Code of Conduct - FAQs

Q.1 What is a Code of Conduct?

KE Code of Conduct sets out the standards required from employees and members of
Board of Directors. It is a document designed to help us understand the Organization’s
ethical expectations.

Q.2 Does this Code of Conduct covers KE Suppliers and Vendors?

KE sets out standards required from its suppliers and vendors to adhere to business
principles that are consistent with our own through the Suppliers Code of Conduct.

Q.3 How can we access The Code of Conduct?

Any employee can access this document at People Connect web link Policy
Repository Work Ethics (Code of Conduct).

Q.4 Can I access Code of Conduct via PC Mobile App?

Yes, Code of Conduct can also be accessed through People Connect Mobile Application.

Q.5 Is the Code of Conduct available in Urdu Language?

The Code of Conduct is available in both English and Urdu.

Q.6 What is the change in revised Code of Conduct?

The revised Code of Conduct is more comprehensive and provides clarity and depth of
information which was not available in the previous document.

Q.7 Is there any E-Module available for Code of Conduct?

E-Module for Code of Conduct is not yet available. KE has planned to launch an E-Module
for the same in the near future.

Q.8 What impact could a breach of Code of Conduct have for KE?

Breaching the Code or any of its policies can have serious consequences for KE and/or
its employees. Illegal conduct can lead to significant fines for KE, penalization of
individuals and significant damage to KE’s reputation.

Q.9 Whom to contact for interpretation of Code of Conduct?

In case of any uncertainty about how to interpret the Code of Conduct or have any doubts
about whether specific behaviors meet the standards required, you must seek advice from
your line
manager, HR Business Partner or seek clarity from the People Connect team. In case of
any difference of opinion or further clarification with respect to Code of Conduct the query
may be raised to HR Leadership Team (HRLT) through Employee Relations (AWAZ)
team at employee.advocacy@ke.com.pk

Q. 10 Is this Code of Conduct applicable on affiliates of K-Electric?

It depends upon the decision of the relevant board and management whether to adopt
this Code or develop one of their own.

Q.11 Whom to contact if I have concerns and/or grievances with reference to

the Code of Conduct?

If you have any concern and/or grievance with reference to this Code of Conduct, you
may communicate/ report along with the relevant details via following modes:

Email Address: employee.advocacy@ke.com.pk

Drop box facility: Hard copies can be dropped in person in designated AWAZ box.

You may raise your grievance though Awaz portal:

People Connect web link  Awaz Portal.

Q.12 What if you observe an actual or potential breach of Code of Conduct?

Employees must support and guide each other when they observe an actual or potential
breach of Code of Conduct. Even after the guidance and consultation if any colleague is
deliberately violating the Code, the matter should be immediately reported to the Line
Manager, Skip Manager and/or HR Business Partner. This may also include instances
where the external business partner’s behavior may not meet the same standards as
required by KE.

Q.13 Are KE employees allowed to work for own business, after office hours?

KE considers any secondary or dual employment in conflict with the best interest of the
company even after office hours. Therefore, secondary or dual employment is strictly
prohibited.

Q.14 Can an employee take part at Professional forums / groups such as PEC,
IEEE, ICAP, etc.?

Yes, however such participation must remain voluntary, should neither hinder job
performance nor result in conflict of interest as per the Code of Conduct.

Q.15 Is an employee allowed to write articles in newspaper in personal capacity?

Yes, however such writing / information sharing must not violate the Code of Conduct or
KE’s interest whatsoever.
 In a personal capacity, an employee may write on issues outside the scope of KE’s
business interest. The content must not violate the Code or KE’s interest whatsoever. It is
recommended that employees seek further clarity by emailing commsqueries@ke.com.pk

Q.16 What if I have an existing Family Business which is running even prior
joining duty at KE?

In case of existing family business, it is imperative that the employee discloses the
information to line manager and HRBP to seek clarity and ascertain possible conflict of
interest. In case of any further clarification HR (Employee Relations) will advise the
employee and line manager for an appropriate course of action.

Q.17 What about paid assignments or trainings? is KE employee allowed to

conduct paid teaching or training assignments after office hours?

Employees can take up ‘part time and without remuneration' teaching, learning, training,
coaching and educational assignments post obtaining written approval from the
respective CXO and CPO.

In case of ‘paid’ teaching, learning, training, coaching and educational assignments, prior
approval of Chief Executive Officer will also be required, however such paid assignments
are not encouraged in general. Following permission, employees are still restricted from
performing any work or assignments whatsoever during office hours on working days.

Q.18 Is engagement with any E-Commerce / online trade of commodities allowed

while employed with K-Electric?

Any such business activity is not allowed. However, sale / purchase of personal assets
and belongings is not prohibited after office hours / shift timings.

Q.19 Am I allowed to trade Shares / Securities / commodities in Stock Market while

employment with K-Electric?

KE respects its employees right to intelligently manage their personal Funds and
occasionally engage in such activity. However, any such engagement, on a regular basis
or in the nature of business, is not allowed during the designated business hours and shift
timings.

Q.20 Can employee pursue higher education, professional courses during

weekends / off days?

Yes, KE encourages its employees to upgrade their professional and personal skills /
qualification. However, it is imperative for an employee to ensure that it does not affect
the job goals / commitment.
Q. 21 Am I allowed to hold directorship in other companies?

KE employees are not allowed to hold directorships in other companies. This may lead to
conflict of interest on the part of employee and is discouraged.

Q.22 Am I allowed to take part in Political activities and/or secure position in a

Political Party?

KE does not take political positions or is associated with any political movements.
KE Employees may choose to offer support and contributions to political parties or groups
in their personal capacity and give no impression of being connected to KE whatsoever.
Their personal political support or contributions should not affect their performance or
objectivity at work in any way. They should not also secure any position in a political party
while employed with KE. No political activities shall be carried out while on official duty
during or after office hours on working/ off days and at any of the company premises
whatsoever.

Q.23 What is the Company policy on employment of relatives and family

members?

Relatives or family members of employees can be hired provided the appointment process
is based on merit, qualification, experience, and skills and there is no conflict of interest.

A "Family member" for the purposes of Code of Conduct is defined as one of the following:

Spouse, parent/step-parent, child/step-child, grandparent, grandchild, brother/brother-in-

law, sister/sister-in-law, uncle, aunt, nephew, niece, first cousin, in-laws (father, mother,
son daughter).

KE employees are required to disclose their relationship status based on above guidelines
at the time of hiring or during the recruitment process as well as during employment in
case of any change or update.

Q.24 Is dress code also part of the Code of Conduct?

There is a separate Dress Code Policy which outlines the organizational requirements for
a professional business attire at workplace.

Q.25 Can a Supervisor direct to act against the Company’s policy? Would it be
considered as a Conflict of Interest’?

A supervisor and any other official cannot direct to act against the Company’s policy.
If any personal gain is expected to a Supervisor or any other official out of his/her
directives, it will be considered as a Conflict of Interest.
Q.26 Would using Company’s manpower for one’s personal work would be
considered as violation of Code of Conduct? How Whistle Blow policy would be
applicable on it?

Using Company’s manpower for one’s personal work is a clear violation of Code of Conduct.
Any such concern may be communicated/ reported along with the relevant details at
speakup@ke.com.pk.

Q.27 What to do if you see a Conflict of Interest at workplace?

The Code of Conduct also provides some important questions to be asked to yourself
when faced with a potential conflict.

Existence of actual or perceived conflict of interest can be reported in writing along with
the relevant details immediately without any fear of repercussion to the immediate line
manager and/or skip level manager and/or HR Business Partner or at
speakup@ke.com.pk.

Q.28 Many departments request data to be shared with the external parties such
as academic institutions etc. Does the code of conduct support such sharing of
sensitive data along with the Non-Disclosure Agreement?

KE respects and maintains all sensitive information with due care which is confidential in
nature as per best industry practices. Customers, employees, and other related parties
need to feel confident that their personal data is processed and used for legitimate
business purposes only. If confidential information is to be shared with external parties, it
is to be ensured that that a written confidentiality agreement /Non-Disclosure Agreement
is in place.

Q.29 Can employee receive gift from suppliers / vendors of KE?

KE ‘s employees are not allowed to receive gifts if it obligates them to make decision /
affairs in favor off. Our relationships with suppliers, customers and others must be based
entirely on sound business decisions and fair dealing. Business gifts, entertainment and
corporate hospitality can help build relationships, but they can also make it harder to be
objective about the person or company providing them.

Unless otherwise expressly permitted, we do not offer or accept expensive or extravagant

gifts or business courtesies. Nor do we offer or accept any cash or cash equivalents as gifts
worth more than USD 20 or equivalent PKR to/ from the same supplier/vendor within any
calendar year.

Occasional business lunches and meetings outside the general office setting with
suppliers, customers and others do not fall under the ambit of Corporate Hospitality and
are only permissible if expressly approved in writing by immediate line manager. If there
is any reason to believe that certain gestures may influence business decisions in an
inappropriate manner, consult your line manager or skip manager.
Q.30 Can employee send gifts to stakeholders including Public Sector?

Sending gifts to any stakeholder is not allowed if it obligates or appears to obligate them
to act in favor of K-Electric.
Any demand for or offer of a bribe must be rejected immediately and reported to the line
manager and/or Employee Relations department in writing.

Please also refer response to Q.29 above.

Q.31 What is the acceptable value of gift that we may accept from Suppliers /
Vendors / Contractors / Client in compliance to Code of Conduct.

We cannot offer or accept any cash or cash equivalents as gifts worth more than USD 20
or equivalent PKR to/ from the same supplier/vendor within a calendar year.

Q.32 Is giving priority out of turn to stakeholder such as resumption of

electricity etc. considered as a violation of the Code of Conduct?

All customers are required to be treated on priority according to KE Values. However,

under genuine circumstances, priority out of turn should be duly disclosed and authorized
at defined levels.

Q. 33 Can an employee request / get prioritized any request of relative / friend

(customer) in KE’s system?

All customers are required to be treated on priority according to KE Values. However,

under genuine circumstances, priority should be duly disclosed and authorized at defined
levels.

Q. 34 Is an employee allowed to share KE’s official post that have been issued
through KE’s official accounts on social media?

Yes, if it is validated that same have been issued officially by KE for public domain.
However, sharing information or communication that has been disseminated for KE’s
internal affairs is strictly prohibited to be shared on social media whatsoever.
If unsure about any communication, submit a question to commsqueries@ke.com.pk.

Q. 35 Can employee respond directly to any negative propaganda against KE?

Employee are not authorized to respond directly on behalf of KE. However, any negative
propaganda may be reported immediately to commsqueries@ke.com.pk.

End of Document