Code of Conduct

03 / 02 / 2021

Policy

Partners, associate lawyers, and trainees of Lassori Advogados are subject to the rules of the profession and to the Code of Ethics and Discipline of the Brazilian Bar Association (OAB), pursuant to Federal Law No. 8,906/1994 (check here).

In addition to the above-mentioned code, Lassori, committed to ethics and integrity, has developed its Code of Conduct with the objective of guiding its professionals in their relations with various audiences.

We are committed to systematically combating corruption, discrimination, and all other forms of misconduct. We do our work with honesty, integrity, and transparency. We respect the legitimate interests of all those with whom we relate.

Our Code of Conduct applies to partners, associates, consultants, contractors, and other members of the firm, without exception, who shall especially observe the following principles:

  • Corporate spirit: conducting one’s professional activities always bearing in mind the general interest of Lassori, which by definition overrides the individual professional interests of each member;
  • Legality: practicing law, in any of its fields, within the limits established by law;
  • No conflict of interest: not accepting a task or cause that may conflict with the interests of clients and the firm itself;
  • Confidentiality: keeping confidential any confidential information and documents which have been transmitted by the client, or which have come to one’s knowledge in the exercise of one’s profession and, in particular, by virtue of one’s position in the performance of one’s professional duties at Lassori;
  • Morality: observing behavior consistent with good manners, sobriety, and courtesy, as well as alert clients and co-workers to situations that may constitute a breach of ethical principles;
  • Transparency: adopting a clear and objective professional posture, subject to the legal cases of confidentiality or reserve necessary to maintain the principle of confidentiality;
  • Exemption: abstaining from associating with clients, except for benevolent purposes and to maintain with clients, without previous knowledge of Lassori, extra-professional business relationships, as well as trading with shares issued by clients;
  • Exactness: taking care of the quality and promptness in the rendering of services and observing legal deadlines strictly.
  • Data privacy: respecting the privacy of personal data of clients and their employees, in accordance with Law No. 1,.709/2018 (click here).

Lassori does not tolerate corrupt practices of any kind. Therefore, it forbids any of its staff from promising, offering, or giving, directly or indirectly, any undue advantage to a public agent or to any third person related to it, with a view to obtaining any undue advantage.

Anti-corruption and anti-money laundering legislation

In the professional performance of all staff members of Lassori, all have the duty to comply with and enforce the anti-corruption rules, notably those set forth in the Brazilian Penal Code and the Anti-Corruption Law (Law No. 12,846/2013). In addition, staff members must respect foreign legislation on the subject, such as the Foreign Corrupt Practices Act (FCPA) in the United States of America and the United Kingdom Bribery Act (UKBA) in the United Kingdom.

Prohibited conduct

Without prejudice to other prohibitions, the following conduct os prohibited:

  • Promising, offering, or giving, directly or indirectly, an undue advantage to a public agent or intermediary, with the intention of obtaining any type of undue benefit for oneself or one’s clients;
  • Facilitation payments, herein understood as a prohibition on offering any advantage to public agents in order to accelerate or favor the performance of official acts, such as obtaining permits, permissions, or other administrative measures;
  • Payment brokerage, herein understood as a prohibition on the brokerage of the delivery of amounts or undue advantages, even at the request of clients, to any public agents or persons related to them, regardless of the reason.
  • Providing or using the personal data of clients, employees, or third parties to which one has had access, without the express consent of the owner, unless it is necessary for the legal exercise of the right.

Lassori’s partners, attorneys, trainees, employees/staff members must also inform the HR department if their spouse, partner, or relative in a straight or collateral line, by blood or marriage, up to the third degree, occupies a position of trust, managerial, or senior management position of any Public Administration body or entity, directly or indirectly, at any level of government.

The conduct guidelines contained in this Code will be brought to the attention of all staff and will also be available at www.lassori.com.br. Any questions regarding compliance with the guidelines set forth in this Code should be addressed to the leader of the area in which the staff member operates or directly to Lassori, through the person of any of its founding partners.

The firm will also receive and investigate complaints about any noncompliance with this Code. Complaints against its staff will be investigated by the Firm, through the person of its founding partners, who will be responsible for applying penalties for non-compliance with this Code, verbal or written warning, suspension, or severance of ties, according to the gravity of the case.

Any deviations from the principles and values established herein can and should be reported by any interested person, whether or not a member of Lassori’s staff and employees, through any of the available reporting channels.

The desire for anonymity or confidentiality of identity is fully and permanently assured, which is intended as a means of motivating reports of violations of this Code.

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