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CODE OF ETHICS

Ethics Policy 

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  • INTRODUCTION

    • This Code establishes the minimum expectations of Laconic, its subsidiaries, affiliates, the companies it controls, and related entities in all nation-states where Laconic operates, and in respect of the conduct of all their members and of everyone who works for Laconic.  Ethics and transparency are essential values in our business and are fundamental to our reputation and success.  All your attitudes and actions, as long as you are a professional working for Laconic, must be guided by these principles.  Always putting the customer first, operational and strategic excellence, and innovation are equal values that we seek in our daily routine. 

    • Laconic takes the standards of this Code very seriously. You must conduct Laconic’s business in full compliance with our values, the spirit and the letter of the law, the standards applying to our activities, and the rules detailed herein. 

    • Every professional, whether an employee, manager, partner, officer, trainee, intern (“Employee”) or consultant, supplier or temporary staff member or anyone providing services to Laconic in any situation, is responsible for reading the provisions of this Code carefully, understanding them and observing them. 

    • Similarly, it is the responsibility of every professional to seek clarification of any doubts from the proper channels (your manager, Director of Security, or Chief Financial Officer, depending on the subject), especially because this document does not pretend to be exhaustive. We expect doubts to arise, and we expect you to seek to clarify them. 

    • When you have a doubt or a query about any situation in your daily routine, always: (i) ask yourself, before you act, if this is the best way to proceed; (ii) ensure that you have all the facts and that you are properly and correctly informed. Trust your judgment and common sense, and always consult your supervisor and talk about your questions or misgivings.  

    • You can also seek help from the Director of Security or Chief Financial Officer.  Laconic is always seeking to achieve excellence in everything we do and in all our businesses. Achieving this objective is only possible if people understand how important it is for everyone to observe the rules of this Code. 

    • Laconic is an entrepreneurial institution. It is persistent and resilient, with its feet on the ground, anticipating trends and making the changes necessary to track them. Our team consists of professionals who bear this entrepreneurial spirit, and who know how to transform ideas into real business opportunities. 

    • Our actions are focused on our aim of being the best sustainable development corporation, performing consistently within the top quartile of the market in all the areas where we operate. 

  • OUR WAY OF BEING

    • For Laconic, it is not just performance that counts. The way we achieve it matters to us, and we see the way we work as a differential that helps us keep the best team of professionals, build long-term relationships with our clients, expand to other countries and attract investments and partners that will provide us with better returns. 

    • The pillars of Our Way of Being are: 

    • Ethics 

    • Alignment with our Customers’ Objectives 

    • Associative and Complementary Action 

    • (Being) United in our Purpose 

    • A Disciplined, Painstaking, and “Hands-on” Team 

    • An Internal Climate Favorable to Performance 

  • ETHICS 

    • Ethics is “doing the right thing”. We do not accept opportunities that are not in line with the precepts of business ethics. We do not believe in shortcuts or in taking the easy path. We prefer to miss an opportunity if we see that it does not meet our ethical precepts. We want to enter and leave by the front door. ​

  • ALIGNMENT WITH OUR CUSTOMERS’ OBJECTIVES 

    • We seek to understand our customers’ objectives, aligning our efforts and our interests so that these objectives are consistently achieved. 

  • ASSOCIATIVE AND COMPLEMENTARY ACTION 

    • We know how to be partners. We try to surround ourselves with professionals and entrepreneurs with similar characters and a wide range of talents. We truly believe that it is better to work together than individually, that the other person has always got something to contribute. This is why we always seek to make alliances based on shared values, mutual respect, alignment of aims, and complementary skills, and we work always in the best interests of Laconic, both in our endeavors and within the company. 

  • UNITED IN OUR PURPOSE 

    • There is a bigger purpose behind each of our endeavors, We take care to create quality assets that bring real benefits to people, communities, and the market from which they benefit. We celebrate when our undertakings achieve their aims. 

  • A DISCIPLINED, PAINSTAKING, AND “HANDS-ON” TEAM

    •  We are disciplined when analyzing an opportunity. We are painstaking in the decisions we make, and we are “hands-on” when managing our projects – in the areas of creating value, managing risk, and sticking to our standards of security and governance. In everything that we do, our professionals apply the experience they have gained to the benefit of our endeavors; and in the process, they also acquire knowledge and seek to enhance their performance. 

  • AN INTERNAL CLIMATE FAVORABLE TO PERFORMANCE 

    • We seek and we expect a high level of performance from our team – and to this end, we promote an internal climate that is one of harmony, trust, and cooperation; that is not hierarchical, and where accountability is clear and well defined. We believe that the right climate provides opportunities for doing business. Everyone can enjoy this climate, and it creates the conditions for each to attain their potential in their own way because each has something special to contribute. 

  • PEOPLE SUBJECT TO THIS CODE

    • This Code applies to all Employees and professionals who work in or for Laconic, irrespective of their basis of employment. Suppliers, consultants, temporary staff, interns, trainees, and any other service providers are therefore also subject to the rules of the Code. 

  • RESPECT FOR OUR CUSTOMERS

    • Laconic is fully committed to attaining the objectives of its customers. We work in good faith, transparently, diligently, and loyally for our customers and commercial partners. 

  • APPLICABLE LAW

    • We do business in strict accordance with all applicable laws. 

  • KNOWING YOUR CUSTOMER (KYC) AND ANTI-MONEY LAUNDERING (AML)

    • Owing to our global footprint, we are subject to many rules and regulations dealing with KYC, i.e., the identification of and knowledge about investors and customers, particularly to prevent money laundering. 

    • Laconic will always take all the necessary measures, whether reporting to the regulatory bodies and authorities or applying internal sanctions, in cases where there is any suspicion of money laundering. 

  • SOCIETY 

    • Corruption and bribery 

    • We believe in carrying out our business ethically and responsibly. We know that corruption in the corporate world does immense harm to society. Corruption undermines the basic pillars on which companies do business in a free market, compromising the criteria for selecting the best price, quality, and necessity for service. 

    • Laconic will not accept any corrupt practices or bribery on the part of its professionals, suppliers, or customers. We have a “zero-tolerance” policy in respect of any act or omission that could lead to violation of the provisions of the rules contained in laws such as the Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act (UKBA). 

    • Corruption is offering, promising, giving, or receiving, directly or indirectly, something to or from anyone, to influence a decision to obtain an undue advantage. A simple promise, without actually delivering the “something”, is also considered to be an act of corruption. 

    • The thing offered, received, or promised is not limited to cash. It can also be any benefit or favor, including the payment of expenses, the offer of gifts, travel, entertainment, and so on. 

    • By undue advantage, we mean any event, whether or not it has financial value, which would not have occurred but for the promise or offer of “something” or “some commodity”. The execution of an agreement or the waiver of a penalty are examples of “undue advantage”, as is access to confidential or privileged information. 

    • Laconic instructs its Employees to cooperate, in the form and to the limit of the law, with investigations or inspections carried out by public bodies, entities, or agents. Actions that might hinder these activities are not allowed and must be immediately reported to Security. 

    • The above actions must not be undertaken by any Employee or a third party acting in the name of or in the service of Laconic concerning any Public Agent (defined below), domestic or foreign, or to any of their family members. 

    • This Code expressly prohibits any act that might harm the Public Administration (defined below) such as the financing of, payment for, sponsorship of, or any support for the practice of acts described as illicit, or using the name of any other individual or legal entity for corrupt purposes. 

    • By Public Agent, we mean a person who, whether or not permanently and whether or not for compensation, is elected, appointed, designated, or engaged by or who in any other way acts for the Public Administration or their spouse, companion or stepchild. 

    • The concept of Public Agent, whether or not the position is considered “material” to define a Politically Exposed Person (“PEP”), includes: 

    • Mayors, governors, deputies, aldermen, political candidates, and staff of the legislative, executive, and judicial branches; 

    • The staff of supervisory bodies, such as the tax authorities, labor offices, municipal councils, and district councils; 

    • Agents of public concessionaires or companies

    • The staff of the Central Bank, the Securities Commission, consulates, and notaries’ offices; 

    • Members of the Armed Forces (including military police) and civil police; 

    • Officials or staff of political parties; and 

    • Service providers working in public bodies (outsourced). 

    • Public Administration is any body or entity managing or executing public services, at the federal, state, or municipal level. These include government agencies, companies or foundations, mixed-economy companies, and other entities controlled, directly or indirectly, by a national government, states, or municipalities. They also include sovereign funds, closed supplementary pension entities, and special social welfare regimes of any government entity. 

    • Foreign public administrations are taken to be state bodies and entities or foreign diplomatic missions, at any level or sphere of government and legal entities controlled directly or indirectly by the Public Administration of a foreign country. Foreign Public Administration includes international public organizations. 

    • A foreign Public Agent is someone who, even temporarily or without compensation, holds a position, employment, or public function in state bodies or entities in foreign diplomatic missions or legal entities controlled directly or indirectly by the government of a foreign country or in an international public organization. 

  • SUSTAINABILITY

    • Laconic is determined to comply with the laws governing environmental issues. Furthermore, Laconic cares for sustainable development and therefore expects its suppliers and the companies it invests in to always observe the applicable environmental legislation. 

    • Working conditions 

    • The values of Laconic are incompatible with activities that might in any way be regarded as child labor or labor analogous to slavery. Our employees, suppliers and the companies we invest in must always take the appropriate measures, as far as possible, to avoid any engagement of labor of this sort, whether direct or indirect. 

    • Respect for the law and paying tax. Prohibition of capital flight and tax evasion 

    • Laconic complies with all the laws applicable to its activities and pays all the taxes required by law. Ignorance of the law is not accepted as a defense in the courts. And so if you have any doubts about whether or not to apply any law, resolution, ordinance, or instruction, seek advice. 

    • Laconic does not permit any action that could represent or give rise to a suspicion of transferring capital out of a country when such a practice is prohibited or is in violation of the law. Similarly, we do not permit any type of consultancy or assistance aimed at concealing, misstating, or otherwise amending information supplied to or requested by public authorities. 

    • Clearing Up Doubts, Approving Exceptions, and Whistleblowing 

    • Doubts

      • If you have doubts about any rule or how to apply a rule in a specific situation, check with your supervisor, Director of Security, or Chief Financial Officer. 

      • Approving exceptions

      • Any exception to or waiver of the application of the rules of this Code requires the prior approval of the CEO. 

    • Obligation to report violations 

    • The violation of any rule of this Code or any Laconic policy, law, ordinance, or regulation, the practice of fraud, including by third parties, or dishonesty on the part of any Employee, must immediately be reported to the Director of Security or Chief Financial Officer.

    • Cases of harassment or intimidation must be reported to your supervisor, Director of Security, or Chief Financial Officer. 

    • The identity of whistleblowers will remain confidential unless, by law or court order, this information must be disclosed. 

    • Laconic does not allow any form of reprisal for good-faith whistleblowing by its employees or third parties. 

  • CONSEQUENCES OF THE VIOLATION OF RULES, POLICIES, AND CURRENT REGULATIONS (SANCTIONS)

    • The violation of any of the provisions of this Code, law, or ordinance related to our activities, or failure to cooperate with an internal investigation, may result in disciplinary measures, including, without limitation, a verbal or written warning, suspension, or dismissal. 

    • The application of internal disciplinary measures does not preclude the application of the appropriate legal remedies to repair any damage to Laconic or its customers, who may claim reimbursement, including monetary reimbursement, if applicable.

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