WE CARE ABOUT PRIVACY

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Communication Policy

PURPOSE
1.1. The purpose of the Communication Policy (hereinafter referred to as the "Policy") is to determine the necessary standards and expectations in order to create a strong communication structure based on the principles of honesty, transparency and professionalism in all internal and external communication processes of HES Kablo A.Ş. (hereinafter referred to as the "Company").
DEFINITIONS
2.1. In this section, specific terms and concepts used in the policy are briefly explained as follows.
 
Company: HES Kablo A.Ş.
Policy: Communication Policy
Employee: Refers to company managers and employees.
Internal Stakeholders: Refers to company senior management and employees.
External Stakeholders: Individuals, groups or institutions/organizations outside the company that are affected by or affect the company. These include the company's customers, the public, suppliers, business partners, investors, local communities, public institutions and regulatory bodies, academic institutions, financial institutions, non-governmental organizations, sector organizations and professional organizations, and media organizations.
SCOPE
3.1. Policy,

  • All employees of the company,

  • Companies from which goods and services are purchased, all business partners and employees,

  • It covers the entire value chain, including external service providers, consultants, lawyers, advisors and external auditors, as well as individuals and organizations acting on behalf of the Company, and the customers with whom the Company has commercial relations

cover.
PRINCIPLES AND BASIS
4.1. Communication Rules
4.1.1. Transparency
4.1.1.1. The Company adopts the principle of transparency and accuracy in communication. It encourages the sharing of real, accurate and up-to-date information in internal and external company communications. It is absolutely unacceptable to communicate misleading or manipulative information.
4.1.2. Honesty and Ethical Principles
4.1.2.1. The Company strictly complies with universally accepted ethical principles and the Ethics Rules Booklet in all communication processes.
4.1.3. Confidentiality and Data Security
4.1.3.1. The Company is obliged to protect the confidentiality of customer information, trade secrets, employee data and other sensitive information. In communication processes, confidential information is shared only between authorized persons and full compliance with relevant laws is ensured.
4.1.4. Communication and Feedback
4.1.4.1. Communication should be mutual and interactive, not one-way. The company creates an open communication channel with employees, customers and other stakeholders and encourages the process of receiving and giving feedback. It makes continuous improvements by taking this feedback into account.
4.1.5 Cultural Sensitivity and Diversity
4.1.5.1. The company encourages effective communication between different cultures and language groups. It respects cultural diversity and creates an environment where everyone can express themselves in communication processes. It does not discriminate based on race, gender, religion or other personal characteristics. 4.2. Communication Methods
4.2.1. The methods to be used when communicating with stakeholders are included in the Stakeholder Engagement Policy.
4.2.1.1. The preferred channels for internal communication are e-mail, instant messaging, meetings, etc. internal communication platforms.
4.2.1.2. In external communication, communication with customers is usually carried out via e-mail, telephone, or face-to-face meetings. Social media platforms are also used carefully by those representing the Company.
4.2.2. Any suspicious or non-compliant situations with the Code of Ethics Booklet, Anti-Bribery and Anti-Corruption Policy, Donation and Aid Policy, Human Rights Policy and Competition Policy can be communicated via the Ethics Line.
E-mail: etik@hes.com.tr
Address: Erciyes District, Hes Street No:22 38210 Hacılar/KAYSERİ
4.3. Communication in Emergencies
4.3.1. Communication methods used in emergencies are included in the SG-ADP-01- EMERGENCY Plan.
4.4. Record Keeping
4.4.1. All communications are recorded in writing whenever possible. These records should include the following information.
• Meeting minutes,
• Original copies of communications in all formats such as correspondence, notes, emails, posters, etc.
4.4.2. Records of communications made regarding the Management Systems should be organized and stored in a way that they can be easily accessed and reviewed. For this purpose, folders created specifically for all departments on the common network, the easy platform and the HES Portal platform are used.
SCOPE AND RESPONSIBILITIES
5.1. Board of Directors
5.1.1. The Board of Directors is responsible for the oversight of the creation, implementation and updating of the Policy.
5.2. Sustainability Committee
5.2.1. Responsible for managing processes related to Stakeholder Engagement together with the Corporate Communications Department.
5.3. Corporate Communications Department
5.3.1. The Corporate Communications Department is responsible on behalf of the Board of Directors for the creation, implementation and updating of the Policy.
5.3.2. The Corporate Communications Department is responsible for establishing accurate and effective communication with internal and external stakeholders and establishing the necessary communication mechanisms. 5.3.3. It is responsible for managing the processes related to Stakeholder Participation together with the Sustainability Committee.
5.3.3. Responsible for managing the processes related to Stakeholder Engagement together with the Sustainability Committee.
5.4. Department Managers
5.4.1. Department Managers are responsible for implementing this procedure in their own field activities and ensuring that the subcontractors they work with comply with this procedure.
5.4.2. Department Managers are responsible for the effective and timely provision of the necessary organizational and technical resources for communication.
5.4.3 Department Managers are responsible for ensuring that employees and subcontractors under their responsibility receive training on the scope of this procedure.
5.4.4 Department Managers are responsible for ensuring that action plans determined for communication are implemented and followed up.
5.4.5. Department Managers are responsible for ensuring that communication-related needs identified from risk assessments are met.
5.4.6. Department Managers are responsible for monitoring and developing the system for continuous improvement.
5.5. Employees
5.5.1. Responsible for attending meetings that are relevant and requested to attend.
5.5.2. Using relevant communication methods in the process of performing their duties,
5.5.3. Responsible for providing feedback/sharing their views to their supervisors or managers and the Corporate Communications Department regarding the effectiveness of communication and potential risks they see.
ENFORCEMENT
6.1. This procedure has been put into effect by the decision of the Board of Directors. This procedure will remain valid and in force until a new announcement is made.
 
REVIEW
7.1. This procedure is reviewed regularly once a year by the Corporate Communications Department based on controls regarding process or technical infrastructure changes. This revised and updated procedure is approved by the Board of Directors.
RELATED POLICIES AND PROCEDURES
Human Resources Policy
Stakeholder Engagement Policy
Ethics Rules Booklet
Anti-Bribery and Anti-Corruption Policy
Donation and Aid Policy
Human Rights Policy
Competition Policy
SG-ADP-01-EMERGENCY PLAN