Whistle Blowing Policy

1. Objectives of the Whistle blowing Policy

Pak Telecom Mobile Limited (PTML) is committed to the highest possible standards of openness, probity and accountability. In line with that commitment, PTML expects employees and others that it deals with, who have concerns about any aspect of PTML’s work to come forward and voice those concerns also referred to as “Whistle Blows”.

The objective of this policy is to promote greater openness in the workplace and to encourage all individuals to disclose immediately any wrongdoings that may adversely impact PTML. In addition, this policy will enable PTML’s Audit Committees to discharge its responsibilities of establishing procedures for the receipt, retention, independent investigation and appropriate follow-up action on Whistle Blows received regarding accounting, internal controls, and auditing or other company matters.

An important aspect of accountability and transparency is a mechanism to enable all individuals to feel confident to voice concerns internally in a responsible and effective manner when they discover information, witness or suspect anything unethical and/or fraudulent which they believe shows malpractice or wrongdoing. Any person raising such concern shall be referred to as a “Whistleblower”. Any Whistleblower providing legitimate information in connection to an attempted, suspected, and/or actual violation is fully protected by the Policy as well as by the laws of Pakistan.

The PTML Whistle Blowing Policy is therefore fundamental to enhance professional integrity and to provide avenues for any individual to raise concerns in confidence and receive feedback on any action taken. It reinforces the value, PTML places on individuals to be honest and respected members of their community. It provides a method of properly addressing bona-fide concerns that, individuals might have, while also offering Whistleblowers protection from victimization, retaliation, harassment or, in certain circumstances, disciplinary proceedings.

The policy however prohibits employees and other stakeholders from making complaints with a malicious intent. Where there are deliberate false allegations, no matter how minor, disciplinary actions will be taken against the Whistle Blower.

Any existing Whistleblowing Policy that may exist in PTML at the Operating Companies level will run concurrently with this policy document without any contradictions. In case of a conflict between this policy and any relevant laws or regulations, including rules of professional conduct, the relevant laws and regulations will prevail. Where a Whistleblowing Policy does not exist, this policy should be adopted and endorsed.

2. Areas in which concerns can be raised

Specific examples of circumstances where a Whistleblower can raise concerns could include but shall not be limited to:

• Over-invoicing, demanding, seeking or acceptance of kick-backs, payment for goods or services not supplied or rendered and any act of fraud, bribery and corruption;
• Forgery of Company documents and financial instruments like cheques and securities;
• Theft or misappropriation of company’s funds and property;
• Corruption involving conflicts of interest and abuse of office;
• Disclosure of business secrets and other confidential company information obtained during the course of employment;
• Financial or Non-financial maladministration or malpractice or fraud that has been/is likely to be committed;
• Leakage/ unauthorized usage of confidential information;
• Compromising the interests of PTML  in dealings with vendors, contractors, consultants. suppliers, agents, distributors and resellers
• Misuse of PTML  Assets / Property;
• Misuse of authority;
• Unethical behavior;
• Misuse of systems or sharing of passwords;
• Non-compliance with internal and/or external laws, regulations, policies & procedures;
• Discrimination towards any staff member, customers or any stakeholders on the grounds of sex, race, nationality or religion;
• Engaging in illegal or unlawful acts;
• Compromising Safety Health & Environment (SHE) standards
• Suspicion of attempted and/or actual receiving/paying of bribes/kickbacks;
• Retaliation against whistleblowers; and
• Any other form of improper action or conduct.

Concerns received through the Whistleblower Program will be subject to preliminary assessment to
determine the appropriate course of action, including investigation, referral, closure, or other suitable
treatment based on the nature, merit, and credibility of the complaint. Matters outside the scope of the
Whistleblower Policy may be referred to the relevant function or handled under applicable policies and
procedures, including Compliance policies, HR Manual, Grievance Management Guidelines, and other
corporate procedures.

Received Personal employment grievances, routine operational matters, customer complaints, vendor disputes, and service-related issues will generally be addressed through normal management channels or relevant departments. However, allegations involving fraud, misconduct, corruption, ethical violations, abuse of authority, or conflict of interest may continue to be handled under the Whistleblower Program irrespective of the department involved. Similarly, customer complaints will also be handled by the relevant department.

3. Fundamental Elements of this policy

a) Confidentiality: PTML will make every effort to keep confidential the identity of the individual raising a concern (if so desired by the individual) unless PTML is required to reveal his/her identity by law.

b) Acting with integrity and in good faith: PTML will act with integrity and in good faith when reviewing or investigating a matter raised by a Whistleblower

c) Anonymous Whistleblowers: PTML encourages Whistle Blowers to disclose their identities when raising concerns. All Whistleblowers, especially anonymous Whistleblowers, should endeavor to provide sufficient corroboratory evidence to justify the commencement of an investigation.

 d) Substantiation of reported WB matter: Investigation may not be initiated where allegations are vague, unsupported, or lack sufficient information to enable a reasonable preliminary assessment. However, whistleblowers are encouraged to report concerns based on reasonable belief and provide any available supporting information or evidence, where possible, to facilitate appropriate review and investigation.

e) Whistleblower Protection: PTML recognizes that the decision to report a concern is not easy due to the fear of reprisals from those potentially affected. PTML has a zero tolerance towards retaliation against whistleblowers acting in good faith or persons cooperating during investigations. Whilst all steps will be taken to keep the identity of the individual raising a concern confidential, necessary protective action will be taken should he/she be identified.

A Whistleblower is subject to retaliation if they are threatened or subjected to negative consequences mainly due to making a whistleblowing report or participating in an investigation. PTML will not tolerate harassment, victimization, retaliation or undue disciplinary action and will take any action that is appropriate to protect a Whistleblower who makes a report in good faith under this policy even if it turns out not to be true after investigations, provided that:

• The report was made in good faith;
• The Whistle Blower had reasonably believed the information disclosed to be substantially true;
• The Whistle Blower did not make the report for personal gains.

Retaliation may take many forms, a whistleblower may be considered subject to retaliation if they are:

• Terminated or downgraded from their existing position;
• Denied a promotion or a fair performance evaluation;
• Subjected to ostracism or maltreatment;
• Hindered or delayed from completing an official transaction;
• Prevented from pursuing other suitable positions within the organization or externally.

If Whistle blower has reasonable grounds to believe that he / she has been threatened or subjected to retaliatory action due to making a whistleblowing report or participating in an investigation, he / she may raise these concerns as per this policy. His / her retaliation claim must be made as soon as possible and supported with appropriate facts and evidences reasonably showing that the retaliatory acts were mainly due to his / her whistleblowing disclosure or cooperation. His / her claim will be reviewed under this policy to determine if the reported unfair act was indicative of retaliatory action.

In the event that an employee is also a Whistleblower, protective actions may include formal notifications and follow-up by Human Resources (HR) to the relevant functions to protect the job environment of the Whistleblower and ensure no reprisals take place.

Similarly, protective action shall be provided to other Whistleblowers (e.g. vendors, contractors, suppliers, consultants, agents, distributors and resellers).

4. HOW TO RAISE CONCERNS

a) Individuals who witness or learn of a potential violation, as explained, can report this matter directly using any of the following channels:

• Email to ptmlwb@ufone.com or
• By speaking directly to the PTML confidential WB line on telephone number + 92 334 0000911; or
• Sending a letter to Chief Internal Auditor of PTCL Group, 14^th Floor, PTML Tower, F-7 Islamabad or
• By escalating the issue to a direct line manager and/or any other escalating/reporting mechanism the Whistleblower feels comfortable with. By way of example, the Whistleblower may feel more comfortable raising his/her concerns in accordance with the reporting line as set out in the Code of Conduct and/or the relevant Human Resources Manual, as applicable.
• Any other channels provided by the Company for the implementation of this policy.
• Where a concern relates to GCEO or any Senior Official of Internal Audit Department of PTCL Group, the Whistle Blower should send their concerns by a letter to Chairman of Audit Committee c/o the Company Secretary of PTCL Group marked “Confidential Complaint”.

b) In case the individual desirous of reporting any matter under this policy considers it inappropriate to report it to the local management due to the criticality or sensitivity of the matter involved, he may report such matter directly to the e& Group using following channels. However, unnecessary use of the Group channels for reporting minor disciplinary or personal issues shall not be encouraged.

• Email to groupwb@eand.com; or
• By speaking directly to the e& confidential WB line on telephone number +971 4 800 2002; or
• Sending a letter to Group Chief Internal Control & Audit Officer– e& and/or the Company Secretary – e&, P O Box 3838, Abu Dhabi, United Arab Emirates.