Al-Karrar Engineering.

1. OBJECTIVE

1.1. To provide Al Karrar Engineering Company for General Contracting Ltd’s employees and vendors an avenue to raise concerns, in linewith Al Karrar Engineering Company for General Contracting Ltd’s commitment to the highest possible standards of ethical, moral and legal business conduct and its commitment to open communication.
1.2. To provide necessary safeguards for the protection of employees and vendors from reprisals or victimization, for whistle blowing in good faith.

2. BACKGROUND

In order to enhance good governance and transparency, this policy has been developed to help employees and vendors report legal and ethical issues like fraud, bribery, corruption or any other unlawful conduct or dangers to the public or the environment. Specific examples could include:

a. A criminal offence (e.g. fraud, bribery corruption or theft) has been/is likely to be committed
b. The health or safety of any individual has been/is likely to be endangered
c. The environment has been/is likely to be damaged
d. Company funds are being used in an unauthorized manner
e. Any other form of improper action or conduct is taking place
f. Information relating to any of the above is being deliberately concealed or attempts are being made to conceal the same.

3. WHO IS COVERED BY THE POLICY

3.1. All employees of Al Karrar Engineering Company for General Contracting Ltd are covered by this policy.
3.2. Vendors working with Al Karrar Engineering Company for General Contracting Ltd may also use the provisions of this Policy to make Al Karrar aware of any concerns that they may have with regard to any contractual or other arrangements with Al Karrar.

4. PROCEDURE FOR RAISING A CONCERN

4.1. As soon as any employee or vendor becomes reasonably concerned:

a. They may write to the Compliance Officer in the prescribed format (Annexure-I).
b. In case the matter relates to Compliance Officer, the matter may be sent to the Chairman of the Company.

4.2. Employees and vendors who wish to raise a concern should follow the guidelines given below:

a. Concerns must be raised in writing with the name and contact details of the whistleblower. Anonymous complaints will not be encouraged.
b. The background and history of the concern should be mentioned (giving relevant dates).
c. Documentary evidence (if available) may also be submitted.

5. PROCEDURE FOR RECORDING CONCERNS & RESPONDING

5.1. All concerns should be sent to Compliance Officer either through email zeshan.safety@alkarrareng.com or through the mail in a sealed confidential envelope addressed to the compliance officer. Concerns may also be dropped in the Whistle Blowing ‘Drop Boxes’ placed at Al Karrar HQ. The Box at Head Quarter will be opened on weekly basis by Compliance Officer or the authorized person (preferably a Senior Executive Cadre) assigned by him, and all complaints will be sent to the Chairman of the Company.
5.2. Usually, within one week of receiving the concern, Compliance Officee will send a reply to the initiator of the concern, giving an estimate of how long it will take to provide a full response.
5.3. Compliance Officer after establishing the facts of the matter would provide his findings within four weeks to the Chairman recommending the concerned department to take cognizance to address the matter.

6. CORPORATE RECORDING & MONITORING
Compliance Officer will maintain a complete record of all concerns which are brought to his attention and will produce a quarterly report as a separate agenda item for review by the Chairman.

7. CONFIDENTIALITY
Persons raising concerns as well as those involved in recording or investigations must also ensure that no disclosure of confidential information takes place during and after the process has been completed.

8. ASSURANCE TO WHISTLE BLOWER
Anyone who raises a concern under this Policy will not be at risk of suffering any form of retaliation.

9. REVIEW OF THE POLICY
This Policy will be reviewed, prior to the start of each Fiscal Year, by the General Manager so as to ensure the continuing effectiveness of the same.

10. COMPLAIN FORM FOR WHISTLE BLOWING
A Complain form for whistle blowing is attached with this procedure in Annexure-I, which can be utilized for the submission of any complaint as per the requirement of this procedure.