Policies
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POLICIES
PURPOSE
Purpose of the information policy is to share Derlüks Yatırım Holding’s past performance, future expectations, strategies, goals and vision other than trade secret information equally with the public, relevant authorities, current and potential investors and shareholders, taking into account the company’s strategies and performance and by announcing the financial information of the company in an accurate, fair, timely and detailed manner within the framework of generally accepted financial reporting principles and Capital Markets Board (CMB) regulations; to provide a continuous, effective and open communication platform by both the investor relations department and the corporate communication department.
The company complies with the CMB and Borsa İstanbul A.Ş (BIST) regulations in all practices regarding public disclosure and aims to implement the most effective communication policy.
SCOPE
The information policy covers issues including which, how often and through which channels developments and information will be presented to the public, apart from the information determined by the legislation.
RESPONSIBLES
The Board of Directors is responsible for creating, auditing and updating the information policy. The information policy approved by the Board of Directors is disclosed to the public on the Public Disclosure Platform (KAP) and on the website. In case of any change in the information policy, the new text approved by the Board of Directors is disclosed to the public on the Public Disclosure Platform and the website.
METHODS AND TOOLS USED IN COMMUNICATING WITH INVESTORS
Within the framework of the CMB and BIST regulations and the provisions of the Turkish Commercial Code, Derlüks Investment Holding uses the following communication methods and tools within the framework of its disclosure policy for public disclosure:
- Special event disclosures and company general information form announced in the KAP
- Financial statements and activity reports announced on the KAP
- Corporate Internet site (www.derluks.com.tr )
- Information and promotional documents prepared for investors
- Investor meetings
- Prospectus, circular, announcement texts and other documents required to be prepared in accordance with CMB regulations,
- Press statements made through written and visual media,
- Announcements and notices through Turkey Trade Registry Gazette and daily newspapers.
SPECIAL CIRCUMSTANCES DISCLOSURE
Information to be disclosed to the public in line with the Communiqué on Material Events numbered II-15.1, prepared within the scope of compliance with the regulations in the Capital Market Law (Law) numbered 6362, is made on the KAP by using the relevant form in the KAP. Unless otherwise stated in the Communiqué on Material Events numbered II-15.1, it is essential that the disclosures are made immediately. In the statement to be made; it is declared that the disclosure is in accordance with the principles of the Communiqué, that it fully reflects the information received by the issuer, that the information is in accordance with the books, records and documents of the issuer, that all efforts are made to obtain complete and accurate information on the subject, and that it is responsible for these disclosures.
Disclosure on material events is available in the Company News section at http://www.derluks.com.tr and www.kap.org.tr
All measures to ensure confidentiality during material events are disclosed to the public are taken by the Board of Directors and the Investor Relations department.
WEB SITE
The company uses the website containing information and data stipulated by corporate governance principles and regulatory authorities for informing and public disclosure.
On the website; general introduction of Derlüks Yatırım Holding, contact information, partnership structure, trade registry information, articles of association, material event disclosures, power of attorney sample, information on board members, periodic financial statements and activity reports, corporate governance principles compliance report, profit distribution policy, and information policy are included. Maximum care is taken to keep the website up-to-date.
PUBLIC DISCLOSURE OF FINANCIAL STATEMENTS
Derlüks prepares annual and interim financial statements and notes related them according to Turkish Commercial Law, Capital Market Law and in this context, as determined in accordance with regulations promulgated Turkey Accounting Standards and Turkey Financial Reporting Standards and the Capital Markets Board regulations and disclosed to the public on the Public Disclosure Platform within the periods specified in the regulations of the Capital Markets Board and following the approval of the Board of Directors in accordance with the procedure specified here. Publicly disclosed financial statements and related footnotes are published under a separate heading on the Derlüks investor relations website within the next business day after the announcement at the latest. The said financial statements and footnotes are available on the Derlüks website for five years. Necessary information that may be needed by shareholders regarding financial tables and related footnotes is available on the website of Derlüks and is regularly updated. All applications and questions made by the shareholders are replied by phone or e-mail without any discrimination.
PUBLIC DISCLOSURE OF THE ACTIVITY REPORT
Derlüks annual and interim activity reports are prepared in accordance with the Turkish Commercial Code, Capital Markets Law, Capital Markets Board Corporate Governance Principles and other regulations put into effect within this scope, and are disclosed to the public through the KAP following the approval of the Board of Directors in line with the periods and procedures specified in the relevant regulations.
The activity reports disclosed to the public are published under a separate heading on Derlüks website within the business day after the announcement at the latest. The said activity reports are published on the Derlüks website for five years.
ANNOUNCEMENTS IN TURKISH TRADE REGISTRY GAZETTE
General Assembly Meeting Agenda, Samples of Power of Attorneys, General Assembly Meeting Resolutions and all Articles of Incorporation Amendments, including Capital Increase, are announced to the public through Trade Registry Gazette.
NEWS AND RUMOURS FROM MEDIA ORGANS AND SIMILAR COMMUNICATION CHANNELS
Follow-up of news and rumours in the written, visual or audible media and/or internet environment is carried out by following the market regularly.
Derlüks, in principle, does not give any opinion on unfounded news, market rumours and speculations not stemming from Derlüks.
In case of existence of news and rumours about Derlüks, which may affect the investment decisions of investors or the price of capital market instruments, that are not sourced from persons authorized to represent Derlüks, disclosure of material event is made within the framework of the Capital Market Legislation regarding their accuracy and/or adequacy. However, in cases where there is a decision to postpone a statement regarding the subject, Derlüks may refrain from making any statement until the reasons for postponement are removed.
In the event that the said news or rumour is not important enough to be considered as the definition of internal information, no opinion is given unless an explanation is deemed necessary by the persons authorized to make public disclosure on behalf of Derlüks.
ANNOUNCEMENT OF EXPECTATIONS AND TARGETS
Derlüks may, from time to time, explain its future expectations within the framework of its Information Policy. In the written documents where Derlüks explains its expectations for the future, it is clearly stated that possible risks, uncertainties and other factors may significantly differentiate the actual results from the expectations.
Forward-looking expectations can only be made by persons authorized to make public disclosures and by expressing the above warnings or by referring to an existing and publicly available written document.
The future expectations included in the explanations to be made are based on reasonable assumptions and estimates and explained together with the reasons and data on which the estimates are based. Expectations cannot contain unfounded and exaggerated predictions; can not be misleading and is associated with Derlüks’ financial status and activity results.
In the case of understood that future expectations and their bases are not realized or will not be realized, this situation is immediately disclosed to the public in accordance with the procedures specified in the Information Policy and the said information is revised.
This Information Policy has entered into force with the decision of the Board of Directors dated 28.05.2018 and numbered 2018/20. When any change is required in the Disclosure Policy, the changes become valid after the approval of the Board of Directors and are disclosed to the public on the Derlüks website. In addition, the investors are informed about the change at the first General Assembly to be held.
Our company distributes dividends within the framework of the provisions of the Turkish Commercial Code, Capital Markets Board regulations, tax regulations and other relevant regulations and the article on profit distribution of our Articles of Association. In dividend distribution, a balanced and consistent policy is followed between the interests of the shareholders and the Company in accordance with the Corporate Governance Principles.
The annual profit distribution proposal of the Board of Directors, which includes the matters stipulated in the profit distribution policy and the CMB Corporate Governance Principles, is included in the annual report, submitted for the approval of the shareholders at the General Assembly, and also announced to the public on the website of our company, together with detailed information about the profit distribution history and capital increases.
In principle, taking into account market expectations, our long-term group strategy, capital requirements of our Company, its subsidiaries and affiliates, investment and financing policies, profitability and cash position, a minimum of 35% of the distributable period profit calculated within the framework of the Capital Market regulations is distributed to the shareholders in cash, as long as the relevant regulations and financial possibilities allow.
The entire amount of dividend foreseen to be distributed can only be distributed as long as it can be met from the current net distributable profit and other resources in the legal records.
The aim is to make the profit distribution within one month at the latest after the General Assembly meeting, and the General Assembly decides on the profit distribution date.
General Assembly or, if authorized, Board of Directors may decide to distribute the dividend in instalments in accordance with the Capital Market Regulations. The number of instalments can be determined by the General Assembly or by the Board of Directors, provided that it is explicitly authorized by the General Assembly. In case the instalment payment times are determined by the Board of Directors, the payment dates are announced to the public within fifteen days following the date of the General Assembly within the framework of the regulations of the Capital Markets Board regarding public disclosure of special events.
According to the Company’s Articles of Association; The Board of Directors may distribute advance dividends, provided that it is authorized by the General Assembly and complies with the Capital Market Regulations.
Within the framework of the dividend distribution policy, the dividend is distributed equally to all shares as of the relevant accounting period, no privileges are applied.
This “Dividend Distribution Policy” may be reviewed annually by taking into account the financial performance of the Company, anticipated investment projects, and industrial and economic conditions.
In the implementation of the dividend distribution policy, a consistent policy is followed between the interests of the shareholders and the interests of the company.
Board of Directors submits to the shareholders at the General Assembly why the profit will not be distributed and how the profit that will not be distributed will be used if no profit distribution is made.
1. Stakeholders
Stakeholders are persons, institutions or interest groups that are influential in achieving the Company’s goals or are involved in its activities. In this context, our stakeholders have been identified as shareholders of our Company, employees, customers, suppliers, public institutions, industry and non-governmental organizations and potential savers who might consider investing in our Company.
2. Protection of Stakeholders
Care is taken to regulate the relations between the stakeholders and our Company through written agreements to the extent possible. Our company protects the rights of stakeholders in its transactions and activities, which are regulated by legislation and mutual agreements. In case the rights of stakeholders, which are protected by legislation and contracts, have been violated, corrective measures are taken quickly and effectively to ensure the restoration of the rights. Our company provides the necessary convenience for the use of compensation mechanisms provided to stakeholders by legislation. In cases where the rights of stakeholders are not regulated by legislation and contracts, the interests of the stakeholders are protected within the framework of good will and by considering the rights, possibilities and reputation of our Company. Our company plays a leading role in settling and resolving any disputes that may arise between our company and our stakeholders. When conflicts of interest arise between stakeholders or if a stakeholder is included in more than one interest group, a balanced policy is followed in terms of protecting the rights owned, and each right is aimed to be protected independently from each other.
3. Informing Stakeholders
Our company has adopted to act within the framework of the principles of equality, accuracy, impartiality and timing in informing shareholders and stakeholders. It is essential that the announcements and notices addressed within this scope are made in a timely, accurate, complete, understandable and easily accessible manner, taking into account the rights and interests of our Company. Our stakeholders are informed with material event disclosures, general assembly meeting minutes, annual and interim activity reports, financial reports through the public disclosure platform and the Company website. Employees are informed about the targets and activities of the Company through evaluation and information meetings held within the framework of open communication. The Investor Relations Department is responsible for informing the stakeholders within the framework of our company’s disclosure policy, and our disclosure policy can be found at this link. The monitoring and development of the information policy is under the authority and responsibility of the Board of Directors.
4. Participation of Stakeholders in Management
There is no regulation in the articles of association of our company that requires the stakeholders to participate in the management of the company. However, within the scope of the decisions taken, there are independent members in the Board of Directors to create assurance that the rights of minority shareholders and other stakeholders to be observed equally.
Transactions of the company that are reported by the stakeholders that are contrary to the relevant legislation and unethical are prepared and reported by the Investor Relations Department to be forwarded to the corporate management committee. The Committee of Corporate Governance, when deemed appropriate, conveys the matter to the Board of Directors. In our company, communication channels are kept open to ensure that stakeholders, especially our employees, contribute to the management of the company in a transparent, honest and accountable management approach. The stakeholders are given the opportunity to contact the Company executives through the contact information on the website of our Company for their questions, opinions, suggestions and complaints.
5. Human Resources Policy
Our basic Human Resources policy is to select, develop, evaluate and manage human resources according to contemporary criteria and with the principle of equal opportunity for everyone by combining the requirements of the job with the skills and competencies of the employees.
The aim of the Human Resources Policy is, by preserving the dynamic structure of the institution, to on the goals of the company with happy employees motivated to work, open to continuous improvement and to build solid foundations for the future years.
Human Resources management is aims to increase the performance of employees by creating a dynamic and innovative environment open to development, to combine corporate goals with individual goals, to establish an effective, efficient and motivated organization, thus supporting the achievement of the Company’s goals effectively.
Derlüks Yatırım Holding Human Resources, in line with the above objectives, targets and policies:
- Prioritizes the personal and professional development of our employees at all levels in line with the company’s goals and strategies.
- Maintains its contribution to the Company’s goals such as “efficiency” and “profitability” by ensuring the continuous development of our employees.
- Provides equal opportunities to our employees in the management of their careers.
- Prioritizes merit without discrimination on gender, religious belief, language, race, ethnic origin, age, disability and refugee by providing equal opportunities in the recruitment process.
- Improves working standards in the value chain process, determines fair distribution of work and wages.
- Pays special attention to low-income groups and women who are sensitive to environmental and social factors in equality of opportunity.
- Investigates and prevents employee and human rights violations within departments, especially those caused by managers.
- Takes the necessary measures to prevent child labour and personnel without work permit from being employed.
- Maximizes the productivity of our employees with career planning, and trains our manager candidates within our organization.
- Follows a transparent and open management policy to establish a reliable and effective interaction with employees.
- Organizes the necessary trainings and takes measures on occupational health and safety.
- Protects employees’ personal data.
- Increases individual performances and team performances with continuous improvement processes and systems, and rewards superior performance.
- Provides a competitive structure within the organization by creating an innovative, productive and job-loving human resource.
- Observes the rights of the employees such as compensation, fringe benefits, union rights, work/life balance solutions and binds the relevant processes to the procedures.
- Creates mechanisms for the resolution of employee complaints and disputes. It determines these processes.
- Organizes events to ensure employee satisfaction and company loyalty.
- Establishes the Company Ethics Policy, explains it and supervises its implementation.
- Organizes activities within the scope of social investment and social responsibility.
- Informs the employees about EMS (Environmental, Social, Corporate Management) studies.
6. Relations with Customers and Suppliers
Our company, by attaching importance to customer satisfaction in the sales, marketing and distribution of its products, effectively carries out practices aimed at ensuring customer satisfaction. Within the scope of customer satisfaction, it is essential to meet the demands of the customer regarding the goods and services purchased in a fast, timely and complete manner and it is aimed to inform the customers about possible delays without waiting for the deadline. In our company, customer satisfaction forms and surveys are applied, and feedbacks on customer satisfaction are received and reported to senior management.
Our company aims to continuously improve product quality in order to meet and exceed customer expectations within the scope of its quality policy. While ensuring that everyone in the company organization goes towards the same goal as a whole, it takes the quality system as the basis of its activities. Our company pays attention to the confidentiality of customer and supplier information within the scope of trade secrets. Necessary measures have been taken by our company in order to establish good relations between our company and our customers and suppliers, and to comply with the terms of the agreement made between the parties, and our sensitivity in this matter has been conveyed to all our employees.
1. Purpose
The purpose of the donation policy is to determine the principles of donations made by Derlüks Yatırım Holding within the scope of corporate social responsibility activities. The main purpose of donations and aids is to fulfil our social responsibilities, to create a sense of corporate responsibility among our partners and employees, as well as to meet social and social needs and benefit the public.
2. Principles of Donation Policy
- The company may make any kind of donation in accordance with the Capital Market Law and the relevant legislation, without disrupting its purpose and subject. The donations and aids made by the partnerships within the framework of the Capital Market Legislation are determined by the Board of Directors.
- All donations and aids made at the decision of the company management are made in accordance with the vision, mission and policies of the company and considering the company’s ethical principles and values and the annual budget allocations of the company. Donations and aids may be made in two ways, in cash and in kind.
- The Company may donate to educational institutions, foundations, associations and public institutions and organizations operating for social, cultural, educational, etc. purposes, within the framework of the principles specified in the Capital Market Law and Turkish Commercial Code, with the approval of the Board of Directors.
- The social responsibility policies of the company are taken into consideration in the selection of the form, amount and institution, organization or non-governmental organization to be made. A separate agenda item is included in the general assembly meeting of the relevant year, and detailed information is given to the board members about the amount and beneficiaries of all donations and aids made during the period.
- Apart from these, the company may also donate and help to foundations, associations etc. that have been established to operate in its field of activity.
- While making donations and aids, attention is paid to the fact that they are organizations that have been granted tax exemption by the Ministry of Finance.
INVESTMENT POLICY
PURPOSE:
Pursuant to the 3rd article of the Articles of Association, the main activity of the Holding Company, “to ensure the establishment of various companies in the country and abroad or to participate in their capitals and to increase the success of the companies that they founded, participate in the capital or participate in the management in any other way, to make them more profitable, productive and efficient. to ensure that they are managed in accordance with the conditions of the day, to reduce the risks that may occur, to create added value by increasing the synergy between the companies and to ensure their administration, to reduce the financial burden by creating common service areas and to ensure the healthy development of these companies. For this reason, an “investment policy” has been established in order to carry out these studies.
SCOPE:
The investment policy includes the improvement of existing facilities, expansion of existing facilities, identification and design of new investment areas, and making future plans, together with all subsidiaries and affiliates.
PRINCIPLES:
Within the framework of the studies discussed under the above headings; The company is focused on producing or developing its own processes and, accordingly, unique projects that enable it to survive in the competitive race.
For this, it should continue the modernization of the systems and capacity increase studies in its existing facilities in order to be able to produce with the least manpower, at the least stock level, with the least waste, at the lowest cost and with the highest quality.
In the development of existing projects and investments, it is essential to apply the “plan-do-check-act” cycle. This will improve the contribution of each employee to his work and his efforts to increase work efficiency, and contribution to personal development and business development efforts will be considered as important criteria in performance evaluations. Studies carried out in this context are gathered at the Holding Company headquarters. A project pool is created and used in the same way or by changing it in future similar works. Thus, energy and time savings are achieved.
In the implementation of modernization and capacity building projects, the primary goal is to benefit from existing manpower and to provide training and development of employees.
“Occupational health-occupational safety-environmental health-social contribution” should always be considered in the projects and investments of the holding companies. “Occupational safety inspection” must be done before the projects and investments are put into use.
Cycles should be followed in identifying and projecting new investment areas and making future plans. World economy, national economy, political and geopolitical stability should be taken into consideration. Periods when my economy shrinks and changes include risks as well as opportunities. The company can take risks in new investments and projects. However, this risk should be predictable and measurable.
In the development of new projects and investments, it is essential to implement the “Set priorities-follow-research-budget-apply-check-take precuation” cycle.
Holding Company board of directors and execution,
- In the selection of new investment areas,
- In the evaluation of feasibility studies of new projects,
- In the selection of implementation times of new projects,
- In the budgeting studies of new investments,
Should work in cooperation with the “Investment Committee”. Company resources should be directed effectively and capital costs should be at the forefront.
Investments should be made with equity as long as possible. For this purpose, the financial status and cash flows of subsidiaries and affiliates should be monitored by the Holding Company. If necessary, investment financing should be provided on a short-term basis from Group Companies. However, foreign resources should be used in periods when financing costs are falling or in projects where the return on investment is higher than the financing lump sum and which can generate sustainable profits in a short time.
RESPONSIBLES:
The Board of Directors is responsible for creating, auditing and updating the information policy. The information policy approved by the Board of Directors is disclosed to the public on the Public Disclosure Platform (KAP) and on the website. In case of any change in the information policy, the new text approved by the Board of Directors is disclosed to the public on the Public Disclosure Platform and the website.
- 1. Asset and Information Management
1.1 Honesty
– Acting within the framework of integrity and honesty in relations with employees and all stakeholders, since integrity and honesty are our priority values in all our business processes and relationships.
1.2 Confidentiality
– To act with the awareness that financial and commercial secrets of the company, information that will weaken the competitive power of the company, employee rights and information, and agreements with business partners are within the framework of “confidentiality”, and to ensure their protection and confidentiality.
– Not to share information and documents learned for business purposes with unauthorized persons and authorities inside and outside the institution for whatever purpose.
– Not to use non-public information about the employees and their customers and other persons and companies with whom they do business for any purpose other than the foreseen purpose, not to share them with third parties without obtaining necessary permissions.
1.3 Information Management
– To provide that all records are properly kept and archived within the legal period.
– Not to respond to information requests from third parties those fall under the confidential category of the company without the approval of senior management.
– To show the necessary care to ensure that the reports submitted by the company are true.
1.4 Security and Crisis Management
– To take the necessary precautions and communicate with the company employees to protect the information and information systems, production and administrative facilities against possible terrorism, natural disasters and malicious attempts.
– To make the necessary crisis planning regarding the emergency crisis management to be created in case of terrorism, natural disaster, etc., thus ensuring the continuity of the business with minimum losses in the crisis.
– To take every precaution to prevent company assets from being stolen or damaged.
- 2. Avoiding Conflict of Interest
– Conflict of interest; refers to all kinds of benefits that affect the employees’ ability to perform their duties impartially and provided to themselves, their relatives, friends or persons or organizations with whom they have a relationship, and the condition of having any financial or personal interest in relation to them.
2.1 Failure to act in favour of one’s own or relatives
– Not to provide unfair advantage in favour of himself, his relatives or third parties by taking advantage of his title and authority,
– Paying attention not to prevent personal investments to be made or activities other than any business activities in terms of giving time and attention to the current duty and to avoid such situations that prevent focusing on the main tasks.
– If the employee and the person who is in the first degree decision-making position in the company or in the position of a customer or supplier are first degree relatives, to inform his/her superior.
– To inform the superior if it is learned that relatives have a share or financial interest in another company with which we have a commercial relationship.
2.2 Participation in representation and organization events
– Participation in events such as conferences, receptions, promotional activities, seminars, sports activities, domestic/foreign trips, etc. that are impressive in decision making or that can be perceived as such and which are open to general participation of persons or institutions with which there is or has the potential to be in a business relationship are subject to the approval of the manager.
2.3 Making business with the company by those who quit work
– After leaving his job in the company, establishing a company himself or as a partner to another company, doing business with the company in the form of sales, contracting, consultancy, brokerage, representation, dealership or similar is a very important issue that may create a negative perception. The fact that an employee who leaves the company is in a senior management or decision-making position in another company is also an issue that should be considered.
– Before or after such a process, it is necessary to act within the Company’s interests, to comply with moral and ethical rules, and to prevent conflicts of interest before and after the process.
– In case of re-employment of an employee who has left the company, it is required that he/she has not been dismissed due to failure to comply with any of the Company Code of Ethics and any of the principles set forth by the Company.
- 3. Anti-Corruption
3.1 Receiving and Giving Gifts
– It is forbidden for all employees of the company to enter into relationships with all third parties, including customers, suppliers, dealers, authorized dealers and authorized services, that may create the impression of obtaining material benefits, including the offer and acceptance of gifts, invitations and entertainment.
– Except for materials that are given in accordance with legal and commercial traditions, customs and traditions or those are of the nature of souvenir/promotional material, any gift that creates the impression of an irregularity, that may cause a dependency relationship such as providing privilege or reference, or may be perceived as such, should not be accepted or offered.
– Gifts should never be given in cash or in a form that maybe converted to cash (like gift vouchers).
– Discounts or benefits that may be perceived as inappropriate from suppliers, dealers, authorized services, customers or third parties should not be requested, offered to third parties or accepted when offered.
- 4. Occupational Health and Safety
– In our company, it is aimed to ensure full occupational health and safety at work and at work. Employees must act in accordance with the rules and instructions set for this purpose and take the necessary precautions. In addition, they should adopt the principle that occupational health and safety improvement activities are the common responsibility of all employees.
– It is forbidden for the employees to keep at their workplace any item or substance that poses a danger to the workplace and/or workers or is of an illegal nature.
– Employees; except for those based on a valid doctor’s report, should not use drugs, addictive, mental or physical restrictive or eliminating substances in the workplace, and should not work in the workplace or within the scope of work while under the influence of such substances.
– All work safety warning signs and signals in the work area should be taken into consideration.
– Those who do not comply with the rules should be warned, dangerous situations should be reported to the superior.
– Employees are responsible for ensuring that the place where they work is always tidy, clean and safe.
– Employees should work as they were taught, and should not work in jobs they do not know or have not been taught.
– No material should be placed in the corridor, stair heads and passageways to prevent passage.
– Lifting equipment should be used for lifting and transporting heavy materials.
– The floor of the work area should not be kept oily and wet, in such a case it should be cleaned immediately.
– When an electrical malfunction occurs, employees should not intervene and the malfunction should be reported to the electrician immediately.
– When a malfunction occurs in machinery and equipment, the malfunction should be reported to the superior and technical service, and the employees should not interfere in this situation. If deemed necessary during the repair, warning signs should be hung.
– Employees should use the personal protective equipment provided to them and preserve these materials in the best possible way, and request a new one in case of any deformation in the materials.
– Authorities should be informed in case of any accident.
- 5. Non-governmental Organizations and Political Activity
– The company does not make donations to political parties, politicians or political candidates. Demonstrations, propaganda and similar activities on these issues are not allowed within the boundaries of the workplace. Company resources (such as vehicles, computers, e-mails) cannot be allocated to political activities.
– Membership in any non-governmental organization representing the company and participation in its activities can only be carried out within the knowledge of the company.
- 6. Code of Ethics Implementation Principles
6.1 Notification of Violations
– If employees learn or suspect that the Company’s Code of Ethics or the laws and regulations that the company is subject to is violated, they are obliged to convey this to the general manager of the company, if the situation is related to the superior, or if the superior does not take any action regarding the suspected violation.
– Any employee who refuses to act contrary to Code of Ethics is not allowed and an employee who reports in good faith is not allowed to be threatened, retaliated against, or harmed in any way at work or outside of the workplace. This type of behaviour is interpreted as a violation of ethical rules.
– When deliberate notices that are false and/or libellous are detected, they are interpreted as a breach of code of ethics.