The purpose of this Policy is to create an environment at Allied Bank Limited (the Bank) whereby employees, vendors, service providers, and other concerned parties are encouraged to reveal and report—without any fear of retaliation, subsequent discrimination, or being disadvantaged in any way—any fraudulent, immoral, unethical, or malicious activity or conduct that may cause financial or reputational loss to the Bank.
The Corporate Whistle Blowing Policy provides assurance to Whistle Blowers regarding secrecy and protection of their legitimate personal interests. It also provides incentives to Whistle Blowers for reporting suspicious activities.
It is the Bank’s policy to support and encourage current or former employees, shareholders, vendors, contractors, service providers, customers, or the general public to report and disclose fraudulent, immoral, unethical, or malicious activities, and to conduct investigations based on such reports. The Policy ensures that all reports will remain strictly confidential. The Bank is also committed to addressing any reports that allege interference, retaliation, or threats against the Whistle Blower.
Although the Bank’s internal control and operating procedures are intended to detect and prevent such activities, no system provides absolute safeguards. Therefore, employees are encouraged to report any misconduct that may cause financial or reputational loss to the Bank.
Whistle Blowing is a communication to a competent authority by an individual or institution to expose and/or inform about alleged fraudulent, immoral, unethical, or malicious activities or discrimination, or any other adverse occurrence that violates laws, regulations, policies, morals, or ethics, particularly those that jeopardize the credibility and reputation of the Bank.
This Policy encourages Whistle Blowers to voice their concerns to an appropriate pre-identified authority regarding any fraudulent, immoral, unethical, or malicious activity that violates the Bank’s policy or adversely affects its business, goodwill, or society—without fear of retribution.
A Whistle Blower is an individual or institution who raises a concern through proper channels, including current or former employees, shareholders, vendors, contractors, service providers, customers, or members of the general public.
Note: A Whistle Blower’s role is limited to reporting. They are not considered investigators and do not determine corrective or remedial action.
An operationally independent function, established under the supervision of ACOB, responsible for handling and monitoring allegations, complaints, and concerns raised under this Policy.
The Chairman ACOB may assign complaints to the Chief ARR, another Bank Executive, or an external investigator. If the complaint concerns the Chief ARR, a person designated by the Chairman ACOB will delegate the investigation accordingly.
A report is made in good faith when it is submitted without personal motives, based on a reasonable belief that the information is true, and is in the Bank’s interest—even if the report is later proven incorrect.
Examples include, but are not limited to: financial fraud, regulatory violations, breach of Bank policy, unethical behavior, negligence, and activities that pose threats to the Bank.
Any act of revenge, harassment, or discrimination taken directly or indirectly against a Whistle Blower due to their disclosure under this Policy.
Protection refers to all reasonable measures the Bank takes to maintain confidentiality of the Whistle Blower’s identity and safeguard them from retaliation or financial loss.
The Audit Committee of the Board (ACOB) shall be responsible for implementing this Policy.
This Policy is applicable to all employees of the Bank and external parties such as shareholders, vendors, customers, etc., including the Bank’s overseas operations.
This Policy shall be available on the ABL SharePoint portal and the Bank’s Corporate Website.
The success of this Policy depends on the integrity, professional ethics, and confidentiality maintained by both Whistle Blowers and respondents. While retaliation by management or peers is a known deterrent, the Bank is committed to protecting Whistle Blowers from emotional, psychological, or physical harm.
All reports will be treated confidentially. The identity of the Whistle Blower will only be disclosed in unavoidable situations—such as legal proceedings—or when necessary for investigation.
The Chief ARR is responsible for keeping this document updated. It shall be reviewed at least once every three years. Any proposed changes shall be submitted to the ACOB and recommended to the Board of Directors (BOD) for approval.
The Whistle Blowing Function is operationally independent and supervised by ACOB.
i. Strengthen a culture of transparency and trust.
ii. Encourage disclosure of unethical or fraudulent acts.
iii. Create awareness about the Whistle Blowing Function.
iv. Provide a confidential channel for early detection of misconduct.
This Policy covers:
Violations of law or regulations, including SBP regulations.
Financial fraud or deception.
Falsification of records.
Health or safety endangerment.
Bribery and corruption.
Policy violations or parallel banking.
Collusive practices.
Any activity undermining the Bank’s reputation or mission.
Note: This Policy is separate from the Anti-Harassment Policy and Employee Grievance Handling Procedure, and should not be used for complaints covered under those policies.
Information and identity will be kept confidential.
The Bank will not tolerate harassment or victimization.
If a Whistle Blower fears retaliation, they may request a transfer, unless the claim is found to be false or malicious.
Retaliatory actions will be treated as Misconduct.
Indemnity may be granted, depending on the merits of the case.
Circulate the Policy twice yearly.
Provide communication channels (email, website form, postal address).
Ensure secure complaint handling.
Periodically evaluate the Policy’s effectiveness.
Escalate legal matters to regulators as required.
Apply the Policy consistently and fairly.
Report known misconduct.
Remain objective and factual.
Avoid false or malicious reporting.
Share identity (recommended) for full protection.
Incentives may include cash rewards, salary increase, or promotion, based on the value of the information.
Anonymous Whistle Blowers are not eligible for incentives.
Rewards will be given confidentially.
No action will be taken against good faith reports that are unsubstantiated.
False or malicious complaints may lead to disciplinary action.
The Chief ARR shall develop a Whistle Blowing Procedures Manual, subject to ACOB’s approval.
Reports will be submitted to the Chairman ACOB and referred for action if necessary.
All complaints will be retained for three years, then archived as per the Bank’s retention policy.
Internal or legal action may be taken based on investigation outcomes.
Right to a fair hearing and appeal
Obligation to maintain confidentiality and cooperate in investigations