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CODE OF CONDUCT
FROM DOXA ADVISERS

PURPOSE

This document refers to the Doxa Advisers Code of Conduct.

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1. INTRODUCTION

  • The Doxa Advisers Code of Conduct (or “Code”) is a set of ethical principles and standards of conduct whose objectives are to improve the “ethical culture” in the Organization and manage conflicts of interest in its internal and external relationships.

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  • The Code applies to Doxa Advisers Collaborators, that is, Partners, Employees, Interns, Associates, Associated Companies, Associated Organizations, Consultants, Sponsors and National or International Partners, as well as third parties who are not part of the aforementioned groups, but who maintain other forms of relationship with Doxa Advisers.

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2. DOXA ADVISERS MISSION

Our purpose is to provide our clients with knowledge and guidance on its use in an effective, rational, ethical and sustainable manner, with adequate cost-benefit to achieve their objectives using a combination of technology and professional experience.

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3. DOXA ADVISERS PRINCIPLES

Considering that Doxa Advisers believes that companies are responsible for the challenge of improving management practices in order to generate positive social and environmental impacts and minimize potential negative impacts, we have decided to adopt the following items:

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Compliance

The ethical principle of reciprocal respect for citizenship rights and the physical and moral integrity of individuals constitutes the basis that guides and underpins our relationships with any and all persons involved and/or affected by our actions.

 

 

We conduct all our activities with integrity, combating the use of influence peddling and the offering or receipt of bribes or kickbacks by any person or public or private entity; we will seek to influence our suppliers and partners to also combat corrupt practices, in the public and private spheres.

 


In order to fulfill its purposes, Doxa Advisers will observe the principles of legality, impartiality, morality, publicity and transparency, economy and efficiency.

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Sustainability

Sustainability is a fundamental aspect of all our activities, as a way of collaborating in the creation and maintenance of an environment that is favorable to the development of human activities. We understand Sustainability in all its aspects, namely:

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- Environmental: involves natural resources and their exploitation by communities and companies.

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- Social: concerns people and how they live, taking into account basic aspects, such as education, violence, leisure and health.

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- Economic: encompasses the production, distribution and consumption of goods and services, considering their impact on social and environmental issues.

 

Transparency

We believe it is essential that society has access to information about the ethical and responsible behavior of companies. We will seek to make available, in a satisfactory and accessible manner, data and information that allows the evaluation of the social and environmental contributions and impacts of companies, except for confidential information.

 

Tolerance

We respect and value different points of view as a fundamental condition for the existence of an ethical relationship and the development of humanity.

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We will seek to encourage the promotion of the exchange of ideas as a positive differential in the development of our mission. We will not tolerate discrimination of any nature under any pretext.

 

Quality of Life

We understand that all our activities have as their ultimate goal the full fulfillment of ourselves and our employees, customers and associates as human beings. To this end, we always bear in mind the personal aspects involved in our decisions, seeking to respect the personal lives and needs of everyone with whom we interact.

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4. RULES OF CONDUCT

Special rules for partners and managers

In addition to all partners and managers having the duty to observe and comply with the rules established in the Code, the partners of each area are responsible for:

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  • Taking the necessary measures to ensure that all employees involved are aware of and duly apply the rules established in this Code of Ethical Conduct;

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  • Being an example of conduct to be followed by all employees;

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  • Responding promptly to questions and doubts raised by associates, consultants and partners regarding appropriate conduct in the face of ethical dilemmas;

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  • Considering any doubts regarding the interpretation of the text of the Code as relevant, as well as clarifying specific decisions, which should be discussed with the Internal Ethics Committee;

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Respect

Respect must prevail in the workplace, so that acts of moral or sexual harassment or situations that constitute pressure, intimidation or threats in the relationship between associates, consultants and partners, regardless of their hierarchical level, are completely unacceptable.

 

Political Activity

Doxa Advisers respects the political freedom of its Employees, however, it prohibits the carrying out of political party campaigns or propaganda in its activities or using resources from and/or in its name

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Religious Activity

Doxa Advisers respects the religious freedom of its Employees, but prohibits the holding of religious services on its premises and/or using resources from and/or in its name.

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Assets and Heritage

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Physical Assets

It is the responsibility of all Doxa Advisers employees to ensure the integrity of the company's systems, equipment and facilities.

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Electronic Resources

Computing resources, including but not limited to computers, cell phones, e-mails, Internet access and communication software, belonging to Doxa Advisers are made available for strictly professional purposes.

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The following practices are strictly prohibited:

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  • Access websites with inappropriate content, such as online games and pornography;

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  • Transmit messages or files containing political-partisan positions, chain letters, social, racial or religious intolerance, pornography or slanderous, defamatory and/or insulting content;

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  • Use unauthorized programs and/or pirated software.

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Employees declare that they are aware that corporate resources may be inspected at any time, authorizing the monitoring of all folders and files contained in the computer used by them, as well as corporate emails, telephones and cell phones.

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Such practice does not constitute a violation of any rights, since the equipment belongs to Doxa Advisers and its use is for professional purposes.

 

5. CONFLICT OF INTEREST MANAGEMENT

A conflict of interest occurs whenever the personal interests of employees, groups or third parties are contrary to the principles of Doxa Advisers and may, as a consequence, cause harm of any nature to the company.

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The following are considered conflicts of interest:

 

Hiring of Family Members of Employees and Advisors

The paid hiring of direct and indirect family members of any degree of kinship of Doxa Advisers Employees and Advisors is not permitted.​

 

Affective relationship

Doxa Advisers respects any romantic relationships that may arise between Employees. In order to minimize the occurrence of Conflicts of Interest, such relationships must be communicated to the Managing Partner. Subordination relationships between the Employees involved are prohibited.

 

Gifts, Presents and Entertainment Events

Receiving or offering gifts and invitations to entertainment events may generate a Conflict of Interest, therefore, the following guidelines must be followed

 

- Gifts and presents: The receipt of gifts is permitted as long as it is for institutional marketing purposes; the receipt of gifts that involve an expectation of return must be subject to consultation with the Internal Ethics Committee;

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- Entertainment events: Invitations for entertainment may be accepted by Employees, after consulting the Internal Ethics Committee. In the case of invitations to Board Members, these may be accepted after consulting the Ethics Committee.

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Regarding the offer:

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  • Only people previously authorized by the Board of Directors may make gift offers.

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  • The events held by Doxa Advisers are institutional and seek to unite people and companies in the search for a more ethical business environment. Therefore, invitations to participate in such events will be granted to companies and people whose event theme is relevant. Any offer made must have the sole purpose of strengthening partnerships, without any expectation of reciprocation.


 

Parallel activities

Parallel activities are those that Employees perform outside of working hours, whether or not they receive remuneration for their performance.

 

Although Employees are free to do so, it is essential that the practice does not impact their individual performance and/or affect the image of Doxa Advisers. They must also observe the following rules:

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  • It is not permitted to carry out parallel activities during working hours or on the premises of Doxa Advisers. Doxa Advisers assets are exclusively intended for activities related to Doxa Advisers;

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  • Invitations to take on advisory roles in other non-profit entities, as well as in any company, must be authorized by the Board of Directors;

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  • If there are Conflicts of Interest, especially when arising from relationships with other non-profit entities or companies, bring them to the attention of the Board of Directors;

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  • Invitations to teach courses and/or lectures, write texts or participate in similar activities, as a representative of Doxa Advisers, must be strictly voluntary and expressly authorized by the Board of Directors.

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Social Media

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  • The high level of exposure of personal information on social media has become increasingly present in our daily lives. This practice has led to the need for institutions to regulate rules and norms of social behavior to be observed by all their employees, so that they do not make their own confidential information public or link it to any form of discrimination, resulting in damage to the corporate image.

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  • In this sense, the disclosure of photos and videos related to the company or partners on social media (Facebook, Twitter, Linkedin, YouTube, among others) will only be permitted if the materials are available on the official Doxa Advisers website or on its official social media, that is, if they are already in the public domain. With regard to internal and confidential information, this may not, under any circumstances, be displayed on any of the aforementioned media.

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  • The provisions contained in the Doxa Advisers Institute Communication Policy must also be followed.

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6. DOXA ADVISERS’ RELATIONSHIP RULES WITH STAKEHOLDERS

Associate companies

The terms established to guide the association between the associated company and Doxa Advisers are guidelines for the relationship with associated companies, with the aim of facilitating the development of the entity’s mission and consolidating and improving the companies’ social responsibility policies and practices. Associate companies must meet the following requirements:

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  • They must not be included in the Registry of Employers who have subjected workers to conditions analogous to slavery of the Ministry of Labor and Employment (MTE);

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  • They must not be included in the Registry of Unfit and Suspended Companies (CEIS) of the Comptroller General of the Union (CGU);

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  • They must not be included in the Registry of Prohibited Private Non-Profit Entities (CEPIM);

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  • ​You must make this Code and the commitments defined in the Association Agreement, which are conditions for maintaining the status of all your employees, aware.

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Governments and Public Authorities

  • Relations with government officials or public authorities must always be based on transparency and integrity, as well as on other principles established in Laws No. 9,790/1999 (OSCIPs Law) and 12,846/13 (Anti-Corruption Law).

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  • Doxa Advisers repudiates any and all forms of corruption, favoritism, extortion and bribery at all levels and fully complies with all guidelines and demands of the Business Pact for Integrity.

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  • Any practices of soliciting or offering money, favors or any form of benefits are prohibited, including the use of assets and resources of authorities and public agents for the purpose of acquiring or expediting any service provision.

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  • In the event of situations that constitute a conflict of interest with public bodies, the fact must be immediately reported to the Managing Partner.

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Media / Press

  • Collaborators must have prior authorization from one of the Partners to speak in the media on behalf of Doxa Advisers and, if they have a position that differs from that defended by the organization, it must be explicitly stated as being the position of the collaborator.

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  • Partners must consult the Board in advance to speak in the media on behalf of Doxa Advisers.

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Suppliers and Service Providers​

  • The hiring of third parties must comply with strict principles of fairness and transparency.

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  • Doxa Advisers reserves the right to replace and/or terminate relations with any and all suppliers who fail to comply with integrity, environmental, labor, tax, health and safety at work laws, or who conflict with Doxa's interests.

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  • It is also important to emphasize that Doxa Advisers does not tolerate the use of child labor, slave labor or labor analogous to slavery, or any violation of Human Rights in its value chain.

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  • If the supplier or service provider needs to subcontract to meet Doxa Advisers' demands, the parties must provide for this in a contractual clause signed between them, including any guidelines that may be necessary. Authorization to subcontract will be granted exclusively by the Partner responsible for the project.

 

7. INFORMATION MANAGEMENT

The intellectual property of Doxa Advisers' brands, logos on its website and other logos and brands developed for its projects belong solely and exclusively to Doxa, as well as the software, systems, applications, documents and plans developed.


Therefore, Collaborators declare that they are aware that all files developed during the course of their professional activities must remain in the possession of Doxa Advisers or the end client in accordance with a specific contract, even after the Professional leaves the Company.

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8. CODE OF CONDUCT MANAGEMENT

Ethics Committee

The Ethics Committee is formed by Partners (General Partners and Associate Partners), assigning the following responsibilities to the body:

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  • assessment and opinion on violations of the Code of Conduct and institutional policies that must be submitted to the Board of Directors;

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  • analysis and guidance of cases not covered by the Code of Conduct;

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  • review and proposal for updating the Code of Conduct and institutional policies;

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  • promotion of training and dissemination of ethical culture.

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  • Violations of the Code of Conduct

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Failure to comply with this Code of Conduct by Employees will result in penalties depending on the severity of the incident, which may include a warning, suspension or termination of the contract, as well as other applicable legal measures.

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Communication Channels

  • Doxa Advisers employees should preferably discuss all matters relating to this Code with their immediate manager. However, if for any reason they do not feel comfortable doing so, they should contact the Administrative and Financial Director.

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  • People outside Doxa Advisers should discuss matters relating to this Code by communicating directly with the Executive Director, who will then forward it to the Ethics Committee.

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  • Any professional who notices any practice or act that is contrary to the provisions of this Code of Conduct must notify the Partner responsible for their activities, and they will have the option of remaining anonymous. All reports or non-compliance will be treated confidentially.

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