Download Code of Ethics


ISA Group and its companies advance to increasingly demanding and ambitious goals, developing its practices in different and innovative contexts that require firming and supporting its decisions on the most solid set of values. At this stage the Ethics is recognized as the value that defines the global nature of the organization, generates confidence to all stakeholders and identifies itself as the intrinsic feature of its officers, administrators and employees.

Since its creation, ISA Capital has maintained its identity in ethical principles based on adoption of honest, constructive, reputable and socially responsible conducts that promote business continuity.

To fulfill its mission, ISA Capital maintains relationships with its stakeholders (shareholders and investors, employees, suppliers, customers, society and State) based on its values, policies and commitments, thereby strengthening corporate identity and institutional coherence.

Seeking to improve the relationship with these stakeholders, ISA Capital advances in the way of transparency and corporate governance, when launching its Code of Ethics, which seeks to materialize the philosophy and corporate values of the organization by guiding criteria for performance of all employees and members of the Board of Directors.


ISA Capital works in building an organizational culture where values are the pillars that support the organization's results.

Corporate values defined promote trust and credibility and guide its conduct and the way it wants to be recognized.

They are:

  • Ethics
  • Social Responsibility
  • Excellence
  • Innovation

Corporate values are accompanied by attributes that support, strengthen and sustain the actions related to ethics and facilitate compliance and experience in the organization.


Acting reliably, accessibly, clearly and honestly.

Respect for the dignity of others with whom the company relates, in an environment of mutual recognition of rights and obligations of the parties involved.

Commitment to perform the promises and meet the parameters, policies and standards of the organization.

Recognition that the difference between people contributes to an environment of respect and enriches the organization in places and cultures where it operates.

Duty of employees fulfilling their responsibilities to achieve the mission objectives of the organization. Implies accomplishing, with care and dedication, works and duties that are proposed in the company.


ISA Capital understands Ethics as a set of principles that guide the actions of its employees, allowing consistency between its statements, decision making and relationship with stakeholders, inspiring the fulfillment of business objectives, transparency and the common good.


The Code of Ethics is a reference document, developed with the goal of presenting as ISA Capital's employees must act in relationships with stakeholders, since directs general criteria of action and decision in accordance with the corporate values. Thus, it is essential that stakeholders know their rules of behavior, as they will impact on relationships between the parties.


Equal Treatment
Every shareholder and investor, regardless of the value of their investment or the number of shares they represent, will receive the same treatment, ensuring the exercise of their rights to submit questions, requests or positioning.

ISA Capital counts on good governance practices aiming at the development of better management processes, oriented both to the generation of value of investments and the business ethical integrity.

Disclosure of Information
Make good governance practices is ISA Capital's commitment to add value to the business. Thus, it keeps the market informed about its performance and makes proper accountability appropriately and transparently. Information disclosed should not affect the rights of third parties, or pose risks to investments or business continuity.


Relationships based on Equal Treatment
ISA Capital promotes, equally, access to employment and adequate working conditions.

Discriminatory treatments on the basis of gender, race, color, nationality, social origin, age, marital status, sexual orientation, ideology, political opinion, religion or any other personal, physical or social condition are not tolerated.

Working Conditions
ISA Capital promotes an organizational climate based on respect and offers to its employees an environment in which the risks that threaten their health and safety are properly managed and are known to each employee. Moreover, it promotes balance between work responsibilities and personal and family life of its employees.

Harassment intolerance
ISA Capital promotes a work environment where manifestations of violence, physical, sexual, psychological, moral or any other kind of harassment are not accepted, as well as does not tolerate abuse of authority at work or other conduct that generates a climate of intimidation or offense to the personal rights of its employees.

Information Protection
In ISA Capital, is respected, maintained and adequately protected the privacy of employees, as well as the personal data needed to fulfill the law. Likewise, employees are responsible for not disclosing confidential or strategic information they have access because of their positions.

Right to Association
ISA Capital recognizes the right of free association of its employees to unions or similar entities, respects their participation in any type of collective bargaining and does not practice any type of discrimination against employees linked to these institutions.

Intolerance to Fraud
ISA Capital does not accept any type of fraud committed by its employees.

Use of Company Assets
ISA Capital offers to its employees the resources and means necessary to accomplish work activities according to each function.

Employees agree to use goods, facilities and resources of the company to fulfill their professional goal, avoiding any direct or indirect use to its benefit or of third parties, or serving to provide actions that may cause loss to the company.

These commitments also include:

  • Protecting and caring of the assets of which the company has or has access to
  • Protecting computer systems, exacerbating its safety measures.
  • Rationally using natural resources and protecting the environment.

Conflict of interest
A conflict of interest is when occurs an action that does not consider the legal, contractual, statutory or ethical duties of the employee and presents itself when personal interest is directly or indirectly opposed to the company.

Conflict of interest materializes when, by reason of his duties, the employee, when making a decision, performs or omits an action, chooses between his personal interest and of his company, customer or supplier, generating with his decision, action or omission, an undue benefit that he would not receive otherwise.

It is also understood as personal interest when the conflict will benefit a person with whom the individual is linked. Therefore, no employee will participate in contracts or negotiations where there is a conflict of interest or when in the negotiation participate people within the fourth degree of kinship, second degree by affinity and first civil degree, and, for the last two, are considered father-in-law, mother-in-law, brother-in-law, sister-in-law, spouse and adoptive children.

Faced the conflicts of interest, the performance of ISA Capital's employees must be based on the following:

Acting at all times with loyalty to ISA Capital and its shareholders, regardless of its own or other interests.

Refraining from intervening or influencing decisions that may affect the company, people or entities with which there is conflict.

Not having access or disclosing information deemed confidential that may affect the conflict of interest.

Informing its immediate superior of a situation of conflict of interests faced by means of a written document.


Fairness in Relationships
In ISA Capital fair and respectful relationships with customers are promoted, based on the recognition of their rights and needs.

Management of Information
The services provided by ISA Capital are conducted honestly and transparently, thus avoiding transmitting misleading information in terms of contracts and in corporate communications.

ISA Capital is committed to maintaining clear, transparent and balanced communication with its customers.

ISA Capital seeks confidentiality of information of its customers, undertaking not to disclose it to third parties except with the consent of the customer or due to legal obligation.

Service Provision
ISA Capital undertakes to ensure and maintain standards of quality in its services. Besides, it also provides its customers with channels and mechanisms of relationship that allow them to present their needs and perceptions of the services provided.


Just and Independent Relationships
ISA Capital maintains relationships with suppliers based on respect, equality and mutual transparency, avoiding any kind of fraudulent treatment.

Thus, it encourages its suppliers to meet and share their ethical principles, requiring from its suppliers and their value chain a performance based on laws in force and promoting compliance with environmental standards, respect for human rights and socially responsible practices.

Gifts and Favors
As a general rule, ISA Capital's employees may not accept gifts, favors, courses or invitations from customers, competitors or suppliers of goods and services, including personal financial services, resulting from functional relationship and that may affect decisions, facilitate business or benefit third parties.

The following are not included in this prohibition:

  • Objects of small value, with promotional gifts, which have no commercial value or correspond to common business events in times of Christmas and anniversary of the Company.
  • Invitations to technical qualifications, where ISA Capital covers expenses of travel and/or accommodation needed.

For questions about exceptions to these situations, please contact the Ethics Line.

Treatment of Information
ISA Capital's employees provide necessary information to suppliers for hiring relationships, in an egalitarian manner. And they undertake to keep confidentiality of any information of supplier, except under court order or legal determination, including information relating to its business or market methods and strategies, costs, and financial information, as well as any other documents deemed confidential by the supplier.

Excluded from these conditions is public information or that is included in the supplier evaluation reports submitted as part of its selection process


Compliance with Laws, Rules and Regulations
ISA Capital complies with all laws, rules and regulations in force in the regions where it operates, respecting the legal instances.

Relationship of Cooperation and Transparency
ISA Capital maintains with the authorities, regulatory agencies and other state institutions relationships based on the principles of cooperation and transparency.

Intolerance to Corruption
ISA Capital does not accept that its employees perform practices that could be construed as corruption. Accordingly, under any circumstances, it does not allow its employees to promote any form of payment or benefits to persuade a public or private third party to make a decision that meets the company or an employee, or that expedites a routine administrative action.

Information and Relationship with the State
ISA Capital has, with local, regional and national public authorities, stable channels of communication to answer to formal requests for information. Moreover, it accounts for to these institutions, when appropriate

Before the public authorities, ISA Capital represents its legitimate interests and positions itself as a transparent, rigid and consistent organization.


Relationships based on Respect and Recognition
ISA Capital maintains respectful behavior and attitude of dialogue with society, especially with the communities surrounding its infrastructure, in order to achieve common goals, present corporate situations and prevent possible situations of conflict and risk.

For this management, specific actions with representative groups of society that promote dialogue in specific spaces and through established channels are identified.

Respect for Human Rights
ISA Capital conducts its operations based on respect. Its performances are linked to human rights recognized by national laws and global initiatives.

ISA Capital does not tolerate any of its stakeholders to perform, directly or indirectly, practices that violate human rights, nor accept any payment intended to sponsor illegal activities.

Also it does not tolerate, in a categorical manner, child labor or any form of slave labor and undertakes to take this position to the attention of its stakeholders, especially suppliers and third parties.

Sponsorship of Political Organizations
ISA Capital does not fund or promote political parties or their representatives or candidates. Nor makes sponsorship of conferences or activities whose purpose is the political advertising. Therefore, its employees cannot use the goods or resources (information systems, internal or external meetings, among others) of the company for such purposes.

Thus, ISA Capital does not exercise any direct or indirect pressure to political representatives, nor encourages any of its employees to do so.

In countries where active political participation is permitted, the employee can perform such actions out of working hours, fulfilling what has been stated.

Intervention in External Events
For an employee to participate on behalf of ISA Capital in conferences, events or other similar public actions he must have the permission of his immediate superior, who will evaluate the appropriateness or not of the participation.

Environmental Care
ISA Capital is committed to a business management that allows the performance of its business operations as part of its commitment to sustainable development.

Relationships with Civil Society Entities
The support and possible contributions to civil society entities are subject to fulfillment of local laws and compliance with corporate guidelines.

Relationships with Competitors
ISA Capital maintains honest, constructive and reputable relationships with its competition. This implies, among other commitments:

  • Fairly competing in the markets, without making misleading advertising or denigrating its competitors or third parties.
  • Obtaining information of competition always legally.
  • Meeting the antitrust standards, avoiding any conduct that constitutes or may constitute cartel, abuse or restriction of competition.


Compliance with the Code of Ethics will be followed by the CEO, who may delegate to the Ethics Committee elected by him, which committee is composed of an odd number of people, and one of them is the representative who will report on the ethical management of the company.

In case of non-compliance with the Code of Ethics, the Committee, through its representative, shall inform in writing to the monitoring instance, for compliance with the procedures of its competence and that actions are taken to correct the non-compliance.

The Code of Ethics of ISA Capital was approved at the meeting of the Board of Directors held on February 21, 2011 and from that moment became effective for all employees of ISA Capital.

The Code of Ethics will be reviewed and updated periodically when needed and according to company evaluation.

All employees and members of the Board of Directors undertake to comply with the Code of Ethics. Therefore, this document applies to all directors, officers, managers, employees, service providers, temporary employees, apprentices and trainees, regardless of hierarchical level, geographic location or position in ISA Capital.

The Code of Ethics establishes criteria and guidelines for the conduct of employees of ISA Capital, but each person is responsible for his actions or omissions.

No one, regardless of office or position, is authorized to request that an individual submitted to this code commits an ethics violation or infringes the provisions hereof. In his turn, no professional of ISA Capital can explain a misconduct, illegal behavior or that violates the Code of Ethics, justifying his actions as fulfillment of an order from a superior or from a social agency of which he is a party.

This Code does not include all rules or regulations that apply to every routine situation of the company. Therefore, its content should be considered together with the policies, procedures and instructions of ISA Capital and the requirements of the law.

However, when the situation requires a specific orientation, it is expected that the professional applies the ethical principles.

The action guided by the Code of Ethics is subject to fulfillment of internal regulations and rules of ISA Capital. To the extent that regulations and/or internal rules that establish more rigid criteria than those provided for in this Code arise, the latter shall prevail to the definitions in this document.


The Code of Ethics is a document that guides the performance of employees of ISA Capital before stakeholders and must be respected and followed by everyone.

For questions or perceived breach of this document, ISA Capital provides a support channel to the code: [email protected]

This channel is exclusive to meet doubts, criticisms and complaints that reach the ethics of ISA Capital, i.e. implying non-compliance with the code or no understanding of its contents.

It is an electronic means which receives internal and external demands and makes the appropriate dealings. This system was specially developed to monitor complaints or doubts and ensure confidentiality and commitment of response.

The ethical line values the anonymity (of information and people) and the determination of the issues exposed to the channel. Its management will be accompanied by the Chief Office, through the Ethics Committee.

To ISA Capital, the trust relationship is also translated into everyday relationships. Therefore, the guidance is that employees seek first their immediate superiors to answer their questions and discuss ethical issues and, if they continue, opt to use the channel.

In ISA Capital vague complaints are not accepted. Nor are encouraged anonymous complaints, but it is at employees discretion to identify themselves or not.

IMPORTANT: complaints related to violations of the Code of Ethics will not imply retaliation or will be object of appreciation or recognition of professionals who made the complaint.