Ethics Protocols

Policy Documents

Incidents of Wrong-doings

Aurat Foundation will entertain and deal with any complaint, received through any means as highlighted on this page, in accordance with principles, rules and procedures laid down in the Whistleblower Policy. The Whistleblower Policy covers the following perceived situations/complaints/wrong-doings:

• Fraud – such as theft or misuse of AF's funds or other resources by an employee or a third party; falsification of costs or expenses; forgery or alteration of documents; destruction or removal of documents; paying of excessive prices or fees to third parties with the aim of personal gain.
• General malpractice – such as illegal or unethical conduct (including where someone's health & safety has been put in danger).
• Gross misconduct – such as blackmail, extortion or physical abuse.
• Infractions of AF's policies, including the Conflict of Interest Policy.
• Infractions of applicable laws.

Dealing with Malicious Whistleblowing

All whistleblowing disclosures made to the Ethics Committee will be treated as confidential, unless the Committee concludes that the allegations were malicious, mala fide or not in good faith.

Examples of malicious whistleblowing include, but are not limited to, allegations that are based on:

• Misogyny (e.g. not wanting to report to, or work with, a member of the opposite sex).
• Religious or cultural beliefs.
• Hearsay.
• Personal dislike or dispute.
• Documents that are either subject to forgery (e.g. email threads, photocopies etc.) or lie outside the legal ambit (e.g. telephone transcripts obtained from phone companies without a warrant).

Frequently Asked Questions about Whistleblowing

A. Definition of Whistleblowing

What is Whistleblowing?
Whistleblowing is a confidential disclosure by an individual, or group of people, of any concern encountered in the workplace relating to a perceived wrongdoing.

What is the difference between whistleblowing and making a complaint?
Whistleblowing occurs when a worker raises a concern about danger or illegality that affects others. A complaint is made when someone has personally been poorly treated and is seeking redress for themselves. Complainants are expected to prove their case, whereas whistleblowers are not.

B. Procedures to be followed by the Whistleblower

Can concerns be raised confidentially or anonymously?
The best way to raise a concern is openly. Confidential reporting is accepted. However, anonymous calls or emails sent fictitiously will not be entertained.

What information should a whistleblower provide?
State facts with as much specific information as possible. Key questions to answer include:

• Identify the person(s) engaged in the wrongdoing.
• Is management involved or aware of the problem?
• What is the nature, location, and duration of the incident?
• How did you become aware of the violation?
• Provide details of witnesses or other valuable evidence.

Is there a deadline for filing a report?
No, but it should be reported as soon as possible after discovery.

How can the whistleblower help (and what should they NOT do)?
The whistleblower should provide facts and be prepared for interviews.
Crucially: The whistleblower should NOT conduct their own investigation or obtain evidence they do not have a legal right to access.

Will the whistleblower be informed of the outcome?
Generally, yes, you have the right to know the findings. However, specific disciplinary actions taken against an employee are confidential and may not be disclosed.

C. Retaliation & Protection

What if there is retaliation?
AF policy prohibits discharge, demotion, suspension, threats, or harassment against any staff reporting in good faith. If you feel you are being retaliated against, you may file a written complaint with the Human Resources department within 12 months of the incident.

What happens if the allegations are unsubstantiated?
If you made a good faith report based on reasonable belief, you are protected. However, if a whistleblower knowingly makes a false or malicious allegation, they may face disciplinary action, including dismissal.

D. Procedures for the "Subject" (The Accused)

Does the accused person get to explain themselves?
Yes. An investigation is a neutral fact-finding process, not an accusation. The subject will be given opportunities to respond to material evidence before a report is finalized. The subject also has the right to consult a lawyer.

E. Procedures for Managers

If a Manager at any level receives a whistleblower disclosure from an employee, partner, vendor, or grantee, they must handle it with utmost care and immediately refer it to the Ethics Committee.

Anti-Fraud Complaint Form

Ethics Committee and its Role

The Ethics Committee is a three-member committee based at the head-office. It comprises two national level directors and the head of the Internal Audit.

The HR Manager serves as the secretary of all meetings and is kept in the loop by the Ethics Committee throughout the proceedings of every case. The present Ethics Committee includes:

1. Ms. Mumtaz Mughal, Director Programmes (mmughal@af.org.pk)
2. Ms. Muneezeh Khan, Resident Director, Karachi (rdkhi@af.org.pk)
3. Mr. Asim Malik, Director Outreach and Network (asim@af.org.pk)

The HR department is responsible for maintaining the record and documentation of all such proceedings. If any one of the members of the Ethics Committee is the subject of a whistleblower's allegations, then he or she will be replaced on the Committee for that specific case.

After conducting investigations, if the Ethics Committee feels that the issue raised by the whistleblower is critical to the operations of AF and threatens to have pervasive negative implications, the Committee will escalate the matter to the Board of Governors through the Finance, Audit and Human Resources Committee of the Board for further deliberation. The decision of the Board will be considered final.