Our Policies
Commitments and transparency
Our Commitments and Internal Policies
CONTENT seeks to promote its purpose through concrete actions in its services and areas of operation, resulting in various internal policies related to the environment, workers, consumers and clients, community, and governance. These policies follow principles established by multiple reference standards, such as the UN Sustainable Development Goals (SDGs) criteria and ESG standards.
TABLE OF CONTENTS
1. Applicability
2. Principles and Values
3. Conduct Guidelines
3.1. Discriminatory Actions
3.2. Use of Alcohol, Drugs, and Weapons
3.3. Relations with Business Partners
3.4. Receipt/Offering of Gifts
3.5. Fraud, Bribery, and Corruption
3.6. Relations with Authorities and Government Agencies
3.7. Relations with Shareholders and Investors
3.8. Relations with the Press
3.9. Social Responsibility
3.10. Environment
3.11. Health and Safety
3.12. Freedom of Association
3.13. Use of Company Assets
3.14. Use of Information/Confidentiality
3.15. Parallel Activities
3.16. Activities Unrelated to the Company’s Interests and Business
3.17. Relatives/Romantic Relationships
3.18. Potentially Conflicting Situations
4. Whistleblowing Channel
5. Management of the Code of Ethics and Business Conduct
6. Advisory Bodies
7. Miscellaneous
1. APPLICABILITY
1.1. The rules set forth in this Code of Ethics and Business Conduct, as well as other policies and regulations of CONTENT Ltda. (“Content” or “Company”), and the laws and regulations of the locations in which we operate, must be understood and respected by Employees, Members of Administration, Team Coordination, Interns, Apprentices, Suppliers, Service Providers, and any third party acting on behalf of Content (“Collaborators”).
2. PRINCIPLES AND VALUES
2.1. The Company strives for the highest standards of integrity, transparency, and reliability in all its business and relationships, guided by a set of ethical and moral values. All Collaborators are responsible for disseminating these values and conducting the Company’s business accordingly.
2.2. Content’s fundamental principles and values are:
a) Respect: Acting with respect for people and the environment, with social responsibility towards the community in which it operates, and in compliance with prevailing laws and regulations.
b) Honesty: Establishing and maintaining relationships in an honest, impartial manner, without omitting facts, and always based on truth and moral integrity.
c) Customer Focus: Ensuring customer satisfaction by developing and delivering high-quality services that meet their requirements.
d) Quality: Striving for excellence in execution, with high performance, commitment to delivering safe and high-tech services, and a focus on continuous improvement.
e) Results-Oriented: Continuously seeking results while maintaining consistency, quality, and adherence to agreed deadlines.
f) Professional Development: Providing opportunities for employee growth based on personal effort, merit, performance, and goals.
g) Purpose: Remaining faithful to its mission of building, enhancing, and promoting a purpose-driven communication culture.
3. CONDUCT GUIDELINES
a) The following conduct guidelines represent mutual commitments between the Company and its Collaborators, aiming to guide professional practices and clarify potential conflict situations in internal and external relations.
b) The selected topics, which do not exhaust all possible situations, have been prioritized to form the Company’s Code of Ethics and Business Conduct, contributing to ethical and sustainable management.
3.1. Discriminatory Actions
3.1.1. The following practices are strictly prohibited for any Content Collaborator:
a) Any conduct characterized as discriminatory based on race, nationality, color, gender, sexual orientation, language, disabilities, religious belief or political conviction, social origin, HIV status, or any other condition.
b) Any behavior that constitutes moral or sexual harassment, offense, hostility, public humiliation, intimidation, or ridicule.
c) Conducting political propaganda or religious demonstrations on Content’s premises or externally in the Company’s name.
3.2. Use of Alcohol, Drugs, and Weapons
a) Content does not allow the possession, consumption, or presence under the influence of alcoholic beverages or illegal drugs on its premises or in the Company’s name.
b) The use of cigarettes or similar products, including electronic cigarettes, is not recommended and is prohibited in indoor areas of the Company, in accordance with the law.
c) The possession and storage of weapons on Company premises are prohibited, except for legally authorized professionals expressly permitted by management.
3.3. Relations with Business Partners
3.3.1. All relationships with Content’s business partners, including Clients, Suppliers, and Service Providers, must be based on technical and transparent criteria, conducted ethically and respectfully to foster long-term trust-based relationships aligned with corporate objectives.
3.3.2. Collaborators with family or personal interests involving a Content business partner must not participate in any Company decisions or use their position to influence matters related to the partner.
3.3.3. It is considered a conflict of interest to use the Company’s name for personal purchases, service contracts, or loans, benefiting from the credit or special discounts granted to Content.
3.3.4. Receiving advantages such as payments, gifts, loans, entertainment, travel, employment for relatives, or favors from current or potential business partners is considered a conflict of interest.
3.3.5. Internal Collaborators with relationships (including family ties) with individuals commercially linked to Content, such as Suppliers, Investors, or Partners, must disclose such relationships to the Company via the Compliance Directorate.
3.4. Receipt/Offering of Gifts
3.4.1. The exchange of gifts, services, and presents must be conducted with caution and transparency to ensure it does not influence or appear to influence business decisions.
3.4.2. The receipt or offering of non-monetary gifts valued up to 20% of the federal minimum wage per calendar year is not considered a conflict of interest.
3.4.2.1. Gifts exceeding this value must be returned or, if not possible, forwarded to the Operations Director for final disposition.
4. WHISTLEBLOWING CHANNEL
4.1. Content’s Collaborators who become aware of any violations of this Code, Company policies, or applicable laws and regulations must report them through the Company’s Whistleblowing Channel, available at contentcomunica.com.br.
4.2. Content’s Whistleblowing Channel allows for transparent and anonymous reporting and ensures impartial and confidential handling. Reports will be analyzed by the Compliance Directorate, guaranteeing confidentiality and protecting the whistleblower from any form of retaliation.
5. MANAGEMENT OF THE CODE OF ETHICS AND BUSINESS CONDUCT
5.1. Collaborators are responsible for adhering to and enforcing the rules outlined in this Code of Ethics and Business Conduct.
5.2. Violations of this Code and other Content policies may result in consequences, including verbal or written warnings, suspension, termination (with or without cause), or contract termination for legal entities.
5.3. Disciplinary measures will be applied based on the type and severity of the violation.
6. ADVISORY BODIES
6.1. Legal Department and Compliance Directorate.
6.2. The Compliance Directorate is responsible for monitoring Code compliance, managing the Whistleblowing Channel, and ensuring confidential and anonymous reporting.
6.3. The Legal Department, alongside the Compliance Directorate, will propose updates to the Code to the Board of Directors.
6.4. The Compliance Directorate will establish criteria for handling unanticipated situations, resolving ethical dilemmas, and ensuring uniform resolution of similar cases.
7. MISCELLANEOUS
7.1. Content reserves the right to modify policies and regulations without prior notice, without necessarily altering this Code.
7.2. If any provision of this Code conflicts with national laws in the countries where Content operates, legal requirements shall prevail.
7.3. The Company will periodically provide training on the Code of Ethics and Business Conduct.
1. PURPOSE
1.1. In accordance with the objectives of Law 12.846/2013, various international anti-corruption laws and guidelines (“Regulations”), and the internal rules adopted by CONTENT Ltda. (“Content” or “Company”) through its Code of Ethics and Business Conduct (“Code of Ethics”), this Anti-Corruption Policy (“Policy”) aims to ensure that all stakeholders understand the requirements of the Regulations, the preventive anti-corruption practices, legal and internal sanctions, and reinforce the obligation of compliance while reaffirming Content’s commitment to corporate governance principles: transparency, fairness, accountability, and corporate responsibility.
2. SCOPE
2.1. This Policy applies to the following individuals (“Collaborators”), who must comply with it:
(i) Company Employees;
(ii) Interns and Apprentices;
(iii) Members of the Administration and Board of Directors;
(iv) Suppliers;
(v) Service Providers;
(vi) Commercial Representatives;
(vii) Any third party acting on behalf of the Company.
2.2. Collaborators automatically adhere to this Policy as an integral part of other documents such as contracts, general conditions, responsibility terms, letters, etc., which will be archived at the Company's headquarters. Company Employees automatically adhere to all Company policies.
3. KEY DEFINITIONS
3.1. Below are key definitions necessary for the proper understanding of this Policy.
- Public Administration: Set of bodies and entities that manage and execute public affairs or services through public officials at the federal, state, and municipal levels, including para-governmental entities and any private associations or foundations that receive funds, subsidies, incentives, or financial support from public entities.
- Private Organization: Any legal entity under private law, including associations, corporations, foundations, religious organizations, political parties, and individual limited liability companies.
- Public Official:
- (a) Any person holding a public office or function, even temporarily or without remuneration, including positions in public companies or state-owned enterprises.
- (b) Any person acting on behalf of a political party.
- (c) Any foreign public official, including those working in public entities or diplomatic representations of foreign countries, even if temporarily or without remuneration. This also includes international public organizations.
- (d) This definition extends to immediate family members (spouse, parents, children, and/or siblings) of the public official or any person or entity that can potentially influence, directly or indirectly, the decisions and positions of any Public Official or Public Administration, including candidates for public office or former officeholders.
- Offering or Promising Undue Advantage: The mere act of offering or promising an undue advantage, regardless of acceptance, constitutes corruption.
- Undue Advantage: “Anything of value,” not necessarily economic, offered with the intent of receiving preferential treatment in return (e.g., dinners, scholarships).
- Directly or Indirectly: The promise or offer of an undue advantage can occur directly or indirectly when it is directed at third parties related to the public official.
- Bribery: The offer, promise, donation, acceptance, or solicitation of an undue advantage of any value (whether financial or non-financial), directly or indirectly, in violation of applicable laws, as an incentive or reward for or from a legal entity or individual from a Private Organization, influencing their obligations.
- Fraud: The intent to cause harm to third parties and/or conceal the truth to evade obligations through bad faith.
- Bidding Process: The procedure used by Public Administration to contract services or acquire products from a private company.
- Public or Administrative Contract: Contracts between a private entity and the Public Administration.
- Economic-Financial Balance of the Contract: The proportional balance between the obligations established for both parties in a contract.
- Money Laundering: A crime under Law No. 9.613/98, which involves concealing or disguising the origin and movement of assets derived from illegal activities.
4. COMPLIANCE WITH THE LAW
4.1. Collaborators must ensure that their interactions with the Public Administration and Public Officials strictly comply with applicable laws, regulations, procedures, and the Code of Ethics, refraining from engaging in any form of corruption, including but not limited to:
(i) Promising, offering, or giving, directly or indirectly, an undue advantage to a public official or a related third party.
(ii) Assisting in the execution of illicit acts against Public Administration for personal benefit.
(iii) Using an intermediary individual or entity to conceal real interests or the identity of beneficiaries in transactions.
(iv) Impeding or manipulating bidding processes, public contracts, or related acts.
(v) Fraudulently disqualifying competitors or offering undue advantages to influence bidding outcomes.
(vi) Gaining undue advantages or manipulating the economic-financial balance of contracts through fraud.
(vii) Obstructing investigations or interfering with regulatory agencies and oversight bodies.
5. PRIVATE SECTOR BRIBERY
5.1. Although Law No. 12.846/2013 and the FCPA do not explicitly address bribery in the private sector, such acts are strictly prohibited under this Policy.
5.2. Collaborators must conduct their relationships with Private Organizations and their employees in strict compliance with laws, regulations, procedures, and the Code of Ethics, refraining from engaging in corruption, including but not limited to:
(i) Promising, offering, or giving, directly or indirectly, an undue advantage to an employee of a Private Organization or a related third party.
(ii) Assisting in illicit acts against a Private Organization for personal benefit.
(iii) Using an intermediary individual or entity to conceal real interests or the identity of beneficiaries in transactions.
(iv) Gaining undue advantages or manipulating the economic-financial balance of contracts through fraud.
6. MONEY LAUNDERING
6.1. The following behaviors may indicate money laundering attempts and must be avoided by Collaborators:
- Requests to conduct cash transactions or use non-standard payment methods to settle obligations.
- Requests to conduct transactions for multiple beneficiaries or third parties unrelated to the contract.
6.2. Collaborators must refuse to engage in any act if there are doubts regarding its legitimacy and legality.
7. EXCEPTIONS
7.1. The following items are permitted under this Policy if they meet the specified criteria and comply with the law:
- Gifts and Promotional Items: Any gifts, services, or promotional items offered in Content’s name must be pre-approved by the relevant Directorate and have a nominal value limited to 20% of the federal minimum wage per year. Cash or equivalent gifts, such as loans or gift cards, are strictly prohibited.
- Travel Expenses: In certain circumstances, Content may cover travel expenses for visits to its facilities. These expenses must be reasonable and pre-approved.
- Hospitality: Meals and entertainment may be provided under specific circumstances with prior approval.
- Sponsorships and Donations: Sponsorships for cultural, educational, and scientific purposes or societal benefits are allowed, provided they comply with Company policies and receive prior approval.
7.2. All payments must be properly recorded in the Company’s books and records.
8. ELECTORAL CAMPAIGNS
8.1. Content prohibits financial or economic support for electoral campaigns, as it may disguise corruption-related actions.
8.2. Donations to electoral campaigns, whether directly or indirectly, in Content’s name—including monetary contributions, sponsorships, or fundraising events—are strictly prohibited.
9. WHISTLEBLOWING CHANNEL
9.1. Content’s Whistleblowing Channel is a confidential and secure platform for reporting unethical behavior or legal violations. Reports can be made anonymously.
9.2. Reports will be analyzed by the Compliance Directorate and, if substantiated, reported to the Board of Directors.
9.3. Access the Whistleblowing Channel via the Company website or email compliance@contentcomunica.com.br.
10. PENALTIES
10.1. Violations of this Policy may result in civil, criminal, administrative, and disciplinary penalties, including termination of employment or contracts.
10.2. Legal penalties include substantial fines, imprisonment, and the possible dissolution of the legal entity.
For full details, refer to the Anti-Corruption Policy available at: https://www.contentcomunica.com.br/policies
Director of Communication and Relations – Leslie Garcia
Responsible for establishing connections between CONTENT and its clients and suppliers, coordinating sectors, practices, and the delivery of communication services based on internal quality policies and socio-environmental objectives. Holds decision-making autonomy and is a member of the Executive Board.
Director of Purpose-Driven Strategies and Compliance – Julio Garcia
Responsible for the company's administrative, financial, and legal operations, ensuring strategic alignment with its purpose and socio-environmental objectives, expanding stakeholder relations, and overseeing pro-bono projects. Holds decision-making autonomy and is a member of the Executive Board.
Purpose-Driven Creative Coordination – Osmar Garcia
Responsible for coordinating the work of internal and outsourced teams in content creation, including but not limited to videos, texts, graphic design, websites, digital and print materials, scripts, and more. Holds executive autonomy and reports to the Director of Communication and Relations. The Purpose-Driven Creative team maintains creative autonomy, reporting to the sector’s coordination while adhering to socio-environmental objectives and the quality, timeliness, and efficiency standards expected in client deliverables.
Purpose-Driven Design Coordination – Position to be filled
Responsible for coordinating the work of internal and outsourced teams in content design, including but not limited to graphic design, websites, digital and print materials, documents, and more. Holds executive autonomy and reports to the Director of Communication and Relations. The Purpose-Driven Design team maintains creative autonomy, reporting to the sector’s coordination while adhering to socio-environmental objectives and the quality, timeliness, and efficiency standards expected in client deliverables.
Board of Directors
CONTENT maintains a Board of Directors composed of its partners, listed below, along with invited external members. The Board is responsible for safeguarding the company’s socio-environmental objectives, providing consultation when necessary, and holding a regular semi-annual meeting.
Board Members:
- Leslie Daniele S. Garcia
- Julio Cesar Garcia
- Osmar S. Garcia (external member)
Responsibilities of the Board of Directors:
- Guide corporate strategies, define strategic goals, and develop key action plans.
- Meet at least once every six months to plan, monitor decisions, and track company activities and objectives.
- Oversee the operations and decisions of the company’s directors and coordinators, providing feedback and recommendations.
- Make decisions unanimously, fostering consensus through discussions and debates that lead to a unified stance without forcing involuntary concessions, reinforcing the strength of integration and shared purpose.
Socio-Environmental Performance
CONTENT is committed to analyzing and evaluating socio-environmental performance in decision-making processes.
- We provide training for employees and collaborators on the company’s mission and purpose regarding relevant socio-environmental issues, particularly concerning the social, environmental, and ethical impact of our content, messages, designs, and client deliverables.
- Our managerial positions include the objective of ensuring that employees achieve excellence in socio-environmental performance within their roles and throughout the company. This requirement is explicitly outlined in job descriptions.
- We conduct periodic training sessions and internal activities to educate employees on socio-environmental topics relevant to the company’s mission and operations.
Stakeholder Engagement
CONTENT considers stakeholder inclusion and engagement a key part of its sustainable restructuring strategy, ensuring their involvement in shaping the expected outcomes of our actions and market presence.
- The company actively participates in industry and trade associations, representative bodies, and, notably, public campaigns and initiatives where our expertise can enhance purpose-driven communication.
- To strengthen connections with stakeholders, CONTENT organizes and participates in events where these groups are represented or directly engaged.
Monitoring Socio-Environmental Objectives
CONTENT employs key performance indicators to annually assess its socio-environmental objectives.
The following aspects are measured each year:
- The quantity and quality of events, meetings, and participatory engagements with stakeholders.
- The quantity and quality of campaigns and service deliveries that align with the company’s socio-environmental mission (positive impact of communication).
- Internal actions to reduce environmental impact and enhance positive contributions.
- Client and stakeholder survey results regarding the company’s impact on socio-environmental objectives.
- Reduction of ecological footprint, carbon emissions, and material usage in client service development.
CONTENT holds semi-annual strategic planning meetings, along with periodic operational decision-making sessions.
CONTENT's Commitment to Human Work and Social Equity
CONTENT values human labor as a fundamental condition for overcoming social inequalities and fulfilling individual life purposes, in alignment with human rights and fundamental freedoms.
Financial Benefits
- Financial benefits are calculated based on the local cost of living and adjusted in accordance with national inflation rates.
- All workers and collaborators, including external service providers, are treated equally and with respect for their differences.
- CONTENT strictly complies with labor laws in all locations where it operates, upholding the principles and rules outlined in its Code of Ethics and socio-environmental objectives.
New Employee Integration
CONTENT welcomes new employees by integrating them into the company’s culture, physical and digital workspaces, available resources, and team dynamics. This process includes meetings, presentations, and opportunities for interaction, fostering friendship and a collaborative work environment.
Employee Evaluations
CONTENT values merit and professional development, recognizing each employee’s progress within their sector and team while acknowledging their personal achievements in relation to their own growth.
- Once a year, each employee receives a self-assessment questionnaire to evaluate their performance, contributions to socio-environmental goals, and collaboration with colleagues.
- After reviewing the responses, the Operations Directorate and supervisors provide summarized feedback, highlighting strengths, recognizing achievements, and offering recommendations for improvement in critical areas.
- Annual individual and team goals are set, aligned with the strategic planning defined by the Board of Directors. These goals are designed to be achievable and clearly identifiable.
Policies and Values
CONTENT fosters a workplace environment based on respect, diversity, ethics, and efficiency, as outlined in its Code of Ethics. This includes established reporting mechanisms and disciplinary procedures to address harassment.
Work Schedules
- Work schedules are determined based on the nature of each role and the employee’s contractual agreement.
- In remote work arrangements or business partnerships (such as self-employed professionals, freelancers, and outsourced partners), work hours are self-managed. The primary performance metric in these cases is the quality and timely delivery of contracted results.
- For other employment arrangements, work hours will be specified in the respective contracts.
Performance-Based Compensation
Whenever feasible and applicable to the nature of the role, compensation will be linked to employee performance and delivered results, including contributions toward the company’s socio-environmental objectives.
Benefits, Training, and Leave Policies
- CONTENT promotes the personal and professional growth of its employees by offering internal training and opportunities for external development.
- Employees may request leave or financial support for external courses and training programs through the Operations Directorate. Requests will be reviewed individually, based on criteria such as relevance, timing, alignment with company objectives, workload compatibility, and existing commitments to clients.
Conflict Resolution
- Workplace conflicts within or involving CONTENT will be addressed through mediation and peaceful resolution, prioritizing open dialogue, transparency, and the right to a fair defense.
- Disputes will be mediated by the Compliance Directorate unless the department or its members are involved, in which case another directorate will assume the mediation role.
- The mediation process ensures all parties have a structured opportunity to express their perspectives, seeking ethical and effective resolutions that restore trust, loyalty, respect, and collaboration.
- Conflict cases will be managed in accordance with the rules and consequences outlined in the company’s Code of Ethics.
CONTENT upholds a chain of responsibility to ensure the positive impact of its actions, considering the entire lifecycle of products and services, reverse logistics, responsibility policies, and socio-environmental objectives. Supplier selection and qualification are based on these criteria.
CONTENT's suppliers must:
- Maintain compliance with all local laws and regulations, including those related to socio-environmental performance.
- Follow good governance practices, including policies on ethics and anti-corruption.
- Implement positive practices that go beyond regulatory requirements, in alignment with their industry and services.
- Hold third-party certifications related to social and/or environmental performance, with special emphasis on B Corporation certification.
- Adhere to the Company’s Code of Ethics and all other policies outlined on this website.
CONTENT is dedicated to providing transformative communication practices for its clients, ensuring high-quality service and customer satisfaction through the following commitments:
- Satisfaction Guarantee: Services are delivered according to client requests (briefing), with the option for contract termination at any time without penalty, provided a 30-day prior notice is given.
- Feedback Channels: Open communication channels are maintained to receive client feedback, service evaluations, and complaints.
- Customer Satisfaction Monitoring: Regular assessments and progress updates are shared with all stakeholders involved in decision-making or service outcomes.
- Performance Evaluation: Analysis of client results derived from our services, particularly in terms of reach, sales, impact, and the effectiveness of communication campaigns.
- Ethical Marketing and Engagement: Adherence to ethical marketing, advertising, and client engagement practices, as outlined in our Code of Ethics and related policies.
- Privacy and Data Security: A strong commitment to protecting client privacy and data security, in compliance with our Privacy Policy.
ÍNDICE DE POLÍTICAS