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It is with great pleasure that we present this Code of Ethics and Conduct of Capital Realty
Infraestrutura Logística Ltda. (“Capital Realty”) that conveys the pledge endorsed by all of us, employees, clients, suppliers, and partners of Capital Realty, thus representing our commitment to follow ethical, transparent and mutually respectful conduct.
In this sense, the Term of Responsibility and Adherence to Capital Realty’s Code of Ethics and Conduct attached hereto should be signed by all employees, clients, suppliers, and partners of Capital Realty as an expression of understanding of its provisions and commitment to fulfill them.
Accordingly, Capital Realty’s Code of Ethics and Conduct seeks to strengthen our culture to perform continually in an ethical way.

Created in 1999, Capital Realty conducts business in the states of Rio Grande do Sul, Santa Catarina, Paraná, and São Paulo and manages a portfolio of more than 400,000 m² of built area.

With a team of managers and engineers with extensive experience in the real estate market, Capital Realty leaves a mark for its technical capacity to develop, execute, and manage real estate assets.

The company is relentless in its pursuit of new constructive solutions so that its designs are streamlined and exceed the expectations of its occupants, given that its client portfolio is made up of leading domestic and multinational companies.

Capital Realty conceives designs and consummates the construction of real estate developments.

With an in-house engineering and architecture staff, it ensures agility and a more competitive solution for clients.



To develop and manage real estate assets in the logistics infrastructure industry in an innovative & efficient way to add value to our clients, employees, and shareholders.


To be a reference in developing and managing real estate assets in the logistics infrastructure industry.


  • Sustainable Development
  • Result-Driven
  • Human Assets
  • Ethics

This Code of Ethics and Conduct of Capital Realty aims to introduce the company’s core guidelines to ground its activities on ethical principles relevant to its business environment.

Thus, this Code should guide Capital Realty’s actions by establishing and encouraging ethical values ​​in the relationship among employees, partners, clients, service providers, and all those engaged by the company’s business.

Therefore, the applicability of this Code encompasses all employees, officers, suppliers, service

providers in general, clients, the community, and public and governmental authorities.


Ethical and transparent conduct should be followed among employees, service providers in general, clients, and all affected by the Capital Realty’s business activity. Discrimination of any nature will not be tolerated, either of moral, sexual, verbal, visual or physical nature, in addition to the use of illegal work, thus honoring the principles of honesty and integrity, besides refraining from approaches or attitudes that could compromise the image, reputation and interests of the company.

Capital Realty maintains a relationship of trust, partnership, and respect with its stakeholders, therefore, employees should, at all times during their job assignments avoid conflicts between personal interests and those of the company, in relationships with other employees, clients, suppliers, between others.

Thus, Capital Realty is:

  • Committed to maintaining an open work environment, free of inappropriate and disrespectful conduct, as well as encouraging people from all backgrounds and experiences to contribute with the most diverse ideas to the organization;
  • Expects its employees, service providers, and clients to be transparent in all acts carried out in the performance of their roles;
  • Such as with discrimination, it does not tolerate moral, sexual, verbal, visual or physical harassment and/or moral distress among its employees, under penalty of contractual termination, without prejudice to applicable criminal measures;
  • Under no circumstances will it use illegal work, as provided by law, both by its employees and its clients, contractors, and service providers in general;
  • Expects from its employees and partners an upright approach whenever they are representing Capital Realty in professional or social situations and should adhere to the principles of honesty and integrity;
  • Always preserves your information, as well as that obtained in commercial negotiations, which is why all Capital Realty information subject to disclosure is available on the website:

Among Capital Realty’s employees, rules of conduct should be fulfilled, namely:

  • Compliance with Law:

Capital Realty’s employees should fully comply with the provisions of all laws – federal, state, municipal, and foreign – applicable to Capital Realty’s business. All federal, state, municipal, and foreign laws are considered an integral part of this policy and incorporated herein by reference for all legal purposes. 

  • Provision of services to other companies and conflict of interests:

A conflict of interest arises when you find yourself in a situation where two or more competing interests conflict and impair your ability to make objective, unbiased, or disinterested decisions. Thus, all Capital Realty employees are expected to perform their activities in a way that does not conflict with the interests of Capital Realty. You should not perform an operation, take part or take any action contrary to Capital Realty’s interests or inconsistent with the duty of loyalty and the obligations inherent to your relationship with Capital Realty. The employee also cannot maintain an employment relationship, provide services, even if one-time ones, or be a manager, holder of partner rights, directly or indirectly, in any form, of a company that operates in the same line of business as Capital Realty.

  • Information Security Policy:

All employees shall have access to Capital Realty’s Information Security Policy hereby attached to this Code (ATTACHMENT IV), so that they should apply it in their routine relationship with Capital Realty to ensure the availability, integrity, confidentiality, legality, and authenticity of the information necessary for carrying out Capital Realty’s business or those with Capital Realty.

  • Information Disclosure Policy:

As provided above, Capital Realty information subject to disclosure is available on the company’s website (, and any information obtained by the employee in their work environment or commercial relationship with Capital Realty cannot be disclosed under no circumstances to third parties, whether from Capital Realty or partners, clients, and others. 


Thus, employees are not allowed to disclose any insider information to which they have access.

Probe your own honesty values and common sense when handling Capital Realty money. You may be required to make cash payments or incur expenses that Capital Realty will reimburse. Make sure Capital Realty pays a fair price and that expenses are reasonable. Requesting reimbursement for expenses with food that has not been consumed, the mileage that has not been traveled, airline tickets not used, or any other expenses that have not actually been spent are illegal acts and a breach of this Code, which shall result in disciplinary sanctions, including waiver.


Intellectual Property 

Confidential information or intellectual and/or industrial property that employees develop as part of their work is the property of Capital Realty. It shall be protected against unauthorized disclosure. Such information includes trade and industry secrets, as well as technical, financial, personal or commercial

information that is sensitive, confidential, private or otherwise restricted. Files/records, practices, charts, plans, projects, and software are included.


You shall not misuse confidential or proprietary information nor disclose such information to anyone who is not an employee of Capital Realty, except for lawyers, accountants, and other service  providers contracted by Capital Realty and need to receive it. This prohibition applies to conversations

with relatives and friends who may naively and inadvertently pass on information. 

If you cease to be an employee of Capital Realty for any reason, including retirement, you shall maintain your obligation not to disclose or misuse information owned by Capital Realty for a minimum of 10 (ten) years. Upon termination of your employment relationship, you shall return all Capital Realty documents, files, and copies thereof.


Capital Realty’s relationship with its clients is always based on ethical principles, as well as on Capital Realty’s mission and values. All customers shall be treated fairly and in keeping with applicable laws, contractual obligations, practices, and regulations.

Information obtained from closed partnerships is confidential, and disclosure to third parties is not allowed unless previously authorized in writing by the client.

Therefore, we expect the same ethical conduct from our clients, as well as the same commitment to Capital Realty’s information and operations.

The activities carried out by Capital Realty’s clients cannot, under any circumstances, disagree with municipal, state and/or federal laws, being subject to licenses and authorizations from the competent public authorities.

Capital Realty seeks client satisfaction with efficient service in accordance with contractual and commercial conditions.


Capital Realty seeks in its suppliers the same ethical standards of conduct with which it operates in order to further and maintain its ethical culture. Every procurement shall be grounded on technical and economic support, and favoritism of any nature is not allowed. All suppliers shall be treated fairly and in keeping with applicable laws, contractual obligations, practices, and regulations.

The rules and procedures of Capital Realty’s Code of Ethics and Conduct apply to all third parties representing Capital Realty, such as consultants, service providers, contractors, business partners, and suppliers, among others.

To ensure the application of this Code of Ethics and Conduct, all contracts entered into with third parties shall provide clauses to ensure ethical conduct as well as compliance with Anti-Corruption Laws to prevent the risk of illicit payments and ensure Capital Realty’s and its suppliers’ wellness in their commercial relationship.


The core purpose of antitrust laws is to protect and provide an open economic environment for new businesses to compete in markets free of collusive or discriminatory conduct. When this purpose is not achieved as a result of collusive private actions or abuse of economic power, antitrust laws and the free competition system are violated. Violating these laws may result in the imposition of severe penalties on Capital Realty and, in some cases, on the individuals involved, including those of a criminal nature.


Capital Realty has always guided its performance in compliance with antitrust laws.


Below is a list of the main prohibitions behind Competitors’ antitrust:


  • Do not discuss prices with competitors;
  • Do not enter into agreements to limit or increase production levels with competitors;
  • Do not split clients, markets or territories with competitors;
  • Do not require clients to hire services only from Capital Realty;
  • Do not make agreements with competitors to boycott suppliers or clients;
  • Do not participate in meetings with competitors for illegal purposes;
  • Do not use a product or service as an influence to force or induce a client to buy another product or service;
  • Do not prepare documents or make statements without considering their impacts on the competition; and
  • Do not hide any wrongdoing; report it immediately to your superior.


This Code is not intended to be an exhaustive review of antitrust laws nor a substitute for expert advice. If you have questions about a specific situation, you should consult Capital Realty’s Legal Department.


Capital Realty is compliant with Brazilian environmental laws, committing itself to protect the environment and aiming at preserving our natural resources. As a means of commitment to the environment and adherence to current environmental laws, Capital Realty arranges the necessary licenses and authorizations for the location, installation, and operation of all its developments.


As such, we responsibly comply with all applicable environmental laws and regulations. 


Capital Realty’s policy is to conduct its activities in an ethical, socially responsible and economically  sustainable manner, protecting its employees, service providers, and clients and expecting the same

conduct from them.


Lastly, the company’s environmental responsibility amounts to a set of attitudes that consider economic growth to protect the environment today, as well as for future generations.


As an upright company committed to ethics, anti-corruption measures should be taken so that Capital Realty does not tolerate in its activities the act of offering, promising or authorizing the giving of any good or anything of value to government agents or private sector companies’ employees, directly or through third parties, in order to influence the action of such agents or employees to obtain improper advantages, under penalty of contractual termination for cause, without prejudice to any criminal

measures that may be applicable. 


Therefore, Capital Realty adopts the domestic and foreign Anti-Corruption Laws applicable to the activity of each partner, including, but not limited to, the United States Foreign Corrupt Practices Act – FCPA), which has become an integral part of this Code, to the extent that its employees, suppliers, partners, and clients should likewise adhere to this policy, as well as to the rules of ethics and conduct.


Therefore, if you have any questions regarding the mentioned laws, seek clarification from your supervisor or Capital Realty’s Legal Department.


Therefore, it is forbidden for Capital Realty to request or accept bribes through its representatives, whether employees, partners or employees in any capacity.


To understand this Policy, “Bribery” means any offer, solicitation, promise and/or authorization to pay or receive any item of value, to or from any governmental authority or any other person of a private enterprise, to induce the receiver to abuse their position or to gain an undue advantage.


Capital Realty does not accept the act of providing or receiving hospitality and gifts under any circumstances.


Commercial, accounting, tax and other mandatory records and books shall accurately reflect Capital Realty’s business. Capital Realty’s payments or receipts shall always be approved with the supporting documentation, and defrauding, circumventing or avoiding internal and/or external accounting controls is prohibited.

Under the same terms, the payment of grease payments, kickbacks or bribes, herein defined as payments to any authorities to speed up the performance of red tape or any administrative acts, including routine and/or non-deliberative acts, is prohibited.


If you are faced with a situation that raises doubts or suspicions regarding the legality of payment or expense, immediately contact Capital Realty’s Legal Department to obtain guidance on the appropriate procedure to be adopted.


Capital Realty underscores that it is the personal responsibility of all employees, partners, service providers, and clients to know the legal rules and restrictions applicable to the assignments they perform and activities they practice so that the breach of the applicable laws or this Code of Ethics and Conduct and Anti-Corruption Policy shall 

subject the infringer to the legal penalties applicable to the case.


No employee shall be sanctioned for delay or loss of business resulting from their refusal to pay or receive a bribe.



As stated above, all coworkers, employees, managers, suppliers, and customers shall behave in accordance with this Code of Ethics and Discipline and/or Anti-Corruption Policy, as well as abide by the applicable laws of the Brazilian and foreign legal system so that any breach shall be treated as a matter of extreme gravity, subject to contractual termination.

If you have reason to believe that this Code of Ethics and Discipline and/or Anti-Corruption Policy of Capital Realty is being violated, we encourage you to bring the matter to the attention of your immediate superior or Capital Realty’s Legal Department, accordingly. Rest assured that employees who, in good faith, report a possible breach shall be protected and shall not face retaliation.

Breach of this Code of Ethics and Discipline and/or the Anti-Corruption Policy is considered occupational misconduct, subjecting the infringer to the appropriate disciplinary measures applicable to each case, whether labor, administrative, civil or criminal, all in accordance with the Brazilian laws.

All breaches of the Code of Ethics and Conduct, as well as the Anti-Corruption Policy, shall be eviewed by Capital Realty’s Legal Department together with the company’s officers, who will define the appropriate punishment for each case and, if applicable, report breaches to the competent authorities.