Sustainability

1. Efesanport Ethical Working Principles and Rules

Efesanport Efesan Demir San. ve Dış Tic. A.Ş., aims to provide products and services of universal quality and standards by using scarce natural resources effectively, and to contribute to economic and social development.

In this way, it aims to be a symbol of reliability, continuity and prestige for its customers, shareholders, employees, suppliers, dealers and authorized services, in short, for all its stakeholders on a national and global scale.

-Our customers are our benefactors,

-Always being the best is our indispensable goal,

-Our most important capital is our human resources,

-Our aim is to create resources for continuous development,

-We aim to add strength to the economy of the country from which we derive our strength,

-It is our motto to comply with superior business ethics and honest working principles,

Based on its principles, Efesanport Efesan Demir San. ve Dış Tic. A.Ş. with its Code of Ethical Conduct, aims to guide its employees and those acting on behalf of Efesanport in their decisions and behaviors while performing their duties.

Efesanport Efesan Demir San. ve Dış Tic. A.Ş. It covers all Efesanport employees, including its management.

All Efesanport employees are expected to exhibit attitudes and behaviors that will ensure the cultural integrity of the group.

In addition, all employees are expected to maintain and improve their reputation and the credibility of the Group's corporate structure. All employees employed within the Group, including temporary staff, are obliged to comply with the Group Code of Ethical Conduct or the Company's Code of Ethical Conduct established in accordance with it.

All stakeholders are expected to comply with the code of business ethics and all the implementation principles that support these rules. Informing all employees of the Code of Ethical Conduct, ensuring that employees give the necessary importance to these rules, and showing the necessary effort and leadership in complying with the Code of Ethical Conduct are among the primary duties and responsibilities of middle and senior managers working in the Group. The responsibility of documenting that the latest version of the Code of Ethical Conduct and Implementation Principles document has been read, understood and committed to implementation  by the employee belongs to the employee's superior.

1. 1.Purpose and Scope

This Code of Ethics Procedure aims to encourage the ethical behavior of our company's employees and managers, to comply with our ethical rules and values, and to report ethical violations. The procedure applies to all employees and managers.

1.2. Ethical Values and Principles

Our company adheres to the following basic ethical values and principles:

Honesty and Business Ethics: Every employee should be honest, fair and law-abiding.

Confidentiality: The confidentiality of internal information and customer data and employee information must be protected.

Conflict of Interest: Employees should avoid conflicts between their personal interests and the interests of the company.

Environmental and Social Responsibility: Our company attaches importance to fulfilling its environmental and social responsibility.

1.3. Notification and Resolution of Non-Compliance with the Code of Ethics

If employees learn that the Company's Code of Business Ethics or the legal regulations to which the Company is subject have been violated, they are obliged to report this to their direct managers, to the Company Ethics Reporting line if the situation is directly related to the manager to whom they are reported, and/or to the Company Ethics Committee if no steps are taken regarding the incident and no results are obtained. If the violation is related to the Company's senior management, the matter should be reported directly to the Company's Ethics Committee.

Notifications made to the company are finalized and resolved in line with the internal functioning and procedures of the company. The Company informs the Company Ethics Committee on important issues and other situations it deems necessary and seeks its opinion. If the Company Ethics Committee deems it necessary, it can directly carry out the review process itself. Those who violate the Code of Business Ethics or the Company's policies and procedures will be subject to various disciplinary sanctions, which may go as far as being asked to leave the job if necessary.

Disciplinary sanctions will also be applied to those who approve, direct or have knowledge of inappropriate behavior and acts that cause breaking the rules but do not make the necessary notification appropriately. In addition, those who behave negatively towards those who make any complaints and notifications or assist during the investigation are also not tolerated.

Intentional reports of falsehood and/or slander are interpreted as a violation of ethical rules. The Company or employee who has been lied or slandered will be able to take separate legal action against those who made the notification in question, within the scope of the Turkish Penal Code, Labor Code, Code of Obligations and other relevant legislation.

1.3.1. Notification of Ethical Violation

Employees can report suspected ethical violations through the company's Ethics Violation Reporting Channels listed below. Papers will be kept confidential.

Infringement notifications can be made in writing or verbally, and there is no need to provide an identity disclosure.

Ethics Hotline notification channels have been put into use in order to ensure that our employees, customers and suppliers report unethical behaviors, abuses and all kinds of non-conformities related to the company to an independent organization without worry, and ultimately to ensure that our group companies are protected from all kinds of losses, including reputational risks.

The ethics hotline is an independent system through which they report unethical behavior, misconduct, and any form of non-compliance.

• By calling the phone number 444 (3845)
• efesan@etikhat.com.tr by sending an e-mail
• etikhat.com.tr web address from User Login

(User Name: Raporhat Password: 2021)

• By sending a message to the WhatsApp line 0552 (3845) 000
• By sending an SMS to 0552 (3845) 000

Operators who are experts of the independent call center company assist in the notifications and the name, contact details and all other information about the notifier (if requested) are kept confidential at every stage.

You can send all your questions to independent expert operators who will help you with peace of mind.

All kinds of information and documents reported in the Ethics Hotline can be accessed by authorized experts who enter the work area with the biometric system (fingerprint).

The person making the notification is not obliged to state his/her identity, but even if he/she discloses his/her identity information and does not want it to be shared with the company, he/she is assured that no harm will come to him/her, that the matter will remain anonymous, and that it will not be disclosed in the end.

• Ethics Committee

Efesanport San. ve Dış Tic. A.Ş., the Ethics Committee, which works under the Chairman of the Board of Directors, Efesanport San. ve Dış Tic. A.Ş. was established to resolve conflicts of interest within the scope of the Code of Business Ethics (EFESANPORT-ETİK), to evaluate the notifications sent to it regarding the violation of the ethical rules, and to advise the managements of the Group Companies on the ways, methods and practices to be followed in case of violations of the code of ethics. The Ethics Committee consists of the following people:

• President: Efesanport Operations Manager
• Member: Group Human Resources Manager
• Member: Lawyer

A representative from the Sustainability Department takes part in the Board as an observer without the right to vote.

1.4.1. Working Principles of the Ethics Committee

The Ethics Committee carries out its activities within the framework of the following principles:

• It keeps the notifications and complaints and the identity of those who make the notification or complaint confidential.
• Anyone who makes a report to the Ethics Committee or the Ethics Hotline with their clear identities is under the protection of the Ethics Committee due to these reports and cannot be subjected to behaviors such as pressure, discrimination or mobbing.
• The Ethics Committee conducts the investigation within the rules of confidentiality as much as possible.
• It has the authority to request information, documents and evidence related to the investigation directly from the existing unit. It can examine all kinds of information and documents it obtains only limited to the subject of the investigation.
• The investigation process is recorded in a written report from the beginning. Information, evidence and documents are added to the report.
• The minutes are signed by the chairman and members.
• The investigation is handled urgently and the result is reached as quickly as possible.
• The decisions taken by the Board are immediately put into practice.
• The relevant departments and authorities are informed about the result.
• The chairman and members of the Board act independently and unaffected by the department managers they are affiliated with and the hierarchy within the organization while performing their duties in this regard. They cannot be pressured or indoctrinated on the subject. They are completely independent.
• If the Board deems it necessary, it may seek expert opinion and benefit from experts by taking measures that will not violate the principles of confidentiality during the investigation.

1.5. Education and Awareness

All employees receive regular training to understand the code of ethics procedure and the ethical values of the company.

Awareness is created to constantly draw attention to ethical values and procedures.

The Code of Ethics is reviewed every year, updated if necessary and communicated to the employees. These ethics documents are also kept in the employee personal file.

1.6. Monitoring and Reporting

The ethics committee and managers regularly monitor the effectiveness of the code of ethics procedure and the level of compliance with ethical values.

Regular reports are prepared on ethical violations, reports and decisions of the board.

All notifications received through the ethics hotline are classified in a certain format and periodically submitted to the authorities determined in our company in the form of a report.

2. Ethical Working Principles and Rules

Efesanport San. ve Dış Tic. A.Ş. and its employees act with integrity and honesty in all their work and stay away from situations that may create a conflict of interest.

It is one of the most important responsibilities of all employees not to use the company's resources, name, identity and power for personal benefit and to avoid situations that will negatively affect the name and image of the institution.

The following application principles determine the conflict of interest situations that Company employees may encounter while performing their duties or in their private lives due to their business relations and the principles to be applied in these cases.

2.1. Activities That May Create a Conflict of Interest

Efesanport makes maximum efforts to encourage its employees to comply with these principles. All Company employees are also required to fully comply with the specified principles and the situations specified below as activities that may create a conflict of interest.

Employees; does not enter into a business relationship with family members, friends or other third parties with whom one has a relationship, providing mutual or gratuitous benefits in any way.

Exceptional cases are subject to the knowledge and approval of the Chairman of the Board of Directors of the Company. In the same direction, Company employees should be careful about conflicts of interest that may arise due to their close family members working for the Company's competitors.

Employees cannot obtain any commercial benefit by leaking any information belonging to the Companies from the inside, and cannot be instrumental in obtaining benefits from others.

Bribery, receiving, giving or offering commissions is unacceptable under any circumstances.

Efesanport San. ve Dış Tic. A.Ş. employees do not work for another person and/or institution for a wage or similar benefit during or outside working hours, under any name, and do not engage in work that requires them to be considered as "merchant" or "tradesman" directly or indirectly.

However, if employees work for another person (family member, friend, other third party) and/or institution outside of working hours for a wage or similar benefit;

• Not to create a conflict of interest with the duties they carry out in the company and the practices of other group companies,
• Not to create incompatibility with other business ethics rules and policies supporting these rules,
• Not adversely affect their continuation of their duties in the company,
• It is possible with the written approval of the Management as stated below.

Approval is given by the Director concerned with the opinion of the Ethics Committee following the opinion of the Director, Manager and the manager to whom he/she reports for all positions reporting to the Manager, and by the relevant Director of the company with the opinion of the company Ethics Committee for other employees.

Efesanport San. ve Dış Tic. A.Ş. employees cannot serve as a member of the board of directors or auditors in companies other than Group Companies without the approval of the Board of Directors of the Company; cannot work in competitors or companies with which the Company has a business relationship.

They can work in non-profit organizations and universities for social responsibility and charitable purposes with the written approval of the management, in cases where they do not disrupt their duties within the Company.

Managers who are in a position to make a recruitment decision cannot hire their spouses, close relatives and their relatives and friends.

Managers cannot ask their employees to do political work or to join a party.

Employees cannot engage in any political activities during working hours and cannot take the time of their colleagues related to these activities.

Employees cannot use the company name, position in the company, title and company resources during their political activities.

The employee is obliged to inform the employer if there is a difference in the declaration of property given at the beginning of the job, which is contrary to the flow of ordinary life.

2.2. Misconduct

It is unacceptable for employees to harm the Companies by using their powers for their own and/or their relatives' interests and without the care expected from them.

Employees cannot directly or indirectly obtain personal profit from the Company's purchasing and sales activities and all transactions and contracts to which it is a party.

Employees cannot commit acts and behaviors contrary to morality, law, Company discipline and working procedures.

2.3. Use of Resources

In the use of resources to be made on behalf of the Company, the interests of the Company are taken into account. The Company's assets, facilities and personnel cannot be used outside the Company under any name and on behalf of whomever and for whomever without the benefit of the Company. The principle of "saving in all matters" is applied by all personnel.

While making project evaluations, the interests of the company are taken into account to the maximum. Project management processes are fully implemented and documented. Technical evaluations of the project results are also made. Authorities and responsibilities are clearly defined and monitored in all processes.

The correct use of resources for the benefit of the Company also requires the correct use of time. During working hours, company employees use their time well and do not spare time for their private affairs during working hours. Managers cannot assign employees for their personal affairs.

It is essential not to accept special visitors during working hours. Employees are required to complete the interviews for mandatory visitors in a reasonable time with the approval of their supervisor, in connection with the subject of the visit and in a way that does not hinder the workflow.

2.4. Relations with Other Persons and/or Organizations with which the Company Has Commercial Relations

The sustainability and success of our commercial relations are directly related to the strategies and policies we follow in our interactions with the outside world. It is shaped by a wide network consisting of other people and/or organizations, business partners, suppliers, customers and consultants with whom we have commercial relations. It is our priority to manage these relations within the framework of mutual trust, transparency, sustainability and ethical rules. A successful commercial relationship network supports its long-term growth, increases the effectiveness of operational processes, and strengthens innovation potential. In this context, Efesanport's strategic collaborations and partnerships play a critical role in achieving commercial goals.

2.4.1. Principles of Ethical Behavior in Commercial Relations

No special business relationship can be entered into with the Company's customers, subcontractors or suppliers and other persons and/or organizations with which the Company has a commercial relationship. Money and/or goods/services cannot be borrowed for personal purposes, and money and/or goods/services cannot be borrowed or received from other persons and/or organizations with which the Company has commercial relations.

In relations with customers; Even if it is in favor of the customer, a transaction cannot be made without customer knowledge, customer weaknesses cannot be exploited, and profit cannot be pursued by providing incomplete or incorrect information to the customer.

Company personnel cannot request gifts from other persons and/or organizations with which the Company has commercial relations or imply in this direction.

Any gifts, money, checks, property, free holidays, special discounts, etc. offers that would put the company under obligation cannot be accepted.

Personal aid or donations from any person or entity that has a business relationship with the Company are not acceptable.

2.4.2. Supplier and Stakeholder Management Principles

• It is essential to keep communication channels open with stakeholders, to benefit from their criticisms and suggestions, and to ensure the continuation of positive relationships.
• Mutual value should be created in business relations with suppliers.
• Communication with suppliers and contractors should be conducted in a clear, direct and accurate manner.
• Suppliers and contractors should be decided with objective criteria.
• In supplier and contractor inspections and visits, reasonable confidentiality and occupational safety rules requested by the supplier must be followed.

2.5. Media Relations

In relations with the media, we act within the Company Communication Protocol. The employee cannot make positive or negative comments, statements or explanations on behalf of the company on social media and other communication tools. Making a statement to any broadcasting organization, making interviews, participating as a speaker in seminars-conferences, etc., advertising, promotion, etc. activities related to the Company in social media and press publications are subject to the approval of the company's senior management. No personal gain can be obtained from these activities in any way.

2.6. Representation of the Company

In all kinds of associations, employers' unions and similar non-governmental organizations representing the company, all kinds of wages to be obtained as a result of the task performed are donated to the relevant institution or to the channels to be shown by the relevant institution.

Payments made by third parties to the Company employee in return for seminar speaker fees or a similar service are similarly donated to the relevant institution or to the channels to be directed by the institution. Apart from money, these people can receive gifts such as prizes, mattresses, etc., which are given as a memory of the day and have symbolic value.

2.7. Gift Acceptance and Giving Policy

Efesanport San. ve Dış Tic. A.Ş. and its employees, and not to attempt to provide gifts and benefits to third parties and organizations that may have such effects. The application principles defined below regulate the gift exchanges that may be made by the Company employees with third parties and organizations with which they have a business relationship and determine the principles to be applied in this regard.

2.7.1 Implementation Principles

Company employees cannot accept any benefit or gift with or without economic value, which affects or is likely to affect their impartiality, performance and decision-making while performing their duties.

Company employees; They may receive and/or give gifts outlined in Article 3 or accept to be subjected to a special application, provided that they are compatible with the business objectives of the Institution, comply with the applicable legislation and that the learning of the Gift by 3rd parties will not put the Company in a difficult situation.

Provided that it complies with the conditions specified in the above article;

• Company employees may give and receive entertainment, refreshments and meals at standards acceptable in the business world with the approval of the Company.
• In seminars and similar organizations attended on behalf of the company, gifts such as awards, plaques, etc. with symbolic value can be received as a memory of the day, apart from money.
• Gifts or benefits that are indirectly or explicitly tied to a return cannot be received.
• Receiving, giving or offering bribes and/or commissions is unacceptable under any circumstances. (See "Anti-Bribery and Anti-Corruption Policy")
• Company employees cannot accept gratuitous or loaned money from subcontractors, suppliers, consultants, competitors or customers, and cannot cover travel expenses, event expenses and similar payments.
• The gifts and promotional materials to be given by the Company to customers, dealers and other third parties with whom the Company has a business relationship are determined by the senior management of the Company.
• Provided that it complies with the above-mentioned conditions, the Company may accept eligible products and services as gifts and act with the knowledge and approval of the Company's senior management.
• In exceptional cases where local cultural values require mutual gifts above the values determined in the company policy, these gifts can only be accepted on behalf of the Company and with the approval of the Company's senior management. In any case, the exchange of gifts should be done in accordance with the local culture.

2.8. Policy on the Protection of Confidential Information

Knowledge is one of the most important assets that Efesanport San. ve Dış Tic. A.Ş. will utilise in realising its vision. In this regard, it is the common responsibility of all our companies and employees to use information effectively, share it correctly and ensure the confidentiality, integrity and accessibility of information in this process. The following application principles; It defines confidential information for companies and regulates the principles that employees must comply with regarding confidential information.

2.8.1 Implementation Principles

Confidential information, including but not limited to these, is not limited to Efesanport Efesan Demir San. ve Dış Tic. A.Ş., trade secrets, financial and other information that has not yet been disclosed to the public, information on personnel personal rights, personal data of our employees, customers and stakeholders, all project, machinery and structure designs, R&D process outputs, software created specifically for the company and information that we are obliged to protect within the framework of "confidentiality agreements" made with third parties.

The principles to be followed regarding confidential information are as follows:

• This information cannot be disclosed to third parties unless it is mandatory to disclose it in accordance with the Official Authorities and Legislation.
• This information cannot be changed, copied or destroyed. Necessary measures are taken to keep the information carefully, to store it and not to reveal it. Changes on the information are recorded together with its history.
• Confidential files cannot be taken out of the institution. For confidential information that needs to be taken out of the institution, the approval of the information responsible or senior management must be obtained.
• Passwords, user codes and similar identifying information used to access company information are kept confidential and are not disclosed to anyone other than authorized users.
• Company confidential information cannot be discussed in dining halls, cafeterias, elevators, service carts and similar public places, and cannot be shared on social media accounts and mobile phone applications. It can only be shared by authorized personnel within the scope and time permitted by the Company Management on social media accounts and mobile applications belonging to the company.
• Confidential information is classified according to their degree of confidentiality, which is clearly stated in the content of the information. Company personnel know the confidentiality of the information they obtain as part of their duties and act in accordance with this confidentiality. When there is any hesitation in terms of the degree of confidentiality, the upper confidentiality class is acted upon and the opinion of the relevant manager is sought when necessary
• In case of sharing information with third parties and/or organizations for the benefit of the Company, a confidentiality agreement is signed for information sharing or a written confidentiality commitment is obtained from the other party in order to guarantee that the responsibilities of these persons and organizations regarding the security and protection of the shared information are understood.
• The personal information of the personnel, such as wages, fringe benefits and similar personal information, which reflects the company policy and is personal, is confidential and cannot be disclosed to anyone other than the authorities. Information about the personnel is sent individually. Personnel may not disclose this information to others or pressure other employees to disclose the information.
• Action is taken in accordance with the legislation on the Protection of Personal Data.
• The above ethical obligations regarding confidentiality continue for the period after leaving the company for employees who leave the job for any reason.

2.9. Policy for Creating and Maintaining a Fair Working Environment

Efesanport Efesan Demir San. ve Dış Tic. A.Ş. considers the creation and maintenance of a fair working environment for employees as one of its most important priorities. It is aimed to increase the success, development and loyalty of employees by creating a fair, respectful, healthy and safe working environment that is compatible with all relevant laws and regulations. The following implementation principles determine the basic principles for creating and maintaining a fair working environment in Companies.

2.9.1 Implementation Principles

• Company practices are in compliance with all applicable laws and regulations regarding employment and working life. Company employees also fulfill all legal requirements within the scope of their activities and act in accordance with legal regulations.
• Efesanport Efesan Demir San. A.Ş. Human Resources policies and practices; It ensures that all other practices such as recruitment, promotion-transfer-rotation, remuneration, rewarding, social rights, etc. are fair.
• It is unacceptable to discriminate among employees within the organization on the basis of language, race, color, gender, political opinion, belief, religion, sect, age, physical disability and similar reasons.
• A positive and harmonious working environment that supports cooperation is created in the company, conflict environments are prevented, and people with different beliefs, thoughts and opinions are ensured to work in harmony.
• Employees' private lives and personal spaces are respected.
• In addition to all kinds of immunities of the employees, their physical, sexual and emotional inviolability is also observed.
• Violation of the immunity of individuals in any way through physical, sexual and/or emotional harassment in the workplace or anywhere they are due to work is against the law and ethical rules and this crime is not tolerated by the Company in any way. In this context, all kinds of measures are taken to ensure that employees work in a work environment where their physical, sexual and emotional immunity is protected.
• Violation of a person's bodily integrity and/or sexual harassment of a person without physical contact is defined as sexual assault/harassment. According to this; It is unacceptable to exhibit any behavior that can be considered within this definition.
• Carried out by one or more people in the workplace against other person or persons, continuing systematically for a certain period of time, aiming to intimidate, pacify or remove from work; "Psychological Harassment in the Workplace" (Mobbing), which is a set of malicious, deliberate, negative attitudes and behaviors that harm the personal values, professional status, social relations or health of the victim or victims, is also seen as one of the above-mentioned forms of harassment.
• It is ensured that the physical working environment and conditions of the workplace are healthy and safe for all employees.
• Efesanport Efesan Demir San. ve Dış Tic. A.Ş.  acts sensitively as a pioneer in its responsibilities towards society and humanity and takes all measures required by the legislation in order to ensure that its basic activities do not have negative effects on the environment, nature and living rights. It improves the awareness and sensitivity of employees on these issues.
• Managers cannot engage in arbitrary behavior, pressure, insults and threatening practices against their employees.
• Equal opportunities are provided for the continuous development and participation of all employees, and merit is given importance.
• Employees are encouraged to be individuals who are sensitive to social issues, respectful to all living things, reassuring and considering the peace of those around them.   
• Sustainable development goals are taken into account in all human resources, production, quality-control, sales-marketing and all other management processes related to maintenance. In this direction, social-economic and environmental balance is observed.

2.10. Payments and Protection of Rights

Efesanport Efesan Demir San. ve Dış Tic. A.Ş.  employees' payments and personal rights are carried out fully and accurately.

Efesanport Efesan Demir San. ve Dış Tic. A.Ş.  provides its employees with their wages and rights in accordance with the relevant laws on time.

Suppliers must comply with all laws governing wages and working hours, including minimum wage, overtime, and other compensation elements, and ensure that their employees receive the full benefits to which they are legally or contractually entitled.

2.11. Ensuring Regular Employment and Compliance with Working Hours

In our group, care is taken to employ the number of employees suitable for the workload, not to go out of working hours and to use regular leave. Utmost care is taken to place the right personnel in the right job.

Suppliers will not ask their employees to work more than the maximum hours allowed by law.

2.12. Granting the Right of Expression and Association,

The right of our Group employees to join, form or not join a trade union without fear of reprisals, intimidation or harassment is respected, and all applicable local and national laws regarding freedom of association and the right to collective bargaining are complied with.

It supports the complete provision and protection of freedom of thought and expression.

The interests of employees are respected.

Suppliers must respect the rights of their employees to organize as provided for by applicable law.

3. Responsibilities

At Efesanport, our understanding of business ethics and responsibility serves as a fundamental guide in all our commercial activities. Our company adopts a business culture based on the principles of honesty, fairness, transparency and responsibility. Our code of ethics aims to ensure that our employees, business partners, and customers operate under fair and equal conditions, respecting their rights.

While achieving its sustainable growth goals, Efesanport prioritizes its responsibilities towards society, the environment and its employees. In our operations, great importance is attached to issues such as respect for human rights, protection of the environment and occupational health and safety. All our employees and business partners are obliged to act in accordance with these ethical standards, and this sense of responsibility plays a critical role in maintaining the reliability and reputation of our company.

These ethical rules also ensure that our company's activities are carried out in a fair, responsible, and accountable manner for all stakeholders.

3.1. Responsibilities of Employees

Efesanport has determined in detail the ethical rules on ethics and related policies and procedures, how we should behave and how we should do our job. Compliance with these rules is the primary responsibility of all employees. In this direction, all Efesanport Efesan Demir San. ve Dış Tic. A.Ş. employees;

• Acting in accordance with laws and regulations under all circumstances,
• Reading the Code of Business Ethics, knowing, understanding, internalizing and acting in accordance with the rules, principles and values contained in them,
• To learn the general and business-related policies and procedures applicable to the company,
• Consulting with his/her manager and human resources about potential violations related to oneself or others,
• Promptly report potential violations by oneself or others; to submit their notifications regarding these issues (based on reliable sources, information and documents as much as possible) to the manager and/or the Ethics Committee in writing or verbally, with or without a name,
• To follow the "Ways and Methods to be Followed When Making Ethical Decisions", which is defined to help in acting in accordance with the rules and solving problems,
• There is a responsibility to cooperate with the Ethics Committee in ethical investigations and to keep the information about the investigation confidential.

 

3.1.1. Ways and Methods to be Followed When Making Ethical Decisions

As a guide in deciding on an action plan, you need to follow the steps below and ask yourself these questions:

*Identifying the Event, Decision or Problem

-Have you been asked to do something that you think might be wrong?

-Are you aware of a situation in companies or business partners that is potentially illegal or does not comply with business ethics?

-Are you trying to make a decision and have doubts about how you should act in accordance with business ethics?

*Think Before You Decide

-Try to clearly identify and summarize the problem or question

-Ask yourself why there is a dilemma

-Think about the options, their implications, and who might be affected

-Consult others

* Decide on a Plan of Action

-Determine your responsibilities

-Review all relevant facts and information

-Consult appropriate company policies, procedures, and professional standards

-Assess risks and think about how you can mitigate them

-Try to create the best plan of action

-Consult others

*Test Your Judgment

-Review questions that need to be asked ethically

-Review your decisions within the framework of the company's core values

-Make sure you take into account company policies, laws and professional standards

-Consult with others and consider their opinions within your planned action plan

*Continue with Determination

-Share your decision with the relevant people along with your reasons

-Share your learnings and success story with others

3.1.2. 4 Basic Questions to Consider

* Is this activity/behavior in accordance with laws, rules and traditions? (Standards)

*Does it meet professional standards?

*Is it in accordance with the law?

*Is this activity/behavior balanced and fair? If a rival company (someone else) did it, would we be disturbed? (Sense of justice)

Is it true in your opinion?

* Would our company and our stakeholders be disturbed if all the details of this event were heard by the public? (Emotions and ethical values)

*Would you be in a difficult situation or embarrassed if others knew that you were doing this?

*Can it have negative consequences for you or your Company?

*Who else may be affected by this (other employees within the company, you, shareholders, etc.)?

* To what extent does the "truth to be perceived" coincide with the "objective truth"?

*How would it be reflected in the media?

*What would a reasonable person think in the same circumstances?

3.2. Responsibilities of Managers

Efesanport Efesan Demir San. ve Dış Tic. A.Ş. managers have additional responsibilities beyond the responsibilities defined for employees within the framework of EFESANPORT ETHICS. Accordingly, managers;

• To ensure the creation and maintenance of a company culture and working environment that supports ethical rules,
• To set an example for the implementation of ethical rules with their behavior, to train their employees on ethical rules,
• To support its employees in submitting their questions, complaints and notifications regarding ethical rules,
• To guide them on what to do when consulted, to take into account all notifications and to forward them to the Ethics Committee as soon as possible when deemed necessary,
• It is responsible for ensuring that the business processes under its responsibility are structured in a way that minimizes the risks related to ethical issues and applying the necessary methods and approaches to ensure compliance with ethical rules.

3.3. Responsibilities of Ethics Committee Members and Others

The responsibilities of Efesanport ethics committee members play a vital role in maintaining and ensuring compliance with our company's business ethics standards. Ethics committee members ensure that ethical principles are adhered to in all activities of the company and guide employees within this framework. The main duties of these members are to resolve ethical dilemmas that may be encountered in business processes, to check whether ethical standards are violated and to increase ethical awareness within the company.

Ethics committee members are responsible for developing policies to ensure that employees and business partners act fairly, transparently and responsibly at all times. Additionally, it examines complaints and feedback, initiates disciplinary processes in relevant cases, and ensures a fair outcome for all parties. These responsibilities ensure the sustainability of our company's commitment to ethical values and social responsibilities.

3.3.1. Ethics Committee Members

To provide guidance and consultancy on questions and issues conveyed by employees on ethics within the company,

To contribute to the resolution of ethical nonconformities within the company and to direct nonconformities that cannot be resolved within the Company to the Ethics Committee,

To report the ethical questions and non-conformities received to the Ethics Committee regularly or when requested, together with the results,

To provide the necessary support to the investigations carried out by the Ethics Committee,

To monitor and follow the effectiveness of ethical practices carried out in the company; It is responsible for supporting applications.

3.3.2. Company Senior Management

They are responsible for the effective implementation of Efesanport Ethics or the Code of Business Ethics specific to their companies that they may create within this framework and for creating a culture in which this is supported.

The Code of Business Ethics and all related policies are reviewed, revised and documented by the Human Resources Group Directorate with the recommendations of the Ethics Committee and announced to the Companies with the approval of the General Manager and the Chairman of the Board of Directors.

3.3.3. Company Human Resources

Informing employees about the Code of Ethics, providing trainings in certain periods in order to ensure the clarity of policies and rules, and ensuring continuous communication on this issue with employees,

They are responsible for ensuring that those who are employed in the company read the code of ethics, are informed about it and sign the Employee Declaration.

3.3.4. Company Managements in Cooperation with the Ethics Committee;

To guarantee the confidentiality of complaints and notifications made within the framework of the Code of Ethics and to protect individuals after their notifications,

To ensure the occupational safety of the employees who make the notification,

They are responsible for ensuring that complaints and notifications are investigated in a timely, fair, consistent and responsive manner and for taking the necessary actions decisively as a result of violations.