Anti-Bribery and Corruption Policy Statement & Whistle Blower Policy Explanation

Anti-Bribery and Corruption Statement:

Summit Corporation Limited (formerly Summit Industrial & Mercantile Corporation (Pvt.) Ltd. (SIMCL)) & its subsidiaries are committed to complying with all applicable laws and best corporate governance practices, wherever we operate. It is a core aspect of our mission to act with integrity in all of our operations. The Board of Directors of Summit Corporation Limited expects all employees to comply with both the letter and the spirit of the law and governance codes.

Summit & its subsidiaries affirm that they will not pay or procure the payment of a bribe or unlawful fee to encourage the proper performance of a task or one which is intended or likely to compromise the integrity of another. We will not accept any payment, gift or inducement from a third party which is intended to compromise our own integrity.

Summit & its subsidiaries have communicated this policy to all its employees, to ensure that their commitment to integrity and legal compliance is followed. When contracting with a third party, we will insist that they acknowledge our commitment to good governance and that they in turn require the same high standards of those they engage.

Any person who believes that Summit & its subsidiaries or its staff are involved in bribery and corruption is encouraged to report their concerns to Ms. Ayesha Aziz Khan, Responsible Director.


Whistle Blower Policy Explanation:

The Policy consists of three Principles and a series of Practical Procedures to give effect to those Principles. The objective of the Policy is to provide a framework to promote responsible and secure whistle-blowing.

The Principles

1. Summit welcomes whistle-blower reports and encourages staff and third parties to draw to its attention instances of corporate wrong-doing within the Summit group of

companies (as defined below a "Disclosure" );

2. It will appropriately investigate and act upon such disclosures;

3. Summit regards attempts to victimize or discriminate against a Whistle-blower as potentially gross misconduct.

Guidelines for disclosure:

A Disclosure should be made in writing to Ayesha Aziz Khan with the issues clearly and unambiguously set out. The Whistle-blower should identify themselves in the disclosure. Anonymous disclosures may prove difficult to substantiate and will be harder to follow.

A Disclosure is not intended to replace an employee's duty to keep their supervisors and managers properly informed on a day to day basis of matters which should be of concern to them or are relevant to the performance of their job. It is intended to be used where an employee has serious and justified doubts about the willingness or ability of that supervisor or manager to act appropriately upon such information.

A "Disclosure" is a concern raised in writing and made in good faith that discloses or demonstrates information that may evidence serious unethical or improper activity within Summit (or a company in its group) and its and their business or practices.

A Disclosure should be factual and not speculative and should contain as much specific information as possible to allow for a proper assessment of the nature and extent of the concerns. A Disclosure could concern malpractices and events which are taking place or are suspected or known to have taken place.

Examples include:

a) abuse of authority;

b) manipulation or falsification of company data or records;

c) financial or compliance irregularities, including fraud, suspected fraud, bribery or corruption;

d) criminal offence having an impact on the group operations or its reputation;

e) deliberate violation of law or regulation;

f) any other unethical behaviour.

This policy relies upon the good faith of staff and it should not be used as a mechanism for raising malicious or unfounded allegations against colleagues. Such practices may themselves be grounds for disciplinary proceedings.

For Third Parties:

Disclosures (as defined above) may come from third parties who are unconnected with Summit. They must be passed to Ayesha Aziz Khan immediately.



Summit condemns any kind of discrimination, harassment or victimization of a Whistle-blower. Summit will provide best effort that:

a) the identity of the Whistle-blower is kept confidential and only disclosed on a need to know basis;

b) papers relating to a DiscIosure are filed carefuIly away and access to e mails and electronic files restricted by the use of an appropriate password so as to avoid the accidental disclosures of a Whistle-blowers identity;

c) instances of victimization of a Whistle-blower are treated as a serious matter which may give rise to disciplinary action by Summit against any person(s) causing or allowing such victimization.

These protections may be lost if a disclosure is not made in good faith.