Code of Ethics

PT-BR VERSION

ENTOURAGE

INTRODUCTION

The year 2025 marks a symbolic milestone for Entourage: we are celebrating 15 years of activity. The challenges of managing artistic careers and producing events are increasingly demanding, and we celebrate our journey of steady growth and continuous efforts to improve our deliverables.

One of these efforts is represented by this Code of Conduct. It is part of programs such as Entourage Social and “Greentourage,” created to encompass several actions aimed at social impact and sustainability—one of our current and future priorities. To take a closer look at our impact on the environment and society, we must first reflect on the work environment we create and the attitudes we practice—and this document arises in that context. This Code is a fundamental tool for those working at Entourage as well as for all those working with the agency: temporary staff, contractors, suppliers, sponsors, business partners, and public agents. It serves as a compass that guides all professional conduct, whether it occurs inside or outside the organization.

Table of contents

ABOUT THIS CODE

Entourage is committed to conducting its operations in all areas with ethics, transparency, responsibility, honesty, integrity, and in compliance with the law. We have full confidence in everyone who is part of Entourage and in the individual and collective decisions made within the agency.

This Code of Conduct is intended to be a guide to direct the standards of behavior expected of shareholders, directors, executives, employees, and also temporary staff, contractors, suppliers, sponsors, business partners, and public agents. It sets out the behaviors that must be adopted to achieve our objectives while maintaining our reputation and reaffirming our strong commitment to our values and integrity.

Everyone working at Entourage receives training on this Code, which will be reviewed annually. You must read, understand, and comply with the practices outlined in this Code. While it may not cover every possible scenario or situation you might face in your professional routine, it also provides a pathway to follow when such situations arise.

If you witness or become aware of suspicious or unethical behavior that may violate this Code of Conduct or even the law, we count on your ability to act. We encourage and expect you to report such situations and provide various means for doing so.

If you do not feel comfortable reporting the situation or prefer to remain anonymous, visit our website and use the “Reporting Channel” section.

We ensure confidentiality and guarantee that no report will result in any form of retaliation. Please read this entire document carefully. For better understanding, we recommend reading it in two or three sessions of 10 to 15 minutes each. If, in your professional routine, you come across a situation that you consider inappropriate, unethical, or in violation of this Code, report it to your supervisor, one of the directors, or one of the company’s partners.

DEFINITIONS

PUBLIC AGENT

Any individual providing services to the State or to entities of the Indirect Public Administration.
Examples: inspectors, military, civil, or federal police officers, firefighters, municipal officials.

FRAUD

Deceptive or cunning means intended to deceive someone, circumvent the law or a contract to gain personal benefit.
Example: forging a signature on a contract.

CONFLICT OF INTEREST

A situation where personal interests conflict with the organization’s interests, whether real, potential, or apparent.
Example: giving preference to a relative’s company in a supplier selection process.

MONEY LAUNDERING

Any practice intended to conceal the illicit origin of money by giving it a legal appearance.
Example: a promoter declaring more tickets sold than were actually sold to legitimize illicit money.

CORRUPTION

Offering or receiving an undue advantage, usually conditioned on performing a certain act.
Example: a firefighter requiring event tickets to release a necessary document.

POLITICALLY EXPOSED PERSONS

Individuals who, in the past five years, have held or currently hold relevant public positions or functions in Brazil or abroad, including family members or close associates.
Example: a city’s Secretary of Culture.

BRIBERY

A form of corruption involving offering, promising, or paying an undue advantage.
Example: an employee requesting commission from a supplier to sign a contract.

ABOUT ENTOURAGE

We operate in commercial representation and career management of artists, talent import and export, and event production in the electronic music market since 2010, reaching both national and international markets with excellence.

Our specialty is connecting artists and audiences through the DJs we manage, and connecting people and music through the major festivals we produce. Quality, love for music, high-standard curatorship, experience, and innovation are some of our guiding principles.

We produce proprietary events such as BOMA and Só Track Boa, which is currently the largest electronic music event in Brazil. We also have a track record of producing international brand events in Brazil, such as the German Time Warp and the Spanish Brunch Electronik, Elrow, and Circoloco.

Our roster includes several internationally renowned artists, celebrated for their musical quality and artistic relevance, such as Vintage Culture, Mochakk, Dubdogz, ANNA, Mila Journée, Ashibah, and Cat Dealers, among others.

OUR PURPOSES

Our love for music and entertainment is so strong that we’ve made it our work. The power of music, represented by the talent of artists and expressed through events, is what drives us. All our purposes are directly related to this, just like our mission, vision, and values:

Mission

To connect artists and audiences through the artists we manage, and connect people and music through the major festivals we produce.

Vision

To remain the leading platform for operation and development in Brazil’s electronic music industry.

Values:

MUSIC AND ENTERTAINMENT IN CONTEXT

To achieve the best possible results in our work, it’s essential that everyone involved understands the unique nature of the music and entertainment industries and the consequences of working within them.

Entourage’s day-to-day involves renowned artists and large-scale events. Everyone must respect the privacy of artists and confidential information, aiming to protect their image.

With regard to events, special care must be taken with commercial, communication, and promotional strategies, as well as with backstage information like schedules, event and artist dates, cities and venues, attraction and label names, which should not be disclosed prematurely (e.g., before official announcements or without explicit permission). Entourage provides the necessary conditions and tools for optimal performance. However, professionals must be attentive to night shifts and the logistical challenges of long-distance travel, which require health and planning care.

OUR PRINCIPLES

Our professional conduct is guided by everyone’s commitment to achieving our goals, aligned with our mission, vision, and values. This commitment is governed by four principles:

RESPECT

We must promote mutual respect in our headquarters, at events, and in all relationships, embracing cultural, artistic, and personal diversity.

RESPONSIBILITY

We must fulfill our professional obligations with ethics, commitment, and punctuality—especially toward artists, clients, audiences, sponsors, and collaborators.

INTEGRITY

We must act with honesty and transparency in our daily activities, respecting ethical standards, regulations, and laws.

SUSTAINABILITY

Our decision-making processes must always consider the environmental impact of our activities, seeking the most sustainable alternatives with a long-term vision.

OUR SPACES, ASSETS, AND RESOURCES

At our São Paulo office, more than sixty people work daily, and we regularly welcome clients, partners, suppliers, and sponsors. We see every event we produce as an extension of our space.

FACILITIES AND STRUCTURE

Everyone who enters our headquarters must keep Entourage’s facilities in proper condition for use and cleanliness. It is essential that all shared resources are used responsibly, avoiding waste and damage. Annex I of this Code outlines the basic rules for using our headquarters and must be read and understood.

Everyone is expected to adopt sustainable practices, such as reducing paper consumption, properly disposing of waste through recycling, and using electricity consciously (lights should be turned off and air conditioning switched off at the end of the workday).

Any activity that could negatively impact the environment must be avoided, and whenever possible, actions aimed at environmental preservation should be promoted.

RESPECTFUL WORK ENVIRONMENT / RESPONSIBLE USE OF RESOURCES / INTELLECTUAL PROPERTY

Respectful Environment

We encourage an inclusive and respectful workplace where everyone is treated with dignity, regardless of race, origin, gender, sexual orientation, religion, or other personal traits.

Any kind of harassment is strictly prohibited and must be reported. Collaboration, empathy, and open communication are key to a harmonious and productive workplace.

Use of Resources

We provide quality tools and equipment to perform duties effectively. These must be used only for work, not personal purposes.

Our assets include not only material goods but also intangible resources: methods, business strategies, budget and artist/event information, and proposals. These must not be shared externally without approval.

Intellectual Property

Employees must respect intellectual property laws and company policies. Any creations or innovations within Entourage belong to the company.

Sharing ideas must follow internal guidelines to ensure sensitive and confidential data is protected.

OUR EVENTS

As an event producer, we understand that the spaces where events are held are extensions of our territory. Therefore, all conduct rules presented here apply to the events we organize, and additional specific ones must also be observed:

Entourage personnel attending our events who are not part of the production team or directly involved in its execution are not authorized to act on behalf of the agency. They may not give orders to the staff, access production-exclusive areas (unless explicitly invited, authorized, and identified by head producers), or grant access to restricted areas such as VIP lounges, backstage, or dressing rooms.

All events endorsed by Entourage must have protocols for harassment, violence, prejudice and discrimination, substance abuse, and extreme weather conditions. All teams involved in organizing the event must receive training on these matters.

All festivals endorsed by Entourage must include designated wellness areas. These spaces are intended for any attendee who needs a quiet and calm environment for decompressing.

These areas must be located far from the sound systems, with minimal noise. They should offer free access to drinking water and contain chairs, sofas, or armchairs suitable for rest. A multidisciplinary team, whenever possible including psychologists, must be available to support people in need.

Anyone requiring medical attention must be referred to on-site medical posts.

OUR CONDUCT

LEADERSHIP COMMITMENT AND RESPONSIBILITY

The company’s leadership commits to acting with integrity, transparency, and ethics in all its actions and decisions. It is responsible for promoting a safe, healthy, and respectful work environment for all employees.

Leaders must also seek the professional growth and development of employees, encouraging the emergence of new leaders.

TEAMWORK AND COLLABORATION

Everyone must work collaboratively and respectfully, supporting one another to achieve the company’s goals together. Diversity of ideas and opinions must be valued.

Offenses, intimidation, and aggression (even verbal) violate this principle and will not be tolerated under any circumstances.

DIVERSITY AND INCLUSION

Entourage values diversity and inclusion in its work environment, promoting equal opportunities for all employees regardless of race, origin, gender, sexual orientation, religion, disability, or any other personal characteristic. Building and maintaining an inclusive and welcoming environment for everyone must be a priority.

To this end, we ensure pay equity among all employees, regardless of race, gender, sex, belief, or any other personal trait.

Recruitment, selection, retention, and promotion practices must always include people from diverse backgrounds. Training and professional development programs will be implemented to guarantee equal opportunities for all individuals, fostering a work environment that respects and celebrates diversity. We will regularly promote training and awareness campaigns, creating a safe and welcoming space where every individual’s voice is heard and respected.

We will regularly promote training and awareness campaigns, creating a safe and welcoming space where every individual’s voice is heard and respected.

INTERNAL POLICY COMPLIANCE / LEGAL COMPLIANCE / INTERNATIONAL RELATIONS / HARASSMENT AND DISCRIMINATION

INTERNAL POLICIES

Company policies are determined in regular meetings and must be followed by all, without exception, including the basic rules for use of the headquarters (Annex I). Non-compliance may result in disciplinary measures.

COMPLIANCE WITH LAWS AND REGULATIONS

All employees must be aware of the rules and laws applicable to their field. When in doubt, legal counsel should be consulted to ensure full compliance. Failure to follow these rules may result in legal penalties and damage to the company’s reputation. The Code of Ethics of the Brazilian Association of Event Companies (ABEOC) must be respected.

INTERNATIONAL RELATIONS

The company commits to maintaining international relations based on respect, transparency, and compliance with local laws. Legal support must guide both our staff and international partners regarding legal matters—especially taxes and duties—that may impact negotiations. All employees involved in international negotiations must act ethically and respectfully, properly representing the company.

HARASSMENT AND DISCRIMINATION

Entourage does not tolerate any form of harassment, discrimination, or prejudice in the workplace, whether verbal, physical, or psychological.

MENTAL HEALTH / CONFLICTS OF INTEREST

MENTAL HEALTH

Entourage recognizes the importance of mental health, especially in the demanding context of music and events. Everyone must help create a safe space where individuals feel comfortable seeking support. Anyone who does not feel comfortable expressing that they need help can email ajuda@entourage.com.br to request psychological support.

CONFLICTS OF INTEREST

Employees must avoid situations where personal interests may influence the objectivity or impartiality of their work.

Any potential conflict must be disclosed to company leadership before a decision is made, so appropriate action can be taken.

Can I suggest a company owned by a relative as a supplier?
Yes. Suggesting someone with personal ties is not a conflict.

Can I choose a supplier because they’re a friend, even if they’re not the best option?
 No. Hiring decisions must be based on objective, impartial criteria

OUR RELATIONSHIPS

WITH CLIENTS

All clients must be treated with respect, honesty, and transparency. Commitment to customer satisfaction is a top priority, and all relevant information must be communicated clearly, with special care to avoid omissions. Any form of deception or bad faith in interactions is strictly prohibited, as is the receipt of improper commissions that compromise the client’s interests..

WITH SUPPLIERS

Employees must maintain ethical and transparent relationships with all suppliers. The selection and contracting of suppliers must be based on criteria such as ethical conduct, quality, price, and technical capability, always aiming for the best outcome for the projects.

Favoring suppliers in exchange for personal advantages or due to personal relationships is strictly prohibited.

Suppliers are expected to always act with the highest level of professionalism and in accordance with Entourage’s principles, in order to maintain strong and reliable partnerships.

WITH COMPETITORS

Entourage values fair and healthy competition in the market. Employees must avoid unfair practices, such as defamation or unfair competition, maintaining integrity and ethics in all interactions with competitors.

Confidential information about competitors must not be sought, obtained, or used in an inappropriate manner.

Competitors must always be treated with respect, with special attention given to public statements and social media interactions.

WITH PUBLIC AGENCIES / SPONSORS / PRESS / THIRD-PARTY EVENTS

WITH PUBLIC AGENCIES

It is everyone’s duty to act with complete transparency and respect in interactions with public agencies and their officials. Offering any benefit or advantage to public agents in exchange for favors or privileges is strictly prohibited. Requests for information and participation in bidding processes must strictly comply with applicable laws and regulations, ensuring impartiality and legality in all operations.

WITH SPONSORS

Entourage values relationships based on respect and transparency with the sponsors and supporters of its events and artists. It is essential that they always receive accurate information and that all agreed commitments are fulfilled with integrity.

Communication must be as clear and honest as possible regarding the expected benefits and obligations. Contract signing must be carried out with close attention to clauses and responsibilities, always demonstrating loyalty to the interests of both the production company and the sponsor.

WITH PRESS AND MEDIA

Our strong relationship with the media and press is fundamental to the success of our artists and events. Any and all information about our business may only be shared through the press office or with the express authorization of the partners.

Once authorization is granted, it is essential that the information provided is always accurate and truthful, avoiding speculation or content that could harm Entourage’s reputation or that of any of its stakeholders.

Interviews must be authorized by management to ensure consistency and alignment with the company’s communication strategy.

ATTENDING THIRD-PARTY EVENTS

When our directors, executives, employees, or staff members are invited to attend events on behalf of Entourage, they must always inform the partners, directors, or supervisors so that their participation can be evaluated and authorized.

If authorization is granted, participation in the event must follow the guidelines outlined in this Code. The attendee must act with respect and courtesy.

IN THE VIRTUAL ENVIRONMENT

Freedom of expression, belief, and thought is a right constitutionally guaranteed to all Brazilian citizens, including in online environments and on social media. Everyone working at Entourage is free to express their ideas in these spaces, but must do so respectfully, with civility and courtesy.

Digital behavior that constitutes aggression, any form of discrimination, moral or sexual harassment, bullying, or that incites violence or criminal acts goes against our values and principles, and may result in both criminal and administrative consequences within Entourage.

The use of fake profiles or pseudonyms is not recommended.

All Entourage employees are required to protect the privacy of the artists represented by the agency, as well as the backstage information of the events we produce. Information, photos, and images from professional routines must be shared with care, avoiding unwanted exposure.

EXPECTED BEHAVIOR
PROHIBITED BEHAVIOR

GIFTS, HOSPITALITY, AND COMPLIMENTARY TICKETS

OFFERING GIFTS

The offering of gifts and presents to clients, suppliers, sponsors, or public agents must always be authorized by the board or the partners and must remain moderate, not exceeding a symbolic value.

Care must be taken to avoid gifts that could be interpreted as attempts to exert undue influence or that may violate rules, regulations, or laws.

RECEIVING GIFTS

When gifts and presents are offered, it is essential to avoid circumstances that could compromise impartiality in decision-making.

If the gifts have significant value or raise any doubts, they should be declined or the situation should be reported to management.

HOSPITALITY

The offering or acceptance of hospitality must be moderate and appropriate to the context in which it occurs. It must always be clearly linked to a legitimate business purpose.

COMPLIMENTARY TICKETS

The offering and acceptance of complimentary tickets for event entry is a common practice in the Brazilian live entertainment market. However, we always recommend exercising caution in this regard.

The offering of complimentary tickets for events produced by Entourage must always follow the guidelines of the marketing team or the partners, respecting good judgment and moderation to avoid them being perceived as attempts at undue influence or as violations of rules, regulations, or laws.

The sale of these complimentary tickets is strictly prohibited.

Requesting complimentary tickets for third-party events operating in the same sector as Entourage is also prohibited. The receipt of complimentary tickets from third parties must always be reported to the directors and partners.

ENTOURAGE AND THE COMMUNITY

SOCIAL IMPACT

Entourage is committed to promoting social impact initiatives aimed at sustainable development and the well-being of the community. Our practices and policies must always align with current legislation and human rights. We are committed to adopting strict monitoring measures and collaborating with partner organizations to identify and prevent situations of child labor, ensuring that our operations do not contribute to this issue and promoting education and the protection of children in our areas of operation.

JUSTICE, EQUITY, DIVERSITY, AND INCLUSION

The organization is committed not only to fostering a work environment that respects and values justice, equity, diversity, and inclusion, but also to ensuring that these principles are consistently upheld in the events we produce.

Efforts will be made to ensure that all events reflect the best possible representation of Brazilian culture and diversity, always prioritizing the right of access for groups in situations of vulnerability.

BRAZILIAN ELECTRONIC MUSIC CONTEXT

We understand that fostering and developing the Brazilian electronic music scene is fundamental to our success. Therefore, one of our commitments is to support and promote local artists, ensuring they have the conditions to express their creativity and highlight regional scenes.

ANTI-CORRUPTION, BRIBERY AND MONEY LAUNDERING PRACTICES

Corruption is understood as the act of offering or receiving an undue advantage, usually in exchange for the performance of a certain act. It is a long-standing social, political, and economic phenomenon that affects all countries around the world. It harms democratic institutions, hinders economic development, contributes to political instability, drives away investors, and discourages the creation and growth of businesses.

Practices such as bribery, kickbacks, fraud, embezzlement, or any other misappropriation of resources by a public official are considered acts of corruption. It may also involve nepotism, extortion, influence peddling, the use of privileged information for personal gain, and the buying and selling of administrative decisions or court rulings, among many other practices.

We are committed to condemning all acts of corruption in our professional conduct and recommend that our employees read the Anti-Corruption Law (Federal Law No. 12.846/2013).

Under this law, we reinforce that it is prohibited to offer, promise, or give any benefit, advantage, or favor to third parties—whether public or private agents—with the intent to influence their decisions or actions.

Money Laundering:

We do not tolerate any action aimed at concealing the illicit origin of financial resources. All members of the organization must be aware of the warning signs of money laundering, whether in the hiring of artists or in event production, and must refuse to take part in any transactions that raise suspicion about the legitimacy of the involved funds.

Any and all suspicious activity must be reported immediately to agency management. Those working in the financial area must pay special attention and be familiar with the Money Laundering Law (Federal Law No. 9.613/1998).

It is possible to report incidents or concerns related to corruption, bribery, or money laundering through the Whistleblower Channel.

Failure to comply with the provisions of this Code on this matter may result in disciplinary action and the immediate referral of the case to the appropriate authorities.

ACTING WITH CAUTION AND ETHICS

Example:
A public agent demands free tickets in exchange for authorizing an event.

Correct Action:

CONSEQUENCES AND RESPONSIBILITIES

Each employee is responsible for their actions and decisions and must always act in accordance with the principles established in this Code. Any violation of this Code of Conduct may result in sanctions ranging from warnings (verbal or written), suspensions, or even contract termination (in addition to legal action, if necessary).

In cases where a violation of the Code occurs and a warning is not sufficient, or if the individual refuses to accept the warning or contests it, the Ethics Committee must be activated. The committee has the authority to review the matter and apply more severe sanctions, always ensuring that the individuals involved have the opportunity to present their case, defend themselves, and appeal.