1.  Objective

 1.1 Encourage all employees and stakeholders to identify and report any wrongdoings within the Company.

 1.2 Provide avenues for confidentiality of concerns raised and allow recommendations on corrective measures.

 1.3 Provide protection to a whistleblower from possible reprisals or victimization.

2.  Confidentiality and protection of whistleblower

2.1   The identity of whistleblower will not be disclosed and information passed on through whistleblowing will be kept confidential to protect the reporting person as well as the accused for any consequent discrimination or unfair treatment. The whistleblower will be protected against unfair treatment from his / her colleagues and management and any harassment or pressure towards the whistleblower will not be tolerated by the Company. Anonymous complaints however, may not be entertained.

2.2    False allegations

Malicious allegations by employees may result in disciplinary action against the complainant and penalties may be imposed.

3. Whistle Blowing Committee

3.1  The Whistleblowing Committee (WBC) shall assess the reasonableness / adequacy of such reporting and shall recommend investigation, if needed. CEO shall have the authority to decide final course of action after the investigation.

3.2 If the complaint is against any member of the WBC, the whistleblower may report the matter to the CEO. The accused member of the WBC shall not be part of the committee for the concerned complaint.

The WBC meeting shall include at least two of the following members, with presence of the Head of Internal Audit as compulsory:

• Head of Internal Audit
• Head of HR
• Company Secretary

Head of Internal Audit shall be Chairperson of WBC.

3.3  The WBC shall:

• Conduct an enquiry in a fair and unbiased manner.
• Ensure complete fact finding.
• Minute committee deliberations.
• Document final report.

4. Procedure (How to blow the whistle)

4.1 The complaint can be reported via following methods:

• Through email at [email protected] preferably with whistleblower’s identity
• A phone call to the Head of Internal Audit on 021-34384044-46-47-48 Ext. 12
• Letter by post to Head of Internal Audit at the Karachi Head Office address: Plot# 40-L-1, P.E.C.H.S. Block 6, Near Jason Trade Center, Karachi 75400, Pakistan

4.2 Each concern received by the WBC shall be logged and acknowledged to the whistleblower.

4.3 Depending on the nature and significance of complaint, the Board Audit Committee (BAC) may be consulted for guidance and recommended course of  action.

4.4  Reporting

Log of whistleblowing complaints and status of proceedings will be updated to BAC on quarterly basis by Head of Internal Audit.