5  
pre- approved by CMES  
 
Gifts 
For purposes of this Guideline, there are two categories of gifts: 
 
A. Customary and Nominal Gifts; and 
 
B. Other Gifts & Travel. Note: meals and/or entertainment (given or received) at which a representative from the sponsoring party (i.e., the 
party paying for the meal and/or entertainment) is not present are considered gifts. Descriptions of, and the logging and pre-approval requirements for, the two categories of gifts are set out below. A. Customary and Nominal Gifts 
Description. Customary and Nominal Gifts are gifts that: 
 
1. Are given or received for customary and legitimate promotion purposes in connection with: (a) firm 
event (e.g., Investor Day); (b) a business relationship meeting (e.g., site tour, introduction meeting, firm 
entertainment event); or 
(c) the commemoration of a transaction (e.g., closing of an investment, joint venture or similar 
transaction); and 
 
2. Are of nominal value. The determination of nominal value is inherently subjective and is based on the 
relevant facts- and-circumstances, including the purpose of the gift, the jurisdiction it is to be given in, 
and other relevant factors. Please consult with the CHRO to whether a proposed gift is Customary & Nominal. Once a gift (or category of gifts) 
has been determined to be Customary & Nominal, it can be given on a go-forward basis in all similar situations. For 
example, once a promotional item to be given at Investor Day has been determined to be Customary & Nominal, it 
can be distributed to all attendees at Investor Day without further inquiry. Likewise, it can also be distributed to 
attendees at future Investor Day events without further inquiry. Examples. The following are examples of Customary and Nominal Gifts: 
• welcome chocolates, mugs or other promotional items given at Investor Day; 
• pens, hats or other promotional items given at a due diligence asset tour; 
• maple syrup, dates or other courtesy gifts given at a business relationship meeting; 
• lucite tombstone, plaque or other decorative item commemorating the closing of an investment or 
similar transaction; and 
• notepads, desk ornaments, umbrellas, tote bags, or shirts given in connection with a firm event. Logging and Pre-Approval Requirements.