Kuwait Energy
6
Kuwait Energy plc, Queensway House, Hilgrove Street, St Helier, Jersey JEI 1ES, Channel Islands
customary or seasonal Gifts of modest value.
Some key questions to ask yourself when considering Gifts and Entertainment are:
Could the Gift or Entertainment be seen as inappropriately lavish or excessive?
Is the Gift or Entertainment out of the ordinary in the context of industry or local norms?
Does the Gift or Entertainment invitation extend to family members (other than spouses or
partners) or other parties outside the normal business relationship?
Is the recipient a Government or Public Official?
If details of the Gift or Entertainment were to become publicly known would it seem
difficult to justify, or otherwise risk being harmful to the reputation of the KE Group?
If the answer to any of the above questions is ‘yes’ or ‘possibly’, this indicates an increased risk
profile for Bribery. You should consider carefully whether the Gift or Entertainment is permissible
within the terms of this Policy, and seek guidance from a Compliance Officer.
Circumstances that would
never
be permissible include (but are not limited to):
a ‘quid pro quo’ (i.e. Gifts or Entertainment offered for something in return);
Gifts in the form of cash or cash equivalent vouchers (except vouchers for a nominal
amount);
Entertainment of a sexual or similarly inappropriate nature;
Gifts and Entertainment, or other advantages, for any Closely Related Individuals of
Government or Public Officials; or
Gifts, Entertainment or other advantages to be provided at/to a private address.
Employees must consult the Compliance Officer if it is unclear whether a Gift or Entertainment
complies with this Policy. When there is any doubt, Employees must not offer or, as applicable,
decline the Gift or Entertainment. Employees wishing to obtain an exception must obtain the
approval of a Compliance Officer.
4.3
PUBLIC OFFICIALS AND STATE-OWNED ENTERPRISES
Get written approval from your Compliance Officer before offering Gifts and Entertainment
to Public Officials.
Whilst this Policy does not prohibit legitimate business interactions with Public Officials or
State-owned Enterprises, these kinds of interactions increase the perception of Bribery and are
consequently subject to stricter rules governing the offering or receipt of Gifts and Entertainment (or
other financial advantage).
To this end, it is the KE Group’s policy that Gifts should only be offered to or received from Public
Officials in accordance with this Policy.
Therefore, before offering Entertainment to Public Officials, you
must
first:
ensure that the Entertainment does not exceed any threshold or limit set by Management;
confirm to your Compliance Officer that the proposed Entertainment would not be
considered excessive under local market practice; and
obtain written authorisations from your Compliance Officer;
