1.1     Purpose

This policy is formalized to ascertain that all company members have a clear and in-depth understanding of recruitment policies and procedures. It also ensures that the recruitment process is conducted systematically and effectively with optimal resource utilization.

The objective is to recruit a diverse workforce, irrespective of any discrimination based on race, color, gender, nationality, religion or disability. Moreover, it shall ensure that everyone involved in the recruitment process, follows and complies with the necessary recruitment and selection procedures, supported by relevant forms, checklists and guidelines.

1.2 Scope

This policy applies to all company members who are responsible and involved in the recruitment process.

1.3 Policy

The company has established a standard recruitment policy for all positions, based upon the kind and level of expertise essential for a specific post. All hiring policies and procedures are as per the company’s rules and regulations. However, certain recruitment policies are subject to Labor Laws of the Government of Pakistan.

  • Employment Categories

The company has the following employment categories:

Regular Members: A regular member is a company employee, who has been appointed on a permanent post against a permanent vacancy. Prior to confirmation, all appointed members have to undergo a probation period of three (3) to six (6) months, as decided by the management.

Consultants: A consultant is a member hired by the company for a limited period under a written contract. This contract may or may not be renewable. As per specific project requirements, a consultant can be hired for temporary assistance on part-time basis.

Associates: An associate is a member with less than one (1) year of prior experience, who must undertake some form of test/ training to meet employment standards.

Interns: An intern is an employee who is hired as a fresh graduate/student for a limited period. It is not mandatory or obligatory for the company to offer a permanent position to an intern.

1.3.2 Policy Framework Any additional resource required for a specific post shall be identified and requested, as per the Business Plan, by the respective manager. A Personnel Requisition Form must be submitted to the HR department to serve this purpose. This form needs to be approved by the DCEO. Based on the JARD (Job Accountability Role Definition) for a particular post, the Personnel Requisition Form shall entail:

  • The area and level of expertise required for a specific post.
  • The tasks to be performed by the potential candidate (list of primary responsibilities).
  • Who is/was responsible for these responsibilities (if it existed before)
  • Why these responsibilities cannot be handled as before.
  • The following primary recruitment sources are in order of preference by which they shall be utilized:
  • Internal postings via advertisements and referrals
  • Online Resume Database
  • E-Services (Headhunters)
  • Career fairs, open houses (campus visits)
  • External Advertisements (Newspapers)
  • All candidates shall be identified and selected by a transparent and merit-based recruitment and selection process. The emphasis of which shall be on relevant education, experience and personal attributes as per job requirements.
    • All candidates are required to submit their resumes online, via the company’s web site or HR websites like Hard copies will not be acceptable unless necessitated due to unavoidable circumstances.
    • Internal Candidates must be confirmed members of the company with one year of service. Furthermore, a clearance shall be required from the concerned supervisor before the candidate takes over the new position.
    • Initially, a pool of candidates shall be screened for a particular position by HR personnel. The list will be sent to the respective technical manager for final short listing of potential applicants for a test/interview, whichever applicable. Moreover, the concerned technical manager will also shortlist applicants, if any, at their end, and coordinate with HR accordingly.
    • The minimum age requirement for employment with the company is 18 years and above.
    • Fresh graduates, being considered for the Associate Program or as Regular Members of the company, shall have to undergo the Professional Aptitude Test(s). This test will be a combination of MCQs and descriptive questions. It shall assess the applicants’ technical/job related skills, comprehensive skills, general knowledge/cognitive abilities etc. Furthermore, test results shall be quantified in percentile form as per pre-defined scoring breakdown.
    • Tests shall not be mandatory for applicants with two (2) or more years of experience in their respective fields.
    • An interview invitation shall be sent to the short listed candidates via email and phone. The interview will be conducted at the Company’s offices. Moreover, an Applicant Form shall be emailed to the interviewees.
    • It is obligatory for all employees, involved and responsible for the recruitment process, to conduct a minimum of two (2) rounds of panel Interviews before selecting the potential applicants. The first/technical interview shall be conducted by a technical panel. This panel will consist of a respective manager and one (1) HR representative. The second interview will be taken by a panel comprised of the HR Manager, one (1) or more HR representatives and the respective GM/Manager.
    • Interviews can be face-to-face or telephonic, whichever applicable. However, it is mandatory that the second interview is face-to-face. The first technical interview must be based on the technical skill set required for a specific post. The second and final interview shall be conducted to assess the applicant’s organizational culture fit as well as their overall personality attributes.
    • Based on the first/technical interview results, the technical panel, as defined in clause 2.2.12, shall determine whether to shortlist or reject/retain the interviewee.
    • The final pool of applicants shall be kept in order of preference as per the relevant skills matrix. These applicants must be called in for a second face to face interview accordingly. Whereas, the rejected/retained applicants shall be informed via email within 30 days. Potential candidates who do not suit the current opening will be retained for six (6) months. .
    • Decision on the interview outcomes of the final pool of applicants shall be prioritized, as per the pre-defined skills matrix and salary range. Furthermore, the concerned HR members, in coordination with the requesting manager/team lead(s), shall undertake the final decision.
  • An applicant being evaluated for a specific job must meet the basic physical requirements. However, all possible arrangements to enhance output of a disabled employee shall be made. If required, selection of the candidate may be made on conditional grounds of medical test(s).
  • Prior to making an employment offer to the potential applicant, all concerned members must ensure that they abide by the policy guidelines in terms of training (if applicable), employment category and remuneration decisions.
  • Selected applicant(s) shall be made an employment offer via phone and email. All relevant documents and a scanned copy of the offer letter must be sent by email. Moreover, IF the new employee(s) fail to submit a Resignation Acceptance letter from the previous employer and previous salary details (if applicable) on the date of joining as well as other required documents within the allocated time, THEN as per company’s policy, the employment offer made to the selected potential applicant(s) SHALL BE DEEMED VOID.
  • After an employment offer has been made to the potential applicant, and the acceptance has been received, the Human Resource Department shall check the references of the applicant by phone or email.
  • Prior to the joining date of the employee(s), HR personnel shall ensure that all necessary arrangements such as space allocation, mail account/network/hardware requests for the new joiner(s) have been made, and the concerned Manager has been informed accordingly.
  • Based on the pre-defined recruitment cycle, the recruitment shall take place twice a month; First (1st) and Fifteenth (15th) of every month. Similarly, the orientation shall take place on the same dates as those pre-defined for recruitment.
  • As per company’s policy, an orientation program for three (3) or more new joiners shall be conducted on the day of the joining.

1.4 Appointment Panel

DCEO/ Respective GM(s), in accordance with the rules laid down in the manual, shall approve all permanent appointments to various posts. The appointing authority has full responsibility for receiving and reviewing applications, processing applicants, making appointments that affect employment and terminations.

Appointments shall be made at a level subject to the approval of the Management Committee, and/or as per requirement of the respective divisions, as Consultant/Associate/ Temporary/Regular employee as well as at Intern level, where applicable.

For managerial and other senior level positions, the panel responsible for hiring decisions shall consist of:

  • CEO of the company
  • DCEO
  • Respective GM

1.5 Roles and Responsibilities

DCEO / Respective GM:

  • Job requisition analysis against resource utilization and business plan
  • Approval of Personnel Requisition Form for a specific post.
  • Final/second interview evaluation.
  • Approval on employment offer, type of employment, training (if applicable) and compensation package.

HR Manager

  • Job Requisition Analysis against resource utilization and business plan.
  • Request a resource, for a specific post, through the Personnel Requisition Form.
  • Second interview and final evaluation
  • Decision on employment offer, type of employment, training (if applicable) and compensation package.
  • Approval on the Offer letter, Confidentiality Agreement and Employment Contract.

Respective Manager:

  • Identify the resource as per resource utilization and business plan.
  • Request a resource, for a particular post, through a completely filled Personnel Requisition Form to HR.
  • Screen and shortlist candidates in coordination with the concerned HR personnel.
  • Conduct first technical interview and evaluate applicants accordingly

HR Team:

  • Screen and shortlist candidates in coordination with the concerned manager.
  • Schedule, conduct and evaluate all interviews undertaken.
  • Prepare all documents such as offer letters, confidentiality agreements and contracts.
  • Ensure a smooth and efficient recruitment process..
  • Verify and cross check all documents provided by the applicant before/after the employment offer.
  • Manage all documents used and required in the recruitment process.
  • Send recruitment related emails to rejected/retained/short listed candidates.
  • Maintain and update the Personnel Record accordingly.
  • Ensure proper and timely filing of all related documents.

Respective Manager:

  • Identify the resource as per resource utilization and business plan and put forward a request of a resource for a particular post through completely filled Personnel Requisition Form to HR.
  • Screen and Shortlist Candidates in coordination with the concerned HR personnel.
  • Conduct First Technical Interview and Evaluate applicants accordingly
  1. Sops of Hiring
Scheduling Technical Interview Requisition Form filled and signed by manager and DCEO.
  Update Requisition Status on HR Server
Resume Scanning/Reference Resume Collection
Coordination of time with the proposed panel
Scheduling the Interview through telephone with the candidate
Send the meeting invitation through mail Calendar to all concerned personnel and cc to HR Group mail (including reception for booking conference room)
Update the Interview status sheet
Send an e mail to the applicant stating the Venue, Date and Time of the interview along with the applicant form
Interview Process
Before the Interview Following documents should be ready :
1. 2 copies of update resume
2. Duly Filled Applicant Form
3. HR Induction Form filled with required information.
At least one HR personnel has to be part of the 1st interview
Once the interview is over induction form should be filled clearly by the technical team and the HR personnel
Final Rating Should be discussed before leaving the hall
If the candidate does not qualify, retain/reject mail is to send through HR.
If the candidate qualifies, a second interview with the HR is to be scheduled.
DO NOT discuss salary in this interview.
Scheduling HR Interview 
HR Interview: Coordinate with the senior HR personnel and schedule according to their availability
Send the meeting invitation to all concerned personnel and cc to HR Group mail (including reception for booking conference room)
Interview Process
Salary and joining dates are to be clarified.
HR policies and procedures are to be explained in detail to the candidate
Last page of the induction form must be filled after this interview
If the candidate does not qualify, retain/reject mail is to send through HR.
Candidate is only hired if clears this round as well
Update interview status sheet
Send Offer
Once all rounds cleared, an offer letter is prepared which states the proposed salary and joining date
Offer letter is  scanned and sent to the Candidate (Through HR)
The candidate is given a week to give his consent (accept or reject)
Follow-up is a must




Security and Reference Check

Once the candidate accepts the offer, telephonic reference check needs to be conducted
Security check with HSSE
Once the offer is accepted, Following documents are to be made before the joining date:
1. Contract
2. Confidentiality Agreement
At least 15 days prior to joining date, send request to Network and Hardware for the new joiner
Create an employee profile
Welcome folder is to be prepared which includes but not limited to :
Offer Letter +  1 Photocopy of Offer Letter for receiving
2 copies of Contract
Confidentiality Agreement
Bank detail
Beneficiary Form
Provident Fund Form
Health Insurance Form
Check lists Form (external and internal)
Temporary Employee Card
Post Joining On the joining date update details on HR server for the Staffing Pattern
Follow-up with the new joiner and HR coordinator to ensure that all the documents are complete in the file
  1. Compensation Plan

A decent compensation plan for a company is based on three anchors: Internal considerations, external considerations, and job performance. Compensation plans should be considered and developed logically and carefully. Also; average salaries for the Organogram are provided for the technical staff. A salary survey to be conducted every 3 years through a reputed firm, such as Fergusons.

  1. Internal Consideration/Equity

This requires ranking all the jobs in the organization hierarchy and the contribution of each job to the organization.

  1. External Consideration/Equity

Salary surveys are conducted and used to help determine whether the company is paying its people what others are paying or what others would have pay for the same person. The company salary structure has to be aligned with the industry; otherwise the company will start losing its staff.

  1. Job Performance

This is where management recognizes proficiencies within the same levels. Sometimes the company establishes ranges of salaries for the same job.

  1. Performance to Salary Ratio

The principle behind the ratio of performance to salary in a free enterprise system is that contribution should be equal to compensation. This is a major component of a good salary program.

The elements involved in this principle are:

  • Evaluating the record of the employee
  • Employee’s experience
  • Employee’s accomplishments/contribution

Reviewing the responsibilities in the present position and checking the results and activities involved in getting the results.

Salary and compensation includes base salary, bonuses, long-term incentives, benefits and prerequisites.

  1. Base salary

The regular annual salary which is often dependent on information from salary surveys of similar companies. Job evaluation is typically used to set employee pay in organizations, however base salary levels of executives are often more influenced by the opinion of or BOD.

  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

KPOGCL is highly committed to promote fair and honest culture through all the departments of the company to keep good and attractive working environment. Therefore, KPOGCL will ensure that all complaints against employees are assessed and investigated by appropriate forums and proper action is taken. Complaints to BOD or CEO may relate to the following matters:

  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

For the purpose of handling complaints against employee(s), given below are the appropriate forums for investigating and handling complaints against different grades:

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
4,3,2,1 and non-management staff, trainees, daily wages etc. 1. General Manager HR
2. Relevant Department General Manager

1.2.         Complaints

Any KPOGCL employee, supplier, contractor or any other stakeholder may lodge complain for any non-compliance with the KPOGCL policies or laws and regulations to CEO, CFO, Manager IA or any GM. The matter shall be kept highly confidential until the CEO or his/her delegate assess the reasonableness of complaint(s). If CEO or his/her delegate is satisfied that the complaint is genuine, the matter shall be referred to appropriate Severance Committee based on the grade of the employee. The employee may be suspended from his service during the investigation of matter.

In case of a complaint seems to intentionally malign an employee’s reputation, a show-cause notice shall be issued to the complainant and the matter shall be referred to the relevant severance forum.


1.3.         Right to Defend

Before investigating the matter, Severance Committee shall give enough time to employee to defend himself and give clarifications. Proper notice shall be given thereby inviting convicted employee for clarification. The notice shall specify the charges against the employee and shall specify the timeframe during which he/she can submit his/her written clarifications. The written clarifications shall be submitted by the convicted employee to any member of Severance Committee nominated for the purpose.


1.4.         Assessment by Severance Committee

Severance shall thoroughly investigate the matter with due care. If the nature of the offence is technical involvement of any other person is required, the Committee members can mutually agree and include other persons to assist them. Severance Committee may also appoint a team of good repute from within KPOGCL to investigate the charges against the employee.

The investigating team members shall present a report covering all aspects of the matter along with recommendations to Severance Committee. Severance Committee may make recommendations to CEO.


1.5.         Warning/termination

Based on severity of the matter, Severance Committee may recommend to issue written warning by CEO to concerned employee or may terminate him/her from service.

The results of the investigation and recommendations shall be forwarded to the following authority for approval:

          For 10A grade, BOD KPOGCL;

          For 10B, 9,8,7,6,5,4,3,2,1 grades by CEO.

Once approved, warning or termination letter shall be issued to the concerned employee by CEO.

1.6.         Appeal

Aggrieved employee of KPOGCL shall have right to appeal against the decision of the Severance Committee. The appeal shall be made to the higher forum than the committee who investigated the matter.

1.7.         Clearance

In case of termination, Human Resource Department shall ensure that the clearance procedure as specified for the outgoing employees is followed. In case of termination from service due to fraud, misappropriation or misuse of company assets, HR shall deduct any such loss from the final settlement of outgoing employee. CEO shall finally approve the settlement.

2.    Grievance Complaints and Redressal

Grievances are complaints that employees raise with their employers. These may relate to how employees have been treated or to actions that an employer is contemplating taking. There is a spectrum of grievances ranging from major and potentially illegal issues, such as discrimination or victimization in the workplace to more minor day‐to‐day disputes such as a poor relationship between two employees or a disagreement over holiday arrangements.

KPOGCL grievance procedures shall provide a clear and transparent framework to deal with difficulties which may arise as part of their working relationship from an employee’s perspective. It is important that employees have a course of action available, should they have a complaint. Procedures are necessary to ensure that everybody is treated in the same way in similar circumstances and to ensure issues are dealt with fairly, reasonably and in a timely manner.

Procedures should be kept as simple as possible, avoiding unnecessary administrative stages. Lodging a formal grievance should be seen as a last resort, after informal methods have been exhausted. Ordinary, day‐to‐day issues can often be better dealt with informally in meetings with Line Managers. If discussions with Line Managers fail to resolve the issue, it is still possible to pursue an informal approach without triggering a formal procedure. For example, Manager – HR could host an informal meeting or discussion.


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 Summary


It is the firm policy of the Khyber Pakhtunkhwa Oil & Gas Company Limited (herein called “KPOGCL”) to identify Conflicts of Interest (herein called “COI”) involving KPOGCL and related parties, as well as to identify situations which may give rise to the appearance of a Conflict of Interest, and to address such Conflicts and situations in a manner that will fully protect the integrity, reputation, time, efforts and funds of the KPOGCL and related parties. This COI Policy was approved by the Board of Directors in the 17th Board Meeting.


This Policy is issued dated 17-March-2017. It is applicable on all Directors of the Board and Employees.


Article I: Purpose of this Policy


The purpose of this Conflict of Interest policy is to protect KPOGCL’s Interests when it is contemplating to enter into any transaction, agreement, contract, arrangement or other work that might benefit the private Interest of a Director (Board of Director), or Employee that might result in a possible excess benefit transaction or may give the appearance of undue influence from outside parties. This policy is intended to supplement but not replace any applicable Provincial and/or Federal laws governing and in vogue. A panel under the CEO, assisted by CFO shall ascertain applicability of COI to a transaction. A report shall be submitted to BOD every six months.


Article II: Definitions


  1. Conflict of Interest


A “Conflict of Interest COI” arises when a Person in a position of authority in an organization, such as a Director, manager, key officer, management staff, non-management staff, expert, volunteer, consultants and alike may benefit Personally from a decision he or she could make.


  1. Interested Person


Any Director, principal officer, committee member or senior staff Person with delegated powers, who has a direct or indirect financial Interest, as defined below, is an Interested Person.


  1. Financial Interest


A Person has a financial Interest if the Person, directly or indirectly through business, investment or family has:


  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 under Article III, Section 2, when a Person who has a financial Interest may have a Conflict of Interest only if the governing Board or appropriate committee decides that a Conflict of Interest exists.


  1. Research Awards


Interested Person shall avoid situations of possible Conflict of Interest in the recommendation of contracts, agreements or grants to other institutions where s/he has Interest.



Article III: Procedures


  1. Distribution of Policy and Procedures


Annually a Disclosure Statement shall be furnished to and completed by each Director, officer, committee member and senior staff member. Any new directors, officers, committee members or senior staff shall be advised by the Compliance Officer (CFO) of this Policy and furnished a disclosure statement upon undertaking the duties of such office.


  1. Duty to Disclose


In connection with any actual or possible Conflict of Interest, an Interested Person must disclose the existence of the Financial Interest and be given the opportunity to disclose all material facts to the Board members or members of committees considering the proposed transaction or arrangement. The KPOGCL’s Disclosure Statement (Form XXXX) shall be provided for this purpose to the Interested Person.


  1. Determining Whether or Not a Conflict of Interest Exists


After disclosure of the Financial Interest and all material facts, and after any discussion with the Interested Person, he/she shall leave the Board or committee meeting while the potential of a Conflict of Interest is discussed and determined. The remaining Board or committee members shall decide if a Conflict of Interest exists. The minutes of the meeting shall note that this procedure was followed and the group’s determination.


  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


The Minutes of the Board meeting and all committee meetings, where such Conflicts have arisen shall contain:


  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

To enable the Company to attain heights of success through investment in human capital, implementation of lean exploration & production methods, services and commitment to Total Quality and Environment Management, we plan, with the help of Almighty Allah, to establish and expand the newly established company into a world class E & P company and attract local, as well as international investments to penetrate into untapped Oil and Gas reserves with pro-active measures and effective planning, implementation and execution. Our objective is to successfully exploit all the available natural resources for benefit of people of Khyber Pakhtunkhwa in particular and the country at large. We intend to set an example in all dimensions of our entrepreneurial activities. We see ourselves committed to the self-defined models of economic, social, and ecological responsibility, which means not only economic success but also conscientious interaction with our Staff members, people, and the environment.

Our primary objective as a leading Exploration and Production (“E&P”) Company in Pakistan is to enhance our reserves and production profile and, ultimately, to maximize value for our shareholders. In order to achieve this goal, we are seeking to execute the following strategic goals:


  • 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


The Company respects the privacy of data relating to individual persons (whether employees or third parties) which it may hold or handle as part of its information processing activities or otherwise. Employees maintain confidentiality of the Company’s and its customers’ confidential information which is disclosed to them.

The Directors and Employees may not take advantage of the Company’s information or property, or their position


KPOGCL is instituting the following Whistle Blower (herein called “WB”) Policy as a result of requirements of Code of Corporate Governance-2013. KPOGCL has always had an informal open door policy for all Directors, employees, contractors and other stakeholders to discuss all matters pertaining to the operation and reporting of activities of KPOGCL.

Employees of entities are often the first to realize that there may be something seriously wrong with an organization. However, they may decide not to express their concerns because they feel that speaking up would be disloyal to their colleagues or to the organization. They may also fear harassment or victimization by the management. In these circumstances, they may feel it would be easier to ignore the concern rather than report what may just be a suspicion of malpractice or malafide.

This Policy document for KPOGCL makes it clear that employees can do so without fear of victimization, subsequent discrimination or disadvantage. This Whistle Blowing Policy is intended to encourage and enable employees to raise serious concerns within KPOGCL rather than overlooking a problem or seeking a resolution for the problem outside KPOGCL.

This Policy applies to all Directors and employees and those contractors working for KPOGCL. It is also intended to provide a method for other stakeholders (suppliers, customers etc.) to voice their concerns regarding KPOGCL’s business conduct.

The Policy is also intended as a clear statement that if any wrongdoing by KPOGCL or any of its employees or by any of its contractors or suppliers is identified and reported to KPOGCL, it will be dealt with expeditiously and thoroughly investigated and remedied. KPOGCL will further examine the means of ensuring that such wrongdoing can be prevented in the future.

What is Whistle-blowing?

Whistle-blowing can be described as giving information about potential illegal and/or underhanded practices i.e. wrong doing.

What is wrong doing?

Wrong doing involves any unlawful or illegal behavior and can include:

  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.

This list is not definitive, but is intended to give an indication of the kind of conduct which might be considered as “wrong doing”. Minor deviations shall construed “wrong doings”.

Who is protected?

This Policy is set in the context of the statutory provisions of Public Sector Companies (Corporate Governance) Rules, 2013. Any employee who makes a disclosure or raises a concern under this Policy will be protected if the employee:

  • 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?

Anyone with a complaint or concern about KPOGCL should try to contact their supervisor or manager responsible for the area which provides the relevant service. This depends however, on the seriousness and sensitivity of the issues involved and who is suspected of malpractice and therefore contact CEO directly. CEO Email and Cell numbers shall always be publically known.

How will KPOGCL respond?

KPOGCL will respond positively to the concerns of the complainant.

Where appropriate, the matters raised may:

  • Be investigated by management, the Board of Directors, or through a disciplinary process;
  • Be referred to the external auditor.

In order to protect individuals and those accused of misdeeds or possible malpractice, initial enquiries will be made to decide whether an investigation is appropriate and, if so, what form it should take.

Some concerns may be resolved by agreed action without the need for investigation. If urgent action is required, this will be taken before any investigation is conducted.

Within 30 calendar days after a concern is raised, the person contacted or a representative thereof will write to the complainant:

  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.

The amount of contact between the persons considering the issues and WB will depend on the nature of the matters raised, the potential difficulties involved and the clarity of the information provided. If necessary, KPOGCL will seek further information from the WB.

KPOGCL will take steps to minimize any difficulties which WB may experience as a result of raising a concern. For instance, if WB are required to give evidence in criminal or disciplinary proceedings, KPOGCL will arrange for the WB to receive advice about the procedure on best effort basis.

KPOGCL accepts that WB shall be assured that the matter has been properly addressed. Thus, subject to legal constraints, we will inform WB of the outcomes of any investigation.


Concerns will be investigated as quickly as possible. It should also be borne in mind that it may be necessary to refer a matter to an external agency and this may result in an extension of the investigative process. It should also be noted that the seriousness and complexity of any complaint may have an impact upon the time taken to investigate a matter. A designated person will attempt to indicate at the outset the anticipated time scale for investigating the complaint.


KPOGCL will not tolerate any attempt on the part of anyone to apply any sanction or detriment to any person who has reported to KPOGCL a serious and genuine concern that they may have concerning an apparent wrong doing.


KPOGCL will respect the confidentiality of any whistle-blowing complaint received by KPOGCL or Government of KP. However, it must be appreciated that it will be easier to follow up and to verify complaints if the complainant is prepared to give his or her name publically. In addition, confidentiality cannot be maintained if such confidentiality is incompatible with a fair investigation or if there is an overriding reason for identifying or otherwise disclosing the identity of the person making the complaint, or if disclosure of the identity of the complainant is required by law.

In the event that anonymity is requested the person should contact supervisor, manager or CEO by phone or email, who will give a case number and a time or times when he or she can call back for updates on the investigation of his or her complaint.


KPOGCL is proud of its reputation of adhering to high standards of honesty. It will therefore ensure that resources are put into investigating any complaint which it receives. However, it is important to realize that KPOGCL will view very seriously any allegations which prove not to be substantiated (unless made in good faith pursuant to this Policy) or which prove to have been made maliciously or knowing them to be false.

KPOGCL will regard the making of any deliberately false or malicious allegations by any employee of KPOGCL as a serious disciplinary offence, which may result in disciplinary action including dismissal for cause and pursuing civil remedies.