Whistle Blowing Policy

OBJECTIVES OF THE WHISTLEBLOWING POLICY

Ubank (referred to as “the bank” afterwards) is committed to the highest possible standards of openness, probity and accountability. In line with that commitment, the bank expects employees and others that it deals with, who have serious concerns about any aspect of the bank’s work to come forward and voice those concerns.

The objective of this policy is to promote greater openness in the workplace and to encourage all individuals to disclose immediately any malpractice or wrongdoings that may adversely impact the bank. In addition, this policy will enable the Board Audit Committee (BAC) to discharge its responsibilities of establishing procedures for receipt, retention, independent investigation and appropriate follow up action on complaints received regarding accounting, internal controls, auditing or other matters.

An important aspect of accountability and transparency is providing a mechanism that allows individuals to raise concerns internally with confidence, responsibility, and effectiveness when they discover information which they believe shows malpractice or wrongdoing. Any person raising such concern shall be referred to as a Whistleblower.

The Whistleblowing Policy is therefore fundamental for enhancing professional integrity and to provide avenues for any individual for raising concerns in confidence. In addition, it reinforces the value which the bank places on stakeholders to be honest and respected members of their individual professions. It provides a method of properly addressing bona-fide concerns that, individuals within the bank might have, while also offering Whistleblowers protection from victimization, harassment or disciplinary proceedings.

The policy however discourages employees and other stakeholders from making complaints with a malicious intent. Other stakeholders, for this purpose, include vendors, customers and shareholders.

AREAS IN WHICH CONCERNS CAN BE RAISED

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

• Theft or misappropriation of the bank’s funds and property;
• Forgery of Bank’s documents and financial instruments like cheques and securities;
• Conflicts of interest and abuse of office;
• Unauthorized disclosures of business secrets and the bank’s other confidential information obtained during the course of employment;
• Usage of confidential information to obtain a personal reward or advantage;
• Compromising the interests of the bank in dealings with vendors or contractors, consultants or suppliers;
• Misuse of the bank’s property;
• Unethical behavior;
• Misuse of authority;
• Misuse of systems or sharing of passwords;
• Engaging in illegal or unlawful acts;
• Compromising the bank’s Safety Health & Environment (SHE) standards as provided in its policies;
• Financial or non-financial maladministration or malpractice or fraud that has been/is likely to be committed; and
• 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.

Vendors and customers can also blow the whistle for malpractices and wrongdoings that adversely affect the bank’s reputation.

Routine vendor grievances and disputes over delays in payments etc. will still be dealt with through normal management channels. Similarly, customer complaints regarding the bank’s services will also be handled by the relevant department. Such matters will not fall within the scope of Whistleblowing Policy of the bank.

Additionally, issues pertaining to staff grievances, discrimination, and harassment are addressed through the established channels outlined in the bank’s Staff Code of Conduct and do not fall within the scope of Whistleblowing Policy.

FUNDAMENTAL ELEMENTS OF THIS POLICY

• Confidentiality

The bank will make every effort to keep confidential the identity of the individual raising a concern if so desired by the individual. In which case, the identity of the individual raising the concern or making the report will not be revealed without his/her prior permission unless the bank is required to reveal the identity of the individual by law. Where there are deliberate false allegations, no matter how minor, disciplinary actions in case of employees and black listing and/or legal action for defamation may be taken against the Whistleblower.

Similarly, if the Whistleblowing results in material improvement in the process of banking operations along with a significant favorable financial impact, a reward may be offered based on a direct link with the level of contribution made by the Whistleblower upon discretion of the BAC.

• Whistleblowers and Evidentiary Support for Allegations

The bank encourages Whistleblowers to disclose their identities when raising concerns. Anonymous Whistleblowers should endeavor to provide sufficient corroboratory evidence to justify the commencement of an investigation. An investigation of unspecified wrongdoing or broad allegations may not be undertaken without verifiable evidentiary support.

It is important to note that no information about the outcome or action taken on the basis of information provided by the Whistleblower shall be provided to such Whistleblower.

• Support

The bank recognizes that the decision to report a concern is not easy due to the fear of reprisals from those potentially affected. The bank will not tolerate harassment, victimization or undue disciplinary actions and will take appropriate action 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 Whistleblower had reasonable grounds to believe that the report is true;
• The Whistleblower did not make the report for personal gains.

Whilst all steps will be taken to keep confidential the identity of the individual raising a concern, necessary support actions which may be required to be taken, may include formal notifications by Human Resources (HR) to the relevant functions to protect the job environment of the Whistleblower should he/she be identified. Follow-up action may be taken by the HR function where the Whistleblower is located (if such location is known) to ensure no reprisals will take place to the bona-fide Whistleblower.

Similarly, stakeholders other than employees will also be provided with the necessary support such as protection against any reprisals or discriminations subject to the fulfillment of above mentioned conditions for whistleblowing.

HOW TO RAISE CONCERNS

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

• Email to wb@ubank.com.pk; or
• By contacting 0333-1556150 WhatsApp # for sharing details of Complaint (during the bank Office working hours);
• Sending a letter to the Chief Internal Auditor of the bank at:

  To Chief Internal Auditor, U Microfinance Bank, PTCL Nest Office, Sector G-8/4, Islamabad.
  

• Where a concern relates to President / CEO or any Senior Official of Internal Audit Department of the bank, the Whistleblower should send their concerns by a letter to Chairperson of BAC c/o the Company Secretary of the bank marked “Confidential Complaint”.
• Where a concern relates to any of the members of the Board of Directors, the Whistleblower should send their concerns by a letter to the group whistleblowing unit or sending an email at wb@ptclgroup.com or groupwb@eand.com.