Kuwait Energy
5
Kuwait Energy plc, Queensway House, Hilgrove Street, St Helier, Jersey JEI 1ES, Channel Islands
is done whilst the recipient conceals, or can be expected to conceal, the request, promise,
offer or Gift from his employer;
makes the recipient appear to be under an obligation to the KE Group or places the
Employee under an obligation; or
is intended to secure, maintain or obtain business or an advantage in business by inducing a
person to perform their function improperly.
4.2
RULES FOR GIFTS AND ENTERTAINMENT
Gifts and Entertainment includes the offer or receipt of Gifts, business meals, tokens of appreciation
and gratitude, or invitations to or sponsorship of events, functions or other social or entertainment
gatherings, in connection with matters related to the KE Group’s business.
Employees and Third Parties should only give or accept Gifts or Entertainment where it is
reasonable, proportionate and appropriate in the circumstances, and never in order to secure any
improper advantage. Entertainment is only permitted to be given where its purpose is to provide an
opportunity to develop or enhance business relationships; i.e. by creating an opportunity to engage in
discussions with a client or business partner.
Gifts and Entertainment should only be offered in compliance with this Policy. Gifts, Entertainment
and other advantages offered to, or received by, Closely Related Individuals of any Employees must
also comply with this Policy.
Accordingly, Employees and Third Parties may not, in the course of or in connection with their
employment or association with the KE Group, promise, give or offer, or request, accept, or agree to
accept, any Gift or Entertainment that:
exceeds customary courtesies common under accepted local ethical business practices or is
not otherwise reasonable and proportionate in the circumstances;
is not for a bona fide business purpose;
is intended to improperly secure any kind of personal or business advantage, or is intended
to influence a Government or Public Official in the performance of their official function, or
to represent an inducement or reward for improper performance by any person of a relevant
function or activity;
coincides or is in any way at risk of being associated with a decision to be taken by, or on
behalf of, or in connection with, the Company in respect of any procurement matter; or
would breach the known policies and procedures of a client or a recipient third party’s
organisation.
Some practical guidance
Bona fide, reasonable and proportionate Entertainment, Gifts and promotional, or other business
expenditure, which seeks to improve the image of a commercial organisation, better present services,
or establish cordial relationships, is recognised as an important part of doing business and it is not
the intention of this Policy to prohibit such behaviour. Common sense should be used at all times
when approaching issues of Gifts or Entertainment. Some examples of Gifts and Entertainment that
would
usually
be acceptable are:
modest, occasional meals with someone with whom the KE Group does business;
occasional attendance at sports, theatre and other cultural events by either the inviting party
or the invitee;
Gifts of nominal value; and
