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GIFTS AND ENTERTAINMENT POLICY

FEBRUARY 2016
GIFTS AND ENTERTAINMENT POLICY

FIL Limited Gifts and Entertainment Policy


The Gifts and Entertainment Policy

The purpose of the Gifts and Entertainment Policy (the Policy) is to establish
requirements for participating in business entertainment and for giving or receiving gifts.

Employees must read this Policy and any country specific supplements to the Policy
(Country Supplements) that apply to them and comply with all rules when giving or
receiving gifts or business entertainment. Where the requirements of a supplement are
more restrictive, employees subject to the supplement must follow those more restrictive
standards. The Country Supplements can be found at https://www.coe.fil.com.

The Ethics Office has developed a number of Fact Sheets to assist you in complying with
the Policy. These can be found on the online Ethics system (https://www.coe.fil.com).

Some of the terms used in this Policy have specific meanings which are set out under
Key Concepts on pages 27 to 29.

Ethics Office Contact Information

Ethics Office Contact Information


If you have any questions on this Policy or any of the rules contained within it, please
contact your local Ethics Office (details below). For local Compliance Office contact
details, refer to the online Ethics system.

Bermuda:
Email: Phone:
Bermuda Code of Ethics (internal) 8-765-7285 (internal)
bcoe@fil.com (external) +441-297-7285 (external)

EMEA:
Email: Phone:
UK Ethics Office (internal) 8-723-7060 or 8-723-7251 (internal)
UKEthicsOffice@fil.com (external) +44-1732-777060 or +44-1732-777251 (external)

India:
Email: Phone:
FIL India Ethics Mailbox (internal) 8-779-1092 (internal)
FILIndiaEthicsMailbox@fil.com (external) +91-124-402-1092 (external)

Asia Pacific (including Japan):


Email: Phone:
Asia Code of Ethics (internal) 8-773-1713 (internal)
asiacodeofethics@fil.com (external) (+65) 6511-1713 (external)

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GIFTS AND ENTERTAINMENT POLICY

Gifts and Entertainment Summary

REQUIREMENTS PROHIBITIONS

Reporting all gifts given or received Soliciting gifts or business entertainment


within 30 business days - p.6-7 - p.3,6
Returning or surrendering to your Offering anything of value that could
local Ethics or Compliance Office all be construed as a bribe or improper
inappropriate gifts - p.7 influence - p.4
Declining, returning or surrendering Soliciting, arranging or accepting bribes
any gift that exceeds US$150 (or local intended for your benefit or the benefit
currency equivalent) from the same of your family, friends, associates or
source in a calendar year - p.7 acquaintances - p.4
Obtaining pre-approval for all business Accepting or giving inappropriate gifts
entertainment given or accepted or business entertainment - p.5
(except routine business meals) - p.11 Accepting gifts (even those received as
Obtaining pre-approval to travel on a raffle prize or as a result of a random
a corporate or private aircraft with or draw) in excess of US$150 (or local
paid by a business partner - p.14 currency equivalent) from the same
Maintaining local records of all source in a calendar year - p.7
business entertainment undertaken Accepting or giving gifts in the form of
by FIL - p.19 cash or cash equivalents - p.9
Obtaining Ethics Office approval prior Accepting gifts or business
to offering a gift exceeding US$25 entertainment from, or giving them
to a Government Employee - p.21 to, any vendor or supplier during the
Obtaining Ethics Office approval selection/tendering process - p.9
prior to giving a personal gift to a Attending more than a total of 5
Government Employee - p.21 business entertainment events per
Reporting all business meals offered calendar year (excluding routine
to or received from Government business meals), with no more than 2
Employees exceeding US$25 per with the same business partner - p.12
person within 30 business days - p.23 Buying/selling tickets from/to a business
Obtaining GOC approval, or for Eight partner - p.13
Roads, approval from the President of Reselling tickets received from a
Eight Roads, prior to making political business partner - p.13
contributions or donations on behalf Passing on tickets unless to someone in
of FIL - p.24 your department - p.13
Obtaining country/business head Spouse or Partner attending business
approval prior to making charitable entertainment - p.13
contributions, donations or sponsorships
Accepting accommodation or
on behalf of FIL - p.24
travel costs (except local ground
transportation) - p.14

IMPORTANT NOTE Reporting Violations and Suspicions

If you become aware that you may have violated this Policy, or suspect that
others may have violated this Policy, you must report this to your local Ethics/
Compliance Office. You may also report violations and suspicions anonymously
through the Confidential ALert Line (CALL). (https://thesource.fil.com/
Departments/Investigations/Pages/Confidential-Alert-Line.aspx)

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Key Principles

Every employee is expected to read and understand this Policy before giving or receiving
a gift or business entertainment. You are expected to abide by the spirit as well as the
letter of the Policy.

1. You should always conduct your personal affairs in a manner that does not conflict or
even appear to conflict with the obligations we owe our clients and investors or that
you owe to FIL.

2. It should never be a condition of any business conducted by or through FIL that a gift
or business entertainment is offered.

3. Gifts, favours, business entertainment or preferential treatment should never be


solicited.

4. You should not only consider the substance of a situation but how it might appear to
an outside observer. If the situation might raise questions of impropriety or a conflict
of interest in the eyes of a reasonable outside observer, it should raise questions in
your mind as well, and should prompt you to consult with your manager or your local
Ethics Office.

5. In considering whether it is appropriate to offer a gift or business entertainment to an


actual or prospective client, customer or distributor, you should comply with this Policy
and obtain the necessary approvals where required.

6. Bribery is against FILs policies and violates your local laws and the laws of other
countries in which FIL does business.

General Standards

FIL will secure and keep business by delivering excellent investment expertise and high
quality service with the utmost regard for ethics and integrity; and every staff member
has an individual and personal responsibility for enhancing FILs reputation.

Any business entertainment or gift referred to in this Policy must meet the following
general standards:
There is a clear potential business benefit to the FIL client.
The business entertainment or gift has not been solicited, and is not preconditioned Note:
on, or related to an improper advantage. A gift or business entertainment should not
The business entertainment or gift is not so unique, unusual, frequent or lavish as be contingent on, or a prerequisite for, a
particular outcome.
to raise questions of impropriety. For example, attending frequent dinners or other
outings with the same business associates or employees of the same business
Please see Key Concepts for examples of
partners firm could fail this test on the basis of frequency even if the cost per person business meals that might be considered
were reasonable. lavish.
The character of the business entertainment or gift is appropriate (e.g. adult themes

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GIFTS AND ENTERTAINMENT POLICY

or visits to casinos are prohibited) and customary in type and value in the relevant
country. If there is any question on the appropriateness of the gift or business
entertainment, you should exercise sound judgement and err on the side of caution.
The business entertainment or gift should be given openly and not in any manner that
may appear secretive or illicit.
Any business related entertainment or gift may not be paid for with your personal
monies or those of a third-party, if FIL paying for the same would violate this Policy.

In addition, you must ensure that any business entertainment or gift you offer or
accept is permissible under the applicable local and internal rules and regulations on
inducements, conflicts of interest, or bribery and corruption. This means that in addition
to the above general standards, the following also applies:

Never offer anything of value that could be construed as a bribe or improper


influence. Never offer, promise, give, or authorise anything of value to a current
or prospective business partner, Government Employee or employee of a private
company (including their immediate family members), with the intent to obtain or
retain business or as an inducement or reward for any improper advantage, including
reductions in taxes, tolerance of non-compliance with rules, or any other favour or
preferential treatment. Similarly, you must never offer or authorise payments, gifts or
other benefits through any third party if you know or have reason to know that the
payment will violate this Policy.

Never solicit, arrange or accept bribes intended for your benefit or the benefit of
your family, friends, associates or acquaintances.

Consider your relationship with the current or prospective business partner or


Government Employee. This Policy is not intended to prevent you from exchanging
personal gifts with business partners or Government Employees who are family
members or friends, or who provide you or your family with special services relating
to you personally, such as public school teachers. However, it is essential that you
can demonstrate that your personal gift does not violate any anti-corruption laws or
regulations.

FIL applies the same high ethical standards to its staff in all countries where it operates
and therefore the fact that a particular behaviour is accepted (or indeed regarded as
normal) in a country does not mean it is acceptable within the Policy.

4 FIL Limited Gifts and Entertainment Policy


Developing a Personal Radar

This Policy emphasises ideas such as reasonableness, propriety and sound judgement.
That is because not all situations can be directly addressed within a Policy such as this.
Therefore it is important that you develop a personal radar that helps you to identify
(and avoid) situations that are, or might appear, questionable.

In making an assessment of a situation, it is important to recognise FILs global reputation


for ethics and integrity actions or behaviours which might be regarded as acceptable
or even normal in one market may not be viewed similarly in another, and we therefore
seek to adopt the highest standards in making decisions on what is or is not acceptable
under this Policy.

Below are some questions that you must ask yourself when looking at a specific case:
Cost is the cost in any way lavish, excessive or extraordinary either by local rules, or
customs, or industry practice or FILs ethical culture?
Frequency is the frequency of business entertainment or gifts appropriate to the
business relationship?
Expectation is there any sense in which the business entertainment or gift is based
on an expectation of some inappropriate reward to the donor?
Context and character is the type, cost or nature of the gift or business entertainment
really necessary and appropriate? Would you be comfortable with it being made
public? Is there any potential that someone else may view it as having a corrupt
intent?
Employer is the person who might receive the gift or business entertainment employed
by the government or by a company owned or controlled by the government?
Family members and friends is the person also a business partner or Government
Employee and if so, is the gift or business entertainment truly personal or related to the
business relationship?

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GIFTS AND ENTERTAINMENT POLICY

GIFTS

This section covers all gifts received and any gifts given that are not part of a FIL
corporate or promotional event or activity. Generally gifts are those items given or
received by individual FIL employees rather than by FIL as a company.

The value attributed to gifts is the retail or Appropriate gift giving is permitted both as giver and recipient but should only take
market value and not the face value. Where place at occasions that are customary for gift-giving in the relevant country. FILs
the retail value is not known, it must be
expectation is that gifts will be low value promotional or nominal gift items (see
estimated on a reasonable basis. If in doubt,
consult your local Ethics Office. definition under Low Value Gifts); and these do not need to be reported. However,
should other gifts be given or received, the value of those gifts must not exceed
US$150 or local currency equivalent per business partner, per calendar year (Gift
Limit). See the Country Specific Gifts Limits section on page 26 for local currency limits.

Please bear in mind that although the individual limit for gifts received or given is
US$150 or equivalent per business partner, per year, you can expect more scrutiny
of higher value items from relevant management and the Ethics Office. If in doubt,
surrender any gift received to your local Ethics Office who will raffle it for charity.

Requirements

Giving Gifts
FILs preference is for gifts given to be low value FIL promotional or nominal gift items
(see definition under Low Value Gifts), but in any event before giving a gift you need to
ensure that its value does not exceed the annual Gift Limit. See the Country Specific Gifts
Limits section on page 26 for local currency limits.

Once the gift has been given, the online Gift Notification Form needs to be completed
within 30 business days. Low value FIL promotional or nominal gift items do not need to
be reported.

TO DO:
You must check the total value of gifts you have given to the business partner and
verify that your latest gift will not bring the total value over US$150 (or local currency
equivalent) for the current calendar year.
You must report all gifts given (except low value FIL promotional or nominal gift items)
within 30 business days of giving the gift via the online Gift Notification Form (available
at https://www.coe.fil.com). Low Value gifts are considered to be promotional or
nominal gift items that are valued less than US$50 or local currency equivalent.

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Receiving Gifts
You must report all gifts within 30 business days of the gift being received. Low value
promotional or nominal gift items (see definition under Low Value Gifts) do not need
to be reported. If the gift is inappropriate or falls outside the annual Gift Limit, it should
be returned or surrendered to your local Ethics or Compliance Office. Even if the gift is
returned or surrendered it needs to be reported. Gifts declined prior to them coming into
your possession do not need to be reported.

Please note that gifts received as a result of a raffle prize, door prize or random draw
etc. must fall within the annual Gift Limit. If they do not, the gifts must be returned or
surrendered.

TO DO:
Do not accept more than US$150 or local currency equivalent in gifts from any
business partner during any calendar year. For example, once you accept a US$75
gift from a business partner employee and another US$75 gift from that individuals
employer, you cannot accept more gifts from that firm or any of its employees until
the next calendar year.
Decline or return any gift given to you by a business partner that exceeds US$150 or
local currency equivalent. If the gift cannot be declined or returned without causing
offence, surrender the gift to your local Ethics or Compliance Office. Employees in the
UK, Singapore, India and Bermuda should deliver any surrendered gifts to the Ethics
Office. Employees in all other locations should deliver any surrendered gifts to their
local Business Compliance Team.
You must report all gifts received (except low value FIL promotional or nominal gift
items) within 30 business days via the Gift Notification Form (available at https://www.
coe.fil.com). Low value gifts are considered to be promotional or nominal gift items
that are valued less than US$50 or local currency equivalent.

Sharing a Gift
Where a gift given or received is to be shared among several people, the gift may
exceed the US$150 limit only when the per-person value is below US$150 and the gift
as a whole is not lavish and does not otherwise seem inappropriate or improper.
The general standards on an employees annual Gift Limit still apply. Reporting of such
a gift should be carried out by the manager of the department concerned, identifying
each recipient.

When sending a gift to be shared by a business partner, the reporting should identify
those individuals amongst whom you expect the gift to be shared, or the department
concerned.

TO DO:
For gifts received, the manager of the department concerned must report, via the
online Gift Notification Form, all gifts that are to be shared along with the name of
each recipient. The value of the gift should be reported as the total value.
For gifts given, the manager must report, via the online Gift Notification Form, all gifts
that are to be shared by the business partner, identifying those individuals amongst
whom he/she expect the gift to be shared, or the department concerned. The online
Gift Notification Form is available at https://www.coe.fil.com.

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Exceptions

Low Value Gifts


The following gifts are exempt from the reporting requirement but the general standards
of the Policy apply:
Low value promotional items such as mugs, T-shirts, key chains, hats, calendars
and small electronic items, if they are clearly printed with a business-related logo or
commercial message and are valued less than US$50 or local currency equivalent.
Low value nominal gift items such as tea, cakes, books and similar items that are
valued less than US$50 or local currency equivalent.

Although low value gifts are generally exempt from the reporting requirements (and
the pre-approval requirement for government officials see page 21 for further
information), it is important to note that they may be improper if they are frequently
provided to or received from the same business partner or Government Employee.

Personal Gifts
This Policy does not apply to personal gifts between friends or family. However, where
friends or family are also business partners it is important to determine whether a gift is
personal or business-related, and whether there might be an actual or perceived conflict
of interest created by the gift. You should ask yourself the following questions to avoid
any impropriety:

W
 hat is the relationship with the donor/recipient? the personal aspect should be
more significant.

Who paid for the gift? if it was paid for personally that is usually an indication that
it is a personal gift.

W
 hats the occasion? milestones such as birthdays, weddings and anniversaries
would be regarded as personal, while the signing of a contract or a thank you for
past business might suggest it is a business gift and subject to the requirements of
this Policy.

Please note: You may not use your personal monies to pay for a business gift for a
business partner, if FIL paying for the same would violate this Policy.

If the gift involves Government Employees additional restrictions may apply. Please refer
to the section on Anti-corruption and Dealing with Government Employees on page 20 for
further information.

8 FIL Limited Gifts and Entertainment Policy


Prohibitions

Cash and Cash Equivalents


You must not accept gifts from or give gifts to business partners in the form of cash, or
cash equivalents (including securities, vouchers, lottery tickets or gift cards / certificates),
even if won as a result of a random draw. This restriction does not apply to internal gifts,
such as staff awards.

You must not accept a discount, price concession or rebate provided by a business
partner which has not been made available universally to all FIL employees.

TO DO:
Decline or return any cash or cash equivalent gift received from a business partner. If
the gift cannot be declined or returned without causing offence, surrender the gift to
your local Ethics or Compliance Office.
Do not give cash or cash equivalent gifts to business partners.
You must report any cash or cash equivalent gift received within 30 business days via
the online Gift Notification Form.

Gifts Given or Received During the Tendering/Selection Process


If you are the primary relationship manager, or are aware of or involved directly in the
negotiation to secure products or services, you may not accept gifts from, or give them
to, any vendor or supplier during the selection or tendering process.

TO DO:
Decline or return any gift given to you by a current or prospective business partner
during the selection or tendering process. If the gift cannot be declined or returned
without causing offence, surrender the gift to your local Ethics or Compliance Office.
Do not give gifts to any prospective business partner during the selection or
tendering process.
You must report any gift received during the selection or tendering process within 30
business days via the Gift Notification Form.

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Examples Of Gifts

1. John, a FIL employee, receives a leather diary worth US$100 from a business partner
Permitted & Reportable The gift is permitted as it is appropriate and is under the
US$150 limit. John must report the gift via the online Gift Notification Form within 30
business days of receipt.

2. A different employee from the same firm that gave John the leather diary sends a gift
basket to Johns department. Johns manager estimates the baskets value at US$50
per employee.
Permitted & Reportable John can accept the US$50 in additional gifts from the
firm but he is now at his US$150 maximum for that firm. He must decline any further
gifts from the firm or any of its employees (including shared gifts) until the next
calendar year. Johns manager must report the basket noting all recipients. Any
further gifts must be returned or surrendered to his local Ethics or Compliance Office
and reported as a gift returned via the online Gift Notification form.

3. Jane is a personal friend and business partner of Douglas who is a FIL employee.
Jane sends Douglas a US$400 case of wine for Christmas. Douglas regards it as
a personal gift but later discovers that the wine was paid for by Janes firm, not
Jane herself.
Prohibited & Reportable The gift cannot be considered personal since it was
paid for with the other firms resources and its value well exceeds the allowable gift
amount. The wine must be returned or surrendered to his local Ethics or Compliance
Office and reported as a gift returned via the online Gift Notification Form.

4. Douglas receives a US$50 gift card to one of the stores owned by a company in
which FIL invests.
Prohibited & Reportable The gift card must be returned or surrendered to his
local Ethics Office as it is considered a cash equivalent. Cash equivalents closely
resemble cash to the extent they have value and do not relate to a specific item.
A gift card at a store allows the holder to buy whatever they want in the store which is
no different than holding cash.

5. Douglas receives a discount voucher from a business partner that entitles only him
to a 10% discount if he purchases over US$500 of merchandise.
Prohibited & Reportable Discount vouchers that are not universally available to
all FIL employees are not permitted as they are considered cash equivalents.

6. Douglas receives a scarf worth less than US$150 from a prospective business partner
who is currently tendering for a contract with FIL.
Prohibited & Reportable - Gifts or entertainment involving parties engaged in a
tender or competitive bidding process are prohibited under the Policy as they could
be construed as a reward or bribe.

7. Sarah, a FIL employee, gives a business partner a bottle of wine valued at US$75.
She had given the same business partner a gift valued at US$65 earlier in the same
calendar year.
Permitted & Reportable - The gift is permitted as it is appropriate and the total value
of the gifts given to the same business partner is under the US$150 limit. Sarah must
report the gift via the online Gift Notification Form within 30 business days of giving
the gift.

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BUSINESS ENTERTAINMENT

Receiving Business Entertainment

This section covers all business entertainment offered to FIL employees. This can include
attending a sporting event, participating in a golf day or accepting an invitation to a
cultural event such as a concert or the theatre. It can also include a broker or issuer-
sponsored conference (except for those conferences that are educational in nature), and
research trips. The definition of business entertainment extends to business meals if the
event takes on the character of entertainment, for example when they are lavish or too
frequent to be classed as routine. Please refer to the Key Concepts section on page
27 for further information on business entertainment.

Specific Standards

In addition to adhering to the General Standards governing this Policy, you may only
accept an offer of business entertainment if:
The nature of the event makes it likely the potential business benefit to the FIL client
can be explored.
The host is present (otherwise, the entertainment would be subject to the section
on gifts).
Prior approval has been obtained from a member of the Global Operating Committee
(GOC) (see quick links in The Source) or a person that directly reports to a GOC
member in a business capacity and is designated by the GOC member to serve as
an approver under this Policy (Designated Approver). For those who work for Eight
Roads, prior approval must be obtained from the President of Eight Roads.
Any entertainment that is not consistent with this Policy should be politely refused.

Requirements

Obtaining Approval for all Business Entertainment Received Except


Routine Business Meals
You must obtain prior approval for all business entertainment received from a business
partner other than routine business meals.

Business meals that take on the character of business entertainment (for example, when
they are lavish or too frequent to be classed as routine) should be pre-approved
if you know in advance that the meal will fall within the definition of lavish (see Key
Concepts, page 29 for examples of business meals that might be considered lavish). If
you are unsure whether a business meal has to be pre-approved, please check with your
manager or local Ethics Office.

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Exception:
In circumstances where pre-approval is not practically possible e.g. if you are
attending a business meal with a business partner and an invitation is extended to
you to go to a business entertainment event immediately following the business meal
pre-approval is not required but the business entertainment must be promptly reported
to your respective GOC member or Designated Approver.

TO DO:
Before accepting business entertainment (other than routine business meals), you must
obtain the prior approval of your respective GOC member or Designated Approver, or if
you work for Eight Roads, the President of Eight Roads. Approval must be sought via the
Business Entertainment Approval Form (available at https://www.coe.fil.com). You must
not accept or attend such business entertainment without first obtaining such approval.
In circumstances where pre-approval is not practically possible, as outlined in the above
exception, you must report the business entertainment to your respective GOC member
or Designated Approver (or for Eight Roads, the President of Eight Roads) as soon as
possible after the event using the same approval form.
If you know in advance that a business meal you have been invited to attend will fall
within the definition of lavish, you must obtain the prior approval of your respective GOC
member or Designated Approver, or if you work for Eight Roads, the President of Eight
Roads using the Business Entertainment Approval Form (available at https://www.coe.
fil.com). Otherwise you must report the lavish business meal to your respective GOC
member or Designated Approver (or for Eight Roads, the President of Eight Roads) as
soon as possible after the meal using the same approval form.
Confirm via the automated email you receive, whether or not you attended an event
and obtained prior approval.

Frequency of Business Entertainment


Business entertainment and routine business meals can be good for building relationships;
however, attending too many events as a guest of a business partner can raise questions
about their appropriateness. With the exception of routine business meals, you may not
as a guest attend more than 5 business entertainment events per calendar year, of which
no more than 2 should be with the same business partner. Please note that you must
obtain approval from your GOC member or Designated Approver, or if you work for Eight
Roads, the President of Eight Roads, prior to attending each event. The GOC member or
if you work for Eight Roads, the President of Eight Roads also has discretion to authorise
attendance at business entertainment events above the aggregate limit.

TO DO:
Ensure that you obtain approval prior to attending a business entertainment event.
With the exception of routine business meals, do not attend more than 5 business
entertainment events over a period of one calendar year unless your GOC member
or, if you work for Eight Roads, the President of Eight Roads, authorises you otherwise.
With the exception of routine business meals, do not attend more than 2 business
entertainment events with the same business partner over a period of one calendar year.

12 FIL Limited Gifts and Entertainment Policy


Attending with a Spouse or Partner
Attending a business entertainment event (including routine business meals) with a spouse
or partner is prohibited. In rare circumstances, approval may be considered by your
respective GOC member or Designated Approver, or if you work for Eight Roads, by the
President of Eight Roads. All approvals will be reviewed by the Ethics Oversight Group.

Tickets
You may not buy tickets from or sell them to a business partner unless:
it is a personal transaction with a friend or family member and the seller owns the
tickets personally, and the exchange is not related to business activity; or
the tickets are purchased from an original source that also happens to be a
business partner.
You may not resell tickets received from a business partner nor pass on such tickets to
anyone else unless to another FIL employee who, because of their role, could have taken
advantage of the business opportunity had it been offered to them directly.

Educational Seminars, Conferences and Similar Events


Bona-fide training or educational seminars arranged or paid for by a business partner
are not considered business entertainment and are therefore not subject to this Policy. The value attributed to tickets to sporting and
cultural events is the retail or market value not
To qualify as bona-fide the seminar must be serious, substantive and have plausible the face value. Where retail value is not known
connection to the business relationship concerned and be substantive enough to stand it must be estimated on a reasonable basis. If
in doubt consult your local Ethics Office.
on its own merits.

When a seminar or training event is accompanied by any social event, theatre,


concert, sporting event, meal or other leisure activity then the General Standards
of the Policy apply.

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GIFTS AND ENTERTAINMENT POLICY

Accepting Travel and Accommodation

Travel and Accommodation with Business Entertainment


You may not accept accommodation or travel costs (other than local ground
transportation such as a coach laid on for a whole party) paid on your behalf by a
business partner when attending business entertainment.

Travel and Accommodation with Regular Business Activities,


Educational Seminars or Conferences etc.
You may also not accept accommodation or travel costs (other than local ground
transportation) paid on your behalf by a business partner in connection with regular
business activities such as attending a business meeting, educational seminar or
attending or presenting at a conference (this includes any speaking engagements).

Corporate or Private Aircraft Travel for Business Purposes


Travelling on a corporate or private aircraft with or paid for by a business partner is
not encouraged and must be pre-approved. Such travel will be approved only where
there is a clear and proper business justification. Pre-approval must be sought using
the relevant form on the online Ethics system. Whenever possible, the business partner
should be reimbursed.

If you are a portfolio manager, analyst or trader, authorisation must be obtained from
the relevant CIO or (for analysts) Director of Research. Otherwise approval must be
obtained from a member of the GOC or, if you work for Eight Roads, the President of
Eight Roads.

TO DO:
You must obtain pre-approval for corporate/private aircraft travel using the Travel by
Corporate or Private Aircraft Form accessible via the online Ethics system (available at
https://www.coe.fil.com).

Business Entertainment Received during the Tendering/


Selection Process
If you are the primary relationship manager, or are aware of or involved directly in the
negotiation to secure products or services, you may not accept business entertainment
from any vendor or supplier during the selection or tendering process.

TO DO:
Decline any business entertainment offered to you by a current or prospective business
partner during the selection or tendering process.

14 FIL Limited Gifts and Entertainment Policy


Examples of Business Entertainment Received

1. Michael, a FIL analyst, is invited to a golf game by an employee who works for a software
company which is a business partner. This is the second event Michael has been invited
to by this business partner over the course of the year.

Pre-Approval Required This is normal business entertainment that was offered without
any preconditions and Michael has good reason to believe that attending the event
with this individual will further a business relationship. This is also the second business
entertainment event that Michael has attended this year which is within the frequency limit
outlined in the Policy. However, prior to accepting the invitation, Michael will need to seek
pre-approval from his respective GOC member or Designated Approver.

2. Michael, the FIL analyst mentioned in the previous example, is invited to a business
entertainment event by another employee who works for the same company mentioned
in the previous example, although in a different business unit.

Prohibited Employees may not attend more than 2 business entertainment events
in a calendar year with the same business partner. Although the invitation is from an
employee in a different business unit, it would be considered the same business partner
and attending this event would cause Michael to exceed the Policy limit.

3. A business partner invites Fiona, a FIL portfolio manager, to the mens semi-finals at
Wimbledon.

Pre-Approval Required Although the entertainment was not given with any
preconditions and is intended to build a business relationship, Fiona will need to seek
pre-approval from her respective GOC member or Designated Approver before
accepting the invitation.

4. Jack, a FIL employee, is invited to use a business partners house in the Isle of Man.

Prohibited As no business partner is present, the use of the house is considered a


gift, not business entertainment, and is valued at more than the US$150 gift limit. Even
if the business partner were present, the acceptance of accommodation is generally not
permitted.

5. Michelle, a FIL employee, is attending a bona-fide educational seminar put on by a


business partner and part of the conference includes tickets to the theatre.

Pre-Approval Required Even though the educational seminar is not itself considered
business entertainment under the Policy, any social event (including the theatre), leisure
activity or meal that accompanies such seminars are subject to the Policy. Michelle must
therefore seek pre-approval from her respective GOC member or Designated Approver
(or if she works for Eight Roads, the President of Eight Roads) before accepting the
invitation to the theatre.

6. While on the phone with a broker, Simon (a FIL employee) learns that they are
sponsoring a summertime jazz festival. He asks if they would invite him or sell him
tickets.

Prohibited Employees are prohibited from soliciting business entertainment from


business partners and from buying tickets from business partners unless purchased
from the original source.

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GIFTS AND ENTERTAINMENT POLICY

7. The finance director of a company in which FIL funds have a substantial holding
invites Rhiannon, a FIL employee, and her partner to make use of their company
yacht this weekend.

Prohibited As no business partner is present, the use of the yacht is considered a gift,
not business entertainment, and is valued at more than the US$150 Gift Limit. Even if the
business partner were present, the entertainment might be viewed as lavish enough to
raise a question of impropriety.

8. Debbie, a FIL healthcare analyst, is invited to the same automobile launch event as her
co-worker, Kevin who is the FIL auto analyst.

Prohibited Generally, the entertainment would not be appropriate for the healthcare
analyst and could be considered extravagant as two analysts from the same company
are invited. However, if the healthcare analyst believes the entertainment is merited, she
must seek approval from her respective GOC member or Designated Approver prior to
attending the event.

16 FIL Limited Gifts and Entertainment Policy


Giving Business Entertainment

This section covers all business entertainment provided by FIL or funded by FIL but This section of the Policy covers everything
offered by individual FIL employees to potential or existing business partners. This can that was referred to in prior years policies as
a promotional activity.
include FIL corporate or promotional events or activities, conferences or seminars, due
diligence trips for clients and any activities (meals, sporting or cultural events) associated
with such events. For clarification on what is deemed business entertainment, please
refer to the definition on page 27 Key Concepts.

All business entertainment funded by FIL but offered by individual employees are
subject to the rules contained in this Policy unless otherwise stated in this section.

Corporate and promotional events or activities (e.g. customer incentive programmes)


are generally subject to the provisions of the Policy. The employee or business
unit that is inviting business partners is responsible for ensuring that the business
entertainment complies with all applicable provisions of this Policy.

For clarification purposes, gifts funded by FIL but offered by individual FIL employees
rather than by FIL are considered gifts and covered under the Gifts section. However,
gifts or prizes funded and offered by FIL as part of a corporate or promotional event or
activity are covered under this section.

All General Standards governing this Policy apply.

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GIFTS AND ENTERTAINMENT POLICY

Requirements

Business Entertainment provided by FIL

Approvals
For the Personal Investing, Platform or Wholesale business most business entertainment
will involve the Marketing or Corporate Events departments and approval must first
be given by the relevant country or business head and then by the appropriate GOC
member or Designated Approver.

For the institutional business, different approval requirements apply and you should
consult with your manager. In addition to those approval requirements, you must also
obtain prior approval from the appropriate GOC member or Designated Approver.

Specific local procedures for obtaining approval are available from your local Ethics
contact. You should bear in mind that the recipients of business entertainment may also
have duties to their own employer, to their own clients and to regulators of their own
business and you should not put such recipients in a position of conflict or perceived
conflict with such duties.

If the business entertainment involves Government Employees please refer to the


section on Anti-corruption and Dealing with Government Employees on page 21 as the
requirements relating to Government Employees are more restrictive.

Low value FIL promotional or nominal gift items and gifts below the Gift Limit can be
given without any need for prior approval provided you follow the general standards set
out in the Gifts section of this Policy. Gifts given as part of a promotional or corporate
event that exceed low value (i.e. US $50) require approval by your respective GOC
member or Designated Approver.

TO DO:
Before giving business entertainment (other than routine business meals), you must first
obtain approval as specified above.
For gifts given in conjunction with a promotional or marketing event, you must obtain
approval for the gifts at the same time you obtain approval for the event. Although
various initial approval requirements may apply, you must still obtain approval from
your respective GOC member or designated approver via the Business Entertainment
Approval Request Form (available at https://www.coe.fil.com).

18 FIL Limited Gifts and Entertainment Policy


Reporting
Records of all business entertainment provided by FIL must be maintained by the teams
organising and facilitating the events (e.g. marketing or other relevant departments).
These records must be maintained in the Promotional Activities template provided by the
Ethics Office and be provided to the Ethics Office at least quarterly. Details recorded must
include, among other things:
Date of event/promotional gift, prize etc.
Business purpose
Approver(s)
FIL attendee
Business partners in attendance, identifying Government Employees
Nature of event/promotional gift, prize etc.
Total cost
Cost per person
Low value FIL promotional or nominal gift items are excluded from this reporting
requirement. Other gifts given by FIL as part of a promotional or corporate event must
be reported on the Promotional Activities template provided by the Ethics Office.

TO DO:
You must maintain records of all business entertainment (other than routine business
meals) given by your department using the Promotional Activities template provided by
the Ethics Office.
You must report all gifts given by FIL as part of a FIL promotional or marketing event
on the Promotional Activities template provided by the Ethics Office.

Business Entertainment funded by FIL but provided by individual


FIL employees
For employees who wish to provide business entertainment that will be paid for by FIL,
you must first obtain prior approval from the appropriate GOC member or Designated
Approver or, for Eight Roads, the President of Eight Roads.

Any gift given by an individual FIL employee in conjunction with business entertainment
is subject to the provisions detailed in the Gifts section of this Policy, including the annual
gift limit of US $150 (or local currency equivalent).

TO DO:
Before giving business entertainment (other than routine business meals), you must
first obtain approval from your respective GOC member or Designated Approver.
This includes business meals that take on the character of business entertainment (for
example, when they are lavish or too frequent to be classed as routine). Approval
must be sought via the Business Entertainment Approval Form (available at https://
www.coe.fil.com). See Key Concepts for examples of business meals that might be
considered lavish.
Before giving a gift you must check the total value of gifts you have given to the
business partner and verify that your latest gift will not bring the total value over US$
150 (or local currency equivalent) for the calendar year.
You must report any gift given (except low value FIL promotional or nominal gift items)
within 30 business days of giving the gift via the online Gift Notification Form (available
at https://www.coe.fil.com).

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GIFTS AND ENTERTAINMENT POLICY

Educational Seminars, Conferences and Similar Events


Bona-fide training or educational seminars arranged or hosted by FIL are not considered
business entertainment and are therefore not subject to this Policy.

To qualify as bona-fide the seminar must be serious, substantive and have plausible
connection to the business relationship concerned and be substantive enough to stand
on its own merits.

Where a seminar or training event is accompanied by a social event, theatre, concert,


sporting event, meal or other leisure activity, the General Standards and other relevant
sections of the Policy apply.

TO DO:
Consult with the Bermuda Ethics Office or your local Ethics contact for assistance when
considering or planning a seminar, conference or educational event.

Providing Travel and Accommodation

In some cases, FIL may pay for reasonable travel and/or accommodation for clients
attending promotional events, educational events or conferences etc. All travel and
accommodation provided to business partners must be pre-approved, first by the
relevant country or business head and then by the appropriate GOC member or
Designated Approver.

TO DO:
Before offering to pay for travel and accommodation obtain pre-approval from your
country or business head, and the applicable GOC member or Designated Approver,
via the Business Entertainment Approval Form (available at https://www.coe.fil.com).

Prohibitions

Business Entertainment Given during the Tendering/Selection Process


If you are the primary relationship manager, or are aware of or involved directly in the
negotiation to secure products or services, you may not give business entertainment to
any vendor or supplier during the selection or tendering process.

TO DO:
Do not give business entertainment to any current or prospective business partner
during the selection or tendering process.

20 FIL Limited Gifts and Entertainment Policy


ANTI-CORRUPTION AND DEALING WITH
GOVERNMENT EMPLOYEES

This section sets out the special rules and concerns relating to giving gifts to or undertaking To view a definition of Government Employee
business entertainment with Government Employees. FIL has a zero-tolerance policy toward please refer to Key Concepts page 29.

bribery (see Key Concepts on page 27). Violations of anti-bribery and corruption laws carry
serious regulatory, civil and criminal penalties, both for you as an individual and for FIL.
Please refer to the FIL Group Anti-Bribery and Corruption Policy for further information.

Requirements for Gifts Offered to


Government Employees

Other than low value FIL promotional or nominal gift items, gifts should not normally be
offered to Government Employees. However, any gift that is offered must not exceed US $150
(or local currency equivalent). All general standards in the Gifts section of the Policy apply.

Pre-approval
All gifts (other than low value FIL promotional or nominal gift items) to Government
Employees must be pre-approved by your local Ethics Office. For the purposes of this
section of the Policy, low value promotional or nominal gift items are those valued less
than US$25 or local currency equivalent.

Personal gifts to Government Employees must also be pre-approved, unless the gift falls
within one of the exceptions listed below.

Exceptions:
Personal gifts given to family members or friends where the following criteria are both met:
The recipient does not serve in a role that could impact FILs interests (e.g. an
elected official would not fall under this exception); and
The recipient is not a current or prospective business partner (e.g. holiday gifts to
your brother-in-law who is an employee of the Department of Public Works would fall
under this exception).
Personal gifts given in recognition of a public service provided to you or your family
and for which recipients are not in a position to impact FILs interests (e.g. school
teachers etc.).
The personal relationship with the Government Employee has been disclosed via the
Conflicts of Interest Form and approval has been obtained from your local Ethics Office.

TO DO:
You must obtain pre-approval from your local Ethics Office before offering any gift (other
than low value FIL promotional or nominal gift items valued less than US$25 or local
currency equivalent) to a Government Employee. Pre-approval must be sought using the
Business Entertainment Approval Form (available at https://www.coe.fil.com).

You must obtain pre-approval from your local Ethics Office before offering any personal gifts
to Government Employees where the recipient is a current or prospective business partner
or is in a role that could impact FILs interests. However, pre-approval is not required if the
personal relationship with the Government Employee has been reported via the Conflicts of
Interest Form and approval has been obtained from your local Ethics Office.

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GIFTS AND ENTERTAINMENT POLICY

Requirements For Gifts Received from


Government Employees

FIL does not expect Government Employees to give FIL employees gifts but if they do the
normal rules in the Gifts section of the Policy apply.

TO DO:
You must report any gift received from a Government Employee (except low value gifts
under US$25) on the online Gifts Notification Form (available at https://www/coe.fil.
com) within 30 business days of receiving the gift.

Requirements for Business Entertainment and


Business Meals with Government Employees

The offer of business entertainment or business meals to or from Government Employees


is specifically prohibited in certain countries. Please check the country supplements or
with your local Ethics Office if you are unsure if this prohibition applies. In all other cases,
the following rules apply.

Pre-Approval
Business entertainment received from or offered to Government Employees requires
prior approval from your local Ethics Office and your respective GOC member or
Designated Approver (or, if you work for Eight Roads, the President of Eight Roads).
The approval request form can be found on the online Ethics system (available at
https:// www.coe.fil.com).

Paying for travel related expenses (if permitted in the local jurisdiction) also requires the
prior approval of the Ethics Office and a GOC member. Please note that a final itinerary
is required for a business entertainment or other event or a training/educational seminar.
This means that if there are any amendments to the scheduled event or itinerary after the
initial submission, you are required to submit the request (with updated details) to your
local Ethics Office for approval.

TO DO:
Obtain pre-approval first from your local Ethics Office and then a GOC member or
Designated Approver (or, if you work for Eight Roads, the President of Eight Roads
before accepting business entertainment (except routine business meals) from, or
offering business entertainment to, Government Employees. Send a completed Gifts/
Entertainment with Government Employees Approval Request Form (available on the
online Ethics system at https://www.coe.fil.com), together with any required supporting
documentation, to your local Ethics Office.
Obtain pre-approval from your local Ethics Office and your respective GOC member
before paying or agreeing to pay for travel related expenses.

22 FIL Limited Gifts and Entertainment Policy


Routine business meals (including cocktail parties or similar events) offered to
Government Employees do not need to be pre-approved except when they are lavish or
too frequent to be classed as routine. If you are unsure whether a meal has to be pre-
approved, please check with your manager or local Ethics Office.

Reporting
You must report any routine business meals exceeding US$25 per person (or local
currency equivalent) to the Ethics Office via the online Meals with Government Employees
Form within 30 business days of attending the meal. Where meals are attended by
more than one employee, reporting of such meals should be carried out by the most
senior employee in attendance, identifying each attendee.

In situations where business entertainment is offered by Government Employees the


normal rules set out in the Receiving Entertainment section of this Policy apply.

TO DO:
Report routine business meals given and received that exceed US$25 per person (or
local currency equivalent) on the online Meals with Government Employees Form
(available at https://www.coe.fil.com) within 30 business days of attending the meal.
Business entertainment provided by FIL (i.e. FIL promotional or corporate events) must
be reported on the template provided by the Ethics Office within 30 business days of
the event taking place. Note: This does not apply to business entertainment funded by
FIL but provided by an individual FIL employee.

Requirements for Employees in Roles that


Involve Regular Contact with Government
Employees

Certain business areas, such as Government Institutions with its sovereign wealth clients,
are in regular contact with Government Employees and may have particular rules and
procedures that apply to them. If you are unsure whether you fall under this category, you
should check with your manager or your local Ethics Office.

Anti-Corruption Examples

1. Jack, a FIL employee, would like to give a birthday gift to his brother-in-law who works
for the local financial regulator.

Pre-approval Required Although this is a personal gift, Jack will be required to


seek pre-approval from his local Ethics Office before giving the gift to his brother-
in-law as the regulator has a business relationship with FIL. However, pre-approval
would not be required if Jack previously disclosed the relationship via the Conflicts of
Interest Form and also had obtained approval from the Ethics Office.

www.coe.fil.com 23
GIFTS AND ENTERTAINMENT POLICY

2. Julia, a FIL employee, travels to Latin America to secure a government license that
is necessary for a business opportunity. The license Julia applied for is granted by a
specific Government Employee who decided to fast-track the processing time. Later
that year, Julia learns that this Government Employee has received a promotion,
and decides to give him a congratulatory gift. She settles on a set of silver cuff
links valued at US$160. Because she is unsure whether FIL will permit the gift, she
considers purchasing it with her own money.

Prohibited While a modest gift may be allowable if pre-approved, this gift would
be considered lavish, violates the Gift Limit, and may exceed the value limit imposed
by the officials own government. Paying for the gift herself is also not permitted
because by doing so, FIL would have no record of the gift.

3. A department within FIL invites a Hong Kong Government Employee to attend an event
it is hosting in the UK. The department agrees to pay for the Government Employees
travel expenses, which includes a stopover in Europe for the Government Employee to
visit a family member. Prior approval to pay for the travel expenses was not sought.

Prohibited - All travel related expenses (if permitted in the local jurisdiction) require
prior approval from the Ethics Office and a GOC member. Approval, if granted, would
pertain only to travel to and from the Government Employees resident country. No
additional stopovers would be permitted.

4. Katie, a FIL employee, invites Erin a business partner who works as a lecturer for a
State University to a modest dinner to promote a new FIL product.

Must be Reported As Erin works for a State University, she would be considered
a Government Employee. Routine business meals with Government Employees
exceeding US $25 (or local currency equivalent) must be reported via the online
Meals with Government Employees Form within 30 business days of the meal.

POLITICAL AND CHARITABLE CONTRIBUTIONS

Political Contributions
Political contributions/donations (including fund raisers or similar events) are governed
by complex laws and in some countries are prohibited. Accordingly no such contributions
may be made on behalf of FIL without approval from a GOC member.

Charitable Donations and Sponsorships


Please consult with your relevant country/business department head before making
charitable donations or sponsorships on behalf of FIL.

Never make a political contribution, charitable donation or sponsorship on behalf of FIL


that can be construed as a bribe or improper influence.

24 FIL Limited Gifts and Entertainment Policy


HOW WE ENFORCE THE POLICY

The Ethics Office


The Ethics Office is responsible for this Policy, the Code of Conduct, as well as the
Personal Trading and Price Sensitive Information Policy, and regularly reviews the
forms and reports it receives. If these reviews reveal information that is incomplete,
questionable, or potentially a violation of this Policy, the Ethics Office will investigate
the matter and may contact you or, where FIL is giving business entertainment, the
relevant department. If you are asked to provide further information or justification
it is in your interest to do so promptly, completely and accurately.

Reports of gifts and entertainment will be regularly provided to various members of


senior management as well as the FIL Ethics Oversight Group (EOG).

Violations
Violations of this Policy may lead to disciplinary action, and could subject you and FIL
to civil, criminal or regulatory penalties.

If it is determined that you have breached this Policy, FIL has a variety of sanctions
available to it which may take the form of one or any combination of the following:

A manager briefing
A sanction letter placed on your personal record
A fine or other financial penalty
Dismissal from employment
Referral to civil, criminal or regulatory authorities

Before any sanction is applied you will be provided with an opportunity to explain
your conduct and make a representation. You will be advised before making your
representation of the potential sanction that might be applied to the violation.

Serious cases may be considered by the EOG formed of representatives from the
business, support and oversight areas.

FIL may take into account any relevant past conduct of the employee, such as prior
breaches as well as if the violation has been reported at the employees own initiative.

FIL will strive to be fair and consistent both in terms of the particular circumstances of
the case and its overall policy on discipline.

FILs interpretation of the requirements of this Policy will take into account all relevant
material and will be regarded as final.

In taking decisions on alleged violations of the Policy, FIL will have regard to the Key
Principles, General Standards and to the potential of the alleged violation to cause FIL
and its officers to face prosecution, as well as damage to FILs reputation were it to be
known outside of the organisation - it will not be a defence simply to assert that the
particular action was not explicitly prohibited by the Policy.

www.coe.fil.com 25
GIFTS AND ENTERTAINMENT POLICY

Exceptions
Unless stated otherwise, any exceptions to the Policy must be approved in writing and
in advance by your local Ethics Office in consultation with the Bermuda Ethics Office.

Appeals
If you believe that an inappropriate sanction has been applied to you there is an
appeal process.

Within a reasonable period, usually five days of the decision, you should provide the
Ethics Office with an explanation for your seeking a review, including any factors which
may not have previously been considered. You may seek a personal meeting on the
matter and bring a personal representative.

In cases of a very serious sanction, any appeal will be handled in accordance with
local employment procedures.

COUNTRY SPECIFIC GIFT LIMITS

COUNTRY LIMIT

Australia AUD 215

Bermuda USD 150

Brazil BRL 575

Chile CLP 105,000

China CNY 950

Euro Member Countries EUR 135

Hong Kong HKD 1,150

India INR 5,000

Japan JPY 18,000

Poland PLN 550

Singapore SGD 215

South Korea KRW 180,000

Sweden SEK 1275

Switzerland CHF 145

Taiwan TWD 3,000 (SITE and FIST)

UAE AED 550

United Kingdom GBP 100

US USD 150

26 FIL Limited Gifts and Entertainment Policy


KEY CONCEPTS

Anything of value
Any object, favour, service, cash or cash equivalent, entertainment, gift, property or
monetary payment, whether paid for personally or offered by FIL.

Bribery
Bribery is offering, promising, giving or receiving a financial (or other) advantage
with the intention of inducing or rewarding a person to act or for having acted in a
way which a reasonable person would consider improper in the circumstances.

Business Entertainment
Entertainment, whether given by FIL or received by an employee, can include:
any sporting, cultural event (e.g. concert or theatre) or similar event;
seminars, conferences and research trips that are not of an educational nature,
and any social event or leisure activity associated with such events;
social and leisure activities associated with seminars, conferences and research
trips that are of an educational nature;
any corporate or promotional event/activity including prizes or gifts given or received
as part of the event/activity;
routine business meals if the event takes on the character of entertainment, for
example through the choice of venue, the cost of the meal or its frequency. It is
important to note that routine business meals with Government Employees must be
reported via the online Business Entertainment Form if their value exceeds US$25
per person;
due diligence trips given to clients;
any travel or accommodation associated with such events.

www.coe.fil.com 27
GIFTS AND ENTERTAINMENT POLICY

Business Partner
This includes companies and individuals and refers to:

Any customer, vendor or supplier, whether current or prospective


Any broker-dealer firm
Distributors or intermediaries involved in the sale of FIL products
Any firm which is or is considered being held within a FIL portfolio
Any research provider or other vendor seeking to do business with FIL
Any employee, representative, agent or other individual associated with the above
Any Trustee, Depositary or Party providing services to FIL through outsourced contracts
A member of any of the above persons immediate family
Any two individuals working for the same firm would be treated as the same business
partner under this Policy.

Designated Approver
A person that directly reports to a GOC member in a business capacity and is
designated by the GOC to serve as an approver under the Policy.

Gift
A gift is anything of value that you receive from or give to a business partner
for whatever reason including but not limited to:

Cash or similar (prohibited)


Securities
Clothing
Goods
Wine and food
Flowers
Charitable donations made in your name by someone else
Gifts also include attendance at business entertainment events where the host is not
present or there is no clear business benefit to FIL. It also includes discounts, price
concessions or rebates provided by a business partner not generally available to other
FIL employees.

Gift Limit
The value of gifts received or given must not exceed US$150 or local currency equivalent
per business partner, per calendar year.

28 FIL Limited Gifts and Entertainment Policy


Government Employee
Individuals that you are dealing with in their capacity of being:
An employee of a government department, government agency, government ministry
or government-owned or government controlled instrumentality, whether at local,
regional or national level (including regulators, legislative and judicial positions etc.)
A member of any military organisation or person of power or influence within a
political party
An employee of a public international organisation, such as the International Monetary
Fund, the European Commission, the United Nations or the World Bank
A director, officer, or employee of a company or enterprise that is owned or controlled
by a government, such as a sovereign wealth fund or state owned enterprise
An individual acting in an official capacity for a government, including for a public
agency or public or private enterprise, and including honorary positions
Family members or agents acting on behalf of any of the above
Except as otherwise provided in a Country Supplement to this Policy or the ABC Policy,
Government Employees do not include directors, officers or employees of publicly listed
companies that may be owned or controlled by a government, unless the employee also
falls within one of the other categories above.

Lavish
Anything that may appear overly generous, frequent, or abundant, either by local rules
or customs or industry practice or FILs ethical culture as defined in this Policy or any
applicable supplement to this Policy.
Examples of business meals that, depending on the occasion, may be deemed lavish are:

A meal at a luxurious or gourmet restaurant


A meal or dining experience such as Haute cuisine or a meal at a palace, museum,
or on a yacht
A meal involving the consumption of prestigious liquor or cigarettes/cigars
A meal involving dishes of various rare and/or luxury food items
This list is not exhaustive and is meant only to provide guidance. If you have any
questions, please contact your local Ethics or Compliance officer.

Promotional Activity
A Promotional Activity can be described as any activity sponsored or coordinated by
FIL as part of a corporate or promotional event or activity involving potential or existing
business partners to promote FIL. This includes most business entertainment and can cover
sales incentives and raffle prizes, conferences or seminars, due diligence trips for clients
and any activities associated with such events. Examples include box-seat gatherings at a
sporting event, a tent at a golf event, or tickets distributed by Corporate Sponsorships. The
employee or business unit that is inviting business partners is responsible for ensuring that
the event complies with all applicable provisions of this policy.

Sporting Events
This includes the attendance at all sports related events, for example, football and rugby
matches, tennis, cricket, track days, horse racing and sailing.

FIL
FIL Limited and its subsidiaries.

www.coe.fil.com 29