Policies

 

Dividend Policy

Cyrela intends to declare and pay dividends and/or interest attributable to stockholders’ equity, in each fiscal year, in amounts equivalent to approximately 25.0% of its adjusted net income, in accordance with the Brazilian Corporate law.

The declaration of annual dividends, including dividends in excess of the minimum mandatory dividend, requires approval by a majority vote of the holders of Company’s common shares and will depend on many factors. These factors include their results of operations, financial condition, cash requirements, future prospects and other factors deemed relevant by their board of directors and shareholders. Within the context of their tax planning, they may in the future determine that it is to their benefit to distribute interest attributable to stockholders’ equity.

Pursuant to rules of the Novo Mercado, the Company’s capital stock has to be represented exclusively by common shares and, therefore, they are not allowed to issue preferred shares. On May 25, 2005, their shareholders’ meeting approved, among other items: (i) the conversion of all of their preferred shares into common shares, on a 1:1 basis; and (ii) the amendment of Cyrela’s by-laws in order to comply with all the requirements of the Novo Mercado. On July 29, 2005, the Company entered into an agreement with BOVESPA providing for the listing of their common shares on the Novo Mercado.


History

The table below shows the dividend and interest on shareholders’ equity distributed to Cyrela shareholders for the periods indicated.
         
Payment Date Action Common Shares CYRE3
(R$ per share)
Preferred Shares CYRE4
(R$ per share)
Dividends
(R$ million)
06/27/14 (-) Paid dividends 0.423071   170.723
06/28/13 (-) Paid dividends 0.125576   52.041
06/28/13 (-) Paid dividends 0.378324   156.785
06/27/12 (-) Paid dividends 0.288105   118.316
06/24/11 (-) Paid dividends 0.337021   142.559
05/11/10 (-) Paid dividends 0.470341   198.906
05/11/09 (-) Paid dividends 0.185395   65.955
05/16/08 (-) Paid dividends 0.040978   14.574
09/25/07 (-) Paid dividends 0.168709   60.000
05/10/07 (-) Paid dividends 0.085152   30.183
12/13/06 Split 2 in 1 CYRE3
10/31/06 (-) Paid interest on equity 0.180554   32.000
04/26/06 (-) Paid dividends 0.268982   40.000
2005 CYRELA entered into an agreement with BOVESPA providing for the listing of the common shares on the Novo Mercado; preferred shares were converted into common shares.
08/16/05 (-) Paid dividends 0.381382 0.419519 32.000
12/23/04 (-) Paid dividends 0.214526 0.235980 18.000
06/08/04 (-) Paid dividends 0.093820 0.103200 7.805
05/30/03 (-) Paid dividends 0.134270 0.147690 11.266
03/18/02 (-) Paid dividends 0.238354 0.262189 20.000
03/07/01 (-) Paid dividends 0.251404 0.276540 20.000
06/23/00 (-) Paid dividends 0.129240 0.142160 9.858


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Disclosure Policy

I –Definitions Applicable to this Policy

AI –Definitions Applicable to this Policy - The definitions used in this Disclosure Policy will have the following meanings:

Stock Exchanges – It means the São Paulo Stock Exchange – Bovespa and any other stock exchanges or organized trading markets in which the Company has Securities admitted for trading.

Company – It means Cyrela Brazil Realty S.A. Empreendimentos e Participações.

CVM – It means the Brazilian Securities and Exchange Commission.

Investor Relations Officer – It means the Company’s officer elected to exercise the attributions provided for by CVM regulation and designed to check and supervise the compliance with the Disclosure Policy.

Material Information – It means any controlling shareholder decision, resolution of the General Meeting or the management bodies of the Company or any other political-administrative, technical, business or economic-financial character act or fact taken place or related to the Company’s business, which may considerately influence (i) quotation of Securities; (ii) investors’ decision to buy, sell or maintain Securities; or (iii) the determination of investors to exercise any rights inherent to the condition of holders of Securities. Examples of situations which may represent Material Information are found in the Article 2 of CVM Instruction 358/2002.

Related Persons – It means the Company, its direct and indirect controlling shareholders, Officers, members of the Board of Directors and the Fiscal Council and any other bodies with technical or consulting functions, controlled companies and/or companies under common control and respective controlling shareholders, members of the management and bodies with technical or consulting functions who have expressly adhered to the Disclosure Policy and are obliged to comply with the rules described herein. Other persons who the Company considers convenient may adhere to this Disclosure Policy, acquiring the condition of Related Persons.

Disclosure Policy – It means the Disclosure Policy of Material Information and Confidentiality Preservation.

Securities – It means shares, debentures, subscription bonus, subscription rights and receipts, promissory notes issued by the Company and derivatives referring to any of these Securities.

 

II – Purpose

The purpose of this Disclosure Policy is to set forth rules which shall be complied with by the Investor Relations Officer and other Related Persons concerning the disclosure of Material Information and the confidentiality maintenance on the Material Information which has not been disclosed to the public yet. The Company’s Disclosure Policy was elaborated under the terms of CVM Instruction 358/2002.

Any doubts on the provisions of this Disclosure Policy, the applicable regulation published by the CVM and/or on the necessity to disclosure or not certain information to the public must be clarified jointly with the Investor Relations Officer.

 

III – Compliance

The Related Persons must comply with this Disclosure Policy, in addition to the Company’s managers and employees who have frequent access to Material Information and other persons who the Company considers necessary or convenient.

The Company will maintain in its headquarters the list of Related Persons and their respective qualifications, indicating position or function, address and Individual Taxpayer’s Register (CPF) and/or Corporate Taxpayer’s ID (CNPJ), always updating it whenever there is any change.

 

IV – Duties and Responsibilities

The responsibilities of the Company’s Investor Relations Officer are the following:

(i) to disclose and inform to the CVM and the Stock Exchanges, immediately after his/her knowledge, any material act or fact taken place or related to the Company’s business which is considered Material Information;

(ii) to care for the wide and immediate dissemination of Material Information simultaneously on the Stock Exchanges and in all markets where the Company has Securities admitted for trading, as well as to the general investing public.

The disclosure of Material Information to the CVM and the Stock Exchanges must be made immediately by means of a written document, describing with details the acts and/or facts taken place, indicating, whenever possible, the amounts involved and other clarifications.

The Material Information must be disclosed to the public by means of a notice published in the newspapers used by the Company. This notice may contain the summarized description of the Material Information, as long as it indicates the Internet address where the complete description of the Material Information is available, in content at least equal to the text sent to the CVM and the Stock Exchanges.

Whenever Material Information is spread by any means of communication, including information to the press or at meetings of class entities, investors, analysts or with selected public, in Brazil or abroad, the Material Information will be simultaneously disclosed to the CVM, the Stock Exchanges and the general investing public.

Any Related Person who has knowledge of acts or facts which may represent Material Information must immediately inform the Investor Relations Officer.

The Related Persons who have knowledge of Material Information, whenever they confirm any omission in the disclosure of Material Information, after three (3) business days from the receipt by the Investor Relations Officer of written and recorded communication sent by a Related Person, without any manifestation on the account of the Investor Relations Officer, must inform the Material Information directly to the CVM, always complying with the provision in the Section V below.

The Material Information must, preferentially, be disclosed before the beginning or after the closing of trading on the Stock Exchanges. Should the Stock Exchanges not be simultaneously operating, the disclosure will be made complying with the trading hours of the Stock Exchanges located in Brazil.

 

V – Exception to the Immediate Disclosure of Material Information

The acts or facts which constitute Material Information may not be disclosed should its disclosure pose risk to the Company’s legitimate interest, confirmed by the Investor Relations Officer.

The Company may decide to submit to the appreciation of the CVM matters on the disclosure to the public of Material Information which may pose risk to the Company’s legitimate interest.

Whenever the Material Information still not disclosed to the public becomes known by several persons who (i) had originally knowledge; and/or (ii) decided to maintain the Material Information confidential, or, should be verified that an unusual fluctuation in the quotation, price or number of traded Securities took place, the Investor Relations Officer must provide for the Material Information to be immediately disclosed to the CVM, the Stock Exchanges and the public.

 

VI – Obligation to Maintain Material Information Confidential

The Related Persons must maintain confidentiality on Material Information which has not been disclosed yet, to which they have access due to post or position they hold, until such material information is disclosed to the public, as well as to manage that reliable subordinated persons or third parties also do the same.

Even after its disclosure to the public, the Material Information must be considered as undisclosed until the market participants have received and processed the Material Information in a reasonable time.

The Related Persons must not discuss Material Information in public places. Accordingly, the Related Persons must only talk about issues related to the Material Information to those who have the necessity to know the Material Information.

Any violations of this Disclosure Policy verified by Related Persons must be immediately informed to the Company by the Investor Relations Officer.

Should any Related Person verify that some Material Information still not disclosed to the public became known by several persons who (i) had originally knowledge; and/or (ii) decided to maintain the Material Information confidential, or, also, that an unusual fluctuation in the quotation, price or number of traded Securities took place, such facts must be immediately informed to the Company by the Investor Relations Officer.

 

VII – Penalties

The Related Persons are obliged to respect and comply with all the provisions in this Disclosure Policy. Its noncompliance is subject to the penalties provided for by the applicable regulation.

Please click here to access the pdf version of the “Disclosure Policy of Material Information and Confidentiality Preservation of Cyrela Brazil Realty S.A. Empreendimentos e Participações”.


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Privacy Policy

Cyrela Brazil Realty’s Privacy Policy was created to reaffirm its commitment to the safety and privacy of information collected from the users of Cyrela Brazil Realty’s interactive services. You may visit this website and get acquainted with the services the Company offers, read reports, obtain news and information without having to provide any personal information. However, should such be the case, this policy purposes to clarify how the Company collects and handles your personal data. Since this policy is subject to occasional updating, Cyrela Brazil Realty advises it be regularly consulted.

1. Any information provided by the users shall be collected and stored according to strict security and reliability patterns.

2. Personal data provided by the users shall be collected through ethical and legal means. Such collection may have one or more targets about which users shall be informed.

3. Users shall be advised that their data is being collected and they may choose whether they want to provide it or not, they will be further advised about the consequences of their decision.

4. Unless a legal or judicial order is issued, information provided by users shall never be disclosed to third parties or used for purposes other than those for which it was collected.

5. Access to collected information will be restricted to employees authorized to adequately use such data. Employees that unduly use such information, infringing Cyrela Brazil Realty’s Privacy Policy, shall be subject to the penalties provided by its discipline procedure.

6. Cyrela Brazil Realty shall maintain the integrity of the information provided through this website.

7. This website contains links or frames for other sites, which may or may not be Cyrela Brazil Realty partners and allies. These links and frames are available merely in the hopes of providing yet another benefit to the users of this website. Note that including these links and frames does not mean that Cyrela Brazil Realty has full knowledge, agreement, or responsibility for those frames and links or for their respective content. Therefore, Cyrela Brazil Realty can not be held responsible for any type of damage caused by the use of the referred links and frames.

8. Cyrela Brazil Realty requires´ any third parties hired to perform support services to adhere to its privacy standards.

9. If it is necessary, the Company may use cookies(*) to confirm your ID, personalize your access and to check the use of Cyrela Brazil Realty’s website aiming at improving its navigating and functioning conditions.

10. Other important information on the terms and conditions of use of this site is available on Terms and Conditions.

(*) Cookie: small archive put into your PC to keep track of moves within the websites, such as visits to homepages and advertisements.


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Insider Trading Policy

A – Definitions and Applicability

1. The words and expressions listed on Appendix 1 to this Insider Trading Policy, whenever capitalized herein, shall have the meanings attributed to them on that list.

2. The Statement of Compliance with this Insider Trading Policy (pursuant to the draft included in Appendix 2) may be signed by the following people, who will become Bound Persons for the purposes provided for herein: the Company’s direct or indirect controlling shareholders; members of the Board of Directors, of the Supervisory Board, whenever instated, and of any other body with technical or consulting functions created under the Bylaws; managers and employees; subsidiaries and/or jointly-controlled subsidiaries and their respective controlling shareholders, management, and members of bodies with technical or consulting functions; service providers and other professionals of the Company with access to Material Information; and all other people the Company deems necessary or convenient, and who are interested in abiding by the terms of this Insider Trading Policy. The rules of this Insider Trading Policy also apply in cases where trading by Bound Persons occurs to their direct and/or indirect benefit by means of the use, for instance, of: (i) a company directly or indirectly controlled by them; (ii) third parties with whom they have executed a trust or management agreement; (iii) attorneys-in-fact or agents; (iv) spouses whom they are not legally separated from, partners, and any dependents included in the annual income tax return.

3. The Company will keep in its headquarters a list of Bound Persons and their respective qualifications, as well as their position or function, address, and Individual and/or Corporate Taxpayer's ID numbers, updating it whenever necessary.

B – Purpose

4. The purpose of this Insider Trading Policy is to set the rules that shall be observed by Bound Persons and by the Company for a transparent and orderly trading in Company Securities, preventing the inappropriate use of Material Information. This Insider Trading Policy was prepared under CVM Rule 358/2002.

5. Any questions that arise regarding this Insider Trading Policy shall be discussed with the Company’s Investor Relations Officer.

C – Prohibited Trading of Company Securities

6. Under CVM Rule 358/2002, Bound Persons shall not trade in Company Securities before Material Information is disclosed to the market.

7. Trading in Company Securities is also prohibited: (i) whenever there is the intention to promote a merger, partial or full spin-off, transformation or corporate reorganization of the Company; and (ii) regarding direct or indirect controlling shareholders and members of the Board of Directors, in the case of acquisition or sale of Company shares by the Company itself, its subsidiaries, affiliated companies or other companies under joint control, or if an option or warrant has been granted for that purpose, except as otherwise provided for in item 14 below.

8. In the case of a public offering for the distribution of Securities and under the provisions in article 48 of CVM Rule 400/2003, Bound Persons shall refrain from trading in Company Securities until the offering closing notice is published.

9. Bound Persons shall not trade in Company Securities in the 15 (fifteen) days prior to the disclosure of quarterly (ITR) or annual financial reports of the Company, except as otherwise provided for in paragraph 3 of article 15 of CVM Rule 358/2002 or in item 13 below.

10. Bound Persons that leave the Company prior to the disclosure of Material Information originating during their term of office shall not trade in Company Securities: (i) for the 6 (six) months following their leaving the Company; or (ii) until the Company discloses such Material Information to the market.

11. The Company's Board of Directors shall not resolve on the acquisition or disposal of Company shares if any agreement or contract aiming at the transfer of the Company's control has been entered into, or an option or warrant for the same purpose has been authorized, or if there is the intention to promote a merger, partial or full spin-off, transformation or corporate reorganization of the Company, and until such transaction is made public through the publication of a material fact.

12. Trading in Company Securities is no longer prohibited as soon as the Company discloses the applicable Material Information to the market. However, trading is prohibited even after the Material Information is disclosed whenever trading in Company Securities by Bound Persons may interfere with the act or fact associated with the Material Information in such as way as to harm the Company or its shareholders.

D – Authorized Trading In Company Securities

13. Under CVM Rule 358/2002, Bound Persons may trade in Company Securities in the period mentioned in item 9 above (black-out period), provided that such trading corresponds to the purchase of treasury shares, via private trading, resulting from the exercise of a call option pursuant to a stock option plan approved at a general meeting.

14. In the case mentioned in item 7(ii) above, trading is prohibited only in the periods during which the Company is acquiring or selling shares in a stock buyback plan, and such periods are the dates when the Company effectively buys or sells shares and the period of 5 (five) days prior to the date the Company buys or sells shares within such stock buyback program.

15. The restrictions in this Insider Trading Policy do not apply to trading by investment funds in which Bound Persons are shareholders, provided that these are not exclusive investment funds or investment funds whose trading decisions by the portfolio manager are influenced by Bound Persons.

E – Liability

16. Bound Persons that do not comply with any provision in this Insider Trading Policy assume the obligation to reimburse the Company and/or other Bound Persons, integrally and with no limitation, for all losses that the Company and/or other Bound Persons may incur and that arise, either directly or indirectly, from such noncompliance.

F – Amendment

17. All amendments to this Insider Trading Policy shall be approved by the Company’s Board of Directors and reported to the CVM and Stock Exchanges. This Insider Trading Policy shall not be amended if any Material Information is pending disclosure.

G – Third-party Liability

18. The provisions in this Insider Trading Policy do not suppress the liability of third parties not directly connected with the Company and who have Material Information.


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Code of Conduct

Message From the CEO

Dear Employee,

The basis for the development and strengthening of Cyrela, and which makes it one of the best and most admired real estate developers in Brazil, consists in its ethical conduct, and this is the culture we wish to share and reinforce through this document.

The company can only act in an ethical manner through the people that represent it, and on all levels, either inside or outside the organization.

This Code of Conduct consolidates the guidelines and behavior standards that we deem ethically correct, seeking to regulate the conduct and actions of all employees (regardless of hierarchic position), business partners, service providers and suppliers, establishing their ethical commitments to the company.

Therefore, we must carry out our activities in accordance with the binding ethical principles and rules provided in this Code and, with your special participation, improve and guarantee the image and reputation of the Company, which is renowned for the excellence and quality of its services.

We suggest that you dedicate some time to learn and assimilate this Code.

It is extremely important that you personally relate to our corporate culture in order for the organization to succeed in guaranteeing that ethics and integrity be the core elements of all its relationships and activities.

CEO

Vision, Mission and Values

VISION
Making a difference, being the best and most profitable company in the real estate development sector, with an ethical operation, committed to social and environmental development in Brazil.

MISSION

Offering the greatest value to its customers, shareholders, employees and to the community as a whole, with an operation based on principles, excellence and quality.

VALUES
The company believes in growth built on solid and ethical grounds.

Therefore, it is critical that it fosters and strengthens the practice of values exercised by the company since its foundation (which we call the Cyrela Culture). These values are:

Customer
Being more for the customer
Offering distinguished properties

Work
Being the owner
Focusing on results
There is always room for improvement
Ideas before hierarchy

People
Leaders creating leaders
Meritocracy
Everyone can grow
Respect for human beings and relationships

Continuity
Principles above all
Responsible use of resources
Financial solidity
Long-term relationships

Founding shareholder
Work and spirituality
Philanthropy


Relationship with employees

Transparency. Cyrela believes that transparency in its relationships with employees is critical for building an environment of mutual trust and responsibility on all levels of the company.

Discrimination. In the processes of recruitment and selection, training, compensation, promotion, dismissal, transfer or any other factors related to professional performance, Cyrela does not accept any form of discrimination in relation to ethnicity, age, gender, color, nationality, religion, sexual preference, physical or mental disability and/or any other classification protected by federal, state or municipal laws.

Harassment and emotional abuse. Cyrela does not tolerate any type of abuse, either emotional or sexual, or any conduct that may be characterized as offensive or embarrassing, and that causes any kind of pain and suffering to any employee.

Use of illegal labor. Cyrela does not tolerate the use of forced, compulsory or child labor, or any other means of exploitation that violate human dignity inside or outside the company. Therefore, Cyrela incorporates the Universal Declaration of Human Rights of the United Nations (UN) and the Statute of the Child and Adolescent to its principles and actions.

Political Parties. Voting for and association with political parties are personal choices of each employee, and cannot be induced in any way by hierarchic superiors or colleagues. In addition, the professional situation of an employee cannot be influenced, harmed or favored based on their political choice.

Alcohol and drugs. Cyrela enforces the government policy that prohibits the use of alcoholic drinks and illegal drugs, as well as being under their influence, during work hours and/or in the work environment. Since it is harmful to health and disturbing to non-smokers, smoking is not allowed in Cyrela's internal environments, pursuant to the legislation in force.

Integrity. Whenever an employee is representing Cyrela, in a professional or social situation, they must honor the principles of honesty and integrity expressed herein, not adopting postures or attitudes that may compromise the image, reputation and interests of the company.

Safety. Cyrela respects all rules relative to workplace safety and health, therefore the managers and other employees must commit to the procedures and instructions that regulate and preserve safety and health.

Company's assets. All employees are responsible for protecting and preserving the assets and properties of Cyrela, and no employee can take possession of the company's assets or resources, nor use them for their own benefit or to benefit third parties.

Preservation of Information. Each employee must guarantee that information owned by the company is duly protected and cannot be accessed by unauthorized people.

Use of electronic information media. All company information subject to disclosure is available on our website (http://www.cyrela.com.br and http://www.livingconstrutora.com.br), therefore the disclosure of any confidential information or internal document on the Internet is not acceptedl.

Employees must use the resources available for electronic communication solely and exclusively for professional purposes, within the legal requirements and in compliance with the ethical principles of this Code. Therefore, employees must not make libelous comments, use offensive language, images or files, or induce any kind of discrimination.

Integrity of the information. All employees are responsible for the safe and accurate information contained in the records and documentations that support Cyrela's activities and, therefore, must ensure the accuracy and fitness of data, as well as maintain the whole documentation in line with established procedures and legal/tax requirements.

It is important to bear in mind that these requirements help guarantee that Cyrela is being efficiently managed, and that the financial reports are providing shareholders with accurate and safe information about the company's financial performance.

Trading of Cyrela Shares. All Cyrela employees are responsible for protecting and keeping confidential any relevant information that the company has not disclosed to the market, in addition to not disclosing it or using it for their own benefit or the benefit of others, in compliance with Cyrela's Insider Trading Policy and the standards and sanctions issued by the Brazilian Securities and Exchange Commission – CVM.

Valuing people. Cyrela believes that its employees are critical for it to thrive as a company, and therefore it encourages their continuous development. Managers must use meritocracy as a criterion to promote the professional development of the company's employees.

Relationship with customers

Cyrela's relationship with its customers must be based on politeness and promptness; efficient service; respect to customer rights; transparency in the transactions conducted; receptivity and appropriate treatment of suggestions and criticism received; confidentiality of the information received; and always acting with dignity and loyalty, not providing deceitful or inaccurate information about the company's products.

It is forbidden to disclose information about customers, unless duly and formally authorized by the company's Marketing and Communication division or in response to a legal requirement.

Customers must have guaranteed access to communication channels qualified to receive any complaints, requests, suggestions and report.


Relationship with Suppliers and Business Partners

The contracting of suppliers and business partners must comply with technical and ethical criteria, and be based on the company's good standing, and its financial and professional capacity to deliver high-quality products at fair prices.

All employees must comply with the contractual and commercial conditions, and protect the secrecy of information established between Cyrela and its suppliers and business partners, which also commit to protect the conditions of mutual trust regarding confidentiality and contractual guarantees, under penalty of ending the commercial relationships.

Cyrela does not accept that, in dealing with suppliers and business partners, any employee will obtain personal advantage from the influence of their position in the company.

Business partners and suppliers contracted by Cyrela must comply with all laws in force, including labor, tax and environmental legislation, and cannot explore child or slave labor.

All suppliers and business partners must follow the principles established in this Code of Conduct. At any time, the supplier or business partner that ceases to meet the aforementioned requirements will be disqualified.

Relationship with shareholders

Cyrela respects the principle of equality in the treatment of its shareholders, its payment of dividends is transparent in the statement of economic and financial situation, and it is proactive in making information available through authorized employees.

Relationship with Labor Associations and Entities

Cyrela acknowledges and has deep respect for the important role performed by Labor Associations and Entities in its business. 

Cyrela and its employees must comply with the collective bargaining agreements applicable to the company's activities.

Communication and inter-relationship between the company and Labor Associations and Entities must only be performed by employees whose function is directly related to such activities, and those appointed by the Board of Executive Officers.

Relationship with Competitors

All employees must act in accordance with the principles of free competition.

Information must be obtained lawfully and with transparency, so as not to expose the business to competitors, preserving the confidentiality of any information known.

No employee is authorized to provide strategic or confidential information about the company, or information that, in any other way, may harm the company's business, to any third party, including, but not limited to competitors.

Relationship with Government and Regulatory Agencies

Cyrela maintains an ethical and transparent relationship with government and regulatory agencies, and does not tolerate any kind of assignment of advantages or privileges to public employees exercising their functions, as well as the payment, either in money, gifts, services or any valuable benefits, with the purpose of bribing or providing special treatment.

Communication between the company and government and regulatory agencies must only be performed by employees whose function is directly related to such activities, and those appointed by the Board of Executive Officers. 

Cyrela and its employees commit to comply with the legislation and to not perform any action that violates the laws and regulations in force.

Every employee, when publicly representing Cyrela, must abstain from expressing their opinion about actions performed by civil servants, or even from making any comments of a political nature.

Appointed employees must cooperate and be diligent in meeting procedures arising from requirements of any regulatory agency.

Relationship with the Press

Cyrela responds in a transparent manner to consultations requested by the press, financial institutions and authorities, always protecting its commercial interest and solely aiming at the institutional disclosure of products and services and at clarifying its actions.


Cyrela does not allow employees to give interviews to any press agency, or to have their image published in relation with matters regarding the company, without the authorization of Cyrela's Communication Committee.

Communication between the company and the press must only be performed by the Chief Executive Officer or a person authorized by such officer, through the Marketing and Communication division. 

Information internally disclosed by the company must be previously approved by Cyrela's Communication Committee, since every information disclosed by the company, either internally or to the press, must be aligned.

Relationship with the Environment

Cyrela complies with the Brazilian environmental legislation and supports initiatives and activities aiming at the country's sustainable development.

Cyrela believes in the importance of sustainable actions to preserve natural resources and protect the planet.

Employees must carry out their activities and projects with respect for the environment, following sanitary standards and regulations, so as not to harm the natural environmental balance.

Conflict of interest

There is a "conflict of interest" whenever an employee uses their influence or does something with the purpose of achieving personal interests that oppose the interests of Cyrela or that may cause damage or losses to Cyrela.

Acts or omissions resulting in the situations mentioned above are prohibited in all relationships involving employees and/or representatives of the company.

Privileges

No gift or entertainment should, under any circumstances, be used to inappropriately influence or compensate a decision, or seek any benefit for Cyrela.

Under no circumstances should employees offer privileges, bribes, or any similar type of payment, directly or indirectly, during the conduction of commercial activities or in any way.

These prohibitions apply regardless of whether the conduct involves government employees, private companies or individuals, and regardless of the amount involved.

Offering of gifts. When the amount of the gift or entertainment to be offered may be considered excessive, approval from the Board of Executive Officers is required. 

Acceptance of gifts. Regardless of the amount, employees cannot accept any gift or entertainment offered in situations where there is reasonable suspicion that such gift or entertainment intends to inappropriately influence the performance of the company's duties.

When a gift or entertainment is offered to civil servants or public authorities, it is necessary to follow even stricter guidelines, in compliance with laws against corruption, since there are significant legal restrictions that prohibit or limit such gratuities.

Ethics Committee

The Ethics Committee has the purpose of ensuring the applicability of and compliance with the Code of Conduct.

The attributions of the Ethics Committee include:

  • Promoting ethical behavior and the maintenance of the conduct standard throughout the company;
  • Ensuring the implementation and compliance with the Code and laws against corruption;
  • Ensuring the confidentiality of information received;
  • Ensuring that reports of violation be treated with exemption and in an unbiased manner;
  • Carrying out the necessary surveys to support the decisions on reports of violation received;
  • Realizar os levantamentos necessários para suportar as decisões sobre as denúncias de violações recebidas;
  • Analyzing and evaluating the violations reported and make the appropriate decision;
  • In the case of more severe violations, proposing the appropriate sanctions and forwarding them for the Board of Executive Officers to make a decision;
  • Evaluating the revisions made to the Code of Conduct, when required, and obtaining approval from the Board of Executive Officers. 

The Ethics Committee will be comprised of members appointed by the CEO, occupying positions in the Board of Executive Officers, Superintendency or Management in the following areas: Human Resources, Legal and Internal Audit.

The Committee will be coordinated by one of its members, and such members will take this position in turns, changing once a year.

The Committee has an annual tenure, which can be renewed.

Any and all revisions of the Code must be approved by the Board of Directors.

Violation of the Code

Each employee is responsible for learning the guidelines and orientations provided in Cyrela's Code of Conduct. Any violation of these guidelines and orientations will result in an appropriate disciplinary action, which can range from a warning to termination of employment, depending on the severity of the situation.


In the case of service providers and suppliers, violation of the company's Code of Conduct may result in immediate suspension of the Agreement and, when applicable, in a lawsuit.

All employees must immediately report any violation of this Code.

Omission of any possible violation, as it compromises the integrity and loyalty of relationships with the company, will also be deemed as unethical conduct, and lead to the same sanctions applicable to other violations.

Every information regarding possible ethical violations or illegal activities will be received and treated under confidentiality, and no retaliation will be accepted.

Cyrela undertakes to keep confidential the identity of those who report and/or participate in the investigation of violations of the Code of Conduct.

Any question, suggestion, complaint, criticism or accusation of non-compliance with the guidelines of the Code of Conduct must be submitted to the Ethics Committee, in writing, via the e-mail address to be provided by the company.

An updated version of the Code of Conduct is available on the website: www.cyrela.com.br.

Commitment and Compliance

The commitment of our employees is critical for the Code of Conduct to be a true instrument of and guide to their conduct on behalf of the company.  Everyone is responsible for its application in their professional routine.

Signing the Statement of Commitment, which is attached to this Code, is mandatory and expresses the employee's agreement to comply with the principles and guidelines contained herein.

Statement of Commitment

I hereby declare to have received, read and understood Cyrela's Code of Conduct, and I agree with the principles and guidelines provided therein, undertaking to comply with them in my professional activities.

All amendments deemed necessary by Cyrela will be automatically incorporated to this Code of Conduct and followed by me.