ETHICAL
POLICY

Our strong code of ethics

• BUSINESS INTEGRITY Open

  KKI insists on integrity, honesty and fairness in all aspects of business and we seek the same from those with whom we do business, directly and indirectly. No employee may directly or indirectly offer, pay, solicit or accept a bribe, or any other such payment which may be construed as such, in any form. Political donations by or on behalf of KKI are also prohibited.

  Gifts and entertainment may only be offered to any third party if they are consistent with customary business practices, modest in value and not in contravention of any applicable law. No employee should seek or accept a personal gift or entertainment that might reasonably be believed to influence commercial activity or the decision-making process. No employee should act in a manner that may bring KKI into disrepute.

  Employees must avoid private, financial or business activities (including those of immediate members of their families) that conflict with their responsibilities to KKI.

  All business transactions must be lawful, reflected accurately and fairly in KKI’s accounts in accordance with established procedures and be subject to audit. KKI’s accounting records will accurately reflect and describe the nature of the underlying transactions. Illegal, unfair or unethical practices are not acceptable.

• OUR COMMITMENT TO STAKEHOLDERS Open

  At KKI, we recognise our corporate responsibility to six main groups of stakeholders. Below are our pledges to each group.

  TO CUSTOMERS
  To win and retain customers by developing and providing products and services that help them to run successful businesses. To promote customer satisfaction, to be responsive to customer comments and complaints.

  TO EMPLOYEES
  To respect the human rights of all employees, whether directly employed or sub-contracted, consistent with the UN Universal Declaration of Human Rights. To provide and maintain safe conditions of work, with competitive terms and conditions of employment. Not to use any form of under-age or forced labour, and to act consistently with the International Labour Organisation Declaration on Fundamental Principles and Rights at Work.

  To promote diversity by selecting, developing and retaining employees on the basis of ability and qualifications for the work performed, without any form of discrimination or prejudice under any circumstances. To insist that harassment does not take place under any circumstances.

  To encourage the involvement of employees in the planning and direction of their work.

  TO SUPPLIERS AND BUSINESS PARTNERS
  To seek mutually beneficial relationships with contractors, suppliers and joint-venture partners. To require that, so far as practicable, all of these adhere to business principles consistent with our own.

  TO THE COMMUNITY
  To conduct business as responsible corporate citizens, to observe the laws of the UK, to give proper regard to the health, safety and the environment of local communities, and to be sensitive to and supportive of local cultural, social, educational and economic needs.

  TO SHAREHOLDERS
  To build shareholder value through growth and total shareholder return. To conduct our operations in accordance with accepted principles of good corporate governance. To provide timely and accurate information on our activities and performance. To build and protect our reputation and our brand.

  TO COMPETITORS
  To respect the confidentiality of any competitor data that may be offered. KKI employees should not solicit or accept any confidential competitor data. Any data received unsolicited should be destroyed. KKI employees should never ‘bad mouth’ any competitors.

• HEALTH, SAFETY AND THE ENVIRONMENT Open

  It is KKI’s policy to establish and manage safe and healthy working conditions for all employees. We seek effective and efficient ways to protect and enhance the environment in which we live and operate.

• COMPLIANCE, MONITORING AND REPORTING Open

  The KKI senior management team is responsible for communicating this Ethics Code to all employees and for ensuring its contents are understood and adhered to. Day-to-day responsibility in this regard is delegated to the senior team at KKI. Each employee is expected to make himself or herself aware of, and deal appropriately with, all significant legal, ethical and accounting considerations relevant to their work for the company.

  Compliance with this Code is monitored and reviewed by the senior management team of KKI as part of its risk management process, supported by relevant committees.

  Breaches of the Code must be reported to relevant senior managers of KKI. Breaches by an employee may be a disciplinary offence. KKI has a ‘whistle blowing’ policy that encourages employees to report breaches of this Code and other concerns in confidence. Under this policy, KKI will take all reasonable steps to ensure that no party suffers unjustified detriment and, equally, that no KKI employee engages in victimisation in any form.

  The Code is intended to foster a search for continuous improvement in all aspects of our performance. It will therefore be reviewed annually and will be referred to in KKI’s Annual Report as part of an ongoing improvement programme.