Çelikler Code of Business Conduct and Ethics

Training and Development Activities

Trainings given within Çelikler Holding can be grouped under three main headings.

The primary purpose of these trainings is to promote personal development of all our colleagues and to maintain and further our current quality level.

  • Vocational Trainings: Activities aimed to develop and improve professional and technical knowledge and skills.
  • Personal Development Trainings: Activities focused on the individual with the aim to develop and improve basic competencies.
  • Compulsory Trainings: Trainings that are compulsory depending on the legal process

Occupational Health and Safety

Each employee is responsible for both his/her own occupational safety as well as that of their coworkers and also for all environmental procedures and instructions they must follow.

Every employee has to know about and act according to our policy.

Every employee must comply with the rules defined in OHS and all instructions and procedures pertaining to it, and execute all works assigned to them in accordance therewith. Use of personal protective equipment (in line with the requirements of the job and as specified in the Personal Protective Equipment Instruction) and compliance with occupational safety/environment rules in the field is an imperative requirements for all.

Information Flow

All department managers, shift supervisors, maintenance engineers and all superiors having employees subordinated to them are responsible for informing their subordinates about all updated Company procedures and rules asap and ensuring that communication takes place in a timely and healthy manner.

All employees at Çelikler Holding are responsible for acquainting themselves with updated Company procedures and rules. Stating they had not been aware of the rules as an excuse for their failure to follow these rules and procedures will not help the employee to escape the initiation of Disciplinary Procedures.

Information flow is conducted through notice e-mails, and all employees must follow the communication channel meticulously and in due manner.

Çelikler Holding Code of Business Conduct and Ethics

Ethics are the body of rules guiding us in all our conduct and behavior while carrying out our activities and business in accordance with laws, regulations and procedures.

All employees at Çelikler Holding sign a written commitment, by which they accept these rules an integral part of their “Employment Contract”.

Employees have to know, understand and execute the principles set out in the “Code of Business Conduct and Ethics”.

Çelikler Holding’s Code of Business Conduct and Ethics applies to all employees.

Honesty and Integrity

Integrity and honesty are a key value in all our business transactions and relations. We act according to the principles of honesty and integrity in all our activities, transactions and relations while fulfilling our conduct, duties and responsibilities towards third parties we establish relations with as a representative of Çelikler Holding, our coworkers within the company, our superiors, subordinates, in short, all our internal and external clients.

Equal Treatment and Fair Practice

Being equitable and fair in all our activities, transactions and relations are our important and indispensable values. We treat each other fairly and respectfully, and we do not engage in discriminatory behavior based on religion, language, race, gender or the like.

Observance of Laws, Regulations and Rules

We act in compliance with all applicable laws, regulations and rules and conduct all our acts and actions in accordance therewith.

Developing Responsible Behavior and Fulfilment of Responsibilities

We are well aware of the place we hold and the role we play in the whole picture and we display responsible behavior in accordance with this awareness towards our clients, coworkers, partners, suppliers, the society and environment. We conduct our activities and transactions in line with laws and provide accurate, complete and clear information to authorities and institutes in a timely manner.

Behavior worthy of Çelikler Holding's Name and Image

Çelikler Holding enjoys well-deserved prestige and reputation gained over the course of years by virtue of the honest, fair and professional approach adopted in all relations and practices, in compliance with the rules of business ethics, respectful to the society and the environment. Every employee has the responsibility of “representation” they bear naturally as an employee of Çelikler Holding, which they must in a way worthy of the image and name of Çelikler Holding.

Environmental Protection, Occupational Health & Safety

Protecting the environment and human health is a fundamental principle that we attach top priority in all our activities. In our work and business environment where occupational safety is ensured at its best and environmental and natural resources are preserved and made use of consciously, we expect all our employees to cherish these values and shape their conduct, actions and behaviors accordingly.

Efficient Use of Resources

Interests of the Company are always a determining factor whenever a resource is to be used for or on behalf of the Company. Under no circumstances can Company assets, facilities and staff be used outside the Company, for any purpose other than serving company objectives, under whatever name or on behalf of whomever, unless it will bring benefit to the Company . Managers may not appoint employees for their private errands.

All employees are expected to use the company resources as efficiently as possible. Being one of the most important resources, “time” must be used well and employees must conclude their meetings with any essential visitors in acceptable time, without interrupting workflow.

Confidentiality & Non-Disclosure

It is essential to avoid any conduct or behavior that would contradict confidentiality.

Information about the employees' personal rights and any commercial and technical issues proprietary to the company can be shared with third parties only in cases where such disclosure is essential and only with prior approval of senior management.

Information about our corporation and our business strategies, financial and personnel information, contracts, information of business partners, suppliers and clients are confidential and may not be altered, copied or destroyed. We take the necessary precautions to safeguard, retain and prevent disclosure of information. We do not take confidential files outside the company, and if this is necessary, we do so after we get the approval of the person in charge of the information or executive management. We do not make groundless declarations and/or spread rumors about any person or corporation.

Information reflecting the company policy or those that comprise employee salaries, extra benefits and any other personal rights are confidential and are not disclosed to any person other than the authorities. Information belonging to personnel are sent privately.

It is prohibited for personnel to disclose this information to others or force other employees to do so.

IT Security

Our policy regarding IT Security is to keep “data security risk” at the lowest level possible. Our employees (the end users) who play a key role in supporting the maintenance of information security in electronic environment are expected to pay due attention in keeping their passwords confidential.

Avoiding Conflicts of Interest & Unfair Advantage

Employees at Çelikler Holding may not derive benefits using their current positions for themselves, their relatives, families and/or any third-party association/corporation they are doing business with. An employee must not engage in any business that can harm Çelikler Holding’s key fundaments and/or that contradict the company interests, either on their own or third parties’ behalf, including their relatives.

Employees may not derive any direct or indirect personal profit from transactions or contracts which Çelikler Holding is a party to.

Taking on Extra Work

It is essential for employees at Çelikler Holding not to work for any other person and/or association within or outside the working hours for a salary or a similar sort of profit.

An employee may work in non-profit organizations and universities for social responsibility programs or charities with written approval of the management, without hindering their duties in the company.

Employees must submit such requests to HR within the knowledge of the related department manager.

Gift Acceptance & Gift Giving Policy

It is essential for employees not to accept any gifts or benefits that could possibly affect their impartiality, decisions and conduct, do not fit into the course of business, provide them with any privilege or benefit, and not to attempt giving gifts and benefits which could affect third parties, associations and corporations likewise. It is strictly forbidden for employees to accept free money or loan from a subcontractor, supplier, consultant or client or to have them cover the employees' travel expenses, entertainment costs etc.

It is not necessary for an employee to ask for permission to hand out a reasonable amount of company's promotional material to business partners they are in touch with or friends for their personal use, without expecting anything in return.

Bribery

Accepting, giving or offering bribe and/or commission is not acceptable under any circumstances whatsoever.

No employee can directly or indirectly offer, promise or give money or anything of value, nor allow the same to be given to, any person he/she is in a business relationship with, in order to obtain an unfair advantage.

We carefully refrain from all types of unethical conduct including bribery, malpractice and corruption.

Business Ethics & Ethical Conduct

We perform our tasks in an egalitarian, transparent, accountable and responsible manner.

Sense of mutual respect, trust and cooperation is fundamental to our relations with our coworkers and other people we work with.

Media Relations

Making a statement to any broadcasting corporation, having an interview, appearing as a speaker in a seminar, conference etc. is subject to the approval of the senior management. Official declarations to press can be made only by people explicitly authorized by the senior management.

Employee Responsibilities

All employees at Çelikler Holding are expected to act in accordance with Company procedures and rules and follow this principle in all their acts and actions.

PROTECTION OF PERSONAL DATA

Enactment of Law No. 6698 on the Protection of Personal Data (“Law”) has made it even more so important what process the personal data obtained through various means up until that day will undergo during the process of establishing compliance with the Law.

Healthy progress of this compliance process, also including the processing and storage of personal data, are under the responsibility of both companies and their employees.

Çelikler Holding and all the companies affiliated to it act in integrity with all their employees while responding to the requirements of the Law.

All kinds of information and practices about our Personal Data policies have been made available to all staff on our company’s official website (www.celikholding.com.tr), and all employees have been informed on the subject through PDP trainings. All employees are required to act in a manner that predicates on policies adopted as part of our PDP Compliance Process and conduct the routine controls and practices as defined therein.