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Ethical Rules Policy

PURPOSE
1.1. The Ethical Rules Policy covers all businesses and activities of Hes Kablo A.Ş. and has been prepared for the purpose of outlining the ethical rules and principles that all employees, business partners and suppliers are expected to comply with and guiding them in implementing the governance structure in this regard.
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: Ethical Rules Policy
Employee: Refers to company managers and employees.
SCOPE AND RESPONSIBILITIES
3.1. This policy;
a) The General Manager of the Company,
b) Company Employees,
c) Companies and employees from which goods and services are purchased,
d) Other persons and organizations acting on behalf of the Company, including consultants, lawyers, advisors and external auditors, and customers with whom it has commercial relations (“Business Partners”)
covers.
PRINCIPLES AND BASIS

4.1. Legal Responsibilities
4.1.1. In order to carry out its activities in a sustainable manner and to protect the environment, the Company designs its investments and power plants in accordance with the relevant legislation and regulations, and goes beyond legal requirements wherever possible. While carrying out all its activities domestically and internationally, it acts within the framework of laws and international legal rules, works in cooperation with all public institutions and organizations, and accordingly presents all kinds of information, documents, papers and notifications requested from it in a timely and understandable manner.
4.1.2. It is sensitive about complying with the rules and requirements of all legislation related to the Company's activities, especially financial legislation and environmental legislation, and expects the same from third parties and institutions it cooperates with. It is always honest in its work and communication with public officials and does not try to influence their decisions with gifts, aid, bribes or other unethical offers.
 

 
4.2. Responsibilities to Customers
4.2.1. The company's primary goal in all areas where it operates and conducts business is to meet customer expectations at the highest level. From this point of view, it constantly works to develop new products that will increase the quality of life of its customers by predicting their needs in the most accurate way and encourage responsible consumption. It constantly renews and improves itself by taking into account customer satisfaction and all kinds of feedback from customers. It works with a customer-oriented working approach that responds to all needs, demands and expectations of customers in the shortest time possible and focuses on resolving any problems that may arise in the shortest time possible.
4.2.2. The Company guarantees the confidentiality of all its customers' personal data and undertakes not to share this data with third parties without the consent of its customers, except for legal obligations or court orders. The collection, use, processing and storage of its customers' personal data are carried out in a way that guarantees privacy rights and complies with relevant legal regulations.
4.2.3. One of the basic principles of the company is to provide its services on time and under the promised conditions. It addresses both its internal and final customers with respect and courtesy, and exhibits a transparent and honest approach. It takes care to ensure that commercial agreements with its customers are arranged in a way that will not cause any misunderstanding, and acts with the principle of transparency in pre-agreement processes.
 

 
4.3. Responsibilities Towards Employees
4.3.1. The basic building blocks of the company are its employees. Therefore, it values ​​its employees as its most important resource and acts with an understanding that will ensure that they work in good conditions, in harmony, satisfied with their jobs and embracing the job.
4.3.2. The company evaluates candidates according to objective criteria during the recruitment process. It makes its selections based on the requirements of the position, talent and ability, and offers equal opportunities to all candidates. It ensures that no employee is discriminated against due to personal characteristics such as language, religion, ethnicity and gender in all processes from the recruitment phase to career and wage practices, and does not allow the opposite situation.
4.3.3. Takes all necessary measures to create a safe working environment in its businesses and areas of activity. Complies with the requirements of the relevant legislation and takes all necessary measures in addition to the legislation. Organizes mandatory and voluntary trainings for its employees on occupational health and safety issues and ensures continuous access to training materials.
4.3.4. Ensures that its employees fully and completely use their rights arising from laws and contracts. Respects freedom of representation and collective bargaining rights.
4.3.5. Supports the personal and professional development of its employees and provides the training they need. Values ​​its employees as individuals, keeps their personal information confidential and uses this information only within the framework required by law.

4.4. Responsibilities Towards Competitors
4.4.1. The Company believes in the necessity of a free market in business life and acts to protect the competitive structure in all its activities such as price determination, purchase-sale conditions, discounts and customer selection. It competes in accordance with the law within the framework of ethical rules and avoids unfair competition. It does not try to learn confidential information about its competitors, does not trust information received by it outside of legal means and does not use such information. It does not make any statements or actions that degrade or damage the reputation of its competitors. It respects their copyrights. It expects its competitors to act in the same way.
4.4.2. In all kinds of marketing activities such as products, services and promotions, especially in terms of advertising ethics; it acts honestly and realistically, in accordance with legal regulations and general morality, and avoids any action that would harm the reputation of the HES Kablo name; and avoids including any expressions or phrases that disparage its competitors or their products in its announcements, advertisements and advertisements.

4.5. Responsibilities to the Society and Humanity in Which They Live
4.5.1. The Company aims to create sustainable value for its stakeholders within the scope of its Sustainability Strategy and acts to contribute to the goals of the Sustainable Development Goals. It contributes to the society it is in with its activities and sustainable development strategy. It works by respecting human rights and the values ​​of different societies, and takes care not to contradict the generally accepted lifestyle, worldview and traditions of the society in its activities both in Turkey and in other countries.
4.5.2. It works to increase the education, culture, economy and social well-being of the communities in which it does business, avoids any illegal employment of child labor, abuse, bad language and treatment towards workers, involuntary employment and any similar attitudes and behaviors that are against human rights, expects all suppliers and business partners to act in accordance with these issues, and terminates commercial relations with individuals and institutions that it learns do not display the necessary sensitivity in this regard.
4.5.3. It does not include elements that are contrary to the fundamental values ​​of society, such as sexual abuse and violence, in its advertisements and avoids any symbol, expression or insinuation that may lead society to develop negative habits. It does not advertise any political view, religion, language or ethnic group that degrades it.

4.6. Responsibilities Towards the Environment
4.6.1. The Company conducts its activities with the principles of respect and protection of the environment, ensures 100% compliance with relevant environmental legislation and standards, and works to minimize its environmental impact in line with its sustainability strategy.
4.6.2. The Company is aware that fulfilling its responsibilities towards the environment also means fulfilling its responsibilities towards its employees, society and humanity, and acts with environmental awareness during all its services and activities, and operates its facilities at standards that will not cause environmental pollution.
4.6.3. Develops and implements ways and methods to minimize the long-term negative environmental impacts of its activities within the scope of its sustainable growth strategy. Keeps natural resource consumption at a minimum level during all manufacturing processes, including construction infrastructure, heating, cooling, electricity and water installations of all its businesses. Invests in energy efficiency to reduce its carbon footprint.
 

4.7. Information Security and Social Media
4.7.1. The Company undertakes to comply with all legal regulations, legislation and standards specified in ISO 27001 regarding information security and personal data. It is defined as all data, text, images, sounds and similar content in physical or digital media produced, used, transmitted, archived or legally transferred to the company during business processes. Company strategic information, organizational information, commercial, technical, financial data, customer dealer information, policies, procedures, regulations, product, service information, employee personal information and all other information, including but not limited to these, are evaluated within this scope.
4.7.2. Any information related to work within the company and not open to the public is classified as confidential information and is not shared with third parties outside the company, except for the requirements of the current task. While transparency is the main principle within the company, care is taken to share information to the extent required by the current task.
4.7.3. All information developed by company employees, acquired by the company or revealed within the scope of business requirements belongs to the company and is considered a trade secret. All kinds of data that are not shared with the public, such as the company's products and services, financial information, technical information, business development information, information about customers and suppliers, information about employees, etc., in written and printed form, in electronic media or in computer programs, belong to the institution and are considered confidential information.
4.7.4. All employees are responsible for the healthy operation of information security systems established to protect confidential information within the company within the scope of their individual duties. Company employees take the necessary care to ensure that any information and/or document they use and access while performing their duties is not lost and, in addition, that the accuracy or integrity of the information and/or document in question is not compromised.
4.7.5. Company employees are aware that all information (financial information, customer information, personnel information, etc.) and/or documents they access due to their duties are confidential and do not share them with third parties (persons other than HES Kablo). They act in accordance with personnel loyalty principles, confidentiality principles, and non-competition principles.
4.7.6. Social media is widely used in the Company as a requirement of business life and to encourage communication opportunities. Social media or internet services are primarily open to business use and to a limited extent to personal use. Employees are aware that all information accessed and sent electronically is monitored and controlled by the Company. Employees are responsible for protecting passwords used for internet access and e-mail services.
4.7.7. In addition to the general principles stated above regarding information security and the use of social media tools, some examples can be stated as follows.
4.7.7.1. Employees regarding information security,

  •  They must attach importance to the confidentiality of confidential and/or trade secret information and adhere to the principles of loyalty and confidentiality.

  •  They report information security breaches, security gaps and any suspicious situation to the relevant units and individuals within the organization.

  •  They protect the confidential and private information of employees, customers, suppliers, business partners and other people and organizations they work with and do not use this information for purposes other than business.

  • They do not share the information learned and documents possessed for the purpose of work with unauthorized persons or authorities within or outside the Company, and they do not use them for personal purposes in any way.

  • They do not use the information and documents they have after leaving the company against the company or in favor of competitors.

 

  • They attach importance to the protection of intellectual property such as patents, trade secrets, copyrights, names and brands, etc.

 

  • They do not forget that it is forbidden to leak any confidential information and/or documents within the scope of “Insider Trading” and to make a profit through the stock market or any other means.

 

  • When some information needs to be shared with third parties due to business requirements, they inform the information security/relevant unit and obtain approval from the senior manager to ensure that this information is shared in a way that will not harm the company (confidentiality agreement, etc.).

 

  • They do not forget that the e-mail account provided by the company is allocated for company business and can be monitored.

 

  • They do not use the technological communication tools provided to employees for the purpose of exchanging information within the business relationship for their individual purposes.

 

  • They avoid any behavior that would threaten the physical/environmental security of PC, Laptop, Server and similar information processing and production devices.

 

  • They ensure that the sharing of information and documents requested by Regulatory Bodies and Independent Auditors is done accurately, understandably and on time, in accordance with company practices.

 

  • They contact the information security unit in case of unauthorized/inadvertent access, exposure or sharing of confidential information for any reason.

 

  • Individual visitors come at a reasonable frequency and in these mandatory cases, meetings are held in the canteen, cafeteria or meeting room after the approval of the unit managers.

  • They do not take out any electronic and/or written documents (CDs, portable memory, etc.) containing information and data for purposes other than business outside the company. (If necessary, the manager's approval is obtained.)

  • They know that the authorization for software installation in the entire system is given by the Information Technologies Department, and they do not install or use programs that will allow files such as music, pictures, movies, etc. to be shared or downloaded on the internet.

  • They do not send electronic mails called “chain letters”.

  • Necessary care and attention must be shown in the use, sharing, storage, and preservation of the accuracy and integrity of all kinds of information and documents. The published “Information Security Policy” document must be followed, and since the issues to be followed are explained in detail in this document, the relevant document must be obtained and read.


4.8. Relations with Suppliers and Customers
4.8.1. Company employees do not gain personal benefit from commercial transactions with suppliers and customers, do not use corporate information and positions for their own interests, do not enter into commercial competition with the company, and do not have close relationships with individuals or organizations that would benefit from the information they have due to their job. In this sense, employees do not become owners or profit partners of a supplier or any competitor with whom the company has a direct business relationship.
4.8.2. In business relations with organizations in which employees' relatives are owners or profit partners, it is expected that business conditions parallel to similar suppliers/customers are provided, that these conditions are provided are demonstrated through periodic internal audit reports, and that the business relationship in question is completely outside the employee's individual field of duty. However, even if all these conditions are met, the General Manager of the relevant company is required to express his/her clear consent.
4.8.3. Employees must not have any financial interest relationship such as borrowing, lending, guaranteeing or similar with suppliers/customers and competitors, and their social relations with suppliers/customers must not be of an intensity that will damage professional business relationships and their personal transactions with suppliers must not be of a nature that could provide advantages beyond ordinary commercial terms.
4.8.4. In principle, the Company does not accept gifts from business partners. However, gifts to be received from business partners (or given to business partners) may be accepted if they comply with commercial practices and the Donation and Aid Policy, remain within the framework of good faith, and do not affect the objectivity of decisions. Any hesitations that may arise in this regard can be resolved by taking into account the limits and rules determined in the Donation and Aid Policy.
4.8.5. The Company works to raise awareness among its suppliers on environmental, social and broader sustainability issues. When selecting suppliers to work with, it observes minimum environmental and social criteria and does not work with suppliers that are found not to meet certain human rights criteria.
4.8.6. In addition to the general principles stated above for relations with suppliers and customers, some special situations can be stated as follows.

  • Employees cannot use their duties and authorities in the institution for personal or private gain for the benefit of themselves, their families or third parties.

  •  Employees working in the purchasing functions of the company do not establish individual commercial relationships with suppliers they are in contact with due to business relationships.

  •  If an employee who leaves the workplace becomes a potential supplier - except for special permissions received from senior management - no commercial relationship can be established between him/her and the institution for two years. If the person leaves the job by becoming a partner of a supplier with whom he/she had a previous business relationship, the existing commercial contracts are re-evaluated and action is taken in line with the opinion of the Ethics Board.

  •  Employees do not request the employment of their relatives or acquaintances from any supplier company with whom they have a business relationship due to their duties in the company.

  •  Employees may participate in activities organized by customers or institutions of which they are customers, provided that they remain within acceptable limits (with the knowledge of the company's senior management).

  •  During meetings where work-related issues are discussed and reviewed, customers or suppliers may be allowed to pay for meals or other expenses appropriate to the requirements of the job.

 

 4.9. Use of Institutional Resources
4.9.1. The movable and immovable properties of the company, all kinds of material benefits obtained through company opportunities, human and information resources constitute the resources of the institution. The interests of the institution are taken into consideration in the use of resources on behalf of the company. The company provides its employees with all necessary and appropriate resources to fulfill their professional responsibilities.
4.9.2. Company employees agree to use the resources provided to them to fulfill their professional responsibilities responsibly and only for the organization. In particular, the employment of human resources in line with the interests of the organization is essential, and it would be a violation of this principle for managers to assign employees for their personal business.
4.9.3. Employees are expected to use all vehicles, fixed assets, goods and facilities allocated for work purposes without causing any damage, within the framework of their obligations of due care and only for the institution. For example,

  •  Long-term personal conversations made on a designated phone,

  •  Excessive and unnecessary expenses incurred during business travel,

  •  Allocation of company personnel's working hours to the manager's personal affairs,

  •  Use of company vehicles for the benefit of third parties who cannot be directly associated with the institution,

  •  Any behavior that prevents the use of common areas or damages fixed assets,

  •  can be evaluated within this scope.

 

4.10. Responsibilities of Managers
4.10.1. All professionals working in managerial roles within the company must have all the skills, experience, qualifications, education and expertise required to perform their duties and responsibilities. In addition, all managers must act transparently, responsibly, efficiently and honestly, and perform their work with the principle of excellence in line with the interests of the institution. All managers in the company are obliged to continuously improve all of the aforementioned characteristics and capabilities.
4.10.2. Managers at all levels in the company adopt the Code of Ethics and become pioneers and role models for its adoption among unit employees. In this context, managers,

  •  They encourage their subordinates to share, ask questions and share their opinions on the Code of Ethics.

  •  They take seriously every issue they are consulted on regarding ethics and, if necessary, forward it to the Ethics Board as soon as possible.

  •  They create business processes in a way that minimizes risks in ethical areas by taking into account all ethical procedures during the execution of the work under their responsibility.

  •  They know the instructions and regulations published within the institution and follow all kinds of changes, and inform their subordinates as necessary.

  •  They immediately inform the upper management on issues that legally concern the institution and do not resort to individual solutions.

  •  They are willing to take initiative regarding their duties and do not consciously avoid using their authority and responsibilities.

4.10.3. All managers working within the Company operate in compliance with legal regulations, legislation and Company policies and procedures. In this context;

  •  Environmental Policy and behaviors towards environmental protection,

  •  Diversity and inclusiveness in all decisions, combating discrimination, and in this context Human Rights Policy,

  •  Behaviors regarding occupational health and safety, taking necessary precautions to prevent occupational accidents and diseases,

  •  Human Resources Policy and related procedures and requirements in the recruitment, evaluation and training processes of all employees,

they adopt, implement and pioneer in creating awareness about it.

4.11 General Responsibilities of Employees
4.11.1. Every individual within the company is a value and it is respectful for them to take part in business life with their own unique lifestyle and worldview. Within the scope of the Code of Ethics, the ethical principles that the Company expects and requires all employees to comply with are specified in terms of main subjects. In this section, the attitudes and behaviors that each HES Kablo employee should display in business life and especially in the office environment are outlined below.
4.11.2. Employees,

  •  Do not physically, psychologically or socially harass or disturb their coworkers, and do not exhibit violent attitudes and behaviors.

  •  Do not use drugs and/or stimulants and/or alcohol in the offices, and never come to the workplace in this manner.

  •  They only get into debt with legally authorized institutions and organizations, and do not enter into debt and surety relationships with each other that would damage the corporate image.

  •  They do not commit theft, abuse of trust, forgery, fraud, slander, bribery, embezzlement (disgraceful crimes) inside and outside the company, and fulfill their duties and responsibilities towards the state as individuals who respect the law and laws of society.

  •  When their business relationship with the company ends, they deliver the information and documents within the scope of their duties to their institutions completely.

  •  They work with the best intentions and effort to fulfill the duties and responsibilities specified in their job descriptions with minimum errors.

  •  They know and follow the working hours determined and announced for them, they give excuses when they do not come to work or arrive late, they do not change their working hours without the knowledge of the manager or the Human Resources Department.

  •  They participate in the trainings planned for them and all meetings organized.

  •  If they have information about any violations of practices within the company, they report this to their superiors and/or the relevant unit.

  •  Full-time, contracted and part-time employees do not work for a similar line of work for a competing company, including paid/unpaid leave periods. Since working for a side job outside a competing company, or in positions that require payment such as consultancy, is not appropriate due to wages and working conditions, the employee personally informs his/her superior and consents to the evaluations to be made in terms of competition, loyalty and performance due to his/her work.

  •  They know that false, misleading and exaggerated information in communication will prevent the transmission of the correct message, and therefore they take care to establish healthy communication.


 
4.12. Evaluation of Incompatibilities
4.12.1. The Company expects employees to take into consideration the Company's values ​​and determine their behaviors on the axis of these values ​​when they are in a dilemma about how to behave in order to comply with high standards.
4.12.2. As can be seen from the examples below, unethical situations and behaviors can occur in many different dimensions.

  •  Managers giving unethical instructions and directions to their subordinates,

  •  Employees behaving in a manner contrary to ethical rules and corporate values,

  •  Employees seeing their colleagues behaving in a manner contrary to ethical rules or corporate values,

  •  Owners, managers or personnel of these companies making unethical offers or demands to their employees in ongoing relationships with business partners (customers, suppliers, etc.).

  •  Employees making unethical offers or demands to their business partners (customers, suppliers, etc.).

4.12.3. If employees are aware of or suspect a situation regarding a violation of ethical rules or corporate values, they must share this information with their senior managers and, if necessary, with the members of the Ethics Committee within the framework of the following criteria. If the employee detects behaviors that he/she may consider unethical or that potentially do not comply with the Company's principles and professional business ethics, he/she must ask the following questions and act according to the answers he/she receives:
4.12. 4. Is the behavior contrary to the Company's principles and business ethics?

  •  Does the behavior violate professional standards and the rules set forth in the Code of Ethics?

  •  Does the behavior conflict with the interests of the organization?

  •  Could the behavior have negative consequences for the company if it were to be heard by the public, customers, and other stakeholders?

  •  Is the behavior clearly against the law and corporate regulations?

  •  If a third party outside the company objectively evaluated the situation witnessed, would they perceive it as unethical?

4.12.5. The employee must analyze the situation and if he answers “yes” to one or more of the above questions, he must report this situation to the relevant authorities.
DUTIES AND RESPONSIBILITIES
5.1. HES Cable Ethics Board consists of the General Manager, Business Managers, Sustainability Manager and HR Specialist and after the approval of the General Manager, it starts its activities by being announced to all employees by the Human Resources unit. Duties and Responsibilities of the Ethics Board:

  •  To investigate complaints and reports of violations of the Code of Ethics within the company,

  •  To decide or have the violations of the Code of Ethics investigated resolved,

  •  To provide opinions and suggestions regarding the implementation of the Code of Ethics,

  •  To respond to applications made for consultation within the scope of the HES Kablo Code of Ethics,

  •  To ensure that the Code of Ethics is in compliance with legal regulations,

  •  To inform employees about the Code of Ethics, to be in constant communication with employees in order to ensure the comprehensibility of the policies and rules,

  •  To ensure that new employees and all employees in the company read the Code of Ethics and are informed about this issue.

5.2. All employees may verbally report their questions about the Code of Conduct and any suspected violations, or they may use the Ethics Committee's communication channels listed below.
E-mail: etik@hes.com.tr
Address: Erciyes District, Hes Street No:22 38210 Hacılar/KAYSERİ
5.3. This board is a body where all employees can consult about situations they find suspicious and dilemmas they experience regarding ethical issues, with the function of evaluating violation notifications. It is also open to all kinds of suggestions from employees in order to develop ethical awareness in the company and to take protective/preventive measures to prevent ethical violations.
5.4. In notifications made to the Ethics Committee, the Company Ethics Committee guarantees that the notification will not have any negative impact on the employee, provided that the notification is not made in good faith, and that all notifications will be kept absolutely confidential.
5.5. Complaints and notifications received by the Ethics Committee are investigated within the framework of confidentiality principles and every stage of the investigation is recorded. The Ethics Committee has the authority to obtain relevant information, documents and papers from any unit it deems necessary regarding the subject it investigates. The Committee takes the necessary measures to conclude investigations regarding violations quickly and may obtain support from experts and specialists, if deemed necessary, taking into account the principles of confidentiality, in order for the investigation to be conducted fairly. Violations of rules reported or detected may be resolved by the company ethics committee, considering their nature and effects, by the Ethics Committee Chair, or they may be referred to the company disciplinary committee and resolved without the participation of the Ethics Committee.
5.6. The Ethics Committee assumes that each employee acts in accordance with ethical rules unless otherwise clearly stated. An employee who is complained about or reported for unethical behavior is given the opportunity to express himself/herself within the scope of the complaint/report. In addition, during the investigation process, the employee is deemed not to have committed any violations until the allegations against him/her are concretely confirmed.
5.7. When a report is received or an opinion is requested, the Ethics Committee meets upon the invitation of any of the Board Members. The Committee may invite persons it deems appropriate to the meetings in order to obtain information on matters deemed necessary. The Ethics Committee Chair is responsible for the implementation of the Ethics Committee's working principles.
ENFORCEMENT
6.1. This Policy has been put into effect by the Decision of the General Manager. 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 regarding process or technical infrastructure changes. This reviewed and updated policy is approved by the General Manager.
RELATED POLICIES AND PROCEDURES
Donation and Aid Policy
Environmental Policy
Human Rights Policy
Human Resources Policy
Anti-Bribery and Corruption Policy
Sustainability Policy