WHISTLE BLOWING POLICY. Version 1

Transcription

1 WHISTLE BLOWING POLICY Version 1 Page 1 of 8

2 TABLE OF CONTENTS 1. Introduction Scope of the Policy 4 2. Purpose and Ownership of the document 4 3. Procedure for amending the document 4 4. Compliance with laws, regulations & professional standards 5 5. Definition & Objective 5 6. Whistle-blowing Policies 5 7. Whistle-Blower 6 8. Responsibility for the Implementation of this Policy 7 Appendix I 8 Page 2 of 8

3 Document review and approval Version History Version Control Version Date Issued Originator / Modified By Head of Internal Audit Reason for Issuance/ Revision Revision history Version Author Date Revision 2 This document has been reviewed by Version Reviewer Date reviewed Name Signature This document has been approved by Version Subject Matter Experts Date approved Name Signature Page 3 of 8

4 1. Introduction Scope of the Policy: The Code of Corporate Governance (the Code) issued by the State Bank of Pakistan (SBP), SBP circular issued from time to time, specifically Annexure 1 of SBP BPRD Circular No. 03 of 2014 dated 21 February 2014 relating to Fraud Risk Management and Reporting has highlighted that banks should formulate and implement whistle blowing program, duly approved by their respective Boards, in order to enable bank s staff and outside parties such as shareholders, vendors, customers etc., to report their concerns against irregularities, financial malpractices, frauds & forgeries, personnel harassment, improper conduct or wrong doing without any fear of reprisal or adverse consequences. In this regard, whistle blowing unit may be formed under supervision of Audit Committee of the Board for receiving, handling and monitoring allegations and concerns raised by the whistle blower. Whistle-blowing Policy of Sindh Bank Ltd. (the Bank) is committed to encouraging all employees, stakeholders, vendors or any member of the public to raise concerns about unethical or unacceptable practices and/ or misconduct related to the Bank, in a manner which ensures that they can discreetly raise matters of concern without fear of reprisal. The aim of this policy is to ensure that our employees are confident that they can raise any matters of genuine concern without fear of reprisals, in the knowledge that they will be taken seriously and that the matters will be investigated appropriately and regarded as confidential. This policy is an important mechanism for maintaining the Bank s accountability and transparency by enabling employees and other stakeholders of the Bank, a means to voice their concerns in a responsible and effective manner. 2 Purpose and Ownership of the document: This document remains the property of the Bank for the exclusive use of the management and employees of the Bank and its contents are strictly confidential and should not be copied or distributed to third parties. The Bank does not accept any responsibility or liability for any loss or damage suffered by any person arising out of the unauthorized use of, or reliance upon, this document 3 Procedure for amending the document: Head of Internal Audit & Inspection is authorized by the Board of Directors (the Board) to approve amendments to this document, as and when necessary, under intimation to the Board. However, the Board reserves the right to require particular types of changes to be referred to it for specific approval. This document was last amended on the date specified under document review and approval above. It will be reviewed once in three years. Page 4 of 8

5 4 Compliance with laws, regulations & professional standards: The Bank and its employees must ensure to fully comply with all the applicable laws, regulations and professional standards, no employee shall undertake any activity considered inappropriate to the business and reputation of the Bank. Should any provision of this document, or any other policy, procedure or guidance, if becomes contradictory with the statutes or any applicable national law, regulation or professional standard, the department identifying the conflict shall promptly notify the appropriate senior official or committee responsible for the establishment or implementation of the subject policy, procedure or guidance, in writing, of the details of the conflict. In the event of any such conflict, the department shall comply with applicable national law, regulation or professional standard, till the time this document is appropriately amended as required. 5 Definition & Objective: Whistle-blowing is a process of indicating and informing senior management of illegal or unethical acts of a supervisor, colleague or sub-ordinate, without being identified as the reporting person, i.e., reporting issues other than the existing reporting lines. This policy aims to set out the Bank s written, formal whistle blowing policy, consisting of responsible and effective policies for reporting of misconduct and impropriety so that appropriate remedial action can be taken if concerns are deemed legitimate. 6 Whistle-blowing Policies: Sindh Bank Ltd., acknowledges and encourages whistle blowing as alerting the Bank authorities that an employee/ individual or group of individuals/ employees have committed or are going to commit offences that are considered to be unethical and improper. By escalating these potential issues, the Bank will be made aware of these concerns and is alerted that its interests and the interests of stakeholders are being compromised, or at the risk of being harmed. This Policy is not designed to question legitimate financial or business decisions taken by the Bank, nor should it be used to reconsider any matters which have already been addressed under grievance, complaints and disputes policies This policy will be interpreted in conjunction with the Bank s Business ethics and Code of Conduct and it is important that all employees and stakeholders become familiar with both the Whistle Blowing Policy and the Bank s Business ethics and Code of Conduct before Page 5 of 8

6 proceeding with raising a compliant. The Board of Directors and the Board Audit Committee give the assurance that employees, stakeholders, or any member of the public can raise legitimate concerns, without fear of reprisals or provided they were made in good faith. The Bank wishes to assure the utmost discretion of whistle blowing, and therefore undertakes to treat all whistle blowing reports as either confidential or anonymous. Whistleblowers can raise their concerns to the designated authorities either orally or in writing. However, a genuine concern should be reported, i.e., there must be reasonable grounds for believing it to be a malpractice or misconduct. The malpractice or misconduct could be illegal or unlawful, financial, unethical, wasteful i.e., a conduct constituting a gross waste or misappropriation of resources. The whistleblower is also encouraged to report any facts that prejudice the integrity of the Bank such as breach of any regulatory obligations. All allegations made in good faith irrespective of whether they are subsequently proved to be false; the Bank will not take any action against the employee/ individual who raised the concern as part of the Whistle Blower policy and procedure. The Bank will not tolerate the harassment or victimization of anyone who raises a genuine concern. However, the Bank may treat false and malicious allegations very seriously. The Bank s Whistle-blowing Policy is aimed at: Encouraging timely reporting of alleged malpractices/misconduct. Providing a means for discreet and confidential channel for escalation of concerns without fear of reprisal. Ensuring consistent and timely institutional response to reported improprieties Ensuring appropriate oversight by the Board of Directors / Regulators Serving as a means of preventing and deterring misconduct that may be contemplated but has not yet taken place. Protecting the rights of the Bank and that of its shareholders 7. Whistle-Blower: Any employee/ individual, stakeholder, vendor or any member of the public, or group of individuals/ employees, who has observed reportable misconduct can report his/ her concerns to designated parties within the Bank. All staff should ensure that they take steps to disclose any wrongdoing or malpractice of which they become aware as non action/ concealment will be deemed as complicity. Page 6 of 8

7 8. Responsibility for the Implementation of this Policy? The day to day responsibility for overseeing and implementing the policy has been delegated to the Bank s Head of Internal Audit and his designated officials. The overall responsibility for monitoring and reviewing the operations of the policy and any recommendations for action resulting from investigations lies with the Bank s Board Audit Committee/ Independent Audit Committee (IAC). Any queries about the content or application of this policy should be made to the Head of Internal Audit. Page 7 of 8

8 APPENDIX I GLOSSARY OF TERMS AND DEFINITIONS The words and phrases in this document related to the Whistle blowing Policy will have the meaning ascribed to them as mentioned below: The Bank The Board IAC Chairman Code Designated Officials SBP/ SECP/ the Authority Personal Interest Sindh Bank Ltd. The Board of Directors of Sindh Bank Ltd. Independent Audit Committee/ Board Audit Committee Chairman of the Board Audit Committee The Code of Corporate Governance The Head of Internal Audit & or his designated officer(s) The State Bank of Pakistan, SECP or any other regulatory authority A person is considered to have a personal interest in a transaction with the company if: He himself, or A member of his family (i.e. spouse, father, mother, sons, daughters, brothers or sisters), or another company of which he is a director or controlling shareholder, is a party to the transaction or has a material financial interest in the transaction. Whistle blower One who alerts Sindh Bank Ltd., that a person, or group of persons is attempting to do, have done or doing something wrong, in terms of, Illegal or unlawful conduct, Financial misconduct, or Unethical misconduct or wasteful misconduct. Page 8 of 8