Bribery and Corruption Policy
IIAF is committed to complying with all applicable laws and best corporate governance practices, wherever we operate. It is a core aspect of our mission to act with integrity in all of our operations. The Board of Directors of IIAF and the Manager of IIAF expect all employees & Staff to comply with both the letter and spirit of the law and governance codes.
IIAF and its Manager affirms that will not pay or procure the payment of a bribe or unlawful fee to encourage the proper performance of a task or one which is intended or likely to compromise the integrity of another. We will not accept any payment, gift or inducement from a third party, which is intended to compromise our own integrity.
IIAF and its Manager have communicated this policy to all its employees, to ensure that its commitment to integrity and legal compliance is followed.
When contracting with a third party, including companies in whom we are considering an investment, we will insist that they acknowledge our commitment to good and adopt appropriate anti-bribery policies.
o Any person who believes that IIAF, its Manager, or any of its staff are involved in bribery and corruption is encouraged to report their concerns to whistleblower@insitormanagement .com
IIAF Whisleblower Policy
IIAF welcomes whistle-blower reports and encourages staff to draw to its attention instances of corporate wrong-doing within the IIAF’s group of companies [as defined below a “Protected Disclosure”];
IIAF will require that every business in which the capital of IIAF is invested adopt and implement Whistle-blower policies in accordance with local laws and international best practices.
IIAF regards attempts to victimize or discriminate against a Whistle-blower as potentially gross misconduct.
Raising a Concern
Individuals may raise a Protected Disclosures (as defined below) in writing to the responsible officer with the issues clearly and unambiguously set out. The Whistle-blower should identify themselves in the disclosure.
“Protected Disclosure” is defined as a reasonably held concern that:
A criminal offence has been committed, is being committed or is likely to be committed;
A person has failed, is failing or is likely to fail to comply with any legal obligation to which he or she is subject;
A miscarriage of justice has occurred, is occurring or is likely to occur;
The health and safety of any individual has been, or is being or is likely to be endangered;
The environment has been, is being or is likely to be damaged;
Information tending to show any matter falling within any one of the preceding paragraphs has been, is being or is likely to be deliberately concealed; and
A concern raised in good faith that discloses or demonstrates information that may evidence serious unethical or improper activity within IIAF (or a company in its group) and its and their business practices.
All Whistle-blowing disclosures made to the IIAF Compliance Officer will be treated as confidential. The whistle-blower should make it clear that they are making their disclosure within the terms of the firm’s whistle- blowing policy. This will ensure the recipient of the Protected Disclosure realizes this and takes the necessary action to investigate the disclosure and to protect the whistle-blower’s identity.
IIAF welcomes Third Party Whistle-blower Reports. These may concern the conduct of its own staff or a portfolio company. All Third Parties Whistle-blower Reports should be addressed to: email@example.com.
IIAF condemns any kind of discrimination, harassment or victimization of a Whistle-blower. IIAF will ensure that:
The identity of a Whistle-blower is kept confidential and only disclosed on a need to know basis;
Papers relating to a Protected Disclosure or a Third Parties Whistle-blower Report are filed carefully away;
Instances of victimization of a person making a Protected Disclosure are treated as a serious matter which may give rise to disciplinary action by IIAF against any person(s) causing or allowing such victimization.
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Photograph representing BioSense on front page is courtesy of Anita Khemka.