This Ethics Policy (the “Policy”) applies to all employees of Accelerant, an initiative of the Dayton Development Coalition, (“Accelerant”), who will be referred to jointly as “associates.” The Policy is a statement of goals and expectations for conduct.
The Policy is effective immediately.
It is important that you read the Policy and understand it. Keep it with you and refer to it frequently. Ask any questions you may have. You are expected to comply with the Policy entirely. Ignorance of the Policy will not excuse you from its requirements. The Policy will help protect our reputation for honesty and integrity. The Policy cannot and is not intended to cover every applicable law or provide answers to all questions that might arise; for that we must ultimately rely on each associate’s good sense of what is right, including a sense of when it is proper to seek guidance from others on the appropriate course of conduct. Since our organization depends upon our reputation for honesty and integrity, in many instances, the Policy goes beyond the requirements of law.
Compliance with Laws
Obeying the law, both in letter and spirit, is one of the foundations on which Accelerant’s ethical standards are built. All associates must respect and obey the laws of the jurisdictions in which we operate. Although not all associates are expected to know the details of these laws, it is important to know enough to determine when to seek advice from supervisors or the Director of Legal & Contract Affairs.
Conflicts of Interest
Your personal activities and relationships must not conflict or appear to conflict with the interest of Accelerant. Keep in mind, the Policy cannot specifically address every potential conflict, so use your conscience and common sense. When questions arise, seek guidance.
Current Conflicts of Interest: Any instance where an employee of Accelerant is benefitting from an action of Accelerant.
Potential Conflicts of Interest: Any instance where an employee of Accelerant has the ability to benefit from an action of Accelerant.
Should the situation arise where a company was being recommended to our Board for investment or being considered for a general service commitment that had affiliation with one of our previous funds, collaborators, or Board members, we would disclose this to the Board approving the investment, or to the Board in a general meeting if the action did not require Board approval (e.g. service commitment). This also includes follow on investments to companies Accelerant Fund I has previously invested.
No associate shall receive compensation from a portfolio company, service recipient, client company, or any other potential opportunity of Accelerant while an employee of Accelerant. If an associate has received compensation prior to their employment with Accelerant, it needs to be disclosed in writing to the General Partner and Director of Legal & Contract Affairs, as well as disclosed to the Board.
Collaborators and members of our independent investment Board need to disclose any and all previous and current affiliations with portfolio companies and service recipients, as well as any other companies that have or have the ability to benefit from involvement with Accelerant.
All associates, and all entities in which an associate is an officer or director or has an ownership interest, are expected to deal with the Accelerant on an arm’s-length basis. All transactions between Accelerant and any such associates or entities should be approved in writing and in advance by the General Partner and the Director of Legal & Contract Affairs, and when approved by the General Partner and the Director of Legal & Contract Affairs, should be promptly disclosed to the entire Board.
Accounts and Record Keeping
Every Accelerant financial record and account must be accurate, timely and in accordance with the law. Our books must reflect all components of transactions, as well as our own standard of insisting upon an honest and forthright presentation. These records are the basis for managing Accelerant’s business and for fulfilling our obligations to stakeholders, associates, and regulatory authorities. Accurate records are everyone’s responsibility.
Never falsify any document or distort the true nature of any transaction.
All transactions must be supported by accurate documentation.
All reports made to regulatory authorities must be full, fair, accurate, timely and understandable.
Associates must cooperate with investigations into the accuracy and timeliness of financial records.
To the extent estimates and accruals are necessary in company reports and records; they must be supported by appropriate documentation and based on good faith judgment.
The use of Accelerant assets for your personal benefit or the benefit of anyone other than Accelerant is not permitted.
You may not take away from Accelerant for yourself any opportunity for financial gain that you find out about because of your position at Accelerant or through the use of Accelerant property or information.
Misuse of Accelerant assets may be considered theft and result in disciplinary action or criminal prosecution.
The Policy prohibits associates from accepting gifts or entertainment. This is an area in which your judgment is critical. If you are uncertain, seek prior approval from the General Partner and Director of Legal & Contract Affairs.
It is your obligation to safeguard Accelerant’s nonpublic information. You should not share confidential information with anyone outside Accelerant unless it is necessary as part of your work responsibilities. Nonpublic information is any information that has not been disclosed or made available to the general public. Nonpublic information includes items such as financial data, plans for acquisitions or divestitures, personal information about associates, material contracts, financing transactions, major management changes and other organization developments.
As described in the Policy, certain persons at Accelerant must review and approve in writing any circumstance requiring special permission. Copies of these approvals should be maintained by Accelerant and made available to auditors or investigators upon request.
Associates should take all responsible steps to prevent a Policy violation. Associates must report suspected Policy violations to the General Partner or Director of Legal & Contract Affairs.
Submission of Complaints or Concerns
We do not permit retaliation of any kind against associates for good faith reports of potential violations of the Policy. Any associate who retaliates against another associate for reporting known or suspected violations of the Policy will be in violation of the Policy.
Investigations and Disciplinary Actions
Accelerant will investigate any matter so reported and may take appropriate corrective and disciplinary actions, which may include, alone or in combination, a warning or letter of reprimand, demotion, suspension without pay or termination of employment. Violations of this Policy are not the only basis for disciplinary action.
Any infraction that the General Partner or Board believes the State of Ohio should be aware of will be sent to the ESP Program Manager and anyone else the Program Manager requests to receive it.
Amendments and Modifications
Accelerant reserves the rights to amend, alter or terminate this Policy at any time and for any reason.