Code of

business conduct

Kentz Corporation Limited

Code of Business Conduct

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Letter from the

Chief Executive Officer
Dear Colleagues
Kentz continues to see significant growth across its Global Business Units and has
recently completed a successful step-up to the Main Board of the London Stock
Exchange. Against this backdrop it is vital that we continue to maintain and build on our
already well established high standards of business conduct and ethics. The Company
has therefore decided to formalise all of the important behaviours expected of Kentz
employees into a single Code of Business Conduct (the Code).
All Kentz directors, employees, and the people we work with, are required to
fully comply with the Code and to use it in ensuring that they maintain the highest
standards of ethics in their working lives, wherever they are located and whatever
their responsibilities.
The Code cannot cover every situation, but it provides general guidance to which
common sense can be applied. When in doubt, always seek appropriate advice and
err on the side of caution.
Every person at Kentz has a responsibility to know and follow the Code in all their
business dealings; to ensure the reputation and respect that Kentz has amongst its
stakeholders is maintained and strengthened.
Kentz relies on its people to ensure compliance with the Code and you must report
any potential or actual breaches of it to management in the manner set out in Section
9 of the Code. Our employees are our most important asset and we have set out in the
Code our responsibilities to you and the protections available to you in the workplace.
David Beldotti, Chairman of our Audit Committee and an experienced member of
the Kentz Board of Directors, has been appointed as Senior Independent Director
of the Board to ensure amongst other things that shareholder enquiries in relation
to the Code are properly addressed. Tony Lenard, Group Internal Audit Manager for
Kentz, has been appointed to act as the Group Compliance Officer and to facilitate the
smooth running of the Code. Please contact him directly should you have any queries
in regard to the Code.
The Code has been approved, and is fully supported, by the Kentz Board of Directors
and will be reviewed on an annual basis and updated as appropriate. You are
encouraged to familiarise yourself with the Code as a matter of priority, as you will be
required to comply with it always from this time forward.

Christian Brown
Chief Executive Officer

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Kentz Corporation Limited

Code of Business Conduct

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Contents

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Kentz Corporation Limited

Code of Business Conduct

01

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General principles of the

Code of Business Conduct
It is Kentzs policy to carry out all
of its activities in an ethical manner.
The Code of Business Conduct applies to
the Kentz Board, senior management and all
employees, and aims to ensure that at every
level of our organisation, at all times, employees
conduct themselves in an ethical way. This
includes their dealings internally and externally
with third parties to ensure the highest standards
of honesty, integrity and fairness and to foster an
environment based on such standards, as well
as complying with all related legislation in the
countries in which they operate.

representing or acting for, or on behalf of, Kentz,

its subsidiaries or joint ventures.
No Kentz employee may take part in or condone
any fraud, dishonest practice, bribery or other
corruption or any other breach of the items
covered by the Code.
The Code emphasises that every Kentz
employee must be aligned to the achievement
of Group goals.
Kentz is committed to ensuring everyone that is
covered by the Code exercises good judgment
and common sense in the execution of Kentzs
business and is individually responsible for
ensuring that Kentzs day-to-day business
activities are conducted in a fair, honest, legal
and ethical manner.
Decisions and transactions by Kentz employees
must in all respects be fair and equitable. Actions
should be avoided that create any perception that
Kentz employees could exert improper influence
on behalf of vendors or clients.

As a specialist service solutions provider operating

on a global basis, Kentz is exposed to the
risks of unethical behaviour both internally and
externally. Some Kentz operations are in countries
where these risks, relative to other countries,
are generally greater. However, we know the
difference between the right and wrong ways of
doing business, and choose to do what is right,
treating all our contacts with honesty, transparency
and without bias.
Kentz is committed to ensuring the highest legal
standards and ethical guidance in all its business
activities. This applies to the behaviour of all
Kentz directors, staff, sub contractors, agents,
consultants, contract labour, vendor and others

Kentz employees and their immediate family

members must avoid any interest, relationship
or outside activity that could affect, or be seen to
affect, their ability to discharge objectively their
responsibilities. Full disclosure by an employee
should be given, and written approval sought,
before entering into any situations where a
potential conflict of interest could occur. Where
such an interest, relationship or outside activity
already exists, full disclosure should also be given
by the person concerned.
Kentz employees must not misrepresent
themselves including their level of authority or any
information concerning Kentz to anyone outside
of the Group. They must not misuse or disclose
confidential information for personal gain or to
prejudice fair competition.

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Kentz Corporation Limited

Code of Business Conduct

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To avoid any perception of an improper attempt to

influence business decisions, and to avoid feeling
obligated to donors, gifts must never be solicited
by a Kentz employee or their immediate family
member. Any payments of cash or cash equivalent
is not acceptable, neither are any gifts that exceed
nominal value or are prohibited by law.
Kentz is also committed to ensuring it always acts
safely and ethically, without
compromising its commitment
to protecting people and the
environment in all its business
activities. It will not accept
any discrimination or
harassment of its people.

Kentz is
committed to
ensuring the
highest legal
standards and
ethical guidance
in all its business
activities.

Kentz directors and managers

have additional responsibility for
creating the proper environment
and encouraging safe and
ethical business practices. They
must lead by example and
give those that report to them the support and
resources they need to understand and follow the
Codes requirements.
The Group aims to continuously improve its
practices to achieve the goals set out in the Code
and seeks assistance from all of its employees,
vendors, agents, contractors and consultants to
achieve this. Its determination to act according
to the Code is critical to preserve Kentzs highly
valued reputation.
The Code requires all members of the Kentz
team to always act on the side of caution in
maintaining Kentzs level of safety, integrity, social
responsibility and ethics and to use their best
judgment and discuss the situation with their line
manager or a member of the senior management
team before making a decision if they are not sure
of the right thing to do.

Kentz expects all its vendors, agents, contractors

and consultants to conduct all business with the
Group in accordance with all parts of the Code,
including those related to health and safety and
bribery and corruption.
Failure to comply with the Code will constitute
grounds for disciplinary action for employees
including, where appropriate, termination of
employment. In relation to third parties; failure to
comply may result in termination of their business
relationship with Kentz.
The Code is communicated to all new employees
on joining the Group and to existing employees
through workshops, posters and briefings by
line management.
At least annually, management report on the
implementation and operation of the Code
to the Board to ensure that it is adequately
communicated to all stakeholders and reviewed
and updated as necessary.

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Kentz Corporation Limited

Code of Business Conduct

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Ethical business dealings

All Kentz group companies and joint ventures,

regardless of location, and all Kentz employees,
contractors, agents, consultants, vendors and others
representing or acting for, or on behalf of, Kentz are
required to comply with the following policies in their
business dealings.

Bribery and Corruption

No Kentz employee may take part in or
condone any bribery or other corruption.
The use of improper payments to gain
advantage is never acceptable.
All Kentz employees and the other parties noted
above must act with integrity at all times, comply
with the bribery and corruption laws of the country
in which they are operating and not induce or
facilitate someone else to break such laws. They
must not make or receive improper payments
either directly or indirectly through third parties.
In many jurisdictions, bribery and/or corruption
is a criminal offence, as are attempts, incitement
or conspiracy to commit such an offence and
may result on conviction in severe penalties
including imprisonment. In addition, Kentz or
its officers and directors may also be liable to
severe penalties for bribery or corruption by its
employees, agents or other representatives.
Kentz therefore has a responsibility to exercise
due care in monitoring those acting on its behalf
to prevent bribery and corruption.
A bribe is any gift, loan, payment or other benefit
offered, given or received with the intention
of gaining a business advantage or inducing
improper conduct by the person receiving it.
Specifically, this includes clients or government
officials who have the potential to make decisions
favourable to Kentz or one of its Group companies.
It may include excessive or inappropriate
hospitality. The giving or receiving of such gifts,
IMS COR 1 0070, Anti-fraud policy

loans, payments or benefits, both in relation to

government officials and private individuals, is
specifically prohibited, unless they are only of a
small token nature.
The Code cannot outline rules for every situation
but requires all employees to err on the side of
caution. If an employee is in any doubt about
a given situation, they should consult their line
manager who may in turn refer it to the Group
Compliance Officer. The Group wants to prevent
even the appearance of bribery or corruption in
relation to Kentz, as acts or allegations of bribery
can damage the Groups reputation.
In this regard, the Group makes no distinction
between bribes and facilitation or enabling
payments.
The only exception to this would be in the
unusual circumstances where there is a real
physical threat to an employee or their family.
If such a payment has to be made, it should be
reported to the Group Compliance Officer at the
earliest possible opportunity.
Where a third party agent is to be used to
represent Kentzs business interests, it must first
be confirmed that their use is necessary and that
the related role cannot be completed internally.
Improper conduct by agents and representatives
could also damage Kentzs reputation.
Particular care should be exercised in dealing
with agents in countries known for high levels of
corruption, where the agent is introduced by a

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Kentz Corporation Limited

Code of Business Conduct

customer or government official or is suspected

of having connections with a customer or
government official, where the agents commission
exceeds the expected market rate for the service
provided or where the agent requests unusual
payment arrangements, such as payment in
cash or in a third country. This could also include
payments to charities or other third party bodies.
It is Group policy that all new or renewed agency,
contractor, consultancy and vendor agreements
include provisions to ensure the agent, contractor,
consultant or vendor has read and agreed to
comply with the section of Code in relation to
ethical business dealings, subject to the penalty of
immediate removal from the approved vendor list
and termination of their related agreement.
If any customer or prospective customer, their
agent or representative seeks any form of
bribe, the Code requires this information to be
immediately reported to the line manager of the
employee concerned and the line manager to
report it to the Group Compliance Officer.
Anti-Competitive Behaviour
Competition laws prohibit anti-competitive
behaviour and the related penalties can be
severe. Kentz requires all of its employees to
ensure that their interaction with our competitors
is completed with integrity and that they are never
in, or deemed to be in, a situation where Kentz
can fix prices or enter into other anti-competitive
practices with its competitors. It is important for
employees to be aware of the related laws and
to ensure that suppliers and customers are not
engaging in anti-competitive activities that could
damage our business.
Vendors, agents, contractors, consultants and
industry partners are crucial to Kentzs success.
It is vital that the Group deals with them fairly
and treats them with integrity and respect.
Kentz chooses all such partners only on the
basis of appropriate business criteria including
performance, price, qualifications, product
quality and deliverability.

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Kentz complies with competition and anti-trust

laws in the countries in which it operates and will
not be involved in any price fixing, bid rigging
or other form of anti-competitive behaviour, or
misrepresent to third-parties its competitors
abilities, products or services.
Conflicts of Interest
Employees should avoid situations where they
have or appear to have a conflict of interest.
Conflicts of interest arise where employees,
consultants or agents have personal, family or
other interests which affect or appear to affect their
ability to be fair and impartial in carrying out their
duties. Actual or apparent conflicts of interest can
undermine stakeholders trust in the Company,
even where mitigating factors are present.
Employment, consultancy or directorship
agreements outside the Group that may
interfere with an employees duties at Kentz,
especially those with an actual or potential
business partner or competitor of the Group,
require disclosure and written authorisation by
the employees line manager.
Employees should preferably not be actively
involved in any transaction between the Group
and any other business entity in which they or their
immediate family have a material shareholding
or management role. Where this is not possible
to avoid, prior written approval is required by the
employees line manager or more senior manager
if deemed appropriate. An employee is also
required to make a full disclosure of any transaction
between the Group and any other business entity
in which they or their immediate family have a
material shareholding or management role, even if
they were not involved in the transaction. The hiring
or recommendation to hire a relative would also
require disclosure. Similar requirements exist when
dealing with personal friends.
Consistent with the rationale behind giving
and acceptance of gifts, any lavish hospitality
may create a conflict of interest or appear to
compromise the integrity of an employee or
vendors decision to award work. While such
courtesies may promote successful working

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Kentz Corporation Limited

Code of Business Conduct

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Kentz prohibits the use of any of its businesses

for such purposes and places a duty on all of its
employees to report any suspected or identified
cases of money-laundering located or suspicious
transactions to their line manager and the Group
Compliance Officer.
Fraud
Kentz is absolutely committed to maintaining
an honest, open and well intentioned atmosphere
within the Group. Thereby it is also committed to
the elimination of any fraud within the organisation
and to the rigorous investigation of any such
cases raised.
relationships and goodwill, the frequency and
scale of hospitality must not reach a level whereby
either party might reasonably be seen as being
influenced by it in a business transaction.
In the case of any doubt regarding potential
conflicts of interest, the employee concerned
should discuss the issue with their line manager or
the Group Compliance Officer.
Inside Information and Insider Dealing
Kentz employees are prohibited from trading
in shares in the Group or any other quoted
company based on the use of price sensitive and
unpublished inside information which, if publicly
known, could affect the market price of Kentz or
another companys shares.
In addition, they must not disclose such
information to any third party that may use it to
deal in such shares.
As Kentz shares are publically traded, there are
close periods each year when employees are not
allowed to trade in the Groups shares.
In case of any doubt relating to close periods,
or trading in Kentz shares, employees should
refer their questions to the Group Head of
Communications.
Money Laundering
Money laundering refers to situations where
companies or individuals try to conceal illicit
funds, including the proceeds of crime and tax
evasion, in a business to try and give the funds the
appearance of being legitimate.

Actions constituting fraud include, but are not

limited to, misappropriation of funds, supplies
or any other assets, impropriety in the handling
or reporting of money or financial transactions,
deliberate misrepresentation or misreporting of
any financial information, performance or results,
incorrect characterisation of expenditure and
forgery or alteration of business documents.
The Chief Financial Officer will be primarily
responsible for the investigation of all suspected
fraudulent acts as defined in this policy. The
Chief Financial Officer may delegate the
detailed investigation to an individual or team of
investigators. These investigators could be either
internal or external.
If the investigation substantiates that fraudulent
activities have occurred the findings will be
reported to the appropriate designated personnel
and if appropriate to the Main Board through the
Audit Committee.
Decisions to prosecute or refer the examination
results to the appropriate law enforcement
agency for independent investigation will be
made in conjunction with legal counsel and senior
management.
Investigation results will not be disclosed or
discussed with anyone other than those who
have a legitimate need to know. This is important
in order to avoid damaging the reputations of
persons suspected but found innocent of any
wrongful conduct and to protect the Group from
any civil liability.
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Kentz Corporation Limited

Code of Business Conduct

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Health and safety

It is Kentzs policy to provide and maintain a safe

and healthy work environment at all times, with
the goal of preventing occupational accidents,
injuries and illnesses.
Management place the health and safety of every
employee above any other consideration of job
operation or administration, with the goal at every
level of the Group to ensure at all times, and in
every phase of a job operation, the health and
safety of Kentz employees and third parties at the
locations in which Kentz operates.

Employees at all levels of the organisation

work conscientiously and diligently to obtain
the highest standards of occupational health
and prevent the suffering and losses which
result from unsafe practices.
Kentz promotes and enforces the development,
dissemination, implementation, effectiveness
and continual improvement of its health and
safety programme, which is available to other
interested parties.
Kentz pursues rigorous and frequent audits to
ensure that each partner in its health and safety
programme provides exemplary leadership in the
prevention of accidents, injuries and illness to
ensure that nobody gets hurt and everyone goes
home safe and well.

Kentz recognises that responsibility for health and

safety requires constant and continuing efforts
from a partnership of management, employees,
subcontractors and clients.
Kentz accepts its responsibility to lead the
promotion and practice of its health and
safety programme.
Kentz will comply with all legal and regulatory
health and safety requirements and generally
accepted work practices in every country in
which it operates. In addition, it enforces its own
procedures for protection and promotion of the
health and safety of its employees and others
affected by the Groups activities. It will also strictly
adhere to all site health and safety standards and
job work rules and practices at the locations where
it undertakes work.
IMS COR 1 0002 3, Health and safety policy
IMS COR HSE 3 0001, Health and safety and environmental manual

Management place the

health and safety of
every employee above
any other consideration
of job operation or
administration, with the
goal to ensure the health
and safety of Kentz
employees

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Kentz Corporation Limited

Code of Business Conduct

Alcohol and Drugs

Employees should be fit to carry out their
duties while on Kentz business. Employees are
specifically prohibited from risking the health
or safety of themselves or other employees by
working while under the influence of alcohol or
drugs or having such items in their system. Except
in the rare cases where approved by senior
management, alcohol consumption by employees
is not allowed on Kentz premises or any other
sites on which Group staff are working. Breach
of these rules can result in severe penalties,
including dismissal.

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Quality
Kentz recognises the requirements for quality
assurance in the areas in which it operates and
has committed to the establishment of an effective
quality management system. It aims to ensure all
contractual and specification requirements are met
for the projects for which Kentz is responsible and
to achieve a reliable and cost effective system of
management in all its activities.
The quality management system addresses all
quality systems requirements identified on the
International Organisation for Standardisation
ISO 9001. Kentz has defined its quality
objectives in its quality manual and these are
reviewed periodically to continually improve the
effectiveness of the system.
The Group Quality Assurance Manager
is responsible for the introduction and
implementation of the quality management system
throughout the Group.
Kentz management requires the quality assurance
department to conduct introductory courses for
all employees to ensure the quality management
system is effectively communicated and
understood within the Group.

IMS COR 1 0002 -1, Quality policy statement

IMS COR 1 0002 5, Drug and alcohol policy statement

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Kentz Corporation Limited

Code of Business Conduct

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Corporate social responsibility

Kentz is committed to being a good corporate citizen

in all countries in which it operates, applying the
principles of sustainable development, working to
minimise its environmental footprint and contributing
to the economic and social development in the
communities where it is active.
It conducts its business in
accordance with applicable
local laws and regulations.
Every Kentz employee, supplier,
agent, contractor and consultant
engaged in any of the Groups
operations must comply with
the laws and regulations of the
country where they are involved.
Legal compliance is a minimum
and not Kentzs entire ethical
and social responsibility. The
Group will operate and expects
its employees, suppliers, agents,
contractors and consultants
to operate in line with industry
standards and to exceed them as economic and
operational constraints permit.
Environmental
Kentz recognises the responsibilities placed
on it by relevant environmental legislation and
regulations on the nature, scale and environmental
impacts of its activities, products and services.
Kentz is committed to the efficient use of
resources; minimising environmental impacts
throughout its operations; developing and
implementing sustainable solutions that contribute
to meeting worldwide energy needs; contributing
constructively to global sustainable development;
preventing pollution; and identifying, assessing
and managing risks to the environment.
Kentz takes statutory obligations and regulations
as minimum requirements only. It will provide
sufficient resources of time, personnel,
finance, training, information and supervision
in pursuance of these objectives and do
IMS COR 1 0002 2, Environmental policy statement
IMS COR 1 002 6, Community policy statement

everything reasonably practicable to ensure its

subcontractors do the same.
It is the duty of all personnel, including suppliers
and subcontractors, to take all reasonable
precautions to improve Kentzs environmental
performance by preventing pollution, reducing
waste, minimising hazardous waste and recycling
as much as possible.
Kentz strives to maintain leading industry
practices and develop, implement and maintain
environmental management systems that meet the
requirements of the ISO 14001.
Community
Kentz recognises the importance of giving back to
the communities in which it operates and to building
strong and sustainable relationships with them.
It is Kentzs policy to bring tangible benefits to
these communities, after listening to community
needs and expectations and allowing for each
communitys uniqueness.
Kentz aims to set measurable targets in this area
and to continually improve its relationship with the
communities it deals with by becoming an active
member of the community through involvement
in charitable, social, recreational, well being and
cultural initiatives.
Outside working hours, Kentz employees
are encouraged to participate in charitable,
educational, community and civic activities and
projects that enhance the quality of community
life, as long as these activities do not interfere
with their ability to do their job or present any
other kind of conflict.

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Kentz Corporation Limited

Code of Business Conduct

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Human resources

Kentz is only able to provide the consistently high

quality services required by its customers because
of the strength and quality of its employees and its
dedicated and motivated management team. The
Group invests time and effort in the development
of its people by supporting them through constant
appraisal, coaching and training, and by encouraging
personal initiative.
It is Kentzs policy to provide its employees
with modern and adequate working facilities,
professional training opportunities, access to
address their social service needs and the means
to resolve any human resources problems that
may arise.
Kentz aims to motivate all employees to
achieve quality internally and externally, reward
achievements and good performance, promote
a culture of trust and a spirit of teamwork and
harmony and to exercise integrity in dealing with
its employees.
Diversity and Human Rights
Kentz operates in many countries with a wide
variety of cultures and has a work force drawn
from across the globe. It prides itself on its ability to
respect different cultures and beliefs and to benefit
from the value this diversity provides the Group.
The Group requires all its employees to interact
with their co-workers with civility and courtesy,
accepting differences without necessarily
agreeing with them.
Kentz welcomes the input of all of its employees
and promotes active communication between
employees and their line managers, with advice
given freely and issues raised and resolved in a
spirit of openness.
All employees and job-applicants deserve and
are given fair and non-discriminatory treatment for
both employment and in developing their careers
with Kentz, irrespective of ethnic or national origin,
IMS COR 1 0002 4, Human resources policy statement

gender, religion, age, sexual orientation, disability

or any other factor other than their ability, aptitude,
qualifications, skills and performance. Kentz offers
equal opportunities for all.
Kentz will not permit harassment of its employees
in any form, including that of a sexual nature,
and requires that its employees do not behave
either openly or covertly in a way that another
person may find unwelcome, offensive, upsetting,
humiliating, embarrassing or demeaning. If any
employee considers that they have been the victim
of any form of harassment, they should report it to
their line manager for follow up as appropriate. All
such issues raised are required to be handled in a
sensitive and sympathetic manner.
Kentz will not use forced, compulsory or
underage labour. Kentz recognises the right
of all its employees to join trade unions where
such rights are recognised by law.
Industrial Relations
Kentz recognises that, from time to time,
issues arise within the Group that occasionally
result in industrial disputes. Through effective
communication and consultation with employee
representatives or, as appropriate, trade unions,
Kentz aims to bring about the satisfactory and
speedy resolution of such issues. Effective
consultation will ensure that the views, opinions,
suggestions and recommendations of all parties
are considered openly and constructively.

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Kentz Corporation Limited

Code of Business Conduct

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Information

Kentz personnel are required to protect confidential

information, both relating to the Group and to other
companies for which confidentiality undertakings
have been given.
Confidential information includes, but is not
limited to, technical information on products,
patents and copyrights, data services and
processes, designs and drawings, software
codes and programmes, supplier and customer
lists, employee information, business plans,
legal documentation and unpublished financial
information, both forecast and actual.

All confidential Kentz information is required to be

clearly marked as such. Employees with access
to employees personal data must only use it for
the purpose for which it was obtained and keep its
contents confidential.
Provision of Kentz Information to Third Parties
While Kentz seeks to maintain a positive and
open relationship with the media, its investors
and analysts, only those employees specifically
authorised to do so can reply to enquiries from
these sources.
Employees are not permitted to enter into
any informal off the record discussions
with any third party.
If any employee receives a request for
corporate information or comment from
any third party they should refer it to the
Group Head of Communications.

The release of such information to third parties

could damage the Groups business and
reputation and in some cases violate the law.
Kentz employees are not permitted to disclose
confidential information to customers, vendors
and other third parties unless it is in their normal
course of duties and where appropriately
protected by a written confidentiality or nondisclosure agreement. They are also not permitted
to disclose any confidential information they
receive from third parties. Kentz respects the
intellectual property rights of third parties and will
not knowingly infringe such rights.

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Kentz Corporation Limited

Code of Business Conduct

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Assets and accounting

Employees are not entitled to use Kentz assets and

resources for personal or third party gain. Employees
are also not entitled to take any assets, documentation
or reports belonging to the Group, including ones they
have worked on, with them when they leave the Group.
Employees are required to use the Groups
IT systems responsibly and primarily for the
business purpose for which they are intended.
They may not use the systems for any external
business, illegal or unethical purpose. The
systems are monitored to ensure all use is
appropriate and legal.
Unauthorised removal or destruction of any
Group assets is strictly prohibited. Their use for
any material non-directly business related activity
requires approval by line management.

Accounting
All Kentz Group company accounts and
supporting records must clearly identify
and properly describe the real nature of all
transactions, assets and liabilities.
All subsidiary company accounts are to be
prepared in line with related legislation and
generally accepted accounting principles in the
country in which the company is located. The
Groups consolidated accounts are prepared
in accordance with International Financial
Reporting Standards.
Accounting records are required to be
retained for at least as long as is required
by local legislation.

IMS COR 1 0031, Computer usage policy procedure

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Kentz Corporation Limited

Code of Business Conduct

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Government relations

Kentz interacts with government and regulatory

agencies in an honest and cooperative manner and
expects its employees, suppliers, agents, contractors
and consultants to do the same. Kentz seeks to
establish long term relationships and effective
communications with the governments of the countries
in which it operates.
It is Kentzs policy to comply with the
legislation in each of the countries in which
it operates, including that relating to hiring
or offering money or benefits to current or
former government employees.
No employee should be anything other than
honest when replying to a legitimate request for
information from any government official.

No employee
should be
anything other
than honest
when replying
to a legitimate
request for
information from
any government
official

Kentz will not do business with

any company or country that
is contrary to United Nations,
European Union or United
States export restrictions or
sanctions or that is blacklisted
by the United Kingdom or
United States governments.

Political Contributions
Kentz does not permit any Group funds to be
used for political donations or for its assets to be
used for any political purposes.
Kentz employees are of course permitted to
make such donations using their own money or
time, but not to be reimbursed by Kentz for doing
this or to do so in a manner that conflicts with
their work. They should inform their line manager
if they intend to stand for or accept any political
party or public office.

Employees and third parties

covered by the Code are
responsible for finding out
and complying with the laws
applicable to the countries in
which they work.

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Kentz Corporation Limited

Code of Business Conduct

09

Page
16

Speaking up

Kentz has its own internal procedures for

monitoring compliance with the Code, but
also relies on its employees and external bodies
speaking up where they become aware of
actual or potential breaches of the Code.
Speaking-up relates to the disclosure of
information by an employee or external
body if they have a genuine concern about
malpractice in Kentz. Instances may include
the contravention of internal policies, legal and
ethical standards, activities that put at risk the
health and safety of Kentz employees or others,
breaches of any environmental or regulatory
requirements, bribery and corruption, false
accounting, fraud and failure to comply with a
legal obligation, or a deliberate concealment of
information relating to any of the above.
Kentz is committed to ensuring any employee
or external bodys concerns of malpractice is
taken seriously and investigated. Every effort
will be made to protect the identity of anyone
speaking out on such matters. However, in
exceptional circumstances a persons identity
may have to be disclosed to conduct a thorough
investigation, to comply with the law and to
provide accused individuals their legal rights of
defence. Where this becomes necessary, any
harassment or victimisation of the complainant
will not be tolerated.
Depending on the nature of the matter being
highlighted, employees should first raise their
concerns with their line supervisor or tell an
appropriate safety officer or manager. If for
any reason they find this difficult they should
report the matter to the Chief Financial Officer
or the Group Compliance Officer, who are the
nominated executives with responsibility for
dealing with concerns raised by employees
speaking up, and are responsible for ensuring
that an appropriate investigation is conducted.

IMS COR 1 0070, Anti-fraud policy

Anonymous allegations are not automatically

disregarded but, given the safeguards which are
in place for those making allegations under this
policy, anonymous allegations are usually less
powerful than those from named individuals.
Any malicious allegations proved to be false or
materially incorrect may result in disciplinary
action being taken against the complainant.
Speaking up is not a way of pursuing a grievance
about a personal situation.
For exceptional cases, and if disclosure is about
a senior executive or director, concerns should
be reported directly to the Senior Independent
Director who will decide how the investigation
should proceed.
Members of the public and outside organisations
are encouraged to raise genuine concerns about
Kentz relating to the areas outlined within the
scope of this document. They should report
any matters or concerns to the Chief Financial
Officer or Group Compliance Officer, who are the
nominated executives responsible for dealing
with such concerns and where appropriate for
ensuring an investigation is conducted.
The Group will decide how to respond in a
responsible and appropriate manner to any
matters raised by the speaking up process. An
investigation will be conducted as speedily and
sensitively as possible. An official written record
will be kept at each stage of the procedure.
Failure to report the knowledge of any actual or
potential breaches of the Code or to cooperate
in any related investigation may result in
disciplinary action being taken against the
employee concerned.

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Kentz Corporation Limited

Code of Business Conduct

Page
17

Chief Financial Officer

Edward Power
ed.power@kentz.com
+971 506166849

Group Internal Audit Manager
Group Compliance Officer
Tony Lenard
tony.lenard@kentz.com
+973 36553504

Senior Independent Director
Chairman of Audit Committee
David Beldotti
dave.beldotti@kentz.com

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