What to report
You may report any good-faith concern about conduct involving Summit Ventures, its personnel or its business partners, including:
- fraud, misrepresentation or misleading communications;
- violations of securities, tax, environmental or other laws or regulations;
- accounting, reporting or recordkeeping irregularities;
- bribery, kickbacks or improper payments;
- conflicts of interest that have not been disclosed;
- health, safety or environmental hazards; and
- retaliation against anyone who has raised a concern.
How to make a report
You can report a concern in any of the following ways:
- Email:info@summitven.com, with the subject line “Confidential: Whistleblower Report”
- Mail: Summit Ventures, Attention: Compliance, 5 Cowboys Way, STE 300, Frisco, TX 75034, marked “Confidential”
- Phone:214-225-9623, asking to speak with compliance
You may report anonymously. If you do, please include enough detail for us to look into the matter, as we may not be able to contact you for more information.
What to include
Helpful reports describe what happened, when and where it happened, who was involved, how you became aware of it, and any documents or other evidence that support your concern. You do not need to have proof; a reasonable, good-faith belief is enough.
Confidentiality
Reports are handled confidentially. Information is shared only with those who need it to review and address the concern, or as required by law. Where you identify yourself, we will protect your identity to the extent possible.
Protection from retaliation
Summit Ventures prohibits retaliation of any kind against anyone who reports a concern in good faith or who cooperates in a review. Retaliation is itself a serious violation, and anyone who engages in it will be subject to appropriate action.
How reports are handled
Each report is reviewed promptly. Where appropriate, the matter is examined in depth, which may involve outside advisers. If a concern is substantiated, Summit Ventures will take appropriate corrective action. Where you have provided contact details, we will acknowledge your report and, where appropriate, let you know when the review is complete.
Reporting to regulators
Nothing in this policy prevents you from reporting possible violations of law directly to a government agency, including the U.S. Securities and Exchange Commission through its Office of the Whistleblower at sec.gov/whistleblower, or from participating in any inquiry by such an agency. You do not need to notify Summit Ventures before doing so.
