Nishat is a large company operating in multiple sectors with over 20,000 employees. The purpose of Nishat's whistleblowing policy is to protect the interests of the company and public by providing a confidential channel to raise concerns about unlawful activity, violations of code of conduct, or incorrect financial reporting without fear of punishment. The policy outlines the channels to blow the whistle, including to the Managing Director, legal advisor, or non-executive director. It also provides protections for whistleblowers and a process for handling concerns raised through investigation and potential actions or rewards.

1. NISHAT

2. introduction

3. Organizational hierarchy

4. • 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

6. Human
resource
Import
export
Finance&
banking
Accounts
Market-
ing
Departments

7. No. of Employees 20510

8. Whistleblowing policy

9. Protection
of interest
companypublic
Purpose
of Nishat’s policy
The purpose of policy is to protect both interests

10. ‘‘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

11. • Confidentiality
• Anonymous allegation
• Bad faith allegations
• Harassment or victimization
safeguards

12. Managing director
Legal advisor
Non executive
director
Channels to blow whistle

13. Managing director /legal advisor/non
executive director
committee
General manager
Internal auditor
HR manager
Chief financial
officer
Access to channel

14. In step one whistle blower will blow a whistle to
recommended channel (managing director , legal
advisor , non executive director)
Step 1

15. 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

16. 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

17. 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

18. 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

19. Committee
General manager
Different expertise
Delegated authority
 Have deep knowledge about co’s affairs
Part of the board
Access (deptt,info)
Experienced
 Easy to access
Have power to take action
justification
Channel

20. 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

21. Report
using
whistle@nish
at.com
Fax no
Company’s
website
Telephone
line
Methods to report

22. • 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

23. 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

24. Positive Negative
If in good faith
then no step will
be taken
As par the severity
of loss
Action against wrong information

25. • 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

26. When internal channel is
not taking action within
one week then
whistleblower is allowed
to report to external party
Reporting to External channel

27. Channel
Head of Nishat group
Head of Nishat
Save reputation
Maintain
secrecy
External channel

28. 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.

29. Board audit committee will be
responsible to check the effectiveness
and analytical criticism of
whistleblowing programme
Monitoring and review of policy