Kuwait Energy
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Kuwait Energy plc, Queensway House, Hilgrove Street, St Helier, Jersey JEI 1ES, Channel Islands
1.
DEFINITIONS
Anything of Value
: Anything – tangible or intangible, financial or not – that provides a benefit or
advantage to the recipient, including, but not limited to, Cash or Cash Equivalents, the purchase of
property or services at inflated or discounted prices, Gifts, Entertainment, cars, jewellery, home
improvements, Travel and Accommodation, securities, etc.
Books and Records
: include all data, digital or on paper, that is used for or part of the bookkeeping
and financial accounting of a KE Group entity. Some specific examples of Books and Records
include, but are not limited to, ledgers, sub-ledgers, deposit books, cheque books, cancelled cheques,
bank statements, wire transfer instructions, bills, receipts, purchase orders, invoices, staff expense
declarations, corporate credit card data, control sheets and certain records created by customers,
suppliers and other Third Parties and that are maintained by the KE Group.
Bribe/Bribery
: A Bribe is where a person, either directly or indirectly promises, pays, solicits,
requests, agrees to receive or accepts Anything of Value to or from:
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another person with the intention to induce that person to perform a function or activity
improperly, or to reward a person for the improper performance of a function or activity;
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another person, knowing or believing that accepting or requesting Anything of Value would
be an improper performance of a function or activity;
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another person, knowing or believing that that person will conceal the request, promise, offer
or Gift from his employer whilst he is required to disclose this information; or
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a Public Official to obtain or retain business or an advantage in business.
This includes an inducement to do or refrain from doing an act in the conduct of business which is in
breach of that person’s duties to his employer or principal, is dishonest, illegal or a breach of trust.
Cash/Cash Equivalents
: Payments in currency or anything that is directly convertible to currency,
including cheques, gift cards and vouchers, gold coins, equities or other securities.
Charitable Contributions
: Payments made without demand or expectation of business return, to
registered charitable organisations, solely for the benefit of society, for charitable, education, social
welfare and similar causes.
Closely Related Individuals:
Spouses, partners, children and other immediate family members of
the relevant person.
Compliance Officer
: Any member of the Legal Department.
Employee(s):
Anyone who is permanently or temporarily employed or engaged by the KE Group or
on secondment/ a trainee at the KE Group.
Entertainment
: Any benefit, where the donor is also present, provided to an Employee or Closely
Related Individual by an external person or provided by an Employee to an external person or
Closely Related Individual in the form of:
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meals, drinks, visits to theatres, other venues, etc.; and/or
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tickets to events (e.g. invitations to concerts, exhibitions, sporting events).
