Whistle Blower Policy

Policy in Reporting Violations

Bank AL Habib Limited requires all employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. They must practice honesty and integrity in fulfilling their responsibilities and comply with all applicable laws, regulations, policies, and instructions issued from time to time.

This Policy outlines a process to enable employees and outside parties to report their knowledge or suspicions about any unethical, illegal, fraudulent, improper, or unauthorized activity within the Bank. This process is intended to be used for serious and sensitive matters. It is not meant for employment-related grievances, which should continue to be routed through normal channels. It is also not meant for business-related complaints, which should continue to be routed to Customer Complaint Unit at Principal Office, Karachi.

Procedures/ Communication Channels for Lodgment of Complaints

Duty to Report

If an employee knows, believes, or suspects that any unethical, illegal, fraudulent, improper, or unauthorized activities (hereinafter called “Violations”), including any violations of the Bank’s Code of Conduct, are being carried out in any Sub-Branch, Branch, or Office of the Bank, it is their duty to report such violations or suspected violations in accordance with this Policy. Failure to report such violations will be viewed as a serious disciplinary offense.

Outside parties, such as shareholders, vendors, customers, etc., should also report, in accordance with this Policy, their concerns relating to any Violations noted by them during the course of their dealings with the Bank.

Where to Report

In line with the Bank’s commitment to open communication, the employees may share their concerns and suspicions with their immediate supervisor. However, if the employees is not comfortable speaking with the immediate supervisor, or is not satisfied with the supervisor’s response, or suspects the supervisor’s involvement in the Violation, he must report the matter immediately to FIU at Principal Office, Karachi.

Names, telephone numbers, and email addresses of relevant officers at FIU will be advised via Instruction Circulars issued from time to time. Employees may report verbally in person or by telephone, or in writing by email or letter.

Customers and other outside parties dealing with the Bank should report their concerns or Violations, as defined above, to the immediate supervisor of the Bank’s employee(s) with whom they have been dealing, or to the respective Zonal Office or the respective Divisional/ Departmental Head at the Principal Office of the Bank. However, if they are not satisfied with the response they receive, they should report the matter to FIU at Principal Office, Karachi.

What to Report
The report should contain sufficient information to permit adequate investigation. At a minimum, the following information should be included:
- Name and contact number of the reporting employee/party.
- Description of nature of the Violation, with sufficient detail to permit an investigation.
- Names of employees and other individuals involved or suspected to be involved in the Violation.

Complaint Handling Procedure

BAll reports received pursuant to this Policy will be promptly investigated by FIU and appropriate corrective action will be recommended by the Head of FIU to the Chief Executive, if warranted by the investigation. In addition, action taken may include a final meeting with the reporting employee/party for complete closure of the matter.

Confidentiality

Reports of Violations or suspected Violations will be kept confidential, consistent with the need to conduct an adequate investigation.

Identities of employees and outside parties reporting in good faith will also be kept confidential, and any disclosure thereof will be viewed as a serious disciplinary offense.

Protection of Reporting Employees/ Outside Parties

Employees and outside parties who, in good faith, report a Violation or suspected Violation will be fully protected against any harassment, retaliation, or adverse employment/business consequences. Moreover, any officer who retaliates against or victimizes such employees will be subject to disciplinary action.

Employees and outside parties whose reports result in early detection of a Violation or prevention of potential losses will receive a letter of thanks/appreciation from the Bank. Employees will also receive due recognition at the time of annual performance review.

Acting in Good Faith/Action against Deliberately False Reports

Employees and outside parties reporting a Violation must act in good faith, without any malicious intent towards any individual or the Bank, and should have reasonable grounds to believe or suspect that a Violation has occurred. However, the reporting employee/ party will not have to prove the Violation.

Deliberately false reports will attract disciplinary or legal action against the reporting employee/party.

Reporting Requirements

Fraud Investigation Unit (FIU) at Principal Office, Karachi, is responsible for investigating the “Whistle Blowing” reports submitted in terms of this Policy by staff members or outside parties. FIU is an independent unit, reporting directly to the Chief Executive. FIU will submit a quarterly summary of the reports received by it and action taken thereon to the Audit Committee of the Board. FIU will submit a quarterly summary of the reports received by it and action taken thereon to the Audit Committee of the Board.