1. Foreign Corrupt Practices Act (Justice.gov FCPA)
It is the Company’s policy to require that any Consultants (including beneficiaries of Company investments), bidders, suppliers, contractors and their agents (whether declared or not), sub-contractors, sub-consultants, service providers or suppliers, and any personnel thereof, strictly observe the highest standard of ethics during the procurement and execution of any of the Company’s contracts or transactions. In pursuance of this policy, the Company requires an Foreign Corrupt Practices Affidavit to be duly signed by the Consultants.
2. OECD Principles on Corporate Governance: (OECD PDF)
3. Transparency and Reporting
ACO Investment Group is committed to transparency and openness to our investors and the wider public. ACO Investment Group is planning to report to investors quarterly, adhering to US GAAP. We intend to distribute a publicly available Annual Report and maintain a regularly updated website including information on our portfolio companies and key employees. ACO Investment Group is also looking to follow a fully compliant process with private equity disclosure guidelines in the U.K. and Germany.
4. Public Pension Fund Reform Code of Conduct
ACO Investment Group is looking to become a signatory to the Public Pension Fund Code of Conduct (the “Code”). Pursuant to the Code, ACO Investment Group is providing information regarding the professional backgrounds of certain key ACO Investment Group personnel (“Disclosure Persons”) and such information can be found under their individual biographies in the “Team” section of this website. In addition, ACO Investment Group will periodically provide to our clients details of certain political contributions to candidates for state and local offices as well as certain federal contributions.
Also pursuant to the Code, ACO Investment Group will be disclosing certain fees and expenses that have been paid on an aggregate basis with respect to investment funds to which U.S. public pension funds have committed since the effective date of the Code. Please contact us for the annual certificate of compliance.