I – Introduction
The mission of FR firm is to be a reference in the area of communication. It aims to provide specialized services with excellence and agility and to develop internal values that enable the intellectual and professional growth of our employees, based on three pillars:
- Credibility: we must work so that our technical capacity makes us a reference in our areas of expertise.
- Independence: we base our solutions on neutrality, independence and technical rigor.
- Integration: we offer solutions that combine expertise in different areas of knowledge.
Our daily work follow fundamental values that guide our relationships, both with customers and the people in the work environment that we create. In all spheres, we act with integrity and in compliance with the laws.
In the relationship with our customers we value:
- Privileging the interests of clients over the interests of the FR firm;
- Preserve the client’s confidentiality; and
- Act in a professional manner.
In our work environment we value:
- A system of meritocracy and respect;
- Diversity and specific contributions, fostering an inclusive, open and reliable environment; and
- Never allow discrimination and harassment of any kind.
This document is based on these fundamental values and aims to provide guidance on the expected behaviors in a variety of situations, serving as a confirmation and formalization of our commitment to always act in an ethical and responsible manner.
This document must be understood as a guide and not as a rule book, due to the inability to cover all the situations we face on a daily basis. Any suggestions on how to improve this Code of Conduct are welcome and will be considered and evaluated carefully and in depth.
The principles and guidelines established here must guide the activities of the FR firm and its professionals. This guide must be clearly understood by our employees and third parties, who are required to know and comply with this Code of Conduct, as well as with all applicable laws.
II – Our conduct in relationships
II.1. With employees
FR acts in compliance with labor legislation and aims to create a safe working environment, free from abusive, violent, threatening or harmful behavior. Collaboration and trust are fundamental factors for the success of our work.
We do not tolerate harassment, discrimination, prejudice, bullying or disrespectful behavior. We respect and encourage open dialogue and do not tolerate retaliation against anyone who speaks out in good faith.
Our decisions regarding hiring, salaries, promotions, performance and assignment of tasks are made based only on the contributions and skills demonstrated by our employees.
II.2. With the clients
FR always puts the interests of its clients above its own, providing its services with integrity and competence. All customers are treated equally and the interests of our employees must never take precedence over the interests of customers.
We only accept to provide services for which we consider ourselves qualified and when we believe that they will benefit our client. We can recommend that other professionals participate in a job whenever their knowledge and skills better serve the client. We do not obtain any financial advantage for this indication.
We do not promise any specific results for the client, nor do we create unrealistic expectations. If there are any relationships, circumstances or interests that may influence our judgment or impair the objectivity of our work, we feel obliged to inform the client.
Our employees and third parties will not seek an advantage of a financial or any other nature due to the knowledge resulting from their relationship with the customer.
We maintain confidentiality about any private information obtained from the client during the course of our professional work. All customer information is the property of the company. Our employees are committed to keeping this information confidential, even after they move away or leave the office.
Our contracts are prepared and negotiated according to the law and ethically. We comply with our contractual obligations and the agreed terms and conditions.
II.3 – With competitors
The FR firm believes that free competition stimulates efficiency and innovation in the sector, benefiting our customers and society as a whole.
We do not enter into contracts with our competitors, formally or informally, to unlawfully restrict competition, set prices or harm customers, markets, people or services.
II.4 – With suppliers
We acquire goods and services based on prices, quality, reputation, performance and suitability. We don’t buy goods and services from our customers just because they buy from us.
We expect our suppliers to comply with the law and include anti-corruption clauses in contracts with strategic suppliers.
We do not accept that suppliers offer or promise personal benefits and bribes to our employees and third parties in order to win, maintain business or relationship advantages.
II.5 – With business partners
Our choice of commercial partners is based on objective criteria that involve complementarity of services, technical capacity, suitability, integrity and reputation.
We expect our business partners to comply with the legislation and rules applicable to their business, and to act with integrity and constant effort to uphold the highest ethical standards.
We do not accept that our business partners offer or promise personal benefits and bribes to our employees and third parties in order to win, maintain business or relationship advantages.
II.6. With the press and other influencers
Our relationship with the press and influencers is based on transparency, credibility and ethics.
We do not disclose information about our customers and partners to the press without proper authorization.
III – Specific conduct policies
III.1 – Conflicts of interest
Conflicts of interest can occur in a variety of situations.
The FR firm employees and third parties must avoid activities, agreements, positions, investments in business or interests that are or may be in conflict with the interests of the office, causing harm or not to our activities, or that may interfere with the performance of their duties inside the office.
We guarantee the right of employees and third parties to participate in businesses of a private or personal nature outside the office, provided that such businesses, in addition to being legitimate and legal, do not interfere or conflict with our interests or result from confidential information obtained in the exercise of their activity professional at FR.
In case of identifying any conflict of interest situation, the employee or third party must inform his/her immediate superior.
III.2 – Bribes, anti-corruption and money laundering
We do not offer or accept bribes, including inappropriate gifts or forms of entertainment. Even if our competitors offer bribes or make questionable payments, the FR firm adopts a zero tolerance policy for bribes and any other activities that violate these laws.
We do not allow our employees and third parties to offer or accept bribes or make questionable payments on our behalf.
We obey anti-corruption laws without exceptions.
We do not engage in any money laundering or terrorist financing activities, nor do we assist third parties to do so.
III.3 – Political positioning
The political affiliations or personal opinions of our employees and third parties do not represent those of FR. We do not use company resources to support, endorse or oppose any political position, political party or candidate.
III.4 – Presents and gifts
Any presents, gifts, meals and accommodation offered or received by the FR firm, its employees and third parties must be legitimate, that is, without the objective of corruption; they must be befitting and not too frequent, in a way that they are not misinterpreted as a bribe.
Many companies have specific policies for their employees about what they can accept. Such policies must be observed with respect to our customers.
The same attention to the criteria established above must be given when interacting with public agents, reinforcing that we will not offer gifts or forms of entertainment with corrupt intentions.
III.5 – Donations and sponsorships
The FR firm does not make any kind of contribution or donation to candidates or political parties. Possible contributions or personal donations made by employees or third parties of the FR in this regard may not, under any circumstances, include resources from the FR.
Donations, contributions or sponsorships to institutions, bodies and associations whose objective is philanthropy must be made in a transparent manner and always respecting the law.
Donations and sponsorships for events must be made in a transparent manner, for a legal purpose and linked to the business of the FR firm, and must be documented in a specific sponsorship contract.
We do not allow donations that aim to obtain an improper advantage.
III.6 – Remuneration
FR charges fairly for its services. The remuneration is based on the nature of the services; in the required time; in the experience, skills and reputation; the degree of responsibility assumed; and the benefits earned by the client.
We do not accept commissions, gratuities and any other advantage from people and organizations whose services, supplies or equipment we recommend during the course of our work.
Reimbursable business expenses are sent to our customers in an accurate and documented manner.
III.7 – Confidentiality, data privacy and privileged information
We respect the privacy and confidentiality of the information of our customers, our employees, third parties and other parties with whom we have a professional relationship, in accordance with data privacy laws.
We protect personal and confidential information in any format.
We collect, store, use, transmit and work with personal and confidential information in a transparent and confidence-inspiring way. We use and maintain personal information of employees, third parties and customers, and other confidential information only if we have a legitimate reason to do so. Access to this information is also provided only if there is a legitimate reason for doing so.
The duty of confidentiality of our employees and third parties is not extinguished when they leave the FR firm. We expect employees and third parties to continue to respect the confidentiality of information even after they leave.
We are cautious when discussing customer issues in public places and do not disclose confidential information inappropriately, including when using social media.
We protect the information and physical electronic assets that we have access to, including from malicious threats and accidental losses.
We securely store all paper and electronic records and keep them only for specified periods.
We retain relevant information when we know or anticipate that there will be an investigation, litigation or other matter, or when we are instructed to do so.
We never inappropriately negotiate or disclose inside information.
Client lists and other commercial information are the property of Agência FR. Employees and third parties are not allowed to disclose or use such information for any purpose.
Employees and third parties must maintain strict confidentiality regarding any confidential or strategic information from FR.
III.8 – Intellectual property
We protect and honor the intellectual property rights of others, as well as we protect the intellectual property of the FR firm, including our accumulated knowledge.
We require our employees and third parties to honor their commitments to former employers. We do not allow employees and third parties to use, disclose or bring to FR any electronic or physical documents from companies for which they previously worked.
We do not allow employees and third parties to download or use copyrighted content without the appropriate licenses.
Our intellectual property is an important differential. Our employees and third parties must protect and maintain it. All content produced by our employees and third parties in the exercise of their work is the property of FR.
Our collaborators and third parties authorize for an indefinite period the FR firm to use their image, registered by us (photographic), for commercial disclosure and all legal purposes, provided that the content of the image is maintained and respected.
III.9 – Use of social media
We hope that our employees and third parties publish their opinions on social networks based on the principles of good faith and common sense and that they do so only in their own name, avoiding associating any type of personal opinion with FR.
We recommend to employees and third parties that:
- Be thoughtful and never publish content that is disrespectful, discriminatory or hostile; protect private information related to your professional activities at FR;
- Protect the intellectual property of FR and respect the rights and privacy of third parties.
We do not allow our employees and third parties to post or disclose derogatory or offensive comments about the company, the work environment, its colleagues, our customers, competitors or partners.
We do not allow our employees and third parties to publicly identify a company as a customer, unless they have the necessary authorization to do so.
III.10. Use of company assets and resources
Employees and third parties must make responsible use of the equipment and tools in their possession, as well as assets in common use, doing their best to avoid accidents, damage or loss.
Employees and third parties are prohibited from sharing passwords for access to FR’s network and internal systems. Access passwords are personal and non-transferable.
It is prohibited to install and duplicate software or modify configurations that put in danger the security of our technology. Only when approved by the FR firm it is possible to use third-party web-based services and solutions to perform data backup.
FR employees and third parties must use responsibly phones, computers and the internet, and mainly for legitimate professional purposes. Personal use must follow the principles of good faith and common sense.
In order to protect the company, our members and our assets, the FR firm may request to carry out checks on personal properties, within the limitations established by law, being able to monitor, at any time, all office assets, including personal computers, e-mails, instant messages and internet usage.
III.11 – Accounting records
FR has a transparent system of accounting and financial records, which fully and accurately reflects all transactions carried out. We comply with regulatory, accounting and applicable laws.
We do not carry out financial or equity transactions outside of commercial or tax books.
III.12 – Cooperation with the authorities
We answer promptly to requests from government and professional authorities to obtain information, in accordance with applicable professional laws and obligations.
IV – Code breaches
All employees and third parties must know, disclose and comply with the FR firm’s Code of Conduct for the good performance of their activities. We encourage everyone to collaborate in combating any irregularities committed.
Our employees and third parties have the right and the duty to report any violation of this Code or any illegal practices. In such cases, the parter the agency or, in his absence, the immediate superiors should be sought.
We will take all possible measures to ascertain what happened and clarify any doubts presented, acting discreetly, preserving the whistleblower’s identity and ensuring that there is no retaliation.
We emphasize that this Code is not intended to address all situations that may occur during the activities of each employee or a third party of the FR firm. As a result, it is extremely important that, in case of doubt about how to act in a specific situation, the employee or the third party consult his/her immediate superior.
All FR employees and third parties, without exception, who fail to comply with this Code will be subject to the following sanctions, which may or may not follow a gradual sequence (and are independent of the application of civil, criminal and administrative sanctions by the responsible authority):
- verbal or written warning;
- Suspension; or
- Termination of employment.
Third parties that practice any violation of this Code will be subject to the specific sanctions mentioned in the respective contracts, such as, for example, the termination of the contract or the extinction of the contractual relationship.