a. Applicability of this Policy
The Policy applies to everyone who carries out any duty for PLTL, including:
- All employees including CEO & MD
- Board of Directors members
- And extends to every individual associated with the PLTL including contractors, suppliers, business partners and the shareholders etc.
They are encouraged and have been enabled to participate without fear of reprisal or repercussions, in confidentiality without fear of retaliation.
b. Purpose and Objective
PLTL whistleblowing policy is intended to:
- Communicate existence of a mechanism for disclosing and reporting suspected wrong doings in complete confidentiality, without fear of retaliation.
- Encourage confidence in all employees and other associated individuals to disclose and report acts elaborated in sub-section (d).
- Provide avenues for confidentiality of concerns raised and allow feedback on corrective measures undertaken.
- Reassure a whistleblower for protection from possible reprisals or victimization.
c. Complaints covered in the Whistleblowing Policy
PLTL Whistleblowing Policy shall cover the following complaints:
- Conduct by anyone, which is an offence/breach of law.
- Failure to comply with legal obligations.
- Violation / non-compliance of company’s policies / procedures.
- Unauthorized use of PLTL assets.
- Health and safety risks, including risks to the public as well as other employees.
- Damage to the environment, PLTL assets and corporate image.
- Possible fraud /corruption / incorrect financial reporting with mala fide intensions.
- Illegal use of sensitive company data.
- Actions which are unprofessional, inappropriate or conflict with a general understanding of what is right or wrong / unethical.
- Miscarriage of Justice.
d. Complaints outside the scope of Whistleblowing Policy
PLTL Whistleblowing Policy does not cover personal grievances and career related issues like promotions, transfers, relocations, trainings etc. for which separate procedure exists. The policy shall not take into consideration anonymous concerns/complaints.
e. Whistle-blower Committee
The Whistle Blower Committee shall comprise of the following officials of PLTL:
- Head of HR;
- Head of respective division / department as co-opted member if not directly involved in the reported concern.
In case the whistle blow relates to any of the above the CEO & MD shall nominate an alternative person to be part of the committee
f. Whistleblowing/Reporting concerns and complaints
- Raising Whistle blowing Concern
All whistleblowing concerns are to be reported in writing on Whistle-blower Report Form (HRF-012-001 – Whistle-Blower Report Form). It must contain the background, the nature of concern; relevant dates and timings where possible, the reasons for the concern and the names of individuals against whom the concern is being reported.
Whistle-blowers may report their concerns through the following methods:
- E-mail – email@example.com, which shall only be accessible to the Whistle-blower Committee
- Regular Mail – Captioned ‘Attention: Senior Management, Whistleblowing at Pakistan LNG Terminals Limited of 5th Floor, Petroleum House, Ataturk Avenue, G-5/, Islamabad.
Where the whistleblowing report is against any member of the Whistle-blower committee itself, the same may be reported directly to the MD & CEO
- Handling Concern
Each whistle blower report received by the Whistle Blower Committee shall be assigned a code that will be used in the subsequent investigation and reporting of the concern.
Initial inquiries / assessments will be made by CFO in consultation with other members to determine whether an investigation is appropriate, and the form that it should take. Some trivial concerns may be resolved by agreed action without the need for investigation.
- Conducting Formal Investigation
An investigation shall only be conducted where available information is sufficiently specific and it contains adequate corroborating evidence to warrant an investigation.
Whistle-blower committee in consultation with respective head of department shall nominate a person either from within the department and/or from any other department to investigate the concern.
Person who is investigating any concern under this policy shall be empowered to seek information from the relevant persons and the concerned departments of the Company shall also cooperate with him.
The investigation will be preferably completed within thirty (30) days from the lodging of concern.
The Whistle-blower committee shall acknowledge receipt to the whistle blower within 07 days of receipt of the concern, with the indication that the matter will be dealt with as per Company policy.
- Formal Reporting and Monitoring
At the end of the investigation, a written report that provides the findings, basis of findings and a conclusion is to be submitted to the MD & CEO.
Whistle-blower committee shall recommend to MD & CEO for further investigation, if required. In case of split decision, the case will be referred to MD & CEO.
Whistle-blower committee shall mutually decide about disposal of the concern and disseminate messages across the Company for avoidance of such incidents in the future.
Whistle blower committee shall maintain a whistleblowing register to record the details of whistle blower reports received and outcome of investigation carried out.
CFO will produce a quarterly report documenting all concerns and the actions taken to resolve them for the review of MD & CEO.
Yearly Summary of the concerns raised and their disposal will be reflected in Annual Report of the Company.
Records of all whistle blowing concerns, investigations, and reports are to be retained for at least 5 years.
g. Whistle-blower Protection
It is understandable that the decision to report a concern can be difficult. However, if the report is true and well-intended, the whistle blower has nothing to fear because the report shall be in the line of duty towards the Company and/or for those to whom we provide our services.
No harassment or pressures towards the whistle blower shall be tolerated and PLTL shall take appropriate actions to protect all such individuals.
All concerns raised will be treated in confidence and wherever required, every effort will be made to maintain confidentiality of the whistle-blower’s identity. At the appropriate time, one may however, need to come forward as a witness.
The policy encourages all to believe that disclosure of concerns is in the Company’s interest. It however cautions all concerned not to act maliciously or make false allegations. Similarly, one must not seek any personal gain through this Policy.
i. False Allegations
Deliberately making a false concern is also an allegation under this Policy and may lead to a disciplinary action against complainant.
j. Disclosure to external bodies
Whistle-blower committee is not allowed to disclose internal concerns to any of the external bodies unless the concern raised involves legal provisions or disclosure is required by law.