ANTI-CORRUPTION POLICY 2.4 The term “Public Official” means any of the following persons (regardless of rank or position): (I) Officers and employees of any government (including but not limited to national, federal, state, or local government), international organization (such as the United Nations and the World Bank) or instrumentality thereof; (II) Any persons holding a legislative, administrative or judicial position, whether elected or appointed (including any candidates therefor); (III) Officers and employees of any state-owned enterprise which means a corporation or other entity: (a) a majority of whose shares or equity interests are owned or controlled, directly or indirectly, by the public bodies described in (i) above; (b) a majority of the members of whose board of directors or similar management body is nominated by the public bodies described in (i); or (c) in addition to (a) and (b) above, substantially controlled by the public bodies described in (i) above; or (IV) Agents or other representatives of such organizations, persons or entities described in (i) to (iii) above. 3. Prohibition against corruption and bribery The Company’s directors, officers and employees must not, directly or indirectly, engage in corruption and bribery, and shall take steps necessary to prevent Associated Persons from engaging in such activities. As used in this Policy, the term “Associated Persons” means a person or corporate entity which performs services for or on behalf of the Company or performs business activities jointly with the Company. Associated Persons may include but are not limited to subsidiaries, affiliates, agents, consultants, distributors, and partners in consortium or joint-venture. 4. Steps to be taken for anti-corruption compliance within the Company 4.1 The Executive Committee of the Company shall be responsible for approval and supervision of the anti-corruption policy and demonstrate actively that it supports the anti-corruption policy. The Corporate Compliance Team in KMD shall be responsible for administering this Anti-corruption Policy, monitoring its implementation and keeping top-level management (the Board of Directors and the Executive Committee) informed. The Corporate Compliance Team shall provide instructions to the head of the Business Units identified in section 4.3 below to ensure the practical implementation of this Policy and shall review the operation of and the level of compliance with this Policy and the Detailed Procedures (see below) on a regular basis and keep written records recording these reviews. 3
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