Khyber Pakhtunkhwa Oil and Gas Company Limited(KPOGCL) INTRODUCTION:

Khyber Pakhtunkhwa Oil & Gas Company Limited (KPOGCL) incorporated in 2013, we are committed to conduct business in an honest, ethical, transparent and legal manner. KPOGCL is an oil & gas exploration and production company fully owned by the Government of Khyber Pakhtunkhwa and Provincial Holding Company. It gets its inspiration from the Energy Apex Committee and Board of Directors. Its actions are governed by the ethical values and principles that we share. The Company is in relentless pursuit to be seen as a role model in the corporate community by its conduct, transparency, openness, growth, par excellence and business practices. All this depends on the Company’s personnel, as they are the ones who are at the forefront of the Company’s affairs with the outside world. All directors and employees have to be familiar with their obligations in this regard and have to conduct accordingly. This Code of conduct in general is in accordance with Company’s core values, goals and objectives that must be interpreted and applied within the framework of laws and customs in which the Company operates. This code will be obligatory for each director and employee to adhere to.


“Integrity, honesty, high ethical, and legal standards are cornerstones of our business practices.”

1.1. Respect, Honesty and Integrity:

Directors and employees are expected to exercise honesty, objectivity and due diligence in performance of their duties and responsibilities. They are also directed to perform their work with due professionalism.

1.2. Compliance with Laws, Rules and Regulations:

The Company is committed to comply and take all reasonable actions for compliance, with all applicable laws, rules and regulations of the State or local jurisdiction in which the Company conducts business. Every director and employee, no matter what position he or she holds, is responsible for ensuring compliance with applicable laws.

1.3. Full and Fair Disclosure:

Directors and employees are expected to help the Company in making full, fair, accurate, timely and understandable disclosure in compliance with all applicable laws and regulations, in all reports and documents that the Company files with, furnishes to or otherwise submits to any governmental authorities in the applicable jurisdiction and in all other public communications made by the Company.

1.4. Prevent Conflict of Interest:

Directors and employees, irrespective of their function, grade or standing, must avoid conflict of interest situations between their direct or indirect (including members of immediate family) personal interests and the interest of the Company. Also, no employee will perform any kind of work (involving monetary benefit directly or otherwise) for a third party without proper approval of CEO.

Employees must notify their direct supervisor of any actual or potential conflict of interest situation and obtain a written ruling as to their individual case. In case of directors, such ruling can only be given by the Board, and will be disclosed to the shareholders.

1.5. Inside information:

Directors and employees may become aware of information about the Company that has not been made public. The use of such non-public or “inside” information about the Company other than in the normal performance of one’s work, profession or position is unethical and may also be a violation of law.
Directors and employees becoming aware of information which might be sensitive with respect to the Company’s operations have to make sure that such information is treated strictly confidentially and not disclosed to any colleagues or to third parties other than on a strict need-to know basis.
Potentially sensitive information must be brought promptly to the attention of the management, who will deliberate on the need for public disclosure. Only the Management will decide on such disclosure. In case of doubt, seek contact with the CEO, CFO and/or Internal/External Auditors.

1.6. Media relations and disclosures:

To protect commercially sensitive information, financial details released to the media should never exceed the level of detail provided in quarterly and annual reports or official statements issued at the presentation of these figures. As regards topics such as financial performance, acquisitions, divestments, joint ventures and major investments, no information should be released to the press without prior consultation with the Management. Employees should not make statements that might provide potentially sensitive information to third parties.

1.7. Corporate Opportunities:

Directors and Employees are expected not to:

a) take personal use of opportunities that are discovered through the use of Company’s property, information or position.
b) use Company’s property, information or position for personal gains.

Directors and employees are expected to put aside their personal interests in favor of the Company’s interests.

1.8. Competition and Fair Dealing:

The Company seeks to outperform its competition fairly and honestly. Stealing proprietary information, possessing trade secret information without the owner’s consent or inducing such disclosures by past or present employees of other companies is prohibited. Each director and employee is expected to deal fairly with Company’s customers, suppliers, competitors and other employees. No one is to take unfair advantage of anyone through manipulation, abuse of privileged information or any other unfair practice.

The Company is committed to providing services honestly and will not pursue any activity that requires acting unlawfully or in violation of this Code.

Bribes, kickbacks and other improper payments shall not be made on behalf of the Company in connection with any of its businesses. However, tip, gratuity or hospitality may be offered if such act is customary and is not illegal under applicable law. Any commission payment should be justified by a clear and traceable service rendered to the Company.

The remuneration cannot exceed normal business rates and practices. All such expenses should be reported and recorded in the company’s book of accounts.

1.9. Protect Health, Safety and Security:

The Company intends to provide each director and employee with a safe work environment and comply with all applicable health and safety laws. Employees and directors should avoid violence and threatening behavior and report to work in fair condition to perform their duties.

1.10. Record Keeping:

The Company is committed to compliance with all applicable laws and regulations that require the Company to maintain proper records and accounts which
accurately and fairly reflect the Company’s transactions. It is essential that all transactions be recorded and described truthfully, timely and accurately on the Company’s books. No false, artificial or misleading transactions or entries shall be reflected or made in the books or records of the Company for any reason.

Records must always be retained or destroyed according to the Company’s record retention policies.

1.11. Protection of Privacy and Confidentiality:

All directors and employees, both during and after their employment, must respect the exclusivity and trade secrets of the Company, its customers, suppliers and other colleagues and may not disclose any such information unless the individual or firm owning the information properly authorizes the release or disclosure.

All the company’s assets (processes, data, designs etc.) are considered as certified information of the company. Any disclosure will be considered as grounds, not only for termination of services/employment, but also for criminal prosecution, legal action or other legal remedies available during or after employment with the company to recover the damages and losses sustained.

1.12. Protection and Proper use of Company’s Assets / Data:

Each director and employee is expected to be the guardian of the Company’s assets and should ensure its efficient use. Theft, carelessness and waste have a direct and negative impact on the Company’s profitability. All of the Company’s assets should be used for legitimate business purposes only.

The use, directly or indirectly, of Company’s funds for political contributions to any organization or to any candidate for public office is strictly prohibited. Corporate funds and assets will be utilized solely for lawful and proper purposes in line with the Company’s objectives.

1.13. Gift Receiving:

Directors and employees will not accept gifts or favors from existing or potential customers, vendors or anyone doing or seeking to do business with the Company. However, this does not preclude giving or receiving gifts or entertainment which are customary and proper in the circumstances, provided that no obligation could be or be perceived to be, expected in connection with the gifts or entertainment.

1.14. Use of Internet / Information Technology:

As a general rule, all Information Technology related resources and facilities are provided only for internal use and/or business-related matters. Information Technology facilities which have been provided to employees should never be used for personal gain or profit and remain the property of the Company. Disclosure or dissemination of confidential or proprietary information regarding the Company, its plans, products or its customers outside the official communication structures is strictly prohibited.

1.15. Compliance with Business Travel Policies:

The safety of employees while on a business trip is of vital importance to the Company. The Company encourages the traveler and his/her supervisor to exercise good judgment when determining whether travel to a high-risk area is necessary and is for the Company’s business purposes.

It is not permitted to combine business trips with a vacation or to take along spouse, relative or friend without the prior written authorization from Management.


“We pursue quality as a way of service. It is an attitude that affects everything we do for relentless pursuit of excellence.”

KPOGCL recognize employees’ input towards quality by emphasizing skills development and professionalism. It will be responsibility of all of us to ensure that KPOGCL must be performance driven, cost effective and continuously improving services, works and productivity to meet requirements of the business.


“We believe in respect for the community and preserving the environment for our future generations and keeping national interests paramount in all our actions.”

KPOGCL encourages the spirit of volunteering in its employees for activities of environmental protection and Social and Community development to fulfill KPOGCL’s commitment for its Corporate Social Responsibility.

KPOGCL is committed to prevent pollution by efficient use of energy throughout its operations, recycle and reuse the effluent where it is possible and use cost effective cleaner production techniques that lead to preventive approach for sustainable development.


“We embrace lifelong learning and innovation as an essential catalyst for our future success. We believe in continuous improvement and to seize opportunities inherent in change to shape the future”.

All employees of KPOGCL will strive to keep themselves abreast with the new developments in their respective areas and will not hesitate to take initiatives that could bring improvement in the way of our working. All efforts in this respect should eventually translate into improved efficiencies and minimization of wastages at all levels.

The Company encourages and facilitates its employees in the activities of knowledge sharing, research and development and promoting the change management culture.


“We believe that competent and satisfied people are the Company’s heart, muscle and soul. We savor flashes of genius in organization’s life by reinforcing attitude of team work and knowledge sharing based on mutual respect, trust and openness.”
We will all make our utmost efforts to foster team work in our respective areas of operation and will give special attention to the following aspects:

5.1. Equal Employment Opportunity:

The Company believes in providing equal opportunity to everyone around. The company policies in this regard have to be complied with and no discrimination upon race, religion, age, national origin, gender or disability is acceptable. No harassment or discrimination of any kind will be tolerated. Directors and employees must comply with standards/laws with regard to child labor and forced labor.

5.2. Employee Retention:

High quality employee’s attraction and retention is very important. The company will offer competitive packages to the deserving candidates. The Company strongly believes in personnel development and employee-training programs are arranged regularly.

5.3. Work Environment:

All employees are to be treated with respect. The Company is highly committed to providing its employees and directors with a safe, healthy and open work environment free from harassment, intimidation or personal behavior not conducive to a productive work climate. In response the company expects consummate employee allegiance to the company and due diligence in his/her job.

The Company also encourages constructive reasonable criticism by the employees of the management and its policies. Such an atmosphere can only be encouraged in an environment free from any prospects of retaliation due to the expression of honest opinion.


“We flourish under an ecosystem of shared understanding founded on the concept of empowerment, accountability and open communication in all directions.”

6.1. Communication:

All communications, whether internal or external, should be accurate, forthright and wherever required, confidential. The Company is committed to conduct business in an open and honest manner and provide open communication channels that encourage candid dialogue.

6.2. Delegation of Authority and Accountability:

The guidelines in respect of delegation of authority i.e. “Limits of Authority” will be implemented in letter and spirit. All employees are expected to follow these limits and ensure maximum decentralization of decision making in their respective areas. The Company also expects that with such a level of empowered culture the employees will understand that they will be responsible for their decisions and would be fully accountable for that.


It is the responsibility of each director and employee to comply with this code. Failure to do so will result in appropriate disciplinary action, including possible warning issuance, suspension and termination of employment, legal action and reimbursement to the Company for any losses or damages resulting from such violation. Compliance also includes the responsibility to promptly report any apparent violation of the provisions of this code.

Any employee meeting with difficulties in the understanding or application of this Code should refer to his/her functional head or if required to CEO.

We pray to Almighty Allah to Help us in observing the above. Ameen.