Terms & Conditions
Summary
CHAPTER I - INTRODUCTION
1.1 Objective
1.2 Scope
CHAPTER II - FUNDAMENTAL PRINCIPLES AND VALUES
2.1 Commitment to Ethics and Legality
2.2 Transparency and Good Faith
2.3 Professional Confidentiality
2.4 Social Responsibility and Sustainability
CHAPTER III - INTERNAL CONDUCT POLICIES
3.1 Customer Relationship
3.2 Internal Relationship
3.3 Relationship with Third Parties
CHAPTER IV – CONFLICT OF INTEREST
4.1. Definition and Nature of Conflict of Interest
4.2. Internal Controls and Supplier Contracting
4.3. Communication of Conflicts of Interest
4.4. Hiring Companies with Participation of Professionals or Family Members
CHAPTER V - CORRUPTION AND BRIBERY
5.1 Commitment to Integrity and Transparency
5.2 Prohibited Seals and Ducts
5.3 Relationship with Public Agents
5.4 Prohibition of Political-Partisan Activities
5.5 Whistleblower Channel
CHAPTER VI - ASSETS AND HERITAGE
6.1 Responsible Use of Goods and Resources
6.2 Confidentiality and Information Security
6.3 Behavior on Social Networks and the Internet
6.4 Protection of Intellectual Property and Confidential Information
CHAPTER VII - DISCIPLINARY MEASURES
7.1 Responsibility for Reporting Violations
7.2 Consequences of Violations
7.3 Penalties for Legal Entities
CHAPTER VIII - COMPLAINTS CHANNEL
8.1. Provision of a Reporting Channel
8.2. Whistleblower Protection Guarantee
8.3 Guarantee of Confidentiality and Anonymity in Reports
8.4. Good Faith Treatment of Complaints
CHAPTER IX - FINAL PROVISIONS
CHAPTER I - INTRODUCTION
1.1 Objective
This Code of Ethics and Conduct aims to establish the guidelines that guide the actions of professionals at RV Pinheiro Advogados (“Firm”), ensuring that all activities carried out by the Firm are guided by the highest ethical and legal standards. Professional ethics, transparency and responsibility must be fundamental principles in the execution of the services provided, ensuring that the commitment to justice and the interests of clients is always observed. This document also aims to promote a respectful, collaborative work environment free from inappropriate conduct.
This Code observes the provisions of Law No. 8,906/1994 (Statute of the Bar) and the OAB Code of Ethics and Discipline, as well as the best governance practices applicable to the legal profession. Compliance with this requirement is essential to maintaining the credibility and trust that the Firm places in its professionals, clients and other parties involved.
1.2 Scope
This Code applies to all members of the Firm, including partners, associates, lawyers, interns, consultants and administrative staff, as well as third parties who maintain any type of professional relationship with the Firm. Suppliers, service providers and business partners must also adhere to these guidelines and ensure that their activities are conducted ethically and transparently.
Compliance with the standards set out in this Code is not optional, and any violation may result in disciplinary action, as detailed in the following chapters.
CHAPTER II - FUNDAMENTAL PRINCIPLES AND VALUES
2.1 Commitment to Ethics and Legality
The Office conducts its activities based on legality and the principles of professional ethics. All its members must perform their duties in compliance with legal standards, the Statute of the Bar, the OAB Code of Ethics and Discipline and other applicable regulations.
Strict compliance with legal and regulatory standards ensures that the Firm operates with integrity and in line with the values of the legal profession. Therefore, any conduct that may compromise the professional integrity or image of the Office will be treated seriously and may result in disciplinary sanctions.
2.2 Transparency and Good Faith
All professional relationships established by the Firm must be conducted with complete transparency and good faith, ensuring that the information shared is always clear, accurate and objective. The commitment to transparency applies both to relationships with clients and to internal interactions between members of the Firm.
Good faith must be a non-negotiable principle in all actions and decisions taken by the Firm's professionals. Acting with loyalty and respect for the commitments made is essential to preserving the credibility and reputation of the Firm.
2.3 Professional Confidentiality
Professional secrecy is an essential pillar of the legal profession and must be strictly respected by all members of the Firm. Information obtained in the exercise of the profession, whether in meetings, documents, correspondence or other means, cannot be disclosed to third parties without due authorization from the client or without legal provision to do so.
Violation of professional secrecy not only compromises the relationship of trust between lawyer and client, but can also result in severe disciplinary and legal sanctions. Therefore, all professionals must act with caution when handling confidential information, ensuring that the privacy and interests of clients are preserved.
2.4 Social Responsibility and Sustainability
The Office recognizes its social role and is committed to adopting sustainable practices in its operations, seeking to minimize environmental impacts and contribute to the development of society. The Office encourages pro bono advocacy, participation in social projects and the dissemination of legal knowledge as a way of giving back to the community.
Social responsibility is also reflected in the appreciation of diversity and the fight against any type of discrimination. The Firm promotes an inclusive, respectful and egalitarian work environment, ensuring that all its members have opportunities for professional and personal development.
CHAPTER III - INTERNAL CONDUCT POLICIES
3.1 Customer Relationship
Relationships with customers must be conducted in a professional, ethical and transparent manner. All lawyers and employees of the Firm must treat clients with respect, diligence and commitment, ensuring clear and objective communication about the services provided.
It is forbidden to promise results or create unrealistic expectations for clients, and technical responsibility and professional independence must always prevail when conducting legal work. Accountability must be provided periodically and in detail, ensuring that customers are always informed about the progress of their demands.
3.2 Internal Relationship
The in-person and virtual work environment must be based on cooperation, mutual respect and the appreciation of each professional. Any form of harassment, discrimination or abusive conduct will not be tolerated, and should be reported immediately through the appropriate channels.
The members of the Office must work collaboratively, always seeking technical improvement and the exchange of knowledge among colleagues. Respect for hierarchy and internal organization is essential to ensure a productive and harmonious environment.
3.3 Relationship with Third Parties
Third parties providing services to the Firm must observe the same ethical standards established in this Code. Any irregularity or deviation of conduct must be reported to the Office's management so that appropriate measures can be taken.
The hiring of suppliers and service providers must be carried out based on objective criteria, prioritizing companies and professionals that share the Firm's values and ethical principles.
CHAPTER IV – CONFLICT OF INTEREST
4.1. Definition and Nature of Conflict of Interest
At the Office, all professionals must avoid situations in which their personal interests may interfere with the performance of their duties and the fulfillment of their professional obligations. A conflict of interest may occur when a professional's actions or interests in the Firm become incompatible with the interests of the Firm or its clients.
A conflict of interest occurs whenever personal interests or those of third parties may influence a professional's ability to act impartially, especially when there is a benefit to be obtained or a loss to be avoided as a result of the choices made.
4.2. Internal Controls and Supplier Contracting
Due to the ethical obligations of the legal profession, it is crucial that the Firm identifies and prevents its professionals from acting in cases that may generate conflict between the interests of two or more clients. To ensure integrity and professional ethics, the Firm adopts a system of governance and internal controls to verify conflicts of interest, this being a mandatory step before accepting new clients or opening new cases.
In addition to internal control mechanisms, the Office also establishes that the hiring of suppliers is carried out based on technical and professional criteria and free from any conflict of interest, whether real or apparent.
4.3. Communication of Conflicts of Interest
All professionals must immediately report to management any situation involving a possible or actual conflict of interest, whether with the Firm or with its clients.
4.4. Hiring Companies with Participation of Professionals or Family Members
The Office is permitted to hire companies in which a professional has participation or involvement of family members, provided that the process is transparent and approved internally, with the due conduct of decisions by professionals exempt from the situation.
CHAPTER V - CORRUPTION AND BRIBERY
5.1 Commitment to Integrity and Transparency
The Firm adopts a zero tolerance policy against any form of corruption, bribery or practice that compromises the integrity of its operations. All members of the Firm must act with transparency and ethics in their relationships with clients, partners and public agents, ensuring that no irregular conduct is practiced in the name of the Firm.
The Office strictly complies with the provisions of the Anti-Corruption Law (Law No. 12,846/2013) and other applicable national and international legislation, preventing any act that could be interpreted as illicit favoritism or obtaining of undue advantages.
5.2 Prohibited Seals and Ducts
No member or employee of the Office may, directly or indirectly, offer, promise, give or accept any undue advantage, including payments, gifts, favors or benefits that may influence the decision-making of public or private agents.
The prohibitions cover not only money, but also high-value gifts, travel, entertainment, business opportunities or any other advantage that could be construed as bribery or corruption. The Office's policy establishes that any benefit granted to third parties must be documented and justified in accordance with ethical and legal criteria.
5.3 Relationship with Public Agents
In relationships with public agents, it is essential that all interactions are guided by transparency and legality. It is prohibited to offer any type of financial compensation or undue benefit to public servants, whether to speed up processes, influence decisions or obtain commercial advantages.
If any professional at the Firm is approached with undue requests or encounters situations that may constitute illicit practices, he/she must immediately notify the Firm's management so that appropriate measures can be taken.
5.4 Prohibition of Political-Partisan Activities
The Office does not make donations to political parties, electoral campaigns or candidates for public office. Any involvement of its professionals in political-partisan activities must occur exclusively on a personal basis, without any association with the Office.
5.5 Whistleblower Channel
The Office provides a secure and confidential reporting channel so that any suspicion of corruption, bribery or misconduct can be reported. All reports will be investigated impartially and confidentially, ensuring that corrective action is taken as necessary.
CHAPTER VI - ASSETS AND HERITAGE
6.1 Responsible Use of Goods and Resources
The assets and property of the Office, made available to its members and collaborators, must be used responsibly and carefully. Everyone has the obligation to ensure the conservation of the Office's material and technological resources, ensuring that there is no damage, loss or waste.
Technological resources, such as computers, printers, communication systems and other tools provided, must be used exclusively for the performance of professional functions. The use of equipment and technologies for personal purposes is not permitted, except in cases previously authorized by the administration.
6.2 Confidentiality and Information Security
Information security is essential for the integrity of the Office and for the protection of client data. Therefore, professionals must keep personal passwords and access data confidential, which must not be shared with other team members. Institutional email must be used exclusively for professional purposes, and the sending of non-corporate content, such as personal messages, political campaigns, jokes or any material that is not related to the work environment, is prohibited.
6.3 Behavior on Social Networks and the Internet
When using the internet and social media, all members of the Office must adopt an ethical and prudent attitude. It is essential that online interactions do not expose the name or image of the Office in a derogatory manner. Derogatory or offensive comments about co-workers, clients, partners or any party involved in the Firm's activities are strictly prohibited.
Furthermore, professionals must refrain from getting involved in situations that could compromise their image or that of the Firm, especially in ethically questionable contexts or that could generate negative repercussions.
6.4 Protection of Intellectual Property and Confidential Information
The Firm's intellectual assets and confidential information, including methodologies, intellectual works, and client and third party data, must be treated with the utmost diligence and respect. The transfer of any technology or information belonging to the Office or its clients outside the corporate environment without due authorization is prohibited.
Taking care of intellectual property is essential to preserving the Firm’s competitiveness and credibility, in addition to ensuring the trust and protection of clients’ sensitive data.
CHAPTER VII - DISCIPLINARY MEASURES
7.1 Responsibility for Reporting Violations
All members of the Firm, as well as third parties with whom the Firm maintains professional relationships, are responsible for reporting any act or situation that contravenes the guidelines established in this Code of Ethics and Conduct. The omission of any irregularity or violation will be considered a serious ethical failure, subject to sanctions, regardless of position or function.
Complaints must be submitted through a direct channel made available by the Office, a secure and confidential means that guarantees absolute confidentiality, including regarding the identity of the complainant. The Office ensures that there will be no retaliation of any kind against those who report violations in good faith, creating an environment in which transparency and correction are a priority.
7.2 Consequences of Violations
When a violation of any principle established in this Code is proven, the Office will take the necessary measures according to the severity of the infraction. Disciplinary actions may range from warnings, whether verbal or formal, to more severe measures, such as temporary or permanent suspension, contract termination, or even the exclusion of the individual from the membership, if the case involves such circumstances.
In addition, the Office may resort to the application of additional legal sanctions, including civil or criminal actions, depending on the nature of the violation. This may involve fines, the return of amounts obtained improperly and any other penalties provided for in current legislation. The investigation process will always be conducted rigorously, respecting the rights of defense and adversarial proceedings, in order to ensure that all measures are proportionate to the offense committed.
7.3 Penalties for Legal Entities
In the case of legal entities associated with the Office, such as suppliers, service providers or business partners, who are responsible for violations of the rules of this Code, the Office may adopt both administrative and judicial sanctions. These sanctions include fines, as well as other penalties stipulated by the Anti-Corruption Law (Law No. 12,846/2013), or by applicable legislation in similar situations. The application of these measures aims to ensure that all commercial and professional relationships maintain the ethical standards required internally.
CHAPTER VIII - COMPLAINTS CHANNEL
8.1. Provision of a Reporting Channel
The Office will provide a secure and confidential communication channel for reporting inappropriate behavior. The channel will guarantee anonymity and protection to prevent retaliation. All complaints will be analyzed by an internal committee, which will take the appropriate measures, always respecting the principles of confidentiality and impartiality.
8.2. Whistleblower Protection Guarantee
The Firm ensures that all its members are protected against any type of retaliation resulting from complaints or reports made in good faith, in accordance with this Code of Ethics and Conduct, as well as with other internal policies and procedures of the Firm.
8.3 Guarantee of Confidentiality and Anonymity in Reports
Professionals have the option to file complaints anonymously. Even though the Office takes all measures to preserve anonymity, in some specific situations, the identity of the whistleblower may be revealed during the investigative process, when necessary. The Office is committed to protecting this identity within the legal limits.
It is important to highlight that, when the complaint is anonymous and does not provide sufficient details, the investigation may be hindered, limiting the possibility of adequate investigation.
If the professional chooses to reveal his/her identity when making a complaint, the Office undertakes to keep this identity confidential, respecting legal limits. Access to information will be restricted to those responsible for investigating the case, ensuring the whistleblower's privacy.
8.4. Good Faith Treatment of Complaints
The Office will treat all complaints based on the presumption of good faith. Even if a complaint proves inconclusive or unfounded at the end of the investigation, the whistleblower will not suffer reprisals, as long as the complaint was made with the intention of contributing positively. Only complaints that are proven to be made in bad faith can result in sanctions.
CHAPTER IX - FINAL PROVISIONS
9.1. This Code comes into force on the date of its publication and will remain valid until any revision or update. Compliance with its guidelines is essential to maintaining the Office’s credibility and reputation.