Code of Ethics
This Code applies to all employees and administrators, hereinafter referred to as Delta Offshore Collaborators.
In this Code, we seek to summarize and present, in a clear and straightforward manner, the ethical values and principles of Delta Offshore, which translate into rules of conduct.
This Code is not intended to cover all matters that may arise in our day-to-day activities. It is complemented by other internal policies of Delta Offshore, which are also mandatory.
It is the duty of every Collaborator to read, understand, and comply with the rules of this Code.
The immediate manager is the most appropriate source of guidance for the Collaborator in case of questions about the Code or ethical dilemmas that may arise.
All other stakeholders directly involved in Delta Offshore’s activities must be informed about the importance of respecting the values and principles expressed in this Code.
Message from the President of Delta Offshore
Committed to ethics, transparency, and integrity, we have undertaken significant efforts to improve and strengthen our Compliance processes.
This Code provides a simple and objective approach and will help us disseminate a culture of doing the right thing in any situation.
It is very important that all our employees and partners read, understand, and practice the rules established here. Each of us has an important role to play in ensuring that we all do the right thing.
We must lead by example, practicing what we preach and always striving to do the right thing. This Code of Ethics and Conduct serves as a guide for our decisions.
We count on everyone’s engagement!
Vitor Cardoso
President of Delta Offshore
Doing What Is Right
Our ethical principles must guide our daily actions and business decisions to ensure that we act with integrity.
However, sometimes it is much easier said than done. Often, we need help to recognize and properly deal with doubts or ethical dilemmas.
Our Code of Ethics and Conduct is an important tool to assist us with this. It defines who we are, highlights our values and ethical principles, and establishes what we are guided by and responsible for.
In a clear and simple way, our Code explains our commitment to always doing what is right and helps us make good decisions.
RESPECT
All our actions are guided by respect as a central value.
RESPECT FOR HUMAN RIGHTS
Delta Offshore fundamentally upholds absolute respect for human rights, especially the right to physical integrity, equal treatment, privacy, freedom of expression, and all civil, social, and cultural rights.
Wherever we operate, we are committed to combating any attempt to violate these rights.
We expect you to:
- Respect the rights of your colleagues and third parties.
- Require the same respect from our business partners.
- Not accept child labor, forced labor, slavery, or similar practices, nor engage with companies or organizations that tolerate such practices.
- Report to your immediate manager or the ethics channel any suspected violations of these rules.
RESPECT FOR DIVERSITY, INCLUSION, AND EQUITY
Delta Offshore respects and provides equal treatment and access to opportunities for all and encourages a respectful and cooperative environment that preserves diversity.
We believe that only through equal opportunity and treatment can we achieve maximum productivity, competitiveness, and efficiency.
We expect you to:
- Treat everyone equally, regardless of position, ethnicity, nationality, gender, religion, sexual orientation, skin color, or any other characteristic.
- Respect the job responsibilities of Collaborators and avoid overstepping them.
- Welcome new Collaborators and provide essential information about the company and their work.
- Speak up if you witness violations of equal opportunity principles.
RESPECT FOR DIGNITY AND PREVENTION OF HARASSMENT
Respect for people is fundamental. Therefore, Delta Offshore rejects any form of harassment that disrespects the dignity, body, image, sexuality, or self-esteem of a Collaborator.
Harassment refers to any unwanted or disrespectful behavior intended to humiliate, embarrass, harm dignity, or create an intimidating, hostile, degrading, or destabilizing environment.
Delta Offshore does not tolerate any form of harassment, such as sexual or moral harassment, nor situations involving disrespect, intimidation, or threats among Collaborators, regardless of hierarchy.
We expect you to:
- Inform your immediate manager or the ethics channel if you experience or witness any abuse or harassment.
- Notify a colleague that their behavior is unacceptable and request its immediate cessation.
RESPECT FOR OUR BUSINESS PARTNERS
Our clients and service providers (“Partners”) are essential to us. Therefore, we make careful choices and use an objective selection process.
We work with our Partners in an honest, respectful, and responsible manner. We are a company our Partners can trust.
We seek to work with Partners who share our commitment to safety, ethics, and compliance.
We achieve our competitive advantages through safety and strong performance, never through unethical or illegal business practices.
We expect you to:
- Choose our Partners carefully.
- Clearly communicate our expectations to them.
- Take appropriate measures if they fail to meet expectations or obligations.
- Speak up if a Partner is not complying with the law or contractual obligations.
RESPECT FOR ANTI-CORRUPTION LAWS
We respect the law and promote a business environment that fosters transparency, integrity, ethics, and free competition.
Delta Offshore is committed to the highest standards of integrity and does not tolerate any form of bribery or corruption.
Such conduct is criminal and may result in fines and penalties for both the company and involved Collaborators.
We expect you to:
- Not accept or offer money, gifts, or commissions to secure contracts.
- Perform your duties with professionalism, loyalty, and honesty.
- Assess risks related to third-party engagements and activities that may violate the law.
- Report any suspicion of corrupt behavior.
DUTY OF LOYALTY AND CONFLICTS OF INTEREST
We recognize that everyone has personal, family, and business interests. However, conflicts of interest may arise.
We must ensure that in business decisions we identify, disclose, and manage potential conflicts that may compromise our duty of loyalty to Delta Offshore.
We expect you to:
- Recognize potential conflicts and be transparent.
- Not use business opportunities for personal gain or benefit of relatives or close friends.
- Avoid participating in decisions involving your own interests or those of close individuals.
- Report any real or apparent conflicts to your manager.
When in doubt, consult your manager or the ethics channel.
RELATIONSHIP WITH PUBLIC ADMINISTRATION
Any relationship with public entities and officials must be based on transparency, ethics, and integrity, and be free of conflicts of interest.
Contacts with public officials and political office holders must follow this Code and the law.
Under our zero-tolerance policy for corruption, any form of offering, promising, or giving undue advantage is prohibited.
We expect you to:
- Never offer or give undue advantage.
- Know and follow the Anti-Corruption Policy.
- Encourage colleagues to do the same.
- Use the ethics channel if in doubt.
GIFTS, PRESENTS, AND INVITATIONS
We promote a professional environment that respects rules; therefore, gifts or invitations must not be used to influence decisions.
Only institutional promotional gifts with company branding, distributed generally and modestly, are allowed.
Gifts must not target specific individuals to influence them.
Offering gifts to public officials is strictly prohibited.
We expect you to:
- Not offer or accept excessive or luxurious gifts.
- Not offer gifts expecting something in return.
DONATIONS, SPONSORSHIPS, AND CONTRIBUTIONS
Donations are voluntary and made without expectation of return.
Delta Offshore does not make donations or sponsorships to improperly influence decisions.
We expect you to:
- Not make donations on behalf of the company without prior approval.
- Not propose donations expecting benefits or preferential treatment.
FINANCIAL INTEGRITY
We are committed to maintaining accurate and complete financial records reflecting the company’s operations.
We expect you to:
- Record accounting entries accurately and promptly.
- Ensure financial transactions are fully documented.
- Report inaccuracies.
ANTI-MONEY LAUNDERING
Money laundering disguises illegal funds as legitimate.
Delta Offshore rejects all criminal activity and ensures its operations are not used for money laundering or terrorism financing.
We expect you to:
- Ensure accurate financial records.
- Know your customer.
CONFIDENTIALITY AND INFORMATION SECURITY
We are committed to protecting confidential and privileged information.
Privileged information is non-public information that could influence investment decisions.
We expect you to:
- Protect confidential information.
- Not disclose or misuse privileged information.
PERSONAL DATA AND PRIVACY
We respect privacy and ensure transparency in handling personal data.
We expect you to:
- Use personal data responsibly and only when necessary.
- Not disclose personal data under any circumstances.
Our Responsibilities
All Collaborators must comply with this Code and internal policies.
Violations may result in disciplinary measures, including termination.
ETHICS CHANNEL
All Collaborators must report suspected misconduct.
Reports are confidential, and retaliation is not tolerated.
Anonymous reporting is allowed.