Code of Ethics and Conduct of Corrêa, Camps & Conforti (“3C Law”)
MESSAGE FROM THE LEADERSHIP
Corrêa, Camps & Conforti was founded as a new option for national and international clients who seek ethical, quality, and innovative service. As the firm’s fundamental values, we strive for ethics, quality, creativity, and innovation in everything we do.
This Code of Ethics and Conduct aims to formalize our values and must be complied with by all our members, associates, employees, and business partners to fulfill the mission of establishing lasting partnerships with national and international clients, offering cutting-edge solutions.
Leonardo Corrêa, Luiz Camps & Mário Conforti
Founding partners
1) CODE OF ETHICS AND CONDUCT
1.1) PURPOSE
3C LAW’S Code of Ethics was developed to ensure that each member, lawyer, associate, employee, or business partner is aware of the principles that guide the decisions inherent in the performance of their respective duties. The focus is on maintaining a transparent, ethical, and honest relationship with each other, clients, public agencies, and other partners.
When performing their duties, 3C Law’s members, employees, and business partners shall not take any action on behalf of themselves or 3C Law in violation of this Code and/or the laws applicable to their activities. If you have questions about the application and interpretation of this Code, seek guidance from the founding partners.
In case of suspicion or violation of this Code, report it immediately to the founding partners.
3C Law prohibits and does not tolerate any acts of retaliation against anyone who reports, in good faith, a suspected or actual violation of this Code.
2) CONDUCT OF TEAM MEMBERS AND BUSINESS PARTNERS
2.1) CONDUCT IN AND OUT OF THE FIRM
3C Law encourages a respectful and inclusive environment among its members, employees, and business partners, aiming to respect everyone’s dignity and enable good professional performance. Thus, we do not accept any act of discrimination and/or harassment.
Harassment is any unsolicited or unencouraged conduct of an abusive and/or derogatory nature. It can be moral or sexual and have various forms (e.g., unwanted touching, verbal abuse, bullying, etc.).
By discrimination, we mean actions based on prejudice related to origin, religion, race, gender, sexual orientation, social class, age, marital status, political party position, and disability of any kind.
3C Law’s members, employees, and business partners shall act in a manner consistent with the precepts of this Code and according to the highest ethical standards, observing honesty and integrity, always protecting 3C Law’s image, reputation, and legitimate interests.
This care must be maintained in public settings, both in the context of the performance of the professional activity and in private circumstances, avoiding involvement with any transaction or activity that could adversely affect 3C Law.
The participation of 3C Law members in lectures, seminars, and other public events must observe the confidentiality of information regarding 3C Law’s activities, services, and clients.
Only people authorized by 3C Law’s Leadership may represent or speak on its behalf, whether when in contact with the press, during participation in a public event, in social media, among other occasions.
3C Law members and employees must use their social media conscientiously, complying with legal limits and the principles of this Code. Consistently, 3C Law respects freedom of expression in its most diverse forms.
The relationship of 3C Law’s members, employees, and business partners with clients must be professional and based on courtesy, seeking an effective and transparent service in the operations performed and respecting information confidentiality. These procedures must be observed in any relations with the clients.
Business dealings with business partners will always be conducted in an isonomic, ethical, and transparent manner.
To maintain integrity during negotiations, offering or receiving any concession and/or advantage in the context of the purchase and sale of products or services (such as commissions, gifts, etc.), which may in any way bias the negotiations, is prohibited. Similarly, obtaining or offering price-related privileges or other privileges when purchasing goods for personal use is not allowed.
In addition, 3C Law’s members and employees must promptly inform any affective, corporate, or employment relationship, including kinship with business partners or clients, so that we may conduct a proper analysis of the situation. This measure is necessary to avoid situations of conflict of interest.
3C Law members or employees who intend to participate, directly or indirectly, as an employee, partner, or member of the management of any other legal entity (such as a corporation, association, foundation, etc.) must inform the respective area or person in charge at 3C Law in advance. The same applies to members and employees carrying out other activities that may conflict with those developed by 3C Law, leading to a conflict of interest.
2.3) SPECIFIC RULES FOR EQUITY AND SERVICE PARTNERS AND ASSOCIATES
It is the responsibility of 3C Law partners and associates to timely pay their Brazilian Bar Association (OAB/SP) annual fees. If any partner or associate is in default with the OAB/SP, the situation must be immediately communicated and solved by the defaulting party within two (2) days, as of the acknowledgment of such default.
Failure by the defaulting party to remedy the matter will entitle 3C Law to perform the payment and deduct the amounts paid from the defaulting party’s compensation.
According to Resolution No. 16/98 of the Ethical Court of the Brazilian Bar Association, after leaving 3C Law, partners and associates will be barred from acting professionally for clients in 3C Law’s Client Portfolio for two (2) years, unless otherwise expressly agreed with 3C Law.
The infringing party will be subject to the payment of damages resulting from the violation of this item. Furthermore, such party will also be liable for any acts practiced before the Ethics Court of the Brazilian Bar Association (São Paulo Regional Office) and other competent bodies, including the Judiciary.
3) ANTI-CORRUPTION GUIDELINES
3C Law and its members, employees, and business partners are committed to observing the anti-corruption laws in force, especially Law No. 12.846/2013 (Anti-Corruption Law). 3C Law also disapproves all forms of corruption, whether within the context of public relations (transactions directly or indirectly involving any Government Entity or Public Official) or in the context of private relations (transactions between private individuals or companies without the involvement of a Public Official and/or Government Entity);
Thus, 3C Law members, employees, or business partners are not authorized to:
- Offer, promise, grant, authorize or give, directly or indirectly, any payment, Undue Advantage or Anything of Value to another person, Private Entity, Public Official or to a related party to influence or induce them to perform an activity or task; and/or obtaining or retaining any illicit business or advantages. • Request, accept or receive, directly or indirectly, any promise or payment of Anything of Value for oneself or a person or Public or Private Entity, in exchange for the performance or omission of any act in the fulfillment of one’s duties.
- Neglect or ignore warning signs when circumstances indicate a potential violation of these guidelines.
3C Law members, employees, or business and partners must also refrain from acting for or on behalf of 3C Law to prevent, defraud, deceive, obstruct, or disrupt public bidding processes or quotations.
4) EXPENSES CRITERIA AND CONDITIONS
4.1) COURTESIES, MEALS, AND ENTERTAINMENT
When maintaining a relationship with the client, it is crucial to consider that it falls within the scope of professional relations and, therefore, some parameters must be observed.
Invitations to meals, courtesies, and entertainment may be offered to cultivate cordiality and good relations with clients.
However, such practices cannot aim to obtain or retain business and/or improperly influence the client’s decision. In addition, the amounts spent must be appropriate and in accordance with market practices and applicable legislation. It is essential to comply with internal policies that limit the amounts spent, both by the firm and the client. Such amounts must be recorded/documented and submitted for registration, control, and compliance verification purposes.
4.2) CHARITABLE DONATIONS AND SPONSORSHIP
Charitable donations or sponsorships on behalf of the firm may be made through a formal procedure and prior authorization, provided that they do not constitute an improper advantage, are within the limits of applicable law, and comply with the provisions of this Code.
5) USE OF THE FIRMS’ INFORMATION AND TOOLS
3C Law owns the information and working tools made available to its members and employees.
Therefore, the professionals mentioned above must return them at the end of their relationship with 3C Law or when requested. The same applies to business partners when using the firm’s tools and holding 3C Law information.
5.1.) INFORMATION SECURITY AND CONFIDENTIALITY
While performing professional activities, 3C Law members and employees will have access to sensitive and confidential information related to clients and the firm itself.
For the sake of client trust and 3C Law’s security, such information shall be kept confidential, except when expressly authorized for disclosure, within the possibilities allowed by professional liability, or when permitted by law.
Confidential information may only be used to fulfill the firm’s purposes and objectives correctly and faithfully.
Confidential information includes, but is not limited to, the firm’s information, including its clients’, regarding advisory and preventive procedures, in Brazilian territory and abroad, especially those provided by 3C Law or that the professional has had access to the content through the firm.
5.2) USE OF ELECTRONIC MEANS OF INFORMATION
It is forbidden to send and use, in any way, obscene, pornographic, violent, discriminatory, racist, defamatory material, which disrespects the dignity of the person and is contrary to the laws in force and the interests of 3C Law.
3C Law members and employees, including business partners using tools provided by the firm, generally should not expect privacy when using the firm’s systems and resources.
Furthermore, under applicable law, 3C Law may review, monitor, and record information exchanged at any time and without notice or permission. This rule covers information transmitted by telephone, e-mail, applications, and any other means of communication or storage on an office system or resource.
5.3) INFORMATION PRIVACY
3C Law respects the right to privacy of the people with whom it has a relationship. The firm only uses the information provided by third parties for legitimate purposes, respecting the grounds on which its collection occurred, in compliance with applicable laws.
6) PENALTIES
This Code intends to establish the general guidelines of the principles to be observed by 3C Law members, employees, and business partners, being each one’s responsibility to act according to its precepts, under penalty of becoming subject to appropriate proportional disciplinary measures in case of violation.
7) TRAINING
3C Law’s members, employees, and business partners will receive training on the content of this Code and must sign the Term of Commitment and Adhesion attached to this Code, to prove that they (i) have received a copy of this Code; (ii) are responsible for reading and becoming aware of its entire content; and (iii) are aware that any violation of this Code will result in disciplinary sanctions.
In addition to this initial training, the firm will also provide periodic training on this Code for updating and reinforcement purposes.
New members, employees, and business partners will receive a copy of this Code and sign the Term of Commitment mentioned above when they start their activities.
