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Anti-Bribery and Anti-Corruption Polic

PURPOSE
1.1. The Anti-Bribery and Anti-Corruption Policy (hereinafter referred to as the “Policy”) aims to clearly state HES Kablo A.Ş.’s (hereinafter referred to as the “Company”) approach to bribery and corruption. With this policy, the Company aims to comply with anti-bribery and anti-corruption laws and regulations, legal regulations and ethical principles in the countries where it operates, and to determine responsibilities and rules in this regard.
DEFINITIONS
2.1. In this section, special terms and concepts used in the policy are briefly explained as follows.
Company: HES Kablo A.Ş.
Employee: Refers to company mandaterse and employees.
Bribery: A person acting contrary to the requirements of his/her duty and gaining a certain benefit by doing, not doing, speeding up or slowing down a job within the framework of an agreement reached with a third party.
Corruption: Requesting, offering, giving or accepting a bribe or any other illegal benefit that leads to deviations in the lawful performance of duties or required behaviors carried out by a person who obtains bribes or illegal benefits directly or indirectly due to the position held.
Donation: Refers to material aid or products provided without consideration in order to create corporate responsibility awareness among stakeholders and employees with a sense of social responsibility, to meet social and community needs and to provide public benefit.
Gift: Refers to products and services that do not require a financial payment and are generally given by people with whom business relations are established or suppliers as a form of gratitude or commercial courtesy.
SCOPE
3.1. This policy covers;
a) Members of the Company's Board of Directors,
b) Company Employees,
c) Companies and employees from which goods and services are purchased,
d) Persons and organizations acting on behalf of the Company, including consultants, lawyers, advisors and external auditors, and other persons including customers with whom it has commercial relations ("Business Partners").
PRINCIPLES AND BASIS
4.1. Bribery and Corruption
4.1.1. The Company has established a policy to combat bribery and corruption as an indication of its sensitivity to business ethics. Bribery and corruption can be carried out in many different ways, including:
a. Cash payments, Political or other donations,
b. Commission,
c. Facilitating payments,
d. Social rights,
e. Hiring a relative,
f. Promotion,
and other benefits.
4.1.2. Within the scope of the principles set forth in this Policy, the Company undertakes to conduct its activities in a fair, transparent, honest, legal and ethical manner.
4.1.3. The Company is extremely sensitive about combating bribery and corruption, is against bribery and corruption, and does not tolerate activities involving bribery and corruption. In this respect, it is unacceptable to offer, imply, receive or give bribes.
4.1.4. It does not adopt as a principle the continuation of business relations with third parties who want to work with the Company through bribery.
4.1.5. Employees shall not be penalized for delays or loss of earnings arising from their refusal to give or receive a bribe.
4.1.6. The Company complies with local and operational laws, regulations and principles regarding the fight against bribery and corruption. Within the scope of its activities, it complies with the Council of Europe Convention on Civil Law Against Corruption and the Criminal Law Convention on Corruption, which Turkey is a party to, and the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions.
4.2. Relations with the Public
4.2.1. It is unacceptable to undertake or imply to give any valuable gift and/or thing to a Public Official, or to make any kind of payment, directly or indirectly, for the purpose of influencing an official action or decision.
4.2.2. In addition, employees cannot bribe public officials directly or indirectly in order to gain benefits in public affairs.
4.3. Agreements and Tenders
4.3.1. The Company takes care to act in accordance with this policy in the agreements it enters into, in the event of initiating or continuing a business relationship, and in public or non-public tenders.
In addition, the Company is expected to act in accordance with this policy in mergers and acquisitions and joint venture processes, and the target companies or companies that are worked with in these processes are also expected to act in accordance with this policy.
4.4. Facilitation Payments
4.4.1. The Company does not allow facilitation payments to secure or accelerate a routine transaction or process (such as obtaining permits, licenses, tender procedures) with public institutions.
4.5. Donations and Gifts
4.5.1. The Company's principles regarding donations and gifts are detailed in the Donation and Aid Policy.
4.6. Keeping Records
4.6.1. The matters that the Company must comply with regarding the accounting system are regulated within the framework of the relevant legislation and regulations.
a. All kinds of accounts, invoices and documents related to relations with third parties (customers, suppliers, other service providers, etc.) are recorded and preserved in a complete, transparent, accurate, fair and reliable manner,
b. Establishment of internal control systems to prevent off-the-record transactions and
c. No changes are made to accounting or similar commercial records related to any transaction and no distortion of facts shows care.
4.7. Representation and Hospitality
4.7.1. Among the representation and hospitality event activities;
a. Social Activities,
b. Accommodation and
c. Dinner Invitation
could be considered.
4.7.2. The Company may perform representation and entertainment activities to develop its commercial relations and establish a commercial communication network.
4.7.3. The Company endeavors to ensure that these activities are reasonable. It takes care not to perform representation and entertainment prior to a fundamental and important decision-making process.
4.8. Training and Communication
4.8.1. The Anti-Bribery and Anti-Corruption Policy has been announced to the Company Employees and is continuously and easily accessible through the institution's website.
4.8.2. Training is organized to raise awareness among employees about anti-bribery and anti-corruption.
4.9. External Service Providers and Business Partners
4.9.1. The Company does not work with individuals and organizations that have negative intelligence regarding bribery or corruption as business partners, suppliers, etc.
4.9.2. External service providers and business partners are obliged to comply with this policy and other relevant regulations. The Company informs these companies and business partners about the policy in question. Business relationships cannot be established with individuals and organizations that do not comply with the rules and other regulations in question, and existing relationships are terminated immediately.
DUTIES AND RESPONSIBILITIES
5.1. Board of Directors
5.1.1. The Company's Board of Directors is responsible for the creation, implementation and updating of the policy.
5.1.2. The Board of Directors is responsible for the effective oversight of the Ethics Committee and Internal Audit Department, which have notification, investigation and sanction mechanisms in case of violations and suspicious situations that are contrary to the principles and fundamentals included in the policy.
5.2. Ethics Committee
5.2.1. The Ethics Committee ensures that the necessary communication channels are established for reporting violations and suspicious situations that are contrary to the principles and fundamentals included in the policy and takes measures to ensure the confidentiality and security of the persons making the notification.
5.2.2. The Ethics Committee meticulously handles the complaints and reports received and initiates the necessary investigation. If a violation of the rules is detected as a result of the investigation, it brings the issue to the agenda of the Internal Audit Department with the necessary evidence and documents. In addition, it takes the necessary measures and establishes the necessary mechanisms to prevent the same violation from occurring again.
5.3. Internal Audit Department
5.3.1. The Internal Audit Department makes objective assessments on situations that may result in Disciplinary Penalty in accordance with the relevant legislation in case of detection of violations and suspicious situations that are contrary to the principles and fundamentals included in the Policy.
5.3.2. The Internal Audit Department, Failure to Act in Accordance with the Policy:
5.3.2.1. It has the right and authority to receive a defense from the employee, initiate an investigation, suspend the employment contract, terminate the employment contract and exercise its rights pursuant to the Labor Law and applicable legislation.
5.3.2.2. It has the right to stop receiving services from consultants, lawyers and financial experts who do not act appropriately and to terminate service contracts.
5.3.2.3. It has the right and authority to stop, suspend and terminate commercial business relations with business partners who do not act appropriately.
5.4. Employees
5.4.1. Responsible for complying with the policies determined by the Board of Directors, working in compliance with internal and external legislation, and reporting any behavior, attitude, transaction, action, decision, activity or practice that is contrary to the Policy via the Ethics Line.
5.4.2. Company employees are obliged to act in accordance with the principles set forth in the policy and cannot be forced to act contrary to the Policy under any circumstances. Employees are obliged to report all behaviors and practices that are contrary to this policy to their managers and/or the Ethics Board via the Ethics Line.
5.4.3. Managers are responsible for the correct implementation of the principles in the policy by the employees, subcontractors and employees and business partners for whom they are responsible.
Ethics Line:
E-mail: etik@hes.com.tr
Address: Erciyes Mahallesi, Hes Caddesi No:22 38210 Hacılar/KAYSERİ
ARTICLE 6. ENFORCEMENT
6.1. This Policy has been put into effect by the decision of the Board of Directors. This Policy will remain valid and in force until a new announcement is made.
REVIEW
7.1. This Policy is reviewed regularly once a year by the Ethics Committee based on controls related to process or technical infrastructure changes. This reviewed and updated policy is approved by the Board of Directors.
RELATED POLICIES AND PROCEDURES
Donation and Aid Policy
Ethics Rules Policy
Sustainability Policy