Ethics & Compliance
Short, practical commitments we can actually follow in the field.
This page sets out how Venezuela Field Support conducts business. It is deliberately short. A policy the firm cannot follow operationally is worse than no policy, because it invites the assumption that the rest is decoration.
Lawful business conduct
All engagements are conducted lawfully under applicable U.S., Venezuelan, and other law. Venezuela Field Support declines work that cannot be performed lawfully, and will withdraw from an engagement if it cannot continue lawfully.
Field work is conducted openly. Venezuela Field Support does not trespass, does not misrepresent its identity or purpose to obtain access or information, and does not use pretexting.
Anti-bribery and anti-corruption
Venezuela Field Support does not offer, promise, give, request, or accept bribes, kickbacks, or improper payments, directly or through third parties, and does not make facilitation payments.
Where a request for an improper payment is encountered during an engagement, it is refused and reported to the client.
Sanctions compliance
Venezuela Field Support does not provide sanctions or export-control advice. It structures its own activity to comply with applicable sanctions, and it coordinates operational planning with a client’s legal and compliance advisers.
Where sanctions or legal questions arise, Venezuela Field Support works alongside appropriately qualified counsel selected by the client or agreed by the parties. Clients are responsible for their own compliance determinations.
Client confidentiality
Client identities, engagement scopes, findings, and information are confidential. Venezuela Field Support does not use client names in marketing without written authorization, does not discuss engagements with third parties, and does not publish client-derived material.
Information is shared inside an engagement only with those who need it to perform the work.
Human rights
Venezuela Field Support does not undertake work intended to facilitate harm, harassment, surveillance of private individuals, suppression of lawful activity, or violation of human rights.
Individuals engaged to support field work are treated fairly, paid as agreed, and are not asked to take risks or perform acts that would be unlawful or that they have not agreed to.
Third-party relationships
In-country resources, subcontractors, and service providers are selected on capability and integrity, told what the work is, and expected to meet the same standards set out on this page.
Venezuela Field Support applies to its own suppliers the validation discipline it applies to a client’s counterparties.
Data protection
Information provided by clients is held securely and used only for the engagement. Venezuela Field Support asks clients not to transmit classified, export-controlled, or otherwise sensitive material through general channels, and arranges appropriate channels when required.
See the Privacy Notice for how website information is handled.
Conflicts of interest
Conflicts are checked before an engagement is accepted. Venezuela Field Support does not take positions in the transactions it assesses, does not accept undisclosed commissions or referral fees from parties it is assessing, and does not accept engagements where its independence would be compromised.
Where a potential conflict arises mid-engagement, it is disclosed to the client immediately.
Why this matters commercially, not just ethically
The value of a verification finding depends entirely on the reader’s confidence that it was not shaped to produce a particular answer. A firm that accepts undisclosed commissions from the vendors it validates, or that has a position in the transaction it is diligencing, cannot produce a finding worth relying on.
Venezuela Field Support’s job is to determine what is actually true, not to validate a preferred conclusion — including the client’s. Findings that are inconvenient are still delivered, and items that could not be verified are reported as unverified rather than presented as fact.
Raising a concern
Anyone — client, counterparty, supplier, or member of the public — may raise a concern about conduct on an engagement by writing to info@venezuelafieldsupport.com. Concerns are reviewed by the founder and managing partner directly.
Independent by design.
If you need a finding you can put in front of a board, it has to come from a firm with nothing riding on the answer.