​The term whistle blowing refers to an act of raising concerns about actual or potential violation of the code of conduct including misconduct, unethical behaviour, fraud/ forgery, bribery, corruption, money laundering, terrorist financing, insider trading, password sharing, alleged dishonesty, danger to health & safety, bullying, harassment including sexual harassment, discrimination, regulatory misreporting, questionable accounting, auditing and financial reporting practices, breach of law, unauthorized use, unethical / unfair practices or illegal activity occurring within an organization that may lead to financial, regulatory or reputational loss.

​A whistle blower raises a concern confidentially if he or she gives his or her name only on condition that it is not revealed without their consent. If the Bank is bound to disclose it under the law, then in that case consent from the whistle blower would not be required. An employee or any other whistle blower raises a concern anonymously if he or she does not give his or her name. Usually, the best way to raise a concern is to do so openly.

Whistle blowers are encouraged to put their names to allegations/ concerns raised in order to facilitate follow-up questions and investigation. Only those anonymous complaints where either material evidences, concrete facts, objective data and logical information are provided shall be considered for initiating initial inquiry / investigation. ​

​Bank endeavours to achieve a culture of openness and accountability along with maintaining highest ethical standards in all its practices. In line with that commitment, it encourages all its stakeholders, including employees (all permanent, temporary and/ or contractual staff, intern and ex-employees), customers, directors, suppliers, vendors, contractors, consultants, service providers, shareholders or any other representative of the bank to raise matters of serious concern through whistle blowing mechanism; rather than ignoring the problem or blowing the whistle outside.

​You can blow the whistle on actual or potential violation of the law and/or code of conduct including, but not limited to, misconduct, unethical behaviour, fraud/ forgery, bribery, corruption, money laundering, terrorist financing, insider trading, password sharing, alleged dishonesty, danger to health & safety, bullying, harassment including sexual harassment, discrimination, regulatory misreporting, questionable accounting, auditing and financial reporting practices, breach of law, unauthorized use, unethical / unfair practices or illegal activity occurring within an organization that may lead to internal financial, regulatory or reputational loss.

• Hot line - Whistle blowers may use a dedicated call number +92-21-111-333-425 with an option whether to record complaint directly or speak to designated Whistle Blow representative. The hotline would be functional for 24 hours and 7 days. If the informant wants to speak to Whistle Blow Unit representative as direct contact, this could only be facilitated during office hours: Monday to Thursday 9: 00a.m to 5: 30p.m and Friday 9: 00a.m to 6:00pm (Pakistan Standard Time) or office hours as may be prescribed from time to time. All complaints received at hotline will be automatically recorded. Both Chief Internal Audit and Chief Human Resource Officer will have the access to these recordings.
• Email - Whistle blowers may report matters to Ethics & Conduct through a dedicated email address whistle.blow@hbl.com
• Postal Mail - Whistle blowers may report such matters through Post-mail, addressed directly to the Chief Compliance Officer with copy to Chief Human Resource Officer and Chief Internal Auditor at following addresses:
• Chief Compliance Officer, 32nd floor, SKY Towers, East Zone, Block 4, Clifton, Karachi, Pakistan Chief Human Resource Officer, 31st floor, SKY Towers, East Zone, Block 4, Clifton, Karachi, Pakistan
• Chief Internal Auditor 13th floor, HBL Plaza, I. I. Chundrigar Road, Karachi, Pakistan

All such mails should be marked “confidential” on the outer envelope and “whistle blowing” on the inside envelope for maximum confidentiality.

• Website Form – Whistle blower may report such matters through whistle blow’s form available at HBL’s website. as mentioned in Annexure A. For International Operations - In addition to the above, the stakeholders of international locations may also report their concerns to relevant Country Manager or Regional General Manager (RGM), who would then be responsible to bring it to the knowledge of CCO & CHRO HOK in line with the above procedures.
• Employee may report their concern to his / her supervisor or one level above supervisor. The person with whom the information is shared would then be responsible to bring it to the knowledge of Ethics & Conduct.

Confidentiality will be maintained within the limitations of law and policy and the legitimate needs of the investigation.​

Yes. The whistle blow unit will decide whether the matters for which whistle is blown are classified improper, illegal, unethical or immoral practices.

​You should state the facts with as much specific information as possible so that your allegations can be investigated; such as brief the matter with clarity (with the name of person/department/branch involved), money amount involved (if any), time since matter existed, evidence if any (documentary or descriptive), brief remedial action that you suggest. ​

​After an initial assessment as to the appropriate treatment of each whistle blow matters detail assessment, investigation, or evaluation of the whistle blow matters would be conducted by the Consulting & investigation Unit, FRMU & HR-RM as the case may be. The investigation team will investigate the matter and will present its report / finding to the whistle blow unit. The Competent Authority will take the decision on the basis of the investigation report.

Sometimes stakeholders blow the whistle about things that aren’t illegal, immoral, unethical or improper, but are related to individual’s personal grievances related to performance appraisal, promotions, bank provided benefits, compensation, discipline & concerns related to job posting etc. are not dealt in whistle blowing policy and whistle blowing program and reported to Human Resources. The preliminary investigation assesses whether or not there appears to be an illegal, immoral, unethical or improper activity. ​

You can provide as much factual information as possible in order to allow the investigation to proceed. However, don’t obtain any evidence for which you do not have a right of access and don’t do your own investigation-leave that to the experts. ​

For routine complaints there is a designated customer resolution unit established by the bank. Account statements not received, customer grievances, incorrect record of particulars, transactions not processed are some of the examples of the routine complaints. All kind of these routine complaints shall be reported to the bank’s Customer Resolution Unit or Phone Banking instead of whistle blow unit.​

Only those HR concerns may be reported which have an entity wide implications or which are significant in nature. Further whistle can also be blown in case of inconsistent implementation of HR policies which comes to the knowledge of the employee. However, this does NOT include complaints of personal nature involving the employee himself / herself.​

To protect your confidentiality and the confidentiality of the investigation, it is advisable not to discuss the matter with friends and colleagues.​

You can contact Whistle Blow Unit – Ethics & Conduct in order to get help for blowing the said whistle.​

As covered in the whistle blowing program only those who are found to have acted maliciously will be subject to appropriate actions.​

​Yes, safeguarding whistle blower is the foremost responsibility. Management will ensure that stakeholders will not be at risk of suffering any form of retribution as a result of concerns raised/ potential fraudulent practices reported by him/her; no matter whether the same are being proven or not; provided that he/she is acting in good faith and in a reasonable manner. There is zero tolerance against harassment or victimization of anyone raising a whistle blowing. Any such act by the accused or other stakeholders, whether inside and outside of the bank’s premises will be treated as gross misconduct, which if proven, may result in disciplinary and/or other legal action(s) against the person involved.

Yes, you can. Kindly forward your request via the channels that you have raised the matter with the case reference number stating reasons for withdrawal.