Whistleblowing Policy
Overview
The Company is committed to the highest standards of transparency and accountability in our business. The Company endeavors to earn and uphold the trust of its shareholders, employees, customers, suppliers, and other stakeholders by serving and dealing with them ethically, lawfully, and professionally. In line with this commitment, Wateen expects employees and others that it deals with, who have serious concerns about any aspect of Wateen’s business, to come forward and voice those concerns.
This Whistle Blowing Program serves to provide a channel for Wateen’s staff and outside parties such as shareholders, vendors, customers, etc. to raise complaints and concerns against irregularities, help uncover financial malpractices, detect and prevent incidents of frauds & forgeries, eliminate personnel harassments, improper conduct or wrongdoing and attend to grievances of those associated without any fear of reprisal or adverse consequences.
This Program has been formulated with an aim to further improve governance and quality of Wateen’s operations. The employees and outside parties are encouraged to use the guidance provided in this Program to report any wrongdoing / improper conduct. This Program also provides assistance to individuals who come across any wrongdoing or improper conduct and are desirous of highlighting it without being identified. It is not designed to question financial or business decisions taken by the Company nor should it be used to reconsider any matters which have already been addressed under other policies/procedures.
Objectives
The intended objectives of this policy are:
a) To develop a culture of openness, accountability, and integrity.
b) To encourage confidence in all employees and other associated individuals to question and raise concerns in the interest of the Company which may cause financial or reputational risk for Wateen.
c) To enable Management to be informed at an early stage about fraudulent, unethical, or malicious activities or misconduct and take appropriate actions.
d) To create awareness amongst employees and other stakeholders regarding the Whistle Blowing Program.
e) To provide avenues for confidentiality of concerns raised and to reassure a whistleblower for protection from possible reprisals or victimization.
Scope of the Program
The scope of this Policy includes, without limitation, the following:
a) Unlawful acts or orders in violation of a law, gross waste, mismanagement, abuse of authority and resources of the Company;
b) An illegal act, false or misleading statements, intentional twisting of the truth, or concealment of facts either for personal gain or for willfully causing loss to the Company;
c) Over-invoicing, demanding, seeking, or acceptance of kickbacks, payment for goods or services not supplied or rendered, and any act of fraud, bribery, and corruption by any employee including management;
d) The collusive arrangement between two or more persons/employees designed to achieve mala fide objectives, including improperly influencing the actions of another person/employee;
e) Forgery of company documents and financial instruments like cheques and securities;
f) Theft or misappropriation of the Company’s funds and property;
g) Conflicts of interest and abuse of office;
h) Disclosure of business secrets and other confidential Company information obtained during the course of employment;
i) Financial or Non-financial maladministration or malpractice or fraud that has been/is likely to be committed;
j) Usage of confidential information to obtain a personal reward or advantage;
k) Compromising the interests of Wateen in dealings with vendors or contractors, consultants or suppliers;
l) Violation/non-compliance of the Company’s policies/procedures;
m) Health and safety risks, including risks to the public as well as other employees;
n) Damage to the environment, Company assets, and corporate image; or
o) Any other activity which undermines the Company’s operations, mission, or repute.
Procedure for Raising Concerns
a) An employee, who has a reasonable belief that there is serious misconduct relating to any of the above matters, may raise a concern in terms of the procedure set out hereunder. Concerns must be raised without malice, must be in good faith,and not based on office gossip nor must it be made for purposes of personal gain. The individual making the disclosure must reasonably believe that the information and the allegations contained therein are substantially true.
(Good Faith is evident when the report is made, in the interest of the Company, without consideration of personal benefit and not based on personal grudges and enmity, and the Whistleblower has a reasonable basis to believe that the contents of the report are true. However, it is not necessary that a report made in Good Faith proves to be true.)
b) Reports are highly encouraged to be made in writing to ensure a clear understanding of the issues being raised. Such reports should be factual rather than speculative and contain as much specific information as possible, including name(s), background of the concern, dates, places, events, and every possible reason for such disclosure. Whistleblowers are encouraged to use the form provided in the Policy.
c) Employees may raise the concern through the following internal avenues:
i) Confidential Call: To make a confidential call, the members of the Audit, Risk & Governance (ARG) are available at the following numbers: +923214502818
ii) Postal Address: Head of Audit, Risk & Governance (ARG), Wateen Telecom Limited, Main Walton Road, Opp. Bab-e-Pakistan, Walton Cantt., Lahore
iii) Via Email: ARGTeam@wateen.com
Investigation Authority and Procedure
a) All complaints/allegations shall be handled by Audit, Risk & Governance (ARG) for necessary investigation. In case a concern is made to an authority other than ARG, the authority shall forward the concern to ARG immediately and without disclosing it to any other person within or outside the Company. ARG may involve other departments considering the nature of the complaint.
b) Each concern received by the ARG shall be logged. In case a concern is made to an authority other than ARG, the authority shall forward the concern to ARG timely and without disclosing it to any other person within or outside the company.
c) Access to information regarding the identity of the complainant and suspected party will be restricted to ARG personnel only.
d) ARG will assess the complaint with a view to decide whether it meets the criteria laid down in the Whistle Blowing Program for an investigation to be conducted.
e) An investigation shall only be conducted if the concern is sufficiently specific and contains adequate corroborating evidence to warrant an investigation.
f) The investigating team shall have unrestricted access to all records which they deem necessary in discharging their duties. The team will have full authority to enquire about any employee and/or take an explanation from him either verbal or written. It is the responsibility of every employee of the Company to extend full cooperation during the investigation. Any instance of non-cooperation shall be dealt with in accordance with the Company’s human resource policies/procedures.
g) At the end of the investigation, a written report shall be prepared including the background, findings, summary of evidence gathered, and a conclusion as to whether or not the allegations have been substantiated.
h) Matters concerning criminal activity or suspected criminal activity may be referred to the Legal department for further legal action.
i) Official alleged fraudulent activity may be suspended from work during investigation if required under the circumstances.
j) In the event that a complaint is lodged against members of Senior Management, namely the Chief Executive Officer (CEO), Chief Financial Officer (CFO), Vice Presidents, Directors, or the Head of the Audit, Risk and Governance (ARG), the investigation into the matter, if deemed actionable, shall be overseen either by a designated Board member or an independent investigator chosen at the discretion of the Board.
Investigation Reporting
a) If the identity of the whistle-blower is known and to respect the privacy of the suspected party, only a general acknowledgment regarding the receipt of the allegations shall be reported to the whistleblower.
b) The final investigation report including the finding, summary of evidence gathered and a conclusion reached as to whether the allegations are substantiated shall be forwarded to the relevant governance body.
c) ARG shall maintain a register documenting all allegations raised by whistleblowers and action taken against the complaint (including allegations not followed up due to the complaint not being specific or lack of adequate/ sufficient evidence).
d) A status report documenting all the whistle-blowing allegations and actions taken to resolve them shall also be made available for the review of the relevant governance body on a regular basis.
Anonymous Allegation
Wateen encourages Whistleblowers to disclose their identities when raising concerns. Concerns raised anonymously shall only be entertained if the same include verifiable facts, sufficiently specific information, and adequate/reasonable corroborating evidence or proof. In case after initial assessment, it is determined that an anonymous complaint shall not be considered further, the reasons shall be recorded in writing. The decision made by the Head of ARG in this regard shall be final.
In case ARG requires further information to complete an assessment of whether to entertain an anonymous complaint, they shall make a reasonable endeavor to contact the anonymous whistle-blower on a number or email (if provided) which shall in no case be more than three times or 1 week as considered appropriate. If contact cannot be established with the anonymous whistle-blower during this time, the complaint will not be considered further.
Protection Assurance
This program makes it clear that employees can speak without any fear of victimization, discrimination, or disadvantage. Any investigation of potential malpractices will not influence or disclose the name of the person coming up & raising such serious facts. The Company will not tolerate any harassment or victimization against a whistle-blower if the disclosure has been made in good faith and the person reasonably believes that the information disclosed is substantially true. Employees will be listened to and supported.
Untrue or False Allegations
Deliberately raising a false concern is also an allegation under this Policy. Disciplinary action may be initiated against complainants who raise false allegations frivolously or for personal gain.
Whistleblower Implicated in Misconduct or Wrongdoing
The Company acknowledges that the act of Whistle Blowing should not shield Whistleblowers from the reasonable consequences flowing from any involvement in improper conduct or wrongdoing. A person’s liability for his or her own misconduct is not absolved by the person’s disclosure of that conduct. However, in some circumstances, such admission may be a mitigating factor when considering disciplinary or other action.
Confidentiality
All the concerns received will be treated in strict confidence and every effort shall be made not to reveal the identity of the complainant before anyone during or after the investigation procedure except before the BAC/BOD (if required).
Rights & Responsibilities of Suspected Parties
The suspected party or parties shall be;
- Bound to answer or respond to the queries made from the investigation and appear in person if called by the investigator.
- The suspected party has a responsibility not to interfere with the investigation. They are not to withhold, tamper, or destroy evidence or influence, coach or intimidate witnesses. Unless there are compelling reasons to the contrary, subjects should be given the opportunity to respond to material points of evidence contained in an investigation report.
- Given a chance to give representation in their favor with proper evidences & witnesses before any action is taken against them.
Other Considerations
a) The Company shall ensure that the Whistle Blowing Policy is fairly and consistently applied.
b) The Company shall keep records in good condition to protect evidence, ensure credibility, and avoid claims of discrimination.
c) The ARG should not rush to judgment. The subject of allegation involves rights which are to be safeguarded. Every person should be given ample opportunity to present his / her case and defend the allegation against him/her.
d) Consideration should also be given to costs and whether the focus is prosecution, recoveries, restitution, or termination. Any decision should take into consideration the potential cost/amounts involved compared to potentially recoverable assets before initiating any action.
Review & Monitoring
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.
Effective Date
This program shall be operative & effective with immediate effect.