IIL is committed to the highest standards of honesty, integrity, transparency and accountability through its code of conduct. The Company’s Whistleblowing Policy encourages and enables all employees and volunteers, to come forward and voice their concerns in good faith within the Company rather than overlooking a problem or 'blowing the whistle' outside.

The Whistleblowing Policy does not apply to employees’ career-related grievances pertaining to promotions, transfers, relocations, compensation, allowances, benefits training and development etc. for which a separate procedure exists.

Matters to report may include but not limited to Fraud, conflict of interest, improper sales promotion and improper sales practices, harassment, discrimination and workplace violence, privacy breach, protection of confidential and sensitive information, misuse of company’s assets and insider trading, bribery, corruption, abuse of authority, breach of applicable laws, non-compliance with corporate governance and misuse of IT systems.

The Company shall ensure that disclosures made by Whistleblowers are evaluated and investigated objectively, and concluded in a fair, timely, and documented manner, while maintaining confidentiality and protection of the Whistleblower.

The Company shall guarantee the anonymity of Whistleblowers. Employees may responsibly report anonymously, however employees are encouraged to report by identifying themselves as this will help in the investigation process.

Any employee or volunteer wishing to report a matter of concern shall approach the Chairman Board Audit Committee directly via email address chairman.bac@iil.com.pk which is accessed only by the Chairman-BAC.

Each concern received is to be logged and assigned a code that will be used in the subsequent investigation and reporting of the concern.

Chairman Board Audit Committee shall be responsible for the implementation of this policy and may utilize the members of the Management Team or the independent auditor in case of any investigation.

Whistle blowers shall receive appropriate and timely feedback regarding the status and, where permissible, the outcome of their disclosure, subject to legal, confidentiality, and privacy obligations.

Where a reported concern is determined to be unsubstantiated, or where the information provided is insufficient to enable a proper assessment or investigation, the matter may be closed. In such instances, reasonable efforts may be made to seek additional information from the whistle blower (where their identity is known).

If, despite such efforts, the information remains incomplete or inadequate to proceed, the case shall be formally closed and documented accordingly. Closure of a case due to insufficient evidence shall not, in itself, be construed as evidence of bad faith on the part of the whistle blower.

The EMT / independent auditor shall take steps to minimize any difficulties which a Whistle blower may experience as a result of raising a concern.

The Board Audit Committee shall, for the period ending June 30 and December 31 of every year, submit to the BOD a list of matters reported by Whistleblowers during the period, together with the outcome of the probe or inquiry conducted therein and comments on the protection of the Whistleblowers.