Code of Ethics


This Code of Business Ethics has the following objectives:

1 Display the Officers and Employees their respective ethical obligations to the Company, investors, customers, suppliers, creditors, competitors and public agencies, establishing an organizational culture that preserves the reputation conquered and consolidated D & F.
2 To base basic criteria to regulate the ethical conduct of all employees of D & F.
3 Ensure that all decisions comply with the existing laws and are governed by high standards of ethical conduct.
4 Establish an organizational conduct that protect the Company from financial losses resulting from extortion, fraud, theft or other dishonest practice.
D & F encourages creativity and freedom of action of its employees. However, it is of utmost importance that all Directors and Employees know and understand corporate values set forth herein and act in accordance with these in the performance of their professional duties.

The Code describes general situations regarding relations with employees, investors, customers, suppliers, public officials and Environment, considering those where there is potential for ethical conflict. Since this is only an illustrative list of behaviors, situations not covered by this Code of Business Ethics shall be determined in accordance with principles and ethics and management criteria.

Employees of D & F live the commitment to the sense of ownership and responsibility for their actions through the values that form the structural contribution of the Company and that support the development of legislation upon which decisions are made and actions are performed.

Thus, our professionals are committed to introduce real improvements in business, minimizing risks and optimizing profits. Aware that our work goes beyond trivial management reports generated in any consulting work, we believe that our activities can, yes, generate effects that benefit those involved, directly and indirectly, providing positive results both to people about the economy. Our values are grounded in five points:

  • Social Improvements: we believe that our work should be able to generate benefits to society.
  • Economic Results: work so that real economic improvements are promoted to the heritage of our customers.
  • Ethical Precepts: we conduct our actions to reflect the highest standards of ethics.
  • Quality: we work in order to have excellence in the delivery of service as a reason for the existence of our business.
  • Impartiality: we exercise our right mode function.

D & F regards the maximum value of human dignity. No person shall be discriminated against on grounds of gender, marital status, age, religion, ethnicity, political option, social and economic class, national origin, sexual orientation or disability.

The Directors and Employees of our company are committed to the adoption of ethical standards in their businesses with compliance with laws, regulations and ordinances, both the Brazilian and the countries with which it has business relationship, and that govern or limit their area responsibility, and with the rules and internal control procedures established by management. Given the complexity of laws and regulations, there may be doubts in the course of business. In these cases, employees should always seek guidance from the Legal Department of the Company.

D & F respects and faithfully complies with the legislation relating to human rights, the prohibition of child labor and forced labor, labor rights, the quality standards, health and safety, the environment, combating corruption and bribery, to taxes and fair competition.

The Company's Directors and Employees must observe a loyal, diligent, objective, respectful and honest conduct, with the highest ethical standards in their activities. In this sense, D & F understands that maintaining a good reputation in the market is essential for the continuity of their business, not being admitted to the sacrifice of this due to, for example, short-term results.

D & F adopts, in any case, as a fundamental criterion for admission, evaluation and promotion of officials and employees the fulfillment of basic requirements for each function, not giving rise to the emergence of any kind of discrimination, promoting a diverse workforce.

We recognize that each of our employees have personal and professional aspirations, the realization of these seek to contribute, including through training programs. We do not accept that the principle of hierarchy can be applied with arbitrariness or abuse of power.

D & F respects the privacy of its employees. Personal information of employees will only be collected and processed for reasons of corporate order, whenever the need for obtaining the data is in accordance with applicable law. However, the company reserves the right to monitor information generated in a communications base in order to inhibit illegal practices such as pornography, pedophilia, terrorism, unfair competition, breach of secrecy and confidentiality, disclosure of trade secrets, among others.

We value respectful relationship among employees, regardless of the position they occupy each of these. Reason is prohibited, condemned and must be denounced any conduct - physical, verbal or non-verbal - that may affect the dignity of persons at work, in particular, conduct that creates intimidation, hostility, humiliation and / or bullying and especially , sexual, because they hurt human dignity, affect productivity and adversely affect the working environment.

Financial information must be accurate, true and sufficient for users of these purposes. It does not tolerate the maintenance of any type of parallel funds, should thus all operations of D & F be duly recorded in the official accounting records.

The Directors and Employees must refrain from conduct comments, either in the family or social environment, on the activities of the Company.

No Director or employee may use the name of D & F in personal benefit activities.

All employees are responsible for safeguarding and the proper use of the Company's property assets made available. The use of these assets for personal gain will not be admitted and all movement must comply with the operating rules and set limits of authority.

The Directors and Employees shall not disclose confidential information concerning the processes, methods, strategies, plans, projects, technical data or otherwise, even after shutdown of the D & F where the disclosure of any confidential information can not be avoided, this must necessarily be approved by the Director of the area and, in the case of involvement with the press, the support area of Corporate Affairs should be requested.

The Directors and Employees should avoid the development of external activity to D & F that requires an amount of time and effort that might affect their ability and availability with the obligations it has in the Company.

It is prohibited to dismiss, demote, suspend, threaten, harass, interfere with the right of employment or in any other manner, discriminate whatever the employee for providing information, help provide information or assist in an investigation into presumed violations any provision of the Corporate Policies of D & F or this Code.

The Directors and Employees who participate in political activities must have special care not to involve the D & F, clearly establishing that acts in a personal capacity and not on behalf of the Company, and not use the resources of this, including working time, phones, e-mail corporate, among others; since it does not influence, support or intervene in these activities. It is also not allowed any kind of political propaganda on the premises or company vehicles.

D & F does not make contributions to political parties or candidates for elective office, whether in cash or in any other way.

The Directors and Employees may not use the resources of the D & F to send, receive, access, or save electronic information that have sexual content, promoting violence, to support gambling, that encourage the use and / or purchase of drugs and to encourage the purchase and / or illegal use of weapons. One should not install or use computer files or software not licensed by the company or approved by management.

Intentional dishonesty. It is a priority of the D & F that all employees adopt ethical behavior, to minimize the possibility of risk to the organization and to third parties related to this. Soon, it promotes and facilitates - through open communication and formal mechanisms implemented in accordance with the provisions set forth in this Code of Ethics - the identification of illegal practices and / or misconduct.

Restrictive Trade Practices. D & F operates under the premise of being governed by laws and regulations, whose observance and enforcement are essential to the existence and proper functioning of their social environment. Therefore, D & F does not participate in any activity that restrains trade or impossible negotiations with customers, members or suppliers who share ethical values and have a solid reputation.

Money laundry. D & F is committed to comply with all regulatory standards related to combating money laundering.


The Directors and Employees who meet customers should treat them equitably, fairly and honestly in all negotiations, providing quality services - are committed to excellence in different areas of activity - watching the best shopping and accepting standards, at all times, official regulations and internal regulations of the D & F.

D & F will integrate into your consultants group only those who share ethical values and have a solid reputation for fairness and integrity in their relationships.

The Directors and Employees who negotiate the purchase of goods and services required by D & F must provide and require fair treatment of suppliers and honest in each relationship, always having as support the Company's interests.

Seek or take some encouragement on the part of suppliers for their selection, it is considered misconduct. Suppliers who believe that an employee of D & F has conducted or participated in any improper or unlawful conduct should report the matter to the Company.


D & F practices acts of competition in accordance with the laws and regulations on fair competition in the places where it operates. Thus, will not participate in any agreement which may restrict the free play of forces of the markets in which it operates and will not use improper means to improve its competitive position in these markets.

The Directors and Employees of D & F, who have contact with representatives of Competitors must maintain a professional attitude linked to the principles and values of the Company representing, for in this way, to monitor both the personal image as the image of D & F.

It is considered legitimate and necessary for business efficiency, obtaining market information. However, in any case, D & F Will not seek entrepreneurial secrets or other confidential information of a competitor through illicit means.


The Directors and Employees of D & F shall cooperate at all times with the Public Officials for the full exercise of their powers and act according to the law, in defense of the legitimate interests of the D & F.

All business transactions and relationships on behalf of the Company with government bodies or their servants shall be made in accordance with the anti-corruption legislation and other applicable laws and normal conduct of business done, vehemently being prohibited and not tolerated any act attempts against the national public property or foreign, against the principles of public administration or against the international commitments made by Brazil. Thus, the D & F adopts the Laws national and international anti-corruption applicable to the activity of each partner, including but not limited to, US Law the Corrupt Practices Abroad (Foreign Corrupt Practices Act - FCPA), which are an integral part of this code, so that your employees, suppliers, partners and customers, must be aligned to this policy and the standards of ethics and conduct.

D & F does not authorize any person or organization to act on their behalf: whether as representative, agent, mandatary or under any other connection. It is also not allowed to use any immoral or unethical means in relationships with public officials.


Aware of the need to have an attitude endowed with social and environmental responsibility, the D & F recognizes the importance of protecting the environment, considered good of common use and essential to quality of life, through the adoption of ecologically balanced pipelines, as this must be defended and preserved for present and future generations.


D & F operates in communities, through contact provided by the client, in a responsible manner. Keeping the basic principles of this with respect to different cultures and thoughts.


D & F believes that health and safety at work are as important as any other function and purpose of the Company.

Measures are taken to ensure compliance with the following safety dictates and health at work: provide and maintain an adequate work environment and develop a safety awareness among employees. Moreover, they are complied with occupational safety standards of existing policies in the activities carried out by consultants on site, in the business environment of our clients.


Administrators and employees can not have interests in businesses that buy, sell or provide services to the D & F. Any transaction that effect must be reported to the Internal Audit.

The Directors and Employees should have no interests or investments that enable them to have a significant impact on commercial competitors.

Operations carried out by employees of D & F with companies belonging to biological relatives, social-affective and related these (spouse, parents, children, siblings, cousins, nephews, in-laws etc.) should be transparent. Thus, it is of fundamental importance that the company's managers are aware of the fact.

The Directors and Employees of D & F should abstain from relatives or family members who work under their supervision, except when authorized in writing by the Board of Directors.

When a director or employee does not feel able to fulfill their responsibilities with objectivity, being pushed by others who are using your position, authority or influence in the Organization, it should immediately report to your supervisor or to Human Resources and, if applicable, also report through the Reporting System established by the Company.


The distortion of records, financial statements or operations is prohibited, whether to simulate achievement of goals and objectives, is to get some personal benefit.

The information generated during all consulting activities are confidential and shall be delivered only to duly authorized users.

People who have access to inside information must take steps to prevent the disclosure or leakage of such information to unauthorized persons.

The Directors and Employees must take precautions to protect confidential information they have access to prevent them from becoming known to unauthorized persons.


The Directors and Employees of D & F must not accept valuable gifts, advantageous conditions, monies, travel, commissions or any other form of compensation - exceeding the acceptable limits of simple courtesy - coming from customers, suppliers, partners, financial institutions, utilities or people with whom transactions are conducted, avoiding thus the customary character. Any action that is set in the context covering the situations mentioned herein must be communicated to managers.


Violations of this Code shall be penalized objects. The severity of those penalties depends on the seriousness of the misconduct. In case of serious violations, sanctions can be of resignation to the criminal complaint before the competent authorities. By way of example, are considered violations of this Code the following practices:

a) not comply with the legal provisions entail sanctions by the authorities, property damage, or future contingencies to the Company.
b) disregard for negligent behavior, policies, standards and practices for good management of the Company in order to cause harm to this.
c) Discriminate, intimidate or harass another person because of gender, marital status, age, religion, ethnicity, political opinion, social and economic class, national origin, sexual orientation or disability.

Finally, one must ensure that the entire team at D & F meet this Code and has been informed of sufficient importance of its contents in the exercise of their activities. It is for the Human Resources department to disseminate this Code among officials, especially among the new ticket, by delivering a copy with signed confirmation of receipt, and include in education programs, the themes contained in the Code of Business Ethics and disclose any changes to this.