1.Introduction
This Code of Ethics and Conduct (the “Code”) sets out how Giani Innovation (W G D Martins - ME, “Giani”) and every brand it owns, including Disparo, expect people to act at work. It guides decisions where no specific rule exists, and it reflects the standard all Giani brands share: official platforms, careful handling of data and trust earned before it is asked for.
1.1. Who this Code applies to
It applies to Giani’s partners, managers, employees, interns and contractors (“Team Members”), and to suppliers, service providers and partners whenever they act on behalf of Giani or any of its brands. A brand may add rules of its own; none may lower the standard set here.
1.2. Validity and updates
The Code takes effect on the date above and stays in force until it is replaced. Giani reviews it at least once a year, and whenever the law, the business or a brand changes in a way that requires it. The current version is always published on giani.dev, and Team Members are told when it changes.
1.3. Fair evaluation
Hiring, evaluation and promotion are based on work, results and conduct consistent with this Code, never on personal relationships or on any characteristic protected by law.
2.Work environment
2.1. Respect, discrimination and harassment
Giani does not tolerate discrimination based on race, color, ethnicity, nationality, religion, sex, gender identity, sexual orientation, age, disability, marital status, pregnancy, political opinion, social origin or any other characteristic protected by law. Moral and sexual harassment, intimidation, humiliation and threats are prohibited in any form: in person, in writing, in messages or online, and outside working hours whenever connected to work.
2.2. Alcohol and drugs
Working under the influence of alcohol or illegal drugs, or bringing them into work activities, is prohibited. Moderate drinking at social events organized by the company is allowed, as long as behavior stays professional.
2.3. Prohibited conduct
- Lying, falsifying records or misrepresenting results, including product metrics and customer data.
- Using any brand’s product to send unsolicited messages, get around a platform’s rules or ignore a customer’s opt-out.
- Using company resources for illegal activities or personal gain.
- Retaliating against anyone who raises a concern in good faith.
2.4. When in doubt
Before acting, ask: Is it legal? Is it consistent with this Code? Would I be comfortable if it were made public? Would it hold up if a customer, a partner or a platform reviewed it? If any answer is no or unclear, stop and ask Giani’s management.
2.5. Conduct outside work and the company’s image
Team Members are free to hold and share personal opinions, but may not speak on behalf of Giani or its brands without authorization, disclose confidential information, or behave in public or on social media in a way that harms Giani, its brands, customers or partners.
3.Information security
3.1. Company assets
Equipment, accounts, software, credentials and data belong to Giani. They must be used for work, protected against loss and misuse, and returned when the relationship ends.
3.2. Security practices
Use strong, unique passwords and two-factor authentication, never share credentials, and keep devices updated and locked. Access to systems and data is limited to what each role needs. Report any suspected incident, lost device or exposed secret immediately.
3.3. Privileged information
Information that is not yet public about Giani, its brands, customers or partners may not be used for personal benefit or shared with anyone who does not need it for their work.
3.4. Confidentiality
Business plans, source code, roadmaps, prices, contracts, customer lists and any customer content are confidential. This duty continues after the relationship with Giani ends.
3.5. Records and documents
Records must be accurate, complete and kept for the periods the law requires. No document may be altered or destroyed to hide information, especially during an audit, an investigation or a legal proceeding.
3.6. Intellectual property
Code, designs, texts, brands and other work created for Giani or its brands belong to Giani, as set out in the applicable contracts. Team Members must also respect the intellectual property of others and use only properly licensed software, fonts, images and content.
3.7. Use of the brands
The names, logos and visual identity of Giani and its brands may be used only for authorized purposes and in line with their brand guidelines.
4.Personal data and privacy
Giani and its brands process personal data in accordance with Brazil’s General Data Protection Law (Lei nº 13.709/2018, “LGPD”) and with the laws of every market where a brand operates. Team Members must:
- collect only the data needed for a clear purpose, and use it only for that purpose;
- access customer data only when a task requires it;
- never copy personal data to personal devices or unauthorized tools;
- honor requests from data subjects, including deletion and opt-out, without delay;
- report any suspected data breach immediately.
Each brand publishes its own privacy policy describing how it handles personal data.
5.Conflicts of interest
A conflict of interest exists when a personal interest could influence, or appear to influence, a decision made for Giani. Team Members must disclose any situation that could create one, such as a relationship with a supplier, a stake in a competitor or a family member in their reporting line, before taking part in the related decision.
5.1. Outside activities and competition
Outside work, investments or businesses that compete with Giani or any of its brands, or that use Giani’s time, assets or information, require prior written approval.
5.2. Gifts, favors and hospitality
Gifts, meals, trips and favors may not be offered or accepted when they could influence a business decision. Symbolic items of modest value are acceptable when given openly and infrequently. Cash and cash equivalents are never acceptable. When in doubt, decline and inform management.
6.Social and environmental responsibility
Giani builds products that help businesses grow responsibly. It works to reduce the environmental impact of its operations, such as unnecessary computing and travel, to choose suppliers who respect labor and human rights, and it never works with suppliers who use child, forced or degrading labor.
7.Anti-corruption, money laundering and terrorist financing
Giani does not tolerate corruption in any form. It is prohibited to offer, promise, give, request or accept, directly or through third parties, any undue advantage from or to public officials or private parties in order to obtain or keep business.
Team Members must comply with Brazil’s Anti-Corruption Law (Lei nº 12.846/2013), its anti-money-laundering law (Lei nº 9.613/1998), its law on terrorist financing (Lei nº 13.260/2016) and the equivalent laws of every market where a brand operates. Suspicious transactions, requests or customer behavior must be reported.
8.Reporting violations
Anyone who becomes aware of a possible violation of this Code, of company policies or of the law must report it to apps@giani.dev. Reporters may choose not to identify themselves. Every report is treated confidentially, and Giani does not tolerate retaliation against anyone who reports in good faith.
8.1. How violations are handled
Every report is reviewed impartially and investigated when needed. Confirmed violations lead to measures proportional to their seriousness, from guidance and warnings to the end of the employment or contract, without prejudice to legal action. When the law requires it, Giani informs the competent authorities.
Questions about this Code can be sent to apps@giani.dev.