Doing what’s right,
not what’s easy
Identifying and Reporting Corruption
“The time is always right to do what is right.” —Martin Luther King, Jr.
In making patient capital investments, Acumen is committed to the highest ethical standards. Acumen wants to work with entrepreneurs who aim to build ethical businesses. We have a zero tolerance policy for businesses or people that do not obey the letter and spirit of all relevant laws, particularly in the areas of corruption, tax-fraud, terrorism and money-laundering. The letter and spirit of employee protection laws are also a major focus for Acumen.
- Acumen does not pay or take bribes or kickbacks and does not tolerate such payments by an investee or contractor even if told that is “how business is done”. Any gifts of any sort to a governmental employee, their relatives or intermediaries raises a red flag for Acumen staff.
- Acumen strives to know our investee companies. We understand that diligence is not a “check the box” exercise and conduct appropriate investigations to understand the ownership, operations, cash flows and reporting of all potential investees and their affiliates. We strive to understand an investee’s activities after an investment closes to ensure that problematic activities are not occurring.
Acumen has designed its investment process to root out some of these concerns, such as by requiring periodic certifications by, and USA PATRIOT Act database searches on, investees. Each investment is unique, and we need the good judgment and efforts of our team to make the process work. Acumen also depends on input and cooperation received from others in reporting allegations of prohibited practices.
Contact Acumen’s General Counsel to report concerns or evidence that corruption, fraud, bribery or some other form of misconduct may have occurred or is occurring related to any Acumen investment. You may report allegations to Acumen by email, fax, mail, in person, or by telephone. (Only Acumen staff can access any such communication.)
Allegations may be reported by any source, including confidential or anonymous sources. However, please note that anonymous reports are much harder to investigate as it may be more difficult to ascertain the truth. Anyone making an allegation is encouraged to provide some means that will allow Acumen to communicate with you.
Fax: (212) 566-8817
Mail (marked “Confidential”)
General Counsel, Acumen
40 Worth Street, Suite 303
New York, NY 10013
In Person: 40 Worth Street, Suite 303, New York, NY 10013
Telephone: (212) 566-8821
Please provide as much detail as possible in your report, including:
- Who do you think committed fraud or corruption? Who else might have been involved?
- What happened? Describe the events fully with as much relevant detail as possible.
- When did it happen? Please provide dates, time, and number of times.
- Where did it happen? Include not only the city and country, but, if possible, an actual address, the name of the building, the office number, etc.
- Who else might have information?
Who will know that you made a report?
- How does your allegation relate to an Acumen investment or program? Was Acumen staff involved?
Reports regarding Acumen investees will be evaluated by Acumen’s General Counsel, who will submit a recommendation for further evaluation, if any, to the Chief Operating Officer (COO). Reports alleging prohibited conduct by Acumen staff are reported to supervisors and escalated to Acumen’s COO, to the extent not resolved. Investigations with respect to Acumen staff are conducted by the General Counsel and Director of Talent on behalf of the COO; a report is presented to the COO with recommendations on the matter, and the COO ensures that the recommended actions are taken. In the event that any report includes allegations of financial fraud, Acumen’s General Counsel advises the Chief Financial Officer (CFO) to conduct a separate investigation into financial matters implicated, and the CFO reports her findings and recommendation to the COO.