Ethics and Anti-Corruption

I know that business works best when business matters are conducted transparently, fairly, ethically, and in accordance with all applicable law. This page outlines my ethics disclosures and anti-corruption policy.

LAST UPDATED: 12 October 2020

ETHICS DISCLOSURES

I maintain passive investments in index funds and various individual technology stocks. I do not have any operational decision-making power in any of those technology companies or portfolio companies of the index funds.

I am the Chairman and majority shareholder of Aswanet Rwanda, Ltd., a privately held company based in Kigali, Rwanda.

Aswanet Rwanda, Ltd. is a member of the Inogen Environmental Alliance, a US-based alliance of engineering and consulting firms. Aswanet is bound by various agreements with Inogen including anti-corruption and data protection agreements, and Inogen members are, in most circumstances, considered close enough that engagement of one Associate may create conflict-of-interest issues if another Associate is engaged for work with a client’s competitor. These situations will be evaluated on a case-by-case basis.

I am the Business Development Director and minority shareholder of Aswanet, Ltd., an inactive privately held company based in Kampala, Uganda.

I am on the Executive Committee of the COVID-19 Call For Engineering Action at the National Academy of Engineering. Through this role, I exercise some executive authority and responsibility over aspects of the program, but I am not authorized to formally bind the Academy, nor do I formally speak on their behalf. I received an honorarium for this work in September 2020.

ANTI CORRUPTION

I have a zero tolerance policy for corruption and will not engage in or tolerate any of the below activities, even if the conduct is prevalent in a country where I am working:

  1. Failing to disclose a true or potential conflict of interest to appropriate stakeholders
  2. Misappropriation of cash or company resources
  3. Falsification of expense reports
  4. Improper bidding procedures, including the offering of benefits (financial or otherwise) to procurement officials or their families in exchange for favored treatment
  5. Engaging in bribery, illegal gifts, or kickbacks
  6. Other corrupt or inappropriate conduct