“Integrity in Action – Speak Up for Transparency, Accountability, and Public Trust.”
1. Purpose
The purpose of this policy is to provide a transparent, secure, and confidential mechanism for employees and stakeholders of National Testing Service – Pakistan (NTS) to report genuine concerns regarding misconduct, irregularities, or unethical practices. This policy aims to promote integrity, accountability, and good governance across the organization.
2. Scope
This policy applies to:
- All NTS employees
- Consultants, vendors, service providers, and other stakeholders
- Any individual associated with NTS who becomes aware of reportable concerns
3. Reportable Concerns
Whistle blowing may include, but is not limited to:
- Financial mismanagement, fraud, or misuse of funds
- Suspected fraudulent activities, corruption, or potential conflicts of interest
- Violations of financial rules, or internal policies
- Irregularities in testing processes, results, or the handling of confidential information
- Abuse of authority or gross misconduct
- Any act causing reputational, financial, or operational risk to NTS
This Policy does not cover:
- Personal grievances or HR-related matters such as performance appraisal, promotion, transfer, or benefits and violation of PPRA Rules for which separate grievance mechanisms exist
- Complaints made with mala fide intent or without reasonable grounds
4. Guiding Principles
- Good Faith Reporting: Concerns must be raised honestly and without malice.
- Confidentiality: Identity of the whistleblower shall be kept confidential to the extent possible.
- Protection Against Retaliation: No employee shall face harassment, discrimination, or adverse action for raising a concern in good faith.
- Fair Process: All complaints will be examined objectively and impartially.
5. Reporting Mechanism
Concerns or complaints under this Policy may be reported to the Audit & Risk Management Committee (A&RMC).
Individuals may submit concerns or lodge complaints either in writing to the:
Convener of the Audit & Risk Management Committee of National Testing Service-Pakistan (NTS)
Treasurer Department, 3rd Floor, Faculty Block-2, COMSATS University Islamabad, Park Road, Tarlai Kalan, Islamabad, Pakistan.
or electronically through the designated email address: [email protected]
Complainants must disclose their identity and provide relevant contact details to facilitate acknowledgment, communication, and effective investigation of the reported matter. Anonymous complaints shall not be entertained under this Policy.
6. Information Required from Whistleblower
The whistleblower should provide:
- Description and nature of the concern
- Names and designations of persons involved
- Relevant dates, locations, and events
- Supporting documents or evidence, if available
The whistleblower is not required to prove the allegation but must have reasonable grounds for concern.
7. Investigation & Action
- All whistleblowing complaints shall be formally investigated by any officer/committee as directed by the Convener of the Audit & Risk Management Committee (A&RMC).
- An initial assessment shall be conducted to determine the admissibility, relevance, and scope of the complaint.
- Investigations shall ordinarily be completed within thirty (30) days from the date of commencement, unless an extension is warranted due to the complexity or nature of the matter.
- Where allegations are substantiated, appropriate corrective, disciplinary, administrative, or legal action shall be taken in accordance with the applicable laws, rules, and organizational policies.
8. False or Malicious Complaints
Deliberately false or malicious complaints may result in disciplinary action under applicable rules. This policy is not intended to substitute normal grievance procedures.
9. Protection of Whistleblower
NTS strictly prohibits retaliation against whistleblowers acting in good faith. Protection includes safeguards against dismissal, demotion, harassment, discrimination, or any adverse employment or contractual action.
Any individual found engaging in retaliation shall be subject to disciplinary action.
10. Oversight & Review
- The Audit & Risk Management Committee shall have oversight of this policy.
- NTS shall submit periodic summaries of whistle blowing cases to A&RMC.
- This policy shall be reviewed periodically to ensure effectiveness and alignment with best practices and regulatory requirements.
11. Policy Commitment
NTS maintains zero tolerance for fraud, corruption, bribery, conflict of interest, abuse of authority, manipulation of testing processes, or any violation of applicable laws, regulations, PPRA Rules, SECP directives, or internal policies. All employees and stakeholders are encouraged to speak up without fear in the best interest of the organization.