractors, etc. However, if these third parties do not have their working methods and ethical conduct publicly known and/or are not consistent and aligned with this Code, the firm’s policy will be not to authorize representation on their behalf.
The activities of SNA employees are guided by the highest standards of ethics and conduct, in addition to compliance with current legislation.
No employee is authorized or may offer, promise, grant, give or authorize, directly or indirectly, in any way, the donation of money or goods of any value, to any person, related to business dealings and office activities, with the aim of obtaining an improper advantage or benefit.
In this regard, SNA advises its employees on day-to-day situations that could affect or compromise its operations and image, as well as those of its business partners, suppliers and clients:
5.1 Gifts, presents and hospitality: Giving gifts and granting hospitality (e.g. entertainment, trips, meals, etc.) are often considered forms of courtesy and are common in the daily business of companies and offices in many regions of the country and even in other countries. However, such attitudes can be interpreted as a form of bribery and corruption.
Any kind of gift, hospitality, courtesy or benefit to public officials in general, i.e. any person who holds a position or function in the Public Administration, directly or indirectly, is forbidden.
The above guidelines do not include offering or receiving promotional gifts that are traditionally used and have brand identification or advertising, or that are of low commercial value, such as calendars, diaries, pens, card holders, books, etc.
5.2 Entertainment: Invitations to entertainment events such as theatrical performances, musical concerts or sporting events may be offered to or received from partners, suppliers and/or clients, provided that they are related to the business environment and do not constitute obtaining an advantage or benefit of any kind.
5.3 Travel and Accommodation: All travel and accommodation require prior approval, including travel to attend hearings, congresses, seminars or business meetings, and are subject to accountability.
5.4 Donations and Contributions: SNA employees have the autonomy to make donations and contributions from their own resources, as long as this is not linked to or involved with SNA’s name. SNA does not make political donations and contributions in any form.
5.5 Payments: Payments made by the SNA must be supported by the respective supporting documentation for the goods and services purchased, as well as the contractual provisions laid down.
5.6 Financial Records and Reports: SNA keeps its records and accounts available in a clear and complete manner, following financial reporting and accounting standards. Any intentional alteration of financial records and reports will be considered a violation of this Code and subject to the application of civil and/or criminal laws.
5.7 Competition: SNA acts ethically and competitively with its competitors in the market, seeking a prominent position for its services on its own merits, repudiating any deceitful and illicit means used to achieve goals.
SNA employees must not get involved in any business relationship or activity that could cause a conflict of interest and/or harm the firm, or even achieve personal benefit or benefit for third parties through a decision that could harm the services provided by the firm. In case of doubt about a potential conflict of interest situation, the fact must be reported promptly through the SNA Communication Channel mentioned in clause 9 below, in order to clarify whether or not such a situation constitutes a real conflict of interest, before any decision is taken.
The choice, hiring and maintenance of relationships with suppliers and third parties must be based on professional, technical, commercial and strategic criteria, always in accordance with the interests and needs of the SNA.
Suppliers and third parties are expected not to use indirect channels for improper payments, such as to public officials in order to obtain any advantage or benefit.
Failure to comply with the legislation and guidelines of this Code can result in serious penalties for SNA and/or its employees, up to and including criminal liability for the individual involved.
All employees are responsible for complying with the rules and guidelines of this Code.
8.1 Disciplinary measures
Without prejudice to any applicable administrative, civil and criminal sanctions, non-compliance with and violation of the guidelines of this Code, as well as any internal policies and procedures, whether by act or omission, will not be tolerated and are subject to disciplinary action. Recurrences, even after prior guidance, are also subject to disciplinary measures.
The investigation of any irregularities on the part of violators of the rules of this Code of Ethics and Conduct may generate all the penalties provided for by law, taking into account the seriousness of the infraction committed.
All employees have a duty to report any (i) violations, (ii) threats of violations, (iii) suspicions and/or doubts regarding violations of the law and this Code of Ethics and Conduct.
The SNA Communication Channel is absolutely confidential and can be accessed by e-mail at denuncias.snasp@integritybr.com.br or by telephone at 08007716607.
Communications and complaints will be duly assessed and investigated by a Disciplinary Committee, as appropriate, which will decide on the measures to be taken.
© 2024 | Stüssi-Neves | All Rights Reserved | Privacy Policy | Compliance