Kuwait Energy
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Kuwait Energy plc, Queensway House, Hilgrove Street, St Helier, Jersey JEI 1ES, Channel Islands
The assistance and local knowledge of such Third Parties can be essential. However, to minimise the
risk of fraud or corruption on their part, Third Parties should be made aware of and adhere to this
Policy, as described below.
This Policy is intended to ensure that the KE Group does not do business with any Third Party that
engages in corrupt practices, and to ensure that the KE Group takes all appropriate steps to be
satisfied that Third Parties involved in the KE Group’s business comply at all times with all
applicable anti-corruption laws and regulations across the world.
Conditions for retention or authorisation of Third Parties
No Third Party may be retained or authorised to do any act on behalf of any member of the KE
Group except in the manner and following the requirements for evaluating, selecting and retaining
such Third Parties as set out below.
Payments to Third Parties must be commercially reasonable and commensurate with the tasks they
undertake. They may be paid by cheque or electronic transfer only, and never in cash.
All payments will be made pursuant to invoices, receipts or other documentation documenting
services rendered in detail.
Third Parties may be hired or authorised to act on behalf of the KE Group only after the completion
and recording of an appropriate level of due diligence and ensuring the results are acceptable.
The level of due diligence conducted should be
proportionate with the perceived likelihood that
the Third Party will be in a position to be involved in any corrupt practices
, particularly if there
is any requirement for them to interact with Government or Public Officials. Such due diligence
could include: ownership, background checks, reviews of letters of recommendation, reviews of
credentials, reviews of financial statements, independent confirmation of the potential Third Party’s
history of government employment and evaluation of the potential Third Party’s other connections to
Government or Public Officials, including family relations.
Alternatively, if the risk is perceived as being higher, it would be appropriate to request such
additional background information financial statements or accounts and written references from the
Third Party. It may even be appropriate to engage an external due diligence provider (e.g. TRACE).
The results of all due diligence should be recorded.
Red flags
Any concerns or questions should be investigated fully and resolved before the due diligence process
is deemed to be complete. When evaluating the due diligence information for a proposed Third
Party, Employees should take into account the following corruption risk factors or “red flags”:
unusual payment patterns or financial arrangements;
any lack of visibility as to the actual services the Third Party offers;
requests for unusually high commission;
lack of transparency in the Third Party’s expenses and accounting records;
apparent lack of qualifications or resources on the part of the proposed Third Party to
perform the services offered;
the Third Party proposes to give Gifts or provide Entertainment to Government or Public
Officials or customers;
