Kuwait’s code (Module 15, Article 4-5) mandates a whistleblowing policy—a direct result of past fraud scandals. Saudi Arabia and Qatar copied this from UK’s 2010 Stewardship Code. However, the UK now emphasizes "risk appetite" statements and ESG (Environment, Social, Governance) metrics. Kuwait and Saudi are behind on ESG integration, though Saudi’s Vision 2030 is rapidly catching up.
While Kuwait requires annual self-evaluations, mandating external board evaluations every three years (as per the UK Code) would introduce independent, objective scrutiny of board performance and effectiveness, moving beyond potentially superficial self-assessments. Kuwait’s code (Module 15, Article 4-5) mandates a
While Kuwait, Saudi Arabia, and Qatar share regional, cultural, and concentrated ownership characteristics, their regulatory execution differs from the UK model: Kuwait and Saudi are behind on ESG integration,
| Jurisdiction | Primary Code / Authority | Key Features / Philosophy | | :--- | :--- | :--- | | | Code of Corporate Governance for Listed Companies (issued by CMA Kuwait, most recent version 2023-2024) | Heavily Sharia-compliant (Article 1-4), strong state influence, family-owned conglomerates. Focus on board composition, related-party transactions. | | United Kingdom | UK Corporate Governance Code (FRC, 2024 edition) | "Comply or Explain" model. Emphasis on board effectiveness, audit/risk management, shareholder rights, and corporate culture. | | Saudi Arabia | Corporate Governance Regulations (CMA Saudi Arabia, 2017, amended) | Sharia-based (Islamic law), aligns with Vision 2030. Focus on BOD independence, remuneration disclosure, and audit committees. | | Qatar | Corporate Governance Code for Companies Listed on the Main Market (Qatar Financial Markets Authority, 2016, updated) | Hybrid model: civil law + Sharia. Emphasis on disclosure, board responsibilities, and protection of minority shareholders. | Focus on board composition, related-party transactions
Corporate governance of listed companies in Kuwait a comparative study with united kingdom saudi and qatar codes.
The UK Corporate Governance Code, maintained by the Financial Reporting Council (FRC), sets a higher threshold. It states that at least half the board, excluding the chair, should be independent non-executive directors. The roles of chair and chief executive must not be exercised by the same individual.