1-PURPOSE OF THE PRINCIPLES
The Ethical Principles and Working Principles for AKIŞ and its subsidiaries express the rules of conduct that must be followed or avoided, and that are based on honesty. The purpose of the AKIŞ Ethical Principles and Working Principles is to create a common corporate culture on business ethics and to create awareness, sensitivity and consciousness on this issue. The Ethical Principles aim to guide all parties in business processes to act not only legally and commercially, but also with ethical responsibility. AKIŞ Ethical Principles regulate the relationships between customers, employees, shareholders, business partners, suppliers, competitors, public institutions and society.
2- SOCIAL RESPONSIBILITIES
Respect for freedom and human rights is one of the fundamental principles of AKIŞ. This principle not only forms the framework of our operations but also a prerequisite for our success. AKIŞ has adopted sustainability as a principle. This principle covers efficiency and effectiveness, sustainable use of existing resources, today and in the future. AKIŞ is committed to implementing the ten fundamental principles of the United Nations Global Compact (https://unglobalcompact.org/what-is-gc/mission/principles). AKIŞ is committed to adhering to the principle of honesty and integrity in all its transactions with its employees, customers, suppliers, competitors and other parties. AKIŞ is aware that legal and cultural requirements vary in the global marketplace. This code of conduct emphasizes important standards consistent with AKIŞ values, including employees, suppliers, customers and other stakeholders. AKIŞ acts with fairness, honesty and responsibility in areas of social responsibility.
3- COMPLIANCE WITH LAWS AND REGULATIONS
AKIŞ is committed to fully complying with applicable laws and regulations. The Ethical Principles are not designed to replace or override national laws, but these principles are considered as minimum requirements and expectations. AKIŞ complies with all laws, rules and regulations that must be implemented in all countries where it does business and takes all necessary measures to ensure this compliance. We attach importance to accurate and timely communication in our relations with regulatory and supervisory institutions and apply AKIŞ Ethical Principles and Working Principles in our business processes.
4-HUMAN RIGHTS
4.1-Respecting Human Rights
AKIŞ treats its employees fairly and equally within the framework of respect for human rights as defined in the International Declaration of Human Rights and the International Labor Organization's (ILO) Declaration on Fundamental Principles and Rights at Work. AKIŞ takes the necessary steps to identify, assess, prevent, reduce and eliminate negative human rights impacts. We are committed to providing equal opportunities to our employees and job applicants. We aim to provide a working environment where our employees feel safe, peaceful and valued, and that is appropriate to the nature of the work they do.
4.2-Freely Chosen Employment
No form of forced, compulsory, debt bondage, human trafficking or modern slavery is accepted. All work is voluntary. Employees have the freedom to leave their jobs at any time, provided they give reasonable notice in accordance with their employment contract. Legal requirements are taken into account in this process. No employee will be asked to make a deposit or pay a recruitment fee during employment. AKIŞ encourages solidarity and cooperation among its employees and prioritizes sharing success rather than negative competition.
4.3- Ethical Recruitment
He defines how AKIŞ interacts with its potential workforce with the principle of “ethical recruitment”. Our ethical employment practices ensure fair and ethical treatment of all employees by providing lawful working conditions. We are also committed to ensuring that no physical or psychological harm is done to employees, and we apply this approach regardless of gender, race, religion, background or economic status. Our ethical hiring principles are based on honesty, fairness, care and respect for others. AKIŞ Human Resources Department has been assigned to ensure the implementation of this principle. In the ethical recruitment process; we do not publish misleading job advertisements, do not discriminate, sign ethical contracts with service providers during the recruitment process and conduct direct interviews with candidates in accordance with the requirements of the job (article 4.7). Managers who are in a position to hire relatives and friends cannot decide on the hiring of these individuals. However, spouses are allowed to work together, provided that they work in different branches and under different superiors. If a first-degree relative of an employee is appointed to a critical position in a rival company, this must be reported to the company in writing within one month at the latest.
4.4-Young Workers
AKIŞ rejects the use of child labor except as specified by law. The term "child" refers to individuals under the age of 15, the age for completing compulsory education, or the minimum employment age in the country (whichever is higher). AKIŞ takes the strongest measures in the recruitment process to protect children from the worst forms of labor. Employees under the age of 18 (Young Workers) are not employed in jobs that may endanger their health and safety, such as night shifts and overtime.
4.5-Working Hours
Working hours are regulated, monitored and documented in accordance with the law. All overtime is voluntary. AKIŞ grants its employees the right to at least one day of rest in every seven-day period.
4.6-Fees and Benefits
We regulate our working hours and wages in accordance with the law. No wage is paid below the minimum wage determined by the state. Wages to be paid to employees, overtime hours and compensations related to mandatory social rights are determined in accordance with the laws in force. We are committed to the principle of equal pay for equal work for all our employees.
4.7-Anti-Discrimination and Anti-Harassment
Any form of harassment, discrimination and unequal treatment in employment against employees is not tolerated and is prohibited. AKIŞ rejects discrimination based on the characteristics of employees such as race, religion, belief, gender, age, marital status, national origin, citizenship, political views, social background or disability status. AKIŞ is committed to ensuring that its employees have equal opportunities and are treated equally based on merit. Physical, psychological, verbal or sexual harassment or abuse is never accepted. Care is taken to protect the personal rights of employees. Necessary measures are taken to prevent physical and emotional wear and tear. The Disciplinary Regulation supporting these requirements is binding on all employees. In cases of non-compliance, legal sanctions, including dismissal, are applied.
5-HEALTH AND SAFETY
In order to create a healthy and safe work environment, we act in accordance with Occupational Health and Safety legislation in our work. We ensure, require and supervise the use of adequate protective equipment and the taking of safety measures. We do not allow the use of any alcohol, drugs, etc. in the workplace or in a way that will affect work performance, and smoking outside of designated areas. Implementing company policies (Energy, Environment and OHS policy) and legal requirements regarding health and safety in the workplace is an important responsibility that all our employees must pay attention to. We take precautions to reduce Occupational Health and Safety risks, conduct personnel training and awareness activities. We make investments in this area.
6-ENVIRONMENT
As an environmentally friendly company, we carry out our activities in full compliance with environmental legislation. We work to prevent air, water and soil pollution. We attach importance to recycling and reuse processes in order to reduce the amount of waste and we make investments in this area. We conduct informational activities to prevent damage to forests and water resources; we develop methods to protect natural resources such as soil, water and air, and we work to ensure the efficient use of energy and materials. We manage wastewater, air and noise emissions arising from our activities in accordance with the Non-hazardous and Hazardous Waste Management Regulation. We identify risks for environmental emergencies and take measures to reduce them. We raise awareness of our employees and suppliers by conducting environmental training and awareness activities (Energy Environment and OHS policy). AKIŞ is aware of the impact of greenhouse gas emissions on global warming. It monitors carbon emissions and takes measures to reduce direct and indirect CO2 emissions.
7 - BUSINESS PRACTICES AND MANAGEMENT RESPONSIBILITIES
AKIŞ promotes integrity and ethics in all aspects of its operations. Therefore, we comply with all relevant laws and regulations regarding privacy, data protection, corruption, bribery, prohibited business practices and competition law. AKIŞ uses an ethics reporting channel for reports of unethical or professional standards violations or other inconsistencies. See section 8 “Responsibility for Compliance and Reporting Violations” for details.
7.1-Protection and Confidentiality of Personal Data
AKIŞ processes personal data in accordance with applicable laws. Personal data is processed fairly and carefully in all cases. AKIŞ has taken appropriate organizational and technical measures to ensure the security of personal data.
7.2-Economic Sanctions and International Trade
AKIŞ and its subsidiaries are subject to different economic sanctions laws due to their operations in more than 70 countries worldwide. Regardless of the country they operate in, the fundamental principle of AKIŞ and its subsidiaries is to act in accordance with the regulations and legislation regarding economic sanctions adopted by the United Nations, the European Union, international organizations and various states. In this context, we expect all our employees to care about the issue of economic sanctions and to seek advice from our Company's Corporate Legal Advisor if they encounter a situation that may cause a problem. AKIŞ complies with all applicable national and international trade sanctions and embargoes, as well as all applicable export and import controls and customs laws. AKIŞ maintains and shares accurate commercial data, information and documentation regarding its products.
7.3-Fighting Against Corruption and Bribery
AKIŞ fights against all kinds of corruption and bribery and expects the same dedication from all relevant parties (Anti-Bribery and Anti-Corruption Procedure and Workplace Disciplinary Regulation).
7.4-Fair Competition
Violation of the regulations in the Competition Law Legislation may have serious consequences, including legal sanctions, for AKIŞ and its subsidiaries, and most importantly, may seriously damage AKIŞ's reputation. Employees are required to conduct their work in accordance with the AKIŞ Competition Law Legislation, and this is an important part of the duties and jobs of all managers and employees. Behaviors that may harm fair competition and create legal concerns, such as sharing pricing, market shares or other undisclosed information, should be avoided. Ensuring compliance of AKIŞ and its subsidiaries and employees with Competition Law Legislation and taking necessary actions to manage the risks arising from this are primarily the responsibility of the relevant Department Managers. The audit and supervision obligation in this regard belongs to the Sales and Marketing Managers and the General Manager. (Anti-Bribery and Anti-Corruption Procedure and Workplace Disciplinary Regulation).
7.5-Unfair Competition (Relations with Competitors)
We avoid actions that would constitute unfair competition in all countries in which we operate. We also hold our employees responsible for complying with laws and regulations. We do not make negative statements against our competitors and their managers, and we avoid statements that would speculate about them and their products. We never resort to illegal or unethical means to access information about other companies, and we develop regulations to prevent our employees from resorting to such means. We do not allow our employees to disclose any data that determines or influences the company's competitive behavior. We also do not tolerate our employees gathering market intelligence by secretly obtaining information belonging to others through industrial espionage, bribery or theft. (Anti-Bribery and Anti-Corruption Procedure and Workplace Disciplinary Regulation).
7.6-Advertisement and Promotion
AKIŞ and its affiliates do not advertise misleadingly or deceptively, or make false statements in their sales and marketing activities. Their advertisements do not discriminate based on gender, religion, language or race, and do not include elements that humiliate or include violence.
7.7-Prevention of Money Laundering
Aiding and collaborating in any way with a person who commits a crime or violates the law by legitimizing the source of their income or the goods they directly or indirectly profit from through deceptive means and participating in a process aimed at depositing, concealing or laundering the resources obtained from such activities is defined as money laundering. We oblige our employees to show due diligence in combating money laundering and corruption. To this end, our employees must comply with all applicable laws and regulations and company policies. We also expect the same sensitivity from our customers and suppliers who do business with us. AKIŞ is obliged to support efforts to combat money laundering and prevent money laundering activities.
7.8- Abuse and Irregularity
We refrain from any unethical activity that would provide bribery, fraudulent behavior or unfair gain in the countries and business areas where we operate. We require our employees to act in accordance with the relevant laws or regulations in the business relations for which they are responsible, not to knowingly cooperate with parties that violate these, not to act contrary to ethical principles, and to avoid fraudulent and wrong means. We do not accept our employees to harm AKIŞ by using their authority for the benefit of themselves and/or their relatives and outside the care expected from them. We do not allow our employees to directly or indirectly gain personal gain from AKIŞ's purchasing and sales activities and all transactions and contracts to which it is a party. We expect our employees to immediately inform their managers and/or the AKIŞ Ethics Board if they detect any irregularity in this context in their business relations.
7.9-Separation of Institutional and Personal Interests (Conflicts of Interest)
We define a conflict of interest as the situation where our employees, their family members and relatives benefit from the commercial activities carried out by AKIŞ and its subsidiaries with their customers and suppliers. We do not allow our employees to work as suppliers or customers of the companies they work for. Likewise, family members and relatives cannot be suppliers or customers of the companies our employees are affiliated with. We do not accept our employees to act against the interests of our suppliers and customers. We also do not allow them to lend money. Similarly, we do not allow our employees, their family members or relatives to benefit from special advantages and conditions provided to the company by the supplier or customer for their personal interests. We recommend that our employees first consult the AKIŞ Ethics Board and their immediate superior to be informed about whether the transactions to be carried out in such and similar cases create a conflict of interest.
7.10-Relations with Suppliers and Business Partners
We always take care to act honestly and fairly in our relations with our suppliers and business partners. We expect our suppliers and business partners to comply with the AKIŞ Ethical Principles and Working Principles, to share the same values and to act within this framework. We oblige our suppliers and business partners to carry out their activities in accordance with laws and regulations, to respect the rights of their employees and to comply with standards such as protecting the environment. (Anti-Bribery and Anti-Corruption Procedure and Workplace Disciplinary Regulation).
7.11-Relations with Customers and Consumers
We consider the satisfaction of our customers as our priority. We avoid unfair or misleading practices in our relations with our customers. We evaluate the opinions, demands and complaints of our customers and consumers and take them into consideration in our decisions. We quickly resolve any problems arising from our companies or channels during the process of our products reaching our consumers and we try to carry product quality beyond the expectations of the consumer. We aim to provide the best service by focusing on changing customer and market needs. (Anti-Bribery and Anti-Corruption Procedure and Workplace Disciplinary Regulation).
7.12-Social Responsibility, Volunteering, Donations
With a sense of social responsibility, we take part in projects that will contribute to the development of society and provide donation support. We seek the condition that our corporate donations and social supports are made to projects, institutions and organizations that comply with our internal regulations, AKIŞ Ethical Principles and Working Principles and our company reputation. We do not make donations to individual accounts or profit-oriented organizations. (Anti-Bribery and Anti-Corruption Procedure and Workplace Disciplinary Regulation). We encourage our employees to participate in social activities such as environment, health, education and sports, and we adopt the principle that participation in individual volunteer activities should be done with their own resources, outside the workplace and in a way that does not affect work performance. We take utmost care to protect human and public health and the environment both in our own activities and in the activities of our suppliers and business partners.
7.13-Acceptance and Giving of Gifts and Benefits (Credits, Discounts, etc.)
We do not allow our employees to receive or give gifts of money or cash equivalents from customers and suppliers of AKIŞ and its affiliates that would affect their impartiality and decisions. Our employees are rewarded with gifts within the framework of the internal reward system within the company. Apart from this, we require our employees to comply with the relevant company regulations regarding accepting and giving gifts (Anti-Bribery and Anti-Corruption Procedure and Workplace Disciplinary Regulation).
7.14-Representation and Entertainment
We allocate a representation expense allowance for the cost of hosting customers and business meetings. We want representation expenses to be used only in the areas they are relevant to. It is essential that expenses are documented with an invoice and an invoice cannot be obtained from another source for expenses for which an invoice is not issued. In cases where necessary, we request that an expense note be prepared in accordance with the laws. Expenses that are not legally accepted are kept in the Non-Legally Acceptable Expenses accounts and recorded in the receivables accounts in the relevant companies. Business-related entertainment activities are meticulously supervised with the help of corporate standards and relevant internal regulations and approved by the company's senior management. Other than this, entertainment expenses cannot be accepted.
7.15-Tasks Accepted Outside
We expect our employees to comply with their employment contracts and loyalty rules. We do not allow our full-time employees to work in an organization outside the company in accordance with the regulations in force. We do not allow our employees to engage in activities that are defined as “merchants” or “tradesmen” directly or indirectly. Likewise, they cannot work in competing companies or companies with which the company has business relations. We allow our part-time or consultant employees to continue their work outside of competing companies, provided that they inform the company management they are affiliated with. Our employees may operate at a representative level in other companies with the approval of the Chairman of the Board of Directors.
7.16-Relations with Public Institutions and Organizations
While conducting all our activities and transactions, we keep an equal distance from public institutions and organizations, non-governmental organizations and political parties without expecting any benefit. We avoid any relationship, influence or activity that would prevent fair decisions regarding our activities. We do not provide any financial or moral value to any public official. We hold our employees who participate in bids, tender preparations or contract negotiations responsible for the accuracy and truthfulness of all statements, correspondence and representations they make to relevant parties.
7.17-Cyber Security
AKIŞ is committed to complying with applicable cybersecurity laws and regulations. It takes precautionary measures to ensure the security of the products, systems and services offered.
7.18-Protection of Company Assets and Data Confidentiality Protection of Institutional Assets
Our employees are responsible for the proper use of all assets and resources of the group, including intellectual property rights, technology, computer hardware and support, software, real estate assets, machinery and tools, raw materials, company vehicles and cash values. The equipment, systems, facilities and assets of AKIŞ and its subsidiaries are used only for the purposes of conducting the company's business or authorized by the management. Unless otherwise provided in the regulations published by the company, our employees are not allowed to use company assets for personal purposes or for the benefit of anyone outside the company. We expect our employees to use company assets in accordance with corporate principles and regulations. We take measures to prevent the use or damage of these assets by unauthorized third parties. All of AKIŞ's Information Technology Resources and the information created, stored or transmitted using these resources are the property of AKIŞ. Our employees use and protect these resources for business purposes, in accordance with the laws and company regulations, responsibly and take the necessary measures to prevent unauthorized persons from accessing these resources. The confidentiality agreement terms determined by AKIŞ apply.
7.19-Confidential Information and Protection of Confidential Information
The titles included in the scope of confidential information at AKIŞ and its subsidiaries are as follows: “Commercial information, technical data, financial data, production data, customer information, personal information, product information, equipment and application information, technical formulas and drawings, system and program information, purchasing information, engineering information, regulations, business plans, internal documents and all information that the company does not disclose to the public, including but not limited to these.” This information is not called confidential, but it is confidential. Our employees protect all confidential information and documents they access while performing their jobs. They use the confidential information they access only for the benefit of the work they do for the company, within the framework of legal and ethical rules. Our employees can never share information that has not been disclosed to the public with third parties for any reason or for their personal interests or the interests of someone outside the company. Even if our employees leave their jobs, they cannot use or have used any of the confidential information and documents mentioned above belonging to the company, directly or indirectly, verbally or in writing, for the benefit of themselves or third parties without the written permission of the company. We expect our employees to be extremely careful about the aforementioned data confidentiality and security issues when using all kinds of Information Technology resources and electronic communication tools. We require our employees to comply with company policies and instructions without exception in taking the necessary precautions to prevent confidential information from falling into the hands of unauthorized persons or leaking to the outside.
7.20-Intellectual Property Rights
Intellectual Property Rights include trademarks, patents, designs and copyrights included in the Industrial Property Law and the Law on Intellectual and Artistic Works, as well as technical information (know-how) that has not been made public. Intellectual property rights belonging to AKIŞ and its affiliates are extremely valuable assets and must always be well protected. The commercial/financial rights of all kinds of products, designs, programs, etc. innovations created by our employees while they are employed or by using company resources as part of their duties, namely intellectual property rights, belong to the company, and no one can claim any rights against the company in this regard. We expect our employees to be aware that all kinds of correspondence, written materials, documents or records, special process information, regulations, special workflow information belonging to our company - whether confidential or not - are the property of AKIŞ and its affiliates and must remain within the organization. We require our employees to comply with rules and laws regarding licenses, patents and copyrights, and we obtain all software and copyrights required to do their jobs through legal means.
7.21-Accuracy in Records and Financial Reporting Accurate and Complete Record Keeping
Accurate and Complete Record Keeping In AKIŞ and its subsidiaries, it is essential that all our records are kept in accordance with the legislation. Documents related to commercial and financial transactions must reflect the real situation. No payment can be made or approved for use other than its purpose. Accurate information and financial reports must be submitted to all necessary places. In all services and transactions of AKIŞ and its subsidiaries, accurate, complete and timely information is provided to investors, customers, suppliers and official authorities in accordance with the legislation.
7.22-Conflict Minerals
AKIŞ is aware of and complies with the laws, regulations and legislation regarding conflict minerals and tin, tantalum, tungsten, their ores and gold originating from conflict areas. Additionally, AKIŞ will not use raw materials in its products that finance armed groups that violate human rights.
7.23-Product Safety, Product and Service Quality
We act in accordance with the legal regulations in the countries we operate in, and contribute to the formation of legal regulations aimed at ensuring product quality and consumer welfare. In addition to national standards, we carry out our activities in accordance with international quality standards such as ISO, IATF, etc., and protect the quality certificates we have together with all our employees. With all our processes and products, AKIŞ aims to contribute to the sustainable use of resources and the protection of the environment, including the protection of the climate. AKIŞ strives to reduce the use of energy, water, raw materials and other resources by constantly harmonizing the quality and performance of its products in line with environmental sensitivities. Within the framework of our ethical approach, as a leading company, we use technologies that will contribute to the lives of individuals and support them to live better, and we produce beneficial products with these technologies. We offer high-quality products and strong brands that our consumers can easily reach, with the best service.
8- COMPLIANCE RESPONSIBILITY AND REPORTING VIOLATIONS
AKIŞ employees and related parties, when they need to about the Code of Ethics and Working Principles; Their immediate Superiors, the relevant Human Resources Unit, they should consult with the AKIŞ Ethics Committee. Report any action or situation that they believe violates the Code of Ethics; they should report to AKIŞ Ethics Committee via www.akisasansor.com.tr . While it is preferred to report a violation by name, anonymous reports that include concrete evidence and serious proof may also be taken into consideration. The evaluation of the violation will be made by the AKIŞ Ethics Board, and if necessary, the opinion of the relevant support unit (Legal, HR, etc.) will be obtained. All reports will be kept confidential. The reports will be reviewed by the AKIŞ Ethics Board and appropriate actions/measures will be taken in line with the decision of the board. AKIŞ is determined to protect the rights of employees who report to the AKIŞ Ethics Board. No retaliation will be allowed against any employee due to the report, and necessary actions will be taken against those who attempt retaliation.
We expect our employees to display a sense of responsibility and attitudes in accordance with business ethics, and to always act consistently in accordance with the meaning and purpose of the Ethical Principles and Business Principles.
