Corporate Whistle Blowing Policy

Corporate Whistle Blowing Policy is aimed to provide a platform for Whistleblowers to voice their concerns to appropriate pre-identified authority about any suspicious or undesired events / activities, which are against the policies of Allied Bank Limited or may have an adverse impact on the business or goodwill of Allied Bank Limited or the society at large. Whistleblowers should be able to report such case(s) without any  reservations of retribution, such as fear for the loss of job, discrimination, victimization, harassment, etc.,.  Whistle Blowing is one of the effective contemporary managerial techniques used for prevention / detection of the likely attempt(s) of defrauding the organization and other malpractices by its employees, customers and/or other parties. It mobilizes the employees to communicate their suspicions and reasonable doubts to the management about malicious activities without fear and prejudice.

1. Introduction

  • 1.1 Purpose

    • The purpose of this Policy is to create an environment at Allied Bank Limited (the Bank) whereby the staff is encouraged to reveal and report, without any fear of retaliation, subsequent discrimination and of being disadvantaged in any way, about any fraudulent, immoral, unethical or malicious activity or conduct, which in their opinion may cause financial or reputational loss to the Bank.
    • Corporate Whistle Blowing Policy of the Bank provides assurance to the Whistleblowers about secrecy and protection of their legitimate personal interests. It also provides incentives for the Whistleblowers upon report of suspicious activities.
    • It is the Bank’s policy to support and encourage its honest, dedicated and loyal employees to report and disclose fraudulent, immoral, unethical or malicious activities and conduct investigation on such reports. The Corporate Whistle Blowing Policy assures that all reports under this Policy would remain strictly confidential and that the Bank is also committed to address reports (if any) that alleges acts of interference, revenge, retaliation and threats against the Whistleblowers.
    • The Bank’s internal control and operating procedures are intended to detect and to prevent or discourage such activities; however, even the best systems of controls cannot provide absolute safeguards against irregularities. Therefore, all employees are encouraged to report any such activity or act / misconduct that may cause financial or reputational loss to the bank.

  • 1.2 Definitions

    • Whistle Blowing: Whistle Blowing is a communication to a competent authority by an individual or an institution to expose and / or inform upon, alleged fraudulent, immoral, unethical or malicious activities, or discrimination, or some other type of adverse occurrence that violates a law, regulation, policy, morals, and/or ethics and especially those matters that jeopardize the credibility and reputation of the Bank as a trusted financial services provider.
    • Corporate Whistle Blowing Policy: Corporate Whistle Blowing Policy is to encourage the Whistleblowers to voice their concerns to an appropriate pre-identified authority about any fraudulent, immoral, unethical or malicious activities, which are against the policy of the Bank, or may have an adverse impact on the business or goodwill of the Bank or the society at large without any reservations of retribution such as fear for the loss of job, discrimination, victimization, harassment etc.,
    • Whistleblower: Whistleblower is a person or institution, who blows the whistle and sends communication to the entrusted authority, following the process as prescribed, includes current or former employees of the Bank, shareholders, vendors, contractors, service providers, customers, or the general public. The role of a Whistleblower would remain to the extent of reporting only, who will neither be considered an investigator nor determines the appropriate corrective or remedial action that may be required under the given situation.
    • Whistle-blowing Unit: An operationally independent Unit established, under supervision of ACOB, for handling and monitoring allegations, complaints and concerns raised by the whistleblower under whistle blowing policy.
    • Investigator: Chairman ACOB shall advise the whistle blowing complaints to Chief ARR or any other appropriate Bank Executive or outsource to any investigator.  Chief ARR shall get the investigation done as per investigation procedure of the Bank. If the complaint is against Chief ARR, the person so designated by Chairman ACOB for investigation may delegate the investigation to any person out of ARR or outsource to any external agency.
    • Good Faith: Good Faith is evident when the report is made, in the interest of the Bank, 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.
    • Misconduct: Examples of Misconduct include, but are not limited to, financial fraud, violation of laws and regulations, violation of Bank’s policies, immoral or unethical behavior or malicious practices, negligence of duty and threats to the Bank.
    • Retaliation: Retaliation means any act of discrimination, revenge or harassment directly or indirectly taken against a Whistleblower, by any person, for making a disclosure under this Policy.
    • Protection:Protection means all reasonable steps taken by the Bank to ensure confidentiality of the Whistleblower’s name as well as measures enforced to protect the Whistleblower from retaliation and financial losses.

  • 1.3 Responsibility for Implementation

    The Audit Committee of the Board (ACOB) shall be responsible for implementation of this Policy.

  • 1.4 Applicability

    This policy shall be applicable to all of the bank’s employees and outside parties such as shareholders, vendors, customers etc.

  • 1.5 Availability

    This policy shall be available on ABL SharePoint portal as well as on ABL’s corporate website.

  • 1.6 Safeguards

    The success of this Policy depends in part on the integrity, observation and professional ethics of the Whistleblower & respondent(s) as well as on the level of confidentiality maintained. However, retaliation by workplace peers and harassment or victimization by the management, are the major disincentives to Whistle Blowing. Therefore, to avoid the possibility of emotional, psychological and/or physical harm upon the whistle blowers as a result of Whistle Blowing, the Bank stands committed to safeguard the Whistleblowers.

  • 1.7 Confidentiality

    All matters will be dealt with confidentiality and the identification of the Whistleblower will not be disclosed except for inevitable situations, where disclosure of identity of the Whistleblower is essential (for instance, his / her statement/evidence is needed in court) or report of a complaint has to be disclosed to those persons who have a need to know in order to properly carry out an investigation of the complaint.

  • 1.8 Revision

    The Chief ARR shall be responsible for keeping this document updated from time to time. Therefore, this Policy shall be subject to a formal review by the Chief ARR on a periodic (at least once in every three years) basis and the proposals for any changes/ modifications/ amendments therein shall be submitted to the ACOB for consideration and its further recommendation to the BOD for approval.

  • 1.9 Independence of Whistle Blowing Unit

    1. Whistle blowing unit has been formed under supervision of ACOB.

2. Objective & Scope

  • 2.1 Objectives

    The intended objectives of this policy are:

    • To develop a culture of openness, accountability and integrity;
    • To provide environment to the honest, loyal, dedicated employees of the Bank to blow whistle where they know or suspect any immoral, unethical, fraudulent act of any current or former employees, vendors, contractors, service providers and customers which may cause financial or reputational risk to the Bank;
    • To create awareness amongst employees and stakeholders regarding the Whistle Blowing Function; and
    • To enable Management to be informed at an early stage about fraudulent, immoral, unethical or malicious activities or misconduct and take appropriate actions.

  • 2.2 Scope

    1. The scope of this Policy includes, without limitation, the following:
      • Unlawful acts or orders requiring violation of a law, gross waste, mismanagement, abuse of authority and resources of the Bank;
      • Fraud – an intentional act by one or more individuals amongst management, those charged with governance, employees, or third parties, involving the use of deception to obtain an unjust or illegal advantage;
      • Corruption – the offering, giving, receiving, or soliciting, directly or indirectly, anything of material value or providing undue benefits to influence improperly the actions of another person / employee;
      • Misconduct – failure by the Bank’s personnel to observe the Bank’s policies, rules and Code of Personal & Professional Standards including those resulting in embezzlement of funds and conducting of parallel banking activities;
      • Collusive practices – an arrangement between two or more persons / employees designed to achieve mala fide objectives, including improperly influencing the actions of another person / employee; and
      • Any other activity which undermines the Bank’s operations, reputation and mission.
    2. Complaints related to the Human Resource and administrative issues shall be forwarded to CEO of the Bank for taking appropriate action as per Bank’s policy and procedures related to that issue.
    3. This Policy is not designed to question financial or business decisions taken by the Bank nor should it be used to reconsider any other matters which have already been addressed under other procedures, rules or regulations of the Bank.

3. Protection of Whistleblowers

  • The information given and the identity of the Whistleblower will be treated in a confidential manner as per sub-section 1.7 of the policy.
  • The Bank stands committed to protect Whistleblowers for Whistle Blowing, harassment or victimization of the Whistleblower will not be tolerated.
  • If the Whistleblower feels that, at his / her place of posting, he / she might be subjected to victimization or harassment by the alleged officials after blowing the whistle, the management may consider transferring him/her to another suitable place on his/her request. However, this assurance is not extended in cases where it is proved that the Whistleblower raised the matters to settle his / her personal grudges or grievances or enmity or where the Whistleblower has been habitually involved in complaining petty issues.
  • Protection that Bank can extend to Whistleblower is limited to the Bank’s capability, but any retaliatory action against any Whistleblower as a result of whistle blown by such person under this Policy shall be treated as Misconduct and subject to disciplinary action.
  • Indemnity from disciplinary action will be provided to the whistleblower employee, against actions/involvement in the activity against which whistle is blown, based on the merits of the subject case,

4. Responsibilities

  • 4.1 Bank’s Responsibilities

    • The Bank will circulate Corporate Whistle Blowing Policy for the information of all the employees of the Bank.
    • The Bank will establish the following communication channels for whistle blowing complaints:
      • A dedicated e-mail address for Whistle Blowing ([email protected]) will be accessible by the Chairman ACOB.
      • Whistle blowing forms available on the bank’s corporate website.
      • Post / courier addressed to Chairman ACOB, Allied Bank Limited, Head Office, 3-4 Tipu Block, New Garden Town, Lahore.
    • Where Whistleblower sends communication on postal address given in this Policy, the Bank shall ensure that the unfiltered complaints are delivered directly to the Chairman ACOB.
    • The Bank will put in place a mechanism to evaluate effectiveness of Whistle Blowing Function under this Policy. Under that mechanism, MIS relating to issues raised through Whistle Blowing arrangements and management response to such issues will be reported to ACOB periodically. In addition to this, names of the official(s) responsible for receiving, handling and monitoring whistle blow complaints shall be presented to ACOB for periodic review.
    • The Bank will ensure that the Corporate Whistle Blowing Policy is fairly and consistently applied. It should spell out zero tolerance for all violations e.g. fraudulent, immoral, unethical or malicious activities.
    • The Bank will ensure that Whistleblower should feel secure while reporting fraudulent, immoral, unethical or malicious activities.
    • The Whistleblowers should share their identity enabling Bank to provide protection as per Section 3 of this Policy and share the results of investigation, if required.

  • 4.2 Responsibility of Whistleblower

    • In the event that any fraud, forgery, fraudulent, immoral, unethical or malicious activities have occurred due to involvement of the Bank’s officials, the employees who have knowledge are ethically and morally bound to Whistle Blowing or take appropriate action if they are authorized to.
    • It is expected that the Whistleblower shall remain unbiased while reporting matters under this Policy.
    • In making a disclosure, the Whistleblower should exercise due care to ensure the accuracy of the information. Whistleblower should not make repeated, malicious, wrong, not based on facts, based on personal grudges, grievances or personal enmity or vexatious allegations. In such a case, appropriate action may be taken against the Whistleblower.

5. Incentives for Whistleblowing

  • To motivate the Bank’s staff to behave honestly, in loyalty with the Bank, independently without any fear, for saving the Bank from risks of financial or reputational losses caused by fraudulent, immoral, unethical or malicious activities or misconduct of some dishonest and corrupt persons, the management may offer incentives. In order to be eligible for all such incentives the Whistleblower(s) must share their contact information. In case of anonymous Whistle Blowing, no such reward shall be given to anyone in any situation or circumstances, even if allegations imposed are proved to be correct.
  • On the recommendation of the ACOB to the management, the Whistleblower, who brings to the notice of the management or report any fraudulent, immoral, unethical or malicious activities, which may lead to financial or reputational losses or legal threats to the Bank, will be suitably awarded according to the significance of the information he / she had provided and impact of losses averted as a result. The award may include cash prizes and or increase in salary and or promotion.
  • The prizes / awards will be given to the concerned Whistleblower confidentially and in a manner that no one can grasp the actual reason thereof.

6. Misuse of Whistle Blowing

It is expected from all employees to refrain from rumor mongering, irresponsible behavior and false allegations and if staff makes an allegation in good faith, but it is not confirmed by the investigation, no action will be taken against them. If, however, staff makes malicious or frivolous allegations /complaint(s) or misuse whistle blowing policy for undue posting/transfer of himself/herself on disclosure to team member/ senior about whistle blown or the shelter available under whistle blowing policy, action may be taken against them after proper investigation.

7. Implementation of Corporate Whistle Blowing Policy

  • 7.1 Process of Whistle Blowing

    The Chief ARR shall be responsible for the development of Whistle blowing Procedures Manual which shall be approved by ACOB.

  • 7.2 Reporting

    Strict confidentiality will be observed in submission of the investigation reports. The report along with the result of investigation carried out by the team formed shall be submitted to the Chairman, ACOB periodically.

  • 7.3 Retention of whistle blowing complaints

    All whistle blowing complaints received at the aforementioned dedicated email address, through mail or through whistle blowing form available at ABL’s corporate website shall be retained for 3 years after which the complaints shall be archived and preserved as per bank’s record retention policy.

  • 7.4 Disciplinary Action

    1. If involvement of the Bank’s officials in fraudulent, immoral, unethical or malicious activities and other malpractices is proved during investigation of the case then disciplinary action will be initiated as per applicable rules and procedures of the Bank.
    2. For external parties, the Bank may on the basis of investigation report and recommendations, consider taking appropriate legal action against the concerned party.
    3. If the matter is of grave nature, the Bank may decide to take legal action against the culprit(s).