LAST UPDATED: JULY 2026
This Code of Ethics and Conduct sets out the principles that guide DM11's decisions and the behavior we expect from partners, employees, suppliers and business partners. It applies to all our business relationships, in Brazil and abroad. Complying with this code is a condition for working with us and for supplying to us.
Ethics informs every decision we make. We pursue business results with reference to our corporate values and to the interests of the different stakeholders we work with.
We work with an owner's mindset: we take responsibility for the outcome, we meet the deadlines and budgets we agreed to, and we act transparently. We seek excellence in execution and innovation that produces real results for the client.
We treat client satisfaction as a standing commitment. That means proposing solutions that improve the client's results while strengthening their management practices and their sustainability.
We foster a workplace built on mutual respect, where each person's dignity is preserved and differences are valued. We do not accept discrimination based on gender, color, race, ethnicity, disability, sexual orientation, religion, national origin, marital status, age, pregnancy, social class or any other personal characteristic.
We do not tolerate sexual, moral, religious, political or organizational harassment under any circumstances. Our managers have an educational role: they are expected to convey these standards through their own conduct, not only through written rules.
We oppose forced labor, slavery-like labor, irregular child labor and any form of sexual exploitation of children and adolescents. If we identify these practices in our value chain, the party involved is removed and the matter is reported to the competent authorities.
We comply with the laws that apply to our activities. This includes health and safety rules, human rights, labor law, environmental law and tax obligations.
We do not engage in money laundering or in financial transactions designed to disguise the unlawful origin of assets. Any case identified is reported to the competent authorities.
We compete freely and fairly. We do not take part in trusts or cartels, we do not seek advantage through fraud or corporate espionage, and we do not make insinuations that damage competitors' reputations.
Gifts, favors and hospitality must follow customary market practice and be of token value. We neither offer nor accept commissions, gratuities or cash. Before offering any courtesy, our people must check that it is consistent with the client's or supplier's own code of conduct.
We contract suppliers whose management practices are consistent with this code, regardless of their size or location. Our supplier base is monitored through an approval process that covers administrative, tax, labor, social and environmental criteria.
Personal interests must not compromise the impartiality of decisions made on DM11's behalf. Any actual or potential conflict must be avoided or disclosed.
Our people are expected to inform their manager of any situation that could affect their professional responsibilities, to abstain from procurement decisions involving relatives or close contacts, and never to use their position for personal gain or to favor third parties.
While a situation is under review, everyone involved must withdraw fully from the decision in question.
All information that is not in the public domain is confidential. The duty of confidentiality survives the end of the employment or service contract, for as long as the information remains non-public.
As an information security firm, we apply to ourselves the same rigor we recommend to our clients. Internal and third-party information is stored and processed in a controlled environment, with shared responsibility for the integrity, availability and confidentiality of information assets.
Methodologies, technologies and improvements developed in the course of our work belong to DM11 and may not be used for personal purposes or passed on to third parties.
DM11's assets include equipment, systems, information and financial resources, but also intangible assets such as the integrity, reliability and reputation built since 2009.
Each person is expected to protect these assets against waste, damage, misuse or loss, to report any sign of fraud or misappropriation to their manager, and to take particular care with access credentials.
Employees, suppliers, clients and third parties may report suspected breaches of this code to their area manager or directly to the Ethics Committee at etica@dm11.com.br. Reports may be identified or anonymous.
All reports are handled confidentially and reviewed by the Ethics Committee, which is composed of members of DM11's management.
We do not allow retaliation against anyone who reports a concern in good faith or cooperates with an investigation. Allegations of retaliation are always investigated, and retaliation itself is subject to disciplinary action.
The Ethics Committee is responsible for communicating this code, clarifying questions of interpretation, keeping the text current and reviewing reported breaches.
Breaching this code exposes the responsible party to disciplinary action and may lead to termination of contracts with DM11 at no cost to the company, without prejudice to any legal measures available.
Questions about this code may be sent to contato@dm11.com.br.