For a safe workplace environment

February 18, 2024

SECP’s draft amendments underscore the necessity for listed companies to establish comprehensive anti-harassment policies

For a safe workplace environment


he Securities and Exchange Commission of Pakistan’s draft amendments to the Listed Companies (Code of Corporate Governance) Regulations, 2019, represent a significant step forward in the country’s efforts to combat workplace harassment. These amendments are designed to ensure that listed companies adopt more stringent measures to create a safe and respectful work environment for all employees, aligning corporate governance practices with the Protection Against Harassment of Women at the Workplace Act, 2010.

The amendments underscore the necessity for listed companies to establish comprehensive anti-harassment policies. This includes the development of a clear code of conduct, which is to be effectively communicated and accessible to all employees.

Such policies are aimed at protecting the rights and well-being of workers by fostering an inclusive and equitable workplace environment.

The proposed amendments require listed companies to ensure that their anti-harassment policies comply with the Protection Against Harassment of Women at the Workplace Act, 2010, and relevant provincial legislation. This includes the development of a code of conduct, forming an inquiry committee, appointing a competent authority and displaying the code of conduct for employees’ awareness and access. Pakistan has a legal framework aimed at preventing harassment at workplace, which includes the Protection Against Harassment of Women at the Workplace Act, 2010. This law defines harassment broadly and mandates the formation of inquiry committees by organisations to investigate complaints, showing that there is a legal basis for companies to build their policies upon.

A key feature of the amendments is the requirement for the formation of inquiry committees within the companies. These committees are tasked with investigating complaints of harassment, ensuring that all allegations are handled promptly and fairly. This mechanism aims to provide a safe channel for victims to report harassment without fear of retaliation or prejudice.

The amendments mandate the designation of a competent authority in each company, responsible for overseeing the implementation and adherence to the anti-harassment policies. This ensures accountability and a structured approach to managing harassment complaints.

In order to increase awareness and ensure transparency, the companies are required to display their code of conduct prominently. This must be done in English and in the language understood by the majority of the employees. The visibility of such policies is crucial for reinforcing the company’s commitment to maintaining a harassment-free workplace.

The SECP has opened these draft amendments for public consultation, inviting comments and feedback from various stakeholders. This participatory approach indicates the regulator’s commitment to inclusivity and the importance of collective input in formulating effective governance standards.

The proposed amendments have far-reaching implications for corporate governance in Pakistan. By integrating robust anti-harassment measures into the governance framework, the SECP is setting a precedent for responsible business conduct. This not only enhances the protection of employees’ rights but also contributes to building a more ethical and sustainable corporate landscape.


hile the draft amendments highlight a significant move towards strengthening anti-harassment measures in corporate governance, some companies have already been proactive in implementing anti-harassment policies to protect their employees. These measures are in line with the Protection Against Harassment of Women at the Workplace Act, 2010, and show a growing awareness and responsibility towards creating safer and more inclusive workplace environments.

It is common practice for multinational corporations and larger domestic companies in Pakistan to have such policies in place, given their global compliance requirements and a growing local emphasis on corporate ethics and employee safety.

Moreover, the private sector is increasingly recognising the importance of these measures as part of its corporate social responsibility initiatives. For example, Nestle Pakistan has a code of conduct for employees that mandates that during the discharge of official duties in the office, all functionaries should follow official decorum. It states that the language should be civilised and simple, and that words and sentences having more than one meaning should be avoided.

It also imposes a dress code. Casual dress is prohibited. Additionally, unnecessary visits to women’s workplace and near women’s washrooms are prohibited. It says that staring is a menace and to be avoided.

Assignment of duties after regular office hours and duties on holidays for women are to be approved by the head of department. Nestle prohibits any action tantamount to harassment of its female employees and treats it as a serious offence leading to disciplinary action under the code of conduct against the offenders.

Finally, it advises all female employees to lodge a complaint immediately to the head of Human Resource Department who will refer the matter to the inquiry committee for investigation and submission of report along with recommendation. The head of HR is the competent authority for taking all decisions in such matters.

The drive towards implementing and enhancing anti-harassment policies in Pakistan is part of a broader effort to ensure a safe, respectful and inclusive work environment. This is crucial not only for the well-being of employees but also for fostering a positive organisational culture that can contribute to the overall success and reputation of businesses in Pakistan and beyond.

The emphasis on accountability, transparency and inclusivity in these amendments marks a significant advancement in Pakistan’s corporate governance standards, potentially serving as a model for other regions grappling with similar issues.These amendments represent a proactive approach by the SECP to align corporate practices with international standards for protecting employees from harassment, thereby promoting a healthier and more productive workplace environment.

However, for stricter implementation, a compliance mechanism must also be formulated with penalties in place.

The writer is an advocate of the High Court, a founding partner at Lex Mercatoria and a visiting teacher at Bahria University’s Law Department. She can be reached at

For a safe workplace environment