KMD POLICY 4.2 The head of the Corporate Compliance Team shall be responsible for the following: (I) The development and improvement of detailed policies/rules and procedures (or the review and improvement of existing policies/rules and procedures, as appropriate) (the “Detailed Procedures”) concerning, among others, (a) gifts, entertainment, hospitality, promotional expenditure, (b) charitable and political donations or contributions, and (c) due diligence procedures and anti-corruption measures for Associated Persons; and (II) education and training of directors, officers and employees of the Company at regular intervals to promote awareness and understanding of this Policy and the Detailed Procedures. 4.3 The head of each Business Unit shall be responsible for the following: (I) promoting awareness of this Policy and the Detailed Procedures within the Business Unit and ensuring compliance with this Policy and the Detailed Procedures; (II) in relation to the business operations being conducted by the division, to carry out risk assessment on corruption and bribery on a regular basis; (III) with respect to each proposed business transaction, to carry out due diligence through appropriate and proportionate means, which may include, for example, considering the types of risks such a transaction is exposed to, checking public sources of information (including published papers/reports) on the country or region in which the transaction is to be carried out and on the potential business partners and asking the potential business partner questions in relation to its history and anti-bribery practices. It is necessary to carry out such due diligence before entering into a business transaction and on an ongoing basis during the term of the transaction so that changes and new information can be properly assessed. (IV) to record and keep on file the results of the risk assessment and due diligence so conducted, and to seek advice and/or instructions from the Corporate Compliance Team regarding risk assessment/due diligence and take necessary measures to prevent corruption and bribery. 5. Permissible Conduct 5.1 Conduct (for example, gifts, entertainment, hospitality, promotional expenditure and do- nations) that is not prohibited under this Policy may be carried out in accordance with the Detailed Procedures. 5.2 Facilitation payments (usually small and unofficial payments made for the purposes of securing or expediting an action by a Public Official which the payer is, either legally or in other ways, entitled to) are strictly prohibited except where such payment is required in order to protect against the loss of life, limb or liberty. 5.3 Whenever a Company director, officer or employee makes, offers, or promises any permissible conduct described in section 5.1 or 5.2, he or she shall do so by following the Detailed Procedures. 5.4 The Company’s directors, officers and employees shall follow the Company’s procedures so that any expenditure incurred pursuant to this section 5 shall be fully and accurately reflected in the Company’s books and records in accordance with those procedures. 4
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