What Is the Corporate Whistle Blowing Policy
Allied Bank’s Corporate Whistle Blowing Policy creates a safe environment for reporting concerns. It covers activities that violate the Bank’s policies or could adversely affect its business, goodwill or reputation. The policy also protects whistleblowers from retaliation, including job loss, discrimination, victimization and harassment.
This policy forms part of Allied Bank’s wider corporate governance framework. The Audit Committee of the Board (ACOB) is responsible for its implementation. The policy is available on the ABL SharePoint portal and the Bank’s corporate website. It applies across the Bank, including its overseas operations.
Who Can Report a Concern
Who Can Use This Policy
This policy is available to a wide range of individuals, including:
All of these stakeholders are encouraged to report concerns under the policy.
A Whistleblower’s Role
A whistleblower’s role is limited to reporting concerns only. They are not expected to investigate the matter or determine the appropriate corrective or remedial action that should follow. That responsibility rests with the Bank’s designated investigators.
What You Can Report
The policy covers several categories of misconduct. It includes unlawful acts, or orders that violate banking laws or regulations. Fraud, which involves the use of deception to obtain an unjust or illegal advantage, is also covered. The policy also covers the falsification of financial records or accounting books.
Other reportable issues include activities that endanger someone’s health or safety. Corruption and bribery, including offering or accepting undue benefits, are also covered. Collusive practices between two or more individuals’ and any activity that undermines the Bank’s operations or reputation qualify as well.
This policy is distinct from Allied Bank’s Anti-Harassment Policy and Employee Grievance Handling procedures. Matters covered under those policies are dealt with separately. The Corporate Whistle Blowing Policy is also not intended to question the financial or business decisions made by the Bank. It focuses on reporting fraudulent, immoral, unethical or malicious conduct.
How to Submit a Report
Allied Bank’s Corporate Whistle Blowing Policy provides three (03) channels for reporting a concern.
All three reporting channels are designed to protect whistleblowers’ identities and ensure confidentiality.
Confidentiality and Protection for Whistle Blowers
Confidentiality
All matters reported under the Whistle Blowing Policy are treated with strict confidentiality. The identity of the whistle blower is not disclosed unless there is a legitimate need to do so, such as when required by a court to provide direct evidence. Otherwise, the whistle blower’s identity is disclosed only to those directly involved in investigating the matter.
Protection from Retaliation
The Bank also protects whistleblowers from retaliation, including discrimination, victimisation, and harassment. If a whistleblower faces risk at their workplace, the Bank may consider transferring them to another suitable location.
Such protection is limited to what the Bank can reasonably provide.
Indemnity for Good-Faith Reporting
Whistleblowers who act in good faith may also be granted indemnity from disciplinary action related to the matter they have reported, subject to the merits of each case.
Note: This protection does not apply to individuals who raise concerns to settle personal grudges.
Incentives for Genuine Reports
The Bank may reward whistleblowers whose reports provide significant value to the Bank. Rewards may include a cash prize, a salary increase or a promotion, depending on the significance of the information shared and the extent of the financial or reputational loss prevented.
To qualify for a reward, whistleblowers must disclose their identity and provide their contact details. Anonymous reports are not eligible for any incentive even if the allegations are later proven to be correct. All rewards are given confidentially, without revealing the reason to others.
Responsibilities of the Bank and the Whistle Blower
The Corporate Whistle Blowing Policy is shared with all employees twice a year. The Bank regularly monitors the effectiveness of the Whistle Blowing Function and reports relevant information to the ACOB. Some concerns may also be escalated directly to the State Bank of Pakistan where required by law.
Whistle blowers are expected to act in good faith, remain unbiased, and provide accurate, fact-based information. Malicious, false or repeated vexatious complaints may result in appropriate action. Whistle blowers are also encouraged to disclose their identity, where possible, so that the Bank can provide stronger protection.
Investigation and Disciplinary Action
The Investigation Process
Outcomes of Proven Misconduct
Proven misconduct by bank officials leads to disciplinary action under the bank’s rules and procedures.
Where appropriate, the Bank may also initiate legal action against external parties or any individual responsible for serious misconduct.
Frequently Asked Questions
Q. Who can use Allied Bank's Corporate Whistle Blowing Policy?
Current and former employees can report concerns under this policy. So can shareholders, vendors, contractors, service providers, customers and the general public.
Q. How can I report a concern to Allied Bank?
You can report a concern by sending an email to [email protected], by submitting a whistle blowing form through the Bank’s corporate website, or by sending your concern by post or courier, addressed to the Chairman, ACOB, Allied Bank Limited, Head Office, 3 Tipu Block, New Garden Town, Lahore.
Q. What types of issues can be reported?
Fraud, corruption, bribery, misconduct, falsification of records, health and safety risks, collusion, violations of Bank policies, and other activities that may harm the Bank or its reputation.
Q. Will my identity remain confidential if I report a concern?
Yes. Your identity will be kept confidential and disclosed only when legally required or when necessary for the investigation.
Q. Am I protected from retaliation?
Yes. The Bank is committed to protecting whistle blowers from discrimination, harassment, victimization, and other forms of retaliation.
Q. What if someone makes a false or malicious complaint?
Deliberately false, malicious, or vexatious complaints may result in appropriate disciplinary action.
Q. Can I report anonymously and still receive a reward?
No. Anonymous reports are not eligible for incentives or rewards, even if the allegations raised are later proven true.
Q. How long does Allied Bank keep whistleblowing records?
All records related to whistle blowing are retained in accordance with the Bank’s record retention policy and applicable regulatory requirements. Speaking up protects both individuals and Allied Bank as a whole. The bank's Corporate Whistle Blowing Policy gives everyone, from employees to customers, a safe channel to raise concerns. If you would like to read the complete policy, visit Allied Bank's page on the Corporate Whistle Blowing Policy.