Session - Integrity Accountability (2) (Recovered)

 

Integrity & accountability awareness sessions

Employee awareness sessions

 

NOTE: Regarding the session We intend to model Int Integri egrity ty and Acc Accoun ountab tabilit ilityy to employees so that it creates trust and establishes their own credibility. Employees must be held accountable for their work, both as individuals and within teams. Our company advocates clear rewards and punishments. Though we understand that for our employees to understand their responsibilities, need to be educated with accountability measures at first. Hence, al alll HO HODs Ds including RGM, RCTO and RDs are asked to conduct awareness sessions.  sessions.   Content provided in this presentation could be used as a helping/supporting material to deliver the session. Such educational progress will create a cul cultur turee of acc accoun ountab tabilit ilityy.

 

TABLE OF CONTENTS

1

2

Our value & code of conduct

Impact of  fraud

3

Embedded Integrity & Risk Prevention

4

Whistleblowing & its importance

 

Our value &

 

code of conduct OUR VALUE

Responsibility Makes Perfection Our Key Behaviors

Integrity means following your moral or ethical beliefs beliefs and  and doing the right thing in all circumstances, even if no one is watching you. you. Having integrity means you are true to yourself and would do nothing that demeans or dishonors you, your family f amily,, your company, your country, your religion

1.   Teamwork 2.   Drive Performance 3.   Innovation 4.   Customer Centricity 5.   Integrity & Accountability

  Responsibility

allows us to create principles & morals and to act accordingly, thus accordingly,  thus helping us to lead our own lives.

  Being

a responsible person helps us to be more honest, more independent and more reliable reliable..

  By

being responsible, responsible, we  we feel good, accomplished and gain other's trust. trust.

  Who

Are We Responsible For ? Us, Company, Fami Family ly,, Country, Co untry, Religion

 

Impacts of Compromised Integrity

CMPak’s Value to society

Causin Caus ing g dire direct ct valu value e cr crea eati tion on,, in inno nova vati tion on an and d pr prod oduc ucti tivi vity ty ga gain inss in othe otherr indu indust stri ries es and an d furt furthe herr co cont ntri ribu buti tion on to pu publ blic ic fina financ nces es via via ta taxe xess an and d othe otherr levi levies es.. Buil Bu ildi ding ng a mo more re technolo technologica gically lly and soci social al incl inclusiv usive e soci society ety.. Contributing directly to education, economic activity, employment, gender opportunities,, an opportunities and d soci social al an and d fina financ ncia iall incl inclus usio ion. n. Establishing natio nationwi nwide de com commun munica icatio tion n cha chann nnel el & con connec nectiv tivit ity y.

W eak ea k co conn nnec tivi vity resu sult ltin ing g in we weak ak pu publ blic ic se serv rvic ice e acce access ss fo forr exam exampl ple: e: Am Ambu bula lanc nce, e, Fire Fir e Bri Brigad gade, e,ecti etc etc.. ..ty re

Compromised Integrity impact:

Loss of Cus Loss Custom tomer er Trus rustt an and d Lo Loss ss of bu busi sine ness ss fo forr CM CMPa Pak. k. Weak Weak econ economi omicc acti activity vity an and d soci social al co conn nnec ecte tedn dnes esss du due e to loss loss of conn connec ecti tivi vity ty Ri Risk skss of  of lit litiga igatio tion n and hea heavy vy reg regula ulator tory y fin fines es.. Investment Withdrawal.. InvestmentWithdrawal

 

Impacts of Compromised Integrity on Individual Level



  Loss of of Managerial  Managerial Trust Trust causing  causing increased  increased control control and  and micro-management.



  Negative Impact on employee employee growth  growth..



  Employee morale Employee morale damaged damaged..



  Organizational reputation Organizational reputation damaged damaged..



  Revocation of Bonuses Bonuses for  for significant period



  Loss of Jobs & lack of opportunities.



  Employee blacklisting Employee blacklisting Industrially  Industrially



  Risk of of Litigations  Litigations and fines



  Family affected affected due  due troubles caused.



  Loss Of Credibility as a Nation as an Ummah

 

CMPak’s Code of ConductConduct- Putti Putting ng Company Company Values Values into Practice Practice

01

What Is It?

It pr prov ovid ides es fi firm rm,, un unco comp mpro romi misin sing g st stan anda dard rdss an and d guid gu idel elin ines es for ea each ch em empl ploy oyee ee in de deal aling ing wi with th al alll stakehold stak eholders. ers. The code of conduc conductt re-emp re-emphasize hasizess and provides further guidance regarding policies which are an integral part of CMPak’s CMPak’s business  business philosophy

Why Is It Important The Code of Conduct expresses CMPak’s CMPak’s   commitment to conducting condu cting business ethically. ethically. It expla explains ins what it means to act with integrity and transparency in everything we do and in accordance with our unique culture and values.

03

02

Who Does It Apply to? Every employee should conform to and abide the applicable laws, rules,, regulations and orders of CMPak and shall observe, and rules comply with all lawful orders and direction which may change from time to time.

The CODE is more than just words on a page , it’s a Way of Life for the Zongers!

This Code of Conduct is also available on our Company portal at: https://zongersclub.zong.com.pk/  

Areas covered under coc

Workplace Violence

1

Record Tampering

Workplace Harassment

2

Use of Information & Technology

Misuse of Official Position

3

Drugs Abuse

Confidentiality and Privacy Protection

4

Preventing Corruption

 

What Are An Employee’s Responsibilities

Follow the Code As emplo employee yeess, it is importa important nt th that at we know know and and fol follo low w th thee Code as a guideline for decisionmaki ma king ng that that is pa pair ired ed with with  . integrity. . integrity.

01

Lead By Example

Lead The Team

No matter what our role is, each one of us is expected to lead when it is a questi question on of ethics ethics and be accountable for our actions. We act with responsibility and integrity in tune with our Core values.

Encourage your team to raise issues and sp spea eak k up. up. Co Comm mmun unic icat atee a po posi siti tivve me mess ssag agee abou aboutt yo your ur co comm mmit itme ment nt to ethi ethics cs an and d co comp mplia lianc nce. e. Prom Promot otee ou ourr values ues, the Code of Conduct and compliance with policies and the law

02

As members of the CMPak family, family, let us follow not only the letter of the Code, but but its intent and spirit as well.

03

 

Compliance of “code of conduct”

1 Sign the Declaration Every employee is required to sign sign the Code of Conduct Declaration at the time of Joining and every time when the policy is updated. The declaration is available at HCM

2 Make Disclosures Make the Disclosures in the declaration wherever necessary

03 Levels of Disclosure First Degree Relatives include Parents, Spouses, Fiancés/Fiancées and Children. Second degree Relative(s) Relative(s) include Brothers, Sisters, their Spouses, Grandparents & Grandchildren Third degree Relative(s) include Uncles, Aunts, Nephews and Nieces. Fourth degree Relative(s) Relative(s) include First cousins and their Spouses.. Relative(s) In Law include parents in law,, siblings in law and children law chi ldren in law

04 Intimate the Change It is the responsibility of every employee to inform the management and HR about the change in the status of declaration

 

Code of conduct conduct-- declar declaration ation Confidentiality of the

01 – Job Responsibility

Informa Info rmatio tionn- 08

One shall maintain integrity on Company’s information and records and will not use/reveal secret information to get personal benefit.

One shall fulfill all the job responsibilities in good faith, honestly and with self-discipline

01 08

02

02 – Use of Power

Position

Company’ss Best Interest Company’ Interest-- 07

One shall not use the power power and inf influe luence nce of

One will ensure in future that all his/her decisions and approvals are in best interests of the Company.

his/her posit his/her position ion to seek unrea unreasonab sonable le benef benefits its from anyone or otherwise harm or cause to harm business interests of the Company

0 3

Code of Conduct

07

Relationship Relation ship Building Building-- 06

Accountabilit Accoun tability y - 05 On occasion of any information that I receive about corruption, bribery, fraud, misrepresentation or misconduct at any level of management, one will immediately bring that information in attention of fraud management and internal audit department for investigation.. investigation

Favors

One shall not receive any gift or consideration of any kind from anyone as an incentive or reward

One shall not promote any lobbying, grouping or building unreasonable personal relations within the Company.

03 – Gifts

06

05

04

for showing favor to any person in relation to any affair concerning business of the Company

04 – Compliance with Company Processes One shall maint maintain ain strict compliance compliance with related related policies and discipline to look after company benefit in procurement and recruitment process and will not unduly intervene in any procurement or recruitment

processs includ proces including ing supplier/em supplier/employ ployee ee select selection ion or rate  

situations of code of conduct compliance

Serving as a consultant for another company that does business busi ness with Polaris can create a conflict of interest interest.. Consequently Conseq uently,, you must receiv receivee appro approval val from CMPak prior to agreeing to serve as a consultant. Raise the

A fr frien iend d as aske ked d me if I co coul uld d confirm an internet blog which claimed that CMPak is offering certain cert ain fea featur tures es in it’s   new year's product plan Should I tell him what I know? .

No. Product plan and product launch information is confidential and proprietary information of CMPak and should not be discussed with anybody outside of CMPak unless CMPak has already been made that information public. If you have questions on whether an issue has been made public, please contact your manager or the appropriate Corporate Marketing Manager Manager...

issue with your supervisor, who will then take the issue to the appropriate people for consideration.

I ha havve be been en as ask ked to se serv rvee as a cons co nsul ulta tant nt for on onee of our our ve vend ndor orss during off hours. Can I do this?

No. CMPak will only do business with people who conduct business ethically and legally. le gally. All suppliers and vendors must comply with the standards in the Code and the law law.. Payin Paying g off government officials is bribery and violates the law. You You should report this conduct immediately.

I was at a vendor yesterday and she told me that the vendor paid off a government official to avoid customs and duties on the products they supply to us. I know this saves CMPak money, money, but is it ok? .

 

Risks for non-compliance

CONFLICT OF INTEREST

FINANCIAL LOSS

Non Compliance may arise a conflict of interest in case of   intellectual property rights preservanc prese rvance e and conf confident identiality iality..

Non-Co NonComp mpli lian ance ce ca can n ha have ve se seve vere re fin inan anci cial al im impa pact ct on the bu bussin ines esss which whi ch wil willl imp impat at the emp employ loyees ees..

REPUTATION DAMAGE

LEGAL CONSEQUENCES

Non Compliance can seriously dama da mage ge th the e co comp mpan any y re repu puta tati tion on and it’s cu cult ltur ure e th tha at wi will ll im impa pact ct the employ employee. ee.

Failu lurre to com omp ply wot oth h the code of conduct may lead to serious and str strenuo enuous us leg legal al lit litiga igatio tion. n.

 

Compliance violations

If you violate our Code, the Company will take appropriate disciplinary action.

Any disciplinary action depends on the nature, severity, and frequency of the violation. It may vary depending uponexpose local law. Please understand that those who violatecivil thedamages laws or regulations mentioned the Code could themselves and the Company to substantial and criminal penalties.in Corrective action may be taken if you: Violate the Code, Company policies and procedures, or applicable laws. • Direct others to violate the Code, Company policies and procedures, or applicable laws. • Are aware of a violation or potential violation, and fail to report it. •

• Fail to effectively monitor the actions of people you manage. • Do not cooperate in a Company audit or investigation. • Fail to participate in required training. • Retaliate against someone for reporting a concern in good faith or for participating in an investigation of such a report. • Disclose information learned during an internal investigation

 

Speak up

It is incumbent upon you to report the violations of the code of conduct. Report your concerns to your manager, Human Resources and Internal Audit. You may write at:

Use the helpline to report: • Inaccuracy of financial records • Accounting and auditing irregularities • Bribery, corruption or illegal payments • Criminal conduct and violations of law • Discrimination and harassment • Conflicts of interest.

 

Code of conduct o’ss o’ Corruption & Bribery Exclusive Services Exclusive

•

•

•

•

Business Relationships

•

Confidentiality

•

  To Report Report offers of bribe made dire directly ctly or indirect indirectly ly to you.   To Report any suspected corruptions.

  Devote Devote oneself exclus exclusively ively for serv service ice of zong and and the respective role during business/duty hours.

  Disclose Disclose personal relati relations ons either working working or doing business with the company in any capacity, directly or indirectly.

  Keeping Company Company information only to the stakeholders allowed as per the Job Description.   Protec Protectt elec electro tronic nic data just as carefully carefully as you any paper document or verbal conversation

Don'ts •

  Engaging in any corruption, extortion or embezz embezzlement lement

•

  To Offer or Acc Accept ept any bribes to gain und undue ue advantage

•

•

•

•

  Doing part or full time work during dut dutyy hours for entities other than CMPak.

  Deliberately conceal any personal relations tha thatt are either work workin ing g or doin doing g busi busine ness ss with with th thee comp compan any y in an anyy capacity.

  Shari Sharing ng any sensit sensitive ive compan company y relat related ed informatio information n with others either intentionally or unintentionally, including that of fellow employees.   Sharing Salary d details etails within and outside the organiza organization. tion.

 

Code of conduct o’ss o’ •

Conflicts of interest with personal work

• •

•

•

Gifts & Hospitality

•

•

•

Competitor Relations

•

•

Incident Reporting

•

       

Avoid Conflicts of interest at all cost. Act in best int interest erest of company company.. Disclosing any po potential tential Conflict of Interests. Devoting time to CMPak only during duty hours hours..

  Reject Reject gifts tha thatt may give appe appeara arance nce of conflic conflictt on interest.   Suppli Supplier er spo sponso nsored red tra traini inings ngs/co /confer nferenc ences es acc accept epted ed without CAD approval.   Non-returnable Gifts are deposited w with ith CAD. CAD.   Behave towards towards others as w wee would like th them em to behave towards us.   Avoiding Avoiding use of any illegal or decep deceptive tive or dishonest dishonest methods while dealing with competitors.   Diligently reports any any corruption and fraud fraudulent ulent activity to FM team.   Reports against against employ employees ees involv involved ed in COC violations violations that may cause harm to the interests of CMPak.

Don'ts •

•

•

•

•

•

•

•

  Not disclosing potential Co Conflicts nflicts of Interest.   Comp Comprom romisin ising g interests.

on

company’s   inter interes ests ts

for

pers person onal al

  Engaging in personal work during duty hours.   Gifts Gifts,, particularly those those involvin involving g transfer of money money,, are accepted leading to conflicts of interest.   Supplier sponsored trainings/conferences accep accepted ted without CAD approval.   Non-returnable gifts are not disclosed to CAD CAD..

  For informat information ion gatherin gathering g purposes purposes,, illegal metho methods ds such as trespass or theft are used, or any deceptive or dishonest methods are used.

  Not disclosi disclosing ng COC violat violations ions,, corru corruption ption and fraudulen fraudulentt activities to relevant departments, thus failing to nip the evil in the bud.

 

Impacts of 

 

fraud Types of Frauds & their Impact on the team

ommon Fraud Types



  Theft/Misappr Theft/Misappropriation opriation of Company’s Company’s Assets.  Assets.



  Bribery & Corruption



  Inciting others others to commit fraud.



  Forgery.



  Falsifying records.



  Theft of Service.

Immediate Impacts 

  Strict Compliances get imposed. imposed.



  Flexibilities in task execution execution get restricted.



  Planned bonuses get denied. denied.



  Focus on on tasks tasks get disrupted.



  Business Partner’s Partner’s trust  trust gets damaged.



  Quality of work gets adversely impacted.



  Work environme environment nt becomes toxic & hostile.

 

Embedded Integrity & Risk

 

Prevention Embedded Integrity

Embedded Integrity & AntiCorruption Risk Program

Main Principles Of the Program

CMPak kick started this new program whose main purpose was for employees to have a risk based approach in assessing and carrying out their tasks. It emphasized the role of employees in highlighting integrity and corruptions risks and preventing fraud, as employees are the owners and experts of their specific area.

•

  Work Honestly.

•

  Report results accurately.

•

  Avoid Conflicts of Interest.

•

  Not allow gifts to influence our decisions.

•

  Prohibit corruption.

•

  Commit to fair competition.

•

•

  Maintain truthful and accurate records.   Protect the confidentiality of information.

 

Preventing fraud

Management

Employee

For preventing fraud, management should: As a general rule to prevent fraud, Employees Employees should: • •

  Avoid sharing passwords passwords at  at all cost.

•

  Protect company assets assets just  just like their personal assets.

•

•

•

  Conduc Conductt Nee Need d Ana Analys lysis is   to cons consid ider er feasib feasibili ility ty of Investments & projects.   Educating oneself regarding regarding what,  what, when and to whom should fraudulent should  fraudulent activities be reported.   Assess Assess every single single activi activity ty and  and   its im impa pact ct on   the company e.g. company  e.g. Is it damaging in any way?

•

  Focus heavily on Projects/investments.

the   Ne Need

Analysis

of

  Carry   detailed reviews of reviews  of work of the  sub-ordinate staff.

•

  Encourage a risk reporting culture

•

  Consider rotations rotations in  in critical areas. areas.

•

  Manage Manage employee grievances properly.  employee grievances properly.

•

  Refrain from demanding demanding from  from employees to carry out any unethical work, even work, even when in good faith.

 

Whistleblowing & its importance  

Importance of Whistleblowing Whistleblowing is a   voluntary disclosure  by an employee, to the  respective  respective autho authority rity of mana managemen gementt relating to any activity that is deemed is deemed illegal, ille gal, unethical, or wrongful within an organization.

Whistleblowing Statistics Based on global fraud case survey conducted by ACFE, •

  Whist Whistleblo leblower wer Tips   are are the the   major major rea reason son   for

•

detection of Fraud.   Mo More re th than an 40 40% %   of   organizationa organizationall frauds frauds   are detected from whistleblower tips.

•

  More than half half of  of these tips had been reported been  reported by the employees the  employees

 

Importance of Whistleblowing “Whistleblower Protection and Investigation Policy” Policy” clearly lays out the following f ollowing guidelines: What to Report Crimi mina nall    Cri

offe of fenc nces es,,

incl in clud udin ing g

frau fr aud, d,

How to report brib br iber ery y

and an d

corruption.

Exercise cise reasonable reasonable care and judgme judgment nt in establ establishing ishing    Exer

   Assisting in concealment of Fraud.

what facts should be reported.

Company’s policies  policies and procedures.    Non-compliance of Company’s

   Report only in Good Faith.

Possib ible le    Poss

Releva evant nt department department heads can be info informe rmed, d, but car caree    Rel

fraud, frau d, co corr rrupt uptio ion n an and d in inco corre rrect ct reporting with mendacious intensions.

   Illegal use of confidential company data.

legal obligations.    Failure to comply with legal    Miscarriage of justice.

fina fi nanc ncia iall

should be taken not to tip off anyone. manager,    If there are doubts on integrity of relevant line manager, report to FM should be made.

 

Rewarding whistleblowers “Whistleblower Protection and Investigation Policy Policy” ” also lays out a reward system for whistleblowers

Reward for Whistle-blower The whistle-blower may be financially be financially rewarded based rewarded based on management decision if they: •

  Voluntarily provides provides to  to fraud management/Internal audit department,

•

  Essential information/evidence information/evidence,,

about any fraudulent activity taking place in the organization and their information leads to a: •

  successful discovery discovery of  of fraud; and

•

  closure of the case case..

 

ADD POINTS HERE

Risks

Rectification Plan

o

  Mention risks related to your domain

o

  Give details of the risks

o

  Give historical examples and what learning has been achieved through these

o

  What areas have 0 tolerance by the management

o

  How employees can start identifying risks

o

  How these risks risks can be mitigated

o

  How we can ensure increased efficiency and effectiveness

o

  How we can implement ethical standards and moral values, so that chances of fraud are minimized

Please note that you are not limited to only these points. You may add more slides  

Engineering O&M

 

Assets Handling & Accountability Fi Fiel eld d Tea eams ms are the key stake holders to ensure 100% compliance of Company policy while Assets Handling.





ATN “Asset “Asset Transfer Note” / BTN “Battery Transfer Note” submission to ensure proper recorder maintenance.



  Field Teams Teams Vehicles Vehicles fuel  fuel should be registered timely on CMPak portal.



  Company Company Vehicle   shou should ld no nott be us used ed fo forr personal use

  Fuel Management: Management: Timely  Timely reconciliation of DGs fueling as per company policy.





  Theft Management: Management: Timely  Timely updates/investigations regarding theft

  Spare Mana Managem gement ent::   Tim Timel ely y

reco re conc ncil ilia iati tion on

of

issu is sued ed

spares/Tool Kits. All returnable items must be returned to

WH as per WH policy.

incidents  

Quality Management/A Management/Acceptance cceptance “Quality means doing it right when no one is looking”

Henry ord

Blank Page Signed

Blank Page

CHECKLIST COMPLIANCE

Check List Marking

Signed

DOCUMENTATION

BOQ Signing

Proper documentation of identification snags, failed tests, Signing off 

Ensure Ensu re 10 100% 0% co comp mpli lian ance ce of ch chec eckl klis istt testing

“On Ground Equipment Verification done, Tower Installed Equipment not verified”



ACCURACY MEASUREMENT

“Lock snags on Email, Use proper terminology while noting down on paper”

System level and site level level information correlation to ensure accuracy.

OBJECTIVE OBJE CTIVE ORIEN ORIENTED TED RMS Working,

Do not relate one site acceptance with wit h ano anothe therr sit site e acc accept eptanc ance e

On Site & System

RMS Working, On Site & System Readings

“Site A will be accepted based on work done on another site”

Readings Same

Different

 

Overtime Overtime claims should be aligned to the company policy and calculated based on actual activity duration.

01

   E    M    I    T    R    E    V    O

02

03

04

(Office e Staff) AMS Logs (Offic

Routine Routi ne Work After 6:00

For Offi Office ce sta staff ff AM AMS S log logss and ove overti rtime me mustbe align aligned ed

Routine Jobs to be concluded within withi n office hours

Car Logs (Field Staff)

Short Leave Approvals

For fi For fiel eld d st staf afff ca carr lo logs gs sh shou ould ld be us used ed to veri verify fy over overtime time

Staff should get approval from respective line manager against all short leaves availed

Work From Home

Work on Weekends Weekends

NO overtime can be claimed against against work from home as per HR Policy

Only important activities to be performed on Saturday and Sunday with prior approval of Line-manager

Activity Standardization

Preventive Maintenance

Standardized activity duration to be used for verification

A llll k ind ind of pr pre e ve ve nti ntive ve ma main inte tena nanc nce e excep ex ceptt cor core e nod nodes es mus mustt be sch schedu eduled led

05

06

07

08

 O  V  E   T   R   I     M E 

 

Wrong Calculation, Routine Activities after 6:00 DG CM

Sr. No.

Activity

1

Alternator Bearing replaceme replacementnt

3

8

2

Alternator Coupling plate fault

4

10

3

Alternator Diode assembly fault

4

8

4

Hours(Minimum) Hours(Mini mum) Hours(Maximum)

ATS fault 3 7 Activity Standardization

Activity Standardization

within withi n officehours

 

Miscellaneous Gift, lunch/dinner bribery, any entertainment from vendor/site owner to be strictly avoided

1.

Pr Prio iorr int intim imat atio ion n an and d own approval required for car TAF else will not be entertained

1

5

Data sharing is not allowed with third party without management approval

2

6

1.

favorr shou favo should ld be be give given n /or /or asked for Site deployment/Acquisition

SCAPs remarks SA/CW must be verified and accurate

3

7

1.

Do no nott ref refer er any any Sub Subco con n to to Vendors / CW contractors

Strict compliance of CMPak SOP and policies are required at all

4

8

1.

Do nott Ref no Refer er an any y to of subcon of yourr you relatives/people

levels

for jobs.