Anti-Bribery Policy

Introduction

The Company is committed to maintaining the highest standards of ethical conduct and integrity in all its business activities. The Company views anti-corruption & anti-bribery measures not merely as a legal requirement or an ethical stance but recognizes that these are a peril to both its business and the communities it serves. The Company acknowledges that Corruption & Bribery has the potential to jeopardize lawful business endeavors, disrupt fair competition, harm reputations, and pose risks to individuals.

This Anti-Corruption & Anti-Bribery Policy (the “Policy”) outlines the Company’s zero tolerance for Corruption & Bribery and lays out the ethical standard that its Employees, contractors, and representatives must adhere to prevent Corruption & Bribery within the Company.

“For the sake of clarity, the capitalized terms used herein and not otherwise defined shall have the meaning ascribed to them in Appendix-A attached with this Policy”

Prohibition of Bribery and Corruption

The Company strictly prohibits Bribery and Corruption in any form, including but not limited to, offering, giving, receiving, or soliciting any form of improper advantage.

The Policy applies to all Employees, contractors, agents, and representatives of the Company. 

Compliance with Laws

All Employees must comply with the requirements of The Prevention of Corruption Act, 1947, and any other anti-corruption & anti-Bribery laws and regulations of Pakistan as may be in force from time to time. Any violation of these laws will be considered a breach of the Policy and may result in disciplinary action, including termination of employment.

Gifts and Entertainment

Employees must exercise caution when giving or receiving Gifts, favors, or Entertainment in the course of business. Gifts of nominal value (equivalent max to USD 100) are generally acceptable, but any offering or acceptance of a gift that could be perceived (by a reasonable prudent and independent person) as influencing business decisions person is strictly prohibited.

Record-Keeping

Accurate and transparent record-keeping is essential. All accounts, invoices, memoranda, and other documents and records relating to dealings with third parties, such as clients, suppliers, and business contacts, should be prepared and maintained with strict accuracy and completeness. No accounts must be kept “off-book” to facilitate or conceal improper payments.

Reporting and Whistle-blower Protection

Any violation of the Policy can be reported at ARGTeam@wateen.com or by calling at +923214502818 in accordance with the Company’s Whistle Blowing Policy.

The Company believes that prevention, detection, and reporting of Bribery and other forms of Corruption are the responsibility of all Employees working with the Company. If the Employees are unsure whether a particular act constitutes Bribery or Corruption, or if they have any other queries or concerns, these should be raised with the established reporting channels.

Employees are encouraged to report any suspected violations of this policy promptly. The Company will protect whistle-blowers from retaliation, and reports can be made confidentially through established reporting channels.

Training and Communication

Employees will receive periodic and pertinent training sessions on the implementation and adherence to this Policy.

The Company’s unwavering stance of zero tolerance towards Bribery and Corruption needs to be communicated to all suppliers, contractors, and business partners at the commencement of our business relationship with them and as necessary thereafter.

Due Diligence

Before entering into any business relationship, the Company will conduct due diligence to assess the Corruption & Bribery risk associated with potential partners, suppliers, and clients.

Enforcement

The violations/breach of this Policy may result in disciplinary action, legal action, or both. The severity of the consequences will depend on the nature and gravity of the violation.

Review and Updates

The Policy will be periodically reviewed and updated to ensure its effectiveness and relevance. Any improvements identified will be made as soon as possible. Employees are responsible for familiarizing themselves with the latest version of the Policy.

All Employees are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing.

APPENDIX-A

Definitions

Bribery: The improper offering, seeking, or acceptance of payments, Gifts, or advantages to influence business outcomes.

Corruption: The misuse of trust to gain an undue advantage, including theft of funds and company assets.

Employee: All individuals working at various levels within the Company, including officers, managers, and temporary staff.

Entertainment: Includes business meals, hospitality, tours, and cultural or sports events.

Gift(s): Tokens, social courtesies, or commemorative items presented on occasions or events.