CODE OF BUSINESS CONDUCT

We, as MİTAŞ Group of Companies, comply with the sector’s ethical professional principles and professional code of conduct in all our activities and processes. As we commit by participating in the United Nations Global Compact, we fully adapt to the human rights, working conditions, universal principles related to environment and decent society. We attach particular importance to ensure that these principles which we internalize are applied by all our stakeholders. We support social development and environmental protection.

Our basic principles guide us in all our operations and actions.

Honesty: We abide by the principle of honesty in all our works and activities, relations with all our stakeholders and other parties.

Reliability: We provide explicit, comprehensible and exact information to the customers and all other stakeholders in accordance with the timely, complete works performed and parole.

Objectivity: We do not treat our stakeholders with prejudice due to gender, behaviour, idea and ethnic origin; we do not discriminate under any circumstances.

Compatibility: We comply with all laws, regulations and standards.

Transparency: We inform the customers and public fully, exactly and timely excluding confidential information.

Protecting Social Benefit and Environmental Impact: In all its processes, operations and investments, Mitaş Group protects the issues of social benefit, sector’s development, sustainability and sustainability of trust for the sector in line with the company’s image, benefit and profitability; complies with the regulations on environmental, consumer and public health.

We acknowledge that the rules we have to abide by regarding our approach and operations are not limited to the aforementioned issues and it is not possible to put all the ethical principles into writing.

In case of encountering a situation other than those written here, we act in the light of our basic principles and consult our superiors about uncertain situations.

We acknowledge that we have to abide by the ethical principles as a whole for maintaining the company’s success and protecting Mitaş Group’s reputation. Even the action of one of us against such ethical principles may effect our reliability and operations before our stakeholders.

Thus, when we encounter an action or process against our ethical principles or we have a suspicion, we absolutely inform the breaches to our superiors. This is as important as acting in accordance with the ethical principals.

Volkan KARABAĞ
Chairman of the Board

OUR ETHICAL PRINCIPLES

1 - Protecting Social Benefit, Decent Society, Fighting against Corruption and Bribery

Human Rights

Everyone is entitled to the basic human rights stated in the United Nations-Declaration of Human Rights such as the right to live, be free, be in safety, not to be tortured and treated badly, to fair and impartial trial, privacy, settlement and travel, marry, acquisition of property, think and declare ideas, participate in the public administration by general and equal vote, has freedom of association, equally benefit from the public services, work under fair and equal conditions, rest and paid annual leave, social security, fair and equal education, participate in and benefit from scientific, artistic and cultural activities, religion and conscience.

We strictly prohibit human rights violations, including slavery, forced labour, child labour, human trafficking, and workplace abuse, related to our own operations, our supply chain and our products.

In this context, respect to human rights is our priority.

Working Conditions

We give importance to healthy, safe and secure working environment.

We do not tolerate forced labour practices and child employment.

We do not subject our employees to discrimination and harassment due to their race, gender, belief, religion, ethnic origin, political opinion, age, disability, etc.

We do our best to ensure that our stakeholders also give importance to these issues.

Environment

We carry out studies for efficient use of natural resources and minimizing the wastes arising from our processes.

We fully comply with the environmental law and regulations. We encourage our stakeholders to develop awareness on this issue. We request the companies which we do business with to take the necessary measures on this issue.

We conduct activities to encourage our employees and other stakeholders to support recycling and reuse activities and to promote awareness on this matter.

We cooperate internationally and support transparency policy to decrease greenhouse gas emission.

In the selection of procurement of products and services, we prefer suppliers which work by using social and environment-friendly activity /production systems.

Compliance with Policy on Decent Society, Fighting Against Corruption and Bribery

In our relations with relevant institutions we expresss clearly that all kinds of bribery and corruption are unacceptible by our company and that we do not finance initiatives for drugs and gambling.

We acknowledge that the purpose of policy for fighting against corruption and bribery is to comply with the laws and regulations against corruption and bribery, ethical and professional principles and universal rules applicable in all the countries our companies are operating and exercise due dilligence on compliance with this policy.

We acknowledge that our policy for fighting against corruption and bribery covers all our employees including the Executive Board, subsidiaries and affiliates and their employees, outsourcing companies which we procure products or services and their employees, the persons and institutions acting on behalf of the company including suppliers, consultants, lawyers and external auditors.

Social Contribution

As an extension of sustainable development and social contribution, we put the social contribution activities into practice in accordance with the requirements and demands of physical and social environment we live in; we develop social responsibility projects in the fields of culture, art and education.

Sustainable Procurement

In the selection of procurement of products and services, we prefer suppliers which have social and environment-friendly activity / production systems.

We expect our suppliers to conduct their relationship with us on a fair and ethical basis and in compliance with our core principles of sustainability in this code of conduct.

2 - Our Responsibilities for Our Customers

Honesty, Transparency and Reliability

We inform our customers regarding their rights and obligations fully, accurately and timely.

We explain to our customers the points to be taken into consideration, benefits, costs and potential risks related to the products and services they use to our customers clearly and timely.

We take care of making clear and exact explanations to our customers, not using technical terms that they would not understand and do not use exaggerated, misleading statements.

We do not make commitments which we can not fulfill related to the products and services to the customers; live up to our promises and do not allow impairment of reliability.

We do not give incomplete and incorrect information to the customers in any way, shape or form; do keep away from all kinds of behaviours and attitudes to be perceived as the breach of customer rights.

We are aware that we have to provide our customers with quality service. Therefore, we try to understand their requirements and expectations properly and create the right solutions for them.

Objectivity

We do not discriminate between our customers on the issues such as race, gender, belief, religion, ethnic origin, nationality, political opinion, age, disability and etc.. We provide our customers with equal and impartial service within the law.

We do not get into religious, political, ethnical and such discussions with our customers.

Customer Complaints

In case the customer’s requests are outside our authority and responsibilities or in fields we do not have adequate knowledge, we convey the subject to the authorized persons or departments.

We provide our customers with the best service; show ultimate attention to prevent customer complaints in the operations carried out.

We try to solve the customer complaints as soon as possible and take the necessary measures to prevent reoccurrence of such complaints.

Compliance with Laws and Regulations

We acknowledge that we have to comply with all the related laws and rules fully.

Fighting against Laundering of Assets Arising from Crime

We are aware of our legal obligations and social responsibility regarding laundering, terrorism financing and other crimes in accordance with our policy in fighting against laundering and terrorism financing.

Cooperation with State Institutions and Organizations

We act in accordance with honesty, accountability and transparency in our relations with the official authorities; take care of submitting the information, documents and records requested for control and audit in accordance with the legislation correctly, completely and timely.

3 - Relations with Media, Public and External Institutions and Persons

Use of Mitaş Trademark and Group Company Names

We acknowledge that trademarks of “MİTAŞ” and our Group Companies are one of the most precious assets of our Group.

We acknowledge the rules and practices related to use of these trademarks and do not use the names, logos and trademarks of our companies outside our work as a general rule.

We do not cause loss of reputation of our trademarks in our works and activities.

Written and Visual Media

We meet the non-business, social / personal demands without using the names of Mitaş and our Companies.

Internet And Social Media

We do not forget that we represent our companies while using the internet and social media. We do not get involved in any connections humiliating and discrediting our companies.

We act in accordance with the regulations such as copyrights and fair use; we do not share the written and visual contents which are against the laws and legislation or including crime elements.

External Institutions and Persons

We do not express any opinions, disclose confidential information on behalf of our companies without the knowledge and consent of the related department in the organizations such as conference, panel, seminar and so on that we are provided to participate in due to our assignment or for training purposes.

We do not disclose confidential information; we do not let our own ideas and opinions shared in the negotiations and talks be perceived as our companies’ in the organizations we participate in out of working hours such as training, course, conference, seminar, panel and etc.

Our Relations with Professional Organizations and Other Companies

Provided that secrets of customers and other companies are not violated; we exchange correct, complete and comprehensible information with the professional organizations within the scope of legislation and principles of our companies’.

We acknowledge that intervening in the free markets and prices of products and tools in these markets or trying to disturb the competitive environment is unacceptable.

In our announcements and advertisements, we act in accordance with the legal regulations and public morality, honestly and realistically; we do not include statements and expressions unflattering other companies or products and services; we avoid all kinds of actions to damage their respectability and reputation.

We avoid all kinds of practices that may cause unfair competition regarding staff recruitment.

4 - Protection of Corporate Assets

Our customers’ and companies’ information are one of our most important assets. The confidentiality of this information should be protected and access of unauthorized persons should be prevented for sustainability of our activies and performance. Confidentiality and information security are also requirements of legal regulations and their violation is subject to legal sanctions. We have to act more responsibly for providing the security of information in this era when data communication channels are highly developed.

Customer Information

We do not misuse customer information that we have due to our position.

We acknowledge our responsibilities on providing the confidentiality of customer information; provide the security of such information and do not share such information with anyone other than legally authorized persons and institutions.

Our Stakeholders Information

We give importance to confidentiality of personal and working information of our employees; take the necessary measures to prevent access of unauthorized persons to such information.

We acknowledge that the information related to our suppliers, project and business partners, other stakeholders are private and confidential; do not share such information with the unauthorized persons.

Protection against Risks

We are aware of the fact that one of the most critical issues is effective risk management. We assess the possible results of our processes and risks we undertake; take care of our activities to be in compliance with the general risk policies and risk management principles.

We act in accordance with the protocol, requirements of professional business life, social norms and ethical principles.

Conflict of Interest

Conflict of interest may be defined as the situation in which an employee himself, his relatives or companies or persons with which he has relationship take a role or a task in the business relation with our companies, thus causing conflict between the employee’s self-interest and the interest of company, or occurrance of such a perception.

Based on this definition, we comply with the basic principles regarding;

  • Non-business activities,
  • Corporate opportunities,
  • Business relations with the parties,
  • Personal business relations,
  • Charities, grants and contributions,
  • Gift acceptance,
  • Political activities and financial contributions.

However, we are aware that situations that may cause or be perceived as conflict of interest are not limited to the aforementioned issues. Thus, we assess our each process and action based on;

  • whether it will be perceived as conflict of interest by the others, and in case of occurrence whether it will put us and our companies in a difficult situation,
  • whether it will affect our objectivity or it will be perceived as breach of objectivity, if not,
  • whether our stakeholders’ will be negatively affected,
  • whether it will negatively affect our duties and responsibilities.

Charities, Grants and Contributions

We may participate in non-profit associations, foundations, cooperatives with the professional organizations like Chamber of Commerce, Stock Market; however, we do not use our companies’ names, facilities and assignments during our duties in the non-profit organizations.

We never make donation requests or similar requests from the customers or other employees even on behalf of the association or various institutions.

We acknowledge that the consent of competent authorities is required for the grants and donations to be made.

We make sure our personal donations to the non-profit organizations to be confidential, voluntary and not to be related to our business

Gift Acceptance

We never accept gifts other than low priced, symbolic gifts from our customers, suppliers and other persons and institutions. We particularly do not accept gifts which may be perceived as effector in our decisions to be taken on the business.

Political Activities and Financial Contributions

We do not actively participate in any political party and institutions which are extensions of such parties; avoid any kind of action which may be seen as financial support to these political parties.

Discrimination and Harassement

We do not allow an employee to be subjected to discrimination and harassement on the issues such as race, gender, belief, religious, ethnic origin, political opinion, age, disability and etc.

We do not make an employee do our personal works incompatible with his duties, authorities and responsibilities.

We acknowledge that career development is based on capacity and performance; and we act accordingly.

We do not cause mobbing in the workplace.

Safety and Business Continuity at Workplace

We, as employees, show a maximum effort to comply with all health and safety policies for providing safety at the workplace.

In case of fire, natural disaster or other emergency situations to suspend business continuity, we acknowledge the emergency plans within the scope of our business continuity plan for continuing to fullfill market’s and customer’s requirements and providing business continuity and our responsibilities within this context if any, and apply them when necessary.