Policies & Procedures

Statement of Ethics & Business Practices

The entire Organization of Sanghar Sugar Mills Limited will be guided by the following principles in its pursuit of excellence in all activities for the attainment of the Company’s Objectives.

The Company

  • Fulfills all statutory requirements of the government and follows all applicable laws of the country together with compliance with accepted accounting principles, rules and procedures required.
  • Activities and involvement of directors and employees of the Company in no way conflict with the interest of the Company. All acts and decision of the management are motivated by the interest of the Company rather their own.
  • Uses all means to protect the environment and ensures health and safety of the employees.
  • Meets the expectations of the spectrum of society and government agencies by implementing an effective and fair system of financial reporting and internal controls.
  • Deals with all stakeholders in objective and transparent manner so as to meet the expectations of those who rely on the Company.
  • Ensure efficient and effective utilization of its resources.

As Directors

  • Promote and develop conducive environment through responsive policies and guidelines to facilitate viable and timely decisions.
  • Support and adherence to compliance of legal and industry requirements.
  • Maintain organizational effectiveness for the achievement of the Company goals.
  • Promote a culture that supports enterprise and innovation, with appropriate short-term and long-term performance related rewards that are fair and achievable in motivating management and employees effectively and productively.
  • Ensure protection and safeguard the interest and assets of the Company and meet obligations of the Company.

As Executives And Managers

  • Ensure cost effectiveness and profitability of operations.
  • Provide direction and leadership for the organization and take viable and timely decisions.
  • Promote and develop culture of excellence, conservation and continual improvement.
  • Develop and cultivate work ethics and harmony among colleagues and associates.
  • Encourage initiatives and self realization in employees through meaningful empowerment.
  • Provide pleasant work atmosphere and ensure an equitable way of working and rewarding system.
  • Institute commitment to environmental, health and safety performance.

As Employees And Workers

  • Observe Company policies, regulations and code of best business practices.
  • Devote productive time and continued efforts to strengthen the Company.
  • Make concerted struggle for excellence and quality.
  • Exercise prudence in effective, efficient and economical utilization of resources of the Company.
  • Protect and safeguard the interest of the Company and avoid conflict of interest.
  • Maintain financial integrity and must avoid making personal gain at the Company’s expense by participating in or assisting activities which compete with the Company.

Policies For Evaluation of Board’s Performance

1. The Board Evaluation is to be adopted as Self-Evaluation of the Board as a whole through open discussion and questions every year in the Board Meeting.

2. The Evaluation System is to address areas of critical importance besides covering the following.
a) Appraising the basic organization of the Board of Directors.
b) Assessing the Board’s overall scope of responsibilities.
c) The efficiency and effectiveness of the operation of the Board and its Committee.
d) Focusing on the goals and results.
e) Evaluate the flow of financial & other management information.
f) Validate the support and information provided by the management.

3. The Board should review and assess the results and such areas which are identified for improvement.

Human Resource Management Policy & Succession Planning

The Company is committed to build the better organizational culture that is shaped by empowered employees who demonstrate a deep belief in the Company’s Vision and Values.

Human Resource Management Policy

H.R. Management Policy is integral part of the Company’s business strategy. The Company fosters leadership, individual accountability and team work. The main Objectives of the Company’s H.R. Management policy are based on the following.
i. Selection of the right person, with the right experience, at the right time, offering right compensation.
ii. Developing Management philosophy and practices to promote and encourage motivation and retention of the best employees.
iii. Encouraging and supporting concept of team-working and team-building techniques.
iv. Recognizing and rewarding employees’ contribution to the Company.
v. Making all reasonable efforts to achieve a high quality of work- life-balance.

Succession Planning

The Company believes in pro-active approach towards Succession Planning. The Company recruits employees, develops their knowledge, skills, abilities and prepares them for advancement and promotion into more challenging roles. Succession Planning ensures that employees are constantly developed to fill each needed role. The Company looks for people who exemplify continuous improvement when it is spotting Successors for future.

Conflict of Interest Management Policy & Insider Trading

Policy Statement

The Company has the policy for actual and perceived conflicts of interest and measures are adopted to avoid any conflict of interest, identify the existence of any conflict of interest and to disclose the existence of conflict of interest. The Board of Directors shall ensure that the Professional Standards and Corporate Values are put in by the Company that promote integrity for the Company, the Directors, Executives, Managers, Employees and Workers in the form of the Code of Conduct and disseminate the Code of Conduct throughout the Company and put on the Company’s Website. The Company Policy provides a guide as to what constitutes a conflict of interest, the processes and procedures that are in place in order to facilitate compliance therewith and the consequences of non-compliance. The Policy is intended to assists Directors and Employees in making the right decisions when confronted with potential conflict of interest issues.

Management of Conflict of Interest

The primary goal of Policy of Sanghar Sugar Mills Limited is to manage conflicts of interest to ensure that decisions are made and are seen to be made on proper grounds, for legitimate reasons and without bias. To do this, the Company has set the following procedures to manage and monitor the conflict of interest:-
i. To identify the areas of risks.
ii. To develop strategies and responses for risky areas.
iii. To educated all employees about the conflict of interest policy.
iv. To communicate with stakeholders to provide the platform for proper disclosure.
v. To enforce the policy of the Company.

Insider Trading

All the Directors of the Company are reminded of the Insider Trading Letter No.1696 dated February 08,2013 alongwith SRO No. 1431(1)/2012 dated December 05,2012 issued by the Securities and Exchange Commission of Pakistan to avoid dealing in shares of the Company while they are in possession of the Insider Information. Every Director is required to provide to the Board complete details regarding any material transaction which may bring conflict of interest with the Company for prior approval of the Board. The Interested Directors do not participate in the discussion neither they vote on such matters. The Transactions with Related Parties in case of supply of sugarcane to the Company are made during the Crushing Period on the Basis of Price Fixed by the Government of Sindh as announced at the start of the each Crushing Season and notified for each year and for Other Transactions that should be made at Arms-Length Basis and complete details thereof should be provided to the Board for their approval. Further, all the Transactions with the Related Parties are fully disclosed in the Financial Statement of the Company.

Whistle Blowing Policy

The Whistle Blowing Policy ensures that Whistle Blowing will be fully protected and the said non-conformance will be investigated in a fair, see through, reliable and principled manner as mentioned below:
i. All Protected disclosures should be reported in writing preferably typed or in legible and clear hand written in Urdu or English.
ii. The Protected Disclosures should be forwarded with a covering letter bearing the identity of the whistle blower.
iii. Anonymous disclosures will not be entertained.
iv. All Protected Disclosures should be addressed to the nominated Ombudsman of the Company.
v. If it is revealed after the initial enquiry by the Ombudsman that the complaint is not substantial, he can dismiss it.
vi. It initial enquiry reveals that further investigation is necessary then the Ombudsman will ensure to carry out investigation in a neutral and fair manner without presumption of guilt. A Written request of the finding will be prepared.
Further investigation shall only be carried out if the Ombudsman feels that the compliant is factual, fair and not speculative. It should contain more factual information to necessitate a preliminary investigation.

Information Technology Governance Policy & Steering Committee

Information Technology Governance Policy

To have properly documented and implemented I.T. Governance policy to ensure integrated framework for evolving and maintaining existing information Technology and acquiring new technology to achieve the Company’s strategic focus.
I. To define I.T. Governance, Scope, its roles and responsibilities.
II. To promote accountabilities, due diligence, efficient and economic delivery of the Company’s I.T. Services.
III. To provide structured decision making process around I.T. investment decisions.
IV. To safeguard the Financial Data of the Company.
V. To lay down solid foundation for Management decision making.
VI. To develop and upgrade different modules to provide reliable, efficient and timely information.

Steering Committee

There will I.T. Steering Committee consisting of following three executives in order to implement the I.T. Governance Policy, report thereon and recommend suggestions for improvement in their in to the Board of Directors to secure the interest of the Company.
Mr. Ghulam Hyder Chairman
Syed Rehan Ahmad Hashmi Member
Manager I.T. Member

Policy on Level of Materiality


The purpose of this Policy is to define the level of materiality for transactions which are financially significant for the consideration of the Board of Directors of Sanghar Sugar Mills Limited (the Company) keeping in view the provisions of the repealed Companies Ordinance, 1984 and now the Companies Act, 2017 and the Code of Corporate Governance, relating thereto:


This Policy shall be applicable to all transactions which are financially material and any other transaction(s) which the Board may consider to be material whether defined or not.


Following transactions should be considered material and be referred to the Board for its consideration, decision and approval by the Directors of the Company in their meeting, namely:-

    1) to incur capital expenditure on any single item or dispose of a fixed asset in accordance with the following limits:
    (i) in case of capital expenditure to be incurred on any single item, an amount exceeding one million rupees: and
    (ii) in case of disposal of fixed assets, an amount of book value exceeding one hundred thousand rupees:
    2) to undertake obligations under leasing contracts exceeding one million rupees;
    3) to approve bonuses to employees
    4) having regard to such amount as may be determined to be material by the Board:
    (i) to write off bad debts, advances and receivables;
    (ii) to write off inventories and other assets of the Company;
    (iii) to determine the terms of and the circumstances in which a law suit may be compromised and a claim or a right in favour of the Company may be released, extinguished or relinquished
    5) to make calls on shareholders in respect of moneys unpaid on their shares;
    6) to issue shares
    7) to issue debentures, participation term certificate or any instrument in the nature of redeemable capital;
    8) to borrow moneys otherwise than on debentures;
    9) to invest the funds of the Company;
    10) to make loans;
    11) to authorize a director or the firm of which he is a partner or any partner of such firm or a private company of which he is a member or director to enter any contract with the Company for making sale, purchase or supply of goods or rendering services with the Company;
    12) to approve annual or half-yearly or other periodical accounts as are required to be circulated to the members;
    13) to declare interim dividend;
    14) all transactions or contract of sale and purchase with associated company/companies and related party/parties; and
    15) any other transaction which, in the opinion of the Board, is material and needs consideration and approval of the Board.

Policy for Safety of Records of the Company

The main purpose of the Company’s Policy will be the following.

i. To ensure that the Company’s records are created, managed, retained, and disposed off in an effective and efficient manner;
ii. To keep Books of Accounts upto the period as required and to comply with the provisions of Section 230 of the repealed Companies Ordinance, 1984 and now the Companies Act, 2017.
iii. To keep records upto the period as required under Income Tax Laws, Sales Tax Laws, General Clauses Act Labour Laws and other Laws applicable to the Company.
iv. To facilitate the efficient management of the Company’s records through the development of Coordinated Records Management Program;
v. To ensure preservation of the Company’s records of permanent value to support both protection of privacy and freedom of information service throughout the Company to promote collegiality and knowledge sharing;
vi. Information will be held only as long as required and disposed off in accordance with the record retention policy and retention schedules
vii. Records and information are owned by the Company, not by the individual or team.

Policy & Procedures for Stakeholder’s Engagement

1. Policy Note

    Sanghar Sugar maintains sound collaboration relationships with its stakeholders.

2. Procedures

    Procedure for stakeholder’s engagement includes communication, good harmony, compliance with laws and regulations and sugarcane growers focused approach which is the key factors for establishment of collaboration relationship with stakeholders.

3. Engagement Frequency

Stake Holders Nature of Engagement Frequency
Shareholders Annual General Meeting
Annual /Quarterly Reports
Cost Audit Reports
Employees Trade Union
Iftar Dinner/ Crushing Ceremony
Sugarcane Growers Regular Meeting
Regular Payments
Iftar Dinner
Providing Seeds and Fertilizers
As required
As required
Suppliers Regular Meetings Continuous
Regulators Submission of Periodic Reports
Responding/Providing Information
Periodic basis
As required
Tax Authorities Submission of Periodic Statements
Responding/Providing Information
Periodic basis
As required
Financial Institution Periodic Meetings
Financial Reporting
Head Office/Site Visits
Periodic basis
As required
Community Providing Education Continuous
Media Announcement As required


Sanghar Sugar Mills Limited has carried out and performed its duties toward Corporate Social Responsibility (CSR) since inception of the Company and fulfilling the various needs of the Society concerning health, Safety, Environment, providing employment particularly to rural people to upgrade their living standards, donations to needy persons or through organizations for the welfare of the public and continuously making yearly contributions (Duties, Income Tax, Sales Tax, and other levies etc) to Exchequer to support the economy of Country. After implementation of the Code of Corporate Governance (2012), the Company is mentioning its duties and performance towards the Corporate Social Responsibility in its Annual Report for the years ended September 30, 2012, September 30, 2013 and September 30, 2014. The Board of Director in its meeting held on January 06, 2016 has revised and elaborated the Corporate Social Responsibility of the Company and mentioned in the Directors’ Report, which is embodied in the Annual Report of the Company for the year ended September 30, 2015 which is produced as under.

Sustainability & Corporate Social Responsibility

Sanghar Sugar Mills Limited (the Company) acknowledges its social and ethical responsibility to carry out its business in order to keep it safe and protect it for the generation to come. Sustainability Policy is considered to be essential for continuing of the business at Sanghar Sugar Mills Limited. The Company considers itself accountable to its stakeholders and informs them about the initiative and measures taken to ensure sustainability and has identified the following dimensions of performing social responsibilities which contributing to economy, environment, health, education and society.

i. To support the sugarcane growers of the area and provide better quality seeds and fertilizers to achieve improvement in quality of sugarcane and enhance its quantity and productivity in order to have regular, constant and better supply in future the major basic raw material for sugar mills.

ii. To alleviate illiteracy in the rural areas of the Country, the Company has launched education program and is providing education facilities at the premises adjacent to the Mills’ Employees’ Colony by the qualified staff on concessional basis to the children of the factory employees and persons living nearby in rural areas.

iii. The Company is contributing to the National growth by sharing its revenue with the nation in the form of taxes, rates and duties. The Company is also helping the Country to improve foreign reserves by earning foreign currency through exports of sugar as and when allowed. The Company is contributing to National Exchequer in the form income taxes, sales tax and other levies every year to support the economy of the Country.

iv. To follow consciously the needs of the Society concerning health, safety and environment for achieving the objective. The Company is responsive to make efforts to minimize the accidental risks, have necessary medical facilities and continuously shrine to improve greenery and maintain clean and safe environment around the Mills, better housekeeping, safeguarding the health of employees and application of the principles of safety in its operations, the consumers and public at large by following the rules and regulations in this regard.

v. The Company’s efforts have primarily on improving the social conditions of the Communities and employees related to the Company by establishing fair working conditions, ensuring occupational safety, setting social standard, establishing minimum wages, zero tolerance on child labour and forced labour etc.
vi. The Company continuously is striving to improve greenery, maintaining clean environment around the mills and better house-keeping.

vii. To encourage employment of workforce living in the rural areas in order to yield significant gain and uplift their living standard.

viii. The Company treats all employees fairly and compensates them according to the industry practice. The Company provides the benefits such as perquisites, annual leaves, pick and drop, facility of mess, safe and healthy working conditions etc along-with group insurance, making payments to Employees Old Age Benefits Institution, Worker’s Welfare Fund, Worker’s Profit Participation Funds.

ix. The Company is committed to maintaining the principles of integrity and trust with respect to privacy of the employees of the Company.