Doing the right thing 1 Code of Conduct & Ethics

CODE OF CONDUCT & ETHICS

Doing the right thing
2 Code of Conduct & Ethics Doing the right thing

CONTENTS f) Declaration of Income, Assets and Liabilities............................................14

g) Professionalism and Performance of duties..............................................14
Corporate Mission and Vision...................................................................3 h) Financial integrity.................................................................................................14
i) Bank accounts outside Kenya...........................................................................14
MESSAGE FROM THE MANAGING DIRECTOR & CEO...................4 j) Acting for foreigners............................................................................................14
k) Acting through Others.......................................................................................14
PART I: PRELIMINARY 4 l) Reporting improper Orders...............................................................................14
m) Communication and Disclosure.....................................................................17
Core Values......................................................................................................5 n) Company Assets and Property.......................................................................17
i. Citation.........................................................................................................6 o) Wrongful and unlawful acquisition of property........................................18
ii. Interpretation.............................................................................................6 p) Public Collections.................................................................................................18
iii. Meaning of our Code of Conduct & Ethics....................................7 q) Citizenship...............................................................................................................18
iv. Our Ethical Commitment......................................................................8 r) Harassment, Discrimination and Bullying....................................................18
v. Purpose of the Code................................................................................8 s) Confidentiality and privacy................................................................................18
vi. Scope...........................................................................................................8 t) Non-Retaliation and Whistleblower Protection........................................19
viii. Administration of the Code................................................................9 u) Political Neutrality.................................................................................................19
v) Conduct of Private Affairs...............................................................................20
PART II: PROVISIONS OF THE w) Gainful employment and offers of future employment........................20
CODE OF CONDUCT & ETHICS...............................................................11 x) Acting in a public entity matter....................................................................20
a) Compliance with Laws, Regulations and Standards..................11 y) Wellness and Safety............................................................................................21
b) Corruption, Bribery and Fraud..........................................................12 z) Environment and Community..........................................................................21
c) Conflict of Interest..................................................................................12
d) Participation in tenders........................................................................13 PART III: ENFORCEMENT OF THE CODE 17
e) Gifts, Benefits and Favours.................................................................13 i. Duty to Report.......................................................................................................23
ii.Enforcement of the Code..................................................................................23
Doing the right thing 3 Code of Conduct & Ethics

Our Mission
Powering People for Better Lives

Our Vision
To Provide World Class Power that Delights our Customers
4 Code of Conduct & Ethics Doing the right thing

As we consistently strive to power people for better lives This Code is a public statement of how we do business and
towards providing world class power that delights our clarifies our expectations of ourselves. It holds us accountable
customers and creating value for everyone with a stake in our for our business conduct.
company, we recognize the enduring importance of acting
ethically at all times and in ensuring that our business practices It is a resource for helping us align our conduct and practices
meet the highest standards of integrity in line with our values. with our values. A key factor in ensuring our continued growth
Ethics and integrity stands at the core of everything we do. and success revolves around doing the right thing accountably
at all times, making the right choices and advocating adherence
In this regard, we have a Code of Conduct & Ethics to promote to our standards and principles by individuals, communities
and institutions which we interact with in the conduct of our
a culture of ethical performance which is a key tenet of good
business. Our Company is continuously in the public eye and
corporate governance. The code has been developed in line
there are many who look up to us to conduct our activities
with our values and is intended as a source of direction and
responsibly.
guidance for our actions and decisions internally and in our
interactions with stakeholders and the public. It is the responsibility for each of us to read, understand and
comply with the standards contained in the Code and build
both internal and external relationships based on integrity and
also avoid activities that could be detrimental to the reputation
of the Company.

If you are personally faced with, or observe, situations that are

contrary to our ethics or core values, you have an obligation
to resolve or report these incidents, using the approaches
described in the Code of Conduct and Ethics.

The Board of Directors and myself are personally committed

to our Code of Conduct & Ethics and appeal to each of you to
make the same commitment.
Thank you for supporting this important initiative.
Doing the right thing 5 Code of Conduct & Ethics

OUR CORE VALUES

Customer First Integrity
The customer is our top priority and should always be our Our business practices are based on openness, transparency,
first thought. Our customers, whether internal or external are trust, honesty, keeping promises and strong moral principles
treated as our first priority. We are individually dependable as perceived by our customers and other stakeholders. And in
to continuously provide high quality service that exceeds our adherence to applicable laws , regulations and standards, We
customers’ expectations. are safe custodians of our business and are responsible for the
protection of the environment and societies within which we
One Team operate.
We are interdependent in all aspects of our work. We
appreciate that as teams we can achieve much more than as Excellence
individuals. We value teams within and across functions as a We persistently strive to attain the highest levels of
means to achieve the corporate vision. We all must work as a achievement. We benchmark to ensure best practice and
team to achieve a common goal. ensure life-long learning for continuous improvement.

Passion
We must serve with enthusiasm, self-drive and total
commitment enabling us to remain focused and to deliver
exceptional performance at all times.
6 Code of Conduct & Ethics Doing the right thing

PART I: PRELIMINARY
i. Citation “The Act” means Leadership and Integrity Act, 2012 (Cap 182);
This code may be cited as the Code of Conduct and Ethics for
Kenya Power & Lighting Company Limited. The code sets out “Corruption” means;
standards of conduct and ethical behavior for employees of
the Company. 1. An offence under any of the provisions of sections 39 to
44, 46 and 47 of Anti-Corruption and Economics Crime
ii. Interpretation Act, 2003;
In this Code unless the context otherwise requires: 2. Bribery;
3. Fraud;
“Commission” means the Ethics and Anti – Corruption 4. Embezzlement or misappropriation of public funds;
Commission established under the Ethics and Anti – Corruption 5. Abuse of office;
Commission Act (Cap. 65A); 6. Breach of trust; or
7. An offence involving dishonesty;
“The Code” refers to the Code of Conduct and Ethics for Kenya • in connection with any tax, rate or impost levied
Power & Lighting Company. under any Act; or
• under any written law relating to the appointment of
“Employee” means a member of staff of the Kenya Power & persons to public office;
Lighting Company Limited.

“Kenya Power” means Kenya Power & Lighting Company

Limited;

“Public Officer” means an officer, employee or member

of a public body, including one that is unpaid, part-time or
temporary; as defined in Article 260 of the Constitution and
section 2 of Public Officer Ethics Act (Cap. 183);
Doing the right thing 7 Code of Conduct & Ethics

iii. Our Code of Conduct & Ethics-meaning

Our Code of Conduct & Ethics provides direction and guiding performance. Our corporate values must be the starting point
principles for our conduct internally and our interactions and foundation of our performance. Decision making should be
with suppliers, contractors, agents, other business partners, value based and should be done in a transparent, accountable
the communities in which we operate and with the public. It and responsible manner. This will safeguard our reputation
summarizes important Company policies, spells out prohibited and enhance stakeholder trust towards the achievement of
conduct and is intended to foster a culture of ethical our vision.
8 Code of Conduct & Ethics Doing the right thing

iv. Our Ethical Commitment:

We are committed to conducting our business ethically, To provide a system of support and resources for obtaining
transparently and accountably. We will do so with honesty, advice and guidance, raising questions, expressing concerns,
integrity and in line with our values. We respect applicable laws, reporting of violations and corrective action.
regulations, codes and industry standards while upholding
human dignity and diversity. We will manage our business vi. Scope
sustainably and in the best interest of all our stakeholders. The Code is a living document created to set and communicate
ethical/integrity and moral standards going beyond the law,
v. Purpose of The Code indicating how internal and external stakeholders of the
The Code of Conduct and Ethics is necessary to provide clear organization should act or behave.
parameters about acceptable principles and behaviors within
which employees are empowered to make decisions and act. This code therefore applies to all our stakeholders including
The Code of Conduct & Ethics while providing an important current and former employees, Board of Directors, customers,
reference point for current and future policies is in line with suppliers, contractors, business partners, consultants, vendors
best practice in terms of governance and compliance. Other and agents.
important uses of our code are:

Build universal understanding of expected behavior at Kenya

Power Provide a foundation from which to build our ethical
environment.

It is a useful barometer to measure the alignment of decisions

made, to our values.

To enhance, guide and maintain a corporate culture that places

great value on upholding the highest ethical standards.
Doing the right thing 9 Code of Conduct & Ethics

viii. Administration of The Code

The Board of Directors, Managing Director & CEO, Managers • Ensure that all employees have access to the code,
and all Supervisors are accountable for ensuring that commit to it by signature, and are helped to understand
the employees, suppliers, contractors, agents and other its requirements and other related corporate policies and
stakeholders are aware of, comply and live this code. procedures.
Leaders, managers and supervisors must also: • Promote a workplace environment that encourages honest
and open communication, and avoid putting pressure on
• Demonstrate exemplary behavior that other employees employees to deviate from the provisions of this code and
can follow other policies and standards.
10 Code of Conduct & Ethics Doing the right thing

• Ensure that the values, standards and policies outlined below. You may also raise a question or a concern or seek help
in this code are incorporated into induction sessions, or guidance from the department using these contacts.
training, performance management processes and
regularly discussed at staff meetings and through other The Risk Management & Integrity Department has a highly
internal communication channels. independent and anonymous reporting mechanism that can
• Respond promptly and ethical conduct matters. be reached through the following channels:
• Protect those who, in good faith, report suspected
violations or misconduct.
• Establish procedures for reviewing the suitability of Walk-in: Ethics & Integrity Office,
consultants, suppliers, partners etc before entering into 2nd Floor Stima Plaza Building (Wing B)
agreements with them. Mobile: Hot-Line: 0718 999 000,
• Establish an enabling environment which ensures that Other Corporate nos: 0711 031401/3
corrective measures are taken to address any operating Integrity Desk e-mail: [email protected]
procedures that may contribute to violations of the code. Corruption Boxes on all floors in all major
Kenya Power Offices.
All employees are required to sign their copy of this Code By Box Mail:
as having read it, understood it and remaining bound by its
provisions. Disciplinary Action including dismissal will be Risk Management & Integrity Department,
applied regarding contraventions of this code. Additional Kenya Power & Lighting Co. Ltd
actions may include reassignment of work duties and limitation P.O. Box 30099-00100
in future job opportunities. Violations of law may be referred Nairobi, Kenya
to law enforcement authorities for prosecution.

If you contravene, suspect or become aware of a possible

contravention of the code, a policy, a law or any regulation,
you should promptly and confidentially report this to Risk
Management & Integrity Department using the contact details
Doing the right thing 11 Code of Conduct & Ethics

PART II: PROVISIONS OF THE CODE OF CONDUCT AND ETHICS

The following are the provisions of this Code which Entities and individuals who do not uphold the law,
are important for living our values and optimizing standards and values of the Company are not to be
performance with integrity: engaged or retained.

a) Compliance with Laws, Regulations and We should not engage in or condone any illegal
Standards. act, instruct or induce others to do so or obstruct
the course of justice. It is a breach of the Code for
It is the policy of Kenya Power and the responsibility an employee to allow or direct a person under his/
of every employee to carry out his/her duties in her supervision or control to do anything that is in
accordance with the constitution, laws, regulations, contravention of the Code. An employee who acts
standards and lawful directives. Kenya Power under unlawful direction is responsible for his or
activities shall be carried out in accordance with her actions.
the letter and spirit of the applicable laws, codes,
regulations and standards. An employee shall submit any declaration or
clarification required by any law or regulation.
Only qualified individuals and reputable and credible Employees shall abide by the Company’s Service
entities should be engaged to do business with Charter.
Kenya Power. Contractors, suppliers, consultants, In carrying out his duties, an employee shall not
vendors, customers, current, former employees violate the rights and freedoms of any person as
and the public cannot be used to circumvent laws, enshrined in the Constitution.
regulations and standards.
12 Code of Conduct & Ethics Doing the right thing

b) Corruption, Bribery and Fraud c) Conflict of Interest

Our policy is zero tolerance to corruption, bribery and fraud in A conflict of interest occurs when an officer’s personal interest
all its forms. Active steps shall be taken against these vices as conflicts or appear to conflict with his/her official duties. All
they are not only illegal, but also unethical and inimical to the employees are expected to perform their duties honestly, fairly,
good of our organization and society in general. transparently and to act in the best interest of the Company
Corruption involves the misuse of authority for personal in all situations avoiding interests, activities, investments,
benefit or for the gain of third parties. relationships and influences that might compromise their
objectivity, effectiveness and the faithful performance of their
Bribery involves the promise, offer, giving, or receiving a benefit duties. All employees shall ensure that they avoid being in a
or anything of value, including cash, gifts, entertainment, or position whereby their personal interests conflict with their
other advantage or gratification intended to unfairly influence official duties.
a decision or obtain an unfair advantage.
A conflict of interest is therefore any relation that is, or appears
Fraud includes cheating, forgery, embezzlement, to be, not in the best interest of the organization. A conflict of
misappropriation, altering physical or electronic documents interest would prejudice an individual’s ability to perform his
and records, preparing and using fictitious and fraudulent or her duties and responsibilities objectively.
information and reports, submitting false claims and
deliberately failing to report a fraudulent act. A Conflict of Interest may arise when an employee has
competing interests between public duty and private interests
Staff shall not directly or indirectly promise, give, solicit which could improperly influence the performance of official
favours or kickbacks from the general public or customers duties and responsibilities.
either in cash or in kind, in the discharge of their duties.
Conflicts of interest have implications for both the employee
An employee shall not favor relatives, friends or associates in and the company. Personal implications include disciplinary
decision making or provision of services. action and loss of credibility. Corporate implications could
range from financial sanctions and penalties, litigation,
regulatory investigations and damage to reputation.
Doing the right thing 13 Code of Conduct & Ethics

The law prescribes a number of instances where conflict of

interest is deemed to occur. These include: If you become aware of or suspect the existence of a conflict
of interest (actual, potential or perceived), you must report
• Conflict of interest in respect of holding shares to the Risk Management & Integrity Department or utilize the
• An officer is prohibited from holding shares or having any Company’s reporting/ whistle-blowing facility.
other interest in a corporation, partnership or other body,
whether directly or through another person, if such action (d) Participation in tenders
would result in a conflict of interest. An Employee is prohibited from participating in a tender for
• Conflict of interest in respect to award of contracts the supply of goods and services to a public entity in which
• An officer is prohibited from awarding or influencing the he/she is serving or is otherwise similarly associated. However,
award of a contract to himself or herself, his/her spouse the holding of shares by an officer in a company shall not be
or child, a business associate or agent, or a corporation, construed as participating in the tender of a public entity unless
private company, partnership or other body in which the the officer has a controlling shareholding in that company.
officer has substantial or controlling interest.
• Conflict of interest in respect to conduct of meetings (e) Gifts, Benefits and Favors
• Where and officer is present at a meeting and an issue When employees are offered gifts, benefits or favours, it
which is likely to result in a conflict of interest is to be influences their judgment and objectivity in relation to
discussed, such an officer is required to declare the their service or
interest at the beginning of the meeting or before the issue transactions.
is deliberated upon. The declaration should be recorded in Employees are
the minutes of that meeting. prohibited from
accepting gifts,
Each employee must complete a conflict of interest declaration benefits or favours.
at inception of employment and thereafter once a year and
also whenever an actual or potential conflict arises in our A Gift presented
individual circumstances. The Company shall maintain a to an employee is
Conflict of Interest register. deemed a gift to
14 Code of Conduct & Ethics Doing the right thing

the Company and shall be declared forthwith in accordance An employee shall:

with the Company’s Zero-Gift policy. The Company shall
maintain 2 gift declaration registers in which it shall record;- • Carry out the duties of their office efficiently and honestly
All gift declared by staff in the Company in a transparent and accountable manner.
All gifts issued out by the company to its stakeholders. • Keep accurate records and documents relating to the
function of their office and report truthfully on all matters
Staff shall therefore not accept money, gifts, benefits, favours of the Company
and donations, or any consideration as an inducement or • Carry out his duties in a way that maintains public
confidence in the integrity of his office.
reward from members of staff or the public extended to them
• Observe impartiality and objectivity as required by the
by virtue of their official position for any act or omission,
constitution and not practice favouritism, nepotism,
which may influence their present or future actions, or show
tribalism, cronyism, religious bias or engage in corrupt or
favour or disfavour to any person.
unethical behaviour.
• Observe the requirements and standards of the
f) Declaration of Income, Assets and Liabilities.
professional body subscribed.
Every employee shall as prescribed by the law submit to the
• Endeavour to deliver high quality and timely service
responsible Commission a declaration of the Income, assets
consistently.
and liabilities of himself, his spouse(s) and his dependents
• Always keep promises and shall not knowingly give false
under the age of 18 years.
or misleading information to members of the public or to
any other employee.
g) Professionalism and Performance of Duties
• Treat the public and his fellow colleagues with courtesy
Authority assigned to an officer is a public trust which is to
and respect.
be used in the promotion of public good. Members of the
• Maintain an appropriate standard of dress and personal
public have a legitimate expectation that officers shall at all
hygiene
times discharge their respective public duties in a manner
• Keep time and display a sense of urgency in the discharge
that promotes public interest. Officers shall be required to
of duties.
take personal responsibility for the reasonable foreseeable
Endeavour to complete assignments as well as their daily/
consequences of their actions or omissions arising from the
monthly set work targets on time and avoid unnecessary
discharge of their duties.
delays.
Doing the right thing 15 Code of Conduct & Ethics

h) Financial Integrity k) Acting through Others

An employee should not use his office to unlawfully or An employee shall not cause anything to be done through
wrongfully enrich himself or herself or other persons. He/ another person that is in contravention to the Constitution,
she should not accept a personal loan or benefit which may laws, regulations, standards and lawful directives; an employee
compromise him/her in carrying out the duties of his/her shall not through coercion or otherwise compel another person
office. Financial integrity also involves exercising prudence in to engage in wrongful conduct.
one’s financial affairs.
An employee shall not allow or direct another person under their
i) Bank accounts outside Kenya supervision or control to do anything that is in contravention
An employee shall not operate a bank account outside Kenya to allocable laws, codes, regulations and standards.
without seeking prior approval from the Ethics and Anti- Any employee who acts under an unlawful direction shall be
Corruption Commission (EACC). held responsible for his or her actions.

An employee who has reasonable grounds for opening or l) Reporting Improper Orders
operating a bank account outside Kenya is required to seek Any employee who considers that anything required of them
approval and where approval is given, shall submit statements is in contravention to the laws, regulations, standards and
of account annually to EACC and Authorize the Commission to values of the Company or is otherwise improper or unethical
verify the statements and any other relevant information in the shall report the matter to the Ethics and Integrity Office or
foreign financial institution where the account is held. Ethics and Anti-Corruption Commission which have a duty
to investigate thereport and take appropriate action within
j) Acting for foreigners ninety days of receiving the report.
An employee is prohibited from being an agent of, or
furthering the interests of a foreign government, organization
or individual in a manner that may be detrimental to the
security interests of Kenya.
16 Code of Conduct & Ethics Doing the right thing
Doing the right thing 17 Code of Conduct & Ethics

m) Communication and Disclosure and open manner while keeping accurate records, making
The Company is committed to providing open, accurate, timely disclosures of material information while respecting
timely and truthful information to all its stakeholders at all obligations of confidentiality and privacy.
times. Employees shall not knowingly give false or misleading
information to any agency, person or members of the public. The Company shall adhere to independent auditing and
financial reporting standards.
The Company shall from time to time be called upon to give
information or express its views to various stakeholders n) Use of Company Assets and Property
including employees, customers, public, media, investor groups, It is the responsibility of all employees to protect and ensure
etc on certain issues, make presentations and participate in that the company’s assets, funds and property are used
conferences and meetings with investors and other interested efficiently in the best interests of the company and only for
parties. Any such communication should be carried out in line legitimate company purposes. The assets of the Company
with the Company’s communications and disclosure policies. shall not be misused, diverted or misappropriated for personal
Employees should avoid speaking or writing on behalf of the or third party benefit. We have to guard against loss, theft,
Company unless authorized to do so. misapplication, damage and waste. Business expenses must
be approved and incurred for good reason and wholly in the
Communication on decisions or changes that are likely to have best interest of the Company. We must use good judgment to
an impact on operations or employees’ livelihood shall be ensure that appropriate value is received by the company for
done openly and in a timely manner. all expenditure.

There shall be timely and adequate communication and Assets, resources, systems, technology, computers, software,
consultation with communities and customers on the Company procedures and networks of the Company or an employee’s
works, goods or services which are likely to impact on their position or status in the Company should not be used for
health, environment and safety. illegal, unauthorized and improper purposes or for the benefit
of third parties.
Company business, including highly technical and complex
contracts and transactions, shall be conducted in a truthful The Company’s information technology assets, resources and
18 Code of Conduct & Ethics Doing the right thing

systems, including data, software and licenses, must be used accordance with the provisions of the Kenya Citizenship and
and utilized responsibly for the Company’s business. The use of Immigration Act, 2011.
computers, electronic devices, internet and e-mail are subject
to restrictions which must be respected by all employees at r) Harassment, Discrimination and bullying
all times. The communication assets, systems, resources and We must work to achieve a positive work environment where
facilities of the company are not to be used to view, send, everyone is treated with dignity and respect.
exchange or distribute information, including pictures that are Harassment is any unwelcome verbal or physical behavior
offensive, degrading, and illegal or constitute harassment. that interferes with work or creates an intimidating, hostile, or
offensive work environment.
o) Wrongful or unlawful acquisition of property
Employees shall not use their office in the Company to It is important that our workplaces are free from all forms
wrongfully or unlawfully influence the acquisition of property of harassment including threatening e-mails, oral or written
for self or others. comments, humiliation and bullying. Hostility, intimidation,
abuse, threats or acts of violence of any sort and degree,
p) Public Collections abusive language and gestures, distribution of insulting and
An employee shall not use his/ her office or place of work offensive materials, pictures and cartoons are prohibited.
to solicit for contributions from members of the public nor
participate in a public collection of funds in a way that reflects Sexual harassment is any unwelcome sexual advance, request
adversely on the employee’s integrity, impartiality or interferes for sexual favours or other verbal, nonverbal, or physical
with the performance of their official duties. conduct of a sexual nature that interferes with work, is made
a condition of employment, or creates an intimidating, hostile,
q) Citizenship or offensive work environment.
The Constitution expressly prohibits a State Officer from
holding dual Citizenship. A state Officer who acquires dual The Company does not expect employees to tolerate sexual
citizenship shall lose his/her position as a state officer. The harassment from any cadre and likewise, sexual harassment
Act requires that upon election or appointment to a state by staff members towards any of the Company stakeholders
office, a person who holds dual citizenship shall not assume including customers, suppliers, contractors and vendors, will
office before officially renouncing hi/her other citizenship in
Doing the right thing 19 Code of Conduct & Ethics

not be tolerated. furthering a private interest.

Discrimination is the unjustifiable treatment or differentiation
between individuals or groups. All information of a personal nature disclosed to another
In relation to working conditions, recruitment, training, staff member in confidence shall be treated as privileged
promotions and continued employment, there shall be no information and may not be used against them.
discrimination on the basis of gender, ethnicity, health status,
religion and physical disability or any other discrimination that Information should be retained only for as long as is required
does not promote inclusion, teamwork and respect. by law and should be physically secured and protected.

An employee shall not use political or any other influence to t) Non-Retaliation and Whistle-blower Protection
manipulate a decision on a disciplinary matter, request for Employees, customers, shareholders, contractors, suppliers
promotions, or other favours to the disadvantage of other and the general public are encouraged to report, in a
colleagues. responsible and ethical manner, practices that are in conflict
with this code, regulations, policies, standards and the rule of
s) Confidentiality and Privacy law. This is intended to address organizational accountability,
We each have a responsibility to safeguard confidential transparency and individual responsibility. Individuals who
information relating to the employees, operations and activities report items in good faith are protected and cannot lose their
of the Company. We should not allow or permit unauthorized positions or suffer any form of harassment or occupational
disclosure of such information. detriment as a result. Such protection is not afforded to anyone
who maliciously raises a matter that they know to be untrue.
Employees who in the course of their duties have access to Malicious reporting may lead to disciplinary action.
confidential matters including employee records and tender
related information have an obligation to keep such matters The substance of an investigation including the identities
strictly confidential. of the parties to it will remain confidential and may only be
disclosed on a strict need to know basis.
Employees shall not directly or indirectly make use of or permit
others to make use of official information for the purpose of No employee shall threaten or victimize another for reporting
20 Code of Conduct & Ethics Doing the right thing

or exposing an illegal act or a violation of ethics. political party.

Any staff member wishing to report misconduct or an illegal • Be a founding member of or be eligible to hold office in a
act anonymously may do so through the established channels political party or movement.
i.e. reporting boxes, e-mail, intranet, telephone or walk-in • Indicate support for or opposition to any political party or
confidence to the Risk Management & Integrity Department candidate in an election.
as more detailed on the Company website and under the
Administration Section of this Code – Part 1 (xi) . v) Conduct of Private affairs.
An employee is expected to conduct his/her private affairs in
All correspondence entered into the Whistle-blowing process a manner that maintains public confidence in the integrity of
is absolutely confidential, whether a person making the his or her office and does not compromise or jeopardize the
disclosure wishes to remain anonymous or not. A distinction image or interest of the Company. This applies both to the
is drawn between the terms ‘confidential’ and ‘anonymous’. officer’s public and private life.
‘Confidential’ refers to information, while ‘anonymous’ refers
to the person disclosing the information. An employee shall not evade taxes nor neglect his/her financial
obligations.
u) Political Neutrality
We must balance our personal activities with the Company’s w) Gainful employment and offers of future employment
status as an independent organization and avoid situations An employee who is serving on a full time basis is prohibited
that could cause the public to believe that the Company is from engaging in any other gainful employment. The Leadership
partisan. An employee should avoid engaging in political and Integrity Act, 2012, defines “gainful employment” to mean
activity that may compromise or be seen to compromise the work that a person can pursue and perform for money or other
political neutrality of his or her office. form of compensation or remuneration which is inherently
incompatible with the responsibilities of the office or which
An employee shall not: results in the impairment of the judgement of the employee in
the execution of the functions or result in a conflict of interest.
• Vie for election as a member of parliament, county An officer should not allow himself or herself to be influenced
assembly, governor or any other political position while. by plans or expectations for or offers of future employment
However, an employee who wishes to vie for such elections or benefit. Where an officer is offered future employment or
will be required to resign as stipulated by law. benefit that could place the employee in a situation of conflict
• Act as an agent for, or so as to further the interest of, a of interest, he/she is required to disclose, in writing, to the
Company and the Commission.
Doing the right thing 21 Code of Conduct & Ethics

x) Former employee acting in a public entity matter z) Environment and Community

The code prohibits a former employee from being engaged by The Company respects the environment and is committed to
or acting for a person or entity in a matter in which the officer carrying out its activities in an environmentally sustainable
was originally engaged in as a state or a public officer, for at manner to ensure current needs are met without compromising
least two years after leaving office. the needs of future generations. We are committed to;

y) Wellness and Safety 1. continually improving our processes in order to prevent

The Company is obliged by the Occupational Safety and pollution, minimize waste, increase our carbon efficiency
Health Act (OSHA) to provide a safe and healthy working and make efficient use of natural resources.
environment for all employees. 2. develop innovative solutions to mitigate environmental
and climate risks. We will encourage green projects,
solutions and innovative ways to reduce the impact of our
We are responsible for ensuring that our workplaces are free activities on the environment.
of occupational injury and illness. 3. ensure that the communities and societies in which we
operate will be better off as a result of our presence.
We each have a responsibility to comply strictly and
consistently with the health and safety standards and policy To achieve this we will:
of the company.
• Communicate and consult on our activities and make
All employees should live a healthy lifestyle which in addition reports available to the public
to physical fitness encompasses other dimensions of wellness • Contribute to biodiversity protection in our areas of
that is spiritual, emotional, social and intellectual wellness and operation.
includes: • Work to reduce pollution, carbon emissions and minimize
• Work-Life Balance waste from our activities.
• Social Connections and Support Systems • Establish, maintain, continually improve and audit
management systems to identify, monitor and control the
• Purpose in life
environmental and community aspects of our activities
• Mind-Body Health • Ensure that employees and all stakeholders are aware of
• Financial Planning these commitments and their responsibilities.
• Continued Learning
• Stress Management
• Nutrition
22 Code of Conduct & Ethics Doing the right thing
Doing the right thing 23 Code of Conduct & Ethics

PART III: ENFORCEMENT OF THE CODE: Any person who has lodged a complaint against an employee
shall be afforded a hearing and is entitled to be informed of
i. Duty to Report any action taken or to be taken in respect to the complaint.
If an employee or other stakeholder encounters unethical
behavior or considers that anything required of him/her is a iii. Acknowledgement and Ethical promise
contravention of this Code of Ethics or is otherwise improper
or unethical, he/she is duty bound to report the matter through
I,Mr./Mrs./Ms./Dr/Prof……………………...........................…………………………
the reporting channels as indicated.
Staff No………….........................… acknowledge that I have received,
ii. Enforcement of the Code
Upon recruitment or appointment into the Company, an carefully read and understood the Code of Ethics. I do promise
employee shall sign and commit to abide by the Provisions of
to live and abide by it in letter and spirit and support its
the Code of Conduct and Ethics.
implementation at all times.
Breach of this Code of Conduct & Ethics amounts to
misconduct for which the employee shall be subjected to
disciplinary proceedings. Signed……………………........……….............................................................…….

Any person may lodge a complaint against an employee who Date …….....…………………..........................................................…………………..
has breached the code to the Company through the stipulated
Supervisor’s Name………….........................................…………..........………..
channels or relevant Agency. The complaint must be recorded
and the Agency will authorize its officers to make an inquire
Signature ……………………………......................................................................
into the complaint on its behalf to determine the merits of the
complaint and give its feedback if the officer has contravened
the code. Based on the feedback of the investigation the
Company will take appropriate action including refereeing the
matter for civil or criminal proceeding.
24 Code of Conduct & Ethics Doing the right thing

Kenya Power Integrity & Ethics contacts:

Integrity and Ethics Department,
Kenya Power & Lighting Co. Ltd.,
P.O. Box 30099-00100 Nairobi, Kenya.
Walk-in: Stima Plaza 4th Floor,
Mobile: Safaricom: 0718 999 000, 0711 031401/3,
Email: [email protected],
Suggestion Boxes in all major Kenya Power Offices. www.kenyapower.co.ke