Chapters
Our Compliance Program, Business Ethics Principles, and Common Code of Conduct
Every workday, we make decisions and choices in line with our company’s strategic goals. While striving to achieve these goals, we are expected to be both creative and efficient while also complying with applicable regulations and company policies. In every business decision we make, we aim to maintain this delicate balance in our professional lives. This means understanding the boundaries set by the regulations and rules we are subject to and making the most creative, beneficial, responsible, and fair business decisions within those boundaries.
Our Relationships with External Stakeholders and Our Responsibilities Toward Them
Anti-Corruption: Definition and Scope
The definition of corruption and the parties involved in bribery can vary from country to country. However, according to our compliance policies, corruption includes any direct or indirect act of bribery or illicit benefit that leads to deviations in the lawful execution of duties. This includes soliciting, offering, giving, or accepting any illegal benefit. In other words, our definition of corruption is not limited to interactions with public officials or institutions but extends to individuals and private sector companies, covering all practices that disrupt fair competition.
Relations with Public Officials
Even though we define bribery and corruption beyond interactions with public officials, we must always exercise great care when engaging with them.
Facilitation Payments
Facilitation payments refer to small, low-value payments given voluntarily or under perceived obligation to public officials to expedite routine procedures. While these payments may be culturally accepted in some regions, they pose compliance risks and must be strictly avoided.
Gift Exchange
The exchange of gifts, representation, and hospitality is an inherent part of the business world. However, it must be carefully regulated and managed under strict policies. Failure to do so can expose both individuals and the company to significant risks.
Donations
Regardless of whether a company has a social responsibility strategy, many corporations, as part of corporate citizenship, mobilize resources to address social and environmental challenges. Companies announce and implement support programs within their capabilities to contribute to these causes.
Fair Competition Principles
Our company strictly adheres to all applicable competition laws and is committed to maintaining fair competition conditions. All employees are expected to comply with competition law regulations. If you suspect that a particular action or situation may violate our fair competition principles, you should seek guidance from your manager or report the issue to the compliance officer.
Accuracy of Financial Records
It is crucial to ensure that all accounts, invoices, and records related to relationships with third parties, such as customers, suppliers, and service providers, are complete, accurate, and properly maintained. No modifications should be made to accounting or commercial records related to any transaction, and facts must not be misrepresented.
Our Relationships with the Environment and Society & Our Environmental Responsibilities
We strive to prevent all forms of pollution and conduct our operations with minimal energy consumption and the least possible negative impact on the environment by continuously improving our business processes. We aim to enhance our environmental protection practices, promote environmental responsibility, and contribute to the development and dissemination of eco-friendly technologies. We expect you to adhere to the following fundamental principles:
- Always consider environmental factors in your daily work.
- Follow the environmental protection instructions given to you.
- Contribute to the conservation of energy and other resources.
- Set an example in reducing environmental impact, including energy consumption.
Our Speak-up Culture
Whenever you find yourself in a dilemma, feel that you are facing an inappropriate situation, or witness such an incident, you should first refer to our company’s relevant policy and make your decisions in line with its guidance. Suppose you have read the policy and still have doubts or concerns… In that case, you should seek help from your senior manager. If you are unable to find the answer there or if the situation involves your senior manager, you should reach out to the ethics and compliance officer.
