HUB PAK SALT REFINERY HPSR-MR-COP 002

Issue 01

Anti Corruption and Bribery Policy

Policy Statement
It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-
tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with
integrity in all our relationships and business dealings wherever we operate and to implementing and
enforcing effective systems to counter bribery.

The purpose of this policy is to:

(a) set out our responsibilities, and of those working for us, in observing and upholding
our position on bribery and corruption; and

(b) provide information and guidance to those working for us on how to recognise and deal with
bribery and corruption issues.

Bribery and corruption are punishable for individuals, if we are found to have taken part in
corruption we could face an unlimited fine and face damage to our reputation. We therefore take our
legal responsibilities very seriously.
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To address these risks we will be taking the following steps:

(a) Implement an anti-bribery and corruption policy;

(b) Undertake a risk assessment exercise, which will be subject to ongoing review;

(c) Undertake a training programme of senior management;

(d) Take steps to implement a training programme for all individuals operating in areas of the
organisation that are perceived as high risk;

(e) Review and amend policies related to this Anti-corruption and Bribery Policy, including
the Public Interest Disclosure Policy;

Your Responsibilities
- You must ensure that you read, understand and comply with this policy.

- The prevention, detection and reporting of bribery and other forms of corruption are the
responsibility of all those working for us or under our control. All workers are required to avoid
any activity that might lead to, or suggest, a breach of this policy.

- You must notify your manager as soon as possible if you believe or suspect that a conflict with
this policy has occurred, or may occur in the future. For example, if a client or potential client
offers you something to gain a business advantage with us, or indicates to you that a gift or
payment is required to secure their business.

- Any employee who breaches this policy will face disciplinary action, which could result in
dismissal for gross misconduct.
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Monitoring And Review

- The Senior Manager will monitor the effectiveness and review the implementation of this
policy, considering its suitability, adequacy and effectiveness. Any improvements identified
will be made as soon as possible. Internal control systems and procedures will be subject to
quarterly audits to provide assurance that they are effective in countering bribery and
corruption.

- All workers are responsible for the success of this policy and should ensure they use it to
disclose any suspected danger or wrongdoing.

- Workers are invited to comment on this policy and suggest ways in which it might be
improved. Comments, suggestions and queries should be addressed to the Compliance
Manager. 15.4 This policy does not form part of any employee's contract of employment
and it may be amended at any time.
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LAWS ON PREVENTION OF CORRUPTION AND CORRUPT

PRACTICES

1. PPC, 1860, Corruption Section 161 to 165(b)

2. Criminal law (Amendment) Ordinance, 1994
3. Prevention of Corruption Act, 1947
4. Pak. Criminal Law (Amendment) Act, 1959
5. Public & Representative Offices (Disqualification) Act, 1949
6. Elective Bodies (Disqualification) Order, 1959
7. Holders of Representative Offices (Prevention of Misconduct) Act, 1976
8. Parliament & Provincial Assemblies (Disqualification for membership) Act, 1976
9. Holders of Representative Offices (Punishments for Misconduct) Order, 1977
10. Parliament & Provincial Assemblies (Disqualification for Membership) Order, 1977
11. National Accountability Ordinance, 1999
12. Punjab Anti Corruption Establishment Ordinance, 1961
13. Federal Investigation Agency Act, 1974
14. Establishment of the Office of Wafaqi Mohtasib (Ombudsman) Order, 1983
15. Federal Tax Ombudsman Ordinance, 2000
16. National Assembly Secretariat, 2003
17. The Punjab Office the Ombudsman act, 1997
18. Pakistan Criminal Law Amendment (Punjab) Rules, 1985
19. Anti-Corruption Establishment Ordinance, 1961
20. Sindh Enquiries Anti-Corruption Rules, 1993
21. PLD 1989 Federal Shariat Court 84 Zafar Awan Vs Pakistan
22. PLD 1992 Shariat Court 72 Federation of Pakistan Vs Zafar Awan Advocate
23. PLD 2005 Shariat Court 19 Federation of Pakistan Vs Zafar Awan, Advocate
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PAKISTAN PENAL CODE 1860

Section 161 to 165-A Pakistan Penal Code, 1860, Sec 5 of Prevention of Corruption Act, 1947 and Sec 9
of the National Accountability Ordinance, 1999 are the main tools in the hands of enforcement agencies
of anti-corruption laws. The Provincial Anticorruption Establishment uses the first two sets of laws while
the National Accountability Bureau uses the third set of laws.

Section 161 PPC: Public servant taking gratification other than legal remuneration in respect of an
official act

Section 162 PPC: Taking gratification, in order, by corrupt or illegal means, to influence public servant

Section 163 PPC: Taking gratification, for exercise of personal influence with public servant

Section 164 PPC: Punishment for abetment by public servant of offences defined in Section 162 or 163

Section 165 PPC Public servant obtaining valuable thing, without consideration from person concerned
in proceeding or business transacted by such public servant

Section 165-A. Punishment for abetment of offences defined in Sections 161 and 165

National Accountability Ordinance (No.XVIII) of 1999

The promulgation of National Accountability Ordinance was a step forward to make efforts to eliminate
corruption and corrupt practices, to provide effective measures to the society by setting up an
institution of National Accountability Bureau.

The National Accountability Ordinance repealed the Ehtesab Act 1997, and all the pending proceedings
would be transferred to the NAB, from the date of promulgation of the Ordinance.
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The prevention of Corruption Act was the first legislation in an effort to control/eradicate corruption
from the country. This Act is still in force but failed to achieve the objects. Then the Federal Government
of Pakistan in November 1999 promulgated the National Accountability Ordinance. The Act was made
applicable not only to public servants but its scope was extended to “holders of public office” and
“persons” involved in corporate business.

The provisions of the Code of Criminal Procedure, 1898. (Act V of 1898), shall mutatis mutandis, apply to
the proceedings under this Order. the provisions of Chapter XXIIA of the Code shall apply to trials under
this Ordinance. Although the Accountability Court may, for reasons to be recorded, dispense with any
provision of the Code and follow such procedure as it may deem fit in the circumstances of the case.

Previous Legislations

1. Prevention of Corruption Act, 1947

1. Public and Representative Offices Disqualification Act, 1949 (PRODA)

1. Elective Bodies (Disqualification Order, 1959 (EBDO)

1. Pakistan Criminal Law Amendment Act, 1958

1. Ehtesab Act, 1996 (Repealed)

1. National Accountability Bureau Ordinance, 1999

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CEO