Ethics & Compliance – Frequently Asked Questions (FAQs)

A. Understanding the Ethics & Compliance Program

1. What is the purpose of the PTCL Ethics & Compliance program?

Our Ethics & Compliance program fosters a culture of integrity by helping employees act ethically and in line with laws, regulations, and our Code of Conduct. It offers clear policies and guidance to support ethical decision-making in all interactions—whether within the company or with external partners, vendors, and other stakeholders.

2. Who is responsible for upholding ethical standards?

Every individual associated with PTCL Group shares the responsibility for upholding ethical standards. This includes all full-time and part-time employees, contractors, directors, officers, advisors, consultants, and board members. We also expect our external partners—such as agents, representatives, and other third parties acting on our behalf—to demonstrate the same commitment to integrity in all business interactions.

3. What is the Employee Code of Conduct?

The Code of Conduct is a guiding document that sets out PTCL’s expectations for ethical behavior from all employees. It encourages integrity, transparency, and responsible decision-making in every professional situation. The Code also supports a culture of innovation, customer focus, adaptability, and respect for diversity and inclusion. Through these principles, it ensures a work environment built on trust, accountability, and continuous improvement.

4. Is there a Code of Conduct for Third Parties?

Yes. PTCL has a Business Code of Conduct that outlines PTCL’s ethical expectations and compliance requirements for all third parties (vendors and business partners). Adherence to this Code is a mandatory condition for engaging in business with PTCL.

B. Recognizing and Avoiding Misconduct

5. What are some examples of compliance violations?

Compliance violations can take many forms, and if you are ever unsure, its always better to ask than assume.

Common examples include:

• Bribery or corruption – Offering or accepting money, gifts, or favors to influence decisions.
• Conflicts of interest – Allowing personal relationships or interests to interfere with objective business decisions.
• Harassment or discrimination – Treating someone unfairly or making them feel uncomfortable based on their gender, race, age, or other personal attributes.
• Breaches of confidentiality – Sharing sensitive company information with unauthorized individuals or entities
• Violations of laws, company policies, or the Code of Conduct – Failing to follow legal requirements, internal policies, or code guidelines designed to promote fairness and integrity in the workplace.

6. What are common red flags of unethical conduct?

Red flags are signs that something may be unethical—even if a violation hasn’t occurred yet. Watch out for behaviors or requests like:

• Requests for off-the-book payments - Being asked to make unrecorded/unauthorized or hidden payments.
• Excessive gifts or entertainment – Offers like expensive watches Air pods or an all-expenses-paid trip.
• Vague or overly complex payment terms - Invoices showing large lump sums without details or justifications.
• Unusual urgency in approvals or decisions - Pressure to approve a contracts, reports, or decisions without proper review.
• Lack of transparency in ownership or operations - A third party refuses to disclose ownership, key business details, or relevant documentation.

If you spot any of these, raise the concern with your manager or contact the Ethics & Compliance team.

7. What is a Conflict of Interest, and how should it be disclosed?

A Conflict of Interest (COI) arises when personal interests interfere—or appear to interfere—with PTCL’s interests. This includes outside employment, business relationships, or personal connections that could impact objectivity.

Employees must disclose any actual or potential conflicts through PCHub using the COI disclosure form under the Compliance tab. External parties should proactively disclose any conflicts during onboarding or as they arise.

8. What should I do if I am offered a gift or hospitality that could be perceived as a bribe?

If you are offered any gift, entertainment, or hospitality that appears excessive, inappropriate, or intended to influence a business decision, you must politely decline or return it, and report the incident immediately.

• Employees are required to notify their line manager, inform the Ethics & Compliance team, and log the offer in the Gifts & Hospitality Register on PC HUB, in accordance with PTCL’s Gifts & Hospitality framework.
• Third parties acting on behalf of PTCL (e.g., agents, consultants) must uphold the same standards and report such offers to compliance@ptclgroup.com.
• Third parties doing business with PTCL (e.g., vendors, suppliers) are also expected to report any inappropriate offers made by PTCL employees or representatives.

9. What should I do if I am unsure whether something is unethical?

If you are unsure, trust your instincts and ask questions. It’s always better to speak up—whether with your manager or the Ethics & Compliance team. No concern is too small when it comes to doing the right thing.

You can reach out confidentially to Ethics & Compliance team anytime at Compliance@ptclgroup.com. Acting with integrity starts with asking questions when you are uncertain. 

C. Reporting Concerns

10. How can I report unethical behavior or compliance concerns?

We provide several secure and confidential channels for reporting concerns:

• Ethics & Compliance queries: Email us at compliance@ptclgroup.com
• Whistleblowing cases: Report via wb@ptclgroup.com
• Sexual harassment complaints: Contact anti.harassment@ptclgroup.com
• Grievances: Use Meri Awaz portal on PC HUB or email meriawaz@ptclgroup.com

All reports are treated confidentially to ensure a respectful and safe workplace.

11. How do I report a suspected case of bribery or unethical conduct—whether internal or external?

Suspected bribery, facilitation payments, or any unethical behavior should be reported without delay to the Whistleblowing hotline wb@ptclgroup.com and Ethics & Compliance hotline at compliance@ptclgroup.com.

12. Will my identity be protected if I report an issue?

Yes. We are committed to protecting the identity of anyone who reports a concern in good faith or supports an investigation. Retaliation is strictly prohibited. For more details, please refer to our Whistleblower Policy: Click here

D. Third Party Expectations

13. Do you expect business partners and vendors to comply with your standards?

Absolutely. We expect all third parties—such as vendors, suppliers, agents, and other business partners—to uphold PTCL’s ethical standards and comply with applicable laws and regulations. This includes, but is not limited to:

• Anti-money laundering (AML) and countering the financing of terrorism (CFT) laws
• Sanctions and export control regulations
• Anti-bribery and anti-corruption requirements
• Respect for human rights
• Accurate recordkeeping
• Disclosure of actual or potential conflicts of interest

These expectations ensure responsible and ethical conduct across our value chain.