CODE OF CONDUCT

I – Introduction

Fato Relevante’s mission is to be a benchmark for Media C​ommunications in Brazil, provide tailor-made services with excellence and agility, and develop internal values ​​that enable our employees’ intellectual and professional growth, based on three main pillars:

  • Credibility: We must work so that our technical capacity provides a benchmark for our areas of expertise.
  • Independence: Our solutions are based on neutrality, independence and technical rigor.
  • Integration: We offer solutions that combine expertise in different fields of knowledge.

Our daily work is guided by key values ​​that drive our relationships, both with our clients and the people who share our work environment. We act with integrity and in compliance with the laws in all spheres of professional life.

In our relationship with our clients we:

  • Put the interests of our clients above our own interests;
  • Preserve our clients’ confidentiality; and
  • Act in a professional manner.

In our work environment we:

  • Promote a culture of meritocracy and respect;
  • Foster diversity and specific contributions conducive to an inclusive, open and reliable environment; and
  • Never allow discrimination and harassment of any kind.

This Code of Conduct is based on these key values ​​and aims to provide guidance on expected behaviors in diverse situations and serve as a visible demonstration of our commitment to act in an ethical and responsible manner.

This document must be understood as a guide and not as a rulebook given that it is not possible to cover all the types of situations that may arise on a daily basis.

We welcome any suggestions on improving this Code of Conduct. They will be considered and evaluated carefully and in depth.

The principles and guidelines established herein must guide Fato Relevante’s activities and its employees.

This Code of Conduct must be clearly understood by our employees and third parties, who are required to learn about and comply with its policies, as well as with all applicable laws.

II – Our conduct in our relationships

II.1. With employees

Fato Relevante works in compliance with Brazil’s labor laws and aims to create a safe work environment, free from abusive, violent, threatening or harmful behavior. Collaboration and trust are key factors for the success of our company.

We do not tolerate harassment, discrimination, prejudice, bullying or disrespectful behavior in the workplace. We respect and encourage open dialogue and do not tolerate retaliation against anyone who speaks out in good faith.

Our decisions regarding recruitment and hiring, salaries, promotions, employee performance and task assignment are made based only on the contributions and skills demonstrated by our employees.

II.2. With clients

Fato Relevante always puts the interests of its clients above its own and provides its services with integrity and competence. All our clients are treated equally and our employees’ interests must never take precedence over the interests of our clients.

We only accept to provide services to clients whom we believe we are qualified and that will benefit from our services. We may recommend other firms to do a job whenever we feel that their knowledge and skills better serve our client. We do not obtain any financial gain from outside referrals.

We do not promise any specific results for our clients, 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 it is our duty to inform our clients.

Our employees and third parties shall not seek any form of benefit, whether financial or otherwise, due to inside knowledge resulting from their relationship with our clients.

We maintain strict confidentiality about any private information obtained from our clients 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 retire or leave the company.

Our contracts with our clients are prepared and entered into in accordance with the law and in an ethical manner. We comply with our contractual obligations and the agreed terms and conditions.

II.3 – With competitors

Fato Relevante believes that free competition stimulates efficiency and innovation in the industry, thus benefiting our clients and society as a whole.

We do not enter into contracts with our competitors, whether formally or informally, to unlawfully restrict competition, set prices or allocate customers, markets, people or services.

II.4 – With suppliers

Fato Relevante purchases goods and services based on prices, quality, reputation, performance, and suitability. We do not buy goods and services from our clients just because they buy from us.

We expect our suppliers to comply with the law and our supplier agreements include anti-corruption clauses.

We do not accept that our suppliers offer or promise personal benefits and bribes to our employees and third parties in order to win a deal, maintain business or gain relationship advantages.

II.5 – With business partners

Our choice of business partners is based on objective criteria that involve complementarity of services, technical skills, honesty, integrity and reputation.

We expect our partners to abide by the laws 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 a deal, maintain business or gain relationship advantages.

II.6. With the press and social media influencers

Our relationship with the press and social media influencers is based on transparency, credibility and ethics.

We do not disclose information about our clients and their 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.

Fato Relevante’s employees and third parties must avoid activities, agreements, positions, business investments or interests that are or may be in conflict with our own interests, whether or not they affect our business activities, or that may interfere with the performance of their duties in the workplace.

We guarantee the right of our employees and third parties to participate in businesses of a private or personal nature outside the company, provided that such businesses, as well as being legitimate and legal, do not interfere or conflict with our own interests, nor result from confidential information obtained in the exercise of their professional activities at Fato Relevante.

Should any conflict of interest situation arise, the employee or third party must promptly inform their immediate superior.

III.2 – Bribes, anti-corruption and money laundering

We do not offer or accept bribes, including giving or receiving inappropriate gifts or forms of entertainment. Even if our competitors offer bribes or make questionable payments, Fato Relevante 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 abide by anti-corruption laws without exceptions.

We do not engage in any money laundering or terrorist financing activities, nor do we assist our third parties to do so.

III.3 – Political positioning

Political affiliations or the personal opinions of our employees and third parties do not represent those of Fato Relevante. We do not use company funds to support, endorse or oppose any political position, political party or candidate.

III.4 – Giveaways and gifts

Any giveaways, gifts, meals and hotel accommodation offered to or received by Fato Relevante, its employees and third parties must be legitimate, that is, without the involvement of corruption. They must be reasonable and not too frequent, and in a way that they are not viewed as a bribe.

Many companies have specific policies for their employees about what they can accept. Such policies must be observed with regard to our clients.

Extra attention to the criteria established above must be paid when interacting with public officials, emphasizing that we shall not offer gifts or any other form of entertainment with corrupt intentions.

III.5 – Donations and sponsorships

Fato Relevante does not make any kind of contribution or donation to political candidates or parties. Possible contributions or personal donations made by Fato Relevante employees or third parties in this regard may not, under any circumstance, involve company funds.

Donations, contributions or sponsorships to institutions, bodies and associations with a philanthropic purpose 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 they must be linked to Fato Relevante’s business under a specific sponsorship agreement.

We do not allow donations that are used to obtain an undue advantage.

III.6 – Fees

Fato Relevante charges reasonable fees for its services. Our fees are based on the nature of the services, on the required timeframe, on experience, skills and reputation, on the level of responsibility assumed, and on the benefits earned by the client.

We do not accept commissions, gratuities and any other forms of payments that can be termed as gains or profits from people and organizations whose services, supplies or equipment we may recommend during the course of our work.  

Reimbursable business expenses are sent to our clients in an accurate and documented manner.

III.7 – Confidentiality, data privacy and privileged information

We respect the privacy and confidentiality of the information provided by our clients, employees, third parties and other stakeholders with whom we maintain a business relationship, in accordance with Brazil’s 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 manner. We use and maintain personal information from employees, third parties and clients, 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 to do so.

Our employees’ and third parties’ duty of confidentiality is not extinguished upon termination of their contract with Fato Relevante. We expect our employees and third parties to continue to respect the confidentiality of information even after their contract is terminated.

We use caution when discussing clients’ issues publicly and we do not disclose any confidential information inappropriately, also when using social media networks.

We protect the information and physical electronic assets to which we have access, including protection from malicious threats and accidental losses.

We securely store all paper and electronic records and keep them only for a specified period of time.

We retain relevant information when we know or anticipate that there will be an investigation, litigation or any other matter, or when we are instructed to do so.

We never inappropriately negotiate or disclose inside information.

Clients’ lists and other commercial information are the property of Fato Relevante. Employees and third parties are not allowed to disclose or use such information for any purpose whatsoever.

Employees and third parties must maintain strict confidentiality regarding any confidential or strategic information from Fato Relevante.

III.8 – Intellectual property

We protect and honor the intellectual property rights of others, and we protect Fato Relevante’s intellectual property, 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 Fato Relevante’s premises any electronic or physical documents from companies for which they previously worked.

We do not allow our employees and third parties to download or use copyrighted content without the appropriate licenses.

Our intellectual property is a key asset for our business. Therefore, we require our employees and third parties to protect it and maintain it. All content produced by our employees and third parties in the exercise of their duties is the property of Fato Relevante.

Our employees and third parties hereby authorize Fato Relevante for an indefinite period to use their images for commercial purposes and for all legal purposes, provided that the content of the images is respected.

III.9 – Use of social media

We expect our employees and third parties to publish their opinions on social media networks based on the principles of good faith and common sense and that they do so in their own name, avoiding associating any type of personal opinion with Fato Relevante.

With regard to social media networks, we recommend our employees and third parties that they should:

  • Be thoughtful and never publish content that is disrespectful, discriminatory or hostile; protect private information related to their professional activities at Fato Relevante;
  • Protect Fato Relevante’s intellectual property 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, their colleagues, our clients, competitors or business partners.

We do not allow our employees and third parties to publicly identify a company as a client, 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 company equipment and tools in their possession, as well as assets of common use, and they should do their best to avoid accidents, damage or loss of such equipment and tools.

Employees and third parties are prohibited from sharing passwords for access to Fato Relevante’s network and internal systems. Access passwords are personal and non-transferable.

Employees and third parties are prohibited from installing and duplicating software, or modifying software configurations that may jeopardize the security of our IT systems. Third-party web-based services and solutions to perform data backup may only be used upon Fato Relevante’s authorization.

Fato Relevante’s employees and third parties must use company mobile phones, computers and the internet responsibly, and mainly for legitimate professional purposes. Personal use of this equipment must follow the principles of good faith and common sense.

To protect the company, its employees and assets, Fato Relevante may request to search the employees’ personal belongings, within the limits established by law, and may monitor, at any time, all office equipment, including personal computers, e-mails, instant text messages and internet usage.

III.11 – Accounting records

Fato Relevante has detailed and transparent accounting and financial records, which fully and accurately reflects all transactions carried out by the company. We comply with regulatory and accounting rules and applicable laws.

All our financial or corporate transactions are recorded in the company’s books.

III.12 – Cooperation with authorities

We promptly respond to requests from government and other authorities to obtain information in accordance with applicable laws and obligations.

IV – Code breaches

All Fato Relevante employees and third parties must read, disclose and comply with this Code of Conduct for the good performance of their activities. We encourage everyone to collaborate to combat any irregularities they may encounter.

Our employees and third parties have the right and the duty to report any violation to this Code of Conduct or any illegal practices. In such cases, the company’s managing partners must be informed, or in their absence, the employee’s immediate superiors.

We shall take all possible measures to ensure investigation of the matter and clarify any doubts that may arise, while acting in good faith to preserve the whistleblower’s identity and ensure that there is no retaliation.

We emphasize that this Code of Conduct is not intended to address every situation that may occur during the course of activity of each Fato Relevante’s employee or third party. Therefore, we strongly recommend that, if an employee or third party is unsure on how to proceed in a specific situation, they should consult their immediate superior.

All Fato Relevante’s employees and third parties, without exception, who fail to comply with this Code of Conduct, shall be subject to the following sanctions, which may or not follow a specific sequence, regardless of the application of civil, criminal and administrative sanctions by the relevant authority:

  • Verbal or written warning;
  • Suspension; or
  • Termination of employment contract.

Third parties involved in any violation of this Code of Conduct shall be subject to the specific sanctions compliance provisions in their respective agreements, such as the termination of the contract or the extinction of the contractual relationship.

March 2020.