Abstract

3one4 Capital is a politically neutral organisation and does not engage in party political campaigning. 3one4 Capital is a balanced organisation in relation to its political contribution and charitable donations.

Definitions

“Charitable Donations” means any item of value, whether in cash or in kind, given to a cause and/or for charitable purposes to a recognized, reputable and registered charity or public international organization.

“Fund” or “Scheme” shall mean an alternative investment fund or scheme that are managed by the Manager.

“Government Official” any person working in a legislative, administrative or judicial position or working for or on behalf of government-owned or controlled entities or agencies, political parties, party officials and political candidates or for a public international organisation whose members are either (1) countries or territories; (2) governments of countries or territories; or (3) other public international organisations. For the purposes of this Policy, this term will also cover immediate family members (parents, spouses, children, in-laws and siblings), consultants who hold government positions, employees of companies owned or controlled by governments, political party officials, or employees retained by government agencies, and anyone else to whom the Government Official provides material support.

“Manager” shall mean 3one4 Capital Advisors LLP or 3one4 Capital Management LLP, as may be applicable in relation to a Fund or Scheme.

“Political Contributions” means any cash which is given to any political party (registered with the Election Commission of India or equivalent outside India), organisation, campaign, or political action committees; party official or a political candidate (including sponsorship or subscription made in relation to any political party or political organization) and contributions made to affiliates of political parties and groups/ movements endorsing political parties or any other campaign/movement intended to directly or indirectly influence the outcome of election results.

Making Political Contributions or Charitable Donations

Any Political Contributions or Charitable Donations shall be made by the Fund only upon prior approval of the Manager. Such decisions of the Manager shall be taken in accordance with the investment management agreement executed by the partners of the Manager. The minutes of such meeting shall be recorded in writing.

Political Contributions or Charitable Donations are permissible where:

·       they serve a legitimate purpose;

·       they are not intended (nor would appear to be intended) to influence the decisions of any Government Official;

·       they are reasonable and proportionate;

·       they are made transparently;

·       they are not made for the personal, financial, or political benefit of any Government Official, or any customer/supplier/third party (or their families); and

·       they are permissible under applicable laws.

Political Contributions or Charitable Donations must not be used as a subterfuge for bribery and corruption, improper influence, money laundering or terrorist financing. To clarify, any Political Contributions or Charitable Donations shall not be in violation of any other policies of 3one4 Capital.

Political Contributions

All Political Contributions may only be paid by way of electronic transfer of funds/account payee cheque to a bank account in the name of the recipient political organization (or in the case of an independent election candidate to an account in that person’s name), held at a reputable bank.

Charitable Donations to organisations in which a Government Official has a role may be considered to provide a benefit to that Government Official. A Charitable Donation to such an organisation is not permitted and shall be deemed to be a Political Contribution.

Any payment towards Political Contributions shall only be from the cash or profits of the Manager and the Fund monies shall not be utilised in this regard.

Charitable donations to organizations in which government officials (who are in a position of authority to influence company operations) have a role may be considered to provide a benefit to those Officials. A Charitable Donation to such an organization is not allowed.

Charitable Donations

Manager may consider Charitable Donations to recognised charitable causes as approved by the Manager in terms of this Policy. The Manager shall ensure that all Charitable Donations are made in an impartial manner.

Such Charitable Donations may be in cash or kind as deemed fit by the Manager.

The non-participation by the employers of the Fund or Manager in such charitable causes shall not result in any penalisation of such non-participating employee.

Exceptions

Employees, acting solely in their personal capacity, may make Political Contributions or Charitable Donations and may participate in political or charitable activities at their own expense, but may not seek reimbursement from the Fund or the Manager for such Contributions or Donations that are not approved as set forth above.

To clarify, where personal contributions and donations are not being made on behalf of the Fund or the Manager, the employee shall not use the Fund’s or Manager’s name, funds, facilities, work time, or other resources to support such activities. Additionally, employees shall not use their position as an employee of 3one4 Capital to request or pressure others to make any contributions or donations.

Disclosures

The Manager shall disclose and report all Political Contributions and / or Charitable Donations in accordance with applicable law, the Fund’s documents, and any other relevant documents that are applicable to the Manager.

Reporting Concerns

Any concerns or questions in relation to this Policy can be directed to partners@3one4capital.com.

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