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  1. At KPOGCL, the Directors and employees reject corruption in all forms – direct, indirect, public or private and do not directly or indirectly engage in bribery, kick-backs, payoffs, or any other corrupt business practices. No employee of the Company shall accept any funds, loans, favors or other assets (including those provided as preferential treatment) to obtain business from any entity or that might tend to influence an employee’s business decisions. Acceptance of any gift by the Directors or Employees will be subject to Company’s Policy.
  1. In the course of their normal business duties, employees may be offered entertainment such as tea, breakfast, lunch or dinner, however Employees shall make best efforts to pay for these. Accepting these offers is appropriate, if those are reasonable and occur in the course of a meeting or on an occasion the purpose of which is to hold bonafide business discussions or to foster better business relations. Employees should not accept tickets or invitations to entertainment or alike.
  1. Employees may offer gifts of hospitality of a customary amount or value for routine services or exchange of customary reciprocal courtesies to prompt general business goodwill provided it does not influence business decisions or dealings of the Company. CEO or CFO shall approve the nature of the gifts.

Anti-Corruption Policy & Procedure

1.    Severance Management

  1. Illegal acts at work place;
  2. Fraud;
  3. Misappropriation;
  4. Non-compliance of KPOGCL policies and procedures, including Code of Conduct;
  5. Unfair use of KPOGCL property; and
  6. Any other factors that may hurdle the smooth running of company operations.

1.1.         Severance Committees

KPOGCL Grades Investigating Authority Approving Authority
10A (CEO) HR Committee of the Board Board of Directors of KPOGCL
10B, 9, 8,7,6,5 1. Chief Executive Officer
2. Sr.GM – HR, Admin & Procurement		 CEO
4,3,2,1 and non-management staff, trainees, daily wages etc. 1. General Manager HR
2. Relevant Department General Manager		  CEO

1.2.         Complaints

1.3.         Right to Defend

1.4.         Assessment by Severance Committee

1.5.         Warning/termination

1.6.         Appeal

1.7.         Clearance

2.    Grievance Complaints and Redressal

Communication to Employee All employees of KPOGCL should be informed about the grievance mechanism at the time they are hired, and details about how it operates should be easily available, in employee handbooks for example. Employees must know to whom they can turn in the event of a grievance and the support that is available to them. Department Heads/Department Managers/Zonal Managers who will be dealing with grievances.
Regular Updates The process should be regularly reviewed and kept up to date. Human Resource Department will be responsible to update the process.
Confidential, Impartiality and non-retribution Formal complaint lodged by an employee shall be dealt with confidentiality. CEO, Employee Line Manager and Manager – HR & Admin shall receive the complaints.

Employee lodging the complaints shall not be subject to any reprisal.
Reasonable Timescales Any complaint received from an employee shall be investigated within a month from the date of the complaint is received Human Resource Department.
Authority to Investigate GM – HR and relevant Department Head will be responsible for conducting meetings and investigations relevant to the grievance.

For any complaints by General Managers against CEO, HR Committee of the Board can designate any of its members for investigation and resolution.
Right of Appeal An employee should have the right to appeal to a higher level of management if he or she is not satisfied with the initial finding.
Keeping records Once a grievance has been raised formally, proper written records shall be kept to aid transparency and allow for any review of the process or decision to be undertaken. Original complaints, meeting minutes and decisions shall be retained as records.

POLICY & PROCEDURES Policy SummarythArticle I: Purpose of this PolicyArticle II: Definitions

  1. Conflict of Interest
  1. Interested Person
  1. Financial Interest
  1. An ownership, partnership, directorship (excluding independent directorships), shareholding or investment interest in any entity with which the Company has a transaction or arrangement, however any prior ownership, partnership, shareholding or investment created 6 months prior to joining KPOGCL shall not construed COI.
  1. A compensation arrangement with the Company or with any entity or individual with which the Company has a transaction or arrangement. Compensation includes direct and indirect remuneration, as well as gifts or favors that are not insubstantial, such as:
  • Consultancy – any consultancy, directorship fee (excluding independent directorship), position in or work which attracts regular or occasional payments in cash or kind,
  • Fee-paid Work – any work commissioned for which the member is paid in cash or in kind,
  • Shareholdings – any shareholding in or other beneficial Interest in shares. (This does not include shareholdings through unit trusts or similar arrangements where the “Interested Person” has no influence on financial management).
  1. A potential ownership or investment Interest in, or compensation arrangement wit, any entity or individual with which the Company is negotiating a transaction or arrangement.

A financial Interest is not necessarily a Conflict of Interest

  1. Research Awards

  Article III: Procedures

  1. Distribution of Policy and Procedures
  1. Duty to Disclose
  1. Determining Whether or Not a Conflict of Interest Exists
  1. Procedures for Addressing the Conflict of Interest
  1. An Interested Person may make a presentation at the Board or committee meeting, but after the presentation, he/she shall leave the meeting during the discussion of, and the vote on, the transaction or arrangement involving the possible Conflict of Interest.
  1. After exercising due diligence, the Board or committee shall determine whether the Company can obtain, with reasonable efforts, a more advantageous transaction or arrangement from a Person or entity that would not give rise to a Conflict of Interest.
  1. If a more advantageous transaction or arrangement avoiding a Conflict of Interest is not reasonably possible under circumstances, the Board or committee shall determine by a majority vote of the “dis-Interested directors” or members, whether the transaction or arrangement is in the Company’s best interest, for Company’s own benefit, and whether it is fair and reasonable. In conformity with the above determination, the BOD shall make its decision as to whether to enter into the specified transaction or arrangement.
  1. In the case of research awards, the member of any institution to which a grant is to be considered shall retire from the room during the course of the discussion, shall not participate in the deliberation nor vote on the matter.
  1. Violations of the Conflict of Interest Policy
  1. If the Board, committee or Compliance Officer has reasonable cause to believe a member has failed to disclose actual or possible Conflicts of Interest, it shall inform the member of the basis for such belief and afford the member an opportunity to explain the alleged failure to disclose.
  2. 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. The CEO shall give ruling on employees in breach of COI. In case of Directors, such ruling can only be given by the Board, and will be disclosed to the shareholders.
  1. If, after hearing the member’s response and after making further investigation as warranted by the circumstances, the Board, Committee or CEO determines that the member has failed to disclose an actual or possible Conflict of Interest, s/he shall be given 15 working days to appeal and/or remove the Conflict of Interest as determined by the BOD, Committee or CEO thereafter BOD, Committee or CEO shall take appropriate disciplinary and corrective action.

Article IV: Records of Proceedings

  1. The names of the Persons who disclosed or otherwise were found to have an actual or possible Conflict of Interest, the nature of the Financial Interest or other Conflict, any action taken to determine whether a Conflict of Interest was present, and the Board’s or committee’s decision as to whether a Conflict of Interest in fact existed.
  1. The names of the Persons who were present for discussions and votes relating to the transaction or arrangement, the content of the discussion, including any alternatives to the proposed transaction or arrangement, and a record of any votes taken in connection with the proceedings.

Corporate Strategy

  • Strive to implement International Best Practice: We strive to implement international best practices which seek to bring about an efficient organizational structure and business processes that are focused on production.

Confidentiality Policy

INTRODUCTION

What is Whistle-blowing?What is wrong doing?

  1. An unlawful act whether civil or criminal;
  2. Breach of or failure to implement or comply with any published KPOGCL policy;
  3. Knowingly breaching mandatory federal or provincial laws or regulations;
  4. Unprofessional conduct;
  5. Questionable accounting practices;
  6. Dangerous practice likely to cause physical harm/damage to any person/property;
  7. Failure to rectify or take reasonable steps to report a matter likely to give rise to a significant and avoidable cost or loss to KPOGCL;
  8. Abuse of power or authority for any unauthorized or ulterior purpose; and
  9. Unfair discrimination in the course of employment or provision of services.

Who is protected?

  • Discloses the information in good faith;
  • Believes it to be substantially true;
  • Does not act maliciously or make false allegations; and
  • Does not seek any personal or financial gain.

Who should the Whistle Blower (WB) contact?How will KPOGCL respond?

  • Be investigated by management, the Board of Directors, or through a disciplinary process;
  • Be referred to the external auditor.
  1. Acknowledging that the concern has been received;
  2. Indicating how they propose to deal with the matter;
  3. Giving an estimate of how long it will take to provide a final response;
  4. Telling the WB whether any initial enquiries have been made; and
  5. Telling the WB whether further investigations will take place and if not, why not.

TIME SCALE

PREVENTION OF RECRIMINATIONS, VICTIMIZATION OR HARASSMENT.

CONFIDENTIALITY AND ANONYMITY

FALSE AND MALICIOUS ALLEGATIONS