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Code of Conduct & Ethics

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1.1 Objective

Saudi Pak strives to provide its employees an environment of support, trust and teamwork and believes in conducting business at all times with full compliance of the Company’s policies and applicable laws and regulations. The objective of defining a code of conduct for Saudi Pak’s employees is to ensure the well-being of both the Company and its employees by clearly outlining the expected standards of conduct/behavior to be exhibited by all employees. Saudi Pak shall take disciplinary action in accordance with the policies and procedures of the Company, regulations and applicable laws of the country where the conduct of any employee is detrimental to the institution or the wellbeing of other employees.

1.2 Applicability

This policy shall be applicable to all regular and contractual employees of the Company.

1.3 Responsibilities

The GM/CE shall set the tone at the top to create a control environment based on integrity/ethical principles by providing leadership and direction to senior management (line managers) and downstream on the subject.

The Divisional Heads (line managers) shall introduce and sensitize new employees on the Company rules, policies, systems, procedures and Company’s expectations of moral and ethical behavior. It is the responsibility of the Divisional Heads to provide guidance and ongoing awareness on the subject to the employees under their supervision/control to ensure adherence to code of conduct laid out in this section. HRD shall also conduct training/awareness sessions on need basis.

The code of conduct and ethics shall be placed on the Company’s intranet for information / observance of all employees. Every employee upon joining, is required to sign an acknowledgment as to having read and accepted this code of conduct. All employees are required to sign a declaration on compliance with this code of conduct every year using a form to be prescribed under the Human Resource Procedures Manual.

Regardless of the circumstances, if employees sense that a course of action they themselves or others have pursued, or are presently pursuing, or are contemplating pursuing may lead to violation of this Code of Conduct, they should immediately communicate all the facts to their supervisors/HRD. All situations involving potential violation of code of conduct must be escalated through proper channel.

1.4 Rules of conduct

1.4.1 Objectivity
The principle of objectivity imposes an obligation on all employees not to compromise their

actions or judgment (in the interest of the Company) because of bias, conflict of interest or the undue influence of others.

Examples of circumstances of conflict of interest or which may pose threat to objectivity:

  • ●  Employees having financial interest in, or family, personal, business or employment relationship with the clients (intermediaries and firms), competing organizations or vendors.
  • ●  Existence of a condition that an employee will be deterred from acting objectively because of actual or perceived pressures, including attempts to exercise undue influence over the employee.
  • ●  Employees directly/indirectly competing with the Company or supporting the competitors.

1.4.2 Integrity and professional behavior

Every employee shall serve Saudi Pak honestly and faithfully and shall use his/her utmost

endeavors to promote the interest of the Company. Every employee is required and expected to exhibit courtesy and attention to all its stakeholders.

Every employee shall conform to and abide by Saudi Pak’s prescribed policies and procedures; applicable regulations in letter and spirit, and shall observe, comply with and abide by all lawful orders, which may from time to time be given by any person under whose jurisdiction, superintendence or control he/she may for the time being be placed.

No employee shall compel or attempt to compel the management to accept any demand by using intimidation, coercion, pressure, threat, assault/ physical injury or such other methods.

1.4.3 Anti-bribery, anti-corruption, anti-money laundering, fraud prevention and prevention of terror financing

Employees of Saudi Pak shall not engage in any activity that may be categorized as bribery, corruption, money laundering, fraud or terrorism financing in general.

Bribery: Bribery is the act of giving or receiving something of value in exchange for some kind of influence or action in return, that the recipient would otherwise not alter.

Corruption: Corruption is dishonesty and illegal behaviour by people in positions of authority or power.

Money laundering: Money laundering is the process of concealing the origins of money obtained illegally by passing it through a complex sequence of banking transfers or commercial transactions.

Fraud: Fraud is deliberate deception to secure unfair or unlawful gain, or to deprive a victim of a legal right.

Terrorism financing: The financing of terrorism involves providing finance or financial support to terrorists or non-state actors.

1.4.4 Protection and proper use of Company’s assets and equipment
The employees shall use all assets belonging to Saudi Pak and its clients, including tangible and intangible assets, with due care and only for legal and authorized purposes.

1.4.5 Copyrights

Any copyright on work done by employees in the course of their official duties shall be vested in Saudi Pak unless otherwise agreed with the management of the Company.

Employees must not use the trademarks, logos, copyrighted, or other proprietary information of the Company, its clients or others in personal blogs, personal postings, or other social media without proper authorisation to do so.

1.4.6 Confidentiality/Protection of Official Information

Every employee shall maintain strict secrecy regarding the Company’s affairs and its constituents. No employee shall be involved in unauthorized disclosure of any confidential information (business/official or personal) or handing over confidential documents or copies thereof relating to the affairs of the Company or associated companies in any manner (including writing articles, teaching or making speeches). Also, employees must not leave confidential information unsecured. In addition, any information gained, by virtue of the employee’s position, may not be used for the purpose of furthering private interests.

When handling financial and personal information about customers or others with whom the Company has dealings, observe the following principles:

  • ●  Collect, use, and retain only the personal information necessary for the Company’s business.Whenever possible, obtain any relevant information directly from the person concerned. Useonly reputable and reliable sources to supplement this information.
  • ●  Retain information only for as long as necessary or as required by law. Protect the physicalsecurity of this information.
  • ●  Limit internal access to personal information to those with a legitimate business reason forseeking that information.
  • ●  Only use personal information for the purposes for which it was originally obtained.
  • ●  Obtain the consent of the person concerned before externally disclosing any personalinformation, unless legal process or contractual obligation provides otherwise.
  • ●  Confidentiality of the information obtained during the service must be maintained at alltimes.Employees are strictly prohibited from disclosing to the customer or any other quarter that a suspicious transaction or related information is being or has been reported to any authority, except if required by the law.All employees must sign a declaration of fidelity/ secrecy and must comply with the policies and procedures of the Company.

1.4.7 Internal and external communication

No employee shall make a representation to authorities higher than the immediate Supervisor, except through proper channel or as defined under relevant HR policy

No employee shall make any statement in electronic or print media/forum concerning the affairs of the Company unless duly authorized by the GM/CE.

No employee shall approach foreign embassies/missions/delegations for any purpose whatsoever without prior approval of the GM/CE or against the guidelines of SBP on the subject

Employees shall not withhold any information or work from a staff which he/she is normally entitled to have in normal performance of his/her duties or preventing an officer from performing his/her duties and functions.

1.4.8 Internet, email and social media usage

Use of the internet by employees is encouraged where such use is consistent with their work and with the goals and objectives of the Company in mind. Reasonable personal use is permissible.

Users are responsible for all actions relating to their email account/pc username and should therefore make every effort to ensure no other person has access to their account. Emails sent or received on the email system form part of the official records of the Company and they are not private property.

Employees are responsible for the content they publish on social media and should use good judgment.

Employees should contact their immediate supervisors or HRD to report a posting that may not comply with this policy. The Company may require employees to remove posts that violate this policy or applicable laws. Employees shall also adhere to the IT security policy & guidelines framed by the Company from time to time.

1.4.9 Outside employment / activities

Employees must avoid acquiring any business interest or participating in any other activities outside the Company that would, or would appear to:
● Create an excessive demand upon their time and attention, thus depriving the Company of their best efforts on the job.
● Create a conflict of interest – an obligation, interest, or distraction – that may interfere with the independent exercise of judgment in the Company’s best interest.

1.4.10 Prevention of discrimination and harassment

All employees should treat each other, clients and other stakeholders with respect, dignity, fairness and courtesy.

All employees should maintain a work environment that is free from all kinds of:

  • ●  discrimination including race, gender, age, caste, disability, ethnicity, religious beliefs;and
  • ●  harassment that violates an individual’s dignity, and/or creates an intimidating, hostile,degrading, humiliating or offensive environment. The harassment could be bullying (physical / psychological), sexual harassment or harassment based on race, gender, colour, religion, national origin, age, or disabilityFor detailed policy on protection against harassment please refer “Protection against harassment at workplace policy”

1.4.11 Political activity

No employee of the Company shall form any political group at the Company or contest in elections or canvass, promote, contribute, collect or lend money or items of any value to any of the political candidates or parties. This also includes using Company’s facilities, equipment, personnel etc. for the purpose. However, they shall be free to participate in political process as concerned individuals through means of voting.

1.4.12 Giving or accepting gifts Guidance

  1. Acceptance of advertising or promotional material of insignificant value, such as pens, pencils, note pads, key chains, calendars, diaries and similar items
  2. Acceptance of gifts of insignificant value (up to Rs.10,000) that are related to commonly recognized events or occasions, such as a promotion, wedding, retirement, birthday
  3. Acceptance of civic, charitable, educational, or religious organization awards for recognition of service and accomplishment.

Taking or giving of bribes of value in any form shall be treated as gross misconduct leading to immediate termination of service.

  • ●  Employees are prohibited from soliciting or accepting or giving anything of value from or to anyone (including government officials, subordinates, business associates etc.) in connection with the business of Saudi Pak.
  • ●  No employee shall accept or permit any member of his/her family to accept from any person any gift, the receipt of which will place him/her under any form of official obligation or undue influence of the donor.


1.4.13 Lending and / or borrowing

No employee shall lend any money to, or borrow money from, or place himself/herself under any pecuniary obligation to any person outside the Company with whom he/she has any official dealings. Saudi Pak shall owe no obligation in the event of default or any kind of recovery proceedings in respect of the money absconded by an employee.

1.4.14 Insider trading

Insider trading encompasses the practice of investment and participating and trading in transactions based on privileged information by Company employees, or allowing others to benefit from buying or selling stocks, securities, money market transactions, treasuries etc. No employee of the Company shall engage in such insider trading. The Company expects that employees will perform their duties conscientiously, honestly, and in accordance with the best interests of Saudi Pak. Employees must not use their positions or knowledge gained as a result of their positions for private or personal advantage.

1.4.15 Whistleblowing

Saudi Pak is committed to maintain an effective internal control environment while delivering services in an ethical, professional and legal manner.

For this purpose the Company has defined a whistleblowing policy which is focused on enhancing the overall operational transparency of Saudi Pak and underpinning its system for combating practice that might damage reputation.

The policy applies to all employees and extends to every individual associated with Saudi Pak including contractors, vendors and business partners etc. They are encouraged and have been enabled to participate without fear of reprisal or repercussions, to report to the relevant authority any improper activity as defined under the policy.

Whistle blowing policy has been added in Annexure B.

1.4.16 Other situations constituting misconduct

Apart from willful non-compliance with rules of conduct provided above, following conditions / situations may also be counted as potential misconduct:

  • ●  Conviction of a Criminal Offence
    A conviction and sentence for any criminal offence under the laws of Pakistan or of any otherstate.
  • ●  InsubordinationWillful failure to carry out any reasonable order by the employers’ representatives, including refusal to work on any job assigned by the immediate supervisor /Divisional head or refusal to accept any communication addressed to the employee by the Company
  • ●  Inattentiveness to dutiesMalingering, deliberate inattentiveness to duties such as idling, willful neglect of job assignments or slowdowns, or undertaking paid work for other organizations or personal gains during office hours.
  • ●  Disorderly ConductCausing any disturbance on Saudi Pak premises, such as might be caused by attempting bodily injury to another employee, engaging in horseplay, throwing things about, or otherwise interfering with the work of other employees.
  • ●  Unacceptable Conduct
    Profane, indecent or unreasonable, abusive, derisive or provocative conduct or language.
  • ●  Safety or Health Rules
    Misuse or disregard of safety devices or equipment, and refusing to conform to safety rulesor safety instructions given by the Company management, or any behavior of an unsafe manner, including failure to maintain a clean work area.
  • ●  Spoilage
    Willful or careless spoilage or waste of materials, tools or supplies or deliberate destructionof material, tools or supplies.
  • ●  Tardiness
    Habitual tardiness or failure to be at a place of work at the proper starting time. Habitualtardiness in returning to place of workstations from lunch or rest period.
  • ●  AbsenceRepeated, unexcused or unauthorized absence from work or absence without leave for more than 10 days. Abuse of the excused privilege, early absence from assigned work area at quitting times and early absence to leave place work for rest or lunch periods.
  • ●  Destruction of Property
    Damage to or defacement of Saudi Pak property, including facilities or equipment.
  • ●  Nepotism and victimization

No employee shall indulge in attitudes which involve a sense of provincialism, fascism, favoritism, sexual discrimination, and victimization in official matters.

  • ●  Liquor or Drugs
    No employee shall be coming to work or being present in the workplace under the influenceof alcohol or any narcotic drug, or any involvement in drug trafficking.
  • ●  Gambling
    No employee shall be involved in any form of unauthorized selling of tickets or Ponzi schemesuch as, but not limited to, lotteries or unauthorized collection on Saudi Pak property in connection with any form of gambling or lottery.
  • ●  Firearms or Explosives
    Bringing firearms explosives, inflammable devices, or other lethal weapons, or ingredients ofan explosive or incendiary device are strictly prohibited within Saudi Pak premises.
  • ●  Other
    Any individual act or pattern of acts, conduct or expressions which are detrimental to theideology of Pakistan; welfare of Saudi Pak, its employees or services and are not specified in this policy.

1.5 Consequences for breach of rules of conduct

Any breach or willful non-compliance with rules of conduct will be subject to disciplinary proceedings in accordance with policy on ‘Mechanism for handling breach of code of conduct’.