Code of Conduct

CODE OF RESPONSIBILITY OF LAWYERS AND STAFF WITH THE FIRM

The set of responsibilities which all lawyers and staff members have with the firm are  mentioned below:
Honesty.  Any kind of conduct which may represent an undue appropriation or misuse of the assets of the firm as well as those of the clients must be prevented at all times.

Ethics.  Must be at all times consonant with the moral principles generally accepted.  Any kind of conduct which may challenge the honorability or the reputation of the individuals or of the firm must be prevented.

Loyalty.  Must be loyal to the firm at all times and prevent any conduct contrary thereto.

Reliability.  The conduct must always be reliable in any statement and in any act with respect to the firm.

Dedication.  It is a duty with the firm to dedicate the best efforts to the execution and compliance with the interests thereof.

Permanent improvement.  The improvement of the knowledge and qualification must be procured at all times in order to enable the fulfillment of the objectives of the firm.

Confidentiality.  All matters and information regarding the office and its clients must be kept in strict confidentiality.

OUR RESPONSIBILITY WITH THE CLIENT
First of all, it is the duty of each lawyer to comply with the requirements of the Know your Client Policy, and to cooperate with the Compliance Officer in any follow-up action that may be necessary.

It is our responsibility and our commitment to serve our clients with professionalism, independence and honesty, according to the policies approved by the partners of the firm, complying at all times with the laws of the Republic of Panama, and of the countries where our services are offered.

We must always act with transparency and sincerity, without detriment to our duty towards confidentiality.  We shall protect any information in order to secure the rights of our clients, partners, human resources, and the interests of the firm itself.

Any lawyer and employee of the firm that may become acquainted with important information which is not of public interest, and which may in one way or another negatively affect a client, must maintain such information as confidential.  This confidential information shall not be disclosed to any third party nor shall be used for personal benefit.

In the event that the information of a client must be disclosed in the course of a negotiation, the lawyer of the firm must consider all measures necessary to protect its confidentiality.

Any confidential information regarding any third party shall only be disclosed with the authorization of such person and as required by law.

 
OUR POLICY ON CONFLICT OF INTERESTS
The firm shall not represent any client having conflict of interests with any other client of the firm except that such client has no objection and consents thereto.

The firm shall prevent any situation that may have influence on its opinion, independence or in the event of an apparent conflict of interests, which may be interpreted as a lack of objectivity and impartiality of the firm towards one client or the other.

The lawyers and employees of the firm are required to prevent any business activity, whether direct or indirect, which may create and/or be perceived as a conflict of interests with the firm or its clients.

Any lawyer or employee of the firm having any doubt on any situation which may involve or is believed may involve a conflict of interests must bring the details thereof to the attention of the partners, and preferably in writing.

Each lawyer and employee of the firm is required to immediately disclose any conflict of interests of its own.

The information furnished to the partners of the firm may result in the approval of the relation or transaction based on the fact that, even though the appearances may seem otherwise, the businesses or transactions are actually not harmful to the firm or its clients.  However, any conflict of interest is prohibited even if  harmless to the firm or its clients, except if disclosed to and approved by the partners of the firm.

 
OUR RESPONSIBILITY WITH THE COMPETITION
The firm accepts that it must compete within an ethical, professional and respectful frame with the competition.

No lawyer or employee of the firm shall compromise or involve the firm in any conduct that in any way be unethical or contrary to the law.

We shall always endeavor to render our services truthfully, including references to colleagues or third parties, with no untruthful or harmful intention.

The lawyers and employees of the firm must not look to create or posses unfair advantages with the intention of influencing or manipulating any decision of the firm or action contrary to the ethical duty towards the competition.

The lawyers and employees of the firm shall not offer or give clients and/or third parties any information or other thing (bribery or threat) which may be considered as an unfair advantage.

 
RESPONSIBILITY WITH OUR HUMAN RESOURCES
Our firm provides a safe, sound, respectful place of work and fair working conditions to its lawyers and employees.  Discrimination or harassment based on ethnic group, gender, religion, national origin, disability, sexual orientation or age, is completely prohibited at the firm.

Respect is required among lawyers and employees.  Harassment and intimidation are practices not accepted at the firm.

Lawyers and employees must also be open, transparent and truthful before their employers, subordinates and managing officers.

 
OUR RESPONSIBILITY WITH THE STATE
We are fully committed in complying with the laws of the Republic of Panama and the countries where we carry on business activities.  If a lawyer or employee of the firm has any doubt regarding any activity, transaction or conduct, he or she must seek appropriate advice.

No lawyer or employee of the firm is allowed to acquire privileges or special benefits by means of briberies, illegal political contributions or any other unlawful payments or give anything of value to any government official with the intention of unappropriately influencing any act or decision of said official.

All transactions shall be recorded exactly and correctly in our accounting books or records, and  always supported with the appropriate documentation.  No undisclosed fund or asset shall be established.

No forged or artificial entries shall be made in the books or records of the firm for any reason, and no lawyer or employee of the firm shall commit itself to any settlement which may give origin to an act contrary to law, even if requested by a managing officer.

 
OUR SOCIAL RESPONSIBILITY
We maintain our commitment with society and the environment in which we offer our services, aware at all times of the strict compliance with ethics and responsibility by our lawyers and employees.

We are likewise committed to the professional and human improvement of our work team and its environment.  To this effect we have created a non-profit foundation, through which we promote and carry out social and humanitarian programs directed towards the most needy sectors of society, with the specific purpose of improving the human standards and living conditions of these people.

Given in the City of Panama, on the 25th day of June of 2007.