CODE OF CONDUCT & DISCIPLINE POLICY

1. CODE OF CONDUCT

1.1 Applicability

These rules shall apply to all employees, of Wateen Telecom and its associated
Companies and sister concerns, whether permanent or contract or any other category,
within or outside Pakistan.

1.2. DECLARATION OF INTERESTS

1.2.1. For the purposes of application of this policy, All employees must declare in
writing to the management or competent authority any financial interest or
relationship that they may have, that may be perceived to have an actual or
potential impact upon the application of Wateen Telecom’s policies and
procedures. This will include:

1.2.1.1. The financial interest in a business or Company where the current

values of the interest is in excess of Rs.50,000. A financial interest due
to subsidized rates of Company products, under the approval of the
management, need not to be declared.

1.2.1.2. Other indirect financial interest in the business or company e.g. family
relationship to the senior member of staff of the company or close
relative employed by a supplier /vendor /contractor /sub-contractor.

1.2.1.3. A “family member” or “family relationship” means and includes

husband/wife, daughter/son, granddaughter/grandson, niece/nephew,
uncle/aunt or the same relationships of the spouse.

1.2.1.4. The financial interest of one spouse is deemed to be the financial

interest of the other.

1.2.2. In situations where the employee is unsure as to whether a financial interest

exists, they should in the first instance declare that interest to management or
the competent authority for that purpose.

1.2.3. Where an employee fails to declare his conflict of interest, strict disciplinary
action will be taken against the employee.

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1.3. TAKING PART IN POLITICS

Employees shall not be allowed to participate in the activities of any political party
during his or her duty hours. However, casting a vote is the right of every Pakistani
citizen.

1.4. ACCEPTANCE OF GIFTS

1.4.1. Employee shall not accept any inducement or reward for doing, promising or
refraining from doing anything in the course of their employment, or corruptly
showing favor or disfavor, in the handling of contracts. In acting corruptly the
employee would demonstrate their intention to purposefully act with a lack of
probity and with a disregard for the implications of their actions for the Company
and other employees.

1.4.2. Gifts offered by contractors or others as a gesture of goodwill or thanks for

example at Eid, New Year etc, that are in no way connected with the
performance of the individuals duties do not constitute an offence and should
ideally be politely but firmly refused. However items of low intrinsic value such as
diaries, calendars, or small tokens of gratitude from vendors, agencies, suppliers,
contractors or sub-contractors such as sweets do not necessarily have to be
refused, for example where to refuse would cause offence. In these
circumstances the employee may accept the gift but must notify their line
manager and Human Resources department to ensure the transparency in the
offer and acceptance of the gift.

1.4.3. In any situation where the employee is unsure as to whether to accept or decline
a particular gift they should firmly but politely decline in the first instance and
seek clarity from their line manager as to the appropriate course of action to
take in the specific circumstances.

1.5. CONFORMING TO APPLICABLE LAW, RULES & REGULATIONS

Employees shall conform to and abide by the applicable laws, rules, regulations and
orders issued by the competent authority, and shall observe, comply with and obey all
lawful orders and directions which may, from time to time, be given to him/her by any
officer or authority under whose jurisdiction, superintendence or control he may, for the
time being, be placed.

1.6. OBLIGATIONS

Employees shall serve the Company honestly, dutifully and faithfully, and shall maintain
strict secrecy regarding the affairs and business of the organization. Every employee

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 shall always report for duty punctually at the time notified by the Company, he/she
shall:

1.6.1. Be courteous and attentive in dealing with the Customers.

1.6.2. Be respectful, courteous and cooperative with his superiors, colleagues and
subordinates.

1.6.3. Always display Company Identity Card while on duty or in Company premises.

1.7. PROHIBITIONS

Employee shall not:

1.7.1. Leave the place of his duty during working hours except with the permission of
his immediate supervisor/line manager.

1.7.2. Leave the office, absent himself from duties, or leave the designated area of the
company without permission of competent authority.

1.7.3. Communicate to any person, organization or press or issue any other documents
related to the Company in any way without prior permission of competent
authority.

1.7.4. Approach or contact any outside authority, in connection with his/her own, or
other official matter without the consent of competent authority.

1.7.5. Remove or use any property of the Company for his personal work and where
any tools or instruments is entrusted to an employee for performance of his/her
official work it shall be deposited for the safe custody at the place specified for
this purpose when his/her work is over unless specific permission is given to
keep it.

1.7.6. Make note, or unauthorized printing or copying of Company document, process

or plan of the Company either for his/her own use or for the use of any
unauthorized person.

1.7.7. Causes or attempts to Cause any material loss or loss of revenue to the
Company. The employee shall be liable to reimburse the loss caused by him/her
and will also be liable to disciplinary action which may lead to the dismissal from
service.

1.7.8. Uses or attempts to use his official position in order to bestow patronage upon or
due favor to an employee or group of employees, vendors, suppliers, contractors
or subcontractors, agencies, competitors or other business organizations in a
manner where the interest of the Company or its employees is harmed and the

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 deserving employees or concerns are deprived of the due, shall be liable to
disciplinary action which may lead to the dismissal from service.

1.7.9. Participate in Radio and Television program, or contribute any article or write any
letter to any newspaper or periodical, except without prior permission of
competent authority.

1.7.10. Engage himself in any employment with competitor of Wateen Telecom, or

work/business during his or her duty hour.

1.7.11. Indulge in provincialism, parochialism, nepotism, victimization and willful abuse

of his /her office.

1.7.12. In any manner obstruct or disturb the operations of the organization peace in the
Company.

2. DISCIPLINE

Disciplinary action shall be taken when, in the opinion of the Management or Competent
Authority, an employee is found guilty of misconduct.

2.1 DEFINITION OF MISCONDUCT

Misconduct is defined in following two categories:

2.1.1 MINOR MISCONDUCT

2.1.1.1 Refusal to work on job or equipment assigned to employee.

2.1.1.2 Refusal to accept or reply to a charge sheet within prescribed time.

2.1.1.3 Habitual late coming.

2.1.1.4 Absence from duty without pre-approved leave.

2.1.1.5 Leaving the work premises without authorized leave/permission.

2.1.1.6 Entering/leaving or attempting to enter/leave work premises except

through authorized entrances and exits.

2.1.1.7 Assaulting or abusing or in any way insulting an employee of the

company inside or outside the premises of the organization; in respect
of official work / duty.

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 2.1.1.8 Smoking in prohibited areas.

2.1.1.9 Sleeping while on duty.

2.1.1.10 Negligence in performing assigned duty.

2.1.1.11 Tardiness, malingering, or slowing down on work, or neglecting to

perform it properly.

2.1.1.12 Holding personal meetings in the Company premises without the

written permission of the management.

2.1.1.13 Failure to meet performance objectives.

2.1.1.14 Unbecoming/rude behavior with external stakeholders, including but not

limited to customers, vendors, partners.

2.1.1.15 Breach of official Dress Code and/or Code of Conduct.

2.1.1.16 Behavior exhibiting involuntary discrimination while dealing with internal

or external stakeholders.

2.1.2 MAJOR MISCONDUCT

2.1.2.1 Any Minor Misconduct becomes a Major Misconduct if committed in

repetition.

2.1.2.2 Willful insubordination or disobedience (whether alone or in

combination with others) of any lawful and reasonable order, rule of
regulation.

2.1.2.3 Absence from work without authorized permission for more than ten
consecutive days.

2.1.2.4 Coming to work under the influence of alcohol or narcotics.

2.1.2.5 Fighting or indulging in a riotous, disorderly or indecent behavior or

using abusive language in the Corporation premises, or indulging in any
act which is subversive of discipline.

2.1.2.6 Distribution or exhibitions within the boundaries of the establishment of

any paper, notice, pamphlet or poster without the prior permission of
the management in writing.

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 2.1.2.7 Spreading false rumors or giving false information or making
defamatory statements (written or oral) which tend to bring the
management or its employees into disrepute.

2.1.2.8 Theft, fraud, or dishonesty in connection with the interest or property

of the Company.

2.1.2.9 Theft of another employee’s property inside the working area or

Company premises.

2.1.2.10 Taking or giving a bribe or any illegal gratification.

2.1.2.11 Acceptance of gifts from subordinates.

2.1.2.12 Gambling on Company property and Company premises.

2.1.2.13 Collecting any money or canvassing the collection of it for any purpose
in the Company premises and during the hours of work without written
permission of the management.

2.1.2.14 Conduct in private life which is prejudicial to the reputation of the

Company.

2.1.2.15 Carrying on a money lending or any other private business.

2.1.2.16 Conviction in any court of law for any criminal offence.

2.1.2.17 Causing willful damage to, or loss of, the Company’s goods or property.

2.1.2.18 Sabotage of or interference with, safety devices/equipment installed at

company premises.

2.1.2.19 Threatening or intimidating any employee inside or outside the

Company premises.

2.1.2.20 Unlawful/unauthorized interference in the work of other employees.

2.1.2.21 Breach of any of the rules applicable to the organization.

2.1.2.22 Preaching or inciting the people to violence.

2.1.2.23 Failure or refusal to wear an appropriate dress, under the “Dress Code”
policy, or use any uniform or protective equipment given by the
employer.

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 2.1.2.24 Keeping Weapon (Licensed/Un-Licensed) within working premises
without permission of Management.

2.1.2.25 Inability to respond to official communication.

2.1.2.26 Committing major mistakes on job that might result in loss of resources
for the organization.

2.1.2.27 Unwillingness to follow Health and Safety standards (as defined by the
organization)

2.1.2.28 Breach of any or all clauses of employment agreement.

2.1.2.29 Harassment / Voluntary discrimination.

2.1.2.30 Any action not defined hereby which indicates a compromised on

integrity by the employee.

2.2 DISCIPLINARY PROCESS

Any form of misconduct will be subject to a formal disciplinary process as defined below.

2.2.1 RESPONSIBILITIES OF LINE MANAGEMENT

 If a Line Manager finds any of his/her subordinates indulged in any Minor

Misconduct (as described in section 2.1.1 of this document), he/she will
counsel the employee for identifying cause of the misconduct and to take
initial corrective actions/guidelines. Line Manager can and should document
all such counseling sessions on an email written to the employee, highlighting
the areas where employee is required to take corrective measures. However,
such communication should not include any warning or call-to-action.

 If a Line Manager finds any of his/her subordinates indulged in repeated

Minor Misconduct or a Major Misconduct (as described in section 2.1.2 of
this document), he/she will immediately report it in form of an email to HR
department. All such emails should be sent as per following guidelines:

o The email should be addressed to Head of HR / Manager HR.

o The email should be copied to (in Cc) to VP – HR & Admin, concerned
Division Head, concerned Department Head.
o The email should contain evidence of the incident and
recommendations by Line Management.

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 2.2.2 RESPONSIBILITIES OF HR DEPARTMENT

The below mentioned responsibilities of HR Department in Disciplinary Process is

detailed in Appendix.

 Upon receiving the email from Line Management, HR will start initial inquiry
with issuance of Show Cause Notice to the concerned employee.

 Following possible outcomes may result depending on the nature of response

to the Show Cause Notice by employee.

o If the employee responds to Show Cause Notice, HR will decide the

action according to degree of the breach.
o In case if a response is not received from the employee, HR will have
the right to either further investigate the matter of take action while
considering it Ex-Parte.
o If the response by the employee demands further investigation, HR
will initiate an internal inquiry (while engaging all concerned
stakeholders).

 If the employee is proven guilty, HR will decide final action in accordance

with applicable laws and company policies.

 If the employee is proven not guilty, HR will clear the employee to report
back to work.

 Irrespective of the outcome of inquiry, complete documentation and inquiry

report will be filed in Personal File of the employee.

2.2.3 GUIDELINES FOR ESCALATION OF DISCIPLINARY CASES

Line Managers should observe the following guidelines when escalating a

disciplinary case to HR department.

 Line Management should not give any official warning or any call-for-action in
their professional or personal capacity. HR will proceed with issuance of any
official communication in response to the information shared by the line
management.
 All stakeholders should ensure confidentiality at all stages of the process.
 All stakeholders should act promptly in reporting a breach of conduct or
when required to respond to any aspect of the inquiry.

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  Line Management should maintain documented record of all relevant
communication (if any)
 All stakeholders should ensure transparency and objectivity at all stages of
the process.

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Process Flowchart for HR’s responsibility following Escalation of Disciplinary Cases:

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