Whistleblowing

Raise your voice!!

Raise your voice is the act of reporting
concerns about malpractice, wrongdoing or fraud

In this policy ‘Raise your voice’ means the reporting by employees of suspected misconduct, illegal acts or failure to act within standards of moral and ethical boundaries.

The "Raise Your Voice Policy" is designed to foster a culture of openness, accountability, and trust within the mall. It encourages employees, tenants, contractors, and other stakeholders to confidently voice serious concerns about any aspect of the Company’s operations, practices, or conduct without fear of retaliation.

By speaking up, individuals play a vital role in upholding the LLM’s integrity, safety, and commitment to excellence.

Your Voice, Your Duty:
A Guide to Ethical Whistleblowing

Email
raiseyourvoice@luckyone.com.pk

To qualify for protection under the Whistleblowing Policy, a worker making a disclosure must reasonably believe two key conditions are met:

Acting in the Organization’s Interest

The worker must reasonably believe that their disclosure is made in the public interest or in the best interest of the organization. This means that personal grievances, individual complaints, or matters related solely to private interests are generally not covered under this policy.

Evidence of Wrongdoing:

The worker must reasonably believe that the disclosure reveals or tends to reveal past, present, or likely future wrongdoing. Such wrongdoing may fall into one or more of the following categories:

Criminal activities
Breaches of legal obligations
Miscarriages of justice
Threats to health and safety
Damage to Company property or the environment
Financial misconduct, including fraud or corruption
Deliberate concealment of any of the above

By meeting these criteria, the worker’s disclosure will be considered a protected act under the Whistleblowing Policy, ensuring they are safeguarded from retaliation and that their concern is addressed appropriately.

Aim & Objective of this policy

The "Raise Your Voice" Policy is designed to create a safe, supportive, and transparent environment where employees and stakeholders can voice concerns about wrongdoing, malpractice, or unethical behavior without fear of victimization, discrimination, disadvantage, or dismissal. It aims to foster a culture of accountability, integrity, and trust within the organization, ensuring that serious concerns are addressed promptly and effectively. This Policy seeks to:

Empower Confidence

Encourage you to feel secure in reporting concerns early and taking action on unethical practices, misconduct, or risks to the company or stakeholders.

Provide Clear Avenues

Provide accessible, confidential ways to report issues and ensure you get timely feedback on actions taken in response.

Ensure Accountability

Ensure your concerns are taken seriously, addressed properly, and that you are informed of the outcomes with options for escalation.

Protect from Reprisals

Assure you that you are protected from any form of backlash if your disclosure is made in good faith for the company or public good.

Promote Internal Resolution

Encourage raising concerns within the company to resolve issues internally, fostering trust, transparency, and effective resolution.

By upholding these principles, the "Raise Your Voice" Policy reinforces our commitment to ethical practices, accountability, and the well-being of all employees and stakeholders.

Scope of this policy

The "Raise Your Voice" Policy is designed to empower employees, contractors, and stakeholders to report concerns about wrongdoing, malpractice, or unethical behavior within the organization that may affect others, services, or the organization as a whole. It encourages individuals to raise such concerns at the earliest opportunity to ensure they can be thoroughly investigated and addressed.

What This Policy Does Not Cover

This policy is not intended to replace existing procedures for other types of concerns. Specifically:

Employee Grievances

01

If your concern relates to your own treatment as an employee (e.g., workplace conflicts, harassment, or personal grievances), please raise it under the organization’s Grievance or Harassment Policy.

Customer Complaints

02

If a mall customer has a concern or complaint about services provided, it should be addressed through the Customer Services Department as per standard practice.

Employee Misconduct

03

Complaints regarding employee misconduct should be reported under the Disciplinary Procedures. For further details, please contact the HR Department.

What Should Be Reported Under "Raise Your Voice

This policy encourages employees to report any suspected breaches of the organization’s Code of Conduct, policies, or legal obligations. Violations that should be reported include, but are not limited to:

Legal and Regulatory Violations

Breaches of laws, regulations, or industry standards.

Conflict of Interest

Situations where personal interests may improperly influence professional decisions.

Criminal Offenses

Illegal activities conducted within or against the organization.

Fraud

Any act of deception for personal or organizational gain.

Financial Misconduct

Misrepresentation, falsification, or misstatement of financial records, accounting fraud, or improper financial practices.

Discrimination and Harassment

Unfair treatment, bullying, or harassment based on race, gender, age, religion, or other protected characteristics.

Miscarriages of Justice

Unfair or improper treatment in organizational processes or decisions.

Bribery and Corruption

Offering, accepting, or soliciting bribes, kickbacks, or under￾the-table commissions.

Health and Safety Risks

Actions or negligence that endanger the health, safety, or well-being of individuals.

Providing False Information

Deliberately supplying incorrect or misleading information.

Environmental Damage

Practices or activities that harm the environment or violate environmental regulations.

Cover-Ups

Deliberate attempts to conceal or ignore wrongdoing in any of the above categories..

No Disciplinary measures on account of good faith Reports

It is a fundamental principle of our policy that employees who file reports in good faith will not face any adverse consequences, retaliation, or disadvantage as a result. We are committed to protecting and supporting those who raise genuine concerns about wrongdoing or malpractice within the organization.

However, employees are encouraged to ensure the accuracy and legitimacy of their reports before submitting them. This helps maintain the integrity of the reporting process and ensures that resources are focused on addressing valid concerns.

By fostering a culture of accountability and trust, we aim to empower employees to speak up while upholding the highest standards of professionalism and ethical conduct.

The Policy

Everything we do is built on the foundations of integrity and responsibility. What does this mean exactly? It means that whichever business activity we are involved in, we stick to our principles and insist on fairness and honesty.

As an employee, you have a personal responsibility to be aware of our Company’s and Values and business principles – and all employees are expected to live up to these standards of behavior.

Channels of Reporting

Raise your voice! Report can be lodged through the following methods:

Contact Line Management or the Human Resource Department:

In principle, all employees are encouraged to discuss such matters with their reporting Managers or, in cases where this line of communication is constrained, with the next higher-level manager or directly with the Human Resource Department via email HR@luckyone.com.pk marking the subject as “Raise your voice”.

In certain cases, reporting of alleged violations of the Code of Conduct or Company policies through the employee’s hierarchical line may not be a viable option in the employee’s best interest. Thus, employees can use any of the following methods to report incidents: raiseyourvoice@luckyone.com.pk

To file a report, please contact us through one of the following confidential channels:
Email: raiseyourvoice@luckyone.com.pk
Mail: Send a sealed letter marked ‘Confidential & Raise your voice’ to the CEO.

All reports will be carefully verified and thoroughly investigated while maintaining strict confidentiality throughout the process. Your privacy and protection are our top priorities.

Emails sent to raiseyourvoice@luckyone.com.pk will be received by CEO and the Chairman of the Board HRC.

What happens after you file a Raise your voice! Report?

a) If you file a Report through your line management and/or HR, your Report will be dealt internally with strict confidentiality.

b) If you file a Report through the channel of raiseyourvoice@luckyone.com.pk, The CEO will confidentially investigate the matter or put together an investigation team depending on the nature of the Report.

When you file a Raise your voice Report outside the hierarchical boundaries, either by phone or by email, you will be given an acknowledgement via email (in case of letter, only if a return address is provided).

After you file a Report outside the hierarchical boundaries, an investigation will be initiated to verify the report to confirm its authenticity. If you provide your name, an investigator may contact you to discuss your concerns. Alternatively, you can contact the reporting person, depending upon the channel used for logging your Report, after 10 working days of filing the Report to see if additional information is required to address your concern.

c) The decision to proceed with or reject a report for further investigation will be made at the sole discretion of the CEO. This decision will be based on the merits of the report, its alignment with the organization’s policies, and the availability of sufficient information to warrant an investigation. Every report will be carefully reviewed to ensure fairness, transparency, and adherence to the principles of the "Raise Your Voice" Policy.

A written summary of the investigation or any actions taken will be shared with the Board HRC to ensure good governance. Depending on the nature of the Report and the extent of investigation required, the Reporting Employee will be provided with a written summary of the results of the investigation normally within eight (8) weeks from the date of filing the incident.

We encourage you to speak up, as any suppression of an employee’s right to speak up itself is a violation of our code. There will be no repercussions for anyone reporting a violation in good faith, even if it turns out to be unfounded. However, we encourage that you try to ensure the legitimacy of the Report on your end before filing it. If you choose to stay anonymous while logging a Report, do understand that it may affect the ability to fully investigate your Report.

Note: Please do not use the Raise your voice! procedure to report emergency incidents. If you require emergency assistance,
Contact your local emergency services, HSE manager or follow local site procedures.

If you have any questions or issues about interpreting the policy,
Contact the General Manager – Human Resources.
hr@luckyone.com.pk

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