Kuwait       Energy
          
        
        
          3
        
        
          Kuwait Energy plc, Queensway House, Hilgrove Street, St Helier, Jersey JEI 1ES, Channel Islands
        
        
          
            Travel and Accommodation:
          
        
        
          
            -
          
        
        
          Accommodation is lodging of any kind including hotels, bed and breakfast establishments,
        
        
          homes, etc.
        
        
          -
        
        
          Travel includes flights, train journeys, car rental, travel by boats or ships, etc.  Travel does
        
        
          not include transport of a short distance such as arranging a bus or a taxi to take external
        
        
          clients or Employees from one point to another.
        
        
          
            2.
          
        
        
          
            INTRODUCTION AND GOVERNANCE
          
        
        
          
            2.1
          
        
        
          
            INTRODUCTION
          
        
        
          The business principles of the KE Group require the highest level of personal and professional
        
        
          conduct by all Employees and Third Parties.  Engaging in behaviour or activities contrary to the KE
        
        
          Group’s business principles, as well as all other applicable laws and regulations, violates our
        
        
          promise to our stakeholders and puts the business, resources and reputation of the KE Group at risk.
        
        
          The KE Group has a zero tolerance policy towards bribery and corruption, regardless of the identity
        
        
          or position of the originator or recipient of the Bribe.  This zero tolerance is endorsed and supported
        
        
          by the highest level of management within the KE Group, with the intention of:
        
        
          
        
        
          protecting the business, resources and reputation of the KE Group;
        
        
          
        
        
          protecting all Employees, Management and other stakeholders from the consequences of
        
        
          wrongdoing;
        
        
          
        
        
          ensuring compliance with applicable anti-fraud, anti-bribery and other anti-corruption laws
        
        
          and regulations in all jurisdictions in which the KE Group conducts its business; and
        
        
          
        
        
          ensuring the integrity of our financial reporting.
        
        
          This Policy was established to raise awareness among Employees of their responsibilities to protect
        
        
          the KE Group against Bribery and corruption.
        
        
          
            2.2
          
        
        
          
            SCOPE
          
        
        
          
            This Policy serves as a minimum standard and compliance with it by all Employees is
          
        
        
          
            mandatory at all times
          
        
        
          .  In jurisdictions where (local) laws or regulations set stricter rules than
        
        
          those set out in this Policy (e.g. lower thresholds), the stricter rules must prevail.
        
        
          
            3.
          
        
        
          
            ROLES AND RESPONSIBILITIES
          
        
        
          
            3.1
          
        
        
          
            EMPLOYEES
          
        
        
          Employees must act, at all times, honestly and with integrity.  In particular, Employees are
        
        
          responsible for:
        
        
          
        
        
          complying with all elements of this Policy, and all applicable anti-fraud, anti-bribery and
        
        
          anti-corruption laws in all jurisdictions in which the KE Group operates;
        
        
          
        
        
          having a good understanding of how the rules relate to their functions and/or responsibilities;
        
        
          
        
        
          seeking guidance from a Compliance Officer when in doubt; and
        
        
          
        
        
          promptly reporting any known or suspected violation of any element of this Policy to a
        
        
          Compliance Officer.