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BRMALLS maintains operations in various states, and in order to hold our company together, our employees must act based on common values and goals. This can be seen in the daily attitudes assumed by people who are part of the BRMALLS team and who undertake a term of commitment with the standards set forth in our Code of Business Conduct.
We value respectful, responsible, and trustworthy relationships with various internal and external stakeholders, and we observe a no-tolerance policy for the following:
Preference, favoring, prejudice, or discrimination in virtue of ethnicity, color, nationality, religion, sex, age, marital status, sexual orientation, special needs, or social status. Abusive attitudes (gestural, verbal, or behavioral) toward the moral or physical integrity of any person, including sexual harassment, moral harassment, intimidation, and threats, are not tolerated.
Transparency, ease of access to higher positions, a result-oriented focus, and continuous communication allow for an open and pleasant work environment which makes room for healthy competition and opportunities for the professional development of our employees.
We are owners of the business, and, as owners, we are proud of our Company and of our people. Our actions reflect our image, and therefore we stress responsible behavior, requiring employees to take sensible and mature action for matters that may influence the performance of our duties and our professional conduct.
Our leaders/managers play an important role in the development of our people. Their behavior must be seen as exemplary and their actions must match their words.
We treat our employees respectfully, regardless of their positions or how long they have worked at the Company.
It is everyones duty to:
- Respect the laws, policies, and internal regulations in force.
- Care for the Company¿s property through the proper use assets and resources in order to avoid damage, inadequate handling, loss, theft, or unauthorized use.
- Take responsibly for the use of the Companys system, which includes:
- using licensed applications;
- accessing permitted websites only; and
- abstaining from exchanging messages that contain improper, racist, or discriminatory content, as well as pornographic images and texts which may offend others.
- Understand that the Company has a neutral position regarding political and religious matters, and to not take part in any religious, political, and/or candidate campaign using any of the Companys resources.
- Only disclose or share confidential information¹ with other employees or third-parties that so require in order to perform their activities in the Company, regardless of the means of transmission, whether on paper, electronically, or orally.
- This rule prevails even after the expiration of the work/service agreement;
- One must pay attention and have prudence when meeting in public places (restaurants, airports, elevators, cafés, etc.);
- In the event of doubts regarding information confidentiality, employees are advised to enquire with their manager.
1 - Information that has not yet been made public, business strategies, new business prospecting, payroll tables, contracts and leasing contracts, etc.
- Not use privileged information in the acquisition of shares directly or through third parties.
- Not consume alcohol during work hours, or be under the effects thereof.
- Be aware and behave responsibly in situations that may lead to addiction (excessive consumption of alcohol and illegal drugs, medication, and gambling) and harm the performance of their activities, as well as their lives and the work environment.
- Be aware that the use or carrying of illegal drugs may be deemed a crime.
Conflict of Interest
Some situations may suggest or result in conflict between our personal interests and those of the Company or of other stakeholders. We must be alert to avoid and/or deal with these situations impartially, with the Companys interests in mind.
We must act transparently in such situations in order to avoid jeopardizing our reputation. Therefore, employees must:
- Refrain from taking advantage of their position in the Company to obtain favors and/or benefits²
- Refrain from maintaining own businesses or activities that drive focus and efforts away from their duties at the Company.
- Report the following situations, by e-mail, to the Ethics Committee for analysis and authorization:
- Any parallel activity that influences or that may influence upon the employees performance or duties;
- Any case in which the employee is a majority shareholder of a business, regardless of their participation in the management/operation;
- Any case in which the employee is a partner in shopping mall stores.
2 - This item does not include agreements executed by the Company for discounts to employees, such as: schools, gyms, standardized discounts for all employees and managers of shopping malls.
- Declare themselves impeded or refrain from participating in, as well as refrain from influencing, any decision within the following situations:
- The hiring of suppliers and employees, referred or not, with whom they hold a personal relation;
- The process of negotiation by companies belonging to family members (parents, siblings, spouse, or children) who are or may become clients of the Company.
- Not hire first-relation family members of our employees: father, mother, children, spouse.
- Not assume a managing/subordinate relation between employees who are related or romantically involved³.
- It is advisable for employees with such involvement (see directly above) to refrain from working in the same area. These situations must be reported to the area manager/director for analysis and resolution.
3 - Boyfriend/girlfriend, siblings..
Free Goods, Favors, Gifts, and Entertainment
We must eliminate any situation that may interfere in our decisions or cause any sort of discredit in the person or company due to the receipt of courtesies, free goods, gifts, gratification, discounts in personal transactions, trips, or invitations for events from customers, partners, or suppliers. Thus, it is our responsibility to:
- Refrain from accepting or offering, either directly or indirectly, personal favors, money, or gifts that may affect decisions, facilitate business, or benefit third parties.
- Avoid awkward situations regarding the receipt of free goods/gifts, the employee being authorized to receive, only and exclusively, promotional gifts without commercial value, such as general stationary, t-shirts, and similar objects, in addition to samples of gifts developed for shopping mall campaigns or other projects valued under R$100.00, such as chocolate, books, etc.
- Forward any and all free good/gift (including invitations to concerts, shows, etc.) that differs from the above mentioned to the area responsible4 for the realization of a ballot among all employees or for charitable donation.
4 - Headquarters: People and Management and Shopping: Administrative/Financial sectors
- Participation in events sponsored or promoted by third parties is conditioned to the approval of the formal manager by e-mail. When there is travel and a hotel involved, approval must be obtained from the area manager/director.
- Expenses with customers, entrepreneurs, and shareholders, such as meals, transportation, and accommodations, may only be made in the case of events related to the Companys activities and by personnel authorized by the Management.
- Business-related meals must take place during working hours, preferably during lunch at our shopping malls. Dinners are discouraged.
- Lunches with suppliers during the phase of negotiation/hiring are discouraged, and therefore expenses must be incurred by the parties.
Relationship with Shareholders and Capital Markets
- We conduct our businesses with a view to comply with the interests of our shareholders and investors.
- We have a policy for the disclosure of information5 in accordance with market rules and with the Brazilian Securities and Exchange Commission (CVM):
- Our shareholders and investors are informed, immediately, via the adequate channels, of major actions or decisions.
- We stress the compliance and fulfillment of this policy to our employees, particularly for the following:
- Periods during which share trading is restricted;
- Employees should not benefit from privileged information in the sale or purchase of shares, directly or through third parties;
- The improper use of such information is illegal and may result in administrative, civil, and criminal penalties.
5 - The full policy may be found on BRMALLSs website (www.brmalls.com.br )
Relationships with Partners
- We consider our entrepreneurs to be our partners and our relationship is guided by non-biased and transparent behavior in compliance with the Company¿s Corporate Governance Manual.
- As we respect the confidentiality of information and establish relationships free of favor, we expect the same from our partners.
Relationships with Customers
- We provide our customers with pleasant and safe shopping malls.
- We pursue customer satisfaction through a varied mix of stores, services, and leisure.
Relationships with the Community and the Environment
We respect the environment and the communities located in the vicinity of our operations. In view of this, we adopt environmental management practices and charitable campaigns. Details may be found on our website.
Relationships with Store Owners (Lessees)
- We treat store owners respectfully and impartially.
- We arrange meetings for the exchange of good commercial practices among our lessees and condominium managers.
- We have an open door policy; our lessees have direct access to the shopping mall management.
- We emphasize that we discourage the receipt or offer of free goods other than those described on page 13 herein, and we count on the commitment of our lessees in complying with this rule.
- We stress that using the Company¿s position to obtain personal benefits with store owners is not permited6.
6 - This item does not include agreements executed by the Company for discounts to employees, such as: schools, gyms, standardized discounts for all employees and managers of the shopping malls.
Relationships with Suppliers
We try to ensure non-biased and good relationships with our suppliers:
- The selection and hiring of suppliers is held based on technical, professional, and ethical criteria.
- All suppliers have access to the same information base during the quotation and purchase process.
- We require the following from our suppliers:
- Competence, compliance with the applicable laws7, and the non-use of child or slave labor; and
- Confidentiality and secrecy regarding Company or customer data and information to which they may have access by any means or form..
- We emphasize that we discourage the receipt or offer of free goods other than those described on page 13 herein, as well as lunch with suppliers during the negotiation phase, and we count on the commitment of our suppliers in complying with this rule.
- We expect, from all our suppliers, the adequate orientation of their employees in performing their activities within the Company¿s facilities, in relation to the provisions in this code and the compliance therewith.
7 ¿ Labor, pension, tax, and other laws applicable to its business.
Relationship with the Media
- Everyone must care for the Company¿s image.
- Only the CEO and employees designated thereby are authorized to speak on the behalf of the Company.
- Information requests from any vehicle of communication, for the headquarters or for the shopping malls, must be directed to our Press Relations area.
Relationships with Competitors
We maintain a professional relationship with our competitors and we do not seek to improperly obtain commercial secrets or confidential information from our competitors.
The application of the Codes guidelines and the maintenance of an environment with the highest standards of ethical conduct is a commitment of all employees.
- Eventual doubts on how to act in a particular situation must be cleared with the respective managers.
- For situations of non-compliance with this Code, the available channel is:
Reports may be anonymous, to whomever wishes to do so; however, we highlight the need for consistency and truth in the information reported.
- We have an Ethics Committee composed of Executive Officers at the headquarters who are responsible for the Legal, People, and Management departments. Their main duties are as follows:
- Analysis of situations not provided for in the Code and definition of procedures;
- Assessment of situations of non-compliance with the Code and resolutions on the measures to be taken; and
- Revision and updating of the Code of Ethics.