A complete policy of Whistleblowing for an org.

2. GROUP MEMBERS:
Ruqia Tabassum MC15051
Zunaira Maqsood MC15221
Tehmina Kousar MC15205
Memoona Maqsood MC15218
Maryam Fayyaz MC15236

3. WHISTLE-BLOWING PROCEDURE
OF
JERS ENGEENIRNG CONSULTANTS

4. “To see wrong and not to expose it,
is to become a silent partner to its
continuance.”
-Dr. Jhon Raymond

5. Whistle-blowing:
• Whistle-blowing procedure is a process of
disclosure by an employee of confidential
information which related to some danger ,
fraud or other illegal or unethical conduct
connected with the work place, be it of the
employer or of fellow employees.
[ by Lord Borrie QC 1995]

6. • To draw attention to unethical, inappropriate
conduct which has or may have detrimental
effects either for the institution or for those
affected by its functions
• It extends to situations where an individual
believes that an activity is harmful while
others involved are not aware of it or reject
the perception that is involved

7. BOARD STRUCTURE
CHAIN OF
COMMAND

8. WHISTLE BLOWING CHANNEL
Mr. M.Naseem Saigol Chairman
Mr. Imran Yasin Sheikh Chief Executive
Officer
Mr. Shahid Ahmed Siddiqi DirectorTechnical
Mr. Nazar Hussain General Director
Mr. Firough Merghub Director / CFO
Mr. Arshad Ali Legal Advisor
Non executive director (recommended )

9. WHAT SHOULD BE REPORTED
• Improper conduct or wrongdoing
Improper conduct or wrongdoing is defined as
– Any fraudulent activity /theft /corruption
– A substantial mismanagement of company
resources
– Any other violation of company’s code of conduct
– Misuse of company’ s funds
– A civil wrong or criminal act
– Improper conduct in company’s Operations;
Accounting; Internal Control; Auditing or Financial
Reporting

10. WHISTLE-BLOWER MAY REPORT
THROUGH :
Via internet : a link on the company
website
E-mail: whistleblower@jec.pk.com
[only accessible by whistle-blowing unit]
FAX: a dedicated fax number
managed by whistle-blowing unit
Telephone : a dedicated telephone
line with automated recording facility

11. WHISTLE-BLOWING PROCEDURE :
The employees can submit their whistle blowing
application to whistle blowing unit of HR
department and from their it is transfered to
whistle blowing committee.

12. RECOMMENDED PROCEDURE FOR
JERS:Investigation
• All the disclosures will be investigated by investigator
along with WIC(whistle blowing investigation
committee.
• In case investigation process leads to another
investigation which has not been reported by the
Whistleblower, the investigator may expand the
scope and timeline to take final decision. Investigator
based on his/her discretion may take decision based
on interim report in cases leading to more
investigation and take the final decision after final
report is submitted.
• If allegations are against any of the WIC member(s)
or in case of conflict of interest in a given case, the
member(s) should rescuse themselves and the others
on the committee would deal with the matter on
hand.

13. PROTECTION OF WHISTLE-BLOWER
The company is committed to the protection of
genuine whistle-blowers against action taken in
reprisal for the making of protected disclosures.
Confidentially of the whistle-blower’s identity,
the nature of the report, and the suspected
person’s identity to be strictly maintained.
Therefore , the whistle-blower should put his name
on the concern whenever possible so that the
designated investigation officer may consult him
for evidence.

14. DECISION :
If the investigation leads the WIC to conclude
that an improper or unethical act has been
committed, it will propose its recommendations
to Ombudsperson. The Ombudsperson then will
recommend the disciplinary or corrective action
to be taken in the matter investigated.

15. REPORTING :
• JERS Audit Committee will be kept informed
about all whistle blowing disclosures &
progress in terms of investigation and
outcome.
• Any investigation beyond 90 days of initial
whistle blowing disclosure will be separately
presented to JEC Audit Committee with
reasons.

16. REWARD FOR WHISTLE BLOWER:
• A genuine whistle blower will get two types of
reward one is spirtual reward in form of self
respect and honour that they will feel after
reporting a wrong doing
• 2nd reward is granted to them from company
in form of monetary incentives i.e. Bonus

17. ACTION AGAINST THE WRONG DOER:
• The company will take action against the
wrong doer according to the severity of thing
they did
• the punishments can include a warning,
suspension and in extreme case legal actions
and firing of employees.

18. WHISTLE-BLOWING REPORT FORM
:
• Because we do not undertake investigations
without adequate cause, we need as much
evidence as possible to confirm the
allegation(s) such as documents, witnesses,
and other specific and relevant information
• When describing the improper activity, please
provide as much of the following information
for each of your allegations and number each
allegation

19. Who? Who is involved?
What? What specifically did the suspect do?
What is wrong with it?
Where? Which division, unit, or campus
location
did the action happen?
When? When did the improper activity occur?
Why? What are the suspect(s) motives?
How? How did the wrongdoing occur?

20. Please enclose completed form in an envelope
marked “Confidential” and mail to:
Address :
Model town
A Block house no:323
Email:
abc@yahoo.com

21. SUSPECT INFORMATION :
Name Position
Unit address Work phone
Home address / home phone ( if non-employed )

22. COMPLAINT: Briefly describe the improper activity and
how you know about it. Specify what, who, when, where,
and how. If there is more than one allegation, number
each allegation, use as many pages as necessary.
 Who did the wrongdoing?
 When did this occur?
 Where did this happen (Unit,
location)?
 What enabled this to happen
(How)?

23. EVIDENCE :
• Please describe supporting documentation or
attach a copy of evidence that you have
already in your possession. You should NOT
ATTEMPT TO OBTAIN evidence for which you
do not have a right of access, as such,
whistleblowers are “reporting parties” not
investigators.

24. REPORTER’S CONTACT
INFORMATION :
Name Position Work location / address
Home address Home phone Work phone
Best time / place to reach you

25. EXTERNAL PROCEDURE :
Supervisory Authorities
National Labour Federation(NLF) Pakistan
Human Rights Commission of Pakistan (HRCP) etc.
External Lawyers
SECP (Regulator)

26. • How can a lay men access to a whistle-
blower form easily?
• Forms are available online but the
persons who have no internet facility,
they can contact on this number:
03333333333

27. Thank You