Code of Conduct

1. Our Core Values

Our Code is rooted in five fundamental values that define who we are and how we work:

2. Compliance with Laws and Regulations

We comply with all applicable laws, rules, and regulations in every jurisdiction where we operate. This includes, but is not limited to, laws governing anti‑corruption, labour, environmental protection, data privacy, competition, trade sanctions, and financial reporting. If a conflict arises between local custom and this Code, the higher standard (or the law, if applicable) prevails.

3. Conflicts of Interest

A conflict of interest occurs when personal interests interfere, or appear to interfere, with the interests of Brackly Group. Employees must avoid situations where personal, family, or financial interests could influence their judgment or actions on behalf of the company. Examples include:

• Hiring or supervising a family member or close friend.
• Owning a significant financial interest in a supplier, customer, or competitor.
• Accepting gifts, entertainment, or favours that could create a sense of obligation.
• Using company property or information for personal gain.

Any actual or potential conflict of interest must be disclosed immediately to your supervisor or the Compliance Officer.

4. Gifts, Entertainment, and Hospitality

Modest, infrequent gifts and business entertainment may be accepted if they are customary, not cash, and do not create an improper influence. You may not offer or accept gifts that violate any law or that could reasonably be seen as a bribe. The following rules apply:

• Gifts with a value exceeding PKR 5,000 must be reported to HR.
• Cash or cash equivalents (gift cards, vouchers) are strictly prohibited.
• Any gift from a government official must be declined or reported immediately.

5. Anti-Bribery and Anti-Corruption

Brackly Group has zero tolerance for bribery and corruption in any form. We comply with the National Accountability Bureau (NAB) Ordinance, 1999 of Pakistan, the UN Convention Against Corruption, and applicable international anti‑bribery laws (e.g., UK Bribery Act, US FCPA). You may not:

• Offer, promise, or give anything of value to influence a business decision or obtain an improper advantage.
• Request or accept any undue payment, kickback, or favour.
• Use intermediaries (agents, consultants) to circumvent anti‑bribery laws.

6. Workplace Conduct and Human Rights

We are committed to providing a safe, respectful, and inclusive workplace free from harassment, discrimination, and retaliation. Every employee has the right to:

• Work in an environment free from harassment (including sexual harassment, bullying, and intimidation).
• Equal opportunity regardless of race, religion, colour, gender, age, disability, sexual orientation, or any other protected characteristic.
• Fair wages, reasonable working hours, and freedom of association as permitted by local law.
• Report concerns without fear of retaliation.

We prohibit child labour, forced labour, and human trafficking in all operations and supply chains, in alignment with the UN Guiding Principles on Business and Human Rights and Pakistan’s labour laws.

7. Confidential Information and Data Privacy

Employees must protect the confidential and proprietary information of Brackly Group, its clients, and partners. This includes trade secrets, business strategies, financial data, customer lists, and any non‑public information. Confidential information may not be shared with unauthorised persons, even after employment ends. We also respect the privacy of personal data in accordance with our Privacy Policy and applicable data protection laws.

8. Use of Company Assets and Resources

Company assets (including computers, equipment, facilities, and software) are provided for legitimate business purposes. Limited personal use is permitted if it does not interfere with work, consume excessive resources, or violate any policy. Employees must not:

• Install unauthorised software or access inappropriate content.
• Use company systems to engage in illegal or unethical activities.
• Remove company property from premises without authorisation.

9. Health, Safety, and Environment

We are committed to providing a safe and healthy workplace and minimising our environmental impact. Employees must:

• Follow all health and safety rules and report hazards or incidents immediately.
• Conserve resources and support our Sustainability Pledge 2030.
• Not work under the influence of alcohol or illegal drugs.

10. Fair Competition and Anti-Trust

We compete fairly and ethically in all markets. Employees must avoid any conduct that could be perceived as anti‑competitive, including price fixing, market allocation, bid rigging, or exchanging sensitive information with competitors. Violations of competition laws can result in severe penalties for both the company and individuals.

11. Reporting Violations (Whistleblowing)

All employees and stakeholders have a duty to report suspected violations of this Code or any illegal conduct. You may report concerns to your manager, the Human Resources department, or the Compliance Officer. Anonymous reporting is available via our Ethics Helpline (details below). Brackly Group strictly prohibits retaliation against any individual who makes a good‑faith report. Retaliation is itself a violation of this Code and will result in disciplinary action.

12. Enforcement and Discipline

Violations of this Code may result in corrective action, including counselling, suspension, demotion, termination of employment, and legal proceedings. Managers who condone or fail to report violations may also be subject to discipline. All employees are required to acknowledge their understanding of this Code upon hiring and annually thereafter.

13. Contact and Resources

For questions, clarifications, or to report a concern, please contact:

We are all responsible for upholding the highest standards of conduct. Thank you for your commitment to integrity and excellence.