Whistleblowing Policy

All employees must promptly notify the organization of inappropriate conduct so that it can be properly addressed. Employees who are aware of or suspect fraud, misappropriation of funds, theft, other misuse of organisation’s resources or assets, accounting irregularities, or other violation of these principles or organisation’s policy, should report their concerns immediately to their supervisor and HR Department either directly or through email. Serious violations may also be reported to the CEO. The whistle-blower is not responsible for investigating the activity or for determining fault or corrective measures; appropriate management officials are charged with these responsibilities. Examples of illegal or dishonest activities are violations of federal, state or local laws; billing for services not performed or for goods not delivered; and other fraudulent financial reporting. The employee must exercise sound judgment to avoid baseless allegations. An employee who intentionally files a false report of wrongdoing will be subject to disciplinary action which may lead up to termination.

Whistle-blower protections are provided in two important areas – confidentiality and against retaliation. Insofar as possible, the confidentiality of the whistle-blower will be maintained. However, identity may have to be disclosed to conduct a thorough investigation, to comply with the law and to provide accused individuals their legal rights of defence. The company will not retaliate against a whistle-blower. This includes, but is not limited to, protection from retaliation in the form of an adverse employment action such as termination, compensation decreases, or poor work assignments and threats of physical harm. Any whistle-blower who believes is being retaliated against must contact HR Department immediately. The right of a whistle-blower for protection against retaliation does not include immunity for any personal wrongdoing that is alleged and investigated.

All reports of illegal and dishonest activities will be promptly submitted to an Investigation Committee constituted for this purpose and will, if so required, be brought in to attention of the HR Committee of the Parwaaz Financial Services Limited Board.

Ethics & Business Practices At Parwaaz

Introduction to Ethics & Business Practices

Parwaaz’s Vision and Emphasis on Ethical Conduct
Parwaaz Financial Services Limited (PFSL) is committed to maintaining a diverse and socially responsible establishment that prioritizes integrity, respect, and equity. The organization emphasizes ethical conduct in all operations, guided by its vision to create a financially included and empowered Pakistan.

Guiding Principles and Decision-Making Questions

• Integrity: Employees must act with honesty and transparency in all dealings and communications.
• Objectivity: Avoid conflicts of interest and maintain impartiality in all professional decisions.
• Respect: Uphold dignity, fairness, and inclusivity in all interactions.
• Professional Behavior: Comply with all applicable regulations, internal policies, and maintain Parwaaz Financial Services Limited’s reputation.

General Principles of Ethics

Conflict of Interest and Its Implications
Employees are required to avoid financial, business, or personal relationships that might conflict with Parwaaz Financial Services Limited’s interests. Any potential conflicts must be disclosed to the Head of Department and Human Resources. Examples include:

• Holding financial interests in vendors or competitors.
• Accepting gifts exceeding PKR 5,000 in value (without prior approval), which might influence business decisions.
• Involvement in external business activities without management approval that could create competition or perceived favoritism.

Obligations and Ethical Responsibilities of Employees

• Treat colleagues and stakeholders with respect, fairness, and professionalism.
• Avoid bias or undue influence in any business decision-making process.
• Adhere strictly to organizational policies regarding ethical standards, ensuring no personal gain or misuse of position.

Corporate Ethical Policies

External Involvement, Publications, and Public Speeches
Employees must obtain prior approval before engaging in external activities, such as:

• Public speeches or publications that relate to Parwaaz Financial Services Limited’s business.
• Participation in external forums, media, or events representing Parwaaz Financial Services Limited in any capacity.
• Publishing or sharing any data or insights derived from company resources without explicit consent from authorized personnel.

Safe Working Environment, Discrimination, and Harassment
Parwaaz Financial Services Limited fosters a safe and inclusive work environment, with zero tolerance for:

• Sexual harassment or unwelcome conduct, defined under the Workplace Harassment Act 2010.
• Discrimination based on race, gender, religion, age, disability, or other protected characteristics.
• Any form of intimidation, hostility, or abusive behavior, ensuring mechanisms are in place for employees to report violations safely.

Use of Bank Resources and Property

Guidelines for Proper Usage and Personal Use Limitations
Employees must:

• Use Parwaaz Financial Services Limited assets (e.g., laptops, software, intellectual property) responsibly and solely for business purposes.
• Follow IT policies regarding proper usage, including mandatory antivirus installations, timely reporting of hardware issues, and adherence to password management protocols.
• Avoid unauthorized installation of software or hardware and limit personal use of company resources. For example, non-work-related web browsing during office hours is discouraged.

Gifts and Favors

Rules on Accepting and Giving Gifts, With Exceptions

• Gifts exceeding PKR 5,000 must be returned or explicitly approved by management.
• Improper gifts intended to influence decisions must not be accepted.
• Gifts that cannot be returned may be donated or used for employee recognition programs, with records maintained by HR for transparency.

Lending or Borrowing Money

Prohibited Financial Interactions and Obligations

• Employees are strictly prohibited from lending or borrowing money from colleagues or stakeholders to avoid conflicts or undue influence in professional relationships.
• For example, a manager borrowing money from a subordinate could create power dynamics that conflict with Parwaaz Financial Services Limited’s ethical standards.

Confidential Information

Protection, Usage, and Sharing of Sensitive Information
Employees must:

• Protect confidential information using encryption and access control measures, such as storing sensitive data on the Parwaaz Financial Services Limited shared drive with restricted access.
• Disclose information only on a “need-to-know” basis and with proper authorization, ensuring it complies with IT security protocols.
• Refrain from using sensitive data for personal gain or sharing it through insecure channels, such as personal email accounts.

 Information Security

User Responsibilities, Access Control, and Password Management

• Employees must maintain password confidentiality and adhere to access control policies.
• Passwords must be strong (at least eight characters with a mix of alphanumeric and special characters) and changed every three months as mandated in the IT Policy.
• Any suspected breaches of IT security must be reported immediately to IT support. For example, if an employee’s login credentials are compromised, they must notify IT to ensure system integrity.

Policies for Data Backup, Maintenance, and Troubleshooting

• Follow IT guidelines for regular data backups, such as scheduled backups on cloud storage for critical business information.
• Report any software or hardware failures promptly for immediate resolution to minimize downtime.

Acceptable Use of Assets

Rules for Desktops/Laptops, External Devices, Printers, and Scanners

• Only authorized devices and software approved by IT should be used. For instance, employees should not connect personal USB drives without prior virus scans.
• Employees must avoid installing unapproved programs or connecting unauthorized devices to Parwaaz Financial Services Limited systems.
• Use of IT equipment must comply with business purposes, and internet usage must avoid accessing non-business-related or inappropriate content.

Internet and Email Usage Policies

• Company email must be used solely for professional correspondence, ensuring it does not expose Parwaaz Financial Services Limited to liability or security risks.
• Avoid engaging in personal online activities during work hours and ensure compliance with IT security protocols. For instance, refrain from downloading attachments from unverified sources.

Social Media Guidelines

Responsibilities and Limitations for Online Behavior

• Employees must avoid sharing confidential or proprietary information on social media platforms.
• Refrain from posting content that may harm Parwaaz Financial Services Limited’s reputation or conflict with its values, including any posts about work grievances or internal policies.

Public Forums and Media Interaction

Rules for Communication with Media and in Public Settings

• Only authorized personnel may represent Parwaaz Financial Services Limited in media or public forums.
• Employees must adhere to internal communication guidelines to maintain consistent and accurate messaging. For example, only pre-approved press releases can be shared publicly.

Relationships with Customers, Vendors, and Counterparties

Due Diligence and Maintaining Ethical Interactions

• Business relationships must be conducted with fairness, transparency, and integrity.
• Avoid favoritism or any actions that might compromise ethical decision-making. For instance, all vendor contracts must be reviewed by the compliance team before approval.

Mis-declaration

Examples of Prohibited Misrepresentations

• Falsifying information on CVs, applications, or official records, such as overstating qualifications.
• Misrepresentation of qualifications, experience, or professional credentials, which can lead to disciplinary action.

Bribery, Fraud, Theft, and Illegal Activities

Definitions, Reporting Mechanisms, and Consequences

• Employees must not engage in bribery, fraud, theft, or any illegal activities. Examples include:
  • Forging documents or falsifying data to secure financial gains.
  • Misappropriation of Parwaaz Financial Services Limited resources, such as using company funds for personal expenses.
• Violations must be reported to HR or the Whistle Blowing Committee, with disciplinary action taken as per policy.

Drug, Alcohol, and Weapon Policies

Prohibition and Consequences Related to Possession and Usage

• Possession or use of drugs, alcohol, or weapons on Parwaaz Financial Services Limited premises is strictly prohibited.
• Violations may result in immediate termination and potential legal action. For instance, any employee found intoxicated during work hours will face disciplinary measures.

Political Activities

Restrictions on Employee Participation and Conduct

• Employees may engage in political activities privately but must ensure such actions do not conflict with Parwaaz Financial Services Limited’s policies or interests.
• For example, employees should avoid using Parwaaz Financial Services Limited resources to promote personal political affiliations.

Sexual Harassment Redressal

Policy Overview and Handling of Complaints

• Parwaaz Financial Services Limited’s Ethics Committee addresses complaints under the Protection Against Harassment of Women at the Workplace Act 2010.
• Complaints must be submitted in writing for investigation and prompt resolution, with confidentiality maintained throughout the process.

Anti-Money Laundering and Combating Terrorism Financing

Compliance with Regulations and Reporting Obligations

• Employees must comply with anti-money laundering laws and immediately report suspicious activities to relevant authorities.
• Parwaaz Financial Services Limited’s policies ensure compliance with all applicable regulations to combat financial crimes, including mandatory training sessions for employees.

Dignity and Respect in the Workplace

Maintaining a Respectful and Discrimination-Free Environment

• All employees are expected to treat others with dignity, fairness, and respect.
• Parwaaz Financial Services Limited is committed to creating a workplace free from intimidation, hostility, or discriminatory practices. Examples include enforcing equal opportunity policies during recruitment.

Related Party Transactions

Definition, Application, and Disclosure Requirements

• Employees must disclose any relationships that might influence business decisions.
• All related party transactions must be documented and approved by the CEO to ensure transparency. For instance, contracts involving family members must undergo additional scrutiny.

Compliance and Non-Compliance

Responsibilities, Accountability, and Consequences for Violations

• Employees are accountable for adhering to Parwaaz Financial Services Limited’s Code of Ethics and policies.
• Violations will result in appropriate disciplinary action, including termination if necessary. For example, repeated non-compliance with IT security protocols may lead to suspension.

Code of Ethics and Business Practices Acceptance

Employee Acknowledgment of the Code

• All employees must sign an acknowledgment of the Code of Ethics and Business Practices, affirming their commitment to adhere to the policies.

Mandatory Disclosures

1. Sequential Order

2. Profile of the Company

3. Governance

4. Investor Relations

5. Media

6. Information to be provided at homepage of website

7. Information of the Group companies registered with the Commission under Group Companies Registration Regulations, 2008

8. Measure for website security