Kuwait Energy
10
Kuwait Energy plc, Queensway House, Hilgrove Street, St Helier, Jersey JEI 1ES, Channel Islands
will not subcontract or assign its obligations or responsibilities under the contract or
agreement without prior written approval from the KE Group, and will ensure that any
permitted subcontractors observe the above anti-corruption provisions.
4.7
SANCTIONS FOR NON COMPLIANCE
Management must ensure that violations of this Policy are addressed.
In some countries, violations of any element of this Policy could result in civil and criminal penalties
against the KE Group and could also subject Employees to prosecution, criminal fines and
imprisonment. In addition to any criminal and civil sanctions, Employees’ failure to comply with
any element of this Policy may be grounds for disciplinary action, including termination of
employment.
4.8
EXCEPTIONS, DEVIATIONS AND WAIVERS
Only the Chief Executive Officer can grant exceptions from this Policy in respect of Public Officials,
including State-owned Enterprises, Third Parties, Political Donations and Charitable Contributions.
Any such exceptions must be made in writing.
For all other provisions, a Compliance Officer may authorise an exception from this Policy under
specific circumstances.
5.
MONITORING AND REPORTING
The KE Group is committed to sound business conduct and therefore manages its business in an
ethical and transparent way. Its aim is to instil a culture where integrity is stimulated and enhanced,
and fraud and corruption is deterred by the promotion of strong internal business and financial
controls.
Incidents of fraud or suspected fraud should be reported in accordance with the KE Group’s
whistleblowing procedure which may be found on the KE Group intranet.
Periodically, Management and Compliance Officers will be requested to report on the status of
implementation, tracking and monitoring activities and to immediately report issues in relation to
this Policy.
