This statement summarises our policy regarding the provision or receipt of gifts and hospitality.
As part of its regular day-to-day business activities, Artemis will provide or receive small business gifts and hospitality to or from third parties with whom we conduct business.
Hospitality will be offered or accepted where it is deemed that the event will offer the opportunity to enhance the relationship between Artemis and the third party by discussing market trends, product development issues and the overall business relationship. Hospitality events typically involve a meal and/or a social engagement. Such events will be designed to enhance the quality of service we deliver to the investors in our funds and other clients.
Artemis has clear policies and procedures in place to ensure that gifts and hospitality provided and received are reasonable and do not result in a conflict of interest with the best interests of our clients. Limits are placed on the value and frequency of the provision and receipt of gifts and hospitality, and there are processes to ensure these are adhered to. The process is overseen by Artemis’ compliance department and is subject to regular monitoring. Internal governance committees review regular management information relating to the provision and receipt of gifts and hospitality.
Our standard limit for the provision or receipt of gifts and hospitality is £200 per individual per gift or event.