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Code of Ethics

Estimated reading time: 14 minutes

Last update: 02/04/2023

1. Summary and Purpose of the Code

The professional Code of Ethics (“Code”) for Andre Sanches and its subsidiaries, affiliates, companies (“Company”, “Company”, “Group”) aims to give our employees and collaborators guidelines on ethics in business and stance on controversial issues. We trust you to use your common sense, but we want to provide you with a concrete guide that you can turn to if you are not sure how to act (for example, in cases of conflict of interest). We will also use this policy to describe the consequences of violating our professional code of ethics.

2. Scope/Scope

This policy applies to everyone we employ or maintain business relationships with. This includes individuals such as employees, interns, volunteers, but also commercial entities such as suppliers, partners, corporate customers or venture capital firms.


Please note that our code of ethics is slightly different from ours.  Code of Conduct . The code of conduct may include elements such as the dress code and use of social media, while our professional code of ethics addresses issues of a legal or moral nature. Still, these two codes overlap.

3. Code elements


What is meant by a professional code of ethics?


First, let's define professional ethics: it is a set of principles that guide people's behavior in a business context. They are essential to maintaining legal business and a healthy work environment.


So what is a code of ethics? Our definition of a code of ethics refers to the standards that apply to a specific setting - in this case, the organization itself.

What is the purpose of a professional code of ethics?

Having our business ethics in writing doesn't mean we don't trust our employees. We strive to hire ethical people who have personal standards, so we hope that a written code will not be necessary most of the time.

But it can be helpful in situations where you find yourself not sure how to act. Life is full of gray areas where right and wrong are not so apparent. Some professional ethics also correspond to laws that you absolutely must know to do your job properly, so we'll mention them in our code of ethics.


Also, every organization makes bad hires from time to time. We also cannot predict how people will behave. When an employee behaves or intends to behave in a manner contrary to professional ethics or applicable laws, we will have clear guidelines on what disciplinary actions we will consider.


For these reasons, we recommend that you read this document carefully and consult your manager or HR, in case of  doubts.

The components of our professional code of ethics

We base our professional code of ethics on common ethical principles:

  1. Respect for others. Treat people with politeness and respect above all.

  2. Integrity and honesty. Tell the truth and avoid any wrongdoing as best you can.

  3. Justice. Make sure you are objective and fair and don't harm others.

  4. Legality. Know and follow the law - always.

  5. Competence and responsibility. Work hard, dedication and efficiency and be responsible for your work and for the best delivery.

  6. Team work. Collaborate and ask for help.  Be open to learning and teaching always, contributing to our mutual growth.

Here is a more detailed overview of our code:

3.1 - Respect for others


It is mandatory to respect everyone with whom you have any type of interaction, with kindness, courtesy, politeness and understanding. The personal space, opinions and privacy of others must be respected.  It is strictly prohibited and will result in immediate termination, the use of any type of violence, whether physical, psychological (threats, humiliation and intimidation), moral (defamation, slander, blackmail), sexual (abuse, harassment, rape,  exposure of nudity), economic (retention of assets or capital, theft, theft) or social (discrimination, segregation, intolerance).


What constitutes harassment? To answer that, we have a policy on harassment [to be published] and a more specific policy on sexual harassment [to be published] that you can take a look at. As a general rule, try to put yourself in someone else's shoes. How would you feel if someone behaves  in a specific way  and differentiated with you? If the answer is "I wouldn't like it very much" or "I would never let that  if they behaved like that to me,” then we don't tolerate that behavior, regardless of who the person is.


If someone, whether a customer, colleague or interested party, is offensive, humiliating or threatening towards you or someone you know, report  immediately to HR or your manager. You may also report rudeness and indifference if they become excessive or frequent.

3.2 - Integrity and honesty


First, always keep our organization's mission in mind. We all work together to achieve specific results. Your behavior should contribute to our goals, financial or organizational.


Be honest and transparent when acting in ways that impact others (for example, making strategic decisions or deciding on layoffs). We do not tolerate malicious, deceitful or petty conduct. Lies and cheating are huge red flags and they could  face progressive discipline [to be published] or immediate termination, depending on the damage done.


Stealing from the company or others is illegal and  you will suffer repercussions depending on the severity of your actions. For example, in case of theft or misuse  in  office supplies, may receive a reprimand, while in case of  theft of money or data (for example, engaging in fraud or embezzlement), you will be fired and face legal consequences. The decision is at the discretion of HR, on a case-by-case basis.

Conflict of interests


Conflicts of interest can occur whenever your interest in a particular subject leads you to actions, activities or relationships that harm  the company. This includes situations such as using the authority of your position for personal gain or exploiting company resources to support a personal business to make money. Even when you seem to act to the company's advantage, you can actually put it at a disadvantage. For example, if an employee uses questionable methods to obtain competitive information and increase his sales record, his actions will have a positive impact on the company's revenue, but will put the company at legal risk by promoting  unhealthy business practices.

If you have created a conflict of interest, it needs to be immediately remedied and closed. If the conflict of interest is involuntary (for example, buying shares in a company without knowing they are competitors), we will take steps to correct the situation. If you repeat the offense, you could be harmed and suffer legal consequences.

3.3 - Justice

Do not act in ways that exploit other people, their hard work, or their mistakes. Give everyone the same opportunity and report  when someone doesn't.


To be  objective when making decisions that may impact others, including when you decide to hire, promote, or fire someone. Make sure you can justify any decision with written records or examples. To search for  and use the most objective methods in any case,  for example, when interviewing candidates, do  the same questions for all of them and avoid  judging non-work-related criteria such as clothing, appearance, etc.

Also, don't discriminate against people with  protected characteristics [link in English from the Commission on Equality and Human Rights]  (eg age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, sexual orientation) as this is prohibited by international and national law. If you suspect you may have an unconscious bias that influences your decisions (do the  Harvard Implicit Association Test  can help you determine this), ask HR for help.


Be fair when exercising authority. Do not show favoritism towards specific employees and be transparent when deciding to praise or reward an employee. You are also required to follow the Hiring Relatives Policy [forthcoming], which prohibits you from having a reporting, managing, or reporting relationship with a relative.


If you need to discipline an employee, make sure you have prepared a case that you can present to HR. Retaliation of any kind against employees or candidates [to be published] (such as where they file complaints) is not permitted, as this is prohibited by law [to be published].


Be fair to customers, partners, suppliers, governments, stakeholders and society in general as well. If you believe our company is wrong in a particular case, don't try to cover it up or accuse the other side. Discuss with your manager to find solutions that can benefit both sides.

3.4 - Legality


You are required to follow all laws that apply to our organization. Depending on your role and profession, there may be several laws you need to observe. For example, accountants and healthcare professionals have their own legal restrictions and must be fully aware of them.


When preparing contracts, stipulations, disclaimers or copies online that may be governed by law (such as consent forms), get a lawyer or law firm to check before finalizing anything.

You are also covered by our Confidentiality Policy [to be published] and the  Privacy Policy . It is expressly prohibited to expose, disclose or put at risk customer, employee, interested party or our business information. Also always follow our cybersecurity policy [forthcoming].


Following the laws regarding fraud, bribery, corruption and any type of aggression is an obligation of all of us. You are also required to follow child labor laws [to be published] and not to do business with illegal organizations.

If you're not sure what the law is in a specific case, don't hesitate to ask through the  Institutional Contacts .

3.5 - Competence and responsibility


We all need to put a healthy amount of effort into our work. Not just because we're all responsible​​ for the success of the organization, but also because the lack of commitment  affects our colleagues. Incomplete, inefficient, or slow work can disrupt other people's work or cause them to shoulder the burden.


This is in direct conflict with our principles of respect and integrity.


We also expect you to take advantage of learning and development opportunities, at work or through educational material or training. If you're not sure how to accomplish this, have an open discussion with your manager.


Also, take responsibility for your actions. We all make mistakes or need to make tough decisions, and it's important that we trust them. Failure to be responsible on a regular basis or in important situations (for example, a critical error in our financial records) will result in termination. If you take responsibility and find ways to correct your mistakes whenever possible, you'll be in a much better position.

3.6 - Teamwork


Working well with others is a virtue.  and not an obligation. You will certainly work autonomously and focus on your own projects and responsibilities. But you must also be ready to collaborate and help others.


Be generous with your experience and knowledge. Be open to learn and evolve. If days go by without you consulting or brainstorming with someone, you are missing out on opportunities for excellence. Instead, work with others and don't hesitate to ask for help when you need it.

Always keep in mind our purpose and that, for it to be achieved, we all need to be in the same direction, always seeking to develop as people and professionals to become even better and deliver better results and experiences to everyone.

4. General


The Company reserves   the right to update the terms of the code from time to time, in the sole discretion of the Company. You should periodically review it for any updates and modifications.

If this code is translated into other languages and there is a discrepancy between the versions, the Portuguese (Brazil) version will prevail.

If you need additional information about the website or this code, please contact us at dos Institutional Contacts.

Code created on 07/10/2020.

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