Kuwait Energy
4
Kuwait Energy plc, Queensway House, Hilgrove Street, St Helier, Jersey JEI 1ES, Channel Islands
3.2
THIRD PARTIES
The KE Group will only engage Third Parties who uphold the KE Group’s anti-corruption and anti-
bribery practices and policies and comply with all applicable anti-corruption laws and regulations.
3.3
MANAGEMENT
Management is responsible for the full implementation of this Policy and in particular for:
fostering an open environment for Employees to discuss possible violations of this Policy;
confirming that the financial/accounting records align to these Policy requirements;
informing Employees about the requirements set out in this Policy and providing periodic
training on the anti-bribery provisions, including induction training of new Employees;
conducting periodic anti-bribery risk assessments, in particular, in relation to Third Parties
and ensuring that the risks of Bribery are included as appropriate in other risk assessments;
tracking compliance with this Policy and applicable laws and regulations; and
taking appropriate action when breaches of this Policy are identified.
3.4
COMPLIANCE OFFICERS
Compliance Officers are responsible for:
assisting Management with developing necessary procedures, implementing this Policy to
comply with applicable laws and regulations and providing guidance to Employees and
Management on the interpretation of this Policy, where necessary;
assisting Management with the communications and training needs associated with
implementing this Policy;
assisting Management and Employees with advice about exception, deviation and waiver
requests;
monitoring implementation of and compliance with this Policy;
reporting any unauthorised Gifts and Entertainment to the Chief Executive Officer; and
immediately reporting all significant breaches of this Policy.
4.
OBLIGATIONS
This section describes the KE Group’s stance on Bribery and the rules for giving and receiving Gifts
and Entertainment. Following these rules will ensure that Employees and Third Parties comply with
applicable laws and regulations and meet the KE Group’s obligations to stakeholders.
4.1
BRIBERY IS STRICTLY PROHIBITED
It is strictly prohibited to offer or accept a Bribe.
Employees and Third Parties cannot, directly or indirectly, make, promise, pay, solicit, request,
agree to receive or accept Anything of Value to or from external parties if doing so:
would violate this Policy; or
would breach applicable anti-bribery law;
influences, is intended to influence or reasonably gives the appearance of influencing any act
or decision by anyone, including inducing anyone to do or omit to do something which is
dishonest, illegal, misleading or a breach of trust or to improperly perform their function;
