Integrity & accountability Employee

awareness
awareness sessions sessions
NOTE:
Regarding the session

We intend to model Integrity and Accountability to employees so that it creates trust

and establishes their own credibility. Employees must be held accountable for their
work, both as individuals and within teams. Our company advocates clear rewards
and punishments.

Though we understand that for our employees to understand their responsibilities,

need to be educated with accountability measures at first. Hence, all HODs including
RGM, RCTO and RDs are asked to conduct awareness sessions. Content provided in
this presentation could be used as a helping/supporting material to deliver the
session.

Such educational progress will create a culture of accountability.

 TABLE OF CONTENTS

Our value & code of Embedded Integrity &

1 conduct 3 Risk Prevention

Impact of Whistleblowing & its

2 fraud 4 importance
Our value &
code of conduct
OUR VALUE
Responsibility Makes Perfection
Our Key Behaviors
1. Teamwork
2. Drive Performance
3. Innovation
4. Customer Centricity
5. Integrity & Accountability
Integrity means following your moral or ethical beliefs and doing
the right thing in all circumstances, even if no one is watching you.
Having integrity means you are true to yourself and would
do nothing that demeans or dishonors you, your family, your
company, your country, your religion
 Responsibility allows us to create principles & morals and to act
accordingly, thus helping us to lead our own lives.
 Being a responsible person helps us to be more honest, more
independent and more reliable.
 By being responsible, we feel good, accomplished and gain
other's trust.
 Who Are We Responsible For ? Us, Company, Family, Country,
Religion
 Impacts of Compromised Integrity

Causing direct value creation, innovation and productivity gains in other industries
and further contribution to public finances via taxes and other levies.
CMPak’s
Value to society Building a more technologically and social inclusive society.

Contributing directly to education, economic activity, employment, gender

opportunities, and social and financial inclusion.

Establishing nationwide communication channel & connectivity.

Weak connectivity resulting in weak public service access for example: Ambulance,
Fire Brigade, etc..
Compromised Loss of Customer Trust and Loss of business for CMPak.
Integrity Weak economic activity and social connectedness due to loss of connectivity
impact:
Risks of litigation and heavy regulatory fines.
Investment Withdrawal.
Impacts of Compromised Integrity on Individual Level

 Loss of Managerial Trust causing increased control and micro-management.

 Negative Impact on employee growth.

 Employee morale damaged.

 Organizational reputation damaged.

 Revocation of Bonuses for significant period

 Loss of Jobs & lack of opportunities.

 Employee blacklisting Industrially

 Risk of Litigations and fines

 Family affected due troubles caused.

 Loss Of Credibility as a Nation as an Ummah

CMPak’s Code of Conduct- Putting Company Values into Practice

What Is It?
01
It provides firm, uncompromising standards and
guidelines for each employee in dealing with all
The CODE is
stakeholders. The code of conduct re-emphasizes and
provides further guidance regarding policies which are more than just
words on a page ,
an integral part of CMPak’s business philosophy

Why Is It Important
The Code of Conduct expresses CMPak’s commitment to
02 it’s a Way of Life
for the Zongers!
conducting business ethically. It explains what it means
to act with integrity and transparency in everything we
do and in accordance with our unique culture and values.

Who Does It Apply to?

03 Every employee should conform to and abide the applicable laws,
rules, regulations and orders of CMPak and shall observe, and
comply with all lawful orders and direction which may change from
time to time.

This Code of Conduct is also available on our Company portal at: https://zongersclub.zong.com.pk/
Areas covered under coc

Workplace Violence 1 5 Record Tampering

Use of Information &

Workplace Harassment 2 6 Technology

Misuse of Official Position 3 7 Drugs Abuse

Confidentiality and
Privacy Protection
4 8 Preventing Corruption
What Are An Employee’s Responsibilities
Follow the Code
As employees, it is important
that we know and follow the
Code as a guideline for decision-
making that is paired with
integrity. .
01
As members of the CMPak family, let us follow not only the letter of the Code, but its intent and
Lead By Example
No matter what our role is, each
one of us is expected to lead when
it is a question of ethics and be
accountable for our actions. We act
with responsibility and integrity in
tune with our Core values.
02
spirit as well.
Lead The Team
Encourage your team to raise issues and
speak up. Communicate a positive
message about your commitment to
ethics and compliance. Promote our
values, the Code of Conduct and
compliance with policies and the law
03
Compliance of “code of conduct”
01
Sign the Declaration
Every employee is required
to sign the Code of Conduct
Declaration at the time of
Joining and every time
when the policy is updated.
The declaration is available
at HCM
02 03 04
Make Disclosures Levels of Disclosure Intimate the Change
First Degree Relatives include Parents,
Make the Spouses, Fiancés/Fiancées and
It is the responsibility of
Disclosures in the Children.
Second degree Relative(s) include
every employee to inform
declaration
Brothers, Sisters, their Spouses, the management and HR
wherever necessary
Grandparents & Grandchildren about the change in the
Third degree Relative(s) include Uncles, status of declaration
Aunts, Nephews and Nieces.
Fourth degree Relative(s) include First
cousins and their Spouses..
Relative(s) In Law include parents in
law, siblings in law and children in law
Code of conduct- declaration
Confidentiality of the
Information- 08
One shall maintain integrity on Company’s
information and records and will not use/reveal
secret information to get personal benefit.
Company’s Best Interest- 07
One will ensure in future that all his/her decisions
and approvals are in best interests of the
Company.
Relationship Building- 06
One shall not promote any lobbying, grouping or
building unreasonable personal relations within
the Company.
Accountability - 05
On occasion of any information that I receive about
corruption, bribery, fraud, misrepresentation or
misconduct at any level of management, one will
immediately bring that information in attention of fraud
management and internal audit department for
investigation.
01 – Job Responsibility
One shall fulfill all the job responsibilities in good
01 faith, honestly and with self-discipline
08 02 02 – Use of Power & Position
One shall not use the power and influence of
his/her position to seek unreasonable benefits
Code of 0 from anyone or otherwise harm or cause to harm
business interests of the Company
07 Conduct 3 03 – Gifts & Favors
One shall not receive any gift or consideration of
any kind from anyone as an incentive or reward
06 04 for showing favor to any person in relation to any
affair concerning business of the Company
05
04 – Compliance with Company
Processes
One shall maintain strict compliance with related
policies and discipline to look after company benefit
in procurement and recruitment process and will not
unduly intervene in any procurement or recruitment
process including supplier/employee selection or
rate
situations of code of conduct compliance

No. Product plan and product launch information is

Serving as a consultant for another company that does
business with Polaris can create a conflict of interest.
Consequently, you must receive approval from CMPak
prior to agreeing to serve as a consultant. Raise the
issue with your supervisor, who will then take the issue
to the appropriate people for consideration.
A friend asked me if I could
confirm an internet blog which
claimed that CMPak is offering
certain features in it’s new
year's product plan Should I tell
him what I know? .
confidential and proprietary information of CMPak and
should not be discussed with anybody outside of CMPak
unless CMPak has already been made that information
public. If you have questions on whether an issue has been
made public, please contact your manager or the appropriate
Corporate Marketing Manager..

I have been asked to serve as a

consultant for one of our vendors
during off hours. Can I do this?
No. CMPak will only do business with people
who conduct business ethically and legally. All I was at a vendor yesterday and she told me that the
suppliers and vendors must comply with the vendor paid off a government official to avoid
standards in the Code and the law. Paying off customs and duties on the products they supply to us.
government officials is bribery and violates I know this saves CMPak money, but is it ok? .
the law. You should report this conduct
immediately.
Risks for non-compliance

CONFLICT OF INTEREST FINANCIAL LOSS

Non Compliance may arise a Non-Compliance can have severe
conflict of interest in case of financial impact on the business
intellectual property rights which will impat the employees.
preservance and confidentiality.

REPUTATION DAMAGE LEGAL

Non Compliance can seriously CONSEQUENCES
damage the company reputation Failure to comply woth the code
and it’s culture that will impact of conduct may lead to serious
the employee. and strenuous legal litigation.
Compliance violations

If you violate our Code, the Company will take appropriate disciplinary action.

Any disciplinary action depends on the nature, severity, and frequency of the violation. It may vary
depending upon local law. Please understand that those who violate the laws or regulations mentioned in
the Code could expose themselves and the Company to substantial civil damages and criminal penalties.
Corrective action may be taken if you:
• Violate the Code, Company policies and procedures, or applicable laws.
• Direct others to violate the Code, Company policies and procedures, or applicable laws.
• Are aware of a violation or potential violation, and fail to report it.
• Fail to effectively monitor the actions of people you manage.
• Do not cooperate in a Company audit or investigation.
• Fail to participate in required training.
• Retaliate against someone for reporting a concern in good faith or for participating in an
investigation of such a report.
• Disclose information learned during an internal investigation
Speak up

It is incumbent upon you to report the violations of the code of conduct.

Report your concerns to your manager, Human Resources and Internal Audit.
You may write at:

Use the helpline to report:

• Inaccuracy of financial records
• Accounting and auditing irregularities
• Bribery, corruption or illegal payments
• Criminal conduct and violations of law
• Discrimination and harassment
• Conflicts of interest.
Code of conduct

Do’s Don'ts
Corruption • To Report offers of bribe made directly or indirectly to
• Engaging in any corruption, extortion or embezzlement
& you.
• To Offer or Accept any bribes to gain undue advantage
Bribery • To Report any suspected corruptions.

• Devote oneself exclusively for service of zong and the • Doing part or full time work during duty hours for entities
Exclusive Services respective role during business/duty hours. other than CMPak.

• Disclose personal relations either working or doing • Deliberately conceal any personal relations that are either
Business business with the company in any capacity, directly or working or doing business with the company in any
Relationships indirectly. capacity.

• Keeping Company information only to the stakeholders • Sharing any sensitive company related information with
allowed as per the Job Description. others either intentionally or unintentionally, including that
Confidentiality • Protect electronic data just as carefully as you any of fellow employees.
paper document or verbal conversation • Sharing Salary details within and outside the organization.
Code of conduct

Do’s
• Avoid Conflicts of interest at all cost.
Conflicts of interest • Act in best interest of company.
with personal work • Disclosing any potential Conflict of Interests.
• Devoting time to CMPak only during duty hours.
• Reject gifts that may give appearance of conflict on •
interest.
Gifts & Hospitality • Supplier sponsored trainings/conferences accepted •
without CAD approval.
• Non-returnable Gifts are deposited with CAD.
Don'ts
• Not disclosing potential Conflicts of Interest.
• Compromising on company’s interests for personal
interests.
• Engaging in personal work during duty hours.
Gifts, particularly those involving transfer of money, are
accepted leading to conflicts of interest.
Supplier sponsored trainings/conferences accepted without
CAD approval.
• Non-returnable gifts are not disclosed to CAD.

• Behave towards others as we would like them to behave

• For information gathering purposes, illegal methods such
towards us.
Competitor Relations • Avoiding use of any illegal or deceptive or dishonest
as trespass or theft are used, or any deceptive or dishonest
methods are used.
methods while dealing with competitors.

• Diligently reports any corruption and fraudulent activity

• Not disclosing COC violations, corruption and fraudulent
to FM team.
Incident Reporting • Reports against employees involved in COC violations
activities to relevant departments, thus failing to nip the
evil in the bud.
that may cause harm to the interests of CMPak.
Impacts of
fraud
Types of Frauds & their Impact on the team

Common Fraud Types Immediate Impacts

 Strict Compliances get imposed.

 Theft/Misappropriation of Company’s Assets.
 Flexibilities in task execution get restricted.
 Bribery & Corruption
 Planned bonuses get denied.
 Inciting others to commit fraud.
 Focus on tasks get disrupted.
 Forgery.
 Business Partner’s trust gets damaged.
 Falsifying records.
 Quality of work gets adversely impacted.
 Theft of Service.
 Work environment becomes toxic & hostile.
Embedded Integrity & Risk
Prevention
Embedded Integrity

CMPak kick started this new program whose main purpose was for employees to have a risk based
Embedded Integrity & Anti- approach in assessing and carrying out their tasks.
Corruption Risk Program It emphasized the role of employees in highlighting integrity and corruptions risks and preventing
fraud, as employees are the owners and experts of their specific area.

• Work Honestly.
• Report results accurately.
• Avoid Conflicts of Interest.

Main Principles • Not allow gifts to influence our decisions.

Of the Program • Prohibit corruption.
• Commit to fair competition.
• Maintain truthful and accurate records.
• Protect the confidentiality of information.
Preventing fraud

Employee Management

For preventing fraud, management should:

As a general rule to prevent fraud, Employees should:
• Focus heavily on the Need Analysis of
• Avoid sharing passwords at all cost. Projects/investments.
• Protect company assets just like their personal assets. • Carry detailed reviews of work of the sub-ordinate
• Conduct Need Analysis to consider feasibility of staff.
Investments & projects. • Encourage a risk reporting culture
• Educating oneself regarding what, when and to whom • Consider rotations in critical areas.
should fraudulent activities be reported.
• Manage employee grievances properly.
• Assess every single activity and its impact on the
company e.g. Is it damaging in any way? • Refrain from demanding from employees to carry out
any unethical work, even when in good faith.
Whistleblowing & its importance
Importance of Whistleblowing

Whistleblowing is a voluntary disclosure by an employee, to the respective authority of management

relating to any activity that is deemed illegal, unethical, or wrongful within an organization.

Whistleblowing
Statistics
Based on global fraud case survey conducted by ACFE,
• Whistleblower Tips are the major reason for
detection of Fraud.
• More than 40% of organizational frauds are
detected from whistleblower tips.
• More than half of these tips had been reported by
the employees
Importance of Whistleblowing

“Whistleblower Protection and Investigation Policy” clearly lays out the following guidelines:

What to Report
How to report
 Criminal offences, including fraud, bribery and
corruption.
 Exercise reasonable care and judgment in establishing
 Assisting in concealment of Fraud. what facts should be reported.
 Non-compliance of Company’s policies and procedures.  Report only in Good Faith.
 Possible fraud, corruption and incorrect financial  Relevant department heads can be informed, but care
reporting with mendacious intensions. should be taken not to tip off anyone.
 Illegal use of confidential company data.  If there are doubts on integrity of relevant line manager,
 Failure to comply with legal obligations. report to FM should be made.

 Miscarriage of justice.
Rewarding whistleblowers

“Whistleblower Protection and Investigation Policy” also lays out a reward system for whistleblowers

Reward for Whistle-blower

The whistle-blower may be financially rewarded based on management decision if they:
• Voluntarily provides to fraud management/Internal audit department,
• Essential information/evidence,

about any fraudulent activity taking place in the organization and their information leads to a:
• successful discovery of fraud; and
• closure of the case.
ADD POINTS HERE

o Mention risks related to your domain

Risks o Give details of the risks

o Give historical examples and what learning has been achieved through these

o What areas have 0 tolerance by the management

o How employees can start identifying risks

o How these risks can be mitigated

Rectification o How we can ensure increased efficiency and effectiveness

Plan o How we can implement ethical standards and moral values, so that chances of fraud are minimized

Please note that you are not limited to only these points. You may add more slides
Engineering O&M
Assets Handling & Accountability

Field Teams are the key stake holders to ensure 100% compliance of Company policy while Assets
Handling.

 ATN “Asset Transfer Note” / BTN “Battery Transfer  Field Teams Vehicles fuel should be registered
Note” submission to ensure proper recorder timely on CMPak portal.
maintenance.

 Fuel Management: Timely reconciliation of DGs

fueling as per company policy.

 Company Vehicle should not be used for

personal use

 Spare Management: Timely reconciliation of issued

 Theft Management: Timely
spares/Tool Kits. All returnable items must be returned to
updates/investigations regarding theft
WH as per WH policy.
incidents
Quality Management/Acceptance

“Quality means doing it right when no one is looking”.

Henry Ford

Blank Page Check List CHECKLIST COMPLIANCE

Blank Page Marking
Signed
Signed Ensure 100% compliance of checklist
testing
DOCUMENTATION

“On Ground Equipment Verification done,
Proper documentation of
Tower Installed Equipment not verified”
identification snags, failed tests,
BOQ Signing off
Signing “Lock snags on Email, Use proper ACCURACY MEASUREMENT
terminology while noting down System level and site level
on paper” information correlation to ensure
accuracy.
OBJECTIVE ORIENTED
RMS Working,
RMS Working,
Do not relate one site acceptance On Site &
On Site &
System
with another site acceptance System
Readings
Readings
Different
“Site A will be accepted based on Same

work done on another site”

Overtime

Overtime claims should be aligned to the company policy and calculated based on actual activity
duration.

AMS Logs (Office Staff) Routine Work After 6:00

01 For Office staff AMS logs and overtime
05
Routine Jobs to be concluded
must be aligned within office hours

Car Logs (Field Staff) Short Leave Approvals

OVERTIME
OVERTIME

02 For field staff car logs should be used

06  Wrong Calculation, Routine
Staff should get approval from respective
to verify overtime line manager against all short leaves availed Activities after 6:00

Work From Home Work on Weekends DG CM

03 NO overtime can be claimed against
work from home as per HR Policy
Activity Standardization
04
Standardized activity duration to be
used for verification
Only important activities to be 07 Sr. No. Activity Hours(Minimum) Hours(Maximum)
performed on Saturday and Sunday with
prior approval of Line-manager 1 Alternator Bearing replacement 3 8
2 Alternator Coupling plate fault 4 10
Preventive Maintenance 3 Alternator Diode assembly fault 4 8
All kind of preventive maintenance 08
except core nodes must be scheduled
4 ATS fault 3 7
within office hours Activity Standardization
Miscellaneous

1. Prior intimation and

Gift, lunch/dinner bribery, any
entertainment from vendor/site
owner to be strictly avoided
approval required for own
1 5 car TAF else will not be
entertained

Data sharing is not allowed with 1. favor should be given /or

third party without management 2 6 asked for Site
approval deployment/Acquisition

SCAPs remarks SA/CW must be 1. Do not refer any Subcon to

verified and accurate 3 7 Vendors / CW contractors

Strict compliance of CMPak SOP 1. Do not Refer any of your

and policies are required at all 4 8 relatives/people to subcon
levels for jobs.
Thank You !