Kuwait Energy
7
Kuwait Energy plc, Queensway House, Hilgrove Street, St Helier, Jersey JEI 1ES, Channel Islands
Gifts and Entertainment or other advantages for Closely Related Individuals of Public Officials can
never
be offered without prior written approval from the head of the Legal Department.
4.4
CHARITABLE CONTRIBUTIONS AND POLITICAL DONATIONS
Get written approval from Management before making Charitable Contributions on the KE
Group’s behalf.
Employees may make appropriate Charitable Contributions on the KE Group’s behalf in the form of
goods or services, technical assistance, training or financial support. However, care must be taken to
ensure that the recipient is a bona fide charity and that there is no reason to believe that the charity
itself may be operated directly or indirectly for the private benefit of a Public Official or a Closely
Related Individual of a Public Official. Therefore, Employees must first obtain written approval
from Management before making any Charitable Contributions on the KE Group’s behalf.
The KE Group’s businesses are not permitted to make Gifts or Political Donations or to offer
Entertainment to political parties or candidates for political office.
Please refer to Recording Gifts and Entertainment below in relation to recording Charitable
Contributions.
4.5
REPORT VIOLATIONS
Report any actual or suspected violations of this Policy through normal reporting channels.
If an Employee or Third Party becomes aware of any violation or potential violation of this Policy,
the Employee or Third Party must immediately report it to a Compliance Officer. If the Employee
or Third Party does not feel comfortable with reporting it to Management the report can be filed
anonymously under the KE Group’s whistleblowing procedure which may be found on the KE
Group intranet.
4.6
RULES FOR ENGAGING THIRD PARTIES
The Compliance Officer must ensure an appropriate level of due diligence is carried out prior
to the appointment of any Third Parties.
What is a Third Party?
A “Third Party” is any individual or entity that provides services, or engages in business activities,
on behalf of the KE Group. Third Parties include anyone who is working on behalf of the KE Group
in any way in the conduct of its business. Third Parties include, but are not limited to:
joint venture partners;
joint venture companies;
suppliers of services;
contractors or subcontractors;
external consultants;
advisors (including tax and financial advisors, accountants and lawyers); and
any other service providers who act on behalf of the KE Group in any way in connection
with its business.
