Gifts & Entertainment Policy

1. Scope

This policy governs the giving and receiving of gifts, hospitality and entertainment by all staff, including anything offered to a family member because of the employee's role at the firm.

2. Declaration threshold

Any gift or hospitality with an estimated value above USD 300 must be declared in the Gifts & Entertainment Declaration within five business days, and pre-approved where it has not yet been accepted.

3. Prohibited items

Cash, cash equivalents, vouchers, loans and personal discounts may not be accepted or offered under any circumstances. Gifts intended to influence a decision are prohibited regardless of value.

4. Public officials

Any gift or hospitality involving a government or regulatory official requires prior written approval from Compliance, irrespective of value.

5. Aggregation

Multiple gifts from the same counterparty within a rolling twelve months are aggregated. Once the combined value passes USD 300, all further items require pre-approval.

6. Register

Compliance maintains the gifts register and reviews it quarterly for patterns such as repeated counterparties or values placed just below the threshold.