Anti-Corruption Policy
Identifying and Reporting Corruption
“Integrity is doing the right thing, even when no one is watching.” —C.S. Lewis
In making patient capital investments, Unity For Equality is committed to the highest ethical standards. Unity For Equality 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 Unity For Equality.
- Unity For Equality 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 Unity For Equality staff.
- Unity For Equality 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.
Unity For Equality 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. Unity For Equality also depends on input and cooperation received from others in reporting allegations of prohibited practices.
REPORTING PROCESS
Contact Unity For Equality’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 Unity For Equality investment. You may report allegations to Unity For Equality by email, fax, mail, in person, or by telephone. (Only Unity For Equality 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 Unity For Equality to communicate with you.
Email: anticorruption@unityforequality.org
Fax: (202) 602-2594
Mail (marked “Confidential”):
General Counsel, Unity For Equality
42-49 Colden Street,
Flushing, NY 11355
In Person: 42-49 Colden Street, Flushing, NY 11355
Telephone: (202) 878-0027
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 a Unity For Equality investment or program? Was Unity For Equality staff involved?
Reports regarding Unity For Equality investees will be evaluated by Unity For Equality’s General Counsel, who will submit a recommendation for further evaluation, if any, to the Chief Operating Officer (COO). Reports alleging prohibited conduct by Unity For Equality staff are reported to supervisors and escalated to Unity For Equality’s COO, to the extent not resolved. Investigations with respect to Unity For Equality 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, Unity For Equality’s General Counsel advises the Chief Financial Officer (CFO) to conduct a separate investigation into financial matters implicated, and the CFO reports his findings and recommendation to the COO.