Anti Corruption Policy

The Management of Water & Sanitation Services Company Kohat realizes the importance of conducting Municipal Services with honesty, transparency and with good corporate governance. Therefore, the Company has retreated its responsibility and set up an Anti-Corruption Policy to prohibit employees and directors from accepting bribes or benefits for corrupt purposes to the benefit of themselves or others.

One of the guiding principles of the Company is “complying with anti-corruption laws”. The Anti-Corruption Policy extends on these principles to all Directors and Employees and any one acting on behalf of Water & Sanitation Services Company Kohat.

This Policy is developed under Code of Corporate Governance for Public Sector Enterprises issued by SECP.

• It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to Bribery and Corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery.
• We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate. We remain bound by local and national laws.

“Agent”: Any individual acting as an agent, paid by the company, acting on the company’s behalf in negotiating with Third Parties.

“Bribery” / “Corruption”: Bribery occurs when one person offers, pays, seeks or accepts a payment, gift, favor, or a financial or other advantage from another to influence a business outcome improperly, to induce or reward improper conduct or to gain any commercial, contractual, regulatory or personal advantage. It can be direct or in direct through Third Parties.

“Company”: Water & Sanitation Services Company Kohat.

“Conflict of Interest”: Occurs when an individual or organization is involved in multiple interests, one of which could possibly corrupt, or be perceived to corrupt, the motivation for an act in another.

“Donation”: A Donation is a voluntary contribution in the form of monetary or non-monetary gifts to a fund or cause for which no return service or payment is expected or made.

“Employee”:For the purposes of this policy this includes all individuals working at alllevels and grades, including senior managers, officers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff, home-workers, casual workers and agency staff, volunteers, interns, agents, sponsors, or any other person associated with us.

“Facilitation Payments”: A form of Bribery in which small payments are made with the purpose of expediting or facilitating the performance by a Public Official of a routine governmental action and not to obtain or retain business or any other undue advantage. Facilitation payments are typically demanded by low level and low income Public Officials in exchange for providing services to which one is legally entitled without such payments.

“Gifts, Invitations & Hospitality”: Invitations given or received to social functions, sporting events, meals and entertainment, gifts or customary tokens of appreciation.

“Intermediary”: Includes but is not limited to Agents, distributors, consultants, implementation partners.

“Kickback”:A bribe to obtain an undue advantage, where a portion of the undue advantage is ‘kicked backed’ to the person who gave, or is supposed to give, the undue advantage.

“Public Official”: Officials or employees of any government or other public body, agency or legal entity, at any level, including officers or employees of state-owned enterprises and officers or employees of enterprises which are mandated by a public body or a state-owned enterprise to administrate public functions.

“Sponsorship”: Sponsorship is about partnering with external organizations to deliver mutual benefits through an exchange of monies, products, services, content or other intellectual property.

“Third Party”:Any individual or organization you come into contact with during the course of your work for us. This includes actual and potential customers, suppliers, business contacts, Intermediaries, government and public bodies, including their advisors, representatives and officials, politicians and political parties.

1. This policy applies to all Employees and relevant Third Parties of the Company and shall be communicated to them at the outset of our business relationship and as appropriate thereafter.
2. This policy applies in all territories where the Company operates. Where local customs, standards, laws or other local policies apply that are stricter than the provision of this policy, the stricter rules must be complied with. However, if this policy stipulates stricter rules than local customs, standards, laws or other local policies, the stricter provisions of this policy shall apply.
3. This policy applies to the directors, officers, employees (whether permanent, fixed-term or temporary), technical and other consultants, agents, or any other person associated with or acting on behalf of the Company, wherever located (collectively referred to as “Representatives” in this policy).

1. This policy does not prohibit normal and appropriate hospitality (given and received) to or from Third Parties.
2. You are prohibited from accepting a gift or giving a gift to a third party in the following situations:
3. it is made with the intention of influencing a Third Party to obtain or retain business, to gain a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits;
4. it is given in your name and not in the name of the Company;
5. it includes cash or a cash equivalent (such as gift certificates or vouchers);
6. it is of an inappropriate type and value and given at an inappropriate time (e.g. during a tender process); and
7. it is given secretly and not openly.
8. We appreciate that the practice of giving business gifts varies between regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable, justifiable, and is proportionate. The intention behind the gift should always be considered.

1. In many jurisdictions, making Facilitation Payments is illegal. We do not make, and will not accept, Facilitation Payments or Kickbacks of any kind.
2. Where the facilitation payment is being extorted or you are being coerced to pay it and your safety or liberty is under threat or you feel you have no alternative but to pay for personal or family peace of mind, then pay the Facilitation Payment and report this to your line manager as soon as possible.

The responsibilities of Members of Board of Directors of Water & Sanitation Services Company Kohat who comes to possess, receives, obtains or comes across any information regarding involvement/indulgence of any director in corruption or corrupt practices directly or indirectly, or observe any action or activity on part of a director that falls within the ambit of corruption or corrupt practices as defined hereunder, to report the same to the Chairman of Board of Directors or his authorized representative. A failure on part of the Board Member in fulfilling this obligation will be deemed as abetment/connivance in the offense and will be cognizable under the Rules.

It will be the duty of every employee of the WSSC Kohat, who comes to possess, receives, obtains or comes across any information regarding involvement/indulgence of any employee in corruption or corrupt practices directly or indirectly, or observe any action or activity on part of an employee that falls within the ambit of corruption or corrupt practices as defined hereunder, to report the same to the Chief Executive Officer or authorized representative. A failure on part of the employee in meeting this obligation will be deemed as abatement/connivance in the offense and will be cognizable under the rules and regulations.

1. To give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;
   1. give, promise to give, or offer, a payment, gift or hospitality to a Public Official or Third Party to ‘facilitate’ or expedite a routine procedure;
   2. accept payment from a Third Party that you know or suspect is offered with the expectation that it will obtain any benefit;
   3. accept a gift or hospitality from a Third Party if you know or suspect that it is offered or provided with an expectation that a benefit will be provided by us in return;
   4. threaten or retaliate against another Employee who has refused to commit a bribery offence or who has raised concerns under this policy; or
   5. engage in any activity that might lead to a breach of this policy or perceived breach of this policy.
2. It is your responsibility to ensure that all accounts, invoices, memoranda and other documents and records relating to dealings with Third Parties, such as clients, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. No accounts must be kept ‘off-book’.
3. You must declare and keep a written record of all Gifts, Invitations & Hospitality according to Company practice accepted or offered, which will be subject to managerial review.
4. You must ensure all expense claims relating to Gifts, Invitations & Hospitality or expenses incurred to Third Parties are submitted in accordance with the Company’s expenses policy and specifically record the reason for the expenditure.
5. The prevention, detection and reporting of any form of Bribery & Corruption are the responsibility of all Employees. You must notify [HR MANAGER, of WSSC Kohat] as soon as possible if you are offered a bribe, are asked to make one, suspect that this may happen in the future, or believe that you are a victim of another form of unlawful activity.
6. All Employees have the responsibility to read, understand and comply with this policy. You should at all times, avoid any activity that might lead to, or suggest, a breach of this policy.
7. Any Employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct.
8. This policy should be read in conjunction with the Company’s Gifts, Invitations & Hospitality policy, Conflicts of Interest policy and Code of Ethics.
9. Employees are encouraged to raise concerns about any instance, or suspicion, of malpractice at the earliest possible stage through their line manager or other available reporting mechanisms.

Employees who refuse to take part in bribery or corruption, or report in good faith under this policy their suspicion that an actual or potential bribery or other corruption offense has taken place or may take place in the future will be protected from detrimental treatment/retaliation. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavorable treatment connected with raising a concern.

1. The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
2. Manager HR/Admin has primary and day-to-day responsibility for implementing this policy and for monitoring its use and effectiveness. Management at all levels is responsible for ensuring those reporting to them are made aware of and understand this policy and are given adequate and regular training on it. This training shall also be given to Intermediaries.

1. The Company will establish and put in place appropriate performance measures and reporting systems to monitor performance against metrics and compliance with the relevant policies, procedures and controls.
2. Manager HR/Admin will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness. Any improvements identified will be made as soon as possible.
3. Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective and will report to the CEO at least annually on the application of this policy.