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Definitions

  • “Corruption” means abuse of official position for an improper private advantage or gain.
  • “Bribery” means inducing the holder of an official position to act in a corrupt manner, by providing such person or their close relative anything of value in order to obtain or retain business or to reward an improper decision or favour.

Explanation: “Anything of Value” extends beyond cash or cash equivalents to include non-cash items and favours as well.

Prohibition and Zero Tolerance

All employees of Bank AL Habib, whether temporary or confirmed, permanent or contractual, are instructed to carefully note and strictly comply with the following:

  • Values and Code of Conduct of the Bank are totally incompatible with bribery and corruption, which have no place at all at Bank AL Habib.
  • The Bank has Zero Tolerance for any activity involving bribery and corruption.
  • It is strictly prohibited for all employees of the Bank to engage in any activity involving bribery and corruption, in Pakistan or overseas. Employees working in overseas offices of the Bank should familiarize themselves with the applicable anti-bribery and corruption laws and regulations of the respective country, and meticulously comply with the same.

This policy should be circulated to all employees of the Bank. It should be brought to the notice of all new employees by Human Resource Division at the time of their joining the Bank.

Reporting of Violations:

It is the duty of all employees to ensure compliance with this policy. Any violation or suspected violation of the policy noted by an employee should be reported by them as laid down in the Bank’s Policy on Reporting of Violations (“Whistleblowing Policy”) and investigated promptly.

As the Bank has Zero Tolerance for violation of this policy, any employee who violates it will be subject to disciplinary action and may also face penalties under the applicable laws and regulations of the country.

Records of bribery and corruption related instances should be maintained at Fraud Investigation Unit (FIU) who should arrange to present these to the Audit Committee and the Board for information and review, on semi-annually basis.

Review and Amendments

The Anti-bribery and Corruption Policy will be approved by the Board of Directors and will be effective from the date of its approval. This policy will be reviewed on annual basis for any amendments.