KATMERCİLER INC. CO.

ETHICAL PRINCIPLES PROCEDURE

1.AIM

Aim of this procedure is governance of the ethical principles which must be followed by the employees

2.SCOPE

This procedure covers the rules of ethical principles for Katmerciler A.Ş.

3.RESPONSIBLE

  • General Director
  • Compliance Manager
  • Disciplinary Committee
  • Department Managers
  • HR Manager

4.DEFINITIONS

OHS: Occupational Health and Safety

5.REFERENCES

Workplace Personnel Regulations

6.RECORDS

Workplace Personnel Regulations

7.IMPLEMENTATION

Ethical rules are measures of integrity and honesty, which form the foundation of personal and social relationships in context of ethical viewpoint. These rules determine the expectations for each employee regarding what to be careful about in their discharge of their duties, how to perform their duties, how to work with clients and suppliers, and how to interact with other employees.

Katmerciler A.Ş. embraces and supports internationally accepted fundamental principles of human rights, occupational standards and anti-corruption in its sphere of influence.

In this context, all Katmerciler A.Ş. employees are required to fully comply with the ethical principles detailed below as a principle. Assessment of petition regarding creating, implementation and violation of ethical principles is among the duties of the Disciplinary Committee (Ref.: Duties and Powers of the Disciplinary Committee). In case any action in violation of ethical principles is observed or anyone becomes exposed to any such action the employee is required to report this situation to their immediate supervisor, the human resources department, the compliance manager or the disciplinary committee.

Anyone acting in violation of the criteria specified under ethical principles procedure must be reported to the relevant bodies listed above. Any employee who fails to report any violation of these rules after witnessing them will be subject to penalties defined under the workplace personnel regulations procedure.

7.1 ETHICAL PRINCIPLES

7.1.1 Time and Resource Management

Company resources are defined as all assets belonging to the company and/or temporarily consigned to responsibility of the company.

Company resources include;

  • All information, documents and instruments belonging to the company;
  • Company vehicles in stock, marketing vehicles and other task-specific vehicle and/or parts, accessories, tools, equipment, fuel, documents and instruments belonging to these vehicles;
  • Vehicles consigned to the employees by the company, personal vehicles of the employees, and/or parts, accessories, tools, equipment, fuel, documents and instruments belonging to these vehicles;
  • Vehicles used for service or sale purposes, vehicles belonging to visiting clients/visitors, and/or parts, accessories, tools, equipment, fuel, personal items, documents and instruments belonging to these vehicles;
  • Hospitality items, kitchen materials, stationery, promotional materials, cleaning materials, information technology consumables, administrative materials and repair & maintenance materials;
  • Desktop computers, laptop computers, cell phones, cell phone lines, telephones, faxes and similar communication devices, scanners, cameras, portable storage devices, card readers, printers, photocopiers and similar office materials;
  • Special tools, test devices, spare parts, warranty parts, scrap, returned parts, tires, fuel and all types of consumable materials.
  • Any asset outside the items listed above which is registered under company assets or consigned to trust of the company.

Interests of the company will be the primary consideration in case of any resource use on behalf of the company. Company assets, facilities or employee cannot be used without company interest and outside the company premises under any name, on behalf and in interest of anyone. The principle of "economy in all aspects" must be practiced by all employees and demonstrated by example of superiors to subordinates.

Employees are responsible to ensure all company resources are used in accord with the intended purpose and relevant procedures, as well as to protect these resources. All employees will be responsible to report to their supervisors in case any negligence, damage or negative condition is observed in use of company resources.

7.1.2 Time Usage

Company employees use time well within the working hours, and they should not spend working hours for their private affairs. Managers cannot charge the employees for their personal affairs.

Visitor cannot be accepted within working hours. Company employees are obliged to complete the discussions with the obligatory visitors in a reasonable time in relation with the visit reason and by avoiding to prevent the work flow.

It is required to pay attention to time usage for the duties out of the company (marketing activities, customer visits, visits to third parties and governmental offices, purchasing, test driving, emergency service, business or educational travel, meetings, etc.)

Relations with Customers/Contractors, Supplier Companies and Other Companies and Persons with whom Company have commercial relations.

Establishing Financial Relations with Customers/Contractors, Supplier Companies and Other Companies and Persons with whom Company have commercial relations

Company cannot establish private business relations with Customers/Contractors, Supplier Companies and Other Companies and Persons with whom Company have commercial relations, and money and goods cannot be borrowed for personal purposes and money and goods cannot be lend to Customers/Contractors, Supplier Companies and Other Companies and Persons with whom Company have commercial relations.

Except this, purchasing personal goods or services from Customers/Contractors, Supplier Companies and Other Companies and Persons with whom Company have commercial relations shall be considered as gaining benefit if it is quite under the value or free of charge, and it is evaluated in the scope of Workplace Personnel Directive.

7.1.3 Customer Relations

The following aspects are taken into consideration in the relations with customers:

  • Meeting the customer satisfaction is the priority of all employees even if it is out of the duty. The aspects causing customer dissatisfaction are discussed primarily. Maximum effort is presented to solve the customer complaints in the shortest time. In case of the fact that employee cannot solve the complaints within its duty field, he/she notifies his/her manager or department of Post-Sale Services.
  • Any process cannot be performed without the knowledge and approval of the customer even if it is for the benefit of the customer. (If there is a factor being in the scope of guarantee and threating the safety of customer in the service processes, it can be realized without requiring approval of the customer).
  • Missing or incorrect information cannot be provided with the customer even if it is for the benefit of the Company.
  • The mistake in any process in relation with the customer cannot be hidden. Solution is asked by notifying the manager. Information is given to customer in relation with the mistake.
  • Personal information of customer (contact information, marital status, profession, education status etc.) or any information or document about the vehicle (service history of the vehicle, km, invoice details, second hand value, expertise report etc.) cannot be given to second persons or company without the consent of customer (excluding written demands of official agencies).
  • Relationship with customer is a company-customer relationship. The way the employee behaves does not change according to friend, spouse and relative or continuous customer statuses of the customer.
  • No undesirable behavior is done to the customer (disrespect, ridicule, insult, harassment, insistence...etc.). In any negative events with customer, employee informs the manager about the reason without any dispute with customer.
  • No discrimination is done to the customer (outer appearance, physical disability, religion, language, nationality, gender etc.).
  • In meetings with customer, no comment or idea is expressed about special subjects such as policy, religion and nationality.
  • Collection from customer is done by departments specified in accordance with work rules. No employee can receive money or valuable document from customer (emergency service or transactions performed in the address of customer are not included).
  • Employees cannot do any payment on behalf of customer.

    • 7.1.4 Present acceptance

    Company employees cannot demand and cannot imply to demand any present from customers, contractors, suppliers and other company or persons with whom the company has a commercial relationship; cannot accept any present, money, cheque, property, free holiday, special discounts that will put the company under obligation (Presents such as book, agenda, flower, chocolate received for new years are not included. Price of this presents cannot exceed 100 dollars.).

    Compulsorily accepted presents within the scope of kindness are donated to foundations specified by the company.

    7.1.5 Accepting Support and Donations

    Personal support and donation cannot be accepted from any person or institution that has business relation with the company.

    7.1.6 Public Relations

    It depends on the approval of the Company's Top Management to make a statement to any broadcasting organization, to interview, to participate in seminars, conferences, etc. as speakers and to determine whether any price is received or not against this event. Otherwise, no personal gain can be obtained from these activities.

    In case of obtaining an income from these activities, it will be donated to foundations specified by the company.

    7.1.7 Relations with Associations, Societies and Political Parties

    Employee cannot provide financial assistance to the political activities on behalf of the company even by using his own financial resources and cannot participate in activities on behalf of the company except for professional and sectoral associations and societies. He/she cannot be active in any political party during his/her duty term. He/she cannot get into an act in any institution, association, society or political party in such a way as to affect the company's activities or disrupt the working atmosphere in the workplace with respect to these issues. Managers cannot demand their employees to engage in political activities or to be a member of a party, association, institution and society. Company employees may personally support the third parties financially or morally, make donations and take part in charity organizations.

    7.1.8 Relationship between Employees

    • The relationship built between employees is a business relationship. Familiarness and kinship of the employee does not change the form of address and behavior of the employee.
    • The employees do not act in a way which exceed the limit of being co-worker in workplace environment.
    • It is inappropriate for couples or relatives to work in a superior-subordinate relationship or to work in the same department.
    • The employees cannot act in a way which is not approved by their fellow workers (disrespect, teasing, humiliation, harassment...etc.).
    • No discrimination between employees is made (appearance, physically disabled, religion, gender, language, race etc.)
    • The employees should not make propaganda on personal issues such as politics, religion, race in the meetings between each other or they should not pressure in order to affect opposite party’s view. The employees cannot ask for their co-workers to involve in a political activity or to become a member of a party.
    • The employees cannot keep weapon, sharp objects, pocket knife and suchlike dangerous objects in the company.
    • Behavior containing violence and/or aggressive attitude and/or threatening talking and ways of behavior are unacceptable in the company. In such cases, the respective manager is notified.
    • The employees cannot make false statements regarding their co-workers, customers and relative organizations related to the company and / or they cannot gossip.
    • Gambling and betting are prohibited within the boundaries of the company.
    • It is forbidden to come to the company with alcohol and pleasure-inducing substance. These substances are not used in the company.

    7.1.9 Conflict of Interest Management

    Katmerciler employees do not engage in an activity or approach that would create a conflict of interest with Katmerciler. Katmerciler employees do not use Katmerciler assets for their personal interests or for the benefit of anyone inside or outside the company. Katmerciler employees; It is unacceptable for Katmerciler to make personal agreements that will weaken the possible advantages of Katmerciler in the negotiation process with the companies that may be subject to agreement, to engage in activities that will cause this or to carry out financial transactions.

    7.1.10 Economic Sanctions

    Some countries we work with; They may have imposed restrictions on other countries, companies and individuals. For this reason, our company always complies with applicable regulations by closely following economic sanctions, export controls, boycott and embargo, corruption and customs laws. We share with our employees that violation of these restrictions can have serious consequences, such as the cancellation of our export licenses, administrative fines, and potentially imprisonment penalties.

    7.1.11 Actions Against Counterfeit and Erroneous Documents

    All records and financial statements of our company must accurately reflect all transactions of the company. No false declaration or entry can be made in the company records for any purpose. Care should be taken to ensure that all costs are properly recorded, disclosed and charged. No record, entry or document will be fraudulent, distorted, misleading, misdirected, deliberately incomplete or suppressed. Katmerciler disciplinary regulation will be applied to the personnel who forged or attempted to counterfeit the documents.

    7.2 OUR LEGAL RESPONSIBILITIES

    Katmerciler carries out all its domestic and international activities in accordance with local and international laws and regulations. Provides timely accurate, complete and understandable information to institutions and organizations that implement legal legislation. While carrying out these activities, it stands at an impartial and equal distance to all kinds of public institutions and organizations, non-governmental organizations and political parties without any expectation of benefit. All kinds of financial statements and reports prepared by the company comply with national and international accounting principles.

    7.3 OUR RESPONSIBILITIES TO OUR SHAREHOLDERS:

    In order to increase the share value of the company, growth-oriented strategies are applied by avoiding unmanageable risks. The company acts within the framework of financial discipline and accountability. The company resources and assets are managed with the awareness of savings and efficiency.

    Statements made by the company to the shareholders and the public are announced to the investors, partners and the public in a complete, simultaneous and understandable manner in line with the principle of equality. Thus, it is ensured that all shareholders access information at the same time and equally. Shareholders and the public are provided with timely, accurate, complete and understandable information on financial statements, strategies and projects that will add value to the company.

    7.4 OUR RESPONSIBILITIES TO SUPPLIERS AND CUSTOMERS:

    In relations with customers and suppliers; The principles of honesty, trust, consistency, professionalism, independence, and respect for mutual interests are observed. It is aimed to fully meet customer needs and expectations in product production. Confidential and trade secret information of the company, personal information of employees and customer information are kept confidential. Donations made by the company are duly announced to all stakeholders and the public.

    7.5 OUR RESPONSIBILITIES TO COMPETITORS:

    Competitor companies and products are not denigrated or misleading advertising. Our company avoids actions that create unfair competition. Fights against unfair competition by legal means.

    7.6 OUR RESPONSIBILITIES TO OUR EMPLOYEES:

    There is no discrimination based on race, ethnicity, nationality, religion or gender among company employees. Equal opportunities are provided to employees under equal conditions, and performance and efficiency are taken as basis in remuneration and promotion. Employees are provided with a safe and healthy working environment as well as the opportunity to develop their careers. Mutual respect and trust in relations between employees and cooperation is essential. Employees cannot use confidential and non-public information about the company in favor of themselves and others. In addition to the training of employees on individual and professional issues, they are trained on natural disasters such as first aid, earthquake and fire. As a company, we support our employees in their voluntary participation in social and social activities, and we observe the balance between their business and private lives.

    7.7 SOCIAL RESPONSIBILITY PRINCIPLES:

    Be sensitive to the protection of the environment and natural life, consumer rights and public health and comply with the legal regulations issued on these issues. Cooperation is made with non-governmental organizations established for social responsibility.

    7.8 KATMERCILER INTEGRATED MANAGEMENT SYSTEM POLICY:

    Katmerciler;

    Aiming innovations within the scope of the 4th Industrial Revolution in Defense Industry and On-Vehicle Equipment Production,

    To determine and reach quality targets without sacrificing quality in order to reach customer satisfaction,

    Customer needs and applicable primary and secondary legislation requirements are determined, understood and regularly met, Quality Policy

    Compliance with the purpose and context of the company, including its structure, scale and activities, and environmental impacts of its products and services,

    To reduce water consumption by using water from our natural resources efficiently,

    To monitor and reduce our air and wastewater emissions,

    To meet the relevant legal requirements in wastewater quality,

    To continuously improve our performance in the direction of environmental protection within the framework of the principle of sustainability,

    To comply with the directives published by the European Union that contain restricted and prohibited chemical materials,

    Determining environmental targets,

    To prevent pollution at its source by considering environmental awareness,

    Fulfillment of compliance obligations,

    To reduce the consumption of natural resources by efficiently using the scarce energy resources in nature,

    Minimizing the use of environmentally damaging wastes,

    To take active measures in the recovery of wastes. Environmental Policy

    To prevent work accidents and occupational diseases,

    To effectively program and implement the control and supervision of production tools and equipment and employees to ensure Occupational Safety,

    Determining and achieving OHS targets,

    To fulfill the legal terms and other conditions,

    To eliminate dangers and reduce OHS risks,

    To continuously develop and improve the OHS Management System,

    Ensuring active participation of employee and employee representatives in the OHS management system,

    Fulfill operations such as the use, safety, commissioning, and relocation of machine equipment in accordance with the standards,

    Establishing an internal organization and application in accordance with legal regulations and standards against emergencies such as fire, earthquake, sabotage,

    To use Personal Protective Equipment effectively,

    To use special ergonomic systems and equipment especially for disabled employees together with all employees,

    Planning and implementing chemical storage, transportation and use activities in a way that does not harm employees and other stakeholders,

    It has adopted to provide all physical precautions to provide fire protection as an Occupational Health And Safety Policy.

    7.8 HUMAN RESOURCES POLICY

    Katmerciler seeks job suitability as the only measure in the recruitment and employment of its employees. It does not discriminate against religion, language, race, gender or similar issues.

    To provide an efficient and safe working environment to make our employees proud of our company,

    To provide continuous training and self-improvement opportunities to our employees,

    To protect our employees' material and moral rights,

    To maximize the existing potential of our employees by making a good career planning,

    Providing opportunities for employees to show their leadership in terms of applying them to their areas of responsibility,

    To apply a transparent and open management policy as top management,

    Aiming to continuously improve and develop our human resources policy,

    To ensure and protect equality of opportunity among our employees in every field

    To effectively program and implement the control and supervision of production tools and equipment and employees to ensure Occupational Safety,

    To prevent work accidents and occupational diseases,

    We do not legally employ individuals under the age of 18, stand against forced labor, which includes forced labor, debt bondage and all forms of human trafficking, illegal child labor of gender discrimination, abuse of children and any other maltreatment or exploitative behavior of employees, and all our business processes We are conducting according to.

    World, country and sector trends are followed in wage and benefit packages, and a compensation policy is applied accordingly.

    Competitive compensation and benefits strategies that reward consistent high performance, are compatible with market conditions.

    Wage policies prevailing in the market are made in accordance with legal obligations, taking into account the size of the company, the wage policies created by taking into account the long-term targets, the work size, performance results, and the balance of wages within and outside the company.

    To implement a fair compensation system within the company and competitive in the sector,

    Working hours that maintain the work-life balance of our employees are adopted, and efficient work is supported.

    We comply with all applicable laws, collective agreements and regulations while regulating daily and weekly working hours, overtime, breaks, weekend and annual paid leaves.

    Without any discrimination within our company, all employees have the right to become a member of the relevant organizations, provided that they comply with the laws and regulations, within the scope of the protection of the right to freedom of association and collective bargaining.

    It has adopted and implemented as a Human Resources Policy.