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