Code of Ethics
Message from Managing Partners Diego Serebrisky and Rogelio De los Santos:
At Dalus Capital (“Dalus”), we understand that the actions of each of our members impact the firm's reputation. For this reason, it is critical that our team act at all times in accordance with the values that have been established. These values are an essential part of Dalus, and they distinguish us in the way we create our culture, make decisions, and do business.
We have designed this code of ethics to ensure that these values are clear and easily accessible to all members and collaborators of this company. This document serves as a guide to follow when making or reviewing decisions.
At Dalus, we are committed to following the obligations described in this code at all times. We also commit to taking action when events occur that are inconsistent with these values. We invite you to read this document and become familiar with our principled way of thinking and doing business.
Content
Our code of conduct is divided into 5 sections:
our responsibility to our stakeholders, our philosophy, our values and guidelines, sexual harassment policy, and our responsibility for code compliance.
1. Responsibility
with our Stakeholders
Investors
We are committed to investing our investors' funds responsibly and achieving the best returns possible. It is also our responsibility to keep them informed in a timely manner about relevant events and to incorporate their opinions into our decision-making process.
Our Team
We continuously strive to create a positive work environment that fosters both personal and professional growth.
Entrepreneurs and Startups within Our Portfolio
We are dedicated to supporting and aiding the growth of the companies we have invested in, always considering the founders' missions.
Other Investment Funds and Players in the Entrepreneurship Ecosystem
It is important for us to maintain good relationships with other funds and key players in the entrepreneurship ecosystem and to collaborate with them to drive the growth of both the industry and the ecosystem.
The Private Equity Industry
We are committed to acting in a manner that benefits the industry as a whole and creates conditions for its continued growth in the future.
Society
Through our investments, we aim to positively impact the communities where they operate, stimulating local economies and generating quality jobs. We invest in companies that directly or indirectly meet community needs and enhance the quality of life for their residents.
2. Our Philosophy
Vision
Support the best entrepreneurs who are leveraging technology to build scalable solutions. We seek that with our capital and experience, these companies can scale their businesses nationally, regionally, and in some cases globally, becoming recognized as leaders within their category as success stories in the region.
Mision
Create value for our investors and society, being the leading fund that boosts venture capital funds in Latin America, helping companies, founders, and consumers in the region.
3. Our values
and Guidelines
Respecting the right to nondiscrimination
Every person has the right to be free from discrimination based on gender, race, ethnicity, religion, sexual orientation, or any other characteristic inherent to their nature. We have the responsibility to create a work environment where equal opportunities are provided to all people, ensuring fair treatment, valuing their differences, treating them fairly, respecting their freedom and their right to privacy.
Acting with integrity
Integrity is one of the main pillars of our business relationships.
It is essential to us that: i).we are congruent in our thinking, speaking, and acting, seeking good and, ii)we rigorously defend our unspotted and proper image, and iii)we seek to understand the long-term consequences of our actions.
Integrity in our business processes implies that our success derives from our individual and collective ability to create, and never from manipulation, deception, or corruption of any kind, whether direct or indirect, or other unethical practices.
Acting with integrity implies recognizing our mistakes, learning from them, and making an effort to implement continuous improvement processes.
Maximizing trust-building
Business happens at the speed of trust; therefore, we always strive to ensure that our actions contribute to building trust among stakeholders and our society, seeking to generate transparency and a solid foundation on which we can build relationships and companies that will last.
Keeping our promises
Acting ethically means keeping our promises, regardless of the absence of a legal obligation to do so.
The following are examples of promises that could be made, which are common in the industry:
– Do sufficient research about the company, its key officials, competition, and industry (due diligence) before making an investment
– Follow up on the promoted companies trying at all times to encourage their development through ethical and honest practices
– Generate periodic and comprehensive reports to investors on portfolio performance and important developments
Acting ethically also involves making reasonable promises given the circumstances and the information available to us. If we are not confident that something can be delivered, we do not promise to deliver.
Finally, it is important to note that all promises are of equal importance, no matter to whom they are made. We must deliver to investors, portfolio companies, co-investment funds, and other stakeholders
Disclosing conflicts of interest
A conflict of interest occurs when an individual or group of people has a duty that is wrongly influenced by a secondary interest of an economic and/or personal nature.
In this case, conflicts of interest can occur between several groups:
– Between several funds
– Between the general partner and limited partners
– Between several limited partners
– Between the fund and the other co-investors of a company in the fund’s portfolio
Conflicts of interest limit the effectiveness of the fund and often lead to dissatisfaction among one of the stakeholders. We recognize the importance of this issue, and we are committed to doing everything possible to avoid this type of situation.
These are some of the measures we take to avoid or deal with conflicts of interest:
– Act impartially when analyzing conflicts of interest
– Report general partner conflicts of interest to limited partners promptly and clearly
– Provide limited partners with an adequate channel for reporting conflicts of interest
Ensure that all stakeholders understand the significance and implications that conflicts of interest could have.
Acting fairly
This involves complying with the rules and taking all stakeholders into account when making decisions. We strive to make all transactions, negotiations, and other business processes transparent and abide by the law. In all business processes, we value the interests of other stakeholders and strive to ensure that they are done fairly.
To ensure that the interests of the various groups are taken into account in the fund’s decision-making, we make sure that everyone has adequate representation on the advisory and investment committees. We also ensure that equal weight is given to the interests and opinions of the various stakeholder groups.
Maintaining Confidentiality
In the normal course of our operations, we acquire sensitive information from companies and limited partners of the fund. We are committed to keeping this information confidential and not disclosing it without explicit permission from those involved.
We also make sure that we let people know when we are giving them confidential information. When presenting information about a company to limited partners, we inform them that the information is sensitive and should not be disclosed. In this way, we protect both the company and the people to whom the data is being shared.
Acting in the best interest of the industry
Success in this area requires having a competitive advantage. While the pursuit of competitive advantage is not in itself prejudicial to the industry, it can lead to a loss of a sense of ethics and thus affect other stakeholders.
With this in mind, we are always mindful of our actions’ effects on the rest of the private equity industry. We always act responsibly and balance the pursuit of success with the good of companies, consumers, and other investors.
4. Sexual Harassment Policy
We define harassment and sexual harassment as:
(a) Harassment, the exercise of power in a relationship of real subordination of the victim towards the aggressor in the workplace, which is expressed in verbal or physical conduct, or both; and
b) Sexual harassment, a form of violence in which, although there is no subordination, there is an abusive exercise of power that leads to a state of defenselessness and risk for the victim, regardless of whether it takes place in one or several events.
Sexual harassment and harassment are also defined as sexual motivation and content, developed in the professional environment, in physical, verbal, gestural, or written form by a Dalus employee of any hierarchy, to another individual belonging or not to Dalus, of the same or another sex, who has neither expressly nor tacitly requested it.
Dalus employees have the right to work in a healthy, safe environment that guarantees the physical, mental, and social well-being of the employees and the moral integrity of each one.
None of Dalus employees, at any level, shall abuse his or her power or threaten or imply that an employee’s refusal to submit to unwelcome sexual inducements or solicitations will negatively affect that person’s employment, compensation, promotion, assigned responsibilities, or any other term or condition of the employee or career development.
Any Dalus employee who, after a confidential, diligent, and thorough investigation of a reported sexual harassment, is found to have engaged in sexual harassment of any kind by another Dalus or non-Dalus employee will be subject to at least severe disciplinary action and up to and including possible termination of employment.
Dalus will in no way retaliate against anyone who makes a report of sexual harassment. Retaliation is a severe violation of this policy and should be reported immediately. Any Dalus employee who retaliates against another person for reporting sexual harassment will also be subject to at least severe disciplinary action, up to and including termination of employment.
5. Our Responsibility
for Code Compliance
Each member and collaborator of Dalus has the responsibility to know and understand this code and the consequences of its non-compliance. We must ensure that we always act by the values we have established and always keep these in mind when making decisions.
At Dalus, we have zero tolerance for unethical conduct. The members of this group have the obligation not only to act ethically but also to report when they perceive a breach in this code to any member of the investment and/or management team.
Dalus undertakes to take action when acting inconsistently with the values established in this document and to make the necessary corrections so that the breach is not repeated.
Beyond imposing a set of rules, our goal is to create a professional environment in which people act ethically on their initiative. This type of environment will help us achieve success with integrity and responsibility.