Ethics Procedures

PURPOSE

This Procedure has been prepared with the purpose of defining the principles determined with regard to operation relations in the company and representation and communication standards undertaken by Erciyes Anadolu Holding A.Ş. Employees for its customers.

DEFINITIONS AND ABBREVIATIONS

Ethics: Work ethic

Ethics Committee: It is a committee established with the purpose of determining behavior principles required to be followed by all employees while performing their tasks on behalf of Erciyes Anadolu Holding Board of Directors, producing opinions about occupational, conscientious and ethical values related to current problems and performing works to ensure that ethical culture is adopted by all of our employees.

SCOPE AND RESPONSIBILITIES

This document applies to all personnel working in Erciyes Anadolu Holding and its affiliates for full-time, partial, definite or indefinite period. Workplace Ethic, Behaviors and Operation Principles document is a document consisting general principles related to rights, responsibilities and working conditions in the company while all personnel working in Erciyes Anadolu Holding A.Ş. Perform their responsibilities. This document is provided together with the individual service contract in employment process of a new staff of the company.

Each staff in company is responsible to act in accordance with internal management operation law and legal rules of Erciyes Anadolu Holding A.Ş. All managers are responsible for monitoring and communicating non-compliance with these rules to senior management.

IMPLEMENTATION

1.1.   GENERAL REGULATIONS: Our employees should perform followings:

1.1.1.     Not acting against ethical behaviors while performing their tasks.

1.1.2.     Be responsible of knowing company regulations and instructions and acting accordingly. Following changes in these subjects.

1.1.3.     Notifying management immediately with regard to legal subjects for the company. Not taking any personal measure.

1.1.4.     Avoiding all types of personal behaviors and attitudes that can harm reputation of Erciyes Anadolu Holding A.Ş. and its group companies.

1.1.5.     Disciplinary Punishments: On condition that rightful and valid termination rights of Erciyes Holding A.Ş. arising from laws, are reserved, following process is realized when it is seen that there are behaviors interrupting word order of the company and its employees and interrupting working peace, and behaviors demonstrated not complying with operation standards.

 

1.1.5.1.          Subjects regarding discipline are taken into account by the Ethics Committee, whose composition and working method are specified in the Ethics Committee Working Principles.

1.1.5.2.          The manager to whom the relevant employee reports, asks the employee in writing to state the reason and explanation for the error observed. The manager should indicate that the employee must provide his/her explanation within one working day. One copy of this letter is given to the employee, one copy to the Ethics Committee and one copy to the Human Resources Department.

1.1.5.3.          The relevant employee gives his/her explanation about the incident in writing

1.1.5.4.          The explanation that is taken from the employee is evaluated by his/her manager and the Ethics Committee.

1.1.5.5.          If it is concluded that the employee is at fault in the evaluation, the sanction to be applied is decided.  

1.2.   ETHICAL COMMITTEE OPERATION PRINCIPLES:

1.2.1.     The Ethics Committee has been established with the purpose of determining behavior principles that should be followed by all employees while performing their tasks on behalf of Erciyes Anadolu Holding Board of Directors, producing opinions about occupational, conscientious and ethical values related to current problems and performing works to ensure that ethical culture is adopted by all of our employees

1.2.2.     The Ethics Committee, which reports to the Chairman of the Board of Directors of Erciyes Anadolu Holding A.Ş., consists of the Chairman, Members and a Reporter Member.

1.2.3.     Tasks and Responsibilities of  the Ethics Committee:

1.2.3.1.          Investigating complaints and denunciations regarding violation of any announced ethical rule.

1.2.3.2.          Reporting results of an investigation to relevant departments and authorities.

1.2.3.3.          Presenting opinions and suggestions for implementation of the ethical rules.

1.2.3.4.          Providing response to applications made for counseling purposes.

1.2.3.5.          Ensuring that Erciyes Anadolu Code of Ethics complies with legal regulations and current changes at local or national level.

1.2.3.6.          Supporting all group companies on ethical practices.

1.2.4.     Operation Principles of the Ethics Committee:

1.2.4.1.          Keeping identity of any complainant and denunciation confidential.

1.2.4.2.          Performing investigation as confidentially as possible.

1.2.4.3.          Having authority to demand any information, document and evidence regarding any investigation directly from relevant department. Examining all types of information and document obtained in a manner limited with only subject of any investigation.

1.2.4.4.          Issuing a written report since beginning of any investigation. Adding all types of information, evidence and documents to that report.

1.2.4.5.          Recording different opinions together with their reasons when a consensus cannot be ensured about one subject taken into the committee’s agenda.

1.2.4.6.          Signing the report by the chairman and members.

1.2.4.7.          Taking investigations into consideration with immediate methods and ensuring conclusion as soon as possible.

1.2.4.8.          Taking the committee decisions by a large majority and implementing these decisions immediately.

1.2.4.9.          Taking action by the Chairman and members independently and without being affected from hierarchy in the organization while performing their tasks. Not making any pressure or infusion on the people.

1.2.4.10.       Applying for an expert opinion when it is considered required by the committee and taking benefit from experts by taking required measures that will not violate confidentiality principles during any investigation.

1.2.4.11.       Facilitating operation of the committee, ensuring administrative and technical support required to ensure relevant actions without compromising confidentiality in a safe and short manner by notifying and taking approval of CEO by relevant departments of the Holding.

 

1.2.5.     Ethics Committee Meeting and Determination of Agenda:

1.2.5.1.          The Ethics Committee performs a meeting upon invitation of the Chairman of the Board when it receives a notice, complaint or when its opinion is requested. The Committee can held a meeting upon recommendation of any of its members to evaluate the works or other evaluation considered required or upon invitation of the Chairman.

1.2.5.2.          The Committee may invite persons it deems appropriate to its meetings to obtain information regarding subjects deemed necessary.

1.2.5.3.          The meeting agenda is determined by the Chairman. The Committee members submit the issues that they want to be included in the agenda and the related information and documents to the Chairman in a reasonable time before the meeting date. The agenda will be notified to the Committee Members in a reasonable time before the meeting.

1.2.6.     Reviewing and General Responsibilities of the Ethics Committee:

1.2.6.1.          The Chairman is responsible of implementation of the Ethics Committee Principles. It is reviewed at least once a year. It can be reorganized in line with changes made in the process when deemed necessary. In case of an update, it is announced to all employees.

1.2.6.2.          Within this framework, Erciyes Anadolu Holding’s Ethics Committee performs followings;

1.2.6.2.1.                The Committee analyses contraventions and suspicious situations submitted to the Committee and decides on corrective action.

1.2.6.2.2.                It monitors whether problems are addressed and resolved and corrective actions are taken in a timely and effective manner.

1.2.6.2.3.                In non-emergency situations, it reports developments to the Board of Directors through meetings and/or interviews. Efforts are made to ensure that decisions are taken unanimously.

1.2.6.3.          The employees are obliged to perform followings;

1.2.6.3.1.                Acting in accordance with the ethical rules while performing their duties,

1.2.6.3.2.                Asking for advice when they feel that there may be a breach of ethical rules,

1.2.6.3.3.                Reporting known or suspected irregularities immediately,

1.2.6.3.4.                Establishing cooperation in examination and investigation of situations contrary to the Code of Ethics.

1.2.6.4.          The managers are obliged to perform followings;

1.2.6.4.1.                Creating an environment that encourages employees to ask questions and raise concerns about ethical issues and encourages ethical behavior,

1.2.6.4.2.                Ensuring that employees know the Ethics Book,

1.2.6.4.3.                Answering employee questions or directing them to appropriate resources,

1.2.6.4.4.                Demonstrating his/her commitment to the Code of Ethics with his/her words and actions,

1.2.6.4.5.                Being careful to prevent and uncover situations contrary to ethical rules,

1.2.6.4.6.                Reporting risks and non-compliance with the code of ethics immediately and taking appropriate measures for corrective actions,

1.2.6.4.7.                Processing employee reports immediately, in compliance with confidentiality.

1.2.6.5.          All of our employees can always consult their managers about situations that may be unethical. In cases where it may not be appropriate to consult with the manager, it is possible to forward it to a higher level manager or a member of the Ethics Committee designated and announced by the Ethics Committee.

1.2.6.6.          Employees can keep their identity confidential during reporting (However, they should know the benefits of being able to reached during an investigation phase). If employees do not indicate their names when they report misconduct or an ethical concern, this information will be disclosed in accordance with the principles of confidentiality (only when necessary).

1.2.6.7.          Retaliation against any individual as a result of reporting and providing support to investigations, is not permitted, even if the misconduct is found to be untrue.

1.3.   CODE OF CONDUCT:

1.3.1.     It is absolutely unacceptable for Erciyes Anadolu Holding A.Ş. employees to harass and disturb their co-workers regarding sexual, social and physical issues. Employees who think that they are victims of any harassment and disturbance and third party employees who are observers of this situation, are obliged to issue a report regarding that subject to the relevant managers for follow-up.

1.3.2.     Violent behaviors and/or aggressive attitudes and/or threatening speech and behaviors are absolutely unacceptable at Erciyes Anadolu Holding A.Ş. Weapons, cutting tools, pocket knives and various dangerous assault tools are not allowed inside the office. In this context, all possibilities that may occur, are investigated and followed up in the most serious way. In cases of violent behaviors, it is sufficient and valid reason for employees to be taken into account as guilty if these employees are responsible for either initiating or continuing the incident in question and responding to it. Employees who think that they are victims of any violent behavior and third party employees who are observers of this situation, are obliged to issue a report regarding that subject to the relevant managers for follow-up. It is expected that employees show courtesy and respect required by the work environment for themselves and their colleagues at all times and under all circumstances.

1.3.3.     Sexual / emotional / sensual contact and movements of our employees are not allowed in Erciyes Anadolu Holding A.Ş. offices. Third party employees who are observers of this situation, are obliged to immediately  issue a report regarding that subject to the relevant managers for follow-up.

1.3.4.     It is absolutely unacceptable to use drugs and/or stimulants and/or alcohol in Erciyes Anadolu Holding A.Ş. offices or to come to the workplace under the effect of these substances. These substances cannot be allowed into the office. When it is observed that employees are under the effect of the substances mentioned, these employees cannot be allowed to work and necessary precautionary measures are applied.

1.3.5.     Promotion for commercial, political, social and religious purposes is not permitted in Erciyes Anadolu Holding A.Ş. offices. Erciyes Anadolu Holding A.Ş. cannot be used in such promotions. Employees are not allowed to promote products during working hours and to organize campaigns and to make association and cooperation membership works, to make commercial sales, to make advertisement distributions, to keep permanent materials in the offices and to take place in similar activities are n.

1.3.6.     They cannot be take place in any political, political, commercial and religious formation by using the name of Erciyes Anadolu Holding A.Ş. No action can be realized in a manner  disseminating and adopting these ideas inside and outside the company. The following behaviors are expected from employees of Erciyes Anadolu Holding A.Ş. in this regard:

1.3.6.1.          Not taking part in protests and mass demonstrations

1.3.6.2.          Not making declarations

1.3.6.3.          Not hanging unauthorized posters and not distributing flyers within the company for any reason whatsoever

1.3.6.4.          Not organizing secret meetings for action purposes

1.3.6.5.          Not dealing with any commercial activity by using the name of Erciyes Anadolu Holding A.Ş.

1.3.6.6.          Not causing the company to be perceived as a addressee and not carrying any legal obligation by using the name of Erciyes Anadolu Holding A.Ş. in any commercial activity which is made personally.

1.3.7.     It is not acceptable that employees of Erciyes Anadolu Holding A.Ş., commit theft, theft, breach of trust, forgery, fraud, perjury, slander, bribery, embezzlement (disgraceful offenses) in and out of the company.

1.3.8.     It is not acceptable that employees of Erciyes Anadolu Holding A.Ş., behave in a way that may prevent or damage the use of common areas during the use of common areas

1.3.9.     Erciyes Anadolu Holding A.Ş. offices have special areas designated for smoking. Smoking in toilets, corridors, offices and system rooms is strictly unacceptable.

1.3.10.  Erciyes Anadolu Holding A.Ş. provides telephone / fax / e-mail services to employees to enable them to fulfill their job responsibilities. Our employees should demonstrate required sensitivity during use of aforementioned tools for personal purposes and try to minimize use them for personal purposes as much as possible.

1.3.11.  Our employees cannot make wrong use of the facilities provided by the company through violation or cannot prevent the rights of others to use them. Examples for these situations: Taking substances such as tea, coffee, sugar, toilet paper in common use, and allowing use of company facilities by third persons by ensuring their entrance into the company are prohibited.

1.3.12.  It is absolutely unacceptable that employees borrow money in a manner that undermines reputation and public image of Erciyes Anadolu Holding A.Ş. and borrow money from their subordinates.

1.4.   OPERATION RULES:

1.4.1.     Employees are responsible of using our telephone system in accordance with company policies and the laws, otherwise is not acceptable in any manner.

1.4.2.     Our employees are obliged to perform their tasks defined in their job definition in a manner not allowing even minimum errors.

1.4.3.     Our employees are responsible for following and complying with working hours planned and announced for them when necessary. Following situations related to the subject are not accepted as these will negatively affect planning processes of the company:

1.4.3.1.          Not coming to work during working hours without an excuse, coming late

1.4.3.2.          Changing working hours without approval of the manager and HR.

1.4.4.     Our employees are obliged to fulfill their tasks assigned to them. Failure to fulfill this obligation without just cause or deliberately is unacceptable. In cases where a task cannot be performed, the person who assigned that task must be informed with the reason.

1.4.5.     It is obligatory for employees of Erciyes Anadolu Holding A.Ş. to attend to meetings planned for them unless there is any mandatory situation. Our employees must attend to trainings based on calls. In case of absence in a training, it is required to make a written notification for excuse minimum one week before a meeting, and in case of absence due to a force majeure, it is required to notify it 1 hour before a training and it is required to make a written notification for valid excuse within following 24 hours. Otherwise, there will be a penal sanction. In case of appearing late, excuse should be notified to a senior manager half hour before training through a call, otherwise, there will be a penal sanction.

1.4.6.     Second/third persons who have knowledge about implementation violations made in the company, are obliged to inform their managers and/or relevant department about these violations. The manager is responsible for reporting this to the Development and Organizing Committee.

1.4.7.     . Employees who are employed in Erciyes Anadolu Holding A.Ş. as full time and contracted employees, cannot work in side words in return of a fee even in their leave periods, in all types of companies and commercial businesses, except social purposed aid organizations and foundations. In the case of consultancy or similar positions that require remuneration, it is required to obtain approval of Human Resources.  Employees that are employed by Erciyes Anadolu Holding A.Ş. as part-time contracted employees, cannot work for the company's competitors and in the same business branch as a paid employee.

1.4.8.     Our employees cannot falsify the official documents they prepare while fulfilling their duties. It is required to comply with the time and other restrictions specified by the relevant authority in preparation of official documents.

1.4.9.     Our employees are obliged to provide correct information, delivering wrong, misleading and exaggerated information cannot be accepted since it will prevent delivering correct message.

1.4.10.  All of our employees are obliged to attend all internal/external meetings determined and notified in advance and to comply with the meeting rules. In case of absence, an excuse notification should be delivered before meeting. Erciyes Anadolu Holding A.Ş. employees are responsible for arriving business meetings on time and leaving at scheduled time. It is excepted that employees organizing a meeting determine the agenda and write a report regarding discussed subjects and taken decision and publish these subjects and decisions. (See. Meeting Regulation)

1.4.11.  Employment and settlement policy:

1.4.11.1.       Erciyes Anadolu Holding A.Ş. cannot employ 1st degree relatives (spouse, sibling, child, mother, father, brother, sister, spouse) within the same company and/or the same department.

1.4.11.2.       In the event of marriage while working at Erciyes Anadolu Holding A.Ş., a department and/or company change is made for one of the spouses.

1.4.11.3.       Employees of Erciyes Anadolu Holding A.Ş. cannot request employment of any of their relatives and friends to any supplier company that they have business relationship due to their tasks in the company. In exceptional cases, the decision of the Board of Directors is required.

1.4.12.  The salary and position degrees of Erciyes Anadolu Holding A.Ş. employees are private and are not shared with third parties.

1.4.13.  The electronic media (technological software and hardware) cannot be used for transmitting publications making politic, religion, ethnic, philosophical discrimination or spreading thoughts which are against moral and dignity consisting information in following types in any manner, or cannot be used for accessing, storing, printing or converting such information into analogue/digital formats:

1.4.13.1.       Discriminatory, racist, pejorative publications targeting any person or group,

1.4.13.2.       Publications with a sexual or pornographic nature,

1.4.13.3.       Publications with political or ideological content or that may give impression that Erciyes Anadolu Holding A.Ş. is involved in any political or ideological association,

1.4.13.4.       E-mails that are encouraged to be sent to more than one person, named as “chain letter”,

1.4.13.5.       All kinds of illegal and threatening, provocative and offensive publications,

1.4.13.6.       Any statement or publication that is contrary to the company's policy or interests or that damages the public image of the company,

1.4.13.7.       Electronic gambling, betting type content that provides personal profit or gain,

1.4.13.8.       Offensive, immoral expressions,

1.4.13.9.       Comments in newspapers, electronic comments / participation in a survey.

1.5.   INFORMATION SECURITY PRINCIPLES

1.5.1.     Erciyes Anadolu Holding A.Ş. Employees are required to notify relevant department/persons regarding any suspicious situation or vulnerabilities and Information Security violations that have been created and/or will be created in the company.

1.5.2.     Erciyes Anadolu Holding A.Ş. employees are responsible for accuracy of all kinds of information and documents submitted to Erciyes Anadolu Holding A.Ş. during recruitment and selection.

1.5.3.     Erciyes Anadolu Holding A.Ş. aims to provide and use communication and information exchange facilities in electronic media with high technology software and hardware in order to provide the best service to its customers. Erciyes Anadolu Holding A.Ş., promotes use of these facilities and relevant resources (for instance; computers, electronic mail, telephone, facsimile, internet access, etc.) by its employees, however, these facilities provided as all other company resources should be used in a manner not allowing abuse, not for personal purposes, not in a manner preventing access for business purposes and access by mentioned systems.

1.5.4.     Physical security principles: Erciyes Anadolu Holding A.Ş. employees are not allowed to host personal visitors. In exceptional and compulsory cases, employees who receive visitors, may accept personal visitors only in the cafeteria or interview rooms after obtaining approval of relevant Department Manager. Erciyes Anadolu Holding A.Ş. employees are not allowed to take their personal visitors in the office. Unauthorized use of all kinds of audio and video recording devices in the workplace is prohibited. The employee is responsible for following-up this subject.

1.5.5.     Employees of Erciyes Anadolu Holding A.Ş. Avoid all types of behaviors that can threat physical/environmental safety of information processing and production ambients (PC, Laptop, Servers, etc., and offices where these are available).

1.5.6.     All kinds of equipment (PC, headphones, etc.) provided for use of Erciyes Anadolu Holding A.Ş. employees are used in accordance with the instructions given and in a manner undamaged.

1.6.   INFORMATION USAGE PRINCIPLE

1.6.1.     All information accessed by Erciyes Anadolu Holding A.Ş. employees during their service (financial information, customer information, etc.) and/or the documents are subjected to confidentiality principles and cannot be shares with third persons (except Erciyes Anadolu Holding and Affiliated Group Companies). It is unacceptable if employees act contrary to the principles of loyalty, confidentiality and non-competition.

1.6.2.      Erciyes Anadolu Holding A.Ş. employees cannot share information such as company targets, policies, and price information with third persons (except Erciyes Anadolu Holding and Affiliated Group Companies). Authority to make statements about financial and administrative subjects of Erciyes Anadolu Holding A.Ş. to be make with Public and Local organizations and Finance organizations, belongs to the persons determined by General Directorate by indicating limits for these statements. Our employees do not make sales and profit forecasts.

1.6.3.     Our employees should pay due care to ensure that all types of information and/or the documents that they use and access to fulfill their work, are not lost and that  accuracy or integrity of such information and/or the documents is not impaired.  (See. Confidentiality Contract) .

1.6.4.     The terms and conditions set out in the Confidentiality Contract are signed and acknowledged by all employees. Situations where the contrary occurs, are clearly stated in the regulation.

1.7.   USE OF ELECTRONIC MEDIA

1.7.1.     It is required to use all types of electronic media taken to the company by performing technical controls with the purpose of not affecting integrity, confidentiality and accessibility of the system in a negative manner.

1.7.2.     No electronic media and/or printed documents containing information and data other than for business purposes, may be taken out of the Company. In case that it is needed to remove them out of the company due to business requirements, it is obliged to obtain approval from a senior manager and obtaining this approval from the manager does not reduce responsibility of relevant employees.

1.7.3.     Electronic mail addresses given to employees by Erciyes Anadolu Holding A.Ş., are not personal e-mails, these e-mails belong to Erciyes Anadolu Holding A.Ş., they are used as tools ensuring easier and more productive works to be performed by employees. Company employees cannot use these e-mail addresses provided to them for personal purposes, i.e. in their private lives. Hence, when it is required, there is no legal or technical obstacle to monitor and to examine these mails Erciyes Anadolu Holding A.Ş., delivered through these tools where in-house communication is ensured. The Company records and stores the information in this respect. Employees are expected to use their e-mail addresses in accordance with company policies and the law.

1.7.4.     Messages sent by Erciyes Anadolu Holding A.Ş. employees to one or more persons over computer networks (e-mail, Internet, web-based mail) can be easily identified and attributed to Erciyes Anadolu Holding A.Ş. Almost all service providers and internet sites have required technology and tools to measure access made and most of them can identify from which company these are used and who used which service most. Therefore, all electronic communications by employees must comply with this and all other company policies and must not disclose proprietary and confidential information.

1.7.5.     Employees cannot share their passwords given to them with anyone, including their managers. They cannot attempt to access or access systems with passwords belonging to others. Sharing passwords and/or accessing them for use is considered an offense. It is a crime for both the person who gives the password and the person who uses it.

1.7.6.     The passwords given to our employees for all types of electronic media access during their period in Erciyes Anadolu Holding A.Ş., together with a user name in which they can change, are proprietary. Users' passwords are generated by applications or systems and stored in a way that cannot be read by others. Therefore, responsibility of storing user-specific passwords and responsibility of performing transactions through these passwords (application, operation, access to the internet, e-mail transmission) belong entirely to the password owner.

1.7.7.     Software installation to all systems within Erciyes Anadolu Holding A.Ş. is carried out only by Information Processing Service. Employees of Erciyes Anadolu Holding A.Ş., cannot install softwares ensuring sharing music, movie, picture, other files on the internet and distributing these.

1.8.   ORGANIZATION REPRESENTATION BEHAVIORS STANDARDS

1.8.1.     Making standard notifications in promotions of Erciyes Anadolu Holding A.Ş. for third party organizations and people and use of standard organization documents, should made in a manner that cause comments and speculations for the company and should not include direct or indirect expressions that can be against the services that the company presents.

1.8.2.     Attention should be paid in this regard where Erciyes Anadolu Holding A.Ş. is represented and it is required to pay attention to avoid attitudes and behaviors that can harm reputation of the company.

1.8.2.1.          Attention should also be paid in employment interviews and other interviews as well as followings;

1.8.2.2.          Meetings with existing-potential customers, telephone conversations,

1.8.2.3.          Orientation presentations,

1.8.2.4.          In relationships with suppliers

1.8.2.5.          In relationships with government offices

1.8.2.6.          In the process of communication with other official authorities (labor inspectors, tax inspectors, lawyers, judges, experts, etc.);

1.8.2.7.          While adhering to the given appointments and timings

1.8.2.8.          Avoiding excessive intimate behavior, following the rules of good manners, taking care to keep a certain distance,

1.8.2.9.          Paying attention to dressing style,

1.8.3.     In case that the company is represented, and situations in social activities collectively, it is required to avoid creating trouble and running wild.

1.8.4.     Use of Erciyes Anadolu Holding A.Ş. logo:  It is required to meet and obtain approval of Marketing and Advertisement Coordinatorship in publishing documents and selecting all types of ambients where the logo of Erciyes Anadolu Holding A.Ş. Will be used and it is required work in coordination with Marketing and Advertisement Coordinatorship with the purpose of ensuring standardization in all types of printed documents and promotion materials.

1.8.5.     It is required to have contact with Marketing and Advertisement Coordinatorship for all types of promotion documents (e-bulleting, brochure, etc.) planned to distribute in and out of the company.

1.8.6.     Written / Visual / Audio / Press Relations - Unauthorized Meetings with the Press: Relations with the written, visual, audio-visual and press are carried out by persons determined by the General Directorate. Statements to be made to all kinds of Public and Local organizations and Financial institutions, local issues or local reflections of corporate issues and statements to be made to third parties, are also handled in the same way.

1.8.7.     Media Requests: All types of requests received from media, should be accurately recorded (name of the caller, affiliated broadcasting organization, telephone number, subject, etc.) first of all and immediately be transferred to the Marketing and Advertising Coordinatorship. Interview requests and questions from all kinds of media organizations including television, radio, newspapers, magazines, local/national and commercial media and internet sites, should be notified to the Marketing and Advertising Coordinatorship in the same way. The Marketing and Advertisement Coordinatorship should respond on behalf of Erciyes Anadolu Holding A.Ş. in line with the company's approval or help to determine the appropriate person from Erciyes Anadolu Holding A.Ş. to respond.

1.9.   RELATIONSHIPS WITH SUPPLIERS AND CUSTOMERS

1.9.1.     Our employees cannot use their tasks and authorities given by the company in any way for personal or private benefit on behalf of themselves, their families or third parties; it is prohibited for them to enter into a close relationship with people or organizations that will benefit from the information that they have due to their job. Erciyes Anadolu Holding A.Ş. employees cannot obtain personal benefit from company operations, cannot use company property, information and positions for their own benefit, or cannot compete with the company. Erciyes Anadolu Holding A.Ş. employees and their relatives cannot be the owner or profit partner of a supplier or any competitor which the company has a direct business relationship. No employee with purchasing responsibilities can individually establish commercial relations in the relevant sector.

1.9.2.     Inappropriate Payments and Gifts:  Our employees cannot request any personal payment or gift from third parties doing business with the company.

1.9.3.     Acceptable Gift: Provided that it remains within the framework of honesty and good faith understanding, acceptance of certain gifts can be given only as to be subject to the following rules;

1.9.3.1.          Our employees cannot accept monetary payments in any form or amount, including instruments (such as gift vouchers, treasury bills, stocks, etc.) that can be converted to money.

1.9.3.2.          The gifts that are not in the form of monetary payment, are considered acceptable provided that their value does not exceed 100 TL and that they are not linked to any agreement regarding the company and that it is clear that they are not given to influence our employees on these positions.

1.9.3.3.          Our employees can participate in non-commercial activities traditionally organized by customers or organizations that we are customers of, provided that they remain within acceptable limits.

1.9.3.4.          It can be allowed that meals or other expenses that may be incurred during meetings where business matters are discussed and reviewed, are paid by customers or customers’ organisation.

1.9.3.5.          For gifts exceeding specified limits, contact should be made with the Development and Organizing Committee.

1.9.4.     Gifts to be given to customers: It should be ensured that the gifts to be given to the customers will not create a conflict of interest between the parties. In this line, the rules regarding the gifts to be given are determined below;

1.9.4.1.          No monetary payment is made in any form or amount.

1.9.4.2.          There should not be an intention to influence the other party when a gift is given, regarding any business or agreement in which the company is involved.

1.9.5.     Gifts to be given to State Officials: If it is intended to give a gift to a government official, consultation should be taken from Senior Management. Gifts may not be given to state officials the approval of the company authorities.

1.9.6.     Corporate payments and donations with political content: No organizational payment can be made to any state official or political party candidates in any way with the purpose of influencing any decision related to continuation of the activities of the organization or in favor of the organization.

1.9.7.     Regulations related to take loan: Employees of the organization may only loan money from legally authorized institutions and organizations.