1. OBJECTIVE AND SCOPE
The objective of this policy is to specify the commitments that should be made by employees of Bati Nakliyat ve Ticaret A.S. (BATI) during the performance of their duties and while acting based on the mission of representing BATI, and to define the ethical values integrated into the company's fundamental values and indicators of compliant behaviour. The Policy applies to employees working in all business places of BATI.
Company employees are obliged to comply with ethical values during the performance of their duties. Our business ethics rules, which are based on our company values, have been established with the awareness that business procedures, instructions, laws and regulations may not guide our attitudes and behaviours. Situations and behaviours not specified in this procedure should be interpreted based on and in parallel with this mindset, and appropriate ethical behaviours should be displayed.
2. ETHICAL VALUES AND OPERATING PRINCIPLES
2.1. Compliance with the Laws
The Company's management and employees act in compliance with the applicable legal requirements in all activities. It is strictly forbidden for our employees to falsify the official documents issued during the performance of their duties.
2.2. Integrity
Integrity and honesty are among our primary values in all our business, operation, processes and relationships. We are based on honesty and honesty in our relations with the government, our customers, our employees and all other stakeholders, and we act with the importance and priority of creating a reliable image.
2.3. Respect to the Environment
The position of our companies and employees is not to harm the environment with our activities, protect the environment and show responsibility about the environmental problems. We support environmentally friendly activities and collaborations in line with our capabilities.
2.4. Discrimination and Marginalization
Our Company respects the equality of opportunity. Our prospective employees and employees are not exposed to any discrimination, marginalization or harassment due to gender, country, nationality, sect, age, race, color, religion, language, sexual preferences or disability.
2.5. Proper Use of Company Resources
Proper, regular and correct use of all kinds of company resources such as people, money, buildings, tools, equipment, time, etc. is essential and misuse of these resources is not tolerated. Our employees must carefully protect the company assets we have and use them efficiently. Company interests are taken into account in all uses of resources. Company assets and facilities may not be used for personal purposes.
Time is an important asset for the company and it is essential to use it efficiently and productively during working hours. Employees should not spare time for their personal business during business hours, and should use their time to fulfill their duties and responsibilities. It is essential that no private visitors are accepted during working hours. In obligatory cases, the meetings should be completed in a reasonable time in connection with the subject of the visit and in a way that does not hinder the workflow. Managers are not entitled to assign employees for their personal business.
2.6. Relations with the Press and Media
The spokesperson determined by the senior management is authorized to make written or verbal statements about the company and activities thereof. Financial and all sensitive information is transmitted only through the spokesperson. Making a statement to any press / broadcasting organization, giving an interview, seminar-conference, etc., participation as a speaker is subject to the prior written approval of the BATI Board of Directors. No personal interest may be obtained as a result of these activities. In the channels accessible on the Internet, in the social media, in the press and media and in all other public channels, actions are taken in accordance with the following rules:
· Company's tradename and information must be written correctly.
· Information that is not related to facts should not be given.
· Inaccurate, misleading, baseless, defamatory, damaging, etc. information or comments may not be given about our company, customers, suppliers and competitors, and it is not permitted to engage in any discussions with any third real or legal person.
2.7. Confidentiality and Protection of Trade Secrets
During the performance of their duties, our employees may not disclose confidential information or trade secrets they have learned about the company or third parties with whom they have business relations, in any medium or by any reason whatsoever. They pay high level of care and attention to the confidentiality of such information.
The employee is obliged to act in accordance with the matters specified within the scope of the employment contract and confidentiality agreements executed with third parties. It is essential that such confidential information is used only for corporate purposes and only shared with relevant persons subject to the authorizations made. It is strictly forbidden to use this information for obtaining any commercial interest.
Employees are not permitted to take the confidential information and documents, and works such as projects, regulations, etc. that are in their possession by reason of their duty, out of the company while leaving the company.
Employees must ensure that confidential documents that need to be destroyed are destroyed so that they cannot be accessed again.
Subjects containing information that may harm the company or its customers are not discussed in the areas where customers or other third parties are present.
Company information (procedure, instructions, forms, etc. all documents) and internal correspondence may not be shared with outsiders, taken out of the company or transferred electronically. In case of any potential situation that may require providing the information described above, the opinion of the senior management is taken and actions are taken accordingly.
2.8. Competition
Our companies and employees are sensitive about behaving ethically, in compliance with the law and in integrity while competing with our competitors. In this regard, they do not behave in a way that will put our company in a difficult situation and damage its image.
2.9. Avoiding Conflict of Interest, Gifts
A conflict of interest is a situation that indicates the potential of a real or legal person to obtain personal or corporate interests by improperly using the status, purpose and mission of that real or legal person.
As BATI, we display behaviours that avoid situations that may create a conflict of interest in our activities. All of our employees are expected to adhere to high standards of business ethics/ethics based on fairness, objectivity and professionalism, and avoid conflicts of interest when doing business with third parties on behalf of the company. It is unacceptable for company employees to exploit their positions to obtain personal interests or interests for others.
Batı employees will not accept or attempt to give gifts and interests that may affect their impartiality and decisions in their relations with third real or legal persons. Products such as calendarts, pens, etc. which have symbolic/ reasonable monetary value are exceptions.
It is forbidden for a Batı employee and his family or relatives to obtain personal interests by taking advantage of the employee's position in the company, and to have relations with individuals or organizations that may benefit from the confidential information in their possession. Our employees should pay utmost care for protecting the interests of the company and avoid acts and behaviours that may serve to their own interests or interests of their relatives while doing their jobs.
In the event that an employee wants to do business with our company by establishing a company or as a partner/employee of another company after leaving his/her job in the company, our current employee who will be in contact with him/her should pay utmost care to the interests of our company before or after the business relation and behave in a way that does not allow any potential conflicts of interest. In such a case, the approval of the General Manager must be obtained before establishing any business relationship.
The Company may be represented in the events such as trainings, celebrations, conferences, introductions that are open to public and organized by real or legal persons such as customers, suppliers, etc. that have or may have the potential to be in a business relationship with our company. Accepting an invitation (sports, cultural or social) that may be effective in decision-making processes or that can be perceived as such, is possible provided that they are directly related to the business and that the customer or supplier makes that invitation to other stakeholders in the ordinary course of business. In case of invitations, reasonable actions are taken without exaggeration.
2.10. Anti-Bribery - Anti-Corruption- Anti-Money Laundering
Our company has a policy that prohibits its employees from offering, giving, accepting or receiving bribes. Corruption is strictly forbidden. Our employees give/ receive gifts to / from only the persons, organizations and institutions in business relationship with our Company, solely subject to the limitations set for this purpose. Money laundering is an act of concealing the source of a proceeds of crime, which constitutes a very serious offense for the official authorities and causes other crimes to be committed. The company or employees thereof are strictly prohibited from participating in or facilitating any such transaction.
2.11. Impartiality
Our company is equidistant from any existing or future political parties and activities. The Company avoids helping any of them and does not take part in political activities. During the performance of operations, the Company complies with its obligations with the awareness of its responsibilities and without any expectation from any public organization and institution, administrative body, non-governmental organization and political party.
2.12. Harassment and Malfeasance
Harassment may be defined as exposing a person to humiliating, distressing and defamatory behaviours in a consistent and wearisome manner. Our Company is strictly against any form of physical, sexual and psychological harassment and malfeasance in every field of business and business operation. Employees are treated with respect and courtesy and behaviours that create an ill-intentioned and violent working environment are not allowed and persons with tendency to show this type of behaviours are not tolerated.
2.13. Our Position Towards Customers, Employees and Suppliers/ Business Partners
BATI has a position based on the awareness of its responsibilities towards the parties in the business ecosystem and conducts its operations in parallel with this position.
a. Our Position Towards Customers
b. Our Position Towards Employees
c. Our Position Towards Suppliers/ Business Partners
3. OPERATIONS AND IMPLEMENTATION
3.1. Notification
Our employees, customers, suppliers and business partners may serve a notification in writing or verbally on their findings and suspects about the matters detailed in this procedure and through the communication channels specified below, within 5 working days, without revealing their identity, if they wish to do so. All notifications will be treated confidentially.
Communication channels for notifications to the Ethics Board:
E-mail : etik@batigroup.com.tr
Phone : +90 212 293 24 00 - Ext. 106
Address : Büyükdere Cad. Akabe Ticaret Merkezi No: 78-80 Fl: 2/202 Gayrettepe 34394 İstanbul, Turkey
3.2. Subject of Notifications Made Over Ethical Channels
Primary subjects are listed below for the notifications of employees or 3rd persons (customers, suppliers, etc.) that may be served about harassment over ethical channels.
Notifications shall be made solely for the matters described in Article and for which examples are provided above, and any claim such as complaint, proposal, objection etc. that contain dissatisfaction shall not be processed.
3.3. Evaluation of Notification
Notifications made inside or outside the company are evaluated by our company's Ethics Committee. The consistency of the subject and the importance of the information are evaluated, a detailed examination and investigation is carried out, and the final decision is made on taking the necessary measures and actions. Based on the decision to be made, if deemed necessary, action will be taken against the relevant persons in accordance with the Disciplinary Procedure.
All notifications are recorded and carefully evaluated. The Ethics Committee may request information and data from any department upon the need for investigation. It regularly reports its results to the General Manager and the Board of Directors. The Ethics Committee has the authority and responsibility to monitor the results, the measures taken by the senior management and management units and the actions taken.
3.4. Ethics Committee
The Ethics Committee is responsible for investigating and solving the complaints and notifications on violation of ethics in accordance with the Ethics Policy and it reports to the Board of Directors.
The Ethics Committee consists of the individuals in the following positions:
Chairperson - Human Resources and Quality Systems Director
Member - Financial Affairs Director
Member - Internal Audit and Risk Management Director
Operating Principles of the Ethics Committee: