Message from Management
In accordance with our values, faith, ethics, and passion, this Code is an essential part of our corporate culture. It is also the basis of our business conduct and the foundation of our policies, procedures, and norms.
This document will be continuously updated to allow us to operate optimally and transparently, reinforcing the trust of our employees, customers, suppliers, competitors, authorities, and other stakeholders.
This is a working tool that will help us make correct decisions in line with our values.
We invite everyone who is part of the company to read and consult this code whenever necessary. We also encourage you to report any irregularities or non-compliances with this or any other procedure or policy.
With your support and commitment, we sustain and grow our company, continuing to build success stories.
Sincerely,
Kattia Rodríguez Pastor / Yorline Quesada Chaves
Legal Representatives
II. Scope
This Code is intended for the reading and compliance of all individuals who make up the
company DO Gestión de Talento S.A
This document describes general situations concerning relationships with various relevant stakeholders of the company, such as employees, investors, clients, suppliers, authorities, organizations, the environment, the community, and any other entity that
has a relationship with or impact on the company.
It is the commitment and obligation of all members of DO Gestión de Talento to comply with each of the guidelines defined in this document for all activities carried out daily, performing their work with professionalism and ethics.
Any situation not foreseen within this Code of Ethics will be resolved according to the best management practices and in consultation with Human Resources and/or Senior Management.
Objective
To establish a framework of values and conducts that serve as reference for the behavior of all employees in their performance, their labor relations, and in their interactions with all relevant stakeholders.
Corporate Philosophy
Mission
To be a bridge that connects successful companies with quality employees.
Vision
To be a socially responsible company, recognized nationally and regionally for making a difference in the integral development of its people and its clients.
Values
FAITH
We believe in God, in our potential, and in the potential of our people.
ETIHICS
We build relationships based on honesty and transparency.
PASSION
We approach our work with joy, warmth, and positivity.
Principles and Fundamental Rights at Work
At DO, we will always respect all applicable national or international legislation regarding:
- Protection of Human Rights for all individuals
- Fair and equitable treatment, and prohibitions against discrimination, abuse, and/or harassment of any kind
- Freedom of association and representation
- Prohibition of forced labor
- Environmental safety and protection
- Workplace safety, health, and hygiene
- Wages, social security, and taxes (including the payment and withholding of
employee income tax) - For the above mentioned, we maintain a permanent legal counseling service to stay updated on these topics and any others that are of interest to internal management.
Human Rights
We recognize and promote that Human Rights are quot;the set of prerogatives based on human dignity, whose effective realization is indispensable for the integral development of the person” (translated from the original definition by the CNDH, México).
The Right to Life and Security
The notion of personal dignity and security is developed through the following groups of rights: the right to life, liberty, and security; the right to be free from slavery, servitude, torture, or inhumane or degrading treatment or punishment; the right to a national legal system in line with the international human rights declarations, treaties, and conventions, ratified by the constitution and national legislation; the right to recognition as a person before the law, equal protection under the law, legal remedy in the event of human rights violations, and freedom from arbitrary detention; the right to a fair trial before an independent tribunal; the right to the presumption of innocence and the protection against retroactive penal laws.
Therefore, in our company:
- We exhibit a conduct that is loyal, respectful, diligent, and honest.
- We recognize the dignity of individuals and respect their freedom and privacy.
- We do not falsely or maliciously accuse an innocent person.
- We, those who are involved in political or religious activities of any kind, do not involve the company, making it clear that we act in a personal capacity and not on behalf of the company.
- We avoid assigning any type of work that goes against any Human Rights.
Child Labor and Forced Labor
Children possess the same human rights as adults do. However, due to their lack of knowledge, experience, and decision-making capacity, they have additional rights by virtue of their age. These rights include protection against economic exploitation in work that may jeopardize their health, moral integrity, or hinder their development.
In Costa Rica, the employment of individuals under 15 years old is a violation of labor laws since it limits the full exercise of the individuals’ rights. Between the ages of 15 and 18, state authorization is required.
In compliance with the aforementioned, the following actions must be taken:
- Enforce the national labor law recommendations regarding minimum working ages and, when national law is insufficient, consider relevant international regulations (such as ILO conventions).
- Use appropriate and reliable mechanisms to verify the age of employees.
- Ensure fair employment and wages for all adult workers to minimize the risk of their children being sent to work.
- Review and ensure that subcontractors, suppliers, and other business partners prevent child labor.
- Therefore, it is the company’s policy not to employ minors. In the event of doing so, we will follow the applicable laws and regulations as determined by our legal advisors.
Additionally, according to the ILO Forced Labor Convention No. 29, forced or compulsory labor refers to quot;all work or service which is exacted from any person under the menace of any penalty and for which the said person has not offered himself voluntarily.quot; As such, DO respects the limits of working hours as indicated by local and international legislation, allowing employees the choice of whether or not to participate in overtime, and ensures that practices promoting compulsory overtime are not present in relations with clients and suppliers.
Working Conditions and Hours
The company will ensure the provision of working conditions and an environment that guarantee the health, safety, and general well-being of individuals. This constitutes an essential right in labor relations, regardless of the type of employment (temporary or permanent).
It is the responsibility of all personnel to maintain workspaces clean and free of any potential safety or health risks. Additionally, it is mandatory to wear the safety equipment required, according to the position held (when applicable).
At DO, we will adhere to the laws regarding working hours and shifts for all personnel, in accordance with the position held and the needs and agreements between the company and the employee. Likewise, DO will make payments in accordance with these working hours and shifts, respecting the country’s laws concerning additional payments for holidays worked, overtime, and any other compensation applicable.
Any individual may suggest or report issues related to the working conditions and hours.
For this purpose, they may contact Human Resources or write an email to: tescuchamos@do.cr. Suggestions or reports must be followed up according to the guidelines established in this document.
Diversity, Inclusion, and Non-Discrimination
At DO, we promote diversity and inclusion, striving to attract and retain talent that shares the same rights and opportunities. Therefore, we prevent, discourage, avoid, and sanction all discriminatory behavior against any person. Our policy is to not discriminate for any reason, including but not limited to: origin, ethnicity, marital status, age, opinions, gender, creed, tribal or union association, social or economic class, health condition, family situation, pregnancy, sexual identity, disability, illness,
nationality, or migration status.
All employees have the right to freedom of speech, peaceful assembly and association
(e.g., unions), and the right to participate in governance.
Additionally, they are entitled to fair evaluations and compensation based on their work and performance. Training, development, and growth plans will be defined impartially and in accordance with individual performance.
DO will allow all individuals the freedom to take actions, form associations, or any other initiatives in support of minority groups, such as the LGBTIQ+ community, diverse ethnic groups, elderly people, among others, applying the principle of non-discrimination in all processes.
When a customer or supplier makes an invitation that involves travel out of town or to attend a sporting or other entertainment event, senior management should be consulted to evaluate the business justification for attendance.
Harassment, Violence, and Bullying
We are committed to promoting and maintaining a work environment in which all employees are respected and treated with dignity. We reject, condemn, prohibit, and denounce all forms of harassment, violence, and bullying, as well as any other activity that undermines the dignity of our employees and third parties both inside and outside our workplace.
Harassment or bullying can manifest in different forms (sexual, workplace, emotional, or physical) and directions (among people in different hierarchical levels), for example:
- Horizontal: Occurs between colleagues at a similar level in the organization’s hierarchy.
- Vertical downward: Occurs between individuals in higher hierarchical positions relative to the victim.
- Vertical upward: Occurs between individuals in lower hierarchical positions relative to their organizational superiors.
It may also manifest in various conducts or situations, such as:
1. Verbal, written, or physical threats that undermine the dignity, emotional or physical integrity of the victim.
2. Controlling tasks through excessive and unjustified monitoring, aiming to cause work-related and/or emotional harm.
3. Spreading verbal or written rumors that harm an individual’s personal or professional reputation.
4.Publicly discrediting someone by unjustifiably attributing errors to them.
5. Exerting pressure or overloading tasks without any justifiable or reasonable cause. In contrast, showing favoritism, sidelining other individuals or deliberately limiting their learning or development opportunities.
6. Shouting, insulting, or inappropriately criticizing personal or private matters.
7. Repeatedly ignoring someone’s presence and prohibiting other employees from interacting with them.
8. Unjustly preventing or restricting access to work equipment.
9. Exhibiting clear discrimination based on sex/gender, age, race, nationality, religion, union affiliation, or other reasons.
10. Unjustifiably denying tasks, or assigning tasks that are excessive or beyond the employee’s knowledge or skills.
11. Overloading or assigning unnecessary or inferior tasks.
12. Unjustifiably obstructing promotions, appointments, trainings, vacations, and other opportunities.
13. Unjustifiably obstructing promotions, appointments, trainings, vacations, and other opportunities.
14. Assigning degrading tasks, incompatible with the employee’s role, or keeping the employee without tasks.
15. Creating tasks within the work unit that lead to workplace isolation.
16. Making structural and functional changes without justification to facilitate
dismissal, transfer, or job changes.
17. Ridiculing individuals for any reason.
Any individual who is a victim or witness of any type of harassment is responsible of reporting the event, following the guidelines established in this document and by emailing: tescuchamos@do.cr. This email is received by multiple people simultaneously to ensure a timely follow-up.
The company will not take any form of retaliation (threat, harassment, suspension, demotion, discrimination, or unfounded dismissal) against those who cooperate in any investigation.
Anti-Corruption
Do will comply and enforce the laws, regulations, and ordinances of the country in which it operates, as well as this code, company policies, norms, and procedures. Bribery and extortion practices are strictly prohibited, condemned, sanctioned, and reported, serving as an example of a culture of legality.
We will conduct business with clients or suppliers who share our ethical values and possess a solid reputation.
In any activity within or outside of the company, or on its behalf, we do not engage in, order, authorize, promise, conspire, induce, or assist anyone in corrupt practices, either directly or through a third party.
Clients and suppliers will be treated equitably and honestly in every interaction, providing them with the highest quality products and services in a timely manner, always adhering to internal regulations and any legal and acceptable business practices.
We do not make false or misleading comparisons with products or services equivalent to those offered by competitors.
Conflict of Interest
A conflict of interest arises when personal, familial, private, or any other type of interests affect or could affect the ethical conduct of the employees, or benefit them directly or indirectly from such interests. Therefore, at DO:
- We do not participate in or influence decision-making processes related to hiring businesses or companies owned by family members or friends.
- We do not have interests or investments that allow us to have significant influence in our competitors’ businesses.
- Those of us who perform surveillance, supervision, auditing, or control over an area managed by a family member must inform our superior to be relieved of that responsibility.
- We do not intercede or fulfill requests from superiors, subordinates, coworkers, family members, or friends if doing so harms the company or other employees.
- We only accept or offer promotional gifts and occasional courtesies as long as their value is symbolic and they are authorized by the company and its authorized representatives.
- We do not receive, pay, offer, promise, or authorize in the name of the company or personally any money, gifts, advantageous conditions, salaries, trips, commissions, or any other form of compensation to influence a business decision or to obtain any type of advantage or benefit.
- When a client or a supplier extends an invitation that involves travel outside the city or attendance at a sporting or any other entertainment event, it must be consulted with senior management to evaluate the commercial justification for attendance.
Information and Asset Management
We acquire, handle, protect, and preserve information as a company asset responsibly, ethically, and in accordance with the applicable laws of the country where we operate and the systems established by management.
Those who, due to their responsibilities within the company, have access to privileged and confidential information must comply with the internal laws and policies, with the PLTI-01 Information Security and ICT Policy. They must also take necessary measures to prevent the disclosure or leakage of such information to unauthorized people.
Personal data will be obtained and handled responsibly, ethically, and in compliance with the privacy laws applicable in the country where we operate.
No confidential information, including trade secrets, intellectual property, processes, methods, strategies, plans, projects, technical data, market data, or any other type of information, will be disclosed.
No comments about company activities that could harm the company or its members will be made, whether in familial settings or on social media.
We recognize the shared responsibility of all company members in protecting and preserving the security of information managed through the technological resources of the company.
Everyone is responsible for protecting and preserving the assets of the company and using them efficiently to contribute to the achievement of business objectives.
Responsibilities
Employees
- Know and comply with the Code of Ethics and internal policies
- Report any potential violations of the Code of Ethics
- Know and use the Reporting System if necessary
Senior Management
Complaint System
- Know the Code of Ethics and internal policies
- Ensure that the employees know and comply with the Code of Ethics and internal
policies. - Support the employees in clarifying doubts or comments and resolving challenges that arise while interpreting or applying this code.
- Report any potential violations of the Code of Ethics
- Know and use the Reporting System if necessary
Our company takes any report of illegal practices or inappropriate conduct within the
organization seriously. Therefore, any employee may file a report through the Human
Resources department or via our email: tescuchamos@do.cr.
Depending on the individuals involved, employees may also submit their reports through a member of senior management.
Human Resources will proceed, within the next 3 business days following the report, to take statements from the complainant, the accused, and witnesses. The case will be reviewed, and if necessary and applicable, appropriate disciplinary actions will be determined with Management. In addition, depending on its complexity, the case may be escalated to an external labor law specialist. This excludes situations where General Management is directly involved, in which case the matter will be escalated to the relevant entities to ensure that no conflict of interest exists.
For any report, it is important to provide at least the following information:
- Names of the individuals involved (complainant and alleged responsible parties)
- Evidence and names of witnesses, if applicable, of the violations or misconducts
- Witnesses must express, in writing (email is acceptable), their willingness to cooperate with the case.
- Detailed description of the facts or conducts that allegedly occurred, including a sequence of events, time, and place
- Dates and other relevant information about the events
Failing to report a known violation of this code (or any other policy), or making a report without a basis or showing defamatory, injurious, or slanderous conduct, can result in disciplinary action up to and including dismissal without employer liability.
Similarly, the company commits to not retaliating against any employee who files a report or anyone who participates as a witness in the investigation. The company will only terminate employment when justified, in accordance with Article 81 of the Labor Code or any other legal established resolution.
Precautionary Measures and Their Application
Within this procedure, the following precautionary measures may be applicable:
1. The accused person may be removed from their position with pay.
2. The accused person may be transferred to a location different from where they
usually perform their duties.
3. The precautionary measure may also include preventing the accused from approaching or communicating in any way with the complainant and the offended party, as well as with the complainant’s witnesses.
If the complainant, as the offended party, requests the application of a precautionary measure, the appropriate management department will resolve this request within three business days.
All precautionary measures must be duly substantiated by the appropriate management.
The precautionary measure must be resolved as a priority, ensuring the security of the complainant.
Any precautionary measures must be endorsed by legal advisors or applicable laws.
In cases where the alleged offender is a direct employee of a DO client, DO’s legal advisors will formally notify the client so they can take the appropriate actions.
Legal Compliance
DO Gestión de Talento is committed to conducting its operations in strict accordance
with local legislation. To ensure the best guidance and advisory in our daily interactions
with clients and employees, we maintain permanent legal counsel.