ANTI-CORRUPTION POLICY

 

In making patient capital investments, the Squeem Foundation is committed to the highest ethical standards. The Squeem Foundation 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 The Squeem Foundation.

The Squeem Foundation 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 The Squeem Foundation staff.

The Squeem Foundation 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.

The Squeem Foundation 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. The Squeem Foundation also depends on input and cooperation received from others in reporting allegations of prohibited practices.

REPORTING PROCESS

Contact The Squeem Foundation’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 The Squeem Foundation investment. You may report allegations to The Squeem Foundation by email, fax, mail, in person, or by telephone. (Only The Squeem Foundation 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 The Squeem Foundation to communicate with you.

Email
foundation@squeem.com

Mail (marked “Confidential”)

General Counsel, The Squeem Foundation
6753 Kingspointe Pkwy, ste 110
Orlando, FL 32819

Telephone (407) 370 2780

Please provide as much detail as possible in your report, including:

  1. Who do you think committed fraud or corruption? Who else might have been involved?
  2. What happened? Describe the events fully with as much relevant detail as possible.
  3. When did it happen? Please provide dates, time, and number of times.
  4. 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.
  5. Who else might have information?
  6. Who will know that you made a report?
  7. How does your allegation relate to a Squeem Foundation investment or program? Was The Squeem Foundation staff involved?

Reports regarding The Squeem Foundation investees will be evaluated by The Squeem Foundation’s General Counsel, who will submit a recommendation for further evaluation.