CODE OF
CONDUCT
This Code of Conduct (CoC) serves only as an
Ethical Guide. If employees confront an ethically ambiguous situation, they
should remember the Company’s commitment to the highest ethical standards and
seek advice to ensure that all actions they take on behalf of the Company honor
this commitment.
Scope
This Code of Conduct applies to all Employees
of Central Power Purchasing Agency (Guarantee) Limited. The Company hereby requires
its entire Employees:
1) Employees
(Regular, Contractual and on Deputation)
2) Advisors
& Consultants
3) Management
Trainees
4) Daily
Wages Staff
The observance of high standards in the
conducting of its business activities. All employees must well understand and
meet the standards of professional and personal Ethics/Integrity expected of
them to protect and safeguard the reputation of the Company. Contravention of
“CoC” will be regarded as misconduct.
Purpose
The Company is proud of the values with which
it conducts business. It has and will continue to uphold the highest levels of
business ethics and personal integrity in all types of Business activities,
transactions and interactions.
The ‘CoC’ defines acceptable and unacceptable
behaviors and it shall be disseminated throughout the Company. This Code of
Business Conduct serves to:
(1) Emphasize the Company’s commitment to
ethics and compliance with the law;
(2) Set forth basic standards of ethical and legal behavior;
(3) Provide reporting mechanisms for known or suspected ethical or legal violations;
(4) Help prevent and detect wrongdoing.
This CoC serves only as an Ethical Guide. If
employees confront an ethically ambiguous situation, they should remember the
Company’s commitment to the highest ethical standards and seek advice following
the given hierarchy to ensure that all actions they take on behalf of the
Company honors this commitment.
Hierarchy: (This Hierarchy is collectively termed as Seek Guidance in this document)
If any point, employees feel uncomfortable
and/or not getting a positive response from the seek guidance hierarchy, they
may also report questionable behaviors by sending an email to HR at voice@cppa.gov.pk (confidentiality will be
ensured).
Ethical
Guidelines
A) General Ethics:
Employee should exhibit some General Ethics in the performance of their day to day duties.
B) Conflict
of Interest:
A conflict can arise when an employee takes
actions or has interests that may make it difficult to perform his or her work
for the Company objectively and effectively. Conflicts of interest may also
arise when an employee or members of his or her family, receives improper
personal benefits as a result of his or her position at the Company.
I. An employee has a prime responsibility to the company and is expected to avoid any activity that could interfere with that responsibility.
II. The company purchases equipment, material and services for various aspect of its operations.The employees are forbidden from holding any personal financial interest, directly or indirectly in any deal of supplying goods or services to the company.
III. Employees should not engage in any outside business or activity that might interfere with their duties and responsibilities to the company.
IV. Employee should declare any private interests relating to his/her official duties and take steps to resolve any conflicts in a way that protects the Company interest;
V. Employee should not place himself/herself under any financial or other obligations to any individual or organization which may influence him/her in the performance of his/her official duties;
VI. Employee should not misuse his/her position and not take decisions in order to derive financial or material benefits for himself/herself, his/hers family or his/her friends;
C) Protection and Proper Use of Company
Assets:
All employees should endeavor to protect the
company’s assets and ensure their efficient use. Theft, carelessness and waste
have a direct impact on the company’s profitability. Any suspected incident of
fraud or theft should be immediately reported for investigation.
I.
The company’s equipment should not be used for
non-company business.
II.
The obligation of employees to protect the
company’s assets includes its proprietary information which includes
intellectual property such as trade secrets, patents, trademarks, copyrights as
well as business marketing and service plans, designs, databases, records,
salary information and any unpublished financial data and reports.
III.
Funds and assets received or disbursed should be
fully and accurately reflected in the books and the records of the company. No
false or fictitious entries should be made or misleading reports pertaining to
the company or its operations should be issued.
IV.
No funds or assets of the company should be contributed
directly or indirectly to any political party or organization or to any
individual who either holds public office or is a candidate for public office.
V.
Unauthorized use or distribution of company’s
information/funds/assets would violate company policy. It could also be illegal
and result in civil or criminal penalties.
VI.
Employees should not tamper with or misuse any
item provided by the company to secure the safety, health and welfare of its
staff and for the protection of the environment.
D) Fair Dealing:
All Employees shall behave honestly and
ethically at all times and with all people. They shall act in good faith, with
due care, and shall engage only in fair and open competition, by treating the Employees
of Generation Companies, Distribution Companies and Company colleagues
ethically. Stealing proprietary information, possessing trade secret
information that was obtained without the owner’s consent, or inducing such
disclosures by past or present employees of other companies is prohibited.
I.
No employee should take unfair advantage of
anyone through manipulation, concealment, abuse of privileged information,
misrepresentation of material facts, or any other unfair practice.
II.
No gift or entertainment should ever be offered
or accepted by an employee or any family member of an employee unless it (a) is
consistent with customary business practices; (b) is not excessive in value,
(c) cannot be construed as a bribe or payoff and (d) does not violate any laws
or regulations.
III.
The offer or acceptance of cash gifts by any
employee is prohibited.
IV.
Employees should Seek Guidance for any gifts or
proposed gifts which they think may be inappropriate.
V.
Employees should neither give nor receive
payments that are intended to influence a business decision or to compromise
independent judgment nor should any Employee receive money for having given
Company business to an outside agency.
VI.
No employee shall seek, accept or permit
him/her to accept any gift or favor, the receipt of which will place him/her
under any form of official obligation to the donor. As part of building
relationship with Power Generation Companies, etc. Employees may receive
occasional gifts, provided that the gift is of nominal value (e.g. pens,
notepads, calendars, diaries, key chains or such promotional material) and the
gift is neither intended nor perceived by others to be intended to improperly
influence business decisions.
VII.
Employees should exercise good judgment so as
to act in a manner that will reflect favorably on the Company and the individual.
VIII.
Employees should take reasonable care to ensure
the health and safety of him/her and others who may be affected by his/her acts
or omissions at work.
IX.
All employees work towards achievement of
corporate objectives, individually and collectively as a team and conduct
themselves at work and in society as respectable employees and responsible
citizens.
X.
Employees will maintain an environment that is
free from harassment and in which everyone is equally respected. Workplace
harassment is defined as any action that creates an intimidating, hostile or
offensive work environment. Such actions include, but are not limited to,
sexual harassment, disparaging comments based on gender, race or religion.
XI.
Employee should be respectful and obedient to his
superiors, helpful and sympathetic to his subordinates.
XII.
Employees behavior generally should be gentle and his/her
conduct in Company particularly should be courteous and polite but at the same
time firm and dignified.
XIII.
While dealing with others Employee should always imagine
himself / herself in the position of the person he is dealing with him as
he/she would like himself / herself to be treated.
XIV.
Employee should avoid employing impolite language in
writing as well as in conversation and should also try not to annoy others.
XV.
Employee should maintain cordial and affectionate
relations with his colleagues and show due respect to his seniors
E) Confidentiality:
Employees must maintain the confidentiality of
the confidential information entrusted to them, except when disclosure is
authorized. Confidential information includes all non-public information that
might be harmful to the Company, Generation Companies or Distribution Companies.
It also includes information that Generation Companies and Distribution
Companies have entrusted to the company. The obligation to preserve
confidential information continues even after employment ends.
I.
In a personal capacity also, due care should be
taken by employees while discussing the company’s performance or plans with
outsiders. In case of doubt, Seek Guidance.
II.
Employees should not keep or make copies of
correspondence, documents, papers and records, without the consent of the
company and all such information should be surrendered to the company when the
individual leaves the company’s employment.
III.
Company information and records should be kept
on company premises only and unpublished information may be disclosed to external
organizations/individuals only on “need to know” basis. In case of doubt in
this regard, Seek Guidance
IV.
Maintain confidentiality in the
performance of his/her official duties as required by any laws for the time
being in force, particularly with regard to information, disclosure of which
may prejudicially affect the Company.
F) Compliance with Laws, Rules and
Regulations:
Obeying the law, both in letter and in spirit,
is the foundation on which the company’s ethical standards are built. In
conducting business, the employees shall comply with applicable governmental
laws, rules and regulations at all levels. Although not all employees are
expected to know the details of these laws, it is important to know enough
about the applicable local and national laws to determine when to Seek
Guidance.
I.
All employees and management personnel should
strictly adhere to the Company rules and regulations, observe the best codes of
conduct and abide by all laws of Pakistan.
II.
The use of alcohol in any form is prohibited on
all company locations/premises. Similarly the use of drugs except under medical
advice is prohibited on all company locations/premises. Any Employee arriving
at a work place under the influence of alcohol or drugs will not be permitted
to enter the premises and will be liable to disciplinary action.
III.
All forms of gambling/betting on the company’s
premises are forbidden.
IV.
Employee will refrain from doing
anything which is or may be contrary to any law, rules, regulations and
established practices;
Violations of Ethical Guidelines:
1.
Reporting
Known or Suspected Violations:
The Company’s directors, CEO, senior financial
and legal executives shall promptly report any known or suspected violations of
this Code to HR at voice@cppa.gov.pk. All other employees should Seek Guidance
(following the Hierarchy defined above in “PURPOSE”) about known or suspected
illegal or unethical behavior. The employees may also report questionable
behavior by sending an email to voice@cppa.gov.pk (confidentiality will be
ensured). No retaliatory action of any kind will be permitted against anyone
making such a report in good faith, and the Company will strictly enforce this
prohibition.
2.
Accountability
for Violations:
If the
management or its designee determines that this Code has been violated, either
directly, by failure to report a violation, or by withholding information
related to a violation, the offending employee may be disciplined for
noncompliance with penalties up to and including removal from office or
dismissal. Such penalties may include written warnings to the individual
involved that a violation has been determined, censure by the management,
demotion or re-assignment of the individual involved and suspension with or
without pay or benefits. Violations of this Code may also constitute violations
of law and may result in criminal penalties and civil liabilities for the
offending employee and the Company. All employees are expected to cooperate in
internal investigations of misconduct.
Compliance Procedures:
We must all work together to ensure prompt and
consistent action against violations of this code. In some situations, however,
it is difficult to know if a violation has occurred. Because we cannot anticipate
every situation that will arise, it is important that we have a way to approach
a new question or problem. These are the steps to keep in mind:
Ø Make sure you
have all the facts - In order to reach the right solutions, we must be as
informed as possible.
Ø Ask yourself -
What specifically am I being asked to do? Does it seem unethical or improper?
Use your judgment and common sense. If something seems unethical or improper,
it probably is.
Ø Clarify your
responsibility and role - In most situations, there is a shared responsibility.
Are your colleagues informed? It may help to get others involved and discuss
the problem
Ø Discuss the
problem with your manager - This is the basic guidance for all situations. In
many cases, your manager will be more knowledgeable about the questions and he
or she will appreciate being consulted as part of the decision-making process
Ø Seek help from
Company resources – In cases where it would be inappropriate or uncomfortable
to discuss an issue with your manager or where you believe your manger has
given you an inappropriate answer, raise your concerns to HR ( ). voice@cppa.gov.pk
Ø You may report
ethical violations in confidence without fear of retaliation – If your
situation requires that your identity be kept secret, your anonymity will be
protected to the maximum extent consistent with the Company’s legal
obligations. The Company in all circumstances prohibits retaliation of any kind
against those who report ethical violations in good faith.
Ø Ask first, act
later - If you are unsure of what to do in any situation, seek guidance before
you act.
© CPPA 2016. All rights reserved.
