Policy, Values and Principles
Accountability Bureau (NAB) has been established to eradicate corruption
from the country, under National Accountability Ordinance 1999, as
amended from time to time.
Accountability Ordinance 1999 confers extra ordinary powers on the
Bureau to eradicate corruption from the society. The immense
responsibility so assigned makes it imperative that such powers must be
exercised properly, fairly and maintaining very high standards of
The Bureau has three principal functions:
This Code of Conduct and Ethics lays down the general
provisions of conduct and interaction which must be followed by all
employees of NAB, while performing their professional duties at work as
well as operating outside their offices.
The purpose of this code is also to create a professional
and efficient work environment in NAB; develop mutual cooperation and
trust of the employees towards their co-workers; enhance the esteem of
NAB staff and make efforts to protect the individual, society and the
state from corruption.
As an employee of NAB, you hold a special position of trust
and the image of NAB could seriously be damaged if such trust is
betrayed in any form.
The Code should not be read as a set of rules, or the words
should not be interpreted for their legal meaning. It is intended to
simply convey the obligations placed on and the behaviour expected of
all the employees of NAB whether permanent, on contract, or engaged by
virtue of any other terms and conditions.
This Code of Conduct and Ethics will be reviewed
periodically and updated to reflect the changes occurring both within
and outside NAB.
Core Values of NAB
To do the right thing the right way and at the right
Being honest and responsible
Focus on what is right for both the organization and
High moral and ethical standards
Commitment to cause
Sincerity of purpose
Reliable in performance of duty
Responsible for the assigned job
Weighing facts for the right course of action
Sound decisions, without missing the details
Completion of task without generating hostility
Courtesy and respect to others
Discreet to avoid embarrassments or defamation
Ability to do what needs to be done regardless of
fear or risk
Resolute and firm in dispensing one’s duty
Overcome difficulty with dignity
Ability to foresee the problem
Initiative to suggest the right action
Being impartial and consistent to apply reward and
Fair in discharge of duties
Avoiding favoritism and nepotism
What principles guide the Code of Conduct?
The Code of Conduct and Ethics is guided by the following principles,
which should also assist you in guiding your conduct and taking
decisions in your day to day work:
At all times, you should be aware that your
employment carries an obligation to have due regard to the impact of
your professional and personal conduct on NAB’s standing and
At a minimum, you must meet the standards of ethical
behaviour and accountability that NAB promotes in its dealings with
other organizations and individuals.
You have an obligation to carry out your work
professionally, impartially, with integrity and in the best
interests of the society at large, keeping in view the
constitutional principles of policy.
You are also required to deal with individuals and
organizations fairly, recognizing their rights as citizens.
Discrimination and partiality, either within NAB or in dealings with
people and organizations outside NAB, constitutes violation of the
constitutional fundamental rights of people.
The name and powers of NAB must be used with
restraint, and with an awareness of their potential effect upon
others. These must never be used to gain personal advantage or
pursue personal issues.
The work of NAB must not be compromised or affected
by any personal interest.
Public resources must be used efficiently and
The security of information about the persons working
with or dealing with NAB must be considered.
confronted with an issue of ethics and conduct, you are obliged
to be mindful of the principles and guidance provided in
this Code. If still uncertain about what course of action to take,
advice should be sought from appropriate officer of NAB.
When you are faced with an ethical dilemma, ask yourself the
Is it legal?
Is it consistent with NAB’s values, principles and
Do I think it is the right thing to do?
What will be the consequences of my decisions and
actions for my colleagues, NAB, other parties, and myself?
Can I justify my actions?
What would be the reaction of my family and friends
if they were to find out?
What would happen if my conduct becomes front page
1.4. Main concepts of terminology used in the Code of Conduct and
purpose of this “Code of Conduct and Ethics”, the following terms used
in the code are to be construed to imply as under:
The NAB employees include all the personnel
working in the NAB in any capacity or under any terms and conditions.
The NAB officer (BPS-17 and above) is a Govt
Servant appointed to a certain position at the National Accountability
Bureau to discharge the functions of the NAB, endowed with
administrative powers appropriate to his or her position.
Public interest means the
public’s rights and expectations with regard to impartial and just
decision-making and relevant actions in public service.
Private interest means private
economic or non-economic interest of persons in service or their close
relatives or other associates, which may affect their decision making in
the discharge of the official duties.
Conflict of interests is a
situation in which an employee’s “private interests” interfere with the
proper discharge of his official duties because of the divided
Defamation is an intentional
false communication, either published or publicly spoken, that injures
another’s reputation or good name.
NAB leadership is the NAB
officers BPS-17 and above.
Close relatives are parents,
children (adopted children), natural brothers and sisters, grandchildren
Advantage, refers to almost any
thing which is of a value.
What does the employment in NAB
require of its employees?
Appointment as a NAB employee is made under the
powers conferred by NAO 1999, with conditions of employment governed
by the policies and practices issued from time to time.
The employment in NAB demands a commitment from the
employees to practice certain values in the interactions with other
public sector agencies, other organizations, individuals and the
staff. These commitments include advancement of the public interest;
acting ethically and with integrity; being fair, impartial and
accountable; striving for excellence in our work, being tenacious
and professional in our aims, respecting colleagues and working as a
As an employee of NAB, you have an obligation
to be aware of and comply with this Code of Conduct and Ethics. By
accepting employment with NAB, you have undertaken:
Not to engage in personal or professional conduct
that may bring NAB into disrepute.
To abide by the secrecy and confidentiality
provisions of the NAO and policies of NAB.
To fully and openly disclose your personal
particulars and your financial and other interests to NAB, and
to apprise NAB of any significant changes in your personal or
Members of staff who are seconded to NAB from other
organizations/agencies, or who are engaged temporarily on contract
of any form, have an equal responsibility to abide by the standards
and behaviour outlined in the Code.
Officers and staff members should be continually alert
to their individual employment obligations to ensure they are acting
ethically, responsibly and productively.
2.2. What are your obligations regarding employment outside NAB?
There could be occasions, when an employee gets an opportunity of a
secondary job or such other commitment. Engaging in outside or
secondary employment can produce difficulties for NAB
officers/officials. It may not always be immediately apparent to you
how a second job or such activity might conflict with your duties. A
second job with lucrative benefits has the potential to compromise
your ability to be, and be seen to be, objective in your duties.
The consequences would be unfortunate or
worse if the secondary employer came to the attention of NAB in some
adverse way. You might not know that a potential employer was of
interest to NAB or to any other agency. Nor might you be aware of
the full implications of being employed in a particular industry or
In order to ensure that NAB employees do
not engage, unwittingly or otherwise, in an inappropriate outside
employment, you must ensure that you do not engage in such
employment, paid or unpaid, without the formal permission of NAB.
2.3. What are your obligations to NAB when you leave to work
If you have been offered or intend to
accept a position which may be having some interest with the
sensitive links to the work you performed for NAB, you should
apprise your supervisor as soon as possible so that any conflict or
potential conflict of interests can be managed.
If you leave the NAB to work elsewhere,
you are obliged by the confidentiality rules to respect the
confidentiality of information that you have come across during your
work, and you should respect the NAB’s intellectual property rights
over material produced by NAB or any information pertaining to the
activities of NAB.
Unless otherwise authorized, when you
leave NAB, you cannot take away any in-house resources such as
classified manuals, materials produced as official functions of NAB,
or download information. These are the property of NAB, governed
under security rules.
3.1. Personal and professional
behaviour expected of NAB employees.
When performing the professional duties, NAB employees
shall be guided by the provisions of NAO, civil laws of the country,
international treaties with other states and be reflective of the core
values of NAB. The salient points are re-emphasized as under:-
You should ensure that your
work habits, behaviour and personal and professional relationships at
the workplace contribute to a harmonious and productive work
You should perform your work honestly, diligently and
You should appreciate that the nature of NAB’s business
requires prudence and discretion about what we do, who we speak to and
what we say.
You should make decisions in a fair and timely manner,
giving due attention to relevant information and proper regard to
relevant rules and NAB’s internal policies and procedures.
You should recognize and respect individual and cultural
differences amongst staff, the rest of the public sector and the
community, and not engage in discrimination or harassment.
You should value diversity of thought, experience and
skills but maintain the overall unity. Avoid influencing others by
expressing your political, religious or social beliefs.
You should observe common courtesies and etiquettes in
terms of day-to-day relationship with other staff.
You should encourage and contribute to a safe and healthy
You must comply with lawful instructions given by an
You should provide and accept supervision appropriate to
By making decisions reach for the essence of the matter,
avoid hastiness and superficiality.
You should be aware that the consumption of alcohol or
use of drugs and narcotics can adversely affect the image of NAB.
3.2. Additional requirements for NAB’s leadership
NABs leadership is expected to:
Put their efforts at creating good and friendly
working environment, forestall conflicts, eliminate causes of
differences, treat their subordinates with respect.
Try to divide workload equally to have the optimum
use of the potential and professional qualifications of each
Reflect objectivity and faith for high standards of
performance by employees.
Show proper appreciation of professional achievements
of distinguished employees.
Observe procedures for the authorized release of
confidential information if required, to avoid incidence of leakage
or willful misuse.
3.3. Conflict of interests, and how to deal with it?
Conflict of interests, or the perception that may have
arisen can do great damage to the reputation of both NAB and its
employees. It could also interfere with your ability to do your job with
detached objectivity. While you have to take responsibility for
identifying and managing any conflict of interest, it needs to be done
with the knowledge and advice of your superiors.
The potential for development of conflict of
interests arises when an individual with various interests in a matter
has to take decisions concerning that matter. In the case of NAB
employee, the situation is of concern when one is a public interest, his
or her duty, and another is a private interest.
When the public interest that you must serve,
comes into conflict with a private interest that you may have, public
interest must come first on all such occasions.
Financial conflict of interests might arise out of
association with business interests, ownership of shares or finding out
information that could be of financial benefit.
For NAB employees other private interests which might arise
include those pertaining to a member of your family, a family member ’s
business associates, a friend, a current or past work mate, a person who
dislikes or is disliked by you and many other relationships.
Our social system at times dictates that you or your close
relatives are approached to gain favors from your position in NAB. In
order to ensure that conflict of interests do not interfere with the
work of NAB, and in order to ensure that public has confidence in the
impartiality of NAB, such conflict of interests must be declared to NAB
You should also apprise your superior if you become aware of
any potential conflict of interests, or anything that may appear to be a
conflict of interests, that arises in the course of your duties. If in
doubt, seek advice from your superior, it is preferable to err on the
side of caution and disclose any interest that you might consider could
affect, or be seen to affect, the impartial and fair performance of your
3.4. Offers of gifts, benefits or bribes
As a NAB employee you may be offered gifts,
benefits like travel or hospitality during the course of your work. The
acceptance of gifts and other benefits has the potential to compromise
your position by creating a sense of obligation and so undermining your
impartiality. It may also affect adversely the public perception of the
integrity and independence of NAB and its employees. As a rule such
offers should be declined.
It is important to avoid creating an
impression that any person or body is securing or attempting to secure
the influence or favor of NAB or any of its officers/officials.
You should never accept any money or any
offer of money. To do so may constitute a criminal offence of bribery,
which could be elaborated as receiving or offering any undue reward by,
or to, any person in public office in order to influence his or her
behaviour in that office, and to incline that person to act contrary to
the known rules of honesty and integrity. Such conduct is also deemed an
offence under the Govt of Pakistan employee’s efficiency and discipline
A key notion in the offence of bribery is that of “undue
advantage.” That is, something intended to be of value to the public
servant. An advantage can encompass anything of value and is not limited
to money or tangible gains. The provision of services may also amount to
such an advantage. Some examples are, any gift (in kind or cash), loan,
employment, discount, service, favor etc, whether offered inside or
outside the country.
As regards the offer of gifts, government
rules on the subject must be complied with by NAB employees. You must
exercise sound judgment when deciding whether or not to accept a gift or
other benefit. For example:-
You must decline any offer from an individual or
organization you know to be the subject of an investigation by NAB,
or the subject or originator of a complaint or report to NAB.
You must decline any offer which is individually
targeted and not available to colleagues or associates who share a
common task and purpose.
You may accept an item which relates to the work of
NAB, such as a book on a relevant topic, from an acquaintance but
refuse items which are unrelated to your work to avoid any kind of
obligation particularly towards a casual relationship.
In an event of interaction with a foreign dignitary
during the performance of your official duties. You may accept a
gift, in exceptional circumstances when to refuse it would be
unnecessarily rude and inappropriate according to the diplomatic
norms. You must however notify receiving of such gift as per
Government Servants (Conduct) Rules.
There could be some occasions when an officer is invited
to deliver a lecture. On such occasions, officers who have agreed
to speak officially at functions, should where possible, notify their
hosts in advance of the occasion that it is inappropriate to offer gifts
or rewards. However, if an institution requests an officer to deliver
lecture or a series of lectures on a specialized subject on payment of
an agreed upon remunerations, he may do so after obtaining prior
permission of the Chairman.
3.5. Obligations in using public resources
NAB’s resources which are mostly funded by public money can be generally
categorized into three areas; equipment, people and finances. Because
they are publicly funded, the use of those resources needs to be
efficient and judicious.
Whereas NAB employees are paid for the time
spent in performing NAB’s work, it is recognized that they occasionally
have unavoidable commitments of personal nature which require their
attention. Although NAB’s policy will enable staff to deal with most
private matters in their own time, staff are permitted to attend to
pressing private business (like pick and drop of school children) during
work time, so long as it is short, infrequent, and does not interfere
with NAB’s work. It must however be ensured that the Officer Incharge
has been informed accordingly.
The expenditure of financial resources is subject to the
provisions of the Government accounts and audit rules. Government rules
are followed for purchasing policy and laid down procedure provides
guidance to staff on this issue. Generally, staff requires prior
approval to incur any expenditure.
3.6. Participation in political activities
Whereas casting your vote is a constitutional right, you
must not participate in other political activities nor you should form a
political association with a political party. You are also prohibited to
participate in public demonstrations of any nature. You should also
avoid such activity, the nature of which may cast doubt on your ability
or willingness to implement NAB policies, objectives or allows NAB’s
position to be misrepresented.
NAB’s employees are strongly encouraged to be prudent in
managing their personal finances. Activities like over spending and
speculative investment beyond one’s financial means can land the
employees in difficult financial situation. Problems under such
conditions could lead to manifest behaviour like:-
Resorting to corruption or other misconduct in an
attempt to pay off debts.
Being subject to considerable pressure and stress,
which may impair the standard of their performance in official
4.1. Obligations on the use of NAB’s information
NAB’s work often involves access to
sensitive or confidential information during the course of an
investigation. Such information may be relating to government
departments, political leaders and other Govt officials or may
pertain to personal or commercial information relating to
individuals or companies. You must ensure that such information is
dealt with appropriately and only used for the purposes of the NAB.
NAB is often entrusted with sensitive information by other agencies
for carrying out its investigative functions or to provide advice on
corruption prevention. As a rule you must not disclose any
information that you acquire during the course of your work except
in exercise of NAB’s functions. It would be tantamount to breach of
Information may be disclosed only when
authorized by Chairman/Dy Chairman if it is necessary in the public
interest to do so.
You must not use information to gain a personal or
commercial advantage for yourself or any other person.
When handling sensitive information you
should abide by NAB’s confidentiality policy. You should also
exercise caution and sound judgment in discussing such information
with outsiders. Normally information should be limited to “need to
NAB files and other confidential documents and information are not
to be removed from the premises except in accordance with the NAB’s
security policies and procedures. If in doubt as how to manage or
secure sensitive material, contact the Intelligence Wing of NAB for
4.2. How should you respond if
asked to publicly comment on NAB’s work?
NAB’s work is often sensitive and requires confidentiality. The very
sensitivity of the NAB’s activities makes it of interest to the
community, and in particular, the media.
The unauthorized or improper release of
information to the media may have the effect of compromising an
investigation, adversely and unnecessarily affecting the reputation
of individuals, or undermining public confidence in NAB.
It is therefore, important to ensure that information
considered appropriate only for public comment is released. This is
generally done in coordination with the authorized media officer of
NAB. Media management is presently being supervised by COS under the
directions of Chairman/Deputy Chairman. Accordingly Media Advisor,
Addl Director (Media) and PRO (Media) are responsible for
implementation of NAB’s media policy.
The Chairman NAB will authorize officers
to make public comments on behalf of NAB. You must only make public
comments with this authorization. If you receive any media
inquiries, these should be referred to the concerned media officer
who is the official spokesperson of NAB. Even if you do not provide
any information to a journalist, inform the media officer of any
approaches from the media for information or comments.
Except when making authorized comment, discussions about
NAB’s work should be confined to material that is already in the
public domain. Public domain material includes published reports and
discussion papers, annual reports, public relations material,
transcripts of public hearings, media releases, and public
addresses. If you are uncertain as to whether information is in the
public domain you must consult the media officer.
No comment should be made about any other
material relating to NAB’s work unless the Chairman/Deputy
Chairman/COS has given specific permission.
You should also ensure that your personal
views are not presented or interpreted as official comment.
If you become aware that comments you
have made socially or inadvertently may be used to harm NAB’s
reputation or compromise its work, you should notify your superior
or the media officer immediately.
Accountability and Enforcement
5.1. What if you
become aware of or suspect corrupt conduct outside NAB?
There could be an instance when you become
aware of suspected corrupt conduct, which has not been otherwise
reported. For example, you may personally observe a public official
engaged in a suspect act; you may overhear a conversation at a
conference or seminar; a friend may report something to you because you
are a NAB employee; or it may be that a public official seeks to enlist
you into an improper arrangement during the course of conducting
government business. You may disclose such information to the
appropriate officer provided you could justify the credibility of such
information in the light of relevant rules.
It is also important that any act of suspected corrupt
conduct encountered by staff in the course of their official duties is
promptly reported. This should be done in writing and addressed to your
supervisor or to the Chairman NAB.
5.2. What if you become aware of or suspect corrupt conduct inside
If NAB is to be successful at improving
public sector integrity, it is critical that it should practice the
conduct it expects of others. It therefore follows that, if any of NAB
employees engages in conduct that is unlawful, unethical or unfair,
NAB’s integrity and public image could be seriously compromised. To this
end, it is important that any such conduct is promptly disclosed.
The report can be made direct to your superior, or
alternatively to the COS or the Chairman depending on sensitivity and
level of persons involved.
How will this Code of Conduct and Ethics be enforced?
Observance of the code of conduct and ethics shall be the honourable
duty of every NAB employee.
NAB’s employee that are unsure of any aspect of this Code or
who want to seek clarification in respect of any issue are encouraged to
consult their superior.
A breach of this Code may lead to corrective or disciplinary
action by NAB under the relevant service rules and other laws. Such
action may include counseling, official notification of unsatisfactory
performance, dismissal or prosecution.
an employee of National Accountability Bureau, Islamabad
have read the Code of Conduct and Ethics for the employees of NAB and
concur to abide by its provisions and am COMMITTED to act in accordance
with the requirements of the Code of Conduct and Ethics and be held
responsible for its violation.
NOTE:- This COMMITMENT shall be placed in
the personal file of the NAB employee.