SUMMARY

INTRODUCTION
MISSION, VISION AND THE LEGAL PRACTICE WE BELIEVE IN
FUNDAMENTAL PRINCIPLES
VALUING AND RESPECTING DIVERSITY: BUILDING A STRONG AND INCLUSIVE TEAM
COMMITMENT TO INTEGRITY AND PROTECTING CLIENT INTERESTS
PRESS RELATIONS AND ADVERTISING
COMPETITION
ANTI-CORRUPTION POLICY
CONFLICT OF INTERESTS
ESG COMMITMENT
DISCIPLINARY SANCTIONS

1. INTRO

Welcome to the Code of Ethics and Conduct of Brasil Fernandes Advogados, a document that reflects not only the fundamental values of our journey, but also the unwavering commitment we have cultivated since our founding in 2005. Started by our founding partner, Dr. Roberto Brasil Fernandes, in 1998, the firm's journey is marked by an unceasing dedication to law and business services. We adopt a unique approach, based on a global and systemic understanding of the cases we undertake. We recognize that a holistic analysis is essential, considering that the repercussions of individual actions must be weighed within the context of the whole. Over the years, we have witnessed the growth of our team and the incorporation of new partners and associates, all driven by the same passion: the law.

This Code of Ethics and Conduct is more than a set of rules; it is a tangible expression of our ethical values and principles. It reflects our commitment to growing organically, evolving, and, above all, defending the interests of our clients with zeal and integrity. By navigating these guidelines, we invite each member of our team to incorporate these values into their daily work, contributing to the construction of an ethical, respectful legal environment committed to excellence. It reflects our commitment to growing organically, evolving, and, above all, defending the interests of our clients with zeal and integrity. By navigating these guidelines, we invite each member of our team to incorporate these values into their daily work, contributing to the construction of an ethical, respectful legal environment committed to excellence.

2. MISSION, VISION AND THE LEGAL PRACTICE WE BELIEVE IN

Our mission

We are rethinking the law by challenging traditional perceptions, revealing its potential as a tool for positive impact on our clients' results and objectives.

Our vision

We want to be our clients' first choice when it comes to tackling complex and strategic legal challenges.

The advocacy we believe in

Systemic
Taking the whole into consideration when analyzing the consequences of individual actions of the parts that compose it.
Every social human being interacts with and is interdependent on others.

Transparent

Operating with openness, communication, and responsibility.

Resilient

Adapting to change, overcoming obstacles, and withstanding the pressure of adverse situations.

Colaborative

Acting with others to achieve a specific result.

3. PRINCIPLES

We uphold a grounded and contemporary approach to our work, reflected in principles that guide our daily conduct. Here are our cornerstones:

Protection and Equity: We are dedicated to defending individual rights, human dignity, equality before the law, and community interests.
Integrity: We strive for the highest standards of integrity, prioritizing transparency and morality in all our operations.
Legal Compliance: We conduct ourselves in accordance with constitutional principles, current legislation, and internal regulations.
Business Commitment: We defend the democratic regime, free enterprise, fair competition, and the value of work.
Environmentally Conscious: We are committed to preserving the environment and using natural resources responsibly, contributing to quality of life and public health.
Community Development: We seek the socioeconomic development of the local communities where we operate.
Ethical Entrepreneurship: We promote entrepreneurship and innovation, maintaining honest and fair relationships in the market.
Citizenship and Sustainability: We implement actions for the formation and promotion of citizenship, contributing to sustainable development in the localities where we are located.
Social Justice: We repudiate labor exploitation, especially child and forced labor, and all forms of work analogous to slavery, defending the principles of social justice.

4. VALUING AND RESPECTING DIVERSITY: BUILDING A STRONG AND INCLUSIVE TEAMIVA

We prioritize diversity as an essential pillar. We seek equity, representation, and a culture of respect, promoting inclusive professional development. With zero tolerance for discrimination, we are committed to creating an environment where the authenticity and contribution of each member are valued. By celebrating our differences, we strengthen not only our team but also enrich our work. We are committed to building a diverse and fair legal community.

5. COMMITMENT TO INTEGRITY AND PROTECTION OF CLIENT INTERESTS

Professional Secrecy: Professional secrecy is a fundamental pillar of our work. We are committed to protecting our clients' confidential information, safeguarding their interests and ensuring that their issues are handled with the highest degree of confidentiality.
Restricted Access and Information Control: We have implemented restricted access policies and strict controls over confidential information. We ensure that only authorized team members have access to relevant information, maintaining the integrity and confidentiality of the data.
Commitment Beyond Legal Boundaries: We extend our commitment to confidentiality beyond legal boundaries. We collaborate ethically with third parties, ensuring that any information shared in partnerships is treated with the same seriousness and protection that we apply internally.

6. PRESS RELATIONS AND ADVERTISING

The BFA management will maintain an open channel with the press in general, making available all the information necessary for the clarification and dissemination of its activities, guided by transparency, credibility and trust, always observing ethical values in its marketing strategy.

The entity's representatives, when authorized to speak on behalf of the BFA, will always express the institutional point of view.

7. COMPETITION

We recognize that competition must be governed by ethical principles, based on loyalty and in full compliance with applicable rules and legislation.

We maintain a firm commitment to respecting institutions and companies that offer services similar to ours. This stance reflects our pursuit of fair and transparent competition, where integrity prevails.

We understand that the dissemination of studies, opinions, or research must be carried out responsibly. At BFA, we ensure that any use of methods, techniques, or models not belonging to the firm is duly authorized by the holders of these rights.

To clients seeking to contract our services, we impose the principle of avoiding derogatory references to competitors. We value an environment where the promotion of one's own work does not compromise professional ethics. However, we allow for warnings about proposals that, in your opinion, may be poorly formulated and not meet the real intended interests.

At BFA, we believe that ethical competition not only raises our standards but also contributes to a fair and balanced market. Our commitment to integrity guides every interaction, ensuring that our business practices are aligned with the highest ethical standards.

8. ANTI-CORRUPTION POLICY

Brasil Fernandes Advogados (BFA) strictly prohibits offering, promising, or granting, directly or indirectly, any undue advantage to public officials, whether national or foreign, or to persons related to them. Undue advantage includes not only cash payments, but also gifts, gratuities, and hospitality offered, promised, or given in exchange for favors or benefits.

It is crucial to emphasize that interactions with public officials are not limited to bidding processes and contracts with the government. They also encompass obtaining licenses, authorizations, permits, and inspections carried out by public officials. Furthermore, we remain vigilant regarding interactions with notary officials, court officers, and regulatory/supervisory bodies. We recommend conducting these interactions in the presence of at least two BFA employees, always seeking to formalize minutes or drafts of the discussions held.

Not limited to the corruption of public officials, our employees are prohibited from offering, promising, granting, requesting, or receiving any undue advantage from private individuals. This applies to obtaining, retaining, or directing business to oneself (or the firm), as well as obtaining special concessions on one's own behalf or on behalf of BFA. If employees identify attempts at corruption or bribery, they must immediately report them to the Firm's Management, in accordance with our Code.

It is worth noting that, regardless of the client's nationality, several jurisdictions, including Brazil, have anti-corruption laws with strict penalties for companies involved in bribery. Furthermore, employees who participate in corrupt practices will be subject to the penalties stipulated in the Penal Code. The anti-corruption policy is not just a guideline; it is an unwavering commitment to ethics and integrity at all levels of our operations.

9. CONFLICT OF INTEREST

At Brasil Fernandes Advogados (BFA), we recognize a conflict of interest as any situation in which an employee's personal interests may affect the interests of the organization. New employees are encouraged to inform BFA about specific situations that could generate a conflict of interest, such as prior representation, close kinship with clients, among others. We respect the commitment to exclusivity, avoiding additional activities that may interfere with the employee's obligations. BFA maintains a formal system to verify conflicts of interest in the provision of services to clients, ensuring transparency and commitment in all activities.

10. "ESG" COMMITMENT

We understand the importance of sustainable business practices, social responsibility, and transparent governance.

Our commitment to ESG guidelines is reflected in every aspect of our operation. We continuously seek to minimize our environmental impact, as evidenced by halving our paper emissions in the last 2 years. Furthermore, in the area of governance, we are committed to maintaining high standards, constantly updating and adapting our management models to meet the expectations of our employees, aiming for quality of life and talent retention.

By incorporating these principles into our organizational culture, we reaffirm our role in building a more ethical, responsible, and sustainable business world. BFA is committed to exceeding expectations, contributing to a more equitable and resilient future.

11. DISCIPLINARY SANCTIONS

To uphold the principles of this Code of Ethics, it is crucial to establish disciplinary sanctions in cases of violation of the ethical and behavioral guidelines outlined in this Code.

Disciplinary sanctions aim to maintain an ethical, transparent, and mutually respectful environment. In cases of inappropriate conduct that violate the principles established herein, corrective measures may include formal warnings, temporary suspensions, and, in extreme cases, contract termination.

The fair and consistent application of disciplinary sanctions reinforces our commitment to professional excellence and the preservation of the values that guide BFA.

Brasil Fernandes Law Firm

Last update: 05/02/2024