Ethics InsightStart a conversation

Integrity and governance due diligence for investors

The business you buy is not quite the business you own.

Investment brings new markets, people, partners, decisions and pressure. Today's governance may say little about tomorrow. We help investors spot the risks that come with scaling, prioritise what matters and build safeguards that fit.

Selected organisations we have worked with

  • Asian Development Bank
  • British International Investment
  • Genmab
  • Impact Fund Denmark
  • Norfund
  • Swedfund
  • WSP

How we see risk

Assess the business in context, not against a generic checklist

A country score or policy review can be a useful starting point, but neither shows where this business will be exposed as it grows. We examine what it does, where and with whom; whether its controls fit that context; and how incentives, authority and behaviour affect what happens in practice.

See how we work

Background checks tell you about past events. Policies show what the company says it has in place.We look at how the business really works, and what changes as it scales.

Illustrative extracts from a sample report

Context, controls and culture

Context

01Context helps us understand the risks ahead.

Context: Country and sector analysis

Repeated interactions with public systems (registries, environmental compliance, inspections, local enforcement) and contracting in frontier settings can create elevated corruption risk exposure.

Most common occupational fraud schemes in Latin America
  • Corruption55%
  • Billing25%
  • Non-cash23%
  • Skimming15%
  • Cheque and payment tampering11%

If land verification is treated as a legal formality rather than a forensic exercise, the risk of disputes that freeze operations increases.

Acme · Reforestation project, Latin AmericaIllustrative extract
Controls

02Controls tell us what's actually in place.

Controls: Gap analysis

We summarised Acme's existing controls against the Investor's business integrity requirements and rated how well each one works today.

ControlIdentified gapRating
Risk assessmentBribery, fraud and conflict of interest risks are grouped together. Action plans are not yet monitored routinely.Moderate
Business partnersOwnership of third-party monitoring is diffuse. Project-level protocols are not yet in place.Moderate
Interactions with officialsControls rely heavily on training and individual judgement.Moderate
Conflicts of interestNo formal declaration process, register or periodic review.Moderate

There is no formal conflict of interest declaration process, register or periodic review.

Acme · Reforestation project, Latin AmericaIllustrative extract
Residual risk

03See where the real risk sits.

Residual risk: Where the risk remains

Fraud risk in land and carbon projects rarely starts with forged titles or credits. It tends to start slowly, through procurement, contracting and reporting, where work is remote and third parties act for the project.

Median loss with and without each anti-fraud control (USD)
  • Surprise auditsWith control: $75kWithout control: $200k
  • Management reviewWith control: $100kWithout control: $250k
  • HotlineWith control: $100kWithout control: $200k

Implementing basic controls can bring down the median loss by about 50%.

Acme · Reforestation project, Latin AmericaIllustrative extract
Action plan

04Prioritise, right-size, integrate and adapt.

Action plan: Summary

Each action builds on what Acme already has, with a clear deliverable and timeframe.

AreaPriorityDeliverableTiming
Interactions with officialsHighA register of licences, permits, inspections and approvalsUnder 6 months
Conflicts of interestHighA declaration form and registerUnder 6 months
Business partnersMediumA supplier and contractor monitoring framework6 to 12 months
DetectionMediumFraud monitoring and exception testing6 to 12 months

Formalise controls for interactions with public officials, including approval rules, logging and review of engagement patterns.

Acme · Reforestation project, Latin AmericaIllustrative extract

What clients say

I worked with Rupert to conduct assessments and advise on integrity issues with our investment portfolio companies. He is particularly skilled at sensitively engaging with firm leadership on very tricky topics.

Rita RocaDirector, Impact Fund Denmark

I appreciate working with Rupert on critical projects in high-risk areas. His expertise and adaptability are impressive. The quality of analysis provided us with a clear improvement plan for our investee; the sector insights were invaluable.

Anjelika KarlssonBusiness Integrity Lead, Swedfund
Rupert Evill

Founder

Rupert Evill

Rupert brings 25 years of frontline work across more than 80 countries. His experience spans investigations, intelligence, political risk, due diligence, crisis response, integrity risk and human rights.

Rupert is a Certified Fraud Examiner and author of Bootstrapping Ethics.

About Ethics Insight and Rupert

Ranulph

Structured integrity-risk analysis

Prioritise what matters without working through every document by hand

Ranulph maps the risks that fit the business, reviews documents and data for gaps, weaknesses and potential signs of fraud, then turns the findings into tailored questions and practical action. It can also reconcile competing action plans, support speak-up and investigation work, and help teams ask better questions across the whole portfolio.

  • Context and diagnostics

    Map the real exposure, then test documents and data for gaps, weaknesses and potential fraud indicators.

    • Context
    • Documents
    • Fraud indicators

    Understand what the business does, where it operates, who it works with and how that shapes the risks it is likely to face. Review documents and data for gaps, weaknesses and areas that need further analysis.

  • Questions and action

    Turn findings into tailored questions, a clear gap analysis and a practical action plan.

    • Questions
    • Gap analysis
    • Action plan

    Draft targeted, right-sized follow-up questions, then identify where controls, implementation, or practice fall short and turn that into a clear, prioritised action plan.

  • Harmoniser

    Bring overlapping or conflicting requirements and action plans into one coherent set of work.

    • Requirements
    • Action plans
    • One set of work

    Bring overlapping or repeated requests into one coherent set of responses, while making shared points, differences and conflicts easier to see.

  • Governator

    Know what's happening in your portfolio.

    • Board packs
    • Portfolio signals
    • Actions

    An agent in the room for board decisions. Load the board pack, however long, and it draws on the rest of Ranulph to tell you what it means and what to do about it. Between meetings, it keeps track of actions, risk indicators, speak-up reports and business partners.

Is it worth a conversation?

If you think we may be able to help, tell us a little about the situation. We will listen, ask a few questions and tell you whether we are the right fit; if not, we will say so and, where we can, point you in a more useful direction.

Start a conversation

We read every enquiry personally and reply as soon as we can.

Please do not send names, allegations or sensitive evidence through the website. We can agree a secure and confidential way to share information after an initial conversation.