- Fundamental Values and Principles
- Integrity and Compliance
We act with ethics, integrity, loyalty, and good faith in all professional and institutional relations, strictly complying with laws, regulations, and our internal policies.
- Professional Confidentiality
We respect and protect the confidentiality of all client information, safeguarding professional secrecy as an inalienable value essential to trust and the practice of law.
- Diversity, Inclusion, and Equity
We value and promote a plural environment, respecting all differences, combating any form of discrimination, and ensuring fair and equitable opportunities for all members of the firm.
- Data Protection and Privacy
We are committed to protecting personal and corporate data under our responsibility, following best practices and applicable data protection laws, especially the General Data Protection Law (LGPD – Law No. 13.709/2018).
Our practices include: processing data for legitimate and transparent purposes; guaranteeing data subjects’ rights such as access, correction, deletion, and anonymization; adopting technical and administrative measures to prevent unauthorized access and leaks; and providing continuous training to keep everyone updated on legal obligations and internal policies.
- Conflicts of Interest
We adopt strict practices to identify, prevent, and manage conflicts of interest, ensuring that our conduct aligns with the Brazilian Bar Association’s (OAB) Code of Ethics and Discipline and the Advocacy Statute, and that our decisions are not unduly influenced by conflicts of interest.
- Ethics Channel
The firm provides an ethics channel (email: etica@cmga.adv.br), through which our members and third parties can clarify questions about our Code of Ethics and its practical application, obtain guidance on how to best address issues related to ethics or compliance with laws and regulations, share concerns, or report any suspected or actual violations of this Code of Ethics or applicable law to the firm’s leadership.
All communications received through the Ethics Channel or addressed directly to any partner of CMGA will be forwarded to the Compliance Committee, composed of the three founding partners of the firm, who will assess, investigate, and take corrective or disciplinary measures as appropriate.
The Compliance Committee will take all necessary measures to ensure confidentiality, protection, and non-retaliation for users of the Ethics Channel. Users may also choose to remain anonymous.
When reporting through the Ethics Channel, users are requested to provide, to the extent possible, all information they know or have heard of, including what happened, when, where, who was involved or aware of the case, and any supporting details or documents. This information is essential for the Compliance Committee’s investigation.
- Social Responsibility and Sustainability
We encourage responsible and sustainable practices, committing to the promotion of a healthy, inclusive, and socially beneficial work environment. - Prevention of Unlawful Acts
We reaffirm our commitment to not tolerate any involvement in unlawful practices such as corruption, fraud, forced labor, or other conduct contrary to law and ethics. - Updating and Training
We commit to periodically reviewing and updating this Code, as well as promoting continuous training to ensure full knowledge and application among all members of the firm.
- Policies:
- Anti-Corruption Policy
The firm upholds a zero-tolerance policy toward corruption, bribery, and illicit practices. We are committed to full compliance with applicable laws, ensuring that no undue advantage is offered, promised, or received in any context.
We expect all members to:
- Reject and do not participate in any form of corruption or bribery.
- Assess risks in engaging third parties and partners, adopting due diligence to prevent unlawful practices.
- Immediately report any suspicion or occurrence of illicit acts to the Compliance area.
- Know and follow internal anti-corruption policies and report violations through the security channel.
This commitment reflects our ethical and legal responsibility, ensuring transparency and integrity in all relations.
- Gifts, Hospitality, and Entertainment Policy
The firm enforces a policy on offering or receiving gifts, hospitality, or entertainment in compliance with applicable laws, counterparties’ policies, and in a manner that prevents real, potential, or perceived conflicts of interest.
Occasional receipt or offering of gifts or hospitality may, depending on context, represent a legitimate contribution to sound business relationships. However, it may also create the appearance of undue influence or a conflict of interest.
Our members must always evaluate the context and applicable rules, especially those of the recipient’s organization, before requesting, accepting, offering, or granting gifts, hospitality, or sponsorships.
In case of doubt, members must consult a founding partner or the Compliance Committee via etica@cmga.adv.br.
- Accounting and Financial Records Policy
The firm maintains accounting and financial records in full compliance with laws, generally accepting accounting principles, and applicable policies.
We commit to keeping complete and accurate financial statements and accounting records that faithfully reflect the firm’s operations and its financial position and results.
The integrity of our accounts depends on accurate, complete, and timely entries. Therefore, we expect our members to document and ensure the full and precise recording of all financial transactions in which they are involved.
- Third-Party Due Diligence and Hiring Policy
Our policy requires that the hiring of third parties and employees be preceded by a due diligence process, including verification of qualifications, background, reputation, and legal compliance of candidates or business partners. This analysis ensures that only individuals and companies aligned with the firm’s ethical values and legal requirements join our value chain and workforce.
For suppliers and service providers, it is essential to assess aspects such as financial integrity, absence of involvement in unlawful practices, compliance with labor and environmental laws, respect for human rights, and cultural alignment with the firm.
The responsible partner must always seek to identify potential risks that could compromise the firm’s integrity, security, or reputation, establish clear monitoring mechanisms, and include termination clauses in contracts in case of noncompliance by the counterparty.
- Anti-Money Laundering Policy
The firm adopts a strict anti-money laundering policy, in compliance with applicable law, particularly Law No. 9.613/1998 and its amendments, while considering the specific nature of legal practice, to prevent illicit funds from being integrated into the financial system through the firm’s services.
All members must remain vigilant and committed to identifying and reporting suspicious transactions, ensuring the integrity and transparency of the firm’s activities.
We encourage members to report any indication or suspicion of money laundering to the Ethics Channel.
- Donations and Sponsorships Policy
The firm adopts a transparent and ethical approach to donations and sponsorships, ensuring that such actions align with institutional values and are exclusively intended to promote legitimate social, cultural, educational, or environmental causes, without any expectation of quid pro quo or direct commercial benefit. All donations and sponsorships must be approved in advance by at least one founding partner, ensuring compliance with internal policies and applicable law.
It is strictly prohibited to use donations or sponsorships to influence decisions, obtain undue advantages, or favor personal or corporate interests. The firm commits to maintaining detailed records of all contributions, ensuring transparency and accountability to both internal and external stakeholders.
Members must report to a founding partner or the Ethics Channel any donation or sponsorship proposal that could generate conflicts of interest or compromise the firm’s reputation.
