NISHAT

introduction

Organizational hierarchy

• Mian Umer Mansha Chief executive officer

• Mian Hassan Mansha Chairman

• Mr. khalid Qadeer Qureshi Director

• Mr. Saeed Ahmad alvi Director

• Syed Zahid Hussain Non executive director

• Ms.Nabiha Shahnawaz Cheema Non executive director

• Mr. Maqsood Ahmad Executive director

Board of directors

Human resource

Import export

Finance& banking

AccountsMarket-

ing

Departments

No. of Employees 20510

Whistleblowing policy

Protection of interest

companypublic

Purposeof Nishat’s policy

The purpose of policy is to protect both interests

‘‘The purpose of this policy is to provide channel to raise concerns of any violations of legal or regulatory requirements , in correct or any financial statements and reports etc without fear of punishment or unfair treatment.’’

Concerns• Unlawful activity

• Against code of conduct

• Incorrect financial reporting

Nishat whistleblowing policy

• Confidentiality

• Anonymous allegation

• Bad faith allegations

• Harassment or victimization

safeguards

Managing director

Legal advisor

Non executive director

Channels to blow whistle

Managing director /legal advisor/non executive director

committee

General manager

Internal auditor

HR manager

Chief financial officer

Access to channel

In step one whistle blower will blow a whistle to recommended channel (managing director , legal advisor , non executive director)

Step 1

In this step the Channel (managing director , legal advisor , non executive director) will share the concerns with whistle blowing committee and this committee will be responsible for next investigation of case.

Step 2

This step is related with complete investigation process.

Step 3

Further information about case

Truth of whistle

Nature and severity of loss

Assigning of code

Finally after complete investigation a written report with all proof and signatures of investigation teem ,will be presented to GM (general manager) for further step.

Step 4

Now ,GM will award the whistle blower if his Whistle save company from loss ,and to the guilty(against whom whistle was blower) with sticks as par the severity of loss to company.

Step 5

Committee

General manager

Different expertiseDelegated authority Have deep knowledge about co’s affairs

Part of the boardAccess (deptt,info)Experienced

Easy to accessHave power to take action

justification

Channel

In writing.

In specified form.

Form must fill completely.

Give all necessary and important information.

Can add extra information other than ,specified in form

Procedure of reporting

Report using

whistle@nishat.com

Fax no

Company’s website

Telephone line

Methods to report

• Assigning of a code.

• Investigation procedure.

• Presentation of written report to MD.

• Resolve concern within 60 days.

• Respond to whistleblower in 3 days.

• Necessary actions against concern.

• Maintain record for 3 years.

Steps to handling concerns

Secrecy of whistleblower’s identity

Form would be attached to salary envelope

Have option of direct access to higher authority

After investigation sharing of outcomes with whistleblower.

Whistleblower’s protection

Positive Negative

If in good faith then no step will be taken

As par the severity of loss

Action against wrong information

• Rewards will be given on the bases of loss and case severity

• He will be awarded with reward if he secure the company from any financial loss

• Secure the market position

• Punishments would be as par loss amount that Nishat will face due to wrong doing

Carrots and sticks

When internal channel is

not taking action within

one week then

whistleblower is allowed

to report to external party

Reporting to External channel

Channel

Head of Nishat group

Head of NishatSave reputationMaintain secrecy

External channel

Non violation of company’s right

Any kind of law can’t prohibit and interfare in company’s law for taking action against

whistle blowing.

Board audit committee will be responsible to check the effectiveness and analytical criticism of whistleblowing programme

Monitoring and review of policy