1. Objectives of the Whistle Blowing Policy

Pakistan Telecommunication Company Limited (PTCL) is committed to the highest possible standards of openness, probity and accountability. In line with that commitment PTCL expects employees and others that it deals with, who have serious concerns about any aspect of PTCL’s work to come forward and voice those concerns.

The objective of this policy is to promote greater openness in the workplace and to encourage all individuals to disclose immediately any malpractice or wrongdoings that may adversely impact PTCL. In addition, this policy will enable the Audit Committee to discharge its responsibilities of establishing procedures for the receipt, retention, independent investigation and appropriate follow up action on complaints received regarding accounting, internal controls, auditing or other matters.

An important aspect of accountability and transparency is a mechanism to enable all individuals to feel confident to voice concerns internally in a responsible and effective manner when they discover information which they believe shows malpractice or wrongdoing. Any person raising such concern shall be referred to as a Whistle Blower.

The Whistle Blowing Policy is therefore fundamental to enhance professional integrity and to provide avenues for any individual to raise concerns in confidence and receive feedback on any action taken. In addition, it reinforces the value PTCL places on stakeholders to be honest and respected members of their individual professions. It provides a method of properly addressing bona-fide concerns that, individuals within PTCL might have, while also offering Whistle Blowers protection from victimization, harassment or disciplinary proceedings. The policy however discourages employees and other stakeholders from making complaints with a malicious intent. Other stakeholders, for this purpose, include vendors, customers and shareholders.

2. Areas in which concerns can be raised

Specific examples of circumstances where a Whistle Blower can raise concerns could include but shall not be limited to:

• Over-invoicing, demanding, seeking or acceptance of kick-backs, payment for goods or services not supplied or rendered and any act of fraud, bribery and corruption;
• Forgery of company documents and financial instruments like cheques and securities;
• Theft or misappropriation of company’s funds and property;
• Conflicts of interest and abuse of office;
• Disclosure of business secrets and other confidential company information obtained during the course of employment;
• Financial or Non-financial maladministration or malpractice or fraud that has been/is likely to be committed;
• Usage of confidential information to obtain a personal reward or advantage;
• Compromising the interests of PTCL in dealings with vendors or contractors, consultants or suppliers;
• Misuse of PTCL property;
• Misuse of authority;
• Unethical behavior;
• Misuse of systems or sharing of passwords;
• Discrimination towards any staff member, customers or any stakeholders on the grounds of sex, race, nationality or religion;
• Engaging in illegal or unlawful acts; and
• Compromising PTCL’s Safety Health & Environment (SHE) standards.

Vendors and customers also can blow the whistle for malpractices and wrongdoings that adversely affect PTCL. However, routine vendor grievances and disputes over delays in delivery, LDs, PO issuance, payments etc. will still be dealt through normal management channels. Similarly, customer complaints will also be handled by the relevant department.

3. Fundamental Elements of this policy

• Confidentiality

PTCL will make every effort to keep confidential the identity of the individual raising a concern if so desired by the individual. In which case, the identity of the individual raising the concern or making the report will not be revealed without his/her prior permission unless PTCL is required to reveal the identity of the individual by law.

Where there are deliberate false allegations, no matter how minor, disciplinary actions in case of employees and black listing and/or legal action for defamation may be taken against the Whistle Blower.

• Whistle Blowers & Evidentiary Support for Allegations

PTCL encourages Whistle Blowers to disclose their identities when raising concerns. Whistle Blowers should endeavor to provide sufficient corroboratory evidence to justify the commencement of an investigation. An investigation of unspecified wrongdoing or broad allegations may not be undertaken without verifiable evidentiary support. In the event a Whistle Blower wishes to remain anonymous, he/she can request to be provided with a reference in order to keep track of the claim and/or submit more information. However, no information about the outcome or action taken on the basis of information provided by the anonymous Whistle Blower shall be provided to such Whistle Blower unless he discloses his true identity to the Chief Internal Auditor, who shall be obligated to keep that identity confidential.

• Support

PTCL recognizes that the decision to report a concern is not easy due to the fear of reprisals from those potentially affected. PTCL will not tolerate harassment, victimization or undue disciplinary actions and will take any action that is appropriate to protect a Whistle Blower who makes a report in good faith under this policy even if it turns out not to be true after investigations provided that:

o    The report was made in good faith;

o    The Whistle Blower had reasonable grounds to believe that the report is true;

o    The Whistle Blower did not make the report for personal gains.

Whilst all steps will be taken to keep confidential the identity of the individual raising a concern, necessary support actions which may require to be taken, may include formal notifications by Human Resources (HR) to the relevant functions to protect the job environment of the Whistle Blower should he/she be identified. Follow-up action may be taken by the HR function where the Whistle Blower is located (if such location is known) to ensure no reprisals will take place to the bona-fide Whistle Blower.

Similarly, stakeholders other than employees will also be provided with the necessary support such as protection against any reprisals or discriminations subject to the fulfillment of above mentioned conditions for whistle blowing.

4. How to raise concerns

a)      Individuals who witness or learn of a potential violation, as explained, can report this matter directly using any of the following channels:

• Email to wb@ptcl.net.pk; or
• By speaking directly to the PTCL confidential line on telephone number + 92 51 2283159; or
• Sending a letter to Chief Internal Auditor of PTCL; or
• By escalating the issue to a direct line manager and/or any other escalating/reporting mechanism the Whistle Blower feels comfortable with. By way of example, the Whistle Blower may feel more comfortable raising his/her concerns in accordance with the reporting line as set out in the Code of Conduct and/or the relevant Human Resources Manual, as applicable.
• Where a concern relates to CEO or any Senior Official of Internal Audit Department of PTCL, the Whistle Blower should send their concerns by a letter to Chairman of Audit Committee c/o the Company Secretary of PTCL marked “Confidential Complaint”.

b)      In case the individual desirous of reporting any matter under this policy considers it inappropriate to report it to the local management due to the criticality or sensitivity of the matter involved, he may report such matter directly to the Etisalat Group using following channels. However, unnecessary use of the Group channels for reporting minor disciplinary or personal issues shall not be encouraged.

• Email groupwb@eand.com for e& group

or +97148002002 (outside UAE)

• Sending a letter to Group Chief Internal Control & Audit Officer– Etisalat Group and/or the Corporate Secretary – Etisalat Group, P O Box 3838, Abu Dhabi, United Arab Emirates.