Subsidiaries

Urdu

Ufone
Ufone (Pak Telecom Mobile Ltd) a wholly-owned subsidiary of PTCL commenced its
operations on 29th January 2001. Since the outset, it has expanded its coverage and
customer base at a rapid pace and established itself as one of the leading cellular
service providers in Pakistan. Ufone is now considered to be one of the most active,
aggressive and innovative players in the mobile sector of Pakistan.
The growth of the cellular industry is a direct result of the successful implementation of
the telecom deregulation and cellular mobile policy by the Ministry of IT and
Telecommunications (MOIT&T) and the support, guidance and timely enforcement of
regulatory process by the Pakistan Telecommunication Authority (PTA).
Privatization
The growth of the cellular sector in Pakistan can also be attributable to good
governance policies of the government of Pakistan and the Privatization Commission. In
April 2006, Etisalat International Pakistan, which is commonly known as Etisalat, has
assumed management control of Pakistan Telecommunication Company Ltd (PTCL) –
part of the $2.6bn deal to buy a 26% stake in PTCL. The successful privatization of
PTCL is hailed as ushering in a new era for telecommunications in Pakistan.
Key Accomplishments
Ufone has always played a pivotal role in the development of the cellular market in
Pakistan. The company has been a step ahead in introducing innovative products to the
market. Ufone was a pioneer in launching the GPRS services and Multi-media
Messaging Service (MMS) in Pakistan, and lead the way in introducing Postpaid GPRS
international roaming and prepaid international roaming for these services in the
Pakistani market.
Performance
Customer focus and innovation at Ufone has helped take our subscriber base to over
twenty four million in less than a decade. The array of products and services that Ufone
brings has been implemented in a multitude of areas including voice, SMS, data, VAS
and lately in MFS and 3G. Ufone covers more than 10,000 locations across Pakistan
providing seamless connectivity to millions of individuals, households, businesses
and SME’s.
Since its inception Ufone has positioned itself as a brand of masses that believes in
innovation. Ufone has always been the trend setter in the industry and has launched
numerous “industry-first” products in all business segments. Over time, Ufone has
augmented its popularity amongst the mass and youth segment on the basis of trust,
affordability, convenience and availability.
Ufone launched Mobile Financial Services in 2013 in Partnership with Umicrofinance
Bank owned by PTCL. Currently Ufone has over 25,000 agents enabling millions of
non-banked consumers. This operation is expanding very rapidly and is currently placed
amongst top MFS players.
More recently Ufone has acquired 5MHz spectrum of 3G. Ufone is the fastest
expanding 3G network in Pakistan with over 700 3G enabled cell sites. Ufone is the
only operator which is offering speed based pricing structure to its customers which
enables them to choose from a variety of internet packages based on speed, volume
and time validity.
International Coverage
Ufone provides International Roaming facility with more than 310 live operators to
create ease of communication in more than 140 countries. Ufone not only has multiple
GPRS roaming agreements with international operators, but is also currently the proud
provider of Pakistan’s largest GPRS & Blackberry roaming coverage available with
more than 233 Live Operators across 126 countries, extended to both Postpay and
prepaid customers. Ufone network coverage is consistently available in over 10,000
locations including cities, rural areas and major highways for the vast-spread
connectivity it offers.
Customer Service
Excellent Customer Services and a strong Customer Focus is a common trait at Ufone.
Through 23 company-owned Sales & Customer Service Centers and 387 Franchise
Sales and Customer Service Centers across the country, Ufone is striving to offer its
customers with the best possible experience and is constantly working on ways to
improve it. The Company outlets across the country are equipped with latest technology
and empowered with highly skilled & motivated Customer Service Team ready to serve
the customers with the most innovative solutions. Maintaining long-term customer
relationships, it has the ability to attract and retain new customers sustaining high level
of satisfaction via optimum network services, accessible outlets and a 24 hour Call
Center facility.
Network Coverage
Ufone has always believed in a solid commitment to growth, security and reliability.
Therefore, Ufone has always balanced its expansion efforts and quality of service.
Ufone has network coverage in more than 10,000 locations (cities, towns, villages)
across the country. Since year 2001 Ufone has covered 77% population of the country
Ufone has been instrumental in the growth of the cellular market in Pakistan. It is a
company committed to excellence. Under the new vision of Etisalat and with the support
and collaboration of its employees and vendors, Ufone aspires to be the best in the
market by offering customer focused products and a quality service and sales
network. After all it’s all about U!
Ufone 3G
We are immensely pleased to announce Ufone has won the auction for 3G. We know
that the successes of today are never sufficient for tomorrow; that’s exactly why
technology and innovation go hand-in-hand at Ufone. By acquiring 3G and empowering
itself with mobile Internet that rivals the speed of light, Ufone is truly the network of
tomorrow.
This is just the first step in a telecommunication revolution that will soon engulf
Pakistan. Using the power of 3G, Ufone is going to add unprecedented levels of
innovation to thrill and excite you with super-fast mobile Internet that will usher U into
the future.

A 3G-enabled future where lightning-fast mobile Internet speeds are more than just
wishful thinking: Where all you really need is a phone to take care of email,
entertainment, social networking and so much more. Where Ufone is the new standard
for Internet and all that it stands for!
Ufone welcomes you to a digitally integrated future where U can finally utilize the power
of smart phones to their full extent. For more details, please visit: http://ufone.com/3G/
Ufone 3G Coverage
To check coverage in each city, please visit: http://ufone.com/3G/Coverage/
Ufone 3G tariff
Ufone was the first operator in Pakistan to commercially launch 3G services. For more
details about Ufone mobile internet bundles, please visit:
http://ufone.com/3G/Tariff/Prepaid/
U Microfinance Bank Limited (Formerly Rozgar Microfinance Bank Limited)
U Microfinance Bank Limited (Formerly known as Rozgar Microfinance bank Ltd.) was
incorporated as public limited company established in 2003 as a district wide
microfinance Bank (MFB) operating in Karachi district. PTCL finalized the arrangements
including regulatory compliances to acquire 100% ownership of Rozgar Microfinance
Bank Limited in August 2012. The acquisition was in line with PTCL Group’s initiative on
financial inclusion through branch banking and availing the benefits of opportunities
offered vide Digital-Commerce. The initiative includes offering banking services &
solutions as well as digital payments. The Bank has been acquired and its name was
changed to U Microfinance Bank Limited in December 2012 and SBP accorded its
approval for the name change along with Nationwide license in January 2013.
The decision to acquire Rozgar Microfinance Bank Limited was an initiative to
enhance financial inclusion through a combination of Branch and alternative delivery
channels. The Bank is engaged in provisioning of all permissible products and services
under Microfinance Institutions Ordinance 2001, which includes diverse range of lending
(Microfinancing), deposits, remittance products including IBFT & debit cards to its target
market through its branch and branchless agents network across the Pakistan.
Branchless banking brings a bouquet of financial services to consumers on the go. The
services include P2P (person to person) Money transfer, mobile wallets, cash-in cash-
out, bill payments, G2P (government to person) payments, merchant/retail payments,
loan disbursement, loan repayment, donation collection and more. Branchless banking
is used to substantially increase the financial services outreach to the mass unbanked
communities. It represents a significantly cheaper alternative to conventional branch-
based banking that allows financial institutions in arrangement with other commercial
sectors to offer financial services outside traditional bank premises by using delivery
channels i.e. retail agents through mobile and internet communication protocols etc.
For further detail please visit Bank website: www.ubank.com.pk
DVCOM Data Private Limited
DVCOM Data, a 100% owned subsidiary of PTCL, was acquired along with the 5 MHz
spectrum in 1900 MHz band licensed to it in nine telecom regions to provide Wireless
Local Loop (WLL) operations after fully complying with all the regulatory requirements.
Objective of the said acquisition is to supplement the EVDO wireless broadband
services of PTCL through synergies within the PTCL Group companies.
Towards this end, formal commercial arrangements are in place in between PTCL and
DVCOM Data.
Smart Sky Private Limited
Smart Sky, a 100% owned subsidiary of PTCL, was incorporated in October 2015 with
the objective to provide Direct-to-Home (DTH) television services throughout Pakistan
under the license from Pakistan Electronic Media Regulatory Authority (PEMRA). The
auction for DTH license was held in November 2016, in which Smart Sky also
participated. Subsequent to the auction, however, the Honorable Lahore High Court
declared the whole process of DTH auction as null and void and advised PEMRA to
restart the whole process. As the said auction is yet to be re-processed by the
regulators, Smart Sky has not started its commercial operations.

PTCL Brand Philosophy

As the leading Information and Communication Technology Service Provider in the
region we are the link that allows global communication. We are striving towards
mobilizing the world for the future. By becoming partners in innovation, we are ready to
shape a future that offers telecom services to bring the world closer.
PTCL Positioning Statement
Hello to the Future
“Hello to the Future” is an amalgam of our vision, brand philosophy, brand values
and strategy. The essence is “futuristic approach”. The positioning
statement “Hello to the Future” is basically comprised of two words “Hello” and
“Future” that provides the inward communication through the word “Hello”, i.e.
PTCL welcomes its customers and the future. Also it offers the outward
communication through the word “Future” by promising customers thefuturistic
ideas and products.
The first key word “Hello” captures the essence of the whole telephony network that is
the backbone of PTCL. “Hello” is a word which is related to the telecommunication
history and has been used ever since and will be used in future. This word expresses
the welcoming nature of the PTCL brand, its customer oriented approach
 and warm environment. Everyday most conversations and relationships start with the
word “Hello”, hence it portrays the relationship building of PTCL with its customers.
The second key word “Future” translates PTCL philosophy in a nutshell to
provide planned and proactive solutions and products to its customers. PTCL is
constantly evolving and taking its customers into the future. The word “Future” holds the
promise that PTCL is committed to, by providing complete customer
satisfaction through innovative and futuristic services and products. PTCL is breaking
the stereotypical perception launching into the Future embracing it as the mission to
transform the world of telecommunication and the way its customers communicate.
PTCL establishes itself as a futuristic entity which is working constantly towards
inventing paramount solutions for its customers.
The font style selected is bold, straight and modern. The font depicts the brand values
that PTCL fosters.
Brand Values
 ✔ Evolving
 ✔ Innovative
 ✔ Human
 ✔ Trustworthy
 ✔ Quality Conscious

Code of Conduct
01 - Introduction to Code of Conduct

We at PTCL are committed to acting in the company’s best interests. This involves
staying within permissible legal limits and taking all possible measures to prevent any
loss or damage to PTCL’s interests and reputation. Actions and behaviors of employees
constitute the organizational culture which determines its standing in the society and
ultimately becomes its corporate brand. This Code of Conduct has therefore been
designed to promote ethics, honesty and professionalism within the Company.
PTCL Management and staff will abide by the ‘Code of Conduct’ in carrying out their
duties so as to preserve public trust, ensure sustainable growth and development and
create value in the Company.

WHAT... Is Code of Conduct?

 Principles
 Standards
 Expected Behaviors
 WHO…. Is required to follow Code of Conduct?

Every employee of PTCL, including contractors or consultants who are our agents or
working on our behalf or in our name through outsourcing of services, processes or any
business activity, will be required to act consistently with the Code. Independent
Vendors may also be made aware of the Code.

WHY…. Do we need a Code of Conduct?

To describe behaviors expected of our employees

HOW … Can the Code of Conduct Help You?

This document provides practical advice about rules, regulations, expectations and
guidance about appropriate behaviors. The guiding principle would remain “acting in the
best interest of PTCL within ethical boundaries” in situations where no specific
guidelines are available.

02 - People and Safety

Organizations achieve their business goals and targets by effectively utilizing their
available assets. Human resource is one such prime asset which needs to be nurtured
and kept motivated and engaged to deliver at its best. Therefore, efforts must be made
to provide them an honest, open and enabling environment where they feel safe and
secure.

01 - Preventing Harassment & Violence

What it means?

A behavior that appears disturbing or threatening. For example, using inappropriate

language or keeping or posting inappropriate materials in work areas.
PTCL’s Standard

 PTCL is firmly against harassment by means of any action that creates an intimidating, hostile or
offensive environment.
 PTCL does not tolerate violence of any type in its premises.

Expected Behaviors

 We neither engage in harassment of any type, nor conduct ourselves in a way that could be
construed as such.
 We treat everyone including our team members, customers, business partners and other
stakeholders—with dignity & respect as they are entitled to a safe & respectful environment.
 We stay polite and respectful at all times even if we disagree with a team member or other persons
at work and do not possess or bring weapons of any type to our workplace. We resolve our
 differences in a calm manner without resorting to bullying, threatening, intimidating or harming
another person or their property through either verbal behavior (written or oral) or non-verbal
behavior (such as gestures or expressions).

02. Equal Opportunity & Diversity

What it means?

 Equal opportunity can be defined as giving a fair chance of success and growth to everyone
regardless of any personal or professional affiliations. A workplace with equal opportunities for all
creates the perfect recipe for an organization to achieve its objectives.
 Diversity is the difference of opinion / views arising as a result of gender, age, experience, expertise,
education, disability and socio-economic status.

PTCL’s Standard

PTCL is an equal opportunity employer and treats everyone with dignity & respect and
is firmly against discrimination of all forms including disparaging remarks based on
gender, age, experience, expertise, education, disability and socio-economic status.

Expected Behaviors

 We provide equal opportunity to all current and prospective employees in induction process,
promotions, talent development and rewards without any regard to race, gender, age or physical
ability.
 We respect all inherent differences and recognize that having diverse views / experiences in the
workplace facilitate in the development of PTCL.

Safe and Healthy Working Environment

What it means?

Everyone at PTCL is entitled to a safe, secure and healthy work place having the
requisite facilities and measures to handle / deal with emergency situations.

PTCL’s Standard

PTCL is committed to providing a safe, secure and healthy work environment, to

observing environmentally sound business practices and to take effective steps to
prevent workplace accidents and injuries.

Expected Behaviors

 We love to work in a clean environment and would work hard and co-operate in keeping our work
place healthy and free from pollutants. We also dump the wastage in proper designated areas and
avoid disrupting the work place by littering.
 We ensure compliance with environmental, health, and safety regulations and report any
environmental or health related issues to the management immediately.
 Our workplaces are Non-Smoking Zones and arrangements have been made to protect non-
smoking staff from secondary smoke. We do not smoke in corridors, rooms, canteen / cafeteria,
toilets or the recreation room and only use the designated areas for smoking.
 We comply with all the security policies and procedures to ensure that no unauthorized access is
granted and human lives, premises and assets are protected

Politics Free Workplace

What it means?

Engaging in politics or political activities that leads to biasedness, unwanted disturbance

and unrest. Political activities do not include CBA activities within the provisions of law.

PTCL’s Standard

PTCL acknowledges and respects the legal right of its employees to support and have
political affiliations in their own private capacity. However, PTCL is a strictly apolitical
organization and does not engage in political activities, support political parties or have
any political affiliations.

Expected Behaviors

We do not use and authorize usage of PTCL’s resources to support personal ventures
and political activities.
We do not become a part of political campaign and do not use influence for any political
party.
We do not contest in any election of National, provincial or local bodies.
We do not try to get any benefit in the Company by using political intervention.

03 - Safeguarding Information & Assets

Information is the key and vital ingredient in making informed and appropriate business
decisions. In today’s competitive corporate world, protection of an organization’s assets
such as those generating or preserving information has become more important than
ever. Organizations invest heavily in safeguarding their assets but no system can work
unless the people recognize and respect importance of an organization’s assets.

01. Protection of Assets

What it means?

Corporate assets can be financial, physical or intangible which include buildings,

equipment, funds, information, data, patents and other intellectual property etc.
 PTCL’s Standard

PTCL’s assets and interests shall be secured and safeguarded in the best interest of
PTCL’s business and in a manner that ensures protection of their value.

Expected Behaviors

 We protect PTCL assets against waste, loss, damage, misuse, theft, misappropriation or
infringement. We also respect physical and intangible assets of others.
 We use PTCL's assets only for business purposes (except where employment terms allow
otherwise) in an appropriate and responsible manner complying PTCL’s policies & guidelines.
 We comply with PTCL’s Information Technology (IT) security & related policies to ensure security of
IT assets.
 We do not sublet c Company provided accommodation.
 We acknowledge PTCL’s right to monitor the use of its resources, including its IT resources.
 We own PTCL and play y our role in its positive image building
 We take care of PTCL's resources as if these are our own

02. Confidentiality of Information & Record Keeping

What it means?

“Confidential information” is used to describe important or valuable business information

belonging to PTCL that is not generally available to the public. It includes internal
communications, employee records, various reports, business plans, suppliers & vendor
information, customers & other stakeholder’s information that has been disclosed to
PTCL under obligations of confidentiality.
“Record” contains information that is evidence of a business activity or required for
legal, tax, regulatory and accounting purposes or is important to PTCL business or
corporate memory. It may also include contracts, financial information, product
specifications, corporate policies & procedures etc.

PTCL’s Standard

PTCL will take every appropriate action to preserve confidential information and
records. PTCL complies with the applicable laws and regulations in respect of retention
of all records.

Expected Behaviors

 We are responsible and diligently active in protecting PTCL’s confidential information, inclusive of all
information related to our customers, business associates & other stakeholders.
 We take reasonable physical and electronic precautions to safeguard the information and store it in
secure location or on secure devices and limiting access.
 We do not share such information with outsiders including our friends and family & ensure that
confidential information of PTCL & its stakeholders is not left open in an unsecured area.
 We do not share confidential information until and unless we are required by a court of law or Law
Enforcement Agencies (LEAs).
 We take appropriate approvals and measures including signing a Non-Disclosure Agreement,
whenever there is a business requirement to share PTCL’s information (including giving access to
PTCL’s systems) with third parties.
 We dispose of confidential information and records securely—shred hard copy documents and use
secure and effective methods for deleting electronic information.
 Even if we leave PTCL, we are still legally and contractually obligated to maintain the confidentiality
of PTCL’s information.
 We understand that improper record management can lead to significant business risks that may
have negative financial, competitive, reputation, compliance and regulatory consequences and can
breach legal, accounting, tax and regulatory requirements.
 We maintain PTCL's confidentiality under all circumstances except where the disclosure is required
as per law.

03. Intellectual Property

What it means?

Intellectual property includes trademarks, logos, copyright works, inventions, patents,

trade secrets and information. These assets are integral to success of organizations
and brand values are built around them. Unauthorized use of PTCL’s intellectual
property can lead to reputational as well as financial loss / damages. Furthermore,
inappropriate use of intellectual property of other organizations may expose PTCL to
lawsuits, fines and penalties and can have a damaging effect on our reputation.

PTCL’s Standard

PTCL’s intellectual property will be protected from unauthorized use, sharing and
access by placing adequate safeguards. Similarly, PTCL respects the intellectual
property rights of others.

Expected Behaviors

 We protect and ensure authorized use of PTCL’s intellectual property internally as well as at the time
of lending these to external parties.
 We ensure that the intellectual property is used in the best interest of our business and product line.
 We understand the implications of using the intellectual property of others. We comply with all
usage policies and obligations in relation to product utilization as well as trade secrets disclosed by
other organizations.
 We obtain input from our legal team before accepting / entering into agreements with any other
business that involves accepting / using proprietary information or letting others have access of our
proprietary information.

04 - Communication & Reporting

Information no matter how carefully prepared and accurate will not add value unless it is
communicated in a proper manner and through proper channel

01. Business Communication

What it means?

This includes every kind of correspondence including mail, electronic documents,

instant messages, websites, social media tools, postings on Workplace, paper
documents, facsimile, voice and voice mail recordings.

PTCL’s Standard

PTCL stands committed and firmly practices providing clear, consistent and accurate
information in its business communications.

Expected Behaviors

 We do not mislead;
 We do not write speculative opinions;
 We do not exaggerate;
 We do not engage in ‘casual conversation’ on sensitive or confidential matters; and
 We do not joke about serious matters.

02. Public Disclosure

What it means?

Any written or oral communication made publicly on behalf of PTCL in any medium
(electronic, print, social) is a public disclosure. Information disclosed must be based on
explicit authorization by PTCL.

PTCL’s Standard

PTCL has strong focus towards ethical practices and believes in providing correct,
honest, consistent and timely information to its stakeholders.

Expected Behaviors
 We do not make public disclosures about PTCL’s business activities if we are not authorized.
 We protect confidential information. If we are authorized to disclose information, we ensure that it is
true, accurate, consistent and not misleading.
 We follow PTCL disclosure policies before making public disclosures.
 We do not engage in communication in any media (social, electronic, print etc.) that is damaging to
the public image of PTCL or contrary to the ideology of Pakistan or propagate / incite sectarian
creed.
 We do not engage with the media without clearance from PTCL’s corporate communication Team.
 We do not engage with investment community without clearance from CFO.
 We ensure that PTCL’s financial records fairly reflect transactions we are responsible for and
PTCL’s financial position

03. Insider Information & Securities Trading

What it means?

Insider information includes unpublished financial results, changes in top management,

new products or services, pricing, mergers & acquisitions, dividend announcement etc.,
not otherwise publicly available and may impact the share prices. Insider trading occurs
when someone has used or disclosed insider information for personal gain / benefit.

PTCL’s Standard

PTCL complies with all applicable laws and regulations relating to securities trading and
prohibit disclosure and use of insider information or insider trading.

Expected Behaviors

 We do not disclose or use insider information or indulge in insider trading.

 We make appropriate disclosure about our dealings in PTCL securities in accordance with the
applicable laws and PTCL’s policies.

05 - Conflict of Interest

“A conflict of interest is a situation or a combination thereof when a PTCL representative

has a personal or outside interest that conflicts with PTCL’s best interests. This
personal interest could be direct or indirect i.e. direct holding of a financial (investment)
interest or indirect holding through immediate family ”.
When faced with a potential conflict, you should ask yourself:

 Would this activity create a direct or indirect incentive (financial or otherwise) for me or for my close
family and personal relationships?
 Would others perceive this situation to apparently create an incentive for me or for my close family
and personal relationships?
 Would this situation create an incentive for an associated business at the expense of PTCL?
 Would this situation create a constructive or legal obligation on my part to give favor to entities or
organizations dealing with or against PTCL?
 If the answer to any of above is “yes,” the relationship or situation is likely to create a conflict of
interest, so you should avoid it. Some common areas (not an exhaustive list) where conflicts of
interest often arise are given below along with guidelines.

01. Financial Personal Interest

What it means?

 This means having a direct or indirect financial interest in an entity, business and organization
having dealings with PTCL which could potentially have an impact on PTCL’s best interests.
 This also includes accepting an external opportunity or starting own business.

PTCL’s Standard

 PTCL personnel will not hold (directly or indirectly) any financial interest (significant or otherwise) in
an organization having business with PTCL unless appropriately disclosed and the person so
involved does not take any business decision on behalf of PTCL.
 PTCL staff will not hold external appointments / positions or duties which may impact their ability to
work in the best interest of PTCL. However, the staff may engage themselves in charitable,
educational or professional activities or affiliate with such bodies after proper approval. PTCL does
not bar its personnel from taking part in sports activities or membership of recreational clubs.

Expected Behaviors

 We avoid direct investments or any business interest (financial interest) that could affect, or appear
to affect, our decision making on behalf of PTCL.
 We do not accept External appointments which may affect our ability to work in the best interest of
PTCL.
 We do not engage in financial transactions (purchase/sales of immovable property, lending or
borrowing money, letting etc.) with whom we have authority or influence in respect of PTCL’s official
dealings. This does not apply to arms-length lending & borrowing from financial institutions / DFI’s
whose primary business is lending & borrowing provided if some personnel deal with such banks /
DFIs then (s)he must make appropriate disclosure with EVP HRO.
 We make all such disclosures of lending and borrowing with HR upon appointments / transfers.

02. Relationship within / Outside PTCL

What it means?

This means being involved in a relationship at PTCL with a co-worker, friend or a

relative (or outside PTCL) that may have an impact on the employee working in the best
interests of PTCL.
 Relationships such as marriage between co-workers depending on work roles &
positions create conflict of interest.

PTCL’s Standard

 PTCL does not allow direct supervision of a family member.

 PTCL’s system of internal control, hiring practices, award of work (PO issuance) etc. involve fair and
equal opportunity to all applicants and is not subordinated to personal likes / dislikes.

Expected Behaviors

 We do not participate in potential/existing PTCL business relationship involving our family or

personal relations.
 We do not award work to a potential vendor based on our personal likes / dislikes.
 We do not indulge in unfair business dealings that may have a bias towards anyone.
 We do not take hiring / on boarding decisions based on our personal commitments or affiliation.

03. Gifts, Entertainment and Other Business Courtesies

What it means?

PTCL awards business to vendors delivering goods (core or non-core) to or performing

certain services for PTCL on basis of considerations such as quality, pricing, technical
abilities and ability to deliver in a timely manner. In the general course of business,
vendors send gifts to the staff / personnel having direct dealing with these persons. The
gifts may appear to be a gesture of goodwill and appreciation and may even be
customary business practice, but the staff and employees should take note of the fact
that such gifts may also be given with the intent to influence a current or future business
decision and accepting such gifts can therefore create conflicts of interest.

PTCL’s Standard

 PTCL believes in providing equal opportunities to all and thus we do not accept or offer lavish,
extravagant gifts including cash or its equivalents.
 Gifts of symbolic value, such as trophies, logos, pens, diaries and shields that are inscribed in
recognition of a business relationship, may be accepted.
 Gifts/discounts offered to a large group of employees or their families as part of agreement between
PTCL & a customer or supplier may be accepted and used as intended by the customer or supplier.

Expected Behaviors

 We do not accept gifts of more than modest value. Further, as a general rule if offered a gift,
sponsorship, meal or entertainment that exceeds the limit of PKR 5,000/-, the employees are
expected to politely decline and explain the Company’s rules.
 We do not accept/ask for meals, sponsorship or entertainment in exchange for an act or promise
something.
 If invited by a vendor to an event involving out-of-town / country travel or overnight stay etc., other
than the training covered under purchase contracts, we politely refuse the same. If such travel/
sponsorship / trainings have adequate business rationale, then we take special approval of CHRO
for such travels.
 In case an employee or staff receives a gift from partner / vendor without information the same may
be disclosed to HR department.

06. Fighting Corrupt Practices

PTCL stands committed to promoting a culture of honesty, integrity, fair and impartial
dealings with all its concerned stakeholders. We, as an organization, have zero
tolerance against all forms of corrupt practices and expect the same from all our
personnel.

01. Corrupt Conduct

What it means?

Corrupt Conduct is defined as when a person or group carries out his / their duties
dishonestly or unfairly, breaches customer trust, misuses PTCL’s information or
resources, or become involved in unwanted activities such as:

 Influencing or attempt to influence a decision by offering bribes

 Committing fraud by employing deception to gain / obtain some benefit (monetary or otherwise) at
the expense of PTCL’s assets / properties / resources or personnel
 Living beyond known means.

PTCL’s Standard

 PTCL has a zero-tolerance policy towards corrupt conduct and believes in ethical and fair dealings.
 PTCL stands firmly opposed to all forms of corruption and deceptive practices.

Expected Behaviors

 We do not give or accept bribes. Nor do we take part in, or facilitate, any forms of corruption.
 We ensure that our actions and day-to-day business activities do not risk creating the perception of
bribery or corruption.
 We also ensure that the transactions and activities we take part in are not, and cannot be perceived
as, an improper inducement for business.
 We disclose our personal wealth and their source as and when required by the Company.
 We make appropriate disclosure with HR of such situations where we are convicted for a crime in
any court of law.
 We do not influence or try to influence PTCL, through any external or internal means, to get any
favor for ourselves or family members.
 We act in an ethical way since it is the foundation of our business
 We demonstrate honesty, behave in a positive & consistent manner and keep commitments &
promises
 We seek guidance from the moral compass that ensures fairness and respect for all individuals

02. Money Laundering

What it means?

Money laundering is the acquisition, conversion, possession, use / transfer of property,

by concealment or disguise of nature / origin and participation in these acts, while
having knowledge or reason to believe that such property is acquired through illicit
means & includes holding it or possession on behalf of others.

PTCL’s Standard

PTCL believes in generating income and business through legal and fair means, we are
against violating laws and regulations of Pakistan and strongly oppose all forms of
money laundering.

Expected Behaviors

 We are against deriving income from illegal means and strongly oppose all types of money
laundering.
 We interact and deal only with those organizations who have ethical mindset and are involved in
legitimate activities.
 We take all appropriate steps to prevent and detect any illegal form of payments.

PTCL Whistle Blowing Policy:

Pakistan Telecommunication Company Limited (PTCL) is committed to the highest

possible standards of openness, probity and accountability. In line with that commitment
PTCL expects employees and others that it deals with, who have serious concerns
about any aspect of PTCL’s work to come forward and voice those concerns.

Specific examples of circumstances where a Whistle Blower can raise concerns could
include but shall not be limited to:

 - 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.
 - Forgery of company documents and financial instruments like cheques and securities.
 - Theft or misappropriation of company’s funds and property.
 - Conflicts of interest and abuse of office.
 - Disclosure of business secrets and other confidential company information obtained during the course of
employment.
 - Financial or Non-financial maladministration or malpractice or fraud that has been/is likely to be
committed.

 - Usage of confidential information to obtain a personal reward or advantage.

 - Compromising the interests of PTCL in dealings with vendors or contractors, consultants or suppliers.
 - Misuse of PTCL property.
 - Misuse of authority.
 - Unethical behaviour.
 - Misuse of systems or sharing of passwords.
 - Discrimination towards any staff member, customers or any stakeholders on the grounds of sex, race or
nationality.
 - Engaging in illegal or unlawful acts; and
 - Compromising PTCL’s Safety Health & Environment (SHE) standards.

PTCL 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 PTCL is required to reveal the identity of the individual by law.

An investigation of unspecified wrongdoing or broad allegations may not be undertaken

without verifiable evidentiary support.

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 Whistle Blower.

For further escalation you can also contact Etisalat Group at groupwb@etisalat.ae, +
971 800 2002, or send a letter to Group Chief Internal Control & Audit Officer – Etisalat
Group and/or the Corporate Secretary – Etisalat Group, P O Box 3838, Abu Dhabi,
United Arab Emirates.