As a matter of policy, MicroVest strictly complies with the Foreign Corrupt Practices Act (“FCPA”) and prohibits its employees, Board members, advisors or other affiliates from offering, promising, paying, or authorizing any bribe, kickback or similar improper payment to any foreign official, foreign political party or official or candidate for foreign political office in order to assist MicroVest in obtaining, retaining, or directing business, including investments in the Funds. MicroVest reviews its policies and procedures with respect to the FCPA with employees as part of its annual compliance training.
In order to minimize the chance that MicroVest could violate the FCPA or similar foreign laws, employees must obtain the written approval of the Chief Compliance Officer prior to making any payment or giving any gift or other thing of value (including paying for entertainment or travel-related expenses), or offering to do the same, to any:
- official of a foreign government;
- employee of any government-controlled foreign business;
- sovereign wealth fund, employee or representatives of a sovereign wealth fund, or third party associated with a sovereign wealth fund’s investment process or investment due diligence; or
- foreign political party or official or candidate for foreign political office.
This policy applies without regard to the purpose or motivation behind the giving of such payment, gift, or other thing of value. As a general matter, the giving of any such payments, gifts, or other things of value will not be permitted. The Chief Compliance Officer will document any exceptions to this general policy.
To the extent MicroVest utilizes placement agents or other intermediaries to solicit Investors in foreign countries, the Chief Compliance Officer will review placement agent agreements for appropriate written representations, including, among other things, that the placement agent or other intermediary will act in accordance with U.S. and foreign laws, including the FCPA.