Kuwait Energy
2
Kuwait Energy plc, Queensway House, Hilgrove Street, St Helier, Jersey JEI 1ES, Channel Islands
Gifts:
Any gift (financial or not) other than Entertainment 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. Gifts do not include any item that is:
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one of a number of identical items that are widely distributed (e.g. pens, desk sets,
promotional materials, items marked with a corporate logo, etc.); or
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covered by the definition of ‘Entertainment’.
KE Group
: Kuwait Energy plc and its subsidiaries and affiliates.
Management
: Chief Executive Officer, Chief Financial Officer and Chief Operations Officer.
Policy
: This Anti-Bribery, Anti-Corruption, Gifts and Entertainment Policy of the KE Group.
Political Donation:
A contribution, financial or in-kind, to support a political cause. Financial
contributions can include both donations and loans whereas in-kind contributions tend to be
payments in goods or services and can include Entertainment, Gifts, endorsement of a political party,
contributions to research organisations or political think-tanks, or the release of Employees without
pay to undertake political campaigning or to stand for office.
Public Official:
means
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Any officer or employee of a foreign, national, local or municipal government whether
elected or appointed (this includes officials holding a legislative, administrative or judicial
position of any kind);
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Any person acting in an official capacity or exercising a public function for or on behalf of
any government or its instrumentality;
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Any officer or employee of a public international organisation such as the UN or the World
Bank;
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Political parties, their officials, and candidates for public office; or
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Employees of State-owned Enterprises or state controlled commercial enterprises.
State-owned Enterprises
: Any organ or instrumentality of the government (if the government
exercises substantial control over a company, the company must be considered an “instrumentality”,
even if some portion of the company’s shares are owned by other entities or are publicly owned).
Some examples of State-owned Enterprises include sovereign wealth funds, state-owned pension
funds, schools or hospitals.
Third Party/Third Parties
: Entities or persons who perform services for or act on behalf of the KE
Group, regardless of the capacity in which the Third Party performs services. Some examples of
entities and persons acting on the KE Group’s behalf include, but are not limited to, intermediaries,
agents, brokers, advisors, suppliers, consultants/(sub) contractors, vendors and joint venture partners.
For more information see section 4.6 of this Policy.
