The Code of Ethics constitutes the standard according to which all employees work. The code applies to an equal degree to all employees of Brazil Property Mart regardless of their position in the hierarchy and includes the management.

Transparency
The primary basis for our efforts to compete fairly and openly is the creation of transparency and the internal documentation of all our decisions. In this way we create internal and external trust in Brazil Property Mart

Confidence in customers and business partners
Our conduct in dealings with business partners, customers and public authorities must be entirely commensurate with our ethical standards. We must be fair, trustworthy, and transparent in all areas including those with a wide margin for interpretation. We must treat all matters with the discretion which we owe our business partners and customers. We will not reveal information given to us in confidence to any party. We will not discuss client matters with others than those that need to be informed professionally.

Dealings with officials and government representatives
In dealings with representatives of the government and public authorities, we undertake to avoid all acts which could unlawfully influence their decisions. In particular we must refrain from offering officials gifts of money or other favors or benefits, even when such procedures could not benefit our financial interests. We may support or hire governmental officials for promoting our business or to lobby for our interests. In those cases we will be fully transparent on our dealings.

Bribery and Corruption
Brazil Property Mart supports international efforts to fight bribery and corruption. This means that we oppose attempts at bribery and corruption, both with regard to the work of both our business partners and our own employees and colleagues. We must carry on our business correctly, efficiently and in observance of the law and work consistently on improving.
Respecting employees, business partners and competitors
We respect all people regardless of their age or sex, their constitution, nationality, race, religion or sexual preference. We equally respect their dignity, their rights and their private lives.

We expect that our employees treat customers, business partners and competitors with respect and do not discriminate against them. In return we expect the same respectful treatment of our employees by others. We do not tolerate discrimination or harassment of our employees.

Social conditions and fair payment
Brazil Property Mart respects the International Labor Organization constitutes on employee safety and health. We will ensure our employees will be able to perform their work within those boundaries. Also third parties employed directly by us will need to be provided adequate working environment and protection.

We will pay our staff at least the minimum wages as decided by the Brazilian government. We will pay our professional staff basic wages above minimum and enable them by performance based payment to reach over market conforming wages.

Reporting
We expect our employees to precisely describe all incidents and the reasons for any suspicions in connection with conflicts of interests, corruption, money laundering or violations of foreign exchange regulations. We also expect that insider information and compliance-relevant facts will be reported to the Compliance Controller. We will not tolerate any negligence, forgetfulness or loss of files as justification for violations. In particular, we must document suspicious facts or circumstances and indications of any such illegal acts. Such suspicious circumstances must always be reported to the respective supervisor.

Complience with Code off conduct
At least once per year the compliance of this ethical code will be discussed in a meeting involving all employees. Our business partners will be informed on our Code of Conduct and in case of major contracts this code of ethics will be incorporated in the contract conditions.