Code of Ethics and Professional Conduct
Integrity, independence and absolute fairness in every consulting engagement — in Brazil and abroad.
Introduction
WAO Consultoria commits to every client to conduct its work with integrity, independence and absolute fairness. This Code sets out those commitments in a public and verifiable way.
WAO works in new market development, sales and service management, sales team development and market research. In all of this work, the client entrusts the consultancy with information, people and strategic decisions.
Client trust is the most valuable asset of the relationship — and it is what this Code protects.
Scope
It applies to the lead consultant and to any partners, associates, collaborators and subcontractors acting on behalf of WAO, on any project, in Brazil or abroad.
Link to our proposals
It accompanies every WAO commercial proposal and is incorporated by reference into signed contracts. In case of conflict with local law, the rule most protective of the client and the public interest prevails.
Core principles
Six principles guide every WAO decision, from the first commercial contact to the close of the project.
Integrity
Telling the client the truth, even when it is uncomfortable or runs against initial expectations.
Independence
Recommendations based solely on the client’s interest, free from the influence of third parties, suppliers or personal gain.
Confidentiality
Protecting all information received, during and after the project.
Transparency
Scope, timelines, fees and limitations communicated clearly and in writing.
Competence
Accepting only work for which WAO has the qualifications and capacity to deliver.
Respect
Treating everyone involved with dignity, especially the client’s employees.
Commitments to clients
On every project, WAO formally undertakes the ten commitments below.
- Honest proposalsSubmitting only proposals that WAO can genuinely fulfil, without promising results that depend on factors beyond its control.
- Clear scope and feesDefining scope, deliverables, timelines, fees and reimbursable expenses in writing before work begins. No additional charges without the client’s prior approval.
- ConfidentialityKeeping all of the client’s strategic, commercial, financial and personnel information confidential, during the contract and indefinitely after it ends.
- Restricted use of informationUsing client data only for the purpose of the project. Never using it for WAO’s own benefit or that of another client.
- No hidden compensationAccepting no commissions, bonuses or benefits from suppliers, partners or providers recommended to the client. Any business relationship with a recommended party will be disclosed in writing.
- Respect for the client’s teamConducting assessments, evaluations and training in a respectful and fair way, based on objective criteria, preserving the dignity of every employee.
- Non-solicitationNot hiring or soliciting the client’s employees during the project and for 12 months after it ends, unless expressly agreed.
- Client autonomyRecommend, not decide. Management decisions always belong to the client, and WAO will present risks and alternatives so the client can decide with full information.
- Knowledge transferDocumenting methods and deliverables so the client can carry the work forward without unnecessary dependence on the consultancy.
- Disclosure of limitationsPromptly reporting any fact that could compromise the timeline, quality or objectivity of the work.
Integrity of data, indicators
and recommendations
The figures WAO presents to the client reflect reality, even when the results are unfavourable to the project or to the consultancy itself.
- Stated sources. Every data point, indicator or market study will state its source, reference period and calculation method.
- No manipulation. No indicator will be omitted, cherry-picked or presented so as to suggest a conclusion the data does not support.
- Explicit assumptions. Projections and estimates will always come with their assumptions and degree of uncertainty.
- Prompt correction. Errors found in work already delivered will be reported and corrected as soon as they are detected.
- Independent professional opinion. In KPI and management meetings, WAO will stand by its professional assessment, even when it differs from the position of the client’s managers or departments.
Anti-corruption, conflicts of interest
and international work
WAO has zero tolerance for corruption and discloses any conflict of interest before it can affect the work.
Anti-corruption
- Never offering, promising, paying or accepting any undue advantage, directly or indirectly, to or from public officials or private parties.
- Neither giving nor receiving gifts or hospitality that could influence decisions. Courtesies of token value are allowed when consistent with the client’s policy.
- Complying with Brazilian anti-corruption law and, where applicable, foreign regulations:
Conflicts of interest
- Disclosing in writing, before engagement or as soon as it arises, any relationship with competitors, suppliers or people involved in the project.
- Not serving direct competitors on the same scope at the same time without the knowledge and express consent of both.
- Declining or ending the engagement when a conflict compromises the consultancy’s independence.
International work
- Complying with the laws of the country where the service is provided and with Brazilian law, always applying the stricter rule.
- Respecting local culture, customs and business practices, without this ever justifying any departure from the commitments in this Code.
- Observing international sanctions and trade restrictions that apply to the client and to the markets studied.
Data protection and
intellectual property
WAO processes personal data only to the extent the project requires and recognises the client’s ownership of its information.
Data protection
- Processing in line with Brazil’s LGPD (Law No. 13,709/2018) and, abroad, applicable local law such as the EU GDPR.
- Secure storage, with access limited to those working on the project.
- Return or deletion of data at the end of the contract, as the client directs, keeping only what the law requires.
- Immediate notice of any security incident.
Intellectual property
- Data and documents provided by the client remain its property.
- Deliverables produced for the client may be used freely by the client, as set out in the contract.
- WAO’s own methodologies, tools and templates remain WAO’s property.
- Client cases and results are cited publicly only with prior written consent.
Enforcement, reporting channel
and review
Any client, client employee or partner may report a possible breach of this Code, with guaranteed confidentiality and no retaliation.
Statement of commitment
I declare that I conduct, and will continue to conduct, all WAO Consultoria engagements in accordance with this Code of Ethics and Professional Conduct, and that I am personally accountable for compliance with it.
Take this Code with you
The PDF version accompanies our commercial proposals and can be attached to your company’s supplier records.