Compliance Management System

Ethics and Compliance Management (CMS)

A systematic approach to prevent non-compliances, ensuring that work is always carried out in accordance with laws, regulations and ethical rules. Responsibilities of employees, managers and practices related to suppliers have been determined.

Situations that have the potential to adversely affect the Brand value and financial structure of the Organization by violating the law, internal regulation and ethical codes of conduct are defined as compliance management risk. Our employees are subject to the Disciplinary Procedure when they violate ethical rules such as bribery, extortion, corruption, receiving and giving valuable gifts, accepting luxury entertainment, , insider trading, etc. Our suppliers, who act in violation of the Code of Ethical Conduct, may terminate their contracts with our organization.

In this context, adherence to the law, social and institutional norms, adherence to ethical codes of conduct, and a transparent corporate culture are important to us.

The Organization has conducted Compliance Management Guidance, Ethical Conduct Guidance (CoC), Third Party Assessment Guidance, Anti-Corruption Statement and Compliance Risk assessment. The organization pays attention to employee rights, not to employ multiple workers, to make special arrangements for female employees, not to discriminate, to be fair, and to protect the environment. The CoC and Anti-Corruption Statement are available online.

The Management is expected to make a notification when you see objectionable behavior and risks threatening our company. Because you may have prevented the effects of risks that may come to our company. You can make your notifications on the link given below, with or without anonymity. You will be feedback with the contact address you provided.

https://www.bkms-system.net/bkwebanon/report/clientInfo?cin=9icf36&c=-1&language=tur

Legal grounds

International legislation on corruption

The new German Anti-Bribery and Anti-Corruption Law that entered into force on 06/24/2014 and relevant provisions:

• Sect. 299   StGB,
• Sect. 335a StGB,
• Sect. 261   StGB,
• Sect. 334, 335a StGB. (for travelers),
• FCPA – U.S. Laws (Foreign Corrupt Practices Act of 1977 ),
• UK Bribery Act.

Anti-Corruption Legislation in Our Country

• Provision on failure to file a declaration of wealth and anti-corruption provisions are set forth in the anti-bribery and anti-corruption law,
• Law regarding prevention of laundering proceeds of crime,
• Turkish Criminal Code and also some private laws.

Our Company developed Value Management System within the scope of compliance and internalized its values, sharing it with all the employees.